Submission to the Department of Infrastructure, Planning and Logistics
Australian Institute of Architects is the peak body for the architectural profession in Australia, representing around 11,000 members. The Institute works to improve our built environment by promoting quality, responsible, sustainable design. Architecture influences all aspects of the built environment and brings together the arts, environmental awareness, sciences and technology. By combining creative design with technical knowledge, architects create the physical environment in which people live, which in turn, influences quality of life. Through its members, the Institute plays a major role in shaping Australia’s future.
As a distinct profession, architects can and do offer services that directly impact on public health and safety issues and quality issues affecting buildings. The Institute’s Code of Conduct expects architects to ‘improve standards of health and safety for the protection and welfare of all members of the community.’ This is an important distinction, beyond the basics of safety, and it is not just to serve interests of the client, the developer or the financial institution, but everyone.
The Institute welcomes the opportunity to make a submission to the Department of Infrastructure, Planning and Logistics. The comments below relate to the following:
The National Construction Code (NCC) Volume One Section J establishes performance requirements for commercial building energy efficiency. The NCC Section J has not been adopted in the Northern Territory and so commercial buildings and the common areas of apartment buildings do not need to meet these energy efficiency performance requirements. The Northern Territory Government is asking industry its views on what the impacts would be if the NCC Section J were to be adopted in the Northern Territory for new commercial buildings including the common areas of apartment buildings.
Components of NCC Section J include: Energy Efficiency; Building Fabric; Building Sealing; Air-conditioning and ventilation systems; Artificial lighting and power; Heated water supply and swimming pool and spa pool plant; Facilities for energy monitoring.
The assessment of the energy efficiency of buildings should not adversely affect the performance of other aspects of a building. No decision has been made by the Northern Territory Government about adopting Section J at this stage -this is a scoping consultation so that Government can gain a better understanding from industry.
The Government needs to consider each component of NCC Section J and would like your views on any of the following:
- Industry readiness to adopt
- Implications and impacts to industry
- Benefits to industry and the consumer
- Costs to industry and the consumer
- Risks of not adopting Section J
- If there are prohibitive reasons to not adopt NCC Section J
- Processes that would need to be put into place to adopt Section J.
SUMMARY OF POSITION
The NCC Vol 1 section J states that “A building, including its services, must have, to the degree necessary, features that facilitate the efficient use of energy appropriate to…”
However,in the NT, for a Class 2 building and a Class 4 part of a building, Section Jis replaced with Section J of BCA 2009.In addition, Section Jdoes not apply to Class 3 and 5 -9 buildings.
In NCC, Vol I Section J energy efficiency of buildings may be demonstrated through performance modelling or satisfying deemed-to-satisfy provisions.
The Decision Regulation Impact Statement Energy Efficiency of Commercial Buildings showed there was overall a positive benefit/cost ratio if Section J was a mandatory requirement in the NT.
The construction industry in the Territory is able to adopt the NCC Section J provisions, given that only a small amount of change to existing practices is required. However, there is a reluctance to do so. Because there is reluctance, does not mean that industry can’t, won’t or shouldn’t adopt the NCC Section J.To quote Dr Sorada Tapsuwan, “Legislation is the key to pushing populations and market forces to better outcomes”.
Recommendations
The Institute recommends that:
- The Northern Territory government support the Council of Australian Governments (COAG) Energy Council’s National Energy Productivity Plan and Trajectory for Low Energy Buildings (Commercial buildings).
- NCC Section J be adopted as a whole in the NT.