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":

to help improve energy efficiency in homes and businesses as well as crating employment in the industry

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?

modelling should include wider outcomes such as employment growth, government savings in energy concessions budget and public health benefits.

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 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?

no it doesn't and should be inline with other countries such as the United States which uses a value of $37 per ton of greenhouse gas abatement to guide energy policy decision making as aposed to ours of $5.49. A higher target could deliver much more positive benefits into the future.

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:

All business have significant opportunities to improve their energy efficiencys at low or negative cost, and these efficiencies and productivity improvements would deliver benefits to businesses and the wider Vic economy.

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:

Low‐income households have tended to miss 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, because they rent, or both. Landlords have little incentive to invest in efficiency improvements as they do not reap the benefits of lower bills. Tenants typically have neither the right to make changes to the dwelling, nor the security of tenure to make such an investment worthwhile. I support setting sub‐targets which require energy retailers to install a certain amount of energy efficiency measures in low‐income households, as is the case in South Australia. However, sub‐targets alone will not be sufficient. 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. To address the ‘split incentive’ barrier faced by renters, minimum energy efficiency rental standards should be introduced within 2 years, combined with targeted financial incentives for landlords to comply with the new standards.

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 which are struggling 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 just 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 outline why you believe these activities should be prioritised.

Ceiling insulation Ceiling insulation is one of the most effective ways to increase the thermal efficiency of a dwelling and hence reduce 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. Commercial lighting and high efficiency LED 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. Split system air‐conditioning units for heating 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).