The Healthy Homes Standards discussion document sets out to impose up to $10,000 per dwelling of additional spending by the owners of New Zealand’s 588,700 rental properties on heaters, insulation, ventilation, moisture and drainage, and draught-stopping.
The spending aims to save the children who live in “poor quality rental homes” who are “at greater risk of being hospitalised, especially for diseases linked to housing” although the document concedes that “limited data and information available on rental homes”.
In other words, Housing and Urban Development Minister Phil Twyford doesn’t know the extent of any problem, if any, but he is going to fix it anyway.
The discussion document asserts that New Zealand rental homes: Are below World Health Organization recommended indoor temperatures of 18C to 20C; have inadequate or unhealthy heating; may not have sufficient insulation; are not ventilated properly; are not protected from rising damp; and are draughty and cold.
Housing in New Zealand became heavily politicised from 2008 when the Opposition parties every winter trotted out cold-damp-housing stories to attack the National-led Government.
The National-led Government responded by launching the Warm-Up Heat Smart programme in 2009, a $340-million-dollar multi–year year programme that provided funding for insulation retrofits and clean, efficient heating grants.
Three problems immediately became apparent. 1. Funding was only available to welfare recipients. 2. The Government promotion of heating and insulation immediately hiked the prices charged by installers. 3. Insufficient Government oversight enabled the heating and insulation industry write the rules.
Property investor associations got on board by circulating an incorrect cost-benefit claim that every dollar spent on insulation brought a $5 savings – without saying that the cost was often on the property owner and the benefit accrued to the Government by way of reduced hospitalisation costs.
Anyone who looked closely at the research purported to back a claimed link between heating and health would notice that relatively small groups of people with health issues (asthma or cardio vascular) were measured.
Any changed health outcome for these small groups resulting from heating and insulation was extrapolated to be the same for everyone living in rental housing (note, owner-occupied homes were not included) regardless of whether or not they had health issues.
That led to the standards that are currently being imposed on all rental property, not all residential property.
A clear-headed and pragmatic way to improve the health outcomes for those who had been hospitalised for asthma or cardio vascular issues would be a targeted approach to ensure that such patients returned to warm homes.
The devil is always in the detail of these broad-brush “reforms” and anyone who looks behind the hype will see that the issue is more political than actually to do with health.
- The WHO 18C to 20C temperature standard is actually readily achievable without requiring the installation of a $2000 heat pump in every room. This may be verified by a simple test by running a 2400-watt electric fan heater and using a thermometer to see how long the room takes to reach 18C. Houses may cold during some days in winter. Even so, the sun shines most days and this heats many rooms. The problem is overstated, grossly. The main barrier to people turning on a heater is that they are terrified of the electricity bill, the cost of which doubled between 2004 and 2014.
- It is a mistake to assume that if a rental property is let without a heater it will remain unheated. Inexpensive heaters are widely available. Some heating, such as unflued portable gas heaters, brings negative outcomes so there is a case to limit their use. These heaters emit poisons and add 200millilitres of water vapour to the indoor environment for every kilowatt hour, making dwellings damp.
- Insulation reduces heat loss by about 30-35 percent through the ceiling and roof, and about 12-14 through the floor, and can reduce an annual power bill by five percent. But the benefits of insulation have been frequently overstated, driven possibly by insulation providers who got the ear of the Government and helped write the rules.
- Ventilation became an issue as a result of occupants keeping windows and doors closed day and night through the winter while cooking, showering, and drying clothes indoors. Properties that had insulation retrofitted have also been found to have a higher incidence of mould when additional condensation was not wiped away and the property ventilated.
- Rising damp can be an issue with some properties with inadequate subfloor ventilation although there is insufficient data to show whether this is an actual and widespread problem.
- Draughts may be readily dealt with by widely available draught-stopping tape and cloth “sausages” than may be placed on the floor where there is an annoying gap under the door.
The discussion document seeks feedback on heaters, insulation, ventilation, moisture and drainage, and draught-stopping and suggests that all upgrades should be done within two years.
The issues, options, and questions from the discussion document are reproduced below, with a further option of no change from the status quo.
We suggest that you print this out, answer the questions, add comments, and mail it to the address at the bottom of questions by 5pm on Monday, October 22, 2018, with your name and contact details as well as a request to give an oral submission to the select committee if you wish.
The changes suggested are neither necessary nor helpful but will be expensive for property owners, with the cost paid for by tenants.
Owners and tenants are in a tenancy together. If one is disadvantaged, so is the other.
Bold text shows recommended responses where appropriate.
- Have you experienced these issues with rental homes?
- What should the minimum standards be, and when should owners be required to comply?
- Are there other options that would work better than our proposed options?
- What should be included on tenancy agreements, or which records retained, to show the rental home complies with the standards?
- Do tenants share/don’t share the Government’s concerns about heating, insulation, ventilation, damp, and draughts?
- Do owners share/don’t share such concerns about heating, insulation, ventilation, damp, and draughts?
- Should standards for heating, insulation, ventilation, damp, and draughts in rental property be the same as those standards for owner-occupied property?
