The Emissions Reduction Fund scheme has every chance of promoting mass energy efficiency activities. Such activities often involve the replacement of older inefficient technology.
The disposal of the old appliance may involve toxic gases or solids being released into the atmosphere or landfill if disposed of incorrectly. Whilst these disposals are usually covered by various Environmental Protection laws, the policing of these may be inadequate and involve investigation and penalising offenders after evidence is gathered and presented.
Schemes such as the ERF provide incentives that escalate the activity for the period of the scheme. Much like in the case of the pink batts scheme where activity outstripped the capacity of those with the responsibility to police it. The replacement of fluorescent lights, air conditioners, refrigerators, TV’s and so on will have a consequent disposal. It is imperative therefore that those operating in the scheme using activities that create the potential of toxic disposals enshrine, not only the current EPA laws, but include evidence of compliance. There is a precedent that appears to work well in the VEET scheme. Invoices from the recycling companies are collected and presented as proof.
Other disposal issues relate to showing proof that the replaced product is no longer able to be used. A drilled hole in a hot water service, the disconnection of wiring for slab heaters are two examples. Photos and a signed confirmation of disposal form are collected as proof and do not overly burden the process. Auditors will check the disposal compliance documentation as an integral part of the process.
Whilst there is a cost of administration and in the disposal itself, the Energy Efficiency Certificate Creators Association would prefer that these requirements are built into the methodologies and that all activities must be carried out in accordance with these requirements. The net effect is that all companies will factor these costs into the bids upfront and competition for ERF funding will be fairer. The unintended consequence of mass toxic gas release or substances in landfill will also be minimised.
In all likelihood, a positive consequence of this will be that rules will be followed more closely than currently and trades will become used to working in this manner. Recycling companies will be supported and costs will reduce due to economics of scale.