1. What should the new VEET target be?
Other
Other (please specify a target and length):
[Required if 'Other' selected] *
Minimum of 6.9 Mt/yr CO2-e for a period of
at least five years.
1a. Please outline why you prefer the
target you identified, or why you selected
"No response":
The Victorian Energy Efficiency Target
(VEET) scheme has at its centre the intention
to deliver greenhouse emissions abatement.
To meet the policy objectives a higher target
should be actively considered where there is
a positive net benefit and confidence that the
market can sensibly deliver. Modelling data
provided in the stakeholder consultation
documents show that the highest net benefits
are delivered by the highest target modelled –
6.2 Mt/yr CO2-e. The modelling suggests
that higher targets may also achieve positive
net benefits showing that maximum net
benefits are delivered at a target of 6.9 Mt/yr
CO2-e. Hence, a 6.9 Mt/yr CO2-e target
should be considered a minimum for target
options under consideration. The longer
period provides greater market certainty and
the development and deployment of project
based actions. Within setting a timeframe,
consideration should be given to the ability to
increase the target and limitations in ability
to transfer to a multi-state or national
program.
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 wider economic benefits from
energy efficiency such as employment
growth and direct savings to the
government’s energy concessions budget. In
addition there is increasing evidence to
suggest reduced public health costs and 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?
Updated marginal coefficient
3a. Please outline why you believe this
option is preferred, or why you selected
"No response":
MEFL recognises that any coefficient should
have integrity whilst being easily adopted. A
key consideration is how readily a coefficient
allows transferability to, or integration with,
a multi-state or national program. Should a
coefficient make any target reduced in real
terms, the target should be revised upwards.
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?
A key consideration is how readily the
approach allows transferability to, or
integration with, a multi-state or national
program.
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:
MEFL welcomes the inclusion of large
energy using sites (industry, hospitals,
universities) in the VEET scheme. There are
significant opportunities for business to
increase energy efficiency and productivity.
Business will be important in achieving a
higher target though care should be taken to
ensure ‘additionality’ to other energy
efficiency action.
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:
MEFL welcomes increased support for low
income households to participate and benefit
from the VEET scheme. To date, low income
households have received some benefit from
the VEET scheme due to the broad uptake of
compact fluorescent lights (CFLs) and
standby power controllers (SPCs). Issues
associated with the quality and permanency
of these items has detracted from their benefit
and there is some evidence to suggest that
low income households are more exposed to
opportunistic VEET providers. Care must be
taken to ensure low-income households can
access higher value measures and participate
in complementary programs. Households on
lower incomes spend a higher proportion of
disposable income on energy than do those
on higher incomes. Complimentary
interventions will be key in delivering
support for low-income households,
preferably delivered through social services
and not for profit organisations and/or local
governments.
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:
Consideration should be given to the split
incentive for residential tenants and business
leases. This is a significant barrier to
investment in higher value actions. VEET
scheme can and should be integrated with
complimentary financing programs such as
commercial and residential EUA schemes
and information and advice programs such as
those provided by state and local government
and NGOs.
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.
To ensure the VEET scheme delivers
measurable and permanent greenhouse
emissions abatement the market must have
the capability and realisable actions to meet
the target. The VEET scheme to date has
largely been delivered through low value or
free measures such as CFLs and SPCs. It’s
important to develop and support high value
activities as these typically deliver larger and
more permanent abatement. However it
should be acknowledged that higher value
activities may have other barriers to uptake
that a VEET certificate value alone may not
be able to overcome. Ceiling insulation
Ceiling insulation is one of the most effective
and significant ways to increase energy
efficiency in Victorian households. Insulation
should be reintroduced given there is no
longer duplication with the Federal Home
Insulation Program. Given the real and
perceived risks of installation, emphasis
should be given to ensure best-practice
accreditation, training, auditing and
minimum product standards are adhered to in
line with the South Australian scheme.
Commercial lighting There is opportunity to
expand the range of allowable activities in
line with other comparable schemes such as
the Energy Saver Scheme in NSW. In
particular, there are significant opportunities
for expanding activity in the commercial
lighting sector. Given lighting is a proven
technology that is easily installed and readily
certifiable, it presents an important
opportunity to support early activity in an
expanded business area. Split system airconditioning units for heating In Victoria gas
has historically been considered a more
affordable and lower greenhouse intensive
heating fuel. However the shift in gas prices
and the rise of efficiency reverse cycle airconditioning units is rapidly changing this
convention. The replacement of inefficient
gas heaters with efficient reverse cycle airconditioning units should therefore be
eligible for the generation of VEECs.
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.
To both realise environmental and financial
benefits for participants and the wider
economy the VEET scheme needs to be
considered alongside complementary
measures. These measures combined would
present a coherent and effective approach to
delivering the Victorian government’s
Efficiency and Productivity Plan currently
under development. Incentives for ‘whole of
house’ upgrades A ‘whole of house’
approach identifies the best combination of
efficiency measures for each house and
presents an important opportunity to engage
residents in behaviour change. Providers
should be encouraged to deliver
comprehensive household assessments and
develop a suite of measures to deliver large
energy efficiency gains. Assessments, where
undertaken by trained staff, present a
meaningful opportunity to deliver value to
households, identify actions to be taken
immediately and follow up actions that the
household can consider over time. The cost
of the assessment could be considered
redeemable if the household adopted a set of
actions above a determined threshold.
Financial assistance to address capital
barriers While reducing the overall capital
cost of actions is important the upfront
capital cost can still remain a barrier. For
energy efficiency, and hence the VEET
scheme, to be effective, consideration should
be given to opportunities to provide secure,
accessible finance. The Victorian
Government should investigate options for
applying Environmental Upgrade
Agreements (EUAs) to residential buildings.
MEFL was responsible for the project
management of the highly successful Darebin
Solar $aver scheme which has assisted 300
pensioners to install rooftop solar systems at
no upfront cost. Minimum energy efficiency
performance standards at the point of sale or
lease Mandatory disclosure of the energy and
water efficiency performance of residential
buildings at the point of sale or lease has
been proposed in recent years as a way of
improving transparency for buyers and
renters, and to create incentives for
homeowners and landlords to invest in
improvements so as to capitalise on increased
market value. However, progress on policy
development has stalled. Mandatory
disclosure informs consumer choice however
low-income renters and home-buyers
typically have few housing options and little
market power. Consequently, disclosure in
the absence of minimum standards does not
effectively remedy the least efficient
properties. Minimum 5-star energy and water
efficiency standards should be introduced at
the point of sale or lease within 2 years,
combined with a comprehensive range of
financial assistance (as outlined above) to
assist homeowners and landlords to
implement the new standards.