Edge Environment Response to the Draft National Building Energy Standard-Setting, Assessment and Rating Framework

In July 2009, the Council of Australian Governments (COAG) agreed to the National Strategy on Energy Efficiency (NSEE), which is designed to substantially improve the levels of energy efficiency across the Australian economy. Measure 3.1.1 of the NSEE requires all jurisdictions to work together to develop a consistent, outcomes-based national building energy standard-setting, assessment and rating framework (the Framework) for driving significant improvement in the energy efficiency (and potentially other environmental elements) of Australia’s building stock.

The draft Framework was developed for consultation by the Framework Subgroup of the Senior Officials Group on Energy Efficiency (SOG-EE). The Select Council on Climate Change (SCCC), established in January 2012, has taken over responsibility for further development of the Framework. This work will be managed by the SCCC Energy Efficiency Working Group (E2WG). Following consultation, the E2WG will recommend a draft Framework to SCCC. In turn, SCCC will forward the Framework to COAG for approval.

Edge Environment Response to: Draft National Building Energy Standard-Setting, Assessment and Rating Framework

(Click here to download the full response)

Edge Environment believe that it is only the final objectives of energy efficiency and environmental impact that should be addressed by the Framework and disagree with the principle that the Framework should recognise “differences in relative effort required to achieve acceptable human comfort conditions in different climate zones”. This principle creates perverse outcomes and leniency in the climate zones with the biggest impact, where we should expect and demand the greatest stringency.

Edge Environment agree that the “approaches adopted should be reviewed on a regular basis to ensure they remain relevant and effective.” Equally though this should not be too regular otherwise this would defeat the objective to “enhance the ability of industry to plan ahead and develop innovative, practical and cost-effective energy efficiency solutions, which will also lower compliance costs for households and businesses;

Edge Environment agree that broader efforts are needed to reduce carbon emissions and particularly to adapt to predicted future climate conditions and more extreme weather events.

 

 

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