Project Based Assessments
VEET Scheme
October 2015
Prepared for:Energy Policy and Programs - DEDJTR
Prepared by:Ian Johnson, Manager EcoSmart Electricians
29 November 2015
Proposal number:20151129 PBA
Background and overview
Objective
NECA is fully supportive of the introduction of Project Based Assessment within the framework of the Victorian Energy Efficiency Target (VEET) administered by the Essential Services Commission.
Where the existing VEET program under the deemed methodology is an excellent example of policy targeted at state energy reduction and carbon abatement the prescriptive method of deemed implementation has limitations when more complex and larger projects are considered.
The NECA objective and goals across industry is the promotion of growth, implementation of technology and excellence in practice of implementation. Under the deemed methodology and requirement for product / process approval / testing and registration, a mandatory necessity of deemed activity, the process places restrictions on some broader application of technology / product implementation and flexibility.
Where we do not want to see any relaxation of quality / performance standards of product under the current product registration system used in VEET, we do see a necessity for flexibility in the use and application of emerging innovative products and practices of implementation.
Project Based assessment is the opportunity for the introduction of such applications.
Quality and Performance Verification
The immediate obstacles we see for the successful implementation of PBA activity is the lack of suitably trained and skilled practitioners in industry capable of providing the required level of independence and technical evaluation for PBA activities.
For all PBA activities the evaluation and submission requirement would be the verification and sign off by a qualified Certified Measurement & Verification Professional (CMVP) or Certified Energy Efficiency Specialist / Leader (CEES)/CEEL) under the International Performance Measurement and Verification Protocol (IPMVP).
Standardisation and harmonisation of this practice in line with the NSW ESS and ERF would be highly beneficial to ensure there is no unnecessary duplication of training, practices or requirements.
Sufficient time would be necessary to allow for industry to establish and implement the required training framework to provide the CMVP / CEES/L training.
NECA under its Education and Careers framework of RTO status would be capable to delivery independent training and validation of qualifications.
NECA supports the proposal where PBA submissions are made by either;
- Existing AP who employ a qualified Certified Measurement & Verification Professional (CMVP) / Certified Energy Efficiency Specialist / Leader (CEES)/CEEL). (NOTE: Under this model separate evaluation by the ESC would be a necessary step to ensure independence of the process)
- Via 3rd party independent assessment by a IPMVP professional engaged by an AP for the project
In either case it would be a mandatory requirement to have professional independent assessment of the project.
As lighting activity features highly in the current base of VEET creation, it is our expectation that the initial phase of PBA will gravitate towards that sector of the market. Our initial review of the IPMVP qualification (additional assessment in this area is necessary) is the training and background knowledge in lighting application requires additional expertise and industry experience. Consideration should be given to an alliance with the Illumination Engineering Society Australia and New Zealand (IESANZ) for the provision of specific lighting expertise.
Operational Verification
In line with the current VEET activity evidence based procedures the ESC should continue to administer this process under the PBA model. In the case of outcome reporting over extended time periods the ESC should rely on reporting process and evaluation of performance from the project CMVP via measurement, commissioning reports, site inspections / evaluations and geotagged photographic evidence.
Included in this reporting process should be the provision of NMI Meter data (Smart Meter) into the process to verify the energy saving achieved.
In the case of extended time frame projects consideration should be given to the requirement of the initially appointed CMVP being assigned responsibility of reporting for the life of the project.