1. What should the new VEET target be?
Other
Other (please specify a target and length):
[Required if 'Other' selected] *
6.9 million tonnes CO2-e per year for at least
five years
1a. Please outline why you prefer the
target you identified, or why you selected
"No response":
Improving the energy efficiency of buildings
is one of the most cost‐effective ways to cut a
community’s greenhouse gas emissions.
Energy efficiency delivers a range of health
benefits. Modelling shows that maximum net
benefits are delivered at a target of 6.9 Mt/yr
CO2‐e for a period of 5 years. The target
should therefore be set at 6.9 Mt/yr for at
least 5 years. However, legislation should
allow for the target to be revised upwards if
evidence becomes available showing this to
be a prudent course of action to protect the
community from severe effects of climate
change.
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?
There are many other benefits that derive
from taking action to ameliorate the effects of
climate change, including the economic
benefits of increased employment in newtechnology industries and the community
benefits of reduced heat stress during hot
weather conditions. As well, there are
massive health benefits that flow from
limiting the extent of climate change, such as
reducing the risk of pestilence that follows
from a warmer climate. Many of these
community benefits cannot accurately be
estimated, but, to the extent they are
unaccounted, the modelling is
underestimating the economic benefits
flowing from achievement of a high VEET
target.
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":
4. The Department has valued greenhouse
gas emissions reductions attributed to the
VEET scheme by adopting a carbon
The modelling has likely underestimated the
benefits of reducing greenhouse gas
emissions, by basing its calculations on ‘cost
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?
of abatement’ value instead of a ‘social cost
of carbon’ value. The social cost of carbon is
defined as the costs imposed on the wider
economy by greenhouse gas emissions. These
costs 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 6.9 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:
There is ample evidence that significant
opportunities exist for business and industry
to improve energy efficiency at low or
negative cost, and that such efficiency and
productivity improvements would deliver
benefits to individual businesses and to the
wider Victorian economy. I support the
inclusion of large energy users (industry,
hospitals, universities etc.) in the VEET
scheme. However, I do not support these
businesses receiving benefits under the
scheme for retrospective investment
decisions. Investments in energy efficiency
made prior to inclusion in the scheme were
presumably based on sound economic and
business rationales, and hence meet the
definition of ‘business as usual’ activities
which are excluded under VEET.
6. Should the VEET scheme be amended
Yes
to better ensure support for low income
households?
6a. Please outline how the VEET scheme
could better support low income
households, and comment on why this
option should be preferred:
Low‐income households have missed out on
the benefits of higher value measures under
VEET (such as draught‐sealing, hot water
and space heating) because they cannot
afford the up‐front costs or because they live
in rented property. Landlords have little
incentive to invest in efficiency
improvements as they do not reap the benefits
of lower bills. Tenants are unlikely to
improve the energy efficiency of a dwelling. I
support setting sub‐targets which require
energy retailers to install energy efficiency
measures in low‐income households.
Government should also provide targeted
financial assistance where a benefit to the
community exceeds the investment.
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:
Households that struggle to pay their bills and
are at risk of disconnection are not always on
low incomes. Often they are large families on
modest incomes who are not eligible for
concession cards, but who live in relatively
inefficient homes and use large amounts of
energy. Consideration should be given to
ensuring that current requirements for energy
retailers to provide assistance to hardship
customers extends beyond simply addressing
payment arrears. Energy retailers should also
be required to provide practical assistance
with improving efficiency and lowering
energy usage.
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
1. Ceiling insulation is one of the most
effective ways to increase the thermal
efficiency of a dwelling and hence reduce
outline why you believe these activities
should be prioritised.
energy use and household bills, particularly
in Victorian climate zones. Since the Federal
Home Insulation Program is no longer
operating, re‐inclusion within VEET will
drive uptake of this important measure. Any
real or perceived risks of insulation
installation can be addressed by establishing
a best‐practice suite of measures including
accreditation, training, auditing and minimum
product standards. 2. Commercial lighting.
There are significant opportunities for
expanding activity in the commercial lighting
sector, which currently represents a fraction
of total activity in Victoria compared with
NSW. Expanding activity in this area will be
key to achieving higher targets, and will
create jobs as commercial lighting
installations are relatively more labour‐
intensive than residential activities. 3. Split
system air‐conditioning units for Electric split
system air‐conditioning units used for heating
are currently ineligible for the generation of
VEECs in gas‐reticulated areas, based on the
historical assumption that gas is a more
affordable and less emissions‐intensive
heating fuel than electricity. But with rapidly
rising gas prices and highly efficient electric
appliances now available, this assumption no
longer holds. This exclusion should therefore
be removed.
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.
Incentives for ‘whole of house’ upgrades. A
‘whole of house’ approach, beginning with a
comprehensive audit, saves time and money
by identifying the best mix of efficiency
measures for each house. Consideration
should be given to encouraging providers to
deliver ‘deeper’ comprehensive household
retrofits, for example by allowing for the
bundling of complementary measures (e.g.
ceiling insulation and down-light covers}.