Submission by Lewin Consulting to the Issues Paper on the Expansion of the Energy Saver Incentive

28 October 2010

Michael Lewin
ABSA Accredited Thermal Performance Assessor 32289
Chairman of Owners Corporation Committee - Southside Gardens

1. Introduction:

I have been attempting, along with the Committee, to reduce the carbon emissions of the 91 apartments in our complex. Like 10s of 1000s of other apartment and flats built between 60s and early 2000s, our apartments (17 years old) have little or no insulation, and poor windows. We have achieved a fair bit by picking the low hanging fruit, e.g. lighting, pool heating, etc., but the big ticket items are in the thermal performance of the building. Owners are responsible for their own electricity, however there is also a large amount used by the complex in common. This amounts to an average of 150 KWh per day.
As you will see from what follows, the big ticket items are so poorly supported by this VEET program that they really are effectively excluded.
All of the issues raised below will apply to SMEs, particularly in an office environment.

2. Positioning of Owners Corporation:

I understand that the owners corporation could have registered under VEET and be the collector of the VEECs while promoting the program with the owners and also undertaking the upgrades for the common use. This would overcome the fact that none of the vendors we looked to use, were registered with or interested in registering with, the Energy Saver Incentive program.
When attempting this we did the calculations and found that our registration fee would hardly be covered by the savings and any reasonable assessment of the cost of time spent on processing the paperwork. I came to the conclusion that it had to be the vendors who were registered. As a follow on from this, the dollars involved were not enough to affect our choice of vendor nor to motivate the vendors to register.
The Owners Corporation need to be able to act as an entity for the common use items, separately from encouraging the owners to act on their own behalf for the individual units. I believe this is possible under the current scheme.
Given expansion to include SMEs, we could also be classified as such, given we would be an organization (Corporation) with an ABN number that does business and signs contracts. We could still act as an agent for the individual owners, who would need help applying for non common items.

3. Big Ticket Items

3.1. Window Replacement

The Owners Corporation undertook to replace 70 odd windows and glazed doors which had rotten frames and reveals, at common expense. This may in fact be an on-going requirement as the existing 450 windows and glazed external doors age. We took the opportunity to get quotations for high performance windows. Ultimately we accepted a quote from Certainteed to supply double glazed PVC framed windows and doors with 12mm gap and in most cases, argon filled, for the same price as timber framed single glazed.

In addition, we encouraged individual owners to take advantage of this to upgrade their windows by offering a $200 rebate per window/door. Many have.

VEET Problems:

• The VEET scheme insists on a minimum of 5m2 per application. Many of the apartments did not do all of their windows and doors and so fell short of this. Buildings of this era do not have the large windows of modern buildings.
  I believe 3m2 would be more reasonable.
• The VEET calculator allowed 3 VEECs for the 5m2. The cost of 5m2 is $5,000 to $6,000 at our much discounted rate. 3 VEECs will give us about $21 at the value at the time. It does not justify the paperwork.
  It would have to be in excess of 10% to be worth the effort. This would at least be 85 VEECs.
• I tried to interest the vendor Certainteed in registering, having realized it would not work for us. There was no incentive for them to do this.
• This change to an apartment delivers a 1 star improvement in Rating and saves approximately 3,332 MJ (48 MJ/m2 for 70m2). Refer appendix A & B.

3.2 Floor Insulation

The typical suspended concrete floor is over an exposed or semi exposed car park. These days it would have to be insulated but at the time these were built is was not. The apartment heating heats this slab only to see it dissipate through the air moving across the under surface. The ceiling of the car park is this surface, and is criss crossed with plumbing, conduit and lighting. To get insulation applied is difficult. Apparently simple solutions like foilboard become very difficult to fit. The labour involved multiplies the cost. A spray on solution is the only reasonable solution. This must be one that satisfies fire concerns and concerns regarding any dropping of fibre. We found a product called Monoglaze by Thermatech. It was expensive but could be applied easily.

