We identified changes in the product class assigned to 18 refrigerated cabinet products (product category 32(21)) in the Register of Products for the VEU program (see table below). These changes were required due to changes in the GEMS register since we first listed these products in October 2021. The latest GEMS register has clarified the correct product class for the affected products.

The update to the Register of Products would impact on the number of certificates awarded for the installation of affected products as listed in the table below.

# Assuming a regional factor of 0.98 (i.e. assuming installations in metropolitan Melbourne)

We had originally identified changes in the classification of 12 of the above products and had sent an email to stakeholders accredited (and those who have applied for accreditation) to undertake refrigerated cabinet activities in the program on 9 March seeking feedback on how an update to the register to rectify the error would impact on their business.

We received feedback from a number of affected accredited providers which detail installations and stock arrangements which will be adversely impacted by the proposed update to the register.

While we have a disclaimer on the VEU Registry website which sets all information is subject to change without notice and the commission is not liable to any person for any loss suffered in connection with the VEU registry, we are committed to developing an appropriate solution which balances the integrity of the program and accredited providers’ participation in the program. 

Proposed changes to Register of Products to correct the product classification

Based on stakeholder feedback, we proposed providing affected accredited providers with a six weeks transition time frame prior to updating the register with the correct class for affected products. This transition would allow affected providers to claim certificates under the program using the original classification for installation of adversely affected products for installations undertaken up to 6 May 2022. This transition would only apply to the sixteen products which will return fewer certificates as a result of the update (i.e. products listed in table above from numbers 1 to 16).

We proposed updating the register for the remaining affected products (i.e. products listed in the table above from numbers 17 and 18) following the end of this consultation (i.e. on 30 March 2022). Accredited providers seeking to claim certificates for these affected products were advised to delay their certificate claims for these products to this date. 

We also proposed removing the following products from the register on 30 March 2022 as we believe they are not valid products.

• Brand: Polar Refrigeration; Model: Polar Freezer
• Brand: Polar Refrigeration; Model: Polar Refrigerator (class 14).

The above approach provided the right balance between ensuring the integrity of the program and providing appropriate relief for affected accredited providers to deliver on their commitments and to pivot their business operations to incorporate the change in certificate values for affected products. 

Consultation outcome

We invited feedback on the proposed transition timeframe for updating the register of products for the above changes. Submissions closed on 29 March 2022. 

Read about the outcome of the consultation.

Contact us

If you have any questions or feedback regarding this consultation, please contact Victorian Energy Upgrades support on (03) 9032 1310 or veu@esc.vic.gov.au

We received feedback from stakeholders on evidence requirements for the cold room activity (activity 43) under the Victorian Energy Upgrades (VEU) program.

In addition, stakeholders have also sought clarification on the eligibility of upgrades that include some shared components servicing multiple cold rooms at a single site.

This consultation seeks to:

• outline our position on cold room upgrades involving shared compressor(s) and/or condenser(s) across multiple cold rooms in the same refrigeration system
• provide stakeholders with an opportunity to provide feedback on proposed changes to the evidence requirements for this activity.

Background

The cold room activity was introduced to the Victorian Energy Upgrades program under Part 43 of the Victorian Energy Efficiency Target Regulations in August 2021. This activity provides for upgrades that are tailored towards simple retrofit of cold rooms and installation of new cold rooms.

This activity enables accredited persons to create Victorian energy efficiency certificates under the following upgrade scenarios:

• Installing an electronic expansion valve and superheat controller into a refrigeration system (activity scenario 43A)
• Installing a refrigeration system that includes at least three of the parts specified for activity 43B(ii) under Part 43 of the VEU Specifications (activity scenario 43B(i))
• Installing a refrigeration system that includes the five parts specified under Part 43 of the VEU specifications (activity scenario 43B(ii)).

Read more about the cold room activity.

Eligibility of multiple cold rooms upgraded with a shared condenser and/or compressor

Stakeholders sought clarification on whether an upgrade involving multiple cold rooms at one site served by a common refrigeration system where some parts (a condenser and/or compressor) are shared are able to create certificates based on the number of cold rooms upgraded under activity scenario 43B(i) and 43B(ii).

