Responses are due on the 25th February 2011. Energetics has reviewed the changes, which we believe could have a major impact on participants. We are preparing our own response to the Department, based on our extensive interaction with participants across all industry sectors. However, we strongly encourage EEO participants review the table of proposed changes to the EEO program (see pdf "EEO proposed program changes and possible impacts" below), which vary in significance depending on your individual circumstances.
Energetics' EEO specialists are available to advise on the impacts of the changes and we can assist you with preparing a tailored response.
We wish to highlight the following key points to EEO program participants:
1. Further alignment with NGER
Several changes are proposed to further align EEO with NGER, including the re-use of NGER corporate structure and energy data for EEO reporting. For participants with different structures, this will cause some re-alignment, and potentially some boundary changes. It will also result in the reporting of energy that is consumed through transformations from one source to another within the facility.
2. Tenant/Landlord or Owner/Contractor "shared buy-in"
Proposed changes may require co-operation between landlords/owners and tenants/contractors who share site operations. The effect on commercial/retail relationships is not clear, and may require landlords to work with tenants to review a "whole" building, rather than focusing only on base building services.
3. Rewording of Key Elements
Proposed changes to the Key Elements within the Assessment Framework may seriously impact participants. The revised wording of Key Element 3 places far greater emphasis on site investigations and the development of a detailed energy-mass balance. This could greatly increase the depth of analysis and cost required to conduct compliant assessments.
4. Meeting coverage rules
Within the consultation paper, DRET proposes several amendments that could assist participant to meet the 80% coverage rule, including:
a. Providing a mechanism for participants to seek discretion where they have not met the 80% coverage rule, due to significant changes in energy use or portfolio size
b. Enabling participants to count assessments conducted prior to their trigger year, assuming they comply with the assessment framework
View the Department’s call for submissions on the discussion paper for the review of the Energy Efficiency Opportunities Program requirements.