National Energy Performance Strategy: consultation paper

Submission - National Energy Performance Strategy

Submission - National Energy Performance Strategy 1
Recommendations 2
Introduction and about the First Nations Clean Energy Network 3
The First Nations Clean Energy Network 3
The Energy System, First Nations housing and a NEPS 4
Addressing the policy, regulatory and financing barriers that prevent First Nations
households accessing solar solutions 6
How the NEPS can address some of these issues 7
The additional benefits of improving the quality of First Nations homes and providing access to
household renewable energy solutions 7
Recommendations
Recommendation 1 Once established, the NEPS should urgently:
● prioritise upgrades to improve the energy performance of
First Nations social and community housing
● establish minimum standards for energy performance for
rental properties nationwide to protect the health and
wellbeing of First Nations people most at risk from homes
with poor energy performance.

Recommendation 2 A national residential energy performance rating system and
mandates must be finalised and deployed.

Recommendation 3 Policy, regulatory and market responses should focus on reducing
barriers to realising the benefits of solar and battery solutions for
First Nations communities, particularly those living in public
housing using prepay, given the significant and demonstrable
positive impact on energy security and affordability provided by
solar in remote locations.

Recommendation 4 Reform of national energy laws and regulatory processes is
needed to focus attention on the specific circumstances of First
Nations people and communities operating under prepay
electricity supply metering and the opportunities presented for
innovative and collaborative policy and financing solutions to
support First Nations-led initiatives.

Recommendation 5 Identify policy and program opportunities to develop a First
Nations workforce equipped to undertake repairs and
maintenance of housing to required energy performance
standards.

Recommendation 6 Provide funding to undertake a comprehensive baseline study on
the current energy performance of all First Nations housing across
Australia so as to provide answers to the following questions:
● What would be the cost of retrofitting existing homes and
building new, energy-efficient housing infrastructure in
every First Nations community?
● What kinds of economic and social impacts can
investment in energy efficient First Nations housing
achieve across Australia?
● How much economic return (including in First Nations
jobs, businesses and improved health outcomes) can
investments in energy efficiency for First Nations housing
realise?

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Introduction and about the First Nations Clean Energy Network
The First Nations Clean Energy Network (FNCEN) welcomes the opportunity to provide a submission in response to the National Energy Performance Strategy Consultation paper and also welcomes the Federal Government’s commitment to developing a National Energy Performance
Strategy (NEPS).

Many of our First Nations communities - particularly those that are experiencing extreme temperatures as a result of climate change - don't currently have access to clean, affordable, reliable power; homes that are designed to cope with dangerous heat and extreme cold; or, the ability or means to access energy-efficient appliances. A NEPS can address these issues, and others, as set out in this submission.

In our communities, the FNCEN wants to see microgrids powered by community-owned renewable energy enterprises, where profits and reductions in bills are passed on to community residents, employment of local people, solar street lighting in the bush, and a system that clears the way through policy, regulatory and financial barriers to ensure public housing residents can also enjoy all the benefits (health, education, financial, cultural, etc.) that solar and battery solutions can provide.

Clean, reliable, affordable energy will help our communities on the frontline of climate change deal with more extreme temperatures and climatic conditions. Housing that is climate-safe, energy efficient, designed by communities, comfortable and which will support improved well-being and health outcomes is also essential and a key focus of this submission, given the role of safe, sustainable and secure housing in providing a place of shelter for families, and for so many health and wellbeing outcomes.

An effective NEPS is one way in which this can be delivered - to help cut energy bills, reduce pollution and emissions, improve standards of housing, create jobs and support improved health, education, economic and cultural outcomes for First Nations.

The First Nations Clean Energy Network
The FNCEN is made up of First Nations people, groups, community organisations, land councils, unions, academics, industry groups, technical advisors, legal experts, renewables companies and others - working in partnership to ensure that First Nations people, groups and communities are key participants in and share in the benefits of Australia’s rapid transition to clean energy. The
FNCEN is led by a Steering Group of First Nations leaders.

Australia’s rapid transition to renewable energy will require access to vast areas of land and waters, including for thousands of kilometres of new transmission infrastructure.

Enabling and empowering First Nations to play a key and central role in Australia’s renewable energy transition goes beyond just social licence issues - it presents a unique opportunity for
Australia to design an economic system around energy and renewable energy infrastructure developments (and upstream and downstream supply chains, including employment outcomes) that is fair and just and which can also positively impact and result in a range of other social and economic benefits for First Nations.

