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Submission regarding removal of ACCU method for lighting upgrades.
Alan Pears AM apears@c031.aone.net.au
I appreciate that a case can be made that the cost of LED lighting upgrades has declined and that mandatory codes are driving progress towards LEDs.
However, this should be put into a broader context.
Why do renewable energy projects that were built many years ago still gain credit for voluntary abatement under the ClimateActive scheme when they have repaid their cost some years ago? And why can new renewable energy investments that are cost-effective still gain subsidies?
While LEDs may be cost-effective the reality is that many upgrades to existing buildings and tenancies that should invest in cost-effective lighting do not, because very rapid payback periods are usually demanded.
Mandatory standards do not set high standards: they lag behind best practice. For example, LED lighting continues to improve in efficiency, while smart controls also improve. There should be incentives for those who install ‘beyond mandated level’ equipment.
For many projects, costs of upgrades are still high. For example, I know of an apartment renovation that was quoted $3000 to upgrade old LED lighting from downlights that leak air and require insulation to be removed from around them to new higher efficiency lamps that are airtight and can have insulation over them. These will deliver significant energy savings and emission reductions.
The reality is that many activities that could be deemed ‘business as usual’ are still eligible for incentives – and they require incentives to overcome market distortions. Lighting fits this category.
