Tasmanian Housing Strategy Submission
View the TCC submission on this topic.
About the Tasmanian Climate Collective
The Tasmanian Climate Collective is a group of passionate and committed organisations and individuals from across Tasmania who advocate for strong action on climate change. The Collective is made up of climate change, social and environmental groups and grassroots organisations. The Tasmanian Climate Collective has no political affiliation and is composed of scientists, farmers, doctors, teachers, nurses and other concerned citizens calling for more action on climate change.
OUR VISION
lutruwita Tasmania is a world leader on climate action, prioritising environment and people.
OUR PURPOSE
Tasmanian Climate Collective connects groups and individuals to encourage, promote and initiate climate action across lutruwita Tasmania through cooperation, influence and knowledge sharing.
The Tasmanian Climate Collective appreciates the opportunity to contribute to the Tasmanian Housing Strategy discussion. Our particular interest in the Strategy is to strongly encourage all new social and affordable housing and private builds to include climate mitigation and adaptation measures. Therefore this submission focuses on Questions 17-20 in Focus Area 3 - Sustainability.
The Tasmanian Climate Collective strongly supports the Tasmanian Housing Strategy objective for “improved sustainability of housing into the future”, including that:
Homes are more energy efficient.
Homes are more adaptable to changing energy sources.
Homes are more resilient to a changing environment.
Homes better meet the needs of generations into the future.
It is critical that the transition to a low carbon future is accessible to everyone, regardless of their socioeconomic status. The benefits gained from renewable energy efficiencies and protection from the extreme effects of climate change must not be limited to the wealthy in society.
The Tasmanian Housing Strategy’s vision that “Every Tasmanian has access to safe and affordable housing” can be achieved by prioritising energy efficient and electrified housing with rooftop solar and energy storage. Housing without these attributes commits residents to escalating and unaffordable energy costs every year for the life of the dwelling.
The Tasmanian Housing Strategy must include social, affordable and private housing that:
Is energy efficient
Protects residents from energy poverty and stress
Does not include gas connections or appliances
Facilitates zero emissions transport options eg. EV charging points
Uses low emissions materials and supply chains
Is climate resilient
Minimises or offsets land clearing
Question 17: What actions are needed to improve sustainability of housing?
Tasmania is part of the national grid and the sustainability of Tasmanian housing must be considered in that context. It is not reasonable for Tasmania to claim 100% renewable electricity since we are part of the single national grid that uses a mix of fossil fuel generated electricity as well as increasing amounts of renewable electricity. Energy savings in Tasmania count as much as energy savings in other states, in terms of emissions reduction.
All future new homes need to be built for a net zero emissions future. Housing stock lasts for many decades and must meet the higher standards that will be expected in the very near future. This is the greatest priority to meet the Tasmanian Housing Strategy objective that “Homes better meet the needs of generations into the future.” As other parts of Australia move towards net zero emissions homes, Tasmania can make use of our natural advantage (renewable energy) and become the leading state by adopting net zero emission homes as part of the Tasmanian Housing Strategy.
Now that Australia accepts the need to urgently decarbonise, the term “sustainable” is being applied to many areas with a wide range of variation in their actual sustainability. Much greenwashing is being exposed and the general public are becoming more educated and intolerant of this. It is important that the long term Tasmanian Housing Strategy is genuinely committed to robust sustainability so that it can withstand public scrutiny for years to come.
If we continue to build new homes with poor energy efficiencies and old technologies, we would be committing to higher carbon emissions and higher energy costs for residents for many years to come. We must learn the lessons of previous low quality construction and embrace the existing energy efficient technologies to give Tasmanians energy efficient, net zero emissions housing befitting a clean green state in a developed country. To do anything less would be a waste of public funds.
The Climate Change (State Action) Amendment Bill 2021 is weak and fails to set sector targets and an overall target beyond the net zero that has already been achieved. The Tasmanian Housing Strategy should expect to go beyond this unambitious legislation, since it will necessarily be strengthened at a later date.
