Expansion of Energy Saver Incentive
Issues Paper – October 2010
In July 2010, the Victorian Government released Taking Action for Victoria’s Future, The Victorian Climate Change White Paper – The Action Plan1 . The Action Plan sets out 10 actions to reduce greenhouse gas emissions to meet the commitments under the Climate Change Act 2010. Included in the Action Plan is a Victorian Government commitment to doubling the Victorian Energy Saver Incentive (ESI) scheme target, and expanding the scheme to include small and medium sized enterprises (SMEs) subject to a Regulatory Impact Statement.
The Energy Saver Incentive commenced operation on 1 January 2009. The scheme is established in the Victorian Energy Efficiency Target Act 2007 (the VEET Act). The objectives of the Act are to:
- Reduce greenhouse gas emissions;
- Encourage the efficient use of electricity and gas; and
- Encourage investment, employment and technology development in industries that supply goods and services which reduce the use of electricity and gas by consumers.
This Issues Paper will support setting the scheme target for the 2012-14 period and in the detailed design of the scheme expansion. Stakeholder views are sought on the following key issues:
- The proposed doubling of the VEET target;
- Expansion of the scheme to the SME sector;
- Assigning energy retailer obligations;
- Determining abatement values for activities; and
- Scheme communications and promotion strategies
Submissions are invited on the key issues set out in this document, and any other matters that stakeholders consider relevant.
On 8 October 2010 the Commonwealth Government released the Report of the Prime Minister’s Task Group on Energy Efficiency. The report recommended implementation of a national Energy Saver Incentive Scheme. This paper does not directly address the issues raised in the Task Group’s report or seek comment on its recommendations. If stakeholders feel it is necessary to include comments on the Task Group report as part of their response to this Issues Paper, please ensure these comments are clearly separated from the responses to the issues raised in this paper.
|October 2010||Consultation on Issues Paper|
|February 2011||Consultation on Regulatory Impact Statement for expanded target|
|May 2011||Set target by regulation|
|September 2011||Public consultation on regulations to establish additional activities|
|December 2011||Establish activities by regulation|
|January 2012||Expanded scheme begins|
Consultation opportunities will be advised at www.dpi.vic.gov.au/energy
DPI will hold a public forum on Wednesday 27 October 2010 to discuss the expansion of the scheme and the issues outlined in this paper.
Time 9am Spring Street Conference Centre Theatrette Mezzanine Level 1 Spring Street Melbourne
Interested parties are requested to RSVP to email@example.com.
Closing date for submissions is Wednesday 17 November 2010.
There is no preferred format for submissions. Responses may be published on the DPI website, therefore stakeholders should indicate if the submission is confidential and/or clearly indicate sections that may contain confidential or sensitive information that is not for publication.
Submissions can be lodged as follows:
in writing to
Anthony Williamson Energy Sector Development Division Department of Primary Industries GPO Box 4440 MELBOURNE VIC 3001
Greenhouse Gas Emissions and the Energy Saver Incentive
Through existing initiatives and the new actions outlined in the Climate Change White Paper, and Victoria’s Energy Future statement 2, Victoria is transforming the State’s economy to a low carbon future. Action is required to prepare Victorian households and businesses to address rising energy costs. Support for local business innovation is important to ensure Victoria can benefit from emerging opportunities in expanding sectors such as energy efficiency.
Energy use is the major contributor to Victoria’s greenhouse gas emissions. Energy consumption from the manufacturing, residential and commercial sectors are responsible for a majority of “end-use” emissions. Currently the Energy Saver Incentive scheme plays a key role in reducing residential greenhouse gas emissions in Victoria and helping consumers adjust to rising energy prices.
Victoria’s 2008 Greenhouse Gas Emissions
The data in the graph above is provided in the table below:
|Victoria’s 2008 Greenhouse Gas Emissions|
|Industrial Processes (2%)|
Source: National Greenhouse Gas Inventory, 2010. www.ageis.greenhouse.gov.au/
Victoria’s Greenhouse Gas Emissions (End Use Allocation of Emissions)
The data in the graph above is provided in the table below:
|Victoria’s Greenhouse Gas Emissions (End Use Allocation of Emissions)|
|Passenger Transport (14%)|
|Primary Production Net (12%)|
|Freight Transport (5%)|
Source: George Wilkenfield and Associates – Victoria’s Greenhouse Gas Emissions (End Use Allocation of Emissions) report to the Department of Sustainability and Environment 2008
The Energy Saver Incentive scheme creates a market for residential energy efficiency activities. Tradable certificates are created when residential energy consumers undertake a ‘prescribed activity’ to improve the energy efficiency of their house. ‘Accredited persons’ must follow the approved process to ensure this activity creates a valid certificate, which is then issued by the Essential Services Commission. Each certificate represents a tonne of lifetime greenhouse gas emission savings (carbon dioxide equivalent). Energy retailers must acquire and surrender the appropriate number of certificates per year to fulfil their legislated obligation. This is proportional to their acquisition of residential electricity and gas for the previous year.