A BRANZ 2015 House Condition Survey, which found that 22 percent of rental homes have no fixed heating compared to 7 percent of owner-occupied properties, confuses heating being affixed to the property with heating raising the temperature.
Electricity bills from Contact Energy showed that the cost of electricity went from 12.95 cents per kilowatt/hour (before GST) in 2004 to 22.553 cents per kilowatt/hour in 2014. Electricity prices have continued to increase every year since. The high price of electricity means that there is no guarantee that a tenant would ever turn on a large heat pump because they would be terrified of the power bill.
Besides, tests show that portable electric heaters up to 2400 watts reach the 18C standard on the cold days during winter when they are required. If the Government was genuine in its claim that interventions are necessary to improve health outcomes, such interventions would probably be more effective if they targeted those at risk. It is a mistake to assume that all occupants of New Zealand’s 588,700 rental properties are at risk.
It appears that the heat pump industry has had a hand in writing these recommendations because owners may be required to install fixed heating devices (estimate of $3000-$3500 for a heat pump), and there is a suggested ban on electric heaters greater than 2400 watts with the exception of heat pumps. Owners possibly may also be required to provide portable plug-in heaters (estimate of $30-$50)
The submission questions are as follows. We have added a further option of no change from the status quo, an option not provided in the questionnaire:
- Where in the home should owners be required to provide heating?
(a) Sitting room only.
(b) Living room and bedrooms,
(c) occupants free to provide a heater of their choice.
- What achievable indoor temperature should heaters be sized for?
(c) temperature of the occupant’s choice.
- Should owners only be required to provide heating devices where portable electric heaters are insufficient to achieve the required indoor temperature?
(a) Owners provide fixed heating devices only,
(b) Owners provide both fixed and portable heating devices,
(c) Owners and occupants free to provide a heater of their choice.
- Should we accept some heating devices, and not others?
(a) Ban unflued heaters (including unflued gas and kerosene heaters), (Ban/Don’t ban), (b) Ban open fires (Ban/Don’t ban),
(c) Ban all electric heaters (except for heat pumps) with a heating capacity of greater than 2.4 kilowatts (Ban/Don’t ban),
(d) Ban using multiple portable electric heaters in one room (Ban/Don’t ban).
(e) Ban using multiple portable electric heaters off a single power point (Ban/Don’t ban).
The Healthy homes standards discussion document asserts that many rental homes still do not have adequate insulation to retain heat and therefore are more likely to be cold, damp and mouldy. The document concedes it is based on limited data.
Insulation is used to reduce heat loss in winter and heat gain in summer. In an uninsulated home, about 30-35 percent of heat loss is through the ceiling and roof, and about 12-14 percent is lost through the floor.
Although an insulated dwelling is more pleasant to live in than an uninsulated one, the benefits of insulation are frequently over-stated. Heating is around 30 percent of an energy bill IN WINTER, and insulation reduces annual energy costs only by around five percent. The main consumer of energy in a household is hot water.
The benefits have been frequently overstated by saying $1 spent on insulation means a $2.10 benefit on health expenditure savings. What is not said is that the property owner pays the price and the benefit goes to the local DHB. A closer look at the cost-benefit analysis that the claim was based on showed an error and the actual return on $1 spent was just 28c.
There are currently standards that owners of rental property must comply with by July 1, 2019. If ceiling and underfloor insulation was installed in a rental property before July 2016, an upgrade may not be necessary provided the insulation is in reasonable condition and achieved at least the minimum R-value when the insulation was installed, which was, for timber-framed homes, ceiling R 1.9 and underfloor R 0.9.
If there was no existing insulation or it was installed after July 1, 2016, insulation in rentals is required to meet the minimum R-values of the three zones being Northland, the remainder of the North Island excluding the Central Plateau, and the South Island plus the Central Plateau, with ceiling being R 2.9 and underfloor R 1.3.
The price for installing underfloor insulation and topping up ceiling insulation in a 50 square metre dwelling was $2380 in 2018.
The standards discussed in the discussion document could require a higher minimum level of existing insulation than the current regulations and does so without quantifying the additional benefits of a higher grade. The submission questions are as follows:
- What minimum level of insulation should be required in rental homes?
(a) The requirements under the 2016 regulations would continue to apply after July 1, 2019.
(b) Replace or retrofit ceiling and underfloor insulation in their rental home if it is not in a reasonable condition (or better), and, when originally installed, did not have the R value of (at least) 1.9 in the ceiling and 1.3 under floor,
(c) Replace, retrofit or ‘top up’ ceiling and underfloor insulation if it is not in reasonable condition (or better), is not in accordance with the relevant New Zealand Standard and, when originally installed, did not have the R-value (at least) of ceiling 2.9 and underfloor 1.3, or
(d) Put the requirement for insulation in rental properties on the same basis as for owner-occupied homes.
- How should the degradation of insulation under “reasonable condition” be assessed?
(a) Where ceiling insulation has not settled below 70 millimetres thick and has no mould, dampness or gaps (status quo),
(b) new minimums of 1.9R to 2.5R for ceiling,
(c) new minimums of 2.9R to 3.3R for ceiling, or
(d) No higher standard without evidence of extra benefits for a higher standard.
(e) Put the requirement for insulation in rental properties on the same basis as for owner-occupied homes.
- How can landlords show compliance with the insulation standard?
(a) Demonstrate the R-value when the insulation was installed,
(b) A record of Building Code compliance and the level of insulation,
(c) Compliance certified by a suitably qualified and experienced assessor, or
(d) No proof of compliance required.
(e) Put the requirement for insulation in rental properties on the same basis as for owner-occupied homes.
It is not as if there are no regulations for housing. The Housing Improvement Regulations of 1947 required opening windows in bathrooms and ventilation in kitchen. Much of this was incorporated into the Residential Tenancies Act 1986 and remained uncontroversial until rental housing became politicised since 2008. Opening windows and doors is the usual way of ventilating a dwelling. The discussion document is silent on why some housing more than 100 years old had no problems with dampness until the past 10 years.
The discussion document cites a BRANZ report that says bathrooms without extractor fans or heating are twice as likely to have moderate or worse patches of mould compared with bathrooms with extractor fans or heating. It also asserts that 37 percent of rental homes have no extractor fans in the kitchen, and 44 percent have none in the bathroom.
The writers of the discussion document appear unaware that some tenants won’t use extractors because they use electricity and sometimes prefer to shower in the dark, with windows and doors firmly shut.
The document cites an NZIER report that said costs outweigh the benefits of installing ventilation equipment in rental properties. The submission questions are as follows:
What level of ventilation is required in rental homes?
(a) Each room should have a window that may be opened (status quo),
(b) Openable windows and extractor fans in rooms with a bath or shower,
(c) Openable windows and extract fans in rooms with a bath, shower or indoor cooktop.
(d) The level of ventilation required in rental property should be the same as that in owner-occupied property.
Moisture and drainage
The discussion document observes that moisture entering a home from outside often contributes to damp and mould issues inside the home in addition to moisture created by everyday occupant activities like cooking and showering.
Rising damp resulting from lack of ventilation under the floor, leaks through holes in the roof, blocked gutters, downpipes, stormwater systems, and failed waterproofing under concrete floors can all contribute to damp homes.
The discussion document assumes that because rental homes are damp and mouldy if nothing is done they will all continue to live in them and the Government would face escalating hospitalisation costs.
There is an attempt to quantify this in the discussion document by saying up to 40 litres of water can rise up from the ground below a 100 square metre home every day, that 76 percent of rental homes have a subfloor, that 44 percent of rental homes with subfloors have insufficient ventilation, and that 81 percent of rental homes with subfloors do not have a ground moisture barrier. No source for this information was provided. Elsewhere in the document was a concession that data on rental properties on which to base such assertions is limited.
How should property owners protect rental homes against moisture entering the home and inadequate drainage?
- Property owners are already required to meet their existing legal obligations, including the Residential Tenancies Act and HI Regulations (status quo).
- Property owners install a ground moisture barrier if vents are not adequate and drainage must be efficient. An exemption would apply if the rental home has adequate (open and unblocked) subfloor ventilation openings of sufficient size and distribution around the subfloor perimeter, if the rental home is a pole house, or if a property owner obtains a certificate from a qualified building surveyor.
- Moisture and drainage requirements for rental properties should be the same as that in owner-occupied properties.
The Healthy homes standards discussion document says New Zealand rental homes are draughty, particularly those built before 1960, without noting that all housing in New Zealand from that era is potentially draughty. Neither does it note that draughts provide ventilation although on a cold winter night it is unwelcome ventilation.
What is the appropriate level of draught stopping to create warm and dry rental homes?
- Currently, regulation 17 of the HI Regulations requires that the materials of which each house is constructed shall be sound, durable and where subject to the effects of the weather, weatherproof, and shall be maintained in such a condition. The walls and ceilings of every habitable room, bathroom, kitchen, kitchenette, hall and stairway shall be sheathed, plastered, rendered or otherwise treated and shall be maintained to the satisfaction of the local authority. This is the status quo.
- Stop unnecessary gaps or holes that cause noticeable draughts, which includes gaps of 3mm or more around windows (we assume that timber windows intended to be opened would be excluded), and blocking any decommissioned chimneys and fireplaces.
- The level of draught-stopping required in rental property should be the same as that in owner-occupied property.
The discussion document also asks whether other requirements for draught stopping should be included in the standard? If so, what?
Option 1: Landlords must comply with the standards within 90 days of a new or renewed tenancy starting after a single compliance date, e.g. July 1, 2021.
Option 2: A single compliance date (e.g. by July 1, 2022).
Option 3: Stagger compliance dates between July 1, 2019, and June 30, 2024, either by the standard, eg insulation by 2022 and heating by 2023, or the location of the rental home.
Option 4: No further compliance beyond existing requirements for owner-occupied property.
How to have your say
The Healthy Homes Standards Discussion document may be downloaded by entering Discussion document: Healthy Homes Standards – MBIE
You may email your submission to Healthyhomes@mbie.govt.nz
You may post your submission to:
Ministry of Business, Innovation and Employment,
15 Stout Street,
P.O. Box 1473,
Please also include your name, or the name of your organisation, and contact details.