Energy Efficient Homes to Net Zero Homes
The National Construction Code now mandates the Nationwide House Energy Rating Scheme (NatHERS) energy rating of 7 in all parts of Australia, except Tasmania, where the lower rating of 6 will persist until 2025 (1). The Tasmanian Housing Strategy must adopt the NatHERS rating of 7 immediately. Energy efficiency matters in Tasmania, since we are part of the national grid and therefore use coal/gas generated power at times.
The Tasmanian Housing Strategy should ensure that from 2030, all new housing will be net zero through a combination of built-in measures like good insulation and all-electric appliances. With our renewable electricity supply, this is a reasonable expectation in a world that is rapidly decarbonising.
Cut energy bills for residents
Tasmanian residents consume more electricity than residents in other states. The average Tasmanian household consumed 7666kWh in 2021 (2). It is crucial that all new public and affordable housing initiatives provide the most efficient and cost effective energy supplies to allow residents to enjoy the cost savings that many private home owners are finding after transitioning to electrification. As stated in the discussion paper: “Changing the source or type of energy supply to housing can result in long-term savings for homeowners and tenants”.
New public housing should include rooftop solar PV and home or community batteries for the following reasons:
Homes built now need to be future proofed to ensure that residents do not suffer energy poverty over coming decades.
Rooftop solar PV is already the cheapest form of energy in Tasmania at 13 cents/kWh compared with 27 cents/kWh (3). This trend is likely to continue as the cost of rooftop solar panels continues to fall. Residents of public housing must be able to enjoy these cost savings as much as private home owners.
Residents with reduced energy costs are more able to pay their rent and food needs, and are less likely to suffer “housing stress”.
Energy poverty and high cost of living leads to poor outcomes in resident physical and mental health, as noted in the Tasmanian Housing strategy discussion paper. The investment in solar and batteries for residents at risk of energy poverty will therefore have substantial savings to the Tasmanian health system as well as the public good of better health outcomes.
It meets the Tasmanian Housing Strategy objective for homes that are more adaptable to changing energy sources.
It is far more cost effective to install rooftop solar during construction, rather than retrofit at a later date.
Community or home batteries for public housing will allow residents to store their solar power for use at peak times in the evening. This is a large cost saving for residents.
Hydroelectricity supplies are vulnerable to reduced rainfall under climate change and this risk will continue to increase with each degree of warming (4). Rooftop solar on homes will help to reduce the demand for hydroelectricity and benefit the grid and the broader Tasmanian community
Rooftop solar in Tasmania contributes to the decarbonisation of the national grid
Climate Resilient Housing
The Tasmanian Climate Collective supports the ambitions listed under “Homes are more resilient to changing environments” in the discussion paper. It is important that these are detailed in guidelines that are closely followed by all. Insurance premiums will only be moderated by building robust housing which can better withstand the impact of extreme weather events resulting from climate change.
Measures to make housing more resilient to climate change include:
Rooftop solar combined with battery storage will make homes more resilient in blackouts that occur in extreme weather events.
Insulation, including double glazing and design features that moderate temperature extremes for the health and well-being of residents
Housing should be located away from flood and bushfire risks and other areas that could be deemed “uninsurable”.
Water tanks should be included in all new builds to allow residents to access clean water during supply and contamination problems associated with extreme weather events.
No gas in new builds
It is important that the Tasmanian Housing Strategy specifies that no new housing may include gas infrastructure. Gas is a fossil fuel and as such, no gas appliances or infrastructure should be installed in any new housing. As other states are currently winding back their gas use and infrastructure, Tasmania is in a good position, since we have historically not used much gas in domestic housing.
Zero emissions constructions
Tasmania’s net zero status is largely due to the reduction in the Land Use, Land Use Change and Forestry (LULUCF). The benefit of this offset will reduce in coming decades and could disappear quickly with a large bushfire event. It is crucial that other sectors of the Tasmanian economy, including housing construction, reduce carbon emissions to maintain our net zero status.
Question 18: What Government assistance programs could help young people and people with changed life circumstances access affordable home ownership?