The following are the ‘prescribed’ activities currently included in the scheme:
- Installation of insulation, double glazing, weather proofing and gap sealing
- Purchase of a high efficiency fridge or freezer and disposal of an old inefficient fridge
- Installation of high efficiency heating system
- Installation of a solar, heat pump or high efficiency gas water heater to replace a more greenhouse intensive system
- Installation of a water saving showerhead
- Replacement of an inefficient light globe with a low energy alternative
For further information
On the scheme:
On scheme administration:
National Policy Directions
The Report of the Prime Minister’s Task Group on Energy Efficiency (Department of Climate Change and Energy Efficiency 2010) strongly supports a national energy savings initiative that leverages off the existing state schemes, such as the Energy Saver Incentive. This national approach has potential benefits, however it will be important to ensure that Victorian businesses and consumers are not disadvantaged, should this recommendation be implemented. Significant further consultation and regulatory development would be required before such a broad scale proposal can be delivered.
The Victorian Climate Change White Paper provides direction and certainty for the next phase of the Energy Saver Incentive scheme. Businesses require regulatory certainty to support their business models, and this development of the Energy Saver Incentive provides that certainty. A strong program will be of significant benefit to Victoria whether or not a national program is developed.
The introduction of a carbon price in Australia would impose a cost on greenhouse gas emissions, thus including emissions in transaction decisions. Under a carbon tax, the abatement savings derived from the Energy Saver Incentive will be “additional” to the pricing mechanism. In the presence of an emissions trading scheme (ETS), the Energy Saver Incentive will not provide additional abatement beyond the set target of the ETS, although it will deliver low-cost abatement from measures that are difficult to fully incentivise through an ETS due to residual market barriers. This approach supports the COAG Complementarity Principles, developed to guide the assessment of emission reduction measures to complement emissions trading. It will assist in reducing the societal costs of achieving a specified greenhouse abatement target.
In the absence of a national carbon pricing mechanism, the Energy Saver Incentive scheme will continue to accelerate greenhouse gas abatement, by reducing the demand for energy.
Barriers to the uptake of energy efficiency measures
The Energy Saver Incentive was established to increase the level of energy efficiency in Victoria and reduce greenhouse gas emissions by overcoming market failures and other barriers which prevent the uptake of cost effective energy efficiency measures in residential households.
Market failures occur when market systems do not allocate resources to achieve the greatest societal good. The Regulatory Impact Statement for the Victorian Energy Efficiency Target scheme published in September 2008, and the Prime Minister’s Task Group Report explore in detail the market failures that constrain the uptake of energy saving activities.
The case for intervention
There are a number of market failures and barriers that prevent the optimal uptake of energy efficiency measures in Victorian households and businesses. The Report of the Prime Minister’s Task Group on Energy Efficiency released in October 2010, summarised impediments to households and businesses taking up energy efficiency opportunities as follows:
- Lack of information. When information has public good characteristics it is likely to be underprovided by the private sector as there is little incentive to do this. Therefore there is insufficient information available about the benefits of investing in equipment and technology that yield long-term savings that outweigh initial costs. For example, property owners can be unaware of their buildings’ energy consumption, and small businesses can be unaware of the energy implications of their consumer choices. Gathering trustworthy information is costly and time consuming; linking action to energy bills may be difficult for consumers.
- Skills gaps. Skills gaps can occur for energy users, business providing energy efficiency services, and those providing auxiliary services such as finance, valuation and legal services. Skills gaps in one sector can lead to skills gaps in other sectors. For example if the financial sector does not recognise returns on energy efficiency projects they may not proceed.
- Split incentives. Motivation will be weak where businesses that bear the costs of undertaking energy-efficiency actions do not enjoy the benefits. For example, landlords and tenants in commercial buildings have different incentives for energy-efficiency upgrades.
