1. What should the new VEET target be?
Other
Other (please specify a target and length):
[Required if 'Other' selected] *
6.9Mt/yr CO2-e for 5 years
1a. Please outline why you prefer the
target you identified, or why you selected
"No response":
I have been advised that modelling and
subsequent analysis undertaken for the
Review shows that the maximum net benefits
are delivered when there is a target of 6.9
Mt/yr CO2‐e for a period of 5 years. If this is
correct, the target should therefore be set at
6.9Mt/yr for 5 years. In addition, the
legislation should allow for the target to be
reviewed upwards following the Climate
Change Act Review (which will set an
Emissions Reduction Target for Victoria), but
not allow for any downwards revision within
the 5 year period.
2. Comments are invited on the modelling
approach used to determine the costs and
benefits of the VEET scheme. Is there any
additional data or information that
should be considered?
Considerations which were recognised but
not quantified in the review need some form
of recognition when drawing final
conclusions, e.g.: •employment growth
•direct savings to the government’s energy
concessions budget and •public health
benefits of mitigating the risks of living in
low-quality housing, particularly during
extreme weather events such as heatwaves.
3. Which greenhouse gas coefficient
should be used to quantify the reduction
in greenhouse gas emissions achieved by
the VEET scheme?
Other
3a. Please outline why you believe this
option is preferred, or why you selected
"No response":
Calculation of the marginal greenhouse gas
coefficient for electricity should be based on
the rationale that when electricity demand is
reduced as a result of VEET activities, the
electricity market responds by scaling back
the most expensive generator (the marginal
generator). However to fully reflect the actual
emission reduction, it should be the integrated
value of this measure over the time of day
that the response measure is actually taking
place. Thus if it were a reduction of
household lighting electricity consumption, it
should be calculated over the times of day
when household electricity reduction
occurred. The value of the electricity
coefficient at other times of day are irrelevant
to the emission reduction claim. While such
an approach may be impractical if it were to
be applied at an extremely detailed level,
some form of generic version would be an
improvement over other options.
4. The Department has valued greenhouse
gas emissions reductions attributed to the
VEET scheme by adopting a carbon
valuation series that was produced by the
Federal Climate Change Authority as
part of its 2014 Targets and Progress
Review.Please outline whether you think
this approach is appropriate for valuing
greenhouse gas emissions reductions over
the period 2016 to 2050?
If I understand the modelling correctly, the
value this study places on carbon emissions is
restricted to the cost of abatement of the
emissions. This is clearly prone to major
underestimation of the real greenhouse
emission costs, given the great number of
effects on Australians, animals and
ecosystems which have not been identified or
quantified. To name a few, the social costs to
human and animal health and dislocation,
fire, flood, agriculture productivity, diseases,
air quality, pests, pastoral productivity, river
systems, aquatic species, atmospheric
stability, rainfall, aridity, soil loss, fish
depletion, coral bleaching, ocean acidity,
cyclones, the built environment, etc. While,
as yet, many of these have not been
quantified, they add up to a considerable cost
which has not been taken into account.
Because of the sheer number and uncertain
scale of these anticipated impacts, it is
difficult to quantify them, and so they tend to
be oversimplified and underestimated. To do
this in this study would be to our great disbenefit and must not be allowed to happen.
Consequently, the cost of carbon currently
used in the study seems far too low. It is also
not consistent with values used in other
countries, e.g. The UE emission trading
system studies suggest the appropriate current
carbon cost to be between €20 to €30/tonne,
and the USA is reported to use US$37/ton.
Australia should be using an equivalent value
to other country estimates. Consideration
could also be given to the international
benefits of Australia’s actions, e.g. if we were
to take the issue even more seriously, we
would recognise that reduced greenhouse gas
emissions in Australia will reduce worldwide
greenhouse gas concentrations in the
atmosphere and benefit people worldwide.
While these benefits to other country citizens
and bio-systems will not be seen in Australia
they are, never-the-less, real benefits. We are
proud of the direct monetary aid we already
give to needy people overseas, and while the
value of the aid we provide by means of our
emission reductions may not be easily
quantified, it may in reality surpass the
benefit we provide by way of direct monetary
aid.
5. Is there a case to exclude any business
sector(s) from participation in the VEET
scheme?
