Table : Stakeholder groups overview SH Group Selection Criteria Int. Primary focus of questions DoIS E3 staff Knowledge of planning processes and priorities, funding arrangements 2 Type A Expectations and delivery of E3, GEMS, IGA process and objectives. Planning product selection process. Opportunities to improve coordination between federal and state governments. Funding breakdown inc. alternative arrangements applied elsewhere in government. Opportunities for cost effectiveness: improvements to process and communication. Alternative schemes (to E3, GEMS, MEPS) and implications (inc. whole of scheme; part of scheme; individual product initiatives). DoIS E3 staff Process knowledge 5 Type B Expectations and delivery of E3, GEMS, IGA process and objectives. Planning product selection process. Opportunities to improve coordination between federal and state governments. Opportunities for cost effectiveness: improvements to process and communication. Alternative schemes (to E3, GEMS, MEPS) and implications (including whole of scheme; part of scheme; individual product initiatives) State representatives on the E3 Committee State perspective Funding knowledge Understanding of state industry impacts Knowledge of E3 work 11 Type C Expectation and delivery of E3, GEMS, IGA process and objectives. Planning product selection process. Opportunities and implications for process improvement.
When comparing the cost of compliance with labelling and MEPS, the results are broadly similar with similar proportions of respondents feeling positively or negatively about them. Efficiency of GEMS Process – Registering 36 % of manufacturing respondents and 43% of regulator/government respondents have found the registering part of the GEMS process very effective or quite effective compared to the 25% of manufacturers who have found it quite ineffective or very infective. No regulator or government respondents have found the process ineffective but there are a large proportion who either don’t know or who haven’t stated either way (57%). Efficiency of GEMS Process- Testing 50% of manufacturing respondents and 43% of regulator/government respondents have found the testing process either very effective or quite effective. Only 11% of manufacturers responded negatively stating that the testing was quite ineffective and no regulator/government, but as in the previous question there is a large proportion who don’t know or who think it is neither effective nor ineffective (57%). How efficient is the GEMS Process – Labelling 44% of manufacturing respondents and 86% of regulator/government respondents have found the labelling process either very effective or quite effective. Only 6% of manufacturers responded negatively stating that the labelling was quite ineffective and no regulator/government respondents. How efficient is the GEMS Process – Communicating 33% of manufacturing respondents and 86% of regulator/government respondents have found the communication process either very effective or quite effective. 19% of manufacturers responded negatively stating that the communication was quite ineffective and no regulator/government respondents. Effectiveness of energy rating labels on helping consumers make energy efficient purchase decisions
With lamps, Australian standards more onerous. Follow EU lead (voltage difference hinders alignment with US). Reduced burden on industry and regulator. <3 Product selection under RIS process Some industry comments felt to be dismissed without discussion. Communicate process to stakeholders, so they are clear on how input is used. 3-10 Some information that is sought in the RIS process is commercial in confidence (e.g. sales data). <3 period Timescales in other jurisdictions longer, e.g. usually two years for minor and five years for major changes once determination made. Discussion with stakeholders about appropriate timescales; alignment with international standards should simplify. Improves compliance at least cost to industry. >10 Contact with regulator – who to talk to / how to ask a question. Uncertainty about where product registration submission goes, e.g. 'if something goes wrong with my registration process, [there's] no way for me to contact regulator. Identifying a dedicated contact per industry (many valued this in the State based system). Regular communication from the department, e.g. as used by the Australian Packaging Covenant who host free seminars and regularly send information. Recognise increased resources would be required to address this. >10 What is the purpose of the data collected in registration process? Clearly communicate purpose to industry and reduce unnecessary requirements. 3-10
Double up on product Crossover with HVAC systems and electric motors. Align registration to avoid double registration. Industry avoids perceivably redundant double payment. 3-10 test labs One test lab owned by competitors. Increase the number and quality of local testing facilities. 3-10 Feedback to industry Feedback regarding test results to communicated to industry. 3-10 Outdated test “Test procedures unchanged from 20 years ago.” Update procedure to make relevant for current products. <3 Testing methods Perceived inadequate or non-transparent monitoring. More tests, increased communication and feedback between department and industry. Reduces non-compliant products and risk to consumers. Knowledge of repercussions if there is non-compliance will increase compliance. 3-10 Inconsistent testing standard for hot water heaters. Develop consistent standard to improve comparisons. <3 Remove non-compliant products from market, e.g. by Customs at point of entry. <3
Customer Education program has been inadequate. Better inform consumers about labelling. Reduced non-compliance as informed consumers discover and report non-compliant products. 3-10 Difficulties for consumers using the Energy Rating website e.g. for lighting. <3 Funding for Not well understood Review funding to ensure suppliers/ manufacturers are caught. Increase policing. Creates truly 'level playing field' by enforcing compliance. 3-10 Label Information not intuitive (kwh rather than $), can be misunderstood. Difficult to compare gas and electrical performance. Consider EU approach with A+ and zone maps; increased consumer education; comparable gas and electricity information. 3-10 Electric hot water systems not included in star rating. Incorporate electric hot water systems in the star rating system and involve consumers in the choice of these products. Better energy efficiency purchase decisions as the bill payer is involved in the purchase (not just the builder/plumber). 3-10 Label Attach label to box rather than appliance. Reduced costs for manufacturers. <3 Printed stickers for PCs can add unnecessary cost since end market unknown when the computer is produced. Allow electronic stickers to be displayed on the computer screen instead of printed sticker. <3 Data collection Mandatory and compulsory data collection. Increase understanding and reduce free-riders. <3 complying
is 5 8 65 – GEMS Regulator may request further information Clear requirement of the regulations Recommend this is reviewed to determine whether limitations or removal of this part of the Act could apply in order to reduce potential for unnecessary burden on industry. For example, the Regulator could be limited to determining whether or not a product is compliant through compliance testing. Y N Not critical, but could be useful in compliance at the point of N N Reduction in flexibility for scheme to require Y Scheme administrator would need to assess information needs in greater depth and make the case for requests. N It is a requirement for further information 2 2 13 Models to be registered against GEMS Clear requirement of the regulations. A few industry stakeholders questioned the need for registration, citing costs and administrative burden. Only a minority of industry stakeholders raised the concept of its removal, and industry highlighted benefits (such as allowing testing of competitor products). Product registration helps allow more effective compliance activities. Y Y Considered by most schemes, (including experts) to be crucial to maintaining an effective compliance regime. by most Y The costs to the scheme in terms of reduced savings (from comprised would, according to experts significantly outweigh the benefits. There would also N (Y for - see N Best practice Application .