- Behavioural, organisational and cultural factors. Even where information is available, established norms may affect decision making. For example where decision makers do not consider improved energy efficiency to be worthy of investigation.
- Externalities. Energy efficiency can benefit other parties, where this ‘externality’ is not valued then the potential benefits may not be appreciated. For example, energy efficiency can reduce the need for investment in expanded energy supply, or innovation can lead to benefits for others who have not borne the initial investment costs.
The Task Group report notes that many of these non-price based barriers described will continue to exist even with a carbon price
The current Energy Saver Initiative model is likely to be effective in the SME sector as SMEs, like households, may lack the time to investigate energy efficiency opportunities or participate in programs. Small businesses tend to be ‘time poor’ and focused on their core income generation activities. Where a business has a low energy cost as a proportion of total operating cost, this may also reduce focus on energy efficiency measures. Energy using appliances, including heating and cooling systems, may not be under the control of small businesses, reducing the opportunity to directly address consumption.
The Victorian Government currently provides a range of other support programs for SMEs. These include the Grow Me the Money and Resource Smart programs, which provide a range of sustainability resources for SMEs and the Carbon Down program which provides business partnership opportunities to promote emission reduction.
The National Framework on Energy Efficiency (NFEE) has found evidence to show that most businesses can reduce energy consumption by 20% through better equipment maintenance and upgrades, smarter systems and energy efficiency technologies. Additionally, the NFEE research has found that savings of up to 30% per annum could be found from a targeted program in organisations that have not actively managed energy previously.
Larger energy users do not face the same uptake barriers as smaller users. Larger users have a more sophisticated understanding of their energy consumption and a greater incentive to act. Their capacity to respond is also assisted by state and federal government policy interventions. For example the Victorian Government’s Energy and Resource Efficiency Plan regulatory measure and the Commonwealth’s Energy Efficiency Opportunities Program are aimed at large energy users.
Energy Saver Incentive scheme performance
The Energy Saver Incentive commenced in January 2009. The first year’s annual target of 2.7 million tonnes of abatement was easily met in 2009. The 2010 target has also already been met. The first three year phase of the scheme, to be completed by the end of 2011, will save 8.1 million tonnes of greenhouse gas over the lifetime of the activities undertaken.
Victorian Energy Efficiency Certificates (VEECs) created
(inc. current status as at 27 September 2010)
|VEEC created||2009||Sept 2010||Totals|
|Total VEECs created||3,667,472||1,969,805||5,637,277|
Each VEEC created represents a reduction of a lifetime tonne of greenhouse gas emissions due to the scheme. More than 440,000 households have participated in the scheme in the thirteen months to 31 January 2010.
Market data from the administrator of the scheme, the Essential Services Commission, shows strong uptake of two activities that DPI understands were provided at low, or no cost to residential households3: the installation of low energy lamps and low flow shower roses. Hot water upgrades also generated a large number of certificates, due to the fact that this activity mitigates a significant level of greenhouse gas emissions.
The performance data suggests the market failures exist and demonstrates that the scheme can be effective in overcoming barriers to energy efficiency. This provides a sound basis for further consideration of an increase in the scheme target and broadening of existing activities.
Currently, certificate prices are at the lower end of the modelled price range. This is to be expected during the initial phase of the scheme, where those measures that can be provided at a lower cost will be delivered first. As these items are exhausted, and the target expanded, the cost of certificate generation is expected to increase.
The scheme has been successful in achieving its objective of encouraging investment, employment and technology development in industries that supply goods and services which reduce the use of electricity and gas by consumers. Any person can become accredited and create certificates under the scheme (subject to eligibility requirements). To date, more than 75 businesses have become accredited.
Regulatory Impact Assessment
The target for each year of the period 2012-14 must be set by 31 May 2011 to comply with the legislative framework of the Energy Saver Incentive. A Regulatory Impact Statement (RIS) will examine the impacts of an increased target. The Victorian Guide to Regulation outlines the elements of a RIS to achieve best-practice regulation and minimise community burden.
Submissions to the Issues Paper will be used in the development of the RIS. This consultation will be used to shape the main options to achieve the objectives of the regulations and the costs and benefits
of the options.
Key issues for consultation
In considering the changes to the scheme outlined in the Climate Change White Paper, Stakeholder views are sought on key issues
1. An increased target
On 26 July, the Premier John Brumby announced that the target for the Energy Saver Incentive would be doubled, and that the scope of the scheme would be expanded beyond the residential sector to include small and medium enterprises.
