The Property Council welcomes the opportunity to comment on the Draft National Building Energy Standard-Setting, Assessment and Rating Framework (the Framework).
The Property Council supports the development of a detailed framework for improving energy efficiency in the built environment.
However, the draft Framework released for consultation:
- is informed by flawed analysis;
- offers no clear vision, target or direction for industry; and,
- ignores the real opportunities for improvement.
The Property Council has consistently argued that the framework should provide an overall sectoral target, complemented by a suite of costed measures to deliver efficiency or abatement dividends.
The Framework must:
- take an evidence-based approach to setting a sectoral energy/GHG savings target;
- set clear targets and timeframes for delivery;
- tie together the government energy efficiency programs currently in place to develop a single, coherent policy framework;
- be supported by properly costed, funded policies and incentive programs; and,
- be underpinned by a robust system of monitoring and evaluation to ensure it remains relevant.
If these criteria are not met, the Framework will not meet its aim of providing a “clear, coordinated and visionary” approach to energy efficiency in the built environment.