VEET Problems:

• The VEET scheme insists on a minimum added R value of R2.5. This is ridiculous. The BCA standard for 5 star rating on a suspended concrete slab over an open area is R1.35 added. Next year with 6 star and BCA 2010 coming into force, it will be R1.79 for this zone.
  This needs to be changed to > R1 added.
• The VEET calculator, when tricked into reporting by entering R2.6, allowed 5 VEECs for the 70m2. This insulation cost approximately $2,300 and only $35 was able to be claimed under VEET.
  It would have to be in excess of 10% to be worth the effort. Perhaps 33($230) VEECs.
• This change to the apartment delivered an improvement in the rating of 1.9 star and delivered a reduction of 5376 MJ for 70m2 (77 MJ/m2). Refer Appendix A & B.

3.3 Ceiling Insulation

The roof of these buildings, as for SMEs will invariably be metal deck. In some instances they may be raked or cathedral as with this building. When these were built prior to 5 star ratings, only an aircell foil at best was used, and it was compressed to a point where it contributes little. It was largely there to meet the condensation requirement. To insulate these it is typically required to lift every second metal sheet, cut back the sisalation, and insert batts. If it was flat a loose fill could be sprayed in but his may be dangerous as where it settles will not be seen.

We obtained quotes for installing these per apartment. Given the qualified roofing labour required, these were of the order of $1800 after taking out the rebate that existed at the time. I would equate this to about $2500 now. These were competitive given the number of apartments that could be involved.

VEET Problems:

• The VEET system has excluded ceiling insulation since the Federal Government Rebate was introduced. This is unlikely to be reintroduced any time soon.
  I would therefore encourage this to be re-opened.
• Using the Calculator on a 70m2 roof, the system assigns 22 VEECs. This would amount to a value of $154. As a proportion of the cost of insulation for a flat metal deck roof, this is trivial.
  If it was in excess of 10% or $250, that is 36 VEECs, then this would be worth considering as an incentive.
• I believe that there needs to be a separate category of “Flat Metal Deck Roof” to reflect this.
  It requires more VEECs than an attic roof where access is a given.
• This change to the apartment delivered an improvement in the rating of 2.1 star and delivered a reduction of 7000 MJ for 70m2 (100 MJ/m2). Refer Appendix A & B.

3.4 Garage Lighting

We have a plan to replace all of the garage lights which are double fluorescents. This would be typical of garage lights in SMEs. There are about 20 doubles in all. These are not globe replacements but light fitting replacements with T5 units or LEDs. The adaptor fittings that are available are problematic and do not seem an effective approach to this. Thus an electrician needs to be engaged. This is an Owners Corporation Expense rather than an owners expense.

The VEECs assigned need to reflect the use of an electrician or change over the fittings.

Appendix A. Energy Savings on Prime Drivers in Apartments

Note:

1. Ceiling insulation is currently suspended. As it does not appear likely the federal government will do anything soon, this should be opened.
2. Subfloor insulation is currently not operational due to error in minimum threshold of R value added. It asks for > R2.5.
3. VEEC values assigned are so out of proportion to the cost that no one would bother with the paperwork.

Explanations:

1. Ceiling Insulation is generally under metal deck flat or raked roofs and will require every second metal sheet to be raised.
   This adds significantly to the cost.
2. Subfloor insulation below a suspended concrete floor must be fitted around plumbing, lighting and electrical conduit.
   It must not drop fibres and have a high fire rating.
   This generally rules out batts and boards require too much labour to cut in. Spray on solutions such as Monoglass only are cost effective.
   BCA Standards for 6 Star Zone 6 (most Vic) (due next year), require a total for R2.25, including the flooring. A suspended slab not enclosed has a value of R0.46. Therefore the required R value is R1.79. With 5 star (current) it is R1.35.
3. Double Glazing, timber/pvc framed with 12mm gap, argon filled and a low E glass pane is used in the example. These are expensive items.

Appendix B. Thermal Performance Assessments

1. Top Floor Apartment - no improvements

FirstRate Report

Rating	3.5 stars
Energy	Total	244.2 MJ/m2
	Heating	164.9 MJ/m2
	Cooling	79.3 MJ/m2
Area Corrected Energy	Total	225.3 MJ/m2
	Heating	152.2 MJ/m2
	Cooling	73.2 MJ/m2
Areas	NCFA	25.7 m2
	NUCFA	0.0 m2
Climate	21 Melbourne RO
Site Exposure	suburban
Client Name	Lewin
Rated Address	17/106 Southbank Blvd Southbank 3006
Accredited Rater	Mick Lewin ABSA 32289
Date
Reference
Comment

This rating only applies to the floor plan, construction details, orientation and climate as submitted and included in the attached stamped plans.