Since the commencement of the scheme almost two years ago, certificates representing more than 5.6 million tonnes of abatement have already been generated, mainly through capturing the “lowhanging fruit” in the residential sector – that is, the low-cost activities such as lighting replacement. This is consistent with forecasts undertaken by government leading up to the introduction of the scheme. Given the Victorian Government’s intent to increase the target, and include SMEs, further analysis is required to forecast the energy efficiency or fuel substitution activities that are likely be taken-up in the expanded scheme and the likely “share” of the activity between residential and SME sectors. This analysis will inform an analysis of the costs and benefits of expanding the scheme, including estimating the cost of compliance and the types of eligible activities that could be considered to meet the target.
Whilst some commentators believe the low cost abatement opportunities may be nearing exhaustion, others believe there is still potential in the residential market for further low cost abatement.
The Department has recently drafted amendments to the Victorian Energy Efficiency Target Regulations to include new activities in the scheme. The following activities are under consideration:
- Expanded coverage of lighting
- Updated coverage of high efficiency refrigerators and freezers
- Replacement of refrigerative air conditioner with evaporative cooler
- Purchase of high efficiency television
- Installation of energy efficient (low greenhouse intensity) clothes dryer
- Installation of high efficiency pool pump
- Installation of standby power controller
- Expanded coverage of high efficiency gas ducted heaters
- Replacement gas heating ductwork
Development of the Energy Saver Incentive scheme will benefit from greater understanding about the energy efficiency opportunities with the highest potential for uptake under the Energy Saver Incentive scheme for SMEs, and the magnitude of energy and greenhouse savings which could be achieved.
Energy savings opportunities for SMEs will be analysed as part of the regulatory impact statement process so that the expansion can target those industries that provide the greatest savings potential and are constrained by market failures.
Many of the existing residential activities may be appropriate to apply to the SME sector. Lighting, heating and cooling, refrigeration and hot water generation are activities undertaken by many SMEs. However, there may be opportunities to expand or refine the list of activities to take account of other new opportunities specific to SME operations. Inclusion of those activities that have a measurable level of energy savings and have wide application will be most appropriate.
What is the nature and impact of barriers to optimal energy efficiency in the SME sector?
Which energy efficiency measures should be included under the Energy Saver Incentive Scheme for SMEs?
What is the nature and size of savings (from the activity and total potential across the sector) of the energy efficiency opportunities for SMEs?
What is the nature and size of savings (from the activity and total potential across the sector) of the remaining residential energy efficiency opportunities which could be covered by the Energy Saver Incentive Scheme?
What are the most critical barriers to their adoption?
2. Scheme scope – expanding the scheme to include small and medium-sized enterprises (SMEs)
The SME definition for the Energy Saver Incentive scheme will prescribe the types of businesses eligible to create certificates.
The term SME may be interpreted in a variety of ways. A clear and easily administered definition is required in order to enable effective administration. A definition that is consistent with other schemes or classifications would be advantageous, but not at the expense of the efficient and effective operation of the Energy Saver Incentive scheme.
It will also be important to ensure that there are no inappropriate gaps or double coverage of businesses. For example the Environment Protection Authority’s (EPA) Environment and Resource Efficiency Plan (EREP) Program requires any site using more than 120ML of water and/or 100TJ of energy in any financial year to submit a Plan which identifies all opportunities with a simple payback period of three years or less to the EPA for approval. Actions must be implemented in the approved Plan according to the implementation schedule. Sites with significant energy consumption are therefore already covered through this program.
Participation in the scheme by SMEs wishing to benefit from energy efficiency activities will be voluntary, however the regulatory burden should be minimised to ensure there are minimal barriers to participation. A simple definition of included SMEs will assist in minimising the administrative burden for the ESC and for participating SMEs.
Defining “Small and medium”
The purpose of the Energy Saver Incentive is to promote energy efficiency and reduce greenhouse emissions. Therefore the most useful definition may relate to energy consumption. Energy consumption could be expressed either units of energy (i.e. kilowatt-hours of electricity and megajoules of gas) or the dollar value for a given period.
An energy based definition would promote a consistent regulatory approach with the EREP Program. Businesses covered under the EREP Program could be exempted from the Energy Saver Incentive Program, promoting coverage of the remaining businesses. However the energy consumption of the remaining businesses and industries varies widely and may require a variety of approaches to enable their appropriate inclusion.
