1. What should the new VEET target be?
6.2 million tonnes CO2-e per year for five
years
Other (please specify a target and length):
[Required if 'Other' selected] *
1a. Please outline why you prefer the
target you identified, or why you selected
"No response":
It is important to bring stability and longer
term incentives to the scheme. If we do not
have ambitious longer term targets then there
is no incentive for suppliers to invest capital
and time in developing new products for use
in the scheme. Developing new concepts and
products can take up to a year and cost tens
of thousands of dollars; without some level of
certainty that there is enough time and
opportunity in the scheme then the desire to
take this ‘risk’ is severely undermined.
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?
No Comment
3. Which greenhouse gas coefficient
should be used to quantify the reduction
in greenhouse gas emissions achieved by
the VEET scheme?
No response
3a. Please outline why you believe this
option is preferred, or why you selected
"No response":
Not knowledgeable enough in this area to
comment.
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?
The modelling has likely underestimated the
benefits of reducing greenhouse gas
emissions to Victoria, by using a ‘cost of
abatement’ value (what it costs to reduce one
tonne of greenhouse gas emissions) instead of
a ‘social cost of carbon’ value in the
calculations. The social cost of carbon is
defined as the costs imposed on the wider
economy by greenhouse gas emissions (most
commonly carbon dioxide). These economic
damages can take various forms including
decreased agricultural yields, harm to human
health, property damages from increased
flood risk and lower worker productivity. The
United States uses a value of $37 per ton of
greenhouse gas abatement to guide energy
policy decision-making. This is significantly
higher than the 2015 values for carbon
abatement which have been used in the
VEET modelling (starting at AU$5.49 per
tCO2-e for 2015). Because the likely benefits
of greenhouse gas emission reductions have
been underestimated, we can be very
confident that the 6.2 Mt/yr CO2-e target will
deliver at least the predicted benefits, and that
higher targets could also deliver positive
benefits if a more realistic value is used.
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:
Business and industry are significant users of
energy, it seems illogical that they should be
excluded from the scheme for political
reasons. If activities in the scheme can help
this sector to improve its energy efficiency
and reduce emissions then surely it would be
sensible to incorporate these significant
reductions into the scheme and allow Victoria
collectively to benefit from this.
6. Should the VEET scheme be amended
to better ensure support for low income
households?
No
6a. Please outline how the VEET scheme
could better support low income
households, and comment on why this
option should be preferred:
6b. Please outline why this is your
preferred option:
Support for low income households is better
dealt with through other initiatives that can
focus on this target group. The Victorian
government should also provide targeted
financial assistance to assist with up-front
cost hurdles, including reinstating successful
state and federal schemes (such as the Home
Energy Saver Scheme and Low Income
Energy Efficiency Program) which have been
closed or are slated for closure.
7. In addition to expanding the range of
energy efficiency activities available in
No response
VEET, should any other action be taken
to target participation by certain groups?
7a. Please outline the actions you believe
should be taken:
7b. Please outline why no other action
should be taken, or why you selected "No
response":
Not knowledgeable enough in this area to
comment.
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.
1.IHD’s: The current abatement levels for
this activity are too confusing and over
conservative, in turn this does not allow for
or encourage wide spread uptake of the
activity. IHD’s allow all households to see
the immediate benefits of their energy saving
efforts therefore providing immediate
reinforcement to their energy saving actions.
The main obstacle to this is that there are two
different abatement levels; 3 VEECs for
country and 2 VEECs for Metro (rounded).
All households should be eligible for 3
VEECS which would immediately allow for
a far broader uptake of this essential and
universally beneficial activity. 2.Lighting
Automation: This is severely neglected
activity for the scheme, studies show that up
to 45% of lighting costs result from lighting
left on when there are no occupants in the
room or office; as low energy lighting is
installed it is felt even more acceptable to
leave lighting on. Occupancy sensors in both
domestic and commercial properties can be
installed relatively easily whilst offering
significant energy savings. The types of
sensors include PIR sensors, movement
sensors, and sound sensors. 3.CFL
replacements: Why is this activity still in the
scheme? It has not been possible to purchase
an incandescent lightbulb for several years,
due to the their short lifespan the number of
functional incandescent lamps in households
is negligible, so what is actually getting
replaced by the CFLs? CFL lights are now
becoming rapidly superseded by LED
technology, it would therefore provide more
significant benefits for the scheme to focus
on LED technology. CFL replacements
should be immediately withdrawn as an
activity in the scheme. 4.Low flow shower
heads: All showerheads purchased for several
years have had to meet water saving
regulations, so the number of non-water
saving showerheads in households must be
negligible. The activity should be upgraded
to focus on flow restrictors that work
effectively to minimise water flow whilst
working with existing showerheads.
Technology now exists to add air into the
water flow rather than just restricting the
volume of water thus not affecting the
performance of the shower in terms of the
user experience. Low flow showerheads
should be withdrawn from the scheme and
replaced with the described flow regulators.
5.Low energy TV replacements: All TV’s
sold today have high levels of energy
efficiency with the power consumption of
TVs been incredibly low compared to
previous generations of TVs. It quite simply
is not a factor when someone purchases a
TV, so why is the scheme providing
retrospective rebates for making a purchase
that consumers would have made anyway?
This activity should be withdrawn from the
scheme.
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. Improvements in the time taken to approve
products and approve AP's for installation.
On occasions it has taken over 6 months to
grant product approval (with a complete
application) and over 9 months to grant AP
installation approval. This time frame is
unacceptable and impossible to operate with
from a commercial perspective. 2. Better
regulation of AP's to ascertain their
suitability to operate in the scheme. It is clear
that over the years that a number of AP's
have worked in the scheme who have no
intention of adhering to rules, regulations,
processes, or the integrity of the scheme. 3. A
more pragmatic and common sense approach
to the inclusion of certain activities and the
relevant abatement levels. To often data and
information already in the public domain is
ignored; instead a glossy extremely
expensive consultation document is used as
the basis for activities and abatement levels.
These become out of date very quickly and
are too theoretical in nature often ignoring
practical information and common sense.