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Minimum standards for rentals and rooming houses - SUBMIT TODAY

The Victorian Government is proposing a series of reforms to improve energy efficiency for the one third of househoulds in Victoria that are rental properties.

Friends of the Earth Melbourne encourages everyone - particularly renters in Victoria - to write a submission for the draft Regulatory Impact Statement on Minimum Standards for Rental Properties and Rooming Houses. Submissions are due by 1 July 2024.

Currently in Victoria rental properties need only comply with a minimum two star energy rating. That’s basically a glorified tent, in terms of insulation. Victorian rentals currently don’t need to offer air conditioning, which is more efficient and cost effective than gas heating in most cases.

Rentals are often occupied by some of the most financially stressed householders. The additional energy required to heat and cool leaky, inefficient rentals adds significantly to both escalating climate change and the cost of living crisis, and renters have for years reported that they will avoid turning on heating and cooling out of fear of unaffordable energy bills.

Half of the gas used in Victoria is blown on heating buildings alone so setting higher standards for rental energy efficiency and mandating ceiling insulation will save Victoria from projected gas shortfalls in the winters in coming years.

We love the proposal that before a property can be leased to new private, public or social housing tenants it must offer higher efficiency standards. Of course, there is downside that this could create a two tier market - those in cheap rentals that are expensive to run and those in more expensive, upgraded properties with lower energy bills.

We believe that this policy should be rolled out alongside mandated price caps for rentals to ensure that homes are affordable for tenants irrespective of whether they are upgraded or not.

We are disappointed that gas appliances are still going to be considered an energy efficient option for rental properties. Fossil gas is around eighty-four times more polluting to the climate than carbon dioxide over a twenty year period and of course increase the risk of asthma and respiratory illnesses for people living with gas cooking. We do, however, welcome the clarification that hot water service upgrades will be specifically all-electric wherever possible.

Please write a submission now to tell the Victorian Government that you want energy efficient, comfortable and affordable rentals that are totally gas free.

So let's get cracking! There are two ways to write a submission; either answer 5 survey questions or write a longer submission and upload it. We've given you some tips for both ways below.

First, open the consultation page in a new tab.

Survey questions

Do you support the introduction of the proposed minimum standards to improve energy efficiency and safety of rental properties and rooming houses in Victoria? Why or why not?

Mostly yes! It’s well past time that renters in Victoria were guaranteed better than a 2 star energy rated house which is basically a tent for thermal purposes.

Better energy ratings for rentals ensure that:

  • Homes are more affordable to run for some of the state’s most financially disadvantaged households
  • Renters have better health. Apart from just being humane, this means
    • Greater productivity – fewer sick days from school and work
    • Less drain on the public health budget – renters are more likely than landowners to rely entirely on public health services
  • We use less energy overall which reduces the risk of gas shortfalls in the years to come
  • We reduce our burden on the climate
  • Rental homes are more resilient in extreme climate events

Do you have any feedback on when the obligation for each proposed minimum standard will be triggered, as outlined in the proposed Regulations?

The introduction of triggers for different standards is well considered and fair enough. The best time to do this was years ago. The next best time is October 2025-October 2027. Or at the end of life of appliances.

Do you have any feedback on the proposed exemptions for the minimum standards, noting there are a range of exemptions for rental providers and rooming house operators, as outlined in the proposed Regulations and Regulatory Impact Statement?

The subordination of these standards to Body Corporate Regulations is a problematic exemption. In years to come this will likely result in slum apartment complexes with unliveable conditions, particularly on extreme weather days. There must be a way to work with apartment complexes and their bodies corporate to ensure that apartments are brought up to the same standards as other dwellings.

The exemptions for rooming house operators should be reduced to ensure that rooming houses, which provide homes to some of the most vulnerable residents in Victoria are of comparable energy standards as the rest of the housing market. This includes the provision of cooling and heating at maximal energy ratings. It’s not fine that rooming houses are not required to fit air conditioning.

What practical implementation issues / challenges might be associated with the proposed minimum standards? What steps should be taken to manage risks and challenges identified?

Acknowledging the consideration of supply constraints for three star heating systems, this policy could be coupled with incentives for manufacturers to scale up production of these systems to meet increasing demand.

These long overdue mandated upgrades risk landowners increasing rents – at a time when Melbourne particularly is one of the most expensive cities to be a tenant. We advocate coupling this policy with rental freezes to ensure that renters are not losing in rent increases what they gain in more affordable energy bills.

