ESIA Submission - VEU Refrigerated Display Cabinets Issues Paper, 19 Aug 2021
The ESIA’s recommendations focus on some key challenges listed below.
- Review the NSW ESS proposed Rule change consultation outcomes on RCs and align the VEU approach.
- Lower the baseline for RCs as the average efficiencies in the database will be higher than the average product being installed for two reasons:
- the majority of products being purchased will be the lowest cost units and hence lowest efficiency; and
- self-report testing and registration under GEMS will result in some inaccuracies (inflation of the efficiency of RCs).
- Allow RCs registered under GEMS 2020 to be claimed throughout 2021 once the new Specification is released.
- Use a common lifetime of 12 years for RCs to avoid incentivising larger cabinets (which consume more energy) to be installed in preference to the right sized cabinet.