Rental Housing Warrant of Fitness

[Ian McChesney]

Hi
With Wellington City Council formally launching its rental housing WOF service, and other councils looking at replicating, a number of participants in this forum will be actively involved as assessors or advisers to landlords and tenants.

I have looked at the app that provides guidance on how the criteria for the WOF will be assessed. Focusing on just the three core components of a healthy home – insulation, heating and ventilation/moisture control – it’s not at all clear to me that achieving the standards in the WOF will provide tenants with the assurance that the physical attributes of the house/dwelling meets conditions necessary for a healthy home.

Insulation – where insulation cannot be installed because of access issues the insulation is considered non-assessable and is deemed to pass. There are no additional requirements to provide compensatory measures, such as additional high efficiency heating capacity. Or, seemingly there is no formal ability to note such deficiencies on the WOF certificate. I find it extraordinary that such houses could simply earn a pass for insulation in such circumstances.

Heating – the assessment criteria states the house must contain “an adequate form of safe and effective space heating”. A heating appliance is to be located within the main living area, and if the house is more than 50m2 the heater must be fixed; if less than 50m2 a plug-in heater is deemed adequate. Unflued gas heaters or open fires do not comply.
It is unclear what form of fixed heating would be deemed adequate because no specific criteria are set out in the app – there is no reference to the EECA guide for heat pump sizing, for example. I also note that the criteria do not specify a requirement for “efficient” heating, which presumably means that fixed panel heaters and the like would be deemed sufficient? The seeming lack of efficiency and capacity criteria in my view inevitably means that some houses passing the WOF heating criteria will lack heating capacity and will not be able to be heated adequately in an affordable manner.

Ventilation/moisture control – it is not a requirement that the two primary wet areas, kitchens and bathrooms, have extract ventilation, except in cases where an opening window is not available. In my experience simply having an opening window is not sufficient to properly provide for moisture control in these wet areas.

In relation to bathroom ventilation the app states that the scope of the WOF is to check that the house is able to be ventilated; it is not a test of tenant behaviour re appropriate use of windows or fans. Presumably this same principle would apply more broadly as well e.g. to heating. But I would argue that the physical attributes of a house very much influence occupant behaviour. If windows are the only option for wet area ventilation they are likely to be under-utilised in cold weather. If fixed heating is too costly to run – for example panel heaters costing 30-35c per effective kWh compared to a reasonably efficient heat pump at about 10 cents per effective kWh – then it will be under-utilised and the home will remain cold.

Of course, providing a higher quality of physical amenity such as extract fans and a heat pump cannot guarantee appropriate use either. But I would argue the chances of achieving warm, dry and healthy homes are greatly enhanced, especially alongside other actions such as education/behaviour change.

The WCC website states that “the Rental WoF gives landlords the chance to promote their property as being warm and dry, and gives prospective renters an assurance that the home they are looking to live in meets the standard”. My concern is that, on the face of it, the current criteria are simply insufficient to provide this level of surety.

However, I appreciate that I am at arms length from this project so I may well be mis-informed or ignorant about how the WoF criteria will be applied in practice. I would welcome the views of those that have a direct involvement.
Ian

Ian McChesney

Add New Note to this Reply

[Author]

Posts