ESIA Submission: VIC Building Electrification RIS Consultation, 28 Feb 2025
The ESIA welcomes the Victorian government’s approach in its Building Electrification RIS to addressing the long-term challenges of gas supply for Victoria known to have been reducing for decades. The government’s recommended approach in the RIS provides a clear pathway to support transition away from gas to cleaner lower priced fuels and supports more efficient and smarter technologies. Households, businesses and commercial and industrial sites will benefit from the approach.
The ESIA recommends that the Victorian government reconsider aspects of its preferred option 3 and underlying modelling. Specifically, the ESIA recommends that existing smaller buildings and businesses NOT be exempt from the proposed regulations.
The ESIA recommendation is reasonable given the RIS recognises as stated on p73, that ‘… smaller businesses are more likely to use residential gas appliances’:
‘Recognising that many businesses operate in small buildings, the cost of large buildings was blended with an estimated cost for small buildings. The costs for small buildings were estimated using the residential cost of an upgrade per MJ of gas taken out of the energy system in Victoria, under the assumption that smaller businesses are more likely to use residential gas appliances. Method for estimating residential cost of electrification is provided in section 5.4.1 and further assumptions provided in Table C.5 to Table C.7.’
The ESIA recommendation is also based on learnings from the NSW Energy Savings Scheme (ESS) Home Energy Efficiency Retrofit (HEER) method*. Under the HEER method, it has been found that in a significant number of situations, for smaller businesses with annual electricity consumption of less than 100MWh, similar equipment may be fit-for-purpose as for residential upgrades.
So, if the BE RIS includes these types of sites in the proposed regulations, there will be viable and cost attractive pathways for electrification at gas appliance end of life. (Some exemptions will be reasonable, many of which are detailed in the BE RIS.) Further, in Victoria these sites will be supported by the VEU to reduce equipment upgrade costs.
The ESIA has not responded to the specific consultation questions which primarily focus on seeking further data inputs.
(PDF)
