Builders in Victoria have joined those in other states in raising concern about proposed changes to the National Construction Code (NCC).

In its latest announcement, the Master Builders Association of Victoria (MBV) has expressed concern about proposed changes to the Code which would introduce new mandatory requirements for accessible housing and would require new homes to meet 7-star energy rating standards.

Master Builders said concerns about the changes need to be addressed.

“MBV acknowledges that future provisions are needed for people as they age or have a disability to ensure there is sustainable and suitable housing stock into the future,” the organisation said.

“But the benefits will not be realised if the changes are not introduced properly.”

As part of efforts to ensure that housing stock of the future is both suitable for older Australians and those with disabilities and responds our need to address climate change, the 2022 update of the National Construction Code (NCC 2022) contains proposed amendments in respect of accessible housing and energy efficiency.

In terms of accessible housing, the Public Comment Draft of the Code introduces new mandatory provisions which would require new homes to meet the standard required for Silver level certification under the Liveable Housing Design Guidelines which are maintained by Liveable Housing Australia.

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.

Proponents of the new requirements argue that the changes are necessary to ensure that new homes cater for those of varying physical abilities and Australians at various stages of their lives.

Making the requirements mandatory, they argue, is necessary as uptake of accessibility features on a voluntary basis has thus far been limited. A 2014 estimate from Liveable Housing Australia indicated that less than five percent of newly constructed homes were meeting the basic LHDG Silver standard.

Builders, however, are concerned about practical aspects of the requirements.

In Queensland, for example, the Master Builders Association in that state has raised concern about a lack of detailed solutions to show how to comply with the requirements, vague and unclear definitions, a lack of allowance for tolerances, reductions in flexibility for home buyers and the need for exemptions in several areas (refer link).

In Victoria, Master Builders has raised concern that the current drafting of the proposed changes may create conflict with other design aspects of a home and will add to the cost of new home delivery.

Master Builders has also raised concern that the changes have not been accompanied by testing to ensure that the requirements will be effective and will generate a net benefit.

On this score, it points out that a Decision Regulation Impact Statement prepared in 2021 which concluded that costs associated with including mandatory requirements in the NCC based on either LHDG Silver, Gold or Gold plus standards were found to outweigh the benefits for any of the options considered.

Rather than being mandated, Master Builders says accessible housing requirements should remain voluntary.

As for the limited take-up, it says adoption of accessible features could instead be broadened by having the proposed requirements included within the NCC as a voluntary tool.

Should the requirements indeed be mandated, it agrees with its Queensland counterpart that a transition period should apply.

This would allow for training and for new display homes to be built.

It would also like the Victorian Government to invest in a campaign of consumer awareness.

On energy efficiency, meanwhile, proposed changes in NCC 2022 will mean that new homes and apartments will need to meet seven-star requirements under the National Housing Energy Ratings Scheme (NatHERS) – up from 6-stars under current NCC requirements.

These changes follow an agreement by the Building Ministers Meeting in 2019 to adopt a long-term Trajectory For Low Energy Buildings.

Under that agreement, ministers agreed that a stringency increase would be applied to commercial buildings in 2019 and to residential buildings in 2022 – the first such stringency increase since 2010.

Master Builders, however, is concerned that the changes will increase the cost of new home delivery.

This will occur through more stringent requirements for glazing and ceiling and wall insulation along with stricter provisions for heating, air-conditions and hot water systems.

MBV is also concerned that tighter energy efficiency requirements could lead to greater incidences of condensation and mould – which in turn could have implications for personal health and well being and could compromise the building’s structure.

(As homes have become more airtight courtesy of energy efficiency requirements, there have been concerns about reduced airflow leading to greater instances of mould.)

In response, Master Builders would like to see the stringency increase in energy efficiency postponed until the Code has been updated to include more stringent condensation requirements and industry awareness about condensation and mold has been improved.

This would include identifying construction techniques which may potentially create mould hazards along with better methods to reduce mold risk.

Moreover, rather than increasing stringency to seven stars, Master Builders believes that similar benefits could be achieved through broadening the NatHERS assessment pathway to incorporate a whole-of-house rating that includes appliances, lighting and the contribution of onsite renewable energy.

Master Builders Victoria CEO Rebecca Casson said any changes need to be carefully considered.

“On top of COVID-19 and its impacts on businesses, we are seeing supply shortages, price increases of 30-50 per cent in some materials, and upcoming changes in trade registration and licensing,” she said.

“It’s vital that these changes are carefully considered as neither the Government, industry nor consumers wish to experience any unintended consequences like those experienced with cladding.”