No
5a. Please outline why this is your
preferred option, and comment on how
this should be implemented:
5b. Please outline why this is your
preferred option:
In general terms I support comprehensive
participation so as to maximise the benefits
available. However, I am uncertain what the
intent is in regard to past investments. If there
is any intention that businesses should receive
benefits under the scheme for retrospective
investment decisions, this provision should be
removed.
6. Should the VEET scheme be amended
to better ensure support for low income
households?
Yes
6a. Please outline how the VEET scheme
could better support low income
households, and comment on why this
option should be preferred:
Specific consideration needs to be given to
the Landlord/tenant problem associated with
improvement of household energy efficiency
improvement, where landlords have little
incentive to invest in efficiency
improvements as they do not reap the benefits
of lower bills and tenants typically have
neither the right to make changes to the
dwelling, nor the security of tenure to make
such an investment worthwhile. VEET offers
a great opportunity to promote action in this
area. One specific approach would be to
mirror the success of the installation of solar
panels which was achieved by the
encouragement of local governments to foster
their implementation. In the case of the solar
panels, my local Council fostered a scheme
whereby people could register their interest
and once 50 people had signed up the Council
obtained a quote to do all 50 installations at a
significantly discounted price. Local
governments could be encouraged to run
similar initiatives to assist rented property
owners in their shire to use the services
promoted by the VEET scheme, such that
both the owners and the renters would gain a
benefit. There is a whole range of efficiency
improvements which could be included in
such an activity. Such initiatives would also
add justification for [presumably separate]
government action to introduce new energy
efficiency standards for rented houses, and
gain an even greater impact.
6b. Please outline why this is your
preferred option:
7. In addition to expanding the range of
energy efficiency activities available in
VEET, should any other action be taken
to target participation by certain groups?
Yes
7a. Please outline the actions you believe
should be taken:
As energy providers are often involved in the
promotion and implementation VEET
activities, and make money in so doing, this
may provide an opportunity to provide
assistance to households which cannot afford
energy efficiency improvements. An
additional amount of VEET funding could be
set aside for specific incentives to encourage
'sympathetic' action beyond that they have
provided in the past, e.g: where energy
providers agree to provide the service for a
significantly lower cost, when hardship can
be proven, e.g. inability to pay bills, instances
of supply being repetitively cut off, etc.
7b. Please outline why no other action
should be taken, or why you selected "No
response":
8. Please suggest up to five activities that
should be prioritised for revision or
introduction to the VEET scheme. Please
outline why you believe these activities
should be prioritised.
Commercial lighting. 1.There are still a lot of
commercial lighting installations in Victoria
which have not yet been converted to
modern, energy efficient systems, despite
such a changes being economic, or close to
economic in their own right. VEET provides
an excellent opportunity to make this happen
and consideration needs to be given as to how
this sector can be specifically targeted.
Perhaps a premium could be applied for those
who act within a stated timeframe, and an
appropriate VEET budget identified to drive
the initiative. 2.Targeting of new Landlord
tenant solution options. Specific initiatives
could be identified, with new incentives, as
raised in my answers under points 6a and 7
above. 3.Split system air conditioning units
for heating Gas and electricity pricing is
expected to continue to rise, resulting in
electric split system air conditioning units
becoming economically and environmentally
attractive for heating and cooling. This means
that the decision to exclude them from VEET
is no longer valid and should be removed.
4.Ceiling insulation in homes. Ceiling
insulation is one of the most effective ways to
increase the thermal efficiency of a home and
hence reduce its energy use and greenhouse
gas emissions. Following the closure of the
Federal Home Insulation Program, VEET has
become the a player in the continued
promotion of this measure. Priority needs to
be applied to ensure it maintains momentum,
including with reconsideration of increasing
the effectiveness of old installations.
9. Please suggest up to three changes
which should be made to improve the
VEET scheme. Please outline why you
believe these changes should be a priority.
1.Add a new specific VEET activity whereby
it provides incentives and actively seeks out
and encourages more organisations to
promote large scale adoption of VEET
activities and so increase their uptake by
making them more economically attractive,
e.g. as outlined in my answer in point 6a to
address the landlord and tenant problem
2.Specific incentives for ‘whole of house’
upgrades such that accredited representatives
offer a comprehensive ‘package’ to
householders, which meets their budgets and
maximises the economic and environmental
benefits of the pursuit of VEET supported
initiatives. To maximise the benefit and there
should be flexibility for such retrofit
packages to include any non-VEET funded
aspects, where they provide genuine
economic benefit to the householders and
have the householder’s support. 3.Specific
incentives as outlined in my response to
question 7