This week we summarise all the points that have been discussed over the last 3 blog posts relating to the BAU case, and the re-consideration of lighting in the 2021-2025 target setting for the VEU.
– Acknowledgement that BAU applies to incandescent lighting which has been phased out.
– BAU could apply to non-dimmable downlights as replacement technologies are available and affordable.
– BAU should not apply to other technologies.
– There are still plenty of abatement opportunities within VEU scheme.
– If there is a BAU case applied to the VEU, it should be very conservative.
– If the DELWP are proposing to follow the E3, and the E3 only address Halogen downlights, the BAU methodology could not be considered for other technologies (including commercial lighting).
The VEU is a market-based program, with a range of technologies and a certificate price that allows for variation in activity, certificate prices, innovation and delivery.
Over 10 years of activity, the VEU has founded a ‘responsible normal’, delivering high quality authentic energy-savings to the customers that need it the most.
Based on the fact that the VEU is now legislated until 2030, DELWP should allow the program, through its proven technologies, to run its course, allowing the opportunity to take advantage of all energy-savings available. If the BAU argument is in fact ‘real’ and is applicable to the lighting upgrade market, this will be identified in time.
It is absolutely clear that this argument is not compelling and imposing changes to abatements based on theories that are disputable across the industry will impact the lighting industry to the point where significant energy-saving will be lost, and customers will miss out. If the lighting industry is affected in the way we fear, businesses such as manufacturers, sales, installers, electricians, compliance companies and accredited parties could collapse, causing re-engagement in the future to be highly challenging.
The next creation targets between 2021-25 is not the time to be imposing aggressive measures. The risk around change is high to all parties and the program. If any BAU is to be applied, it should only be applied to proven BAU cases that align with the current position of COAG and the E3 determination.