be a negative impact for evaluation due to lack of impact assessment data. 6 4 77 GEMS Regulator may charge for services Clear requirement of the regulations. Administrators do charge fees for registration and other services. The allowance of charging fees appears reasonable, but what fees are charged where and for what should be allowed to be reviewed to ensure they are effective and do not put in place unnecessary regulatory burden. Y N Not crucial, but important in order to ensure cost effective running of the service. N Y - saving for which would need to be paid by the Removal would make it challenging to fees in future. N N 2 2 11 GEMS products, GEMS and product classes GEMS broadened the scope of the program to include these other product areas. Removal of these products would significantly reduce the potential benefit of GEMS in future. It also would exclude the possibility of setting standards for products which significantly affect energy use of products which are covered under the regulations (e.g. air conditioners). Y Focused on the inclusion of products, which affect the use of energy of other products. Exclusion of products which affect N N N introduce
energy use of other products (directly or indirectly) would be a clear policy gap if removed. 4 2 34 Including specific timeframes for of once they come into force within the regulations The regulations allow flexibility for timescales to be set as part of the determination development process. Some parts of industry are calling for a blanket time window (e.g. 1-3 years) for all determinations. of a blanket timeframe would be detrimental to product sectors where is desired unanimously (e.g. fans) as it would delay its commencement unnecessarily. Recommend this is addressed clearly in preparatory studies and consultations in order to specify and agree timescales on a determination by determination basis. Y Y Industry in most cases need a time period to prepare for incoming in order to ensure they comply. to and by There is a risk that savings would be if a which could come in sooner did not. N Industry needs to be convinced that the RIS process is an effective mechanism to address the issue of timescales and that their concerns and issues will be heard through this process. 2 2 12 Models of GEMS Needs to be applied within a determination Y Allows industry to Not N Y This would mainly occur
products to be registered in relation to product classes register products within the same product 'family' (as defined by the to in the of families of models in the The regulations only provide guidance as to the principles which should be followed. This guidance could possibly be made clearer here - for example, developing some more examples of what would and would not be allowable under a family of models (paragraph 35). 3 2 16 Supplying GEMS products – with GEMS Grandfathering text would be removed if this requirement was removed. Y Section details compliance with GEMS N N N
and exemptions 3 2 16 Supplying GEMS products – complying with GEMS Required to ensure effective compliance Y Sets out the penalties for N N Y Penalties (60 units for category A products and 120 units for category B units) - are these sufficient to deter in all cases? 3 2 17 Supplying GEMS products – model not registered Only a minority of industry stakeholders raised the concept of its removal, and industry highlighted benefits (such as allowing testing of competitor products). Product registration helps allow more effective compliance activities. Penalties - required to ensure effective compliance N Not crucial as other schemes do not require it, but it is considered best practice. Y ($XX) N (Y for - see N Could be removed if requirement to register models is removed. Penalties (60 units for category A products and 120 units for category B units) - are these sufficient to deter in all cases? 4 Inclusion of a strategic plan is likely to reduce the burden on industry and Government in N Not crucial, but it is important and N Y Y Having a strategic plan will allow stakeholders
developing a RIS. covered by other schemes to input into the decision making process to decide on which products to include and comment on the rationale and timings behind them prior to development of GEMS 4 2 25 GEMS – GEMS level Fundamental to the regulations Y Allows ministers to set minimum standards Y ($XX) N Y The regulations could state here that the GEMS levels should be aligned to international markets as appropriate to the product. This would achieve a greater level of global consistency and therefore reduce regulatory
burden and ensure domestic industry is able to compete on a level playing field with other markets 4 2 27 GEMS – other No regulatory burden alleviated as a result of removal. N Can be important – is being used to cover mercury level in CFLs.. N N Y While this part of the regulations is currently it can play an important role in addressing non-energy efficiency issues (like health issues) to ensure that product is fit for purpose. 4 2 28 GEMS – families of models Important for the effective management of registrations in the market Y Not critical, but important in allowing industry flexibility in complying with the regulations N N Provides high level guidance, but places the onus on the to specify criteria for families of
– limited period been used to date, and therefore there is no regulatory burden associated with it. It could be removed, but if there is no regulatory burden alleviated, then driver to do it is not apparent. Furthermore, it may be useful should a risk arise with a future product group. applied to date within GEMS. provides an option to limit if a risk of stockpiling is perceived during the development of a 4 2 33 GEMS – consent of Difficult to see how this could be streamlined through the regulations, but the administrative process could be made more streamlined. N Not critical, but deemed important to ensure states and territories participate and agree with proposed N N Y Stakeholder feedback states that the degree to which consent is required from states and territories slows the process down. 7 6 GEMS Regulator may publicise certain offences, and adverse decisions n/a N Not critical, but important to ensure compliance in the market N N Y The regulations could state that the regulator must or should publicise certain offences, and adverse