Importantly an energy based definition would be consistent with the VEET Act that allows certificates to be created by consumers of energy. This approach may have the benefit of allowing a simpler definition in the legislation and regulations. Furthermore, this method has the benefit of utilising established consumption brackets to facilitate consistency.
The following boundaries are commonly applied in the electricity sector and often referred to by the government when defining policy programs (such as the Smart Meter program and various assistance programs):
- Small: less than 40 megawatt-hours (MWh) per annum (typical bill~ $8,000)
- Medium: 40 - 160 MWh per annum (typical bill ~ $30,000)
- residential consumers typically use 6 MWh per annum and could expect to pay around $1,400 per year.
- Inclusion in the EREP scheme is triggered at around 28,000MWh per annum
Alternative definitions of SMEs, such as those used by the Australian Bureau of Statistics (ABS), often utilise employee numbers or annual financial turnover. These definitions are unrelated to the objectives of the scheme, and would require additional actions by the ESC and SMEs to determine inclusion. Such definitions may act as a barrier to access the benefits of participating.
The term ‘enterprise’ also requires consideration both in terms of the nature of the organisations which would be eligible, and whether eligibility thresholds should be determined at a site level or across an organisation.
To promote regulatory simplicity, a broad definition based on site energy use may be desirable. There may also be a benefit in excluding specific types of enterprises where this would demonstrably improve the policy outcome.
The following considerations may be relevant:
- Consideration of ‘site’ or ‘corporation’ energy use. Under the Commonwealth Government Energy Efficiency Opportunities scheme, participation is mandatory where corporations use more than 0.5PJ of energy per year. This will include some sites of significantly lower energy use. It may be appropriate to exclude any corporation (and covered lower energy using sites) that triggers the EEO energy use threshold.
- SMEs with multiple sites across Victoria, or rent facilities where the cost of some energy services (air conditioning, lighting) is part of their rent. It will be important to ensure these businesses can benefit from the scheme without undue burden. For example, consider the common situation where major retail chains operate a number of shopfronts in shopping centres across Victoria.
- Public sector entities, such as local governments, schools, hospitals and smaller offices. Inclusion would provide an opportunity for these entities to benefit from the scheme. It also may be difficult to separate public and private schools and hospitals, as many private facilities also draw on public funding.
- Government Departments. If it was decided to allow some public sector entities to be eligible under the scheme, it could still be desirable to specifically exclude Government departments.
Regardless of the definition used it will be important to ensure the sector can be readily identified. If the burden of proof is too high, participants may find this a barrier to benefiting from the scheme.
What is the best way to define a “small to medium enterprise” under the Energy Saver Incentive, taking into consideration the ease of verifying the eligibility of businesses?
Are there any reasons to include separate definitions of “small” and “medium” under the scheme?
Would site based eligibility set at 40 or 160 MWhs annual consumption be appropriate or acceptable?
How should enterprises that operate a number of sites across Victoria (i.e. retailer outlets) be treated under the Energy Saver Incentive?
What entities should be included or excluded? (ie should public-sector entities such as schools and local government offices, or corporations coved by the Energy Efficiency Opportunities scheme be included?)
What is the best way for government to ensure that an enterprise wishing to participate in the Energy Saver Incentive is eligible to do so?
3. Energy retailer liability for the scheme
Under the current scheme, energy retailer obligations under VEET are determined by the volume of residential energy “acquisitions” each retailer purchases from the national electricity market and the national gas market. This data allows greenhouse gas (GHG) reduction rates to be determined which assist retailers to calculate the total amount in tonnes of carbon dioxide equivalent of greenhouse emissions they are liable for in respect of electricity and gas in a year, and hence the number of certificates they must acquire and acquit in a reporting year.
The obligation specifically relates to the level of greenhouse gas emissions that can be attributed to residential customers. Its chief purpose is to allocate energy retailers their proportionate share of the certificate obligation. While the obligation relates to the residential sector, this does not impact the way in which retailers determine their tariffs as they apply to various classes of customers.
With the expansion of the scheme into small and medium enterprises, it is appropriate to refine the way in which the obligation on energy retailers is set. The existing rationale may simply be adopted, by including acquisitions from the SME sector, or through an alternative approach, such as simply considering total retailer energy acquisitions.
The definition of an SME will also impact the ability of retailers to determine their acquisitions, and it will be important to ensure the regulatory burden of determining retailer obligations is minimised.
