Response to VEET Proposed Activity Regulation Changes 2015
Green Energy Trading welcomes the opportunity to respond to the VEET Proposed Activity Regulation Changes.
About us
Green Energy Trading is one of Australia's largest environmental certificate agents, and is committed to making incentives for renewable energy and energy efficiency activities more accessible to Australians.
Green Energy Trading was established in 2007 and supports its clients in accessing incentives available through market mechanisms, including the NSW Energy Saving Scheme (ESS), the Energy Saver Incentive (Victorian Energy Efficiency Target) and the federal Renewable Energy Target.
Green Energy Trading is a registered agent that creates, purchases and trades environmental certificates for customers of solar PV, solar hot water, small wind and other renewable energy, efficient lighting and other energy efficiency projects.
Green Energy Trading became an Accredited Certificate Provider (ACP) of the VEET scheme in 2009. As an independent agent we create, purchase and trade VEECs for households and businesses that have chosen to upgrade to eligible products.
In addition to certificate creation, a large part of our involvement in the VEET scheme has been as a knowledge leader providing education and information on the VEET scheme and how it works to end consumers and installers. We have also worked with the Energy Efficiency Certificate Creators Association (EECCA) and the Essential Services Commission (ESC) on compliance issues that improve scheme integrity.
Green Energy trading is encouraged that the Victorian Government is keen to implement positive changes to the regulations but feel that the failure to provide the detailed methodology and calculations behind the abatement factors (particularly around Schedule 21 activities) constrains our ability to provide feedback and does not enable an informed debate on some of the issues.
Schedule 21 - Incandescent Lighting
The abatement factors for schedule 21C and 21D in VEET are considerably higher than those for similar activities in the NSW and SA energy efficiency schemes. Green Energy Trading advocates for the calculation methodology for these activities (and all other activities) to be released so that a level of transparency and consistency regarding the proposed changes is available.
It appears from the limited information given in this consultation that the reason for the higher abatement value is the use of an asset lifetime of up to 30,000hrs where as in both NSW and SA, the maximum asset lifetime is limited to 10,000 hours.
Schedule 34 - Commercial lighting
Green Energy Trading supports the inclusion of variable operating hours to allow for differing building operating categories for appropriate lighting upgrades and believe that this will stimulate increasing creation of VEECs for this activity, particularly in the retail and manufacturing sectors.
The management of this additional variable will be an important task for the ESC, in order to avoid rorting but provide fair values which appropriately represent energy savings for each particular site. A reasonable amount of guidance will be required for buildings that do notlogicallyfit into any of the building class categories and space types as defined by the BCA.
Green Energy Trading does however;questionwhether the activity of installing T8 LED tubes and bypassing the ballast is an appropriate lighting upgrade that should warrant additional operating hours beyond the default 3,000 hours per year,mainly due to concerns over safety of installations and power factor issues which are not widely understood. In addition, the T8 LED tube was designed to be a temporary retrofit solution, not a permanent solution and therefore should not be treated as one for the purpose of VEECs. If installers wish to install T8 LED tubes as a permanent solution and claim VEECs, the NSW ESS scheme practice should be followed where by the whole luminaire with LED tubes already installed is tested and approved under VEET as a complete product and then installed as a full luminaire upgrade.
Green Energy Trading supports fair changes and enhancements to the VEET and would be pleased to discuss the above comments further should the department require.
Yours sincerely
Caroline Robertson
Energy Efficiency Manager
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