Setting Future Victorian Energy Efficiency Targets Ecovantage submission



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Setting Future Victorian Energy Efficiency Targets

Ecovantage submission


Ecovantage appreciate the opportunity to contribute to the discussion and decision making process and look forward to a stronger scheme and the ongoing engagement process.

The preferred level of the new VEET target;


Ecovantage supports the setting of targets for 5 years as it provides a greater sense of certainty than the current 3 year approach.

We believe that the VEET scheme is an excellent instrument for the government to undertake a significant transition within the Victorian economy. By supporting energy efficiency the government is helping households and organisations strip waste energy from the economy. We will be more efficient more quickly with a successful VEET scheme. The nett flow on effect of that through the entire economy should be very positive.

Ecovantage supports a large target to drive productivity and savings.

The modelling shows a nett benefit at 6.9 million and we would support this target in the absence of a larger one.



We believe that the modelling relies on the activities and these activities need to be adjusted. If these were adjusted the modelling could easily support a larger target. A bit of a catch 22 so in the absence of that, we will support the largest target modelled.

Opportunities for greater participation by different sections of the community;

Low income


  • The VEET has always supported low income well and would be expected to continue to do that.

  • Mandatory disclosure of building efficiency at time of leasing would be beneficial but outside of the scope of VEET.

We currently work in SA and deliver the mandatory percentages of REES Gj from ‘Priority Customers’ and the assessments. We do not have much of an issue in this regard although there may become a stratified price for the Gj. Not sure this is a problem or whether it would just be another thing to trade in Victoria. Certainly there is a small overhead in managing these separately.

Farmers


Agri-businesses have under participated in the scheme to date and need pumps, compressors, fans as well as lighting to start participating in any significant manner.

Industry


Large businesses will benefit from being involved in the scheme via

  • Project Based Methodology – adopt NSW methodologies and look to a third party engineering institution to support it.

  • Deemed high efficiency motors adjusted to replace MEPS baseline

  • Deemed fans and pumps.

  • Lighting upgrades

Small businesses and organisations:


Café’s, restaurants, local accountants are numerous and are yet not well represented as the number of lights and appliances are too few to make it worthwhile to an AP/ACP. It is noted that Commercial lighting rules are relaxed somewhat for these customers.

Introducing new energy efficiency activities, and revising existing activities;

More flexible rules and regulations


  • Move the activities and abatement values out of legislation into rules so that the department can make adjustments more easily whilst recognising the compromise between this and stability.

Insulation:


  • Strict compliance in a similar manner to SA.

  • SA scheme looks likely with reasonable values but may struggle at VEEC rates.

  • Danger of including the activity but having certificate value set too low (SA at $40 equivalent) to generate activity – like double glazed windows..

New build for lighting – greater than 6 star


  • Will need to be at developer level.

  • This may be better off being delivered through the existing framework by reducing the watts per square metre in the building code.

Air conditioners


  • yes but only high efficiency – possibly with movement controllers and similar?

  • Note that Air Conditioning in SA under REES has such a small value it will be unlikely to be used.

Ventilation fans.-


  • The rules also need to be able to handle the replacement of fans/motors with one that produces less power but equal air flow. The issue is manly that quantity of air flow is the required outcome rather than power. Air flow should be the metric used.

  • Suggested – where the installer is a registered refrigeration mechanic, a fit for purpose statement would suffice. Currently it requires a matching power output range which does not cater for more efficient air movement through improved fan technology.

Halogen down light replacement


  • (21C and D) should be rerated to reward the more efficient, higher life expectancy and more permanent 21D.

  • The introduction of the sealed flat panel down light should also be given a higher value due to the reduction in uncontrolled air movement. The older style fittings have gaps to allow air flow.

  • This should be done asap with a 3 month minimum adjustment period.

HE Motors


  • the use of MEPS as a baseline is the issue and not a baseline some 20% less being a more realistic approximation of the actual average in the field.

  • certificates only available if the motor being replaced was still usable and it is to be decommissioned – therefore excluding the replacement of broken motors. This would cater for additionality concerns.

Controllers –


  • lighting, fans, VSD’s and so on. A little difficult to deem accurately but should be included as significant efficiencies can be gained.

Peak demand –


  • some activities like cooling, have a reasonable correlation to Peak demand and could be further supported using a simple multiplier to reflect the added value of efficiency in peak times. Ie Air Conditioning.

Project Based Methodologies:


  • align with NSW.

Setting priorities for improving the VEET scheme.

Rules removed from regulation:


  • Remove the requirement to change the regulation when changing specific rules associated with activities. This will allow the scheme to be more flexible and overall will strengthen the scheme.

Product registration:


  • Recommend the adoption of the NSW Commercial Lighting methodology including product registration.

Align the Commercial Lighting activity with NSW


  • It is very strange that you can have such a variation in values being provided by the two schemes for the same activity.

Reduce the complexity of the Commercial Lighting activity


  • The current Commercial Lighting compliance requirements add to the cost of undertaking the activity without a commensurate improvement in risk reduction. Adopt NSW approach to align with SA and NSW.

  • Allow the owner to sign over all of the certificates associated with the job rather than wait until the end where the exact number is known and they need to be contacted again and sign it off. This adds no real value.

Mandatory Disclosure:


  • Mandatory disclosure of house efficiency and Nabers ratings at time of sale or lease is aligned to taking action on energy efficiency. The assessment of the building could be supported by the VEET scheme.

  • EECCA recommends that this measure is included.

Advisory/Steering Committee:


  • Setup an advisory committee for VEET with representation from the following:

    • Social Services representative (ACOSS or Brotherhood),

    • Industry and Commerce (AI Group or similar)

    • Property incl – housing (PCA)

    • Energy Efficiency industry (EEC)

    • Energy Retailers (ERA)

    • Scheme participants (EECCA)

    • Department and Administrators

Yours Sincerely on behalf of Ecovantage

Bruce Easton

0417 568 918

Bruce.Easton@Ecovantage.com.au

13-May-15


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