Passive House Institute New Zealand (PHINZ) strongly disagrees with proposals to roll back insulation standards. The recent changes to the Acceptable solution in Building code clause H1 Energy Efficiency (H1/AS1) represented a positive step towards achieving the core objectives of the Building Act:

• (i) people who use buildings can do so safely and without endangering their health; and

• (ii) buildings have attributes that contribute appropriately to the health, physical independence, and well-being of the people who use them.

PHINZ acknowledges room for improvement in H1/AS1, but a rollback won't solve the underlying issues. Instead, we propose building on the recent changes by moving to incorporate recommendations PHINZ has previously made, which are closely aligned to those proposed in MBIE's Building for Climate change programme.

Here's our proposal for revising H1/AS1:

• Ditch the Flawed tools: The schedule, calculation and modeling methods contained within H1/AS1 are riddled with limitations and fail to reflect real-world building performance. Setting revised targets based on these methods is unlikely to create any positive change.

• Embrace International Standards: PHINZ proposes replacing NZS 4218 with the internationally recognized ISO 52016. This allows for accurate building modeling and provides data in a universally understood format.

• Performance over Prescriptive Measures: Instead of mandating specific R-values for individual building elements (a known ineffective approach), we advocate using building modelling to target maximum heating and cooling loads. This performance-based approach allows designers and builders to find the best solutions for a given climate, site, and building design.

Following these recommendations will establish robust, evidence-based building standards that fulfill the Building Act's core functions while promoting construction industry innovation.

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