30 November 2015
Project –based assessments in the VEET Scheme
Energy Policy and Programs
Department of Economic Development, Jobs, Transport and Resources
GPO Box 4509
Melbourne VIC 3001
Dear Sir/Madam
PROJECT-BASED ASSESSMENTS IN THE VEET SCHEME
Thank you for the opportunity to provide a submission regarding the Department of Economic
Development, Jobs, Transport and Resources regarding the VEET scheme.
The Air Conditioning and Mechanical Contractors’ Association (AMCA) is the national peak
trade association for member companies operating in the commercial and industrial air
conditioning and mechanical services industry. Our members are highly skilled commercial
operators with expertise in the design, manufacture and installation of air conditioning and
specialised ventilation systems, as well as the ongoing service and maintenance of plant,
equipment and infrastructure.
To support members in their activities, the AMCA delivers technical and policy advice,
advocates to government, assists with training and workforce development, and provides
numerous other services that promote a prosperous, socially and environmentally responsible
industry.
Submission summary
The AMCA welcomes the release of the projects-based assessment method, as it provides a
market based incentive for businesses and building owners to improve their energy efficiency
and building performance. In particular, the ability to forward credit certificates has the
potential to offset capital investment costs, which are one of the key barriers to energy efficient
upgrades of HVAC systems.
Within the context of the VEET scheme, AMCA member companies are likely to be engaged as
contractors by an Accredited Person to upgrade building services such as heating, ventilation,
and air conditioning. From this perspective, the success of the scheme will depend on a clearly
identified scope and baseline, as well as the allocation of responsibilities, requirements and risk
within the contract. In particular, the allocation of design risk will be an important factor,
especially for more complex projects.
For example, if an Accredited Person assures a client that the upgrade of a HVAC system will
deliver a certain number of certificates, who bears the risk if the system underperforms? HVAC
systems contain a variety of plant and equipment that can be individually upgraded to more
energy efficient options; however overall energy performance is a combination of a variety of
direct and indirect factors.
balancing and commissioning; regular service and maintenance scheduling.
These types of issues are not unique, and have been effectively dealt with by industry for other
performance based initiatives such as NABERS and Green Star, as well as performance based
contracts; however it is important for the VEET scheme to encourage contracts to be clear with
respect to the allocation of identifiable risks.
The AMCA would also like to emphasise the importance of service and maintenance to the
achievement of energy efficiency outcomes. This is particularly important given the option to
forward credit certificates, and we suggest that further consideration be given to including
ongoing obligations to ensure that HVAC systems are appropriately maintained following the
initial project’s completion.
Specific comments on the questions posed in the discussion paper are included in the
attachment document.
Further Consultation
The AMCA would welcome the opportunity to consult further with the DEDJTR regarding the
project-based assessment methods, and the VEET scheme more broadly.
Should you wish to discuss any of the issues raised in this submission please contact my direct
on (03) 8831 2810 or by email at benhawkins@amca.com.au.
Yours Sincerely
Benjamin Hawkins
Policy Analyst Submission
1. Proposed M&V Method
1.1. Do you envisage a market for the proposed M&V Method? Why/why not?
Yes, there is a market for the M&V method. In particular, mid-tier buildings have proven a
difficult segment of the existing building stock to motivate for energy efficiency improvements.
The ability to forward credit certificates, thereby offsetting upfront capital costs, should provide
a sufficient incentive for building owners, providing that the marketing, communications and
administration of the scheme is designed in a way that makes it accessible to this target group.
2. Other proposed project-based assessment methods
2.1. Do you envisage a market for these proposed methods? Why/why not?
Yes, there is a market for other assessment methodologies, and it is important that the VEET
scheme methods are aligned with other State and National schemes wherever possible. Industry
is particularly familiar with NABERS-based assessment methodologies, and are therefore more
likely to take-up these methods more quickly.
2.2. Are there any other project-based assessment methods which the Department should
consider as a priority? (Note: please make calls for new deemed methods separately).
