This submission argues that it would be premature to recommend an