Proposed changes to product type and certificate creation for building based lighting upgrades (activity 34)

15 September 2020

Current LED lamp product types in the VEU registry

Many LED lamps approved under building-based lighting upgrades (activity 34) of the VEU program were submitted and approved by us prior to the introduction of the 2018 Victorian Energy Efficiency Target (VEET) Regulations (which commenced on 10 December 2018).  Under the previous regulations (the 2008 VEET regulations), the legislation did not specify different LED lamp types under activity 34.

When activity 34 was established under the program in 2013, we had developed and implemented several lamp product types in the VEU registry to identify the different LED lamps which were then commonly known to the market. Lamp product type categories which we implemented are listed below in table 1. The ‘LED other (240V)’ product type was used to capture any LED lamps which did not belong to the other LED product types.

Table 1: Current LED lamp product types in the VEU registry

We propose retaining most of the above LED lamp product types with the exception of the ‘LED other (240V)’ product type. 

Proposed changes to the ‘LED other (240V)’ lamp product type

With the introduction of the 2018 VEET Regulations and corresponding specifications, various new LED lamp types (table 34.10 of the VEU specifications) were introduced into the program to reflect the advancement of LED technology, and therefore the development of different LED lamp types.  The lamp types listed in the 2018 specifications do not map well to the existing product type categories used in the VEU registry. We have now done an extensive review of the LED lamps categorised as ‘LED other (240V)’ (around 4,000 of them) and propose re-categorising the various approved lamps according to table 2 below to align them better with the LED lamp types listed in the VEU Specifications.  

This change will provide a better understanding of the type of LED lamps being installed under the program and will enable the commission to implement system changes to minimise the risk of improper Victorian energy efficiency certificate (VEEC) creation claims (see below). 

Table 2: Proposed LED product lamp types to replace ‘LED other (240V)’

Proposed lamp ballast combinations and asset lifetime references for LED lamp upgrades

Linked to our efforts to re-categorise the ‘LED other (240V)’ lamp type, is our work to identify and implement changes to support accredited persons (APs) selecting the right lamp ballast combinations and asset lifetime references for the installation of LED lamps under activity 34 of the VEU program.  The key aim of this work is to minimise the risk of improper VEEC creation claims by accredited persons.  We have identified a number of instances of APs selecting the incorrect asset lifetime references for certain lighting upgrades.    

In our program update of 26 May 2020, we provided guidance to accredited persons for selecting the correct asset lifetime reference for certain lighting upgrade situations. 

With the implementation of above LED lamp re-categorisation work, we propose to implement changes in the VEU registry which will prevent certificate claims entered with invalid lamp ballast combination and/or asset lifetime references based on the upgrade lamp type. The matrix of available lamp ballast combinations and asset lifetime references for each lamp type under building based lighting upgrades is detailed in the PDF document below.

Feedback on proposed changes

We propose making the following system changes to the VEU registry on 23 September to give effect to the above changes:

• Changes to the product application portal and listing of LED lamps under the Register of Products to reflect the inclusion of the new LED lamp types as listed in table 2 above, and removal of ‘LED other (240V)’ as a lamp product type.
• Changes to the business rules of the certificate creation process to prevent the creation of certificates which selects invalid lamp ballast combinations and asset lifetime references for an upgrade lamp type. 

We believe the changes we propose are reasonable and valid, and will deliver benefits for both us, as program regulator, as well as to program participants involved in the building based lighting upgrades activity.

We are providing stakeholders an opportunity to provide us with feedback on:

• The proposed additions of the LED lamp product types as listed in table 2 above to replace the ‘LED other (240V)’ lamp type.
• The available lamb ballast combinations and asset lifetime references for each lamp type under building based lighting upgrades (activity 34), as detailed in the PDF document below.

Please provide feedback on this proposal by close of business 21 September by email to: veu@esc.vic.gov.au

Where to get help

If you have any questions or feedback with respect to matters set out in this program update, please contact VEU Support on (03) 9032 1310 or veu@esc.vic.gov.au.