A key lobby group representing builders in Queensland has raised concern about changes which are proposed to be enacted in the National Construction Code (NCC) across Australia and also in Queensland specifically.

In its latest statement, Master Builders Association of Queensland said it had raised concerns about the proposed introduction of new requirements for accessible housing and energy efficiency which have been included in the public comment draft for the 2022 update to the National Construction Code (NCC 2022).

Master Builders Deputy CEO Paul Bidwell said his organisation was advocating at both state and national level to address concerns associated with the new requirements before they come into effect.

“Without addressing some very real concerns, these changes could not only introduce increased costs that neither builder nor consumers can afford but make little difference to those they are designed to help,” he said.

“We’re working at both state and national levels to get a clearer picture on the anticipated mandatory changes. We need to ensure the changes are practical and have a positive impact, as well as providing our industry more time to prepare.”

As part of a desire to improve the suitability of Australia’s housing stock for people of varying ages and physical abilities and to ensure that new homes are delivered in a way which supports Australia’s climate objectives, new requirements regarding the accessibility and energy efficiency of newly constructed homes have been included in the public comment draft of NCC 2022.

On accessibility, the proposed changes introduce minimum requirements into the code for the first time.

Under the draft requirements, newly constructed homes will need to be designed and constructed in such a way as to meet the Silver standard outlined in the Liveable Housing Design Guidelines (LHDG) which are published by Liveable Housing Australia (LHA).

At a broad level, this will require new homes to have:

• Step-free access from street and parking areas
• at least one step-free entrance into the dwelling
• internal doors and corridors that facilitate easy access
• a ground floor toilet
• a step-free shower
• reinforced bathroom walls to support grabrail installation; and
• a continuous handrail on stairs.

Broadly speaking, the inclusion of these requirements in the Code has been welcomed by access consultants, who say that Australia needs to deliver new homes which remain suitable for Australians as they go through various stages of their lives.

Voluntary adoption of the requirements, proponents argue, is not adequate due to the low levels of take-up – a 2014 estimate from Liveable Housing Australia indicated that less than five percent of newly constructed homes were meeting the LHDG Silver standard – the most basic standard which can be achieved under the guidelines.

However, Master Builders Queensland has raised concerns about the draft changes in several areas.

In particular, Master Builders is concerned that that:

• There is a lack of detailed solutions which show how to comply with the requirements. This is important as aspects of the accessibility requirements may potentially conflict with other requirements for drainage, weatherproofing, termites and energy efficiency. As a result, bespoke solutions will be required for each and every home. All up, this could add up to $1,800 to the cost of each home. This is a particular problem for the requirements relating to dwelling entrances and step-free building access, Master Builders says.
• Definitions for several terms are vague and are subject to interpretation. This includes definitions for terms such as ‘community’, ‘older’, ‘easy to enter/navigate’ (for whom and/or what?), ‘safe’ and ‘unobstructed’.
• A lack of tolerances. Whilst it is usual practice to allow a degree of tolerances to allow for on-site variances (For example, a timber frame surface may be out by up to 4 mm and still be compliant under the Queensland Building and Construction Commission Standards and Tolerances Guide), Master Builders says the accessible housing requirements fail to allow for this. For example, the requirements will mean that any hallway which is even a millimetre less than the 1,000 mm required would fail to be compliant and would mean that the entire home would be unable to be approved for occupancy.
• Some requirements will reduce flexibility for homebuyers. Under the new draft requirements, thresholds regarding levelling will need to be achieved at both the dwelling entrance and in key living areas. These requirements will need to be met in order for an occupancy certificate to be issued. For homeowners, this will require them to include items such as floor coverings and landscaping for entrance paths in the build contract and will remove any flexibility for them to delay this work if their budget does not allow for this.
• Exemptions should be provided to cover significant renovations, conflicts with town planning requirements, small sites and small dwellings, small dwellings and sites, and apartments which are not on the ground and are not accessed via lifts. During renovations, for example, meeting larger dimensions required by the new requirements may not be possible, Mast Builders argues. In addition, smaller dwellings and sites are important for housing affordability but will require compromises to allow for the larger dimensions which are needed under the new requirements.

In addition to these concerns, Master Builders Queensland is also seeking a three-year transition period along with a comprehensive implementation guide and consumer awareness campaign.

The transition period will enable project home builders to adjust their standard plans without placing undue pressure on the availability of designers, quantity surveyors and marketing personnel, Master Builders argues.

Meanwhile, the implementation guide would provide detailed guidance for builders, designers, manufacturers and trade contractors whilst a consumer awareness campaign would see governments explain the new requirements and their consequences (e.g., that living area sizes will need to be smaller to allow for larger toilets or wider hallways) rather than this being left up to builders.

Aside from accessible housing, Master Builders is also concerned about changes to the energy efficiency.

The first such change would increase the level of stringency to which new homes are required to be constructed in terms of energy efficiency from six stars under the NatHERS energy rating scheme to 7 stars.

This change has been incorporated into the Public Comment Draft for NCC 2022 and is proposed to be implemented nationally across all states and territories.

The changes follow an agreement at the Building Ministers Meeting in 2018 for Australia to adopt a trajectory which would eventually see the carbon emissions of newly constructed homes and commercial buildings fall to net zero by 2050.

As part of that agreement, Ministers agreed to implement a substantial increase to the level of stringency required under the Code for commercial buildings in NCC 2019 and for residential buildings in NCC 2022.

The changes are supported by groups such as the Australian Sustainable Built Environment Council, who say that the trajectory toward net zero is necessary in order to meet Australia’s climate change commitments and to ensure that Australians are able to live in comfortable homes which are less costly to heat and cool.

Whilst stressing that Master Builders supports the need for Australians to be able to live in homes which are energy efficient, however, Bidwell says the government’s own numbers show that costs associated with the change outweighed the benefits involved.

Bidwell says the changes would deliver a net cost to Queensland of around $330 million each year.

(A Consultation Regulation Impact Statement which was prepared in respect of the changes concluded that the overall costs associated with the increase in stringency would exceed the benefits derived to the tune of $1.795 billion to $2.366 billion nationally.)

In addition to the national changes, Bidwell is also concerned about the removal of several credits and exemptions in Queensland which currently exist under the state’s Queensland Development Code (QDC).

Since 2010, the QDC has allowed optional credits for outdoor living area/ceiling fans and photovoltaic solar when meeting the current 6-star energy efficiency requirements. The QDC also provides reduced glazing requirements and an exemption for insulation under suspended floors in climate zones 1 and 2 – which can be found in Tropical North Queensland and in the Queensland interior.

Under the changes, however, the Queensland Government intends to remove these credits and exemptions.

Speaking of both of the changes referred to above, Bidwell says concerns need to be addressed.

“When it comes to updating the NCC, it’s essential we get it right the first time. As the old building adage goes, measure twice, cut once,” he said.