What is the best way to allocate energy retailer obligations under the Energy Saver Incentive, to ensure it is equitable and the regulatory burden is minimised?
Can energy acquisitions for SMEs be readily identified by retailers and/or other market operators?
4. Assigning abatement values
The Energy Saver Incentive prescribes a range of specific energy efficiency activities that are awarded Victorian Energy Efficiency Certificates (VEECs) based on a “deemed” level of greenhouse gas abatement that can be attributed to the activity. Eligible activities are currently limited to the residential setting, and are listed in the Victorian Energy Efficiency Target Regulations (the regulations).
The number of VEECs awarded to each activity is determined by the estimated lifetime energy savings resulting from implementation of the activity in an average Victorian dwelling, and adjusted according to other factors such as climate, the size of the installation and/or the residential site. These factors are described in the regulations, along with either the number of certificates allocated to each measure, or an algorithm which can be used to calculate the number of certificates allocated.
Deemed abatement is a convenient way of assigning value, as it enables the activity creator – otherwise referred to in the legal framework as the Accredited Person – to receive a number of VEECs up-front through the scheme administrator, which can then be on-sold or traded.
In the SME sector energy end use is much more diverse than in the residential sector – there are a wide range of different businesses, with different operating hours, and which have different energy service requirements. While straightforward deeming might be applicable to certain activities in the SME sector (eg simple lamp replacements), for other activities it might be necessary to take a different approach.
To capture opportunities that are specific to circumstance or “custom” in application, several options could be considered. The activity could be valued by considering the difference in energy consumption before and after the installation of the activity, or set of activities, through meter-reading. Where data is unavailable, an estimate could be made of the annual energy savings; the number of certificates allocated could be calculated from the annual abatement multiplied by the assumed lifetime of the measure, mediated with a risk or confidence factor.
These custom deeming assessments would require a greater degree of administration, and efficient and effective regulation to verify the claimed energy savings. The increased cost of verifying this approach might also warrant a minimum certificate threshold before such an approach could apply.
A combination of simple deeming and custom deeming might also be appropriate. This type of approach is currently used for some SMEs under the NSW Government’s Energy Savings Scheme.
In expanding the scheme to SMEs, what are the benefits and risks of establishing:
What new activities would be best suited to project-based deeming assessments?
How can project-based assessments be efficiently and effectively regulated?
For SMEs are there any special circumstances or sectors which would benefit from a different approach to certificate generation than that used in the residential sector?
What other methods of assigning abatement values should be considered?
5. Communication and promotion
The Victorian Government has supported the success of the Energy Saver Incentive with marketing and promotion of the scheme to both business and the community.
Communication activity promoting the scheme has had dual objectives, seeking to encourage business accreditation, as well as providing support for accredited persons to promote the Energy Saver Incentive to their customers.
Prior to the commencement of the scheme in late 2008, the Victorian Government developed and deployed a communication strategy aimed at encouraging accreditation and supporting the first accredited parties to promote activities under the scheme.
As part of this initial communication phase, targeted email and stakeholder communications were delivered to a wide range of large and small business audiences, garnering requests for further information from more than 1,000 enterprises.
Consumer focused communication soon followed through the Government’s energy efficiency website, www.saveenergy.vic.gov.au.
In addition, the Government has developed a suite of marketing materials, such as brochures, posters and graphics, for order by accredited businesses and has funded exhibits at relevant conferences at which businesses could attend to promote their activities. Finally, media and public relations promotion of the scheme has also been delivered by the Victorian Government from the program’s inception.
The Victorian Government will continue to support the scheme’s success by ensuring business and communities are informed of the opportunities it presents, particularly as changes and additions to the scheme take effect.
It’s also anticipated that direct consumer participation in the scheme will be driven by promotion by accredited persons.
Stakeholders are invited to input into the development of a second stage communication strategy, which supports increased consumer promotion of the program.
What types of consumer communication would stakeholders expect Government to deliver on the Energy Saver Incentive? What strategy would support accredited businesses to engage with consumers on the program?
What communications would support interested businesses through the process of accreditation?
1 Taking Action for Victoria’s Future, The Victorian Climate Change White Paper – The Action Plan. www.premier.vic.gov.au/climate-change
2 Victoria’s Energy Future statement, 2010, www.dpi.vic.gov.au
3 VEET Performance Report 1 January 2009-31 January 2010 (www.esc.vic.gov.au)