House Energy Rating - Controversies

Controversies

• The rating system does not consider factors such as sustainable materials, embodied energy, electricity sources, rainwater capture, local vegetation and access to public transportation.
• Some say that Carbon emissions would be a better metric to use compared to raw MegaJoules of Energy consumption.
• Inaccurate representation of the building in the software can result in an inaccurate assessment of the building's thermal performance. An unskilled or inexperienced assessor can easily make incorrect asssumptions. Some states require in-depth training & accreditation for all assessors before they are considered qualified to use the software, while other states merely highly recommend (but not require) in-depth training & accreditation.
• While not a fault of the software itself, a building is often not constructed as drawn on the plans and some items (weather sealing, insulation values, window coverings, paint colours, etc.) are often different from what was originally simulated. In other unintentional cases, items are installed but are installed incorrectly in a way that compromises their thermal performance (such as foil-based insulation without an air gap).
• In rare cases, certain styles of buildings in certain climates have become very difficult to comply without using expensive materials (such as a house on the side of a hill with solid glass walls along three sides, to provide ample viewing of the natural scenery). While most buildings can still find a solution without any major design alterations, sometimes this is only possible with expensive materials and this drastically increases the price of the house. This is usually an indication that the building was designed with aesthetics taking a prominent position over the comfort & livability of the occupants.
• The rating system does not deal with problems beyond a single household such as urban sprawl, city planning, etc.