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The First Nations Clean Energy Network supports communities to address the barriers to clean, affordable and reliable power, securing good jobs and strong economies, so First Nations can have the choice to continue to live and work on Country.

As a national, First Nations-led coalition, the FNCEN aims to enable and empower First Nations to participate in, benefit from, respond to and shape an energy system in rapid transition as Australia rapidly transitions to renewable energy and seeks to meet legislated emissions reductions targets.

The FNCEN’s approach is built on three pillars:

1. Community The FNCEN supports First Nations communities address issues of
energy security and affordability, and to shape the design,
development and implementation of clean energy projects at every
scale

2. Industry The FNCEN acts as an innovation hub, promoting best practice
partnerships standards and principles that companies should adopt and investors
should require before committing capital to a clean energy project

3. Policy reform The FNCEN advocates to lift significant federal and state regulatory
barriers and stoke government investment, removing regulatory
barriers to energy security and clean energy generation

The Energy System, First Nations housing and a NEPS
Residential buildings are important for the transformation to a zero emissions energy system and homes and the quality of First Nations housing and their energy performance is a critical issue that must be addressed through the NEPS. Improving the energy performance of First Nations homes can also assist make significant gains to improve the health and wellbeing of First Nations and facilitate a range of other positive outcomes.

A large body of research exists about the state of First Nations housing across Australia,1 and the challenges unsustainable and poor housing creates for the health, safety, comfort and wellbeing of occupants.

Climate change and the more extreme weather events it will bring will exacerbate the poor quality of First Nations housing, particularly in remote and regional areas where many of our First Nations communities are on the frontline of a changing climate.

As noted in a recent report from the Kimberley Community Legal Service into the lived experiences of public housing tenants in the Kimberley during periods of extreme heat:2

1
See, e.g. Lea, T., Grealy, L., Moskos, M., Brambilla, A., King, S., Habibis, D., Benedict, R., Phibbs, P., Sun, C.
and Torzillo, P. (2021) Sustainable Indigenous housing in regional and remote Australia, AHURI Final Report
No. 368, Australian Housing and Urban Research Institute Limited, Melbourne, https://www.ahuri.edu.au/research/final-reports/368. See also AHURI’s research library on issues relating to
First Nations housing: https://www.ahuri.edu.au/research/research-library?theme=161 and the Australian
Institute of Health and Welfare: https://www.aihw.gov.au/reports/australias-welfare/indigenous-housing.
2
Kimberley Community Legal Services (2022), Stuck in the Heat: Lived Experiences of Public Housing
Tenants in the Kimberley,

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● Poor quality public housing, maintenance issues and overcrowding due to low housing stock
impacts the ability of public housing tenants to effectively control the temperature and
energy efficiency of their homes
● Public housing tenants in the Kimberley may experience energy poverty due to high energy
prices and the use of inefficient cooling appliances
● Exposure to high internal house temperatures may harmfully impact a householders’ health
and affect their ability to participate in their community
● The effects of a warming climate on the habitability of public housing in the Kimberley is a
pressing issue and appropriately designed policy to mitigate the effects of heat should be
prioritised.

This situation, described so starkly in that report (where energy costs, inefficient and poor quality housing, and the growing extremity of climatic events combine to create very challenging living conditions) is replicated across many remote and regional First Nations communities, with the impacts of energy insecurity3 and poor housing exacerbated by other policy, regulatory and financial barriers (which are often unique to First Nations communities).4

These unique policy, regulatory and financial barriers include the use of prepayment metering for electricity supply - which requires residents in a number of remote communities having to prepay for their electricity using “power cards”.5 If cards are not topped up, the power is disconnected, exposing residents to energy access challenges not encountered by energy consumers elsewhere https://static1.squarespace.com/static/56aae0e04d088e4dfa68396f/t/6385f2f85f679917d0fb7b2e/166972288
2386/Stuck+in+the+Heat+2022.pdf.