Our position was that an activity involving multiple cold rooms served by shared compressor(s) and/or condenser(s), or a shared combined compressor and condenser in a single refrigeration system, can be claimed as multiple cold room upgrades under the program. This is provided that other upgrade components have been installed in each cold room, and the upgrade meets all requirements for the relevant activity scenario as detailed in Part 43 of the Victorian Energy Upgrades Specifications.  

For example, an accredited person will be able to claim certificates for three activities for an upgrade at a single site under activity 43B(i) involving:

• the upgrade of single condenser and compressor which serves three cold rooms in a single refrigeration system
• the installation of new electronically commutated fans in each of the three cold rooms.

Our view is that this position provides for the creation of certificates which aligns with the policy intent of the activity under the program (i.e. the expected amount of greenhouse gas reductions for such an upgrade is deemed based on number of cold rooms upgraded).

Proposed changes to evidence requirements for cold room activity

Stakeholders provided us with the following feedback:

• In some instances, installers may have difficulty in meeting some of the photographic evidence requirements we have requested due to physical barriers.
• In some instances, requested evidence requirements are duplicated.

Based on this feedback we proposed the following changes to the evidence requirements for the activity.

Proof of commercial transaction and energy consumer (tax invoice document) – all activity scenarios

We proposed removing the requirement for the recording of the installation date on the tax invoice. This is based on feedback that the installation date recorded on the invoice may not accurately represent the installation date where there is an extended commissioning process.  We also accepted that the installation date is already captured in the certificate of electrical safety.

Upgrade product(s) (geo-tagged photographs of the installed parts) – activity 43A

We proposed removing the requirement for a geotagged photograph showing the nameplate of the electronic expansion valve and superheat controller based on feedback that the nameplate is not always visible and able to be photographed.  We accepted that a photograph of the electronic expansion valve and superheat controller is sufficient when supported by other evidence requirements.

Upgrade product(s) (geo-tagged photographs of the installed parts) – activity 43B(i) and 43B(ii)

We proposed inclusion of a document from from the manufacturer listing the various components of the system as per the Victorian Energy Upgrades program specifications and a photograph of the system’s name plate as alternative evidence to photographs of the name plate of each of the installed parts. This proposed change was based on stakeholder feedback that the nameplate of each installed part is not always visible and able to be photographed, particularly with pre-assembled refrigeration units.

Temperature factor (geo-tagged photograph of the thermostat controlling the installed cold room system) – all activity scenarios

We proposed amending this evidence requirement to remove the need to provide a geo-tagged photograph of the superheat set point. This is based on feedback that such additional evidence is not useful.  We accepted that a geo-tagged photograph of the cold room set point is sufficient for us to determine compliance against the activity’s temperature factor requirement.

New evidence requirements for upgrade involving multiple cold rooms and a shared compressor and/or condenser – activity scenario 43B(i) and 43B(ii)

We proposed amending our evidence requirement for technical data sheet(s) for activity scenarios 43B(i) and 43B(ii) to include provision of a schematic diagram (such as a single line diagram) of the refrigeration system where a site upgrade involves multiple cold rooms using a shared compressor and/or condenser. We believed this document enables us to confirm that the compressor and/or condenser are indeed common to each of the cold rooms being claimed.

View a comparison of current evidence requirements against the requirements we proposed.

Consultation outcome

We invited feedback on the above proposed changes to our evidence requirements, including holding an online workshop on 2 December 2021 to discuss the proposed changes. Submissions closed on 10 December 2021.

Read more about the consultation outcome.

Accredited persons sought guidance on wood-fired room heater decommissioning, and the meaning of ‘permanently inoperable’ in this context.

The safety of professionals during the activity, and of residents and consumers after the activity, is our main concern. We sought feedback on:

• the appropriate level of assurance to demonstrate compliance with our regulations and safety considerations, and
• what other decommissioning methods might allow wood-fired room heaters to remain safely within premises.

We received one submission which can be found in the resources section of this page.

The consultation assisted in informing us of changes to the Water heating and space heating/cooling activity guide. Updates of which can be found in the resources section of this page.

For further detail on the changes made to the activity guide please see the full program update.

