1. What should the new VEET target be?
Other
Other (please specify a target and
length): [Required if 'Other' selected] *
A minimum of 6.9 million tonnes per year of
carbon dioxide equivalent (Mt/yr CO2‐e) for
a period of 5 years.
1a. Please outline why you prefer the
target you identified, or why you selected
"No response":
The climate council states levels of carbon
pollution (CO2) in the atmosphere are now
the highest they have been in the past 400,000
years.The CSIRO and the Bureau of
Meteorology both acknowledge updated
climate change predictions confirm Australia
is on track for increasingly extreme weather
as the climate is affected by greenhouse gas
emissions. It is therefore imperative that we
reduce our greenhouse gas emissions. One
way Victoria’s greenhouse gas emissions
could be reduced is by increasing the energy
efficiency of our buildings. Indeed, given our
high population growth rates (and associated
construction), this would be one of the most
cost‐effective ways as the benefits would
continue to operate over future decades.
However an effective VEET would have
flow-on benefits in other areas than individual
households, especially in the creation and
extension of associated industries with their
new employment opportunities. Reducing the
impacts of climate change would also help
reduce public health concerns such as
heatwave deaths or diseases carried in
floodwaters. Therefore the selection of a
particular VEET should be such as to ensure
maximum benefits to citizens and their
households, businesses, and the wider
Victorian economy. Since the modelling
undertaken for the Review demonstrated that
maximum net benefits would be procured by
a target of 6.9 Mt/yr CO2‐e for a period of 5
years, I consider that the target should
therefore be set at 6.9 Mt/yr for 5 years.
Moreover the legislation should cater for the
target to be reviewed upwards but not
downwards in the relevant 5 years after the
Climate Change Act Review sets an
Emissions Reduction Target for Victoria.
2. Comments are invited on the modelling
approach used to determine the costs and
benefits of the VEET scheme. Is there any
Some of the broader benefits of reducing
greenhouse gas emissions were not included
in the review's modelling because of the lack
additional data or information that
should be considered?
of adequate data. Employment opportunities,
public health concerns such as heatwave
deaths, and many of the exact ways to
mitigate climate change in regional
agricultural Victoria could not always be
included in the modelling owing to
insufficient data being available. Whilst this
is understandable, it means that the modelling
results probably present a lower estimation of
the overall benefits and hence the 6.9 Mt/yr
CO2‐e target should be seen as providing
even more benefits than the modelling shows.
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":
I don't know enough to make a
recommendation here - a greater statistical
expert (making certain they are non-partisan
and independent) should be consulted.
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 impacts of greenhouse gas emissions on
climate have consequent social costs, ranging
not just from the effects on agriculture and
food production but to other economic factors
such as industry (including tourism) and
transport costs (eg rail tracks failing in
extreme heat). Public health concerns and
environmental consequences on our flora and
fauna shall also accrue with worsening
climate change. Yet the modelling has relied,
for ease of statistical analysis, merely on what
it costs to reduce greenhouse gas emissions
(measured using one tonne unit reductions).
Whilst this 'cost of abatement' is in some
ways easier to deal with when doing the
modelling, it also underestimates the widerranging but still applicable benefits that using
a ‘social cost of carbon’ value in any relevant
calculations would display. The social cost of
carbon includes more of the actual costs
imposed by greenhouse gas emissions on the
overall economy, including property damage
and lower worker productivity (as well as
some of the social costs mentioned above).
Furthermore the actual values used in the
VEET modelling for carbon abatement are
significantly lower than the values used in
countries like the United States (VEET uses
U$5.49 per tCO2‐e for 2015 as a beginning
price, whilst the USA uses a value of $37 per
tonne to guide energy policy decision‐
making. This means that the benefits from
greenhouse gas reductions shall be
underestimated and this should be borne in
mind so that the possibility of setting higher
targets, yet still obtain overall benefits from
doing so, can be admitted.
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:
Whilst it is obvious that the fossil fuel
industry has certain levels of self-interest to
protect, they should still have an opportunity
for input. However it is already apparent that
major opportunities for interested parties to
improve energy efficiency exist, often at little
or no cost. Moreover any improved energy
efficiency obtained by individual businesses
would have benefits that would flow into the
wider economy. Large energy users like
industry, prisons, hospitals, and tertiary
education facilities and perhaps even schools
should be able to participate in the VEET
scheme but steps should be taken so that no
unfair advantages are obtained. I don't think
that benefits for retrospective investment
decisions should be granted as these would
have already had strong business or economic
reasons for their previous introduction and
VEET specifically excludes ‘business as
usual’ activities. Perhaps some funds could
also be used to set up solar charging stations
for electric cars as these become more widely
used?
6. Should the VEET scheme be amended
to better ensure support for low income
households?
No response
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:
I am not sure how to approach the problem of
low-income households and renting.
Landlords already receive negative gearing
benefits and renters often move.
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?
No response
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":
The problem with having categories of need
is that people may just 'miss out' on the help
they may desperately require if their income
is only just above the cut-off point. Many
Australian homes are energy-inefficient (eg
McMansions and their huge open living
spaces, or older draughty uninsulated homes)
and even people with moderate incomes may
be struggling with energy bills. Perhaps there
should be a no-interest loan scheme for all so
that houses benefit, and then whoever lives in
them in the future also benefit as they pay
back the loan.
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.
Ceiling and wall insulation - particularly
ceiling - as this is an effective method of
reducing the energy consumption of houses,
with immediate economic benefits flowing
onto the inhabitants. A sensible inclusion of
insulation within VEET would help people
insulate, although care should be taken with
who is able to install the insulation, given the
unfortunate side-consequences of the now
defunct federal scheme. However the very
popularity of the federal scheme shows how
people are desperate to improve their energy
efficiency and their energy bills. Commercial
and street lighting are other areas in which
energy use improvements could easily be
made. Councils should be helped to make
their street lighting more efficient (could
street lighting be motion -operated as well
between the hours of 2am to 5am in some
areas?). It would also help if a wider range of
units used for actually heating homes could
be included in the scheme. At the moment
electric split system air‐conditioning units are
not eligible for the generation of VEECs in
gas supplied areas. This is because,
historically, gas was both cheaper and less
emissions‐intensive than electricity. Such
considerations are no longer so relevant as
gas is dearer than it used to be and electrical
appliances more efficient.
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.
I am not sure of the best way to prioritise.
However small business at least is likely to be
helped through the proposed federal budget
(tax etc) so perhaps some greater
considerations should be made to individual
households.