We are consulting on proposed changes to the evidence requirements for the Victorian Energy Upgrades (VEU) cold room activity.
Consultation on cold room (activity 43) evidence requirements
Consultation commences25 November 2021
Consultation closes10 December 2021
We have 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.
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)).
Further information on the cold room activity can be found on the commission website.
Eligibility of multiple cold rooms upgraded with a shared condenser and/or compressor
Stakeholders have 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 is 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 have 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 propose the following changes to the evidence requirements for the activity.
Proof of commercial transaction and energy consumer (tax invoice document) – all activity scenarios
We propose 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 accept 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 propose 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 accept 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 propose 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 is 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 propose 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 accept 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 propose 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 believe this document enables us to confirm that the compressor and/or condenser are indeed common to each of the cold rooms being claimed.
A comparison of current evidence requirements against the proposed requirements are detailed in the document below.
How to submit your feedback
We believe the proposed changes to the evidence requirements provide the right balance of minimising barriers to compliance and ensuring adequate checks are in place to guarantee compliance with the activity requirements.
We invite feedback on the proposed changes to our evidence requirements. Submissions must be received by close of business Friday, 10 December 2021, in electronic format if possible.
Electronic feedback should be made via email to email@example.com and contain the subject line: ‘Consultation on cold room (activity 43) evidence requirements’
Submissions by mail should be addressed to:
Essential Services Commission
Victorian Energy Upgrades
Level 8, 570 Bourke Street
Melbourne VIC 3000
We will be holding an online workshop on 2 December 2021 from 10am to 11am. In the workshop we will discuss the proposed changes. Participants will also be able to raise other questions about eligibility of different cold room upgrade situations and/or the requirements we have set for this activity.
To participate in this workshop, please RSVP to: firstname.lastname@example.org by close of business Tuesday, 30 November.
When making a submission, you are required to provide personal information, such as your name, email address, town of residence and postcode. We may use this information to send you updates about this review. We may also collect personal information when you contact us with a query.
Aside from any exceptions in relevant privacy legislation, we will not use or disclose the information you provide for any purpose other than to progress and respond to your query. You have the right to access personal information we hold about you, which may be subject to a small fee. You can also request that we correct your personal information in our records (at no charge) by contacting email@example.com.
We will publish your submission
Unless you instruct us otherwise, we will publish your submission on the commission website. This may involve publishing your full name, however your address will not be disclosed.
We generally do not accept anonymous submissions. If you have concerns about your identity being made public, please consider making your submission confidential rather than submitting it anonymously.
If you believe your submission contains information that is commercially sensitive or should be treated as confidential, you must let us know why in writing. If we agree the information is commercially sensitive or confidential, you will need to provide one complete and one redacted version. Documentation can be redacted by blocking out the relevant confidential information rather than deleting it.
If you make your submission public (for example by supplying it to the media) we will assume that confidentiality no longer applies to your submission and will publish the unredacted version.
Read more information about our submissions policy.
If you have any questions or feedback regarding this consultation, please contact Victorian Energy Upgrades support on (03) 9032 1310 or firstname.lastname@example.org