Rental property standards questioned

A total of 1769 submissions were received for the consultation on the so-called “healthy homes guarantee” extra standards for rental property, which closed on October 22, 2018.

Consultation on rental property standards was conducted at the same time as consultation on proposed changes to the Residential Tenancies Act that had a higher profile and attracted 4761 submissions.

The Healthy Homes Guarantee Act (No 2), that was passed into law in December 2017, amended the Residential Tenancies Act 1986 to enable the Government to create regulations that will set new standards for New Zealand’s 588,700 rental properties.

The consultation document (see sought feedback on proposed requirements, (see the link for The Healthy Homes Standards Discussion document at the bottom of the page), covering:

  • Fixed heaters, possibly heat pumps,
  • Extra insulation beyond 2016 requirement,
  • Extractor fans in kitchens and bathrooms,
  • Polythene sheets under dwellings to stop rising damp,
  • Draught-stopping tape where gaps around windows and doors are greater than three millimetres.

The Ministry of Housing and Urban Development cited a cost-benefit analysis by the Health Research Programme of the University of Otago, Wellington, in 2018, which found that after installing insulation people had no fewer health events, reducing the costs of hospitalisation and mortality. (see

Our submission may be viewed here on the link MB Submissions Standards at the bottom of the page.

We commissioned “The Proposed Healthy Homes Regulations: An Assessment” by economist Ian Harrison. (See

He found that only 2.7 percent of those surveyed thought their rentals were cold and damp, according to the Building Research Association of New Zealand, (page 4), contradicting a claim in the discussion document that “many” rentals were cold and damp.

He also found that the claim in the discussion document that many New Zealand rental homes are colder in winter than the 18C indoor temperatures recommended by the World Health Organization gives the impression that a lower temperature is unhealthy when in fact the World Health Organisation did not recommend a minimum indoor temperature.

We asked Housing and Urban Development Minister Phil Twyford 26 questions under the official Information Act. (See OIA standards Oct 24)

The response was delayed, involved an approach to the Ombudsman, and eventually some questions were sent to the Ministry of Business, Employment, and Innovation for a response.

The responses may be seen here in the Covering letter 22112018150556-0001.pdf,  and in Attachment 1, and Attachment 2  which you can open by clicking the buttons below.

In attachment 1, the Ministry of Business, Employment, and Innovation suggested grants to mitigate against some rental property owners selling (Briefing, October 30, 2017, page 14), detailed insulation installation costs (Briefing, November 8,, 2017, page 4), and advised the Minister that the biggest gain achieving 80 percent heat-loss reduction was by insulating to the 1978 standard of R1.9 (Briefing, November 8, 2017, page 6).

Attachment 2 details the NZIER cost-benefit on page 28 following, claims a benefit of $64 a year per property by insulating to the 2001 standard (page 29), claims a benefit of $49 per property by installing draught-proofing tape around windows and doors (page 29), and says extractor fans in kitchens and bathrooms are expected to cost of $48 per property with no benefit shown (page 29)


The Healthy Homes Standards Discussion document is available here.

Download this document here: MB submission standards