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The inability of households to secure a necessary level of energy service to meet basic energy needs.
4
See Riley, B., White, L., Longden, T., Quilty, S., Nabanunga, S., Jupurrurla, N. and Wilson, S. (2023),
Connected: Rooftop solar, prepay and reducing energy insecurity in remote Australia (forthcoming publication) and https://www.abc.net.au/news/2021-12-19/tennant-creek-rooftop-solar-nt-public-housing-norman-frank/100
710698 for a description of some of these barriers.
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Prepayment metering is an electricity supply arrangement restricted (and unique) in Australia to remote
First Nations communities - indeed, prepayment meters may not be permitted in other areas in jurisdictions.
See the following links for additional information on prepayment metering:
● QCOSS. 2014. ‘Empowering Remote Communities Experiences of Aboriginal and Torres Strait
Islander Customers Using Electricity Pre-Payment Meters in Queensland’.
● Longden, Thomas, Simon Quilty, Brad Riley, Lee v. White, Michael Klerck, Vanessa Napaltjari Davis,
and Norman Frank Jupurrurla. 2021. ‘Energy Insecurity during Temperature Extremes in Remote
Australia’. Nature Energy 7 (1): 43–54. https://doi.org/10.1038/s41560-021-00942-2.
● Quilty, Simon, Norman Frank Jupurrurla, Ross S Bailie, and Russell L Gruen. 2022. ‘Climate, Housing,
Energy and Indigenous Health: A Call to Action’. Medical Journal of Australia 217 (1): 9–12.
https://doi.org/10.5694/mja2.51610
● Riley, B. 2020. ‘Energy Security on Remote Aboriginal Communities during the COVID-19 Crisis’. In
Indigenous Australians and the COVID-19 Crisis: Perspectives on Public Policy Edited by Markham, F.,
Smith, D. and Morphy, F., no. CAEPR Topical Issue 1/20: 24–26
● ABC (2021), Finally, dangerous power cuts are in the past for NT's first public housing tenant with
rooftop solar,
https://www.abc.net.au/news/2021-12-19/tennant-creek-rooftop-solar-nt-public-housing-norman-f
rank/100710698

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in Australia’s energy system.6 This vulnerability to disconnection is compounded by the absence of consumer protections that exist in mainstream parts of Australia’s electricity networks.

And because many First Nations households are often renting,7 as tenants they will have little control over efficiency improvements such as insulation, or heating or cooling, and which can make the biggest difference to costs and comfort.

Cheaply deployed solutions to address poor quality housing are typically energy inefficient, expensive to run and amplify electricity use. And because of remoteness and other issues, for First
Nations communities, existing disincentives to investment by landlords (including by governments) in upgrades to rental properties are magnified.8

This situation - of low quality poorly insulated, energy inefficient housing, energy instability and insecurity (because of the cost of power and prevalence of disconnections if credit runs low on prepaid meters) and extreme temperatures - of course has a direct impact on health and wellbeing, particularly for First Nations with chronic diseases who depend on cool storage for medications and electrical equipment.9

Addressing the policy, regulatory and financing barriers that prevent First Nations households accessing solar solutions
Although the challenges with energy performance of First Nations housing described above are experienced across Australia, in a twist of irony, often many of the challenges outlined above exist particularly for First Nations people and communities living on lands host to some of the best solar resources in the world.10

In these locations, upfront capital costs, combined with an absence of local regulations codifying the ability for residents of social housing to connect solar to prepay metering locks many of these

6
See https://www.anu.edu.au/news/all-news/power%C2%A0disconnections%C2%A0put-first-nations%C2%A0pe ople-at-risk.
7
68% of First Nations adults are renters (34% living in social housing and 34% living in private rental arrangements or renting from some other type of landlord in urban and regional areas), while in remote and very remote areas, 89% of First Nations adults rent, with 71% in social housing - see https://www.aihw.gov.au/reports/australias-welfare/indigenous-housing.
8
See, e.g. ‘NT Supreme Court finds public housing tenants in Santa Teresa entitled to reasonable ‘reasonable comfort’’, https://www.abc.net.au/news/2022-02-04/nt-supreme-court-finds-for-santa-teresa-public-housing-tenants/
100804718.
9
See, e.g. ‘Northern Territory electricity retailer Jacana overhauls processes after disconnecting life support customer’, https://www.abc.net.au/news/2022-12-07/nt-jacana-electricity-retailer-disconnects-life-support/101739426, and Quilty, Simon, Norman Frank Jupurrurla, Ross S Bailie, and Russell L Gruen. 2022. ‘Climate, Housing,
Energy and Indigenous Health: A Call to Action’. Medical Journal of Australia 217 (1): 9–12.
https://doi.org/10.5694/mja2.51610.
10
Riley, B., White, L., Longden, T., Quilty, S., Nabanunga, S., Jupurrurla, N. and Wilson, S. (2023), Connected:
Rooftop solar, prepay and reducing energy insecurity in remote Australia (forthcoming publication).

