Submission: Investigation into Minimum Energy Efficiency Rental Standards

The Tenants’ Union welcomes the opportunity to provide feedback on the NSW Government's consultation paper investigating the implementation of minimum energy efficiency rental standards. Our responses are guided by our work with renters, the growing body of evidence around minimum energy efficiency standards and also the casework experience of the local Tenants Advice & Advocacy Services across NSW. We know first hand from renters that they are living in homes that are in a poor condition and this is further exacerbated by the homes having poor energy efficiency. Minimum energy efficiency rental standards are crucial in NSW to address long-standing market failures, including the split incentive between landlords and renters and ensure that renters live in safe, healthy, secure & affordable homes.
 

Recommendation 1

NSW Government should implement performance based minimum energy efficiency rental standards (MEERS) with the primary objectives of improving the thermal safety of rental
homes to protect renters health and improve energy affordability and reduce energy hardship for renters.

Recommendation 2

NSW Government should implement Option 2: Home Energy Rating (NaTHERS) with specific feature standards to be implemented in the short term as we progress towards NaTHERS based performance standards.

Recommendation 3

Implementation of MEERS should take into account the different climate zones in NSW and using the NaTHERS rating certificate will ensure these different zones are considered in a home's energy rating.

Recommendation 4

Any financial subsidies provided to landlords to reduce their MEERS compliance costs should be means tested and conditional on a limit on rent increases for 3 years.

Recommendation 5

Implement restrictions on landlords issuing a notice of termination on grounds of renovations or significant repairs due to compliance with MEERS.

Recommendation 6

MEERS should apply to all rental homes in NSW and be consistent and equitable.

Recommendation 7

Higher minimum standards should be considered in the long term for housing types which house renters who are more vulnerable due to health conditions.

Recommendation 8 

If exemptions to MEERS are to be considered in NSW then they should be specific and limited with the onus on the landlord to apply for an exemption and provide proof they qualify.

Recommendation 9

MEERS should be considered part of the existing minimum standards for rental homes in NSW and all minimum standards be a requirement before homes can be advertised for rent.