Young people today face the combined threats of climate change and Tasmania’s unprecedented housing affordability crisis. It is hard to overstate the seriousness of their situation. As stated by Justice Bromberg in Sharma vs Minister for the Environment (May 2021, FCA 560)
“It is difficult to characterise in a single phrase the devastation that the plausible evidence presented in this proceeding forecasts for the Children. As Australian adults know their country, Australia will be lost and the World as we know it gone as well. The physical environment will be harsher, far more extreme and devastatingly brutal when angry. As for the human experience – quality of life, opportunities to partake in nature’s treasures, the capacity to grow and prosper – all will be greatly diminished. Lives will be cut short. Trauma will be far more common and good health harder to hold and maintain. None of this will be the fault of nature itself. It will largely be inflicted by the inaction of this generation of adults, in what might fairly be described as the greatest inter-generational injustice ever inflicted by one generation of humans upon the next. To say that the Children are vulnerable is to understate their predicament.”
As all levels of government adopt climate mitigation measures, so too we need to adopt housing affordability measures. Housing affordability is more than just the initial purchase cost of a home - it includes the cost of living and maintaining that home, ongoing. It is therefore crucial that the extra costs of building a truly sustainable home are subsidised through measures such a no-interest loans and rebates for energy efficient items, rooftop solar PV and energy storage systems (home/community batteries or bi-directional electric vehicle connections)
Question 19: What can be done to improve the energy efficiency of existing and new homes?
We have detailed some energy efficiency measures for new homes in our response to Question 17 above. Further measures should include:
Expand and continue the No Interest Loan Schemes for energy efficient refits and appliances for new and existing dwellings. At a time when we need more households to reduce their carbon emissions, there is an increased proportion of income spent on repayments and cost of living expenses. This leaves less disposable income to purchase energy saving items such as rooftop solar, double glazing, home batteries and electric vehicles. No interest loan schemes can assist households meet these costs while they benefit from the savings. This is an important contribution to increasing the sustainability of Tasmanian housing.
Mandate the installation of energy efficient appliances in all new builds
Ban new gas appliances and infrastructure for new and existing builds
Ban electric resistance hot water heaters for all new builds, consistent with other Australian states
Include outdoor clothes drying areas in all new builds to minimise electric drying and reduce indoor condensation.
Question 20: What else can be done by stakeholders to improve sustainability?
Landlord incentives
Introduce incentives and mandated requirements for landlords to install energy efficient appliances, rooftop solar, household batteries and electric vehicle charging ports. Tenants with reduced energy costs are more able to pay their rent with lower financial stress.
Bi-directional storage
The transition to battery electric vehicles with bi-directional storage is likely to resolve the problem of insufficient grid level storage throughout Australia – 20 million cars with 60kWh batteries grid connected for the 97% of the time they are not actually driving can provide 3 times the storage we need for 100% renewable energy. The transition to BEV’s will happen early in the life of the buildings being approved now so should be anticipated in the Tasmanian Housing Strategy.
Access to cost efficient, low emissions transport
New social, affordable and private housing should have easy access to low emissions transport options including:
Public transport
Active transport - bike paths, footpaths, road cycleways, etc.
Private electric transport - new builds must facilitate electric vehicle charging such as power outlets at each carpark and dedicated electric circuits future-proofed for bi-directional battery electric vehicle charging/storage.
References
National Construction Code Updates Mean Energy Efficiency Ratings Expansion for New Residences 2022
AEMC Residential Energy Price Trends 2021 https://www.aemc.gov.au/sites/default/files/2021-11/2021_residential_electricity_price_trends_slide_pack.pdf
Australian Energy Council, Solar Report Quarter 1 2021
https://www.energycouncil.com.au/media/w4pjs1xf/australian-energy-council-solar-report_q1-2021.pdfImpacts and Opportunities for Tasmania, Climate Council 2014
https://www.climatecouncil.org.au/resources/impacts-and-opportunities-for-tasmania/
1 September 2022