The Calculating Cool tool being developed by Sustainability Victoria has the ability to be used as
a tool for measurement and verification.
3. Accredited Persons
3.1. What minimum qualifications and/or experience should an AP need in order to
demonstrate capacity to deliver the M&V Method? E.g.:
3.1.1. Certified Measurement & Verification Professional (CMVP)
3.1.2. Certified Energy Efficiency Specialist /Leader (CEES/CEEL)
3.1.3. Relevant industry experience (please specify)
3.1.4. Other (please specify)
The above mentioned examples are perhaps the best placed to become accredited persons in
the immediate term; therefore it makes sense to focus in these areas. Additionally, experienced
industry professionals in the field of testing, balancing and commissioning have a skill set that
should be considered. This includes the above mentioned qualifications, as well as NABERS
assessors, but should also include practitioners certified by the National Environmental
Balancing Bureau (NEBB).
www.nebbaustralia.org.au Submission
4. PBA Assessors
4.1. What minimum qualifications and/or experience should a PBA Assessor possess in
order to demonstrate capacity to provide assessments? E.g.:
See 3.1 above. It is also important that PBA Assessors have a strong understanding of the
National Construction Code, as well as relevant Victorian building regulations. This is
particularly important for larger, more complex projects.
4.2. How can the independence of the PBA Assessor be assured?
4.2.1. Restrictions on who can be a PBA Assessor (please specify)
4.2.2. Contractual arrangements (please specify)
In other segments of the building and construction market, the lack of qualified and
independent assessors can seriously undermine compliance. PBA contracts should explicitly
require the disclosure of a conflict of interest. Accredited persons should be limited from
dealing with the same PBA/s on all projects.
4.3. Should APs be able to act as PBA Assessors if they are able demonstrate they don’t
have a conflict of interest?
Given the relatively low numbers of certified M&V professional, all options for PBA assessors
will need to be explored.
4.4. Should an AP be able to choose their own PBA Assessor, or should PBA Assessors be
assigned by the ESC?
Accredited persons should be limited from dealing with the same PBA/s on all projects.
However, this should be balanced with the cost of administering the scheme, which would
presumably increase if the ESC was required to assign a PBA assessor to all projects. Provided
that an adequate oversight structure is in place, APs should be able to engage a PBA assessor.
5. Eligibility
5.1. Is it preferable that this information is provided later at the M&V Plan step?
5.2. Are there any potential issues at this step with commercially confidential
information, e.g. budget information? How could this be managed?
As a statement of principle, eligibility for the scheme needs to be determined as early as
possible using the least amount of information as possible. Contractors may be discouraged
from tendering if the process requires detailed project documentation to be submitted before
eligibility has been determined.
The process could include a simple, early test of eligibility that would allow a request for tender
to be made so that contractors have a degree of confidence that the project will go ahead, with
final eligibility to be determined once the tender process has been completed.
6. M&V Plan
6.1. What information should be required in the M&V Plan, and what should be able to be
provided later? Please refer to the proposed content listed in this section, as well as the
PIAM&V method and IPMVP framework.
It is vital that the M&V Plan clearly identifies the scope, roles, responsibilities and risk
allocations. This will be simple for some projects (e.g. a chiller upgrade); however, if the project
involves a full retrofit of the HVAC system, there are likely to be more parties involved that are
capable of influencing performance. A retrofit, for example, might include the Accredited
Person, a consulting engineer and the contractor.
7. Operational verification
7.1. How can proponents demonstrate that the implementation has been installed
correctly and is operating as intended?
Testing, balancing and commissioning are vital to achieving the desired performance of a HVAC
system and should therefore be a requirement of any project executed under the VEET scheme.
8. What training or capacity development needs are needed to support businesses using
the M&V Method in Victoria?
It would be beneficial to have training and information available specifically for contractors.
This might encourage contractors to proactively promote the VEET scheme to existing clients. It
may also encourage them to invest in developing internal staff capabilities with respect to M&V
services.