What evidence-based ‘healthy home’ standards look like

Evidence-based rental property standards would require ceiling insulation to the 1978 standard, no subfloor insulation, and nothing more, Tenancies War spokesman Mike Butler said today.

Advice to the Government obtained under the Official Information Act (See http://tenancieswar.nz/healthy-homes-legislation/)  shows no support for the claim that heat pumps, extra insulation, extractor fans, draught-proofing, and moisture-proofing, which soon may be imposed under the Healthy Homes Guarantee Act, would keep 10,800 children out of hospital each year.

The World Health Organisation never recommended a minimum indoor temperature, as the discussion document claimed, and the Building Research Association of New Zealand found that only 2.7 percent of renters thought their dwelling was cold and damp, which is hardly a crisis, Mr Butler said. (See The proposed healthy homes regulations: an assessment http://www.tailrisk.co.nz/documentlist)

We already have standards for rental property and if Housing and Urban Development Minister Phil Twyford followed advice, the standards he would confirm under regulation would be thus:

  • Heating: A tenant should be able to use whatever he or she chooses to plug in so long as it is safe. Both fixed and portable heaters can deliver sufficient warmth. Last year, Housing New Zealand found that a number of tenants would not use 15,000 fixed heaters recently installed because they were not what they were used to. (see  http://tenancieswar.nz/2018/10/09/complaints-show-problem-with-heaters-in-rentals/?fbclid=IwAR3uFj9j1V95oRmjDl1Q_TbFpWNXJxXMfpFtJO1aWezlB-JxOxipfoG2PxE ) The high price of electricity is the greatest barrier to poor people turning on the heater, not the presence or absence of a heater. Wood-burners are useful for those who prefer a fire.
  • Insulation: Ceiling insulation to the 1978 standard of R1.9 for most of the North Island should be the standard because it has the greatest impact and anything over that has diminishing cost-effectiveness. Underfloor insulation is a waste of money because it hardly reduces heat loss. Owners forced to install it should be compensated.
  • Ventilation: Windows that may be opened is a basic standard of ventilation and have been required since 1947 under Home Improvement Regulations of that year. There is no solid evidence that mould is a serious issue in rental properties.
  • Draught-proofing: Residents will protect themselves from draughts when they need to and any serious issues may be remedied through discussion with the owner. Requiring draught-stopping tape in gaps greater than 3mm in 588,700 rental properties is absurd.
  • Moisture-proofing: No evidence has been offered to prove all rental properties suffer from rising damp. The evidence is that 2.7 percent are perceived as cold and damp. Dampness problems are remedied by discussion with the owner or through the Tenancy Tribunal.

The outrageous $4000 dob-in-your landlord incentive imposed by the previous government should be dropped, he said.

The attempt to blame housing-related hospitalisations of 10,800 children annually on the condition of 588,700 rental properties while ignoring 1.1 million owner-occupied properties and not accounting for overcrowding is deceitful, he said.

Up to $7000 of extra spending per property may be required if every rental property required a heat pump, extra insulation, extractor fans, as well as the suggested draught-proofing and moisture proofing and this would have little benefit, Mr Butler said. (See http://tenancieswar.nz/2018/11/)

The money for extra compliance can only come by way of a rent increase from the tenant who is in effect being forced into buying extra appliances and building material without necessarily wanting it, he said.

A more-effective way ahead should be driven by owners and tenants in which any issues with heating, insulation, ventilation, draught and moisture proofing could be sorted out by agreement, 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.

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

Cherished ‘damp rental’ beliefs rubbished

Cherished ‘damp rental’ beliefs rubbished

Fewer than 3 percent of tenants find their homes cold and damp, the World Health Organisation did not recommend a healthy temperature, and client-friendly research helped understate the costs of heating and insulation proposals for rental property, according to a discussion document released today.

Iconoclastic economist Ian Harrison of Tailrisk Economics has taken aim at the cherished beliefs of Housing Minister Phil Twyford in a discussion document titled The proposed Healthy Homes Regulations: An Assessment.

Twyford is finalising a series of standards for New Zealand’s 588,700 rental properties on heating, insulation, ventilation, moisture and draught-proofing under the so-called Healthy Homes Guarantee Act that was passed last December.

As justification, the Minister points to assertions that many New Zealand houses, not just rental houses, are “cold and damp” and that this has health implications.

A key touch point is that our homes don’t meet the World Health Organisation recommendation that indoor spaces be heated to at least 18C.

The Healthy Homes Standards discussion document put out for public consultation in September has six pages of references which give the appearance of sound and thorough research. But for anyone who goes to the papers and checks the claims, it quickly becomes obvious that:

  1. Only 2.7 percent of tenants thought that their rental was cold and damp, according to a survey by the Building Research Association of New Zealand in 2017, and of that percentage it was not clear what proportion was due to inadequate use of heating and a failure to ventilate by tenants.
  2. The World Health Organisation did not recommend a minimum indoor temperature of 18C. What they did say was that no conclusions could be reached on the average indoor ambient temperature below which the health of the general population may be considered endangered.
  3. Research evidence shows that the common New Zealand practice of lightly heating bedrooms does not present a health risk.

The bulk of the paper was devoted to a cost benefit analysis done for the Government by the New Zealand Institute of Economic Research, that Harrison described as “client friendly”.

Key “unhelpful” documents were sometimes ignored, costs were systematically understated, and unrealistic methodologies were adopted that overstated the net benefits, Harrison wrote.

Harrison redid the cost benefit analysis by including the unhelpful documents while correcting costs and methodologies to find that a heat pump in every living room would come at a capital cost of $457-million bringing a net loss of $500-million.

Insulation top-ups would cost $410-million bring a loss of $269-million, ventilation would cost around $200 million with very limited benefits, moisture proofing would cost around $300-million with no material benefit, and draught-proofing would cost around $300-million, again with limited benefits.

The NZIER’s assessment of the cost of insulation was based on outdated prices and only considered ceiling insulation, which by excluding subfloor costs, increased its benefit.

When questioned on why underfloor insulation was not included, NZIER said that they were directed by the Ministry of Business, Innovation and Employment not to consider it.

The value of underfloor insulation is marginal because only 10 percent of heat is lost through the floor while 40 percent is lost through the ceiling.

The evidence shows that “healthy homes guarantee” slogan is nothing more than political spin, which is very bad news for all rental property owners who may be forced to spend around $7000 per dwelling on unnecessary upgrades.

Since an insulation top-up costs the same as insulating from scratch, all those “good” rental property owners who have installed insulation since whenever have probably wasted their money because they may have to re-do it.

The proposed Healthy Homes Regulations: An Assessment may be read at http://www.tailrisk.co.nz/documentlist.

Ian Harrison, who has a BCA Hons from Victoria University Wellington, and a Master of Public Policy SAIS Johns Hopkins, has worked with the Reserve Bank of New Zealand, the World Bank, the International Monetary Fund, and the Bank for International Settlements.

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