Applicant details
Date of submission11th December 2015
Company name
Brotherhood of St. Laurence
ABN/ACN
24 603 467 024
Warehouse 6, 2 Judge St Sunshine 3020
Contact person details
Christine Sammut Senior Manager Development and Growth
Social Enterprises
9474 7830 0404 495 162
Summary of proposal
Amendment to schedule 19 Destruction of Refrigerator of Freezer
Amend destruction date from 1996 to 2005
Household refrigeration paper 3:MEPS3 in Australia and NZ- preliminary Impact assessment of New MEPS levels in 2015. Refer to pages 1, 29 & 30
Residential Energy Baseline Study: Australia. Prepared for the Department of Industry and Science on behalf of the trans - Tasman Equipment Energy Efficiency (E3) program. August 2015. Refer to page 5
Lloyd Harrington, Energy Efficient Strategies, A2SE Summer Study, Sydney Feb 2013. Refer to slides 4 & 5
AS/NZS 4474.1.2007 Performance of household electrical appliances and refrigerating appliances.
AS/NZS 4474.2.2009 Performance of household electrical appliances and refrigerating appliances. Part 2 Energy labelling and minimum performance standards
Amendment to schedule 19 Destruction of Refrigerator of Freezer / Provide generic category, not the name of a particular product.
Example: Thermally efficient windows, rather than a proprietary product.
For proposed amendments to existing activities, identify the current activity within the Regulations.
Confidentiality statement
The Submission is not confidential
MUST BE COMPLETED
In lodging a submission, parties acknowledge the Department's right to engage consultants and contractors to assist in the assessment process, and to disclose information (that might otherwise be identified as confidential by a party) to such persons for those purposes. / The Department will list on its website (at minimum) the category of all activities submitted and the name of the submitting party.
If any part of this submission should be treated as confidential then please provide two versions of the submission, one with the confidentialinformation removed for publication.
Clearly identify all confidential components of submission or state that the submission is not confidential.
Briefly describe new or amended activity Max 100 words
Significant improvements have been made for energy reduction in fridges from 1993 to 2005.Fridges are one of the highest energy users in households. Appliances make up for 25% of energy use for the average household .
The introduction of stage 2 to the MEPS, delivered significant increases in efficiency standards for fridges and freezers which are reflected in the updated standards of 2007 & 2009.
Assessment of fridges and freezers would be conducted utilising;
1.Manufactures product information.
2. Use of the refrigerant R12- used in the 70's and 80's, and refrigerant R 134a - used since 1990 to replace R12.
3. Energy saver website
Estimate the average annual energy savings for an average installation of that activity
Savings would be the same as the existing calculation.
/ Submissions should establish the basis for the claimed savings:
- describe the average installation, including applicability to residential and/or business sectors.
- explain how this activity should be rewarded through the proposed calculation under a deeming or project based approach.
- Provide supporting evidence that the proposed savings are likely to be achieved in an average installation.
Demonstrate that the activity is likely to be additional to business as usual (BAU)
Inefficient fridges/freezers are being removed from use to be degassed and scraped. The consumer is replacing this with a new efficient model manufactured under the 2007/2009 standards. / Consider the BAUuptake of the activity and how the savings are additional to the BAU uptake (eg through a correction factor if required).
Consider whether the energy savings proposed are likely to be reduced by behavioural factors such as potential for removal of the product or increased use of other devices.
List the key variables that should be considered to ensure the activity best represents the delivered energy savings
The product life of a well maintained fridge is 14 - 17 years.
Fridges that run on R12 gases are less energy efficient than R134a. In turn, fridges that run on R134a are less efficient than R600a (by about 7%). As demonstrated by the graph, the newer model fridges are getting more and more efficient. / Variables may include fuel type, relative product efficiency against similar products, product life, climate zone, type of business activity, usage of products, or human behaviour.
List all existing product standards which support the claims for energy savings or related matters
AS/NZS 4474.1.2007 Performance of household electrical appliances and refrigerating appliances.
AS/NZS 4474.2.2009 Performance of household electrical appliances and refrigerating appliances. Part 2 Energy labelling and minimum performance standards / Describe existing standards that underpin quality assurance and/or performance. These could be Australian Standards, recognised or widely used international standards, or standards and tests used as the basis of certification schemes in Australia or other countries.
Where defined standards do not exist, discuss how quality/performance expectations can be validated, e.g. provide a proposed outline of a standard approach for assessing the energy performance of the activity.
Ensuring savings are valid
Continue with the existing paperwork requirements with verification required from consumers.
Assessment of fridges and freezers would be conducted utilising;
1.Manufactures product information.
2. Use of the refrigerant R12- used in the 70's and 80's, and refrigerant R 134a - used since 1990 to replace R12.
3. Energy saver website / Consider how installation of the activity can be verified and how a robust compliance regime can be assured, whilst minimising red tape and administrative burden.
Protecting health and safety
Continue with existing requirements / Note any safety or occupational health and safety issues generated by the activity.
Identify any options to address these issues, e.g. consider relevant training, qualifications, licensing or certification relevant to the proposed activity including any (proposed or existing) mandatory requirements.
Other benefits and issues
Removal of inefficient fridge's also has the added benefit of removing CFC's and HFC's from the environment. HFC's were ceased to be used in fridge production in 2012 due to the greenhouse impact.
A reduction of fridges and freezers to landfill. Once degassed they are sold for scrap metal. / Evaluation will consider the demonstrated potential for significant uptake of the activity in Victoria and broader benefits. Supporting evidence of benefits should be provided such as:
- The estimated cost of implementing the activity (capital and installation costs).
- The estimated total number of installations possible in Victoria annually.
- Potential for product or service innovation, or industry development, including likely investment or employment creation.
- Consistency with similar schemes in other jurisdictions