8 July 2013
Review of Energy Saver Incentive : Issues Paper - June 2013
Department of State Development, Business and Innovation Regulatory Impact Statement
NECA Victoria Submission
Response, comment and input into the review of the ESI including alternative policy options, associated costs, benefits and effectiveness of the scheme.
Overview - NECA
The National Electrical and Communications Association (NECA) is the peak national industry association representing contractors responsible for the delivery of electrical, voice and data communications in Australia. In Victoria, NECA hasapproximately 1250 businesses as its members which employ close to 30,000 people.
NECA represents its members' interests on important matters that affect their businesses and actively works on behalf of members with a range of government departments, industry associations and other peak bodies.
Where NECA has limited activity or involvement directly in the scheme the enclosed commentary is targeted at specific topics addressed in the RIS.
NECA appreciates the opportunity to provide input and comment into the future of the scheme.
Key Issues for Consideration
1. Barriers to the uptake of energy efficiency areas
NECA recognises the requirement for energy efficiency incentives in the market and maintaining an approach consistent with consumer sentiment to provide avenues for GHGE reductions as a method of action against the effects of global warming.
For some time, NECA has supported the position detailed by the International Energy Agency Report - Redrawing the Energy Climate Map which, in part, estimates GHGE can be reduced by 10 per cent at no net cost by ensuring compliance to currently established energy efficiency standards (Part J of the Building Code of Australia), maintaining minimum design performance standard in accordance with Green Star Design Certification via the Green Building Council of Australia and monitoring / reporting building energy efficiency via the National Australian Built Environment Rating System (NABERS).
By ensuring compliance in the market to minimum performance standards several benefits are achieved.
1. By maintaining a level playing field the information delivered by industry practitioners to stake holders and end users takes on a consistent theme delivering a degree of comparable transparency and imparting confidence that the content / information / advice being provided is trustworthy and accurate.
This, in part, addresses end user information gaps associated with access to and availability of information. The successful delivery of these outcomes requires a level of expertise and skill upgrade across the industry. NECA is uniquely positioned to provide training and resources to the market in all aspects of electrical efficiency compliant with outcomes detailed in the various Schedules of the ESI Scheme.
A NECA initiative, EcoSmart Electricians provides accreditation to electricians who have successfully attained qualification through the training scheme. The program maintains registration on the NTIS. An EcoSmart Electrician is deemed competent above that of a qualified electrician where expertise
is gained across the entire spectrum of electrical energy efficiency measures.
By engaging the resources of an EcoSmart Electrician consistency of information imparted to end users is maintained in conjunction with best practice delivery of goods and services.
2. Compliance to minimum performance standards removes market inconsistencies where end users and consumers perceive conflicting information via poor quality or non compliant product offers and specification. The race into the gutter with lower priced product, parallel import or non compliant product not only raises serious safety implications but drives reputable providers into alternate practices to compete. The outcome is end user confusion and suboptimal uptake of energy efficient product.
The independent market position of NECA allows for the impartial dissemination of information and education along with access to business decision makers with credible comparative information and assessment.
The key aspect to maximisation of uptake of energy efficient practices relies on the dissemination of quality education outcomes removing doubt and providing market confidence the decisions made and money invested will result in
beneficial outcomes. Pathways to these results can be gained through utilisation of electricians via the EcoSmart program.
Evidence gained from electricians through the Department of Planning and Community Development "Light for Living" training program indicates compliance to relevant standards and codes of practice pertaining to energy efficiency compliance are either inconsistent or non existent.
Adoption of practices by the Victorian Building Commission ensuring legislative compliance to energy efficiency measures would create the base for consistent industry outcomes. A compliance regime such as this would drive the uptake of demand for various ESI services.
2. Performance of ESI to date
Activities associated with Schedule 21 and Schedule 34 require a high degree of performance compliance to ensure achievement of minimum performance standards. NECA is aware of some industry concern relating to the scheme's high regulatory compliance requirements of some types of lighting technology, mainly in the emerging technology sector of LED product. Where aspects of the compliance regime come under the ire of AP's for excessive testing and documentary requirements these minimum performance requirements have to be maintained to ensure performance and quality outcomes are delivered to the end user.
Failure to maintain a high standard of product and design compliance poses very real risks associated with the safety, performance and quality aspects of an installation. NECA endorses these standards to ensure quality outcomes and risk minimisation for end users and the scheme's operation.
Potential aspects that can be identified affecting Schedule 34 activities in commercial lighting applications relate to the correct establishment of the base energy load and design criteria for the allocation of the quantity of VEEC's on a project. In addition, adequate training and experience is necessary to ensure correct design principles are adopted to ensure compliance with minimum performance standards associated with the quality outcomes of a lighting installation.
Verification of base energy load, design criteria, light planning application and post installation verification should require mandatory sign off by suitably trained practitioners. Qualified members of organisations such as the International
Association of lighting Designers (IALD), The Illuminating Engineering Society (IES) and electricians who have, as a minimum, achieved EcoSmart
accreditation are examples of persons suitably qualified to undertake such
3. Looking Forward: The future scheme from 2015
As the scheme continues opportunity for carbon abatement via activities targeting simple solution, low cost residential outcomes will diminish. Substantial opportunity exists in the residential sector for upgrade of low efficiency Tungsten Halogen Low Voltage (MR16) downlight lighting to LED lighting.
Low cost "give away" solutions such as those currently operating in the light globe to CFL arena require EXTREME care and scrutiny when an LED solution is considered. Based on 2013 technology low cost LED solutions pose a serious safety, equipment maintenance and lighting outcome performance risk. High
performance standards have to be maintained within the scheme to ensure successful outcomes in this area.
Reliable industry estimates rate the number of Low Voltage MR16 lamps currently in service in Victoria to be approximately 40 million across residential and commercial installations. The potential energy saving through the conversion of 50 watt lamps to current technology LED of 12 watts is substantial approaching up to 2 GWh.
Based on current LED technology, a low cost "give away" solution is not financially viable for residential applications. Future technology development will alter this position. As LED technology advances solutions for residential applications and more so Schedule 34 commercial activities will evolve.
Substantial opportunities exist in retail, commercial and industrial applications for future LED technology.
In addition to LED lighting consideration should be given to Photo Voltaic (solar) and solar hot water activities. Where current technology restricts performance outcomes limiting VEEC viability future advances will resolve this situation.
While this submission relates to a small number of specific topics associated within the ESI Scheme, NECA maintains the opinion key areas for ongoing success and viability of the scheme should focus on the minimum training requirements necessary to establish base knowledge of practitioners and AP's associated with the scheme. For the specialised criteria of commercial lighting activities within Schedule 34, design should be undertaken by specifically trained practitioners and EcoSmart certified electricians should be recommended for installations activities and commissioning.
Via NECA Skills, an industry recognised RTO, training in all the above design and installation criteria can be provided and should form the base level for any AP activity.
NECA would welcome the opportunity to address any of the aspects discussed in this submission in greater detail. Thank you for considering our submission and we look forward to hearing from you in the near future.
Manager EcoSmart Electricians
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