2020 consultation submissions summary

In September and October 2020, we asked the public for their views on our proposals to increase the operational efficiency of buildings, and to reduce the embodied carbon across the lifecycle of buildings as part of the Building for Climate Change programme.

Summary of submissions report

We asked the public for their views on our 2 Building for Climate Change emissions mitigation frameworks:

• Whole-of-life embodied carbon reduction — which proposes to set mandatory reporting and measurement requirements for whole-of-life carbon emissions, including from the materials used in construction, the construction process, construction waste, and the disposal of a building at the end of its life.
• Transforming operational efficiency — which proposes to set required levels of efficiency for energy use and water use and define minimum indoor environmental quality measures for buildings.

MBIE received 374 submissions from across the building and construction sector.

The summary of submissions report from this public consultation has been released, and is available to read in full.

Key themes

• Information needs to be more available around building low carbon
• Cost is a major concern for people
• Reusing building materials is something people want to be able to do to reduce costs, and our impact on the planet
• Prefabrication is seen as part of the solution
• Building strength and resilience shouldn’t be sacrificed to reduce embodied carbon
• Consenting shouldn’t be hard – and there should be simple consent methodology, tools and information to support low carbon materials and methods
• Monitoring is needed to ensure the operational efficiency gains are realised and to determine if the modelling works
• Existing buildings are an issue of big debate – whether or not they should be included in the initial plans
• Government needs to lead the way in making changes.

Consultation by the numbers

Feedback from architects and designers

• Key barriers identified by this group were: lack of an agreed methodology, inadequate data quality and availability, lack of appropriate tools or software, and administrative burden on businesses.
• Many said cost was a barrier, noting that sustainability minded people are sometimes torn between affordability and sustainability
• Several highlighted the lack of access to information
• There was a strong desire to remove barriers the reuse of construction materials
• Several respondents wanted a clear, common standard to measure performance

Feedback from builders

• Key barriers identified by this group included cost, home owners not wanting to build past existing code and entrenched beliefs within the building industry.
• Most respondents asked us to make sure it’s not too complicated.
• Concerns were noted at the lack of focus on how a building is built.
• About half the submissions felt that the proposals are not explicit enough in regards to existing buildings or have not considered them enough.

Feedback from building owners

• Most respondents said that costs of implementing the frameworks would be too high, including material costs, council charges, refurbishing very old stock, innovation overheads, compliance costs, and time.
• They noted that existing regulations prevent the reuse and recycling of materials.
• They expressed that exceeding the bare minimum standard needs to be normalized, otherwise the minimum will need to rise.
• Several people mentioned the importance of educating consumers on things like the advantages of green building standards and the benefits of sustainable design.
• There was concern that carbon intensive materials like concrete and steel would be banned or heavily limited.
• They are eager to see clear guidance from central government to local government to ensure smooth consenting processes.
• Several respondents highlighted the need to align the programme with existing legal frameworks and guidelines.
• They also noted that excluding existing buildings from the framework could lead to the perverse outcome of keeping old stock as newer builds under the framework become more expensive.

Feedback from the concrete industry

• They noted that the lack of agreed methodology around measuring carbon in concrete was a problem.
• They suggested using a whole of life LCA approach (cradle to cradle) to decide what low carbon is, as some materials may have more upfront carbon but have better thermal performance and last longer.
• They also said Government should incentivize material reuse such as using construction wastes in cement or repurposing used concrete into aggregates.

Feedback from the steel industry

• They noted their opposition to any Framework that favours one building material, and said it’s important not to lose sight of the principal basis for material selection: the product’s suitability for the building’s expected durability, lifespan, safety requirements, and intended use.
• They commented that embodied carbon calculations must take into account not only production, but also maintenance, demolition and waste.
• They also noted the lack of a level playing field when having to compete with imported steel products that the Emissions Trading Scheme does not apply to, and proposed options for robust transport emission calculations.
• There were many comments about the ‘roadmap to zero emissions’, noting that the development process should be transparent and industry led.
• They also encouraged the removal of barriers to reusing construction materials.

Feedback from the timber industry

• They expressed the need for a common, agreed methodology, simple tools and a set of carbon values to assess and compare embodied carbon.
• They encouraged financial incentives for designing carbon negative structures that can be moved at a later date and to encourage off-side prefabrication.
• They noted eliminating coal-fired boilers as a quick win.

Feedback from the broader supply chain

• Increased costs were seen as the biggest barrier to the public making the necessary changes.
• They thought the 2035 timeframe was unreasonably long and should be brought forward.
• Respondents argued that the focus on operational efficiency was less ideal than a focus on operational emissions.
• They noted that requiring councils to monitor embodied carbon during the consent process will result in increased costs and longer consent times.
• They also noted that including existing buildings in the initial roll-out would increase employment opportunities, as demand for energy efficiency retrofits would be significant.
• They cited the need for better tools and methods to enable the measurement of emissions.
• Respondents said embodied carbon and operational emissions reduction must be considered together or the programme would risk unintended consequences.

Feedback from local government (including Building Consent Authorities)

• BCAs noted concerns about cost barriers, and how the costs would be shared through the system
• Many mentioned the lack of resourcing within councils, and the obligations this would add for BCAs
• Almost all mentioned waste as a major issue, and noted the need for waste management strategies, including recycling initiatives.
• Off-site construction and prefabrication were noted as ways to reduce construction waste or the adoption of standard sizes in design.
• Respondents all mentioned needing tools for carbon calculations and want central government to implement them so they are all using same standards and processes.
• They also noted the need for increased information, including NZ specific data for emission factors for building products, materials, systems and construction.
• Most are keen for some sort of expert body or certification system so that the onus for working out the carbon cost does not fall on council.
• They noted the importance of government leading the way.

Feedback from engineers

• Many felt that direct subsidies or incentives were required to make clients consider emission reductions in their designs which would increase demand across the sector.
• Implementing operational energy requirements at the consent stage would add a lot of time and cost to projects and require new skills such as energy modelling, which could have an impact on smaller developers.
• The largest barrier for many regarding reporting whole-of-life embodied carbon is the lack of a robust simple carbon measurement system that can act as a “single source of truth”.
• A common theme was for incentives to improve building lifespan and reusability.
• Many respondents felt that there was a lack of comprehensive embodied carbon data available, and improving this would make it easier to make decisions based on embodied carbon and then justify these choices to clients.
• There was an overall sense that government should lead the way with their procurement and building practices as this will expand the supply chain of low impact materials into New Zealand.
• Some noted the need for increasing carbon literacy throughout New Zealand, especially as it relates to the built environment.
• They felt that embodied carbon caps and requirements should be extended to renovations and demolitions that aren’t currently covered by the building consent system.
• They also thought a separate organisation from councils could provide embodied carbon assessments.
• They also expressed the need for the two frameworks to work together to prevent perverse effects.

Feedback from homeowners

• We had low rates of response from homeowners, so we are planning to do targeted research to better understand their experiences.
• Those who did respond noted the limited public knowledge around carbon consequences for using various materials and possible alternatives, and expressed the need for broader education about green building standards.
• They also noted the lack of appropriate materials readily available and affordable, including natural NZ made products.
• And they expressed concerns about cost to the end user to meet this standard.
• They thought encouraging smaller buildings is one way to increase efficiency.
• They said there needs to be consistency between councils.