Changes to any of these could affect the rating.

Summary 27-10-2010 07:57:40 EST
Ver:5.0 Build:226
Accredited Rater:Mick Lewin ABSA 32289

2. Top Floor Apartment - ceiling (R3.5) insulation

FirstRate Report

Rating	5.6 stars
Energy	Total	135.4 MJ/m2
	Heating	65.9 MJ/m2
	Cooling	69.6 MJ/m2
Area Corrected Energy	Total	125.0 MJ/m2
	Heating	60.8 MJ/m2
	Cooling	64.2 MJ/m2
Areas	NCFA	25.7 m2
	NUCFA	0.0 m2
Climate	21 Melbourne RO
Site Exposure	suburban
Client Name	Lewin
Rated Address	17/106 Southbank Blvd Southbank 3006
Accredited Rater	Mick Lewin ABSA 32289
Date
Reference
Comment

This rating only applies to the floor plan, construction details, orientation and climate as submitted and included in the attached stamped plans.

Changes to any of these could affect the rating.

Summary 27-10-2010 07:59:06 EST
Ver:5.0 Build:226
Accredited Rater:Mick Lewin ABSA 32289

3. Lower Floor Apartments - no improvements

FirstRate Report

Rating	4.0 stars
Energy	Total	209.6 MJ/m2
	Heating	155.4 MJ/m2
	Cooling	54.2 MJ/m2
Area Corrected Energy	Total	193.4 MJ/m2
	Heating	143.4 MJ/m2
	Cooling	50.0 MJ/m2
Areas	NCFA	25.7 m2
	NUCFA	0.0 m2
Climate	21 Melbourne RO
Site Exposure	suburban
Client Name	Lewin
Rated Address	17/106 Southbank Blvd Southbank 3006
Accredited Rater	Mick Lewin ABSA 32289
Date
Reference
Comment

This rating only applies to the floor plan, construction details, orientation and climate as submitted and included in the attached stamped plans.

Changes to any of these could affect the rating.

Summary 27-10-2010 07:59:58 EST
Ver:5.0 Build:226
Accredited Rater:Mick Lewin ABSA 32289

4. Lower Floor Apartments - sub-floor insulation

FirstRate Report

Rating	5.9 stars
Energy	Total	126.4 MJ/m2
	Heating	62.3 MJ/m2
	Cooling	64.0 MJ/m2
Area Corrected Energy	Total	116.6 MJ/m2
	Heating	57.5 MJ/m2
	Cooling	59.1 MJ/m2
Areas	NCFA	25.7 m2
	NUCFA	0.0 m2
Climate	21 Melbourne RO
Site Exposure	suburban
Client Name	Lewin
Rated Address	17/106 Southbank Blvd Southbank 3006
Accredited Rater	Mick Lewin ABSA 32289
Date
Reference
Comment

This rating only applies to the floor plan, construction details, orientation and climate as submitted and included in the attached stamped plans.

Changes to any of these could affect the rating.

Summary 27-10-2010 08:02:47 EST
Ver:5.0 Build:226
Accredited Rater:Mick Lewin ABSA 32289

5. Lower Floor Apartments - Double Glazed windows only

FirstRate Report

Rating	5.0 stars
Energy	Total	158.0 MJ/m2
	Heating	110.1 MJ/m2
	Cooling	47.9 MJ/m2
Area Corrected Energy	Total	145.8 MJ/m2
	Heating	101.6 MJ/m2
	Cooling	44.2 MJ/m2
Areas	NCFA	25.7 m2
	NUCFA	0.0 m2
Climate	21 Melbourne RO
Site Exposure	suburban
Client Name	Lewin
Rated Address	17/106 Southbank Blvd Southbank 3006
Accredited Rater	Mick Lewin ABSA 32289
Date
Reference
Comment

This rating only applies to the floor plan, construction details, orientation and climate as submitted and included in the attached stamped plans.

Changes to any of these could affect the rating.

Summary 27-10-2010 08:07:27 EST
Ver:5.0 Build:226
Accredited Rater:Mick Lewin ABSA 32289