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First Nations households out from realising the benefits (health, education, economic and cultural) associated with solar and battery solutions.11

As noted in a forthcoming publication focusing on the experiences of co-authors Serena Morton
Nabanunga and Norman Frank Jupurrurla, in the remote northern town of Warumungu (Tennant
Creek), these barriers were overcome in a significant trial supported by the First Nations-led organisation Original Power.12 As was demonstrated in this trial, access to rooftop solar reduced household electricity expenditure by almost $150 per month, and helped alleviate frequent exposure to household energy insecurity, as well as bringing multiple other benefits.

How the NEPS can address some of these issues
In addition to addressing issues particular to remote First Nations residents who receive energy supply via prepay metering systems to access solar, a well-designed, inclusive and fair NEPS has the potential to address a range of issues relating to poor quality housing through initiatives (some of which are already underway), such as:

● the Greenhouse and Energy Minimum Standards (GEMS)
● raising minimum energy efficiency requirements under the Nationwide House Energy
Rating Scheme (NatHERS) star ratings system
● expanding the National Australian Built Environment Rating System (NABERS), and
● developing a national framework for mandatory energy efficiency rental standards.

Cutting waste by improving efficiency is one of the quickest, most cost-effective ways to reduce emissions and to help meet the Government’s national emissions reductions targets.

Accordingly, for Governments there is undoubtedly a significant value proposition in making First
Nations homes energy efficient, safe, sustainable, and healthy through focused attention in the
NEPS, as this will catalyse a range of beneficial cultural, health, economic and education outcomes for First Nations.

The additional benefits of improving the quality of First Nations homes and providing access to household renewable energy solutions
Retrofitting existing homes and building new, safe, sustainable and energy-efficient housing infrastructure in First Nations communities will undoubtedly result in a range of important health, cultural wellbeing, economic and social outcomes - and will reduce emissions and pollution.

A report produced by the First Nations Clean Energy Network’s sister organisation in Canada13 presents the significant value proposition in financing energy efficient homes in Indigenous communities across Canada (to address poor housing quality, and a range of health, social,

11
Ibid. See also https://www.abc.net.au/news/2021-12-19/tennant-creek-rooftop-solar-nt-public-housing-norman-frank/100
710698.
12
See https://www.originalpower.org.au/energy_justice. Original Power continues to work on these policy, regulatory and financing barriers and is presently undertaking a project to identify pathways to deploy solar on social housing across the Northern Territory.
13
See Energy Foundations: The Value Proposition for Financing Energy Efficient Homes in Indigenous
Communities Canada-Wide, https://d2y5h3osumboay.cloudfront.net/sef2yhs0cny36m9288e7zklo9o8c

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economic and cultural challenges caused by energy insecurity and energy affordability). The report notes that although the total cost of the upgrading and retrofitting would be capital intensive upfront, the investment in energy efficiency yielded:

● significant direct economic impacts creating 47,000 FTE jobs, $1 billion in household
expenditure savings over 10 years, and $11 billion in asset enhancement
● major indirect and induced impacts including 26,000 additional secondary jobs, avoiding
an estimated 5 million tCO2e of GHG emissions over 10 years, and important health
outcomes for community members.

The message emerging from this report overwhelmingly support urgent action to address energy efficiency issues in First Nations housing, finding that to do so will:

● reduce household emissions
● improving quality of life and wellbeing
● create jobs, business opportunities and other beneficial economic and financial outcomes.

This of course links to the workforce issue mentioned in the NEPS consultation paper, and a range of policy priorities for all governments across Australia.

For First Nations communities, retrofitting, upgrading and new builds to establish energy-efficient
First Nations housing will require local people with existing cultural and linguistic skills and connections to communities to be trained and employed to carry out and maintain the standards of housing required - creating the potential for locally-held, community-based jobs. Similarly, investment in energy efficiency upgrades will create business and supply opportunities including to small- to medium-sized businesses and community organisations, covering a range of trade, service and manufacturing organisations.

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