Subfloor insulation in rentals a costly mistake

A requirement to install subfloor insulation in rental properties should go and owners who have installed it under threat should be compensated, Tenancies War spokesman Mike Butler said today.

Insulation features in “healthy homes” regulations that Housing and Urban Development Minister Phil Twyford is expected to impose next month.

Under existing law, New Zealand’s 262,000 owners of rental property are required to install both ceiling and underfloor insulation by July 1 or face a penalty of $4000 payable to any person who reports non-compliance.[1],

The cost of installing R 1.3 subfloor insulation as required by the Residential Tenancies (Smoke Alarms and Insulation) Regulations 2016 for most of the North Island was $881.64 for a 77 square metre dwelling.[2]

The requirement for subfloor insulation is ridiculous because at best it reduces heat loss by only 9 percent which means the cost of installing it substantially outweighs any benefits, [3] Mr Butler said.

Ceiling insulation reduces heat loss by 35 percent but the difference between ceiling and subfloor insulation was not considered in the cost benefit analysis done by the New Zealand Institute of Economic Research for the Government, he said.

When asked why, an NZIER spokesman said that the Ministry of Business Innovation and Employment asked them to leave it out of the analysis, Mr Butler said.[4]

Requiring subfloor insulation in rental properties was a policy blunder perpetrated by the former National-led Government that should be remedied, he said.

The Minister has rectified another costly failure by the former Government by amending a methamphetamine contamination threshold that was 24 times lower than the lowest level that anyone could plausibly have a health risk, Mr Butler said.

Mr Twyford could include in the “healthy homes” standards a similar correction by dropping the requirement for subfloor insulation, he said.[5]

Owners who have installed subfloor insulation under threat based on faulty advice require compensation, Mr Butler said.

A repeal of the subfloor insulation regulation could save the Government millions of dollars in work not required for any state houses that may not have subfloor insulation, he said.

Stop the War on Tenancies is a group that since last October has been highlighting the evidence that successive governments have ignored while creating rental property policy.

[1] Schedule 1A Amounts for unlawful acts, Residential Tenancies Act 1986, at http://www.legislation.govt.nz/act/public/1986/0120/latest/whole.html?search=qs_act%40bill%40regulation%40deemedreg_residential+tenancies+act_resel_25_h&p=1#DLM3285790

 

[2] Qualifying ceiling insulation. See http://www.legislation.govt.nz/regulation/public/2016/0128/16.0/DLM6856254.html

[3] How Insulation Works, Level. http://www.level.org.nz/passive-design/insulation/how-insulation-works/

[4] The proposed Healthy Homes Regulations: An assessment, Ian Harrison, p17. http://www.tailrisk.co.nz/documentlist

[5] Meth, evidence, govt failure. https://www.nzcpr.com/meth-evidence-govt-failure/

Evidence undermines insulation standards, $4000 penalty

Evidence undermines insulation standards, $4000 penalty

Evidence provided to the Government undermines both current rental property insulation requirements and makes a mockery of a $4000 penalty for non-compliance, Tenancies War spokesman Mike Butler said today.

Owners are required to install both ceiling and underfloor insulation by July 1 or face a penalty of $4000 payable to the person who reports it[1], Mr Butler said.

The penalty applies to subfloor insulation which has little quantifiable benefit to tenants or owners, he said.

This is because the floor and air leakage account for only 9 percent heat loss in an uninsulated timber-framed house in which 30–35 percent of heat is lost through the roof, 21–31 percent through the windows, and 18–25 percent through the walls.[2]

The Residential Tenancies (Smoke Alarms and Insulation) Regulations 2016 currently requires R 2.9 insulation for ceilings and R 1.3 for underfloor in most of the North Island.[3]

These specs exceed advice to the Government that a 1978 requirement of R 1.9 in ceilings brought the biggest energy savings, Mr Butler said.[4]

Additional insulation over 1978 requirements is of decreasing benefit to tenants and a waste of money for owners, he said.

In fact, every dollar spent on topping up insulation in 190,000 buildings to the standards proposed would only bring a 39-cent benefit according to a report by economist Ian Harrison, of Tailrisk Economics, released just before Christmas.[5]

Besides the waste of a poorly focussed policy, the $4000 penalty payable to a complainant has created an incentive for the unscrupulous few to remove insulation for financial gain, Mr Butler said.

This means that owners will gave to carry out regular checks to ensure that their insulation is still there, Mr Butler said.

At least there should be a $3000 penalty for tampering with or removing insulation since there is a $3000 penalty for tampering with or removing smoke sensors, he said.

The Government has lost sight of the fact that insulation merely improves energy efficiency. Insulation in itself does not save lives. It is the increase in temperature achieved by turning on a heater that generates health benefits, Mr Butler said.

Stop the War on Tenancies aims to fill an information gap in the face of blunders by successive governments on rental property policy.

[1] Schedule 1A Amounts for unlawful acts, Residential Tenancies Act 1986, at http://www.legislation.govt.nz/act/public/1986/0120/latest/whole.html?search=qs_act%40bill%40regulation%40deemedreg_residential+tenancies+act_resel_25_h&p=1#DLM3285790

 

[2] How Insulation Works, Level. http://www.level.org.nz/passive-design/insulation/how-insulation-works/

[3] Qualifying ceiling insulation. See http://www.legislation.govt.nz/regulation/public/2016/0128/16.0/DLM6856254.html

[4] Healthy Homes Standards: Options for the discussion, May 18, 2018. P8

[5] The proposed healthy homes regulations, Tailrisk Economics, December 2018, p18. See http://www.tailrisk.co.nz/documentlist