Submission to the Proposed Residential Tenancies Regulations

Download Submission to the Proposed Residential Tenancies Regulations for insulation and smoke alarms (PDF, 490KB)

The Salvation Army welcomes that an aim of the current tenancy law changes are “to make homes warmer, drier and safer for hundreds of thousands of New Zealand families.” We therefore support aspects of these Regulations that seek to create minimum housing standards.

However, The Salvation Army believes that the proposed regulations do not go far enough to provide tenants with secure, safe and healthy housing. In addition to specific comments below in response to the consultation document, it is our submission that:

• The insulation standards currently recommended are too low, outdated, and seemingly ignore the current recommendations of the Energy Efficiency and Conservation Authority (EECA).
• The Regulations create too many exceptions that have the potential to undermine the overarching aim of making homes warmer, drier and safer for hundreds of thousands of New Zealand families.
• The Regulation’s exceptions are underpinned by an unrealistic voluntary compliance model and fail to require landlords to improve warmth and dryness standards in alternative ways.