Proposed VEET Activity Regulation Changes - Nov 2015

Proposed VEET Activity Regulation Changes - Nov 2015

EECCA submission

EECCA is the peak body for businesses accredited and operating in the energy efficiency schemes in the NSW, Victorian and South Australian. We appreciate the work performed by the department and the opportunity to contribute to the discussion and decision making process and look forward to a stronger scheme and the ongoing engagement process.

3. Greenhouse abatement coefficients ...... 3

Modelling by Jacobs sets the coefficient 13% higher than previously and effectively reducing the amount of activity required to meet the target. .

We believe it is important to base the scheme on robust calculations and the only concern would be that less activity will be benefitting the Victorian community.

4.1. Schedules 7, 8, 9 and 10 – Space heating ...... 4

Tightened up due to technology improvements – EECCA supports these adjustments.

4.2. Schedule 21 – Lighting ...... 10

4.2.1 Schedule 21A - Installation of low energy GLS in place of mains voltage GLS

Basically trying to move to the LED variety by providing values for the longer life variety. Good.

4.2.2 Schedule 21C – Installation of low energy 12 volt lamp to replace 12 volt halogen

Retention of current values. No reduction see 21D.

4.2.3 Schedule 21D – Installation of mains voltage low energy downlight in place of existing 12 volt halogen downlight

Retention of current values. No increase so still very similar to 21C and yet providing a more efficient and longer lasting outcome. EECCA recommend consideration of increasing the difference to further encourage 21D over 21C as has been our position previously. It would be useful to be provided with the assumptions behind the values so that we may provide specific commentary.

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.

4.2.4 Schedule 21E – Installation of mains voltage low energy downlight with

GU10 base in place of existing halogen downlight with GU10 base. EECCA supports this addition.

4.3 Schedule 31 - High Efficiency Motor Replacing An Electric Motor

This activity should be provided more support but this change will not see act 31 creating anything more than a handful of certificates due to the continued use of MEPS as the baseline instead of a baseline which would more closely resemble the average energy efficiency gain.

This has been requested several times previously and ignored.

Given the potential of the business impact we would consider this an oversight (again).

4.4 Schedule 32 - Refrigerated Display Cabinet

No change really.

4.5 Schedule 33 - Refrigeration Fan Replacement

No change really and continues to be very low compared to the values claimed by the fan companies. Should be recalibrated to recognise real energy saving from a 24/7 365 day activity.

4.6 Schedule 34 - Commercial lighting

The primary changes to this activity are to

· Add variable hours of use to allow for differing building operating times alignment to NSW - Good

· Add the capability for non-building based lighting projects (eg street lighting) to participate

Good, this was an oversight.

Complexity of Act 34

Revision to Commercial Lighting

·  Commercial Lighting (Act 34) in Victoria is complex and carries a high compliance cost that is not commensurate with the risk of the activity itself. It needs to be simplified and also minor modifications made to reduce overheads where unnecessary (eg Allow the owner to sign over all certificates associated rather than wait until the end where the exact number is known and they need to be contacted again to sign it off. This adds no real value).

·  Lux reading requirement for standard one to one replacement should not be required.

·  Increase the size of small and medium jobs from 50 to 100 and 100 to 200.

Power factor – ballast and capacitor

EECCA also has an issue with lamp only replacements of fluorescent tubes where the ballast and capacitor are left in place. This causes a major problem with the Power Factor – reducing it from > 0.8 to <0.3.

Testing should be done and expert opinion sought as soon as possible.

Whilst the impact of poor power factor will vary from site to site, it is an established and precedented position to exclude activity creating such. The downlight is an example of this where they must achieve a min value of 0.72.

We believe that unless testing proves otherwise, this activity should be disallowed, thus requiring all ballast and capacitors to be bypassed.

This should be a high priority.

Emergency Lighting

Emergency, carpark and stairway lighting only gets a small uplift through application of an occupancy sensor control. This does not reflect the likelihood that this type of light in these areas are at the standby rate for the vast majority of time. A value of 0.8 could be applied to more accurately reflect the true energy efficiency value.

Lack of a Ventilation Fan activity – without refrigeration

It appears this activity has again been left. This should be an easy deemed value for application in carparks, stairwells, agricultural sheds, factories etc.

Yours Sincerely on behalf of EECCA

Bruce Easton

0417 568 918

Friday 1st May 2015