Background

Activities 9A(iii) and 10A(iii) enable accredited persons to generate Victorian Energy Efficiency Certificates (VEECs) for the installation of gas, liquefied petroleum gas (LPG) room heaters or room air-to-air heat pumps (also known as reverse cycle split system air conditioners).

As part of these activities, we needed evidence to show that:

• the gas, LPG room heater or room air-to-air heat pump has been installed
• an existing plug-in electric heater or a wood-fired room heater^[1] has been decommissioned.

The need to decommission is detailed in the Victorian Energy Efficiency Target Regulations 2018. It provides assurance that a reduction in electricity consumption and greenhouse gas production is likely to occur in alignment with the VEECs generated from the upgrade.

The Water Heating and Space Heating/Cooling Activity Guide requires accredited persons to provide geo-tagged photos showing the wood-fired room heater ‘rendered permanently inoperable^[2]’.

As a regulator, we must balance effective and efficient decommissioning with ensuring that the practice is safe for professionals as well as consumers, both during and after the upgrade. As such, we require professional licensing or relevant industry standards to be met for several upgrade scenarios.

Before the changes, we required a plumber licensed by Victorian Building Authority (VBA) under the ‘Mechanical Services’ category to perform the decommissioning. In addition, accredited persons had sought clarity on the evidentiary requirements for wood-fired heater decommissioning.

This consultation aimed to gather feedback on our considerations.

What is safe wood-fired room heater decommissioning?

To clarify our expectations, we considered the meaning of ‘rendered permanently inoperable’ for these activities.

The risks to safety of future residents and integrity of buildings are significant. As a result, we believed the proportional approach is to require a high level of assurance. This would include evidence demonstrating the removal of the wood-fired heater and flue up to the ceiling (or fireplace), repair of the ceiling, and either:

• leaving the flue in the roof space and through the roof
• removing and repairing of the roof.

Documentation would have to demonstrate the following aspects of decommissioning:

• disconnection and removal of the flue from the heater
• removal or disabling of any combustion air intake or damper
• removal or disabling of any supply air fan (where fitted)
• disassembling of the heater and flue
• removal and disposal of the door from the heater and the heater itself
• having the heater recycled at a metal recycling firm, with evidence of disposal via an invoice from an appropriately permitted waste management operator
• repair and plastering of the ceiling ore roof / wall penetration, including a Certificate of compliance if repair work is greater than $750.
• in the case of a fireplace, the full structural removal of the fireplace.

Any removal of wood-fired room heaters needs to safely manage the spread of and exposure to ash, soot and creosote, and must be undertaken by a plumber licensed by the Victorian Building Authority under the ‘Mechanical Services’ category. Roof penetrations must be rectified by a licensed roof plumber.

Changes to product approval requirements for lighting products with switchable wattage settings

We received an increasing number of lighting products with switchable wattage settings for approval under the VEU program for installation under building-based lighting upgrade (activity 34). We identified several administrative risks associated with the installation of this type of product.

Initial consultation – 9 October 2020

We had a small number of products containing switchable wattage settings which have been approved and listed on the Register of Products. For these products, we proposed to end-date the product models with the lower wattage settings and to only maintain the product model with the highest wattage setting. We note that switchable products will still be able to be used in the VEU program, however, certificate claims would only be able to be made for the product based on its highest power setting. The consultation closed on 31 October 2020.

Further consultation on products with switchable wattage setting - 18 December 2020

Based upon feedback, we proposed a transition period which ends on 31 March 2021. This is effectively a six-month transition which should allow participants to install stock held and complete current work orders.

Also, following our October consultation, we identified' easily switchable' products (e.g., wattage settings can be switched outside of the factory) and 'not easily switchable' products (e.g. where wattage settings are finalised at the factory). We believed these products should be treated differently under the program.

Therefore, we sought stakeholder feedback on:

• our thinking on the definition of a product that is ‘not easily switchable’.
• evidence we require from an applicant to prove that the product meets the definition of ‘not easily switchable’. 
• our proposed transition period (approximately six months from early October 2020 to end of March 2021)

Consultation outcome

The consultation closed on 31 January 2021. Read about the consultation outcome.