Do you have any feedback or any additional evidence on the potential outcomes or benefits that could be expected from the introduction of the proposed standards on renters, rental providers, rooming house residents, rooming house operators or the broader rental market?

In addition to the obvious benefits for renters and rooming house residents, there are a couple of policy measures that would help both providers/operators and tenants.

Currently renters do not pay service charges for water bills. This should be extended to gas and electricity bills so that renters are only charged for usage. This will incentivise landowners to disconnect gas to save themselves the nearly $1/day service charge to stay connected to gas. This benefits residents and the climate.

Requiring that all rental properties include an independent assessment of their energy rating when advertised/listed for rent will provide renters with an immediate understanding of what they’re moving into. It also ensures that the Victorian Government and broader community has access to useful information about the energy status of rentals statewide. Rental energy assessments should be undertaken on a state government subsidised basis with the balance paid by the landowner.

Understanding that this is a federal matter and therefore outside the terms of this consultation, the scheduling of rental property income to energy standards of each rental would incentivise improved thermal and energy efficiency values for rental properties. If a landowner offers a property with a very low energy efficiency standard they should be charged a higher tax bracket. Alternatively, landowners offering the highest efficiency home for rent should be charged the lowest income tax for their rental income. It would be great if the Victorian Government advocated for this to the Federal Government.

Or if you’re putting together a full written submission…

Link to the submission page


Preference for option 3B, being installation of insulation at R5.0 for all ceilings with no or low levels of insulation.

Properties that have some ceiling insulation but that has degraded or been shifted to create exposed areas of ceiling would not benefit from option 3A, which only identifies homes with no existing ceiling insulation.

We note that in-wall and under floor insulation is not captured in this RIS and believe that in the absence of any consideration to mandate wall or floor insulation that the highest possible level of ceiling insulation must be mandatory on leasing of a property.

Draught proofing

Advocate for option 4 to ensure that homes have the best thermal values possible. However, if this turns out to be unviable at the very least we urge the government to adopt option 3.

Anything less than option 3 is inadequate in our view because draughty window frames, skirting and floorboards, and leaky ceiling roses, heating and cooling vents can make a significant difference to the thermal values of a home, negating or dramatically diminishing the benefits of insulation of a building.

Hot water systems

Anything less than option 4 continues to lock gas in as a fuel source for water heating and is therefore unacceptable. This option represents the lowest running costs for households which is a priority of this submission.

Bearing in mind that hot water system replacement under the RIS is only mandated for end of the appliance’s life we believe that establishing the highest standard of efficiency as a requirement for hot water system replacement is the only sensible and acceptable option.

Heating and cooling

In rentals

We support option 4; minimum 2 star electric-only heating and 3 star cooling establishes the most comfortable and future proof options for householders in rental properties. Acknowledging that these provisions are only implemented at the end of life of appliances we support the requirement that cooling systems be installed with any new lease and advocate for these to be mandatorily split system air conditioners, which also act as heaters.

In rooming houses

We advocate for option 2 in this instance. Noting that this only applies from October 2025 for rooming houses without central heating units (and only at and of life for those serviced by central heating) we consider that the supply chain concerns can be addressed in the interim, particularly when considering the lower numbers of rooming houses compared to other residences across the state.

There are currently over 1000 rooming houses statewide which house some of the most vulnerable residents in Victoria. Their comfort should be a priority and the mandating of 3 star heating systems will make rooming houses more comfortable and cheaper to run.

Impacts on rental stock and rental market

We advocate for these changes to be implemented subsequent to rental price capping to ensure that rental prices do not jump following upgrades as required under the RIS. Rental prices have continued to skyrocket in recent years and it is important that in addition to being affordable to run, rental properties are affordable to lease in the first place, otherwise the benefits of improved appliances will not be felt by renters too scared to turn on heating and cooling or use hot water due to fear of energy bill shock.

Implementation and evaluation

We understand the logic behind the implementation dates of the regulations and the different standards therein. We consider this to have been carefully considered and sensibly determined.

In addition to information provided by CAV on their website we believe it should be a requirement that landowners are provided with information about the new standards and the Victorian Energy Upgrades program, as well as being provided with a rental provider hotline to help answer any questions about compliance with the new regulations.

Further, we believe that tenants should be provided with information about the new standards, what they can expect either at milestone implementation dates or at the end of the life of an appliance and information to help them access rental advocacy services where a landowner falls short of compliance.


Please be sure to write your submission in your own words and share with your friends! This is a very important reform for energy justice and the climate and it's important that everyone's voice is heard.


Thanks for being a fantastic contributor!

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