11 November 2015
Proposed VEET Activity Regulation Changes October 2015
Energy Policy and Programs,
Department of Economic Development, Jobs, Transport and Resources
GPO Box 4509, Melbourne VIC 3001
The Green Guys Group Pty Ltd Submission on Proposed VEET Activity Regulation
Changes October 2015
Dear Sir/Madam,
Thank you for the consulting with industry on the proposed regulation changes. The Green Guys are very
positive about the proposed changes and welcomes most as they stand.
We believe the timeframes for these amendments are timely and appropriate.
1.1 Company Background
The Green Guys Group Pty Ltd is accredited under ESS commercial lighting methodology since 2011. We have
created over 1 million ESCs under this methodology.
We are also involved in the VEET scheme and have generated over 200,000 VEECs in 2015 through registered
AP Wattly Pty Ltd under Schedule 21 and 34.
We envisage that we will shortly lodge our own application for Schedule 34 activities
1.2 Regulation Changes Feedback
1.2.1
Schedule 21 Changes
Schedule 21A - We support Energy Mad’s proposal for a 21A high efficiency and 25,000+ category
Schedule 21B –
We would to support the continuation of 21B due to the following reasons
 It appears main driver for removal was the lack of activity.
 Main issue historically was that CFL technology not being suited to this activity
 Recently suppliers have developed LED reflector lamps that are suitable for this activity
 It would appear that substantial opportunity for uptake is available with an estimated > 6 million
mains voltage incandescent reflector lamps in Victorian homes (E3 Residential Lighting Report)
 We suggest that Schedule 21B remain and the abatement factors are reviewed to consider greater
lifetime and efficiency now available with LED technology.
Schedule 21C – We support the proposed regulation changes.
Schedule 21E - We fully support the introduction of Schedule 21E to support the transition of GU-10 lamps to
high efficiency / LED lighting
1.2.2
Schedule 34
We fully support the addition of variable operating hours to the calculation of the abatement factor this
recognises the large potential savings that we not previously correctly incentivised.
We support the addition of streetlight lighting and freestanding lights on masts that was previously excluded
and have encountered this as an obstacle to doing lighting upgrades for outdoor car parks, and car sales yards.
Please ensure outdoor sports facilities are covered. It is not clear which section they would be covered under
and what would be suitable operating hours for those
Traffic Signal Lighting: 8670 hrs. In reality there is only 1 of the three signals turned on at any time so we’d
suggest that this figure should be at the standard 3,000 hours.
Retrofit Lamps vs Modification of the Luminaire
In general we support the existing regulations in relation to retrofits and modifications. We see both as
excellent opportunities to unlock low cost abatement. We have performed in excess of 200,000 fitting
upgrades using these methods that have delivered good results from all aspects of efficiency, saving and
safety.
Retrofit Lamps: There have been some suggestions that the ability to install T8 LED lamps in a retrofit fashion
(starter only) should be removed from the scheme. We’d strongly recommend any changes to this involve a
detailed study of the claimed negative impacts of the tubes and if any changes are required then a suitable
period of at least 12 months adjustment (for stock and forward contract positions) should be provided (for this
and any other products change).
We support the existing limit of a 30,000 hours lifetime for lamp only replacements (eg T8 LED and MR16) as it
stands and not altering this for variable operating hours.
We support the existing asset lifetime of 10 years (under variable operating hours) where either lamps are
installed using the modification method (bypassing the ballast and removing the capacitor) AND also where a
full luminaire replacement is performed. This rewards the more permanent upgrade.
Ben Henderson
Managing Director
www.greenguys.com.au
Sydney: 2/176 Euston Road, Alexandria, NSW, 2015
Melbourne: 95 Munster Terrace, North Melbourne, VIC, 3051
Ph. (02) 95574441 Fax. (02) 9557 4443 M. 0403 043 103