ASBG responded to the Discussion Paper, Proposed changes to the Energy Efficiency Opportunities (EEO) program assessment and reporting requirements with clarification of the second cycle.
Overall ASBG was disappointed with the discussion paper as it proposed further expansion of the Key Elements and other compliance requirements under the EEO program. Streamlining not increasing the burden should have been the outcome of this review. EEO is already an inefficient and costly way to achieve its energy efficiency outcomes. ASBG believes the proposed additional complexity will do far more to add to compliance costs than serve to identify viable projects. Adding further complexity will undermine the value of the program to businesses and organisations.
Members consider the EEO program is good at identifying cost effective energy efficiency opportunities, but is very inefficient in its process of finding and evaluating viable opportunities.
A number of suggested improvements were provided such as undertaking economic viability vetting of projects at the start to remove unnecessary documentation and processes. Also removing the disincentive where the documentation proportionally increases with the number of energy savings projects identified.
ASBG recommended replacing the current set of proposals with a process of streamlining the EEO system with full consultation from the reporting companies.