9 July 2013
Dear Mr Blowers
Review of the Energy Saver Incentive scheme
Following are Lighting Council Australia's comments on the scheme.
About Lighting Council Australia
Lighting Council Australia is the peak body for Australia's lighting industry. The Council represents manufacturers and suppliers of luminaires, control gear, lamps, solid state lighting and associated technologies. A number of our members have supplied lighting products under the ESI.
Fast moving pace of lighting technology
Lighting technology is evolving rapidly, particularly in the areas of solid state lighting and lighting controls. In the context of administration of the ESI it is important that the Department is aware of such developments. Awareness will assist in adapting the scheme as technology develops. For example, LED tubes are improving in efficiency and efficacy and should be considered for admission to the scheme. They are presently excluded due to inefficient or poor quality earlier versions being supplied.
There have been extensive developments in lighting controls in recent times. Modern lighting controls have the potential to improve efficiency by 50% over a non-controlled space. Consequently the ESI scheme would be enhanced by incorporating this technology.
It is recommended that the Department consult regularly with Lighting Council Australia to facilitate understanding of technology change in the lighting industry.
Harmonisation of energy savings schemes
It would greatly assist industry if harmonisation could be achieved among energy efficiency incentive schemes administered by Australian jurisdictions. This particularly applies to Victoria's ESI scheme and NSW's Energy Savings Scheme managed by the Independent Pricing and Regulatory Tribunal. While these schemes have similar objectives, the processes and requirements for registering products are very different. This causes unnecessary duplication of effort and discourages participation.
It is recommended that jurisdictions work towards a high degree of harmonisation in the administration of their respective energy efficiency incentive schemes.
The cost of compliance with ESI requirements is a concern. For example, one of our members markets a range of interior LED downlights that are certified under Lighting Council Australia's Solid State Lighting Quality Scheme. The products are fit for purpose and comply with all Australian safety and EMC standards. However the same products do not qualify for the ESI scheme because of a requirement for a higher onus of proof such as test reports from a NATA-accredited laboratory. The cost of this supplementary documentation is high - in the order of $5,000-$8,000 per product. This company has its own very capable lighting laboratory but its test reports are not accepted.
LEDs have short life cycles - in the order of 6 to 12 months. The implications are that new testing has to be done and new documentation submitted on a frequent basis. Issues related to compliance costs, duplication of effort and the need to address different jurisdiction compliance requirements under a short life cycle have been raised by many Lighting Council members. As a consequence some have elected not be part of the ESI scheme.
It is recommended that scheme compliance requirements be reconsidered and costs lowered, particularly for products such as LEDs with a high technology refresh rate.
Electrical Equipment Safety System
The new Electrical Equipment Safety System, initiated by the Electrical Regulatory Authorities Council, will be adopted by Victoria on 1 January 2014. The Scheme's features include improved electrical safety, public visibility of suppliers on a common database and complementary Australian Communications and Media Authority compliance marking requirements. The EESS is strongly supported by industry.
It is recommended that registration of suppliers (and, if applicable, registration of product) under the Electrical Equipment Safety System become a prerequisite for registration under the ESI scheme.
Recycling decommissioned lamps and the FluoroCycle scheme
Lighting Council Australia currently manages the national FluoroCycle scheme, a joint initiative of the Commonwealth Government and industry to increase the recycling rate of waste mercury-containing lamps. The scheme targets the commercial and industrial sectors where the bulk of waste lamps are generated. Lamp recycling can help reduce the amount of toxic mercury being sent to landfill. FluoroCycle was developed as part of the National Waste Policy and is supported by the Council of Australian Governments. The Essential Services Commission, Victoria recently became a Signatory to the scheme. The ESI Guidelines currently require APs to provide proof that recycling of decommissioned lamps has been carried out. Many APs have also applied as Signatories to the FluoroCycle scheme.
Lighting Council Australia strongly encourages the requirement for APs to recycle decommissioned lamps, particularly mercury-containing lamps, to remain in any revision of the ESI guidelines.
Chief Executive Officer
LIGHTING COUNCIL AUSTRALIA
25 Bentham Street
Yarralumla ACT 2600
ACN 130 217 613
PO Box 7077
Yarralumla ACT 2600
Tel +61 2 6247 8011
Fax +61 2 6162 3457
Page last updated: 24/06/20