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Submissions

Submission to the Victorian Government’s proposed regulations for Minimum (Energy Efficiency) Standards for Rental Properties

Submission to the Victorian Government's consultation on the Residential Tenancies and
Residential Tenancies (Rooming House Standards) Amendment (Minimum Energy Efficiency and
Safety Standards) Regulations 2024

We strongly support minimum energy efficiency standards in all rental properties, recognising the detriment to people’s physical, mental and financial wellbeing of living in a home that is impossible to keep warm in winter, cool in summer or is mouldy.

Setting these standards should be a priority to give people relief from high energy bills and ensure that Australian homes are climate resilient.

Our submission on the Victorian Government’s proposed Regulations for Minimum Standards for Rental Properties and Rooming Houses notes five key opportunities for improvement, which are detailed in the submission:

  1. Consider a practical timeframe and staged approach for implementing R.5 ceiling insulation requirements to rental homes with low levels of ceiling insulation (R1.5 or less). Mandating the proposed insulation requirements only to homes with no insulation prevents 87.3% of Victorian rental households from enjoying healthier and more comfortable homes.
  2. Provide clear definitions and examples for what constitutes justifiable and reasonable exemptions to the proposed Regulations in ways that prevent currently exempt cases from being locked into less-than-optimal arrangements in the medium to long-term.
  3. Require the replacement of gas-powered cooking appliances at end of life, with electric ones, in addition to space and water heating systems.
  4. Commit to reviewing and updating the proposed Regulations at least every five years and to provide regular and public reports on progress of the implementation of the standards. The review and update process must ensure minimum efficiency rental standards are in line with best practices and building codes for new homes, reflect changes in the climate adaptation needs of homes, and also the reduction in costs and technology improvements of products and services for better consumer outcomes.
  5. Ensure there are sufficient enforcement and compliance measures to monitor how the proposed Regulations are implemented, how exemption cases are justified, and how renters are being informed about the changes in minimum standards, from listing and advertisement to end of lease. The onus of requesting compliance to minimum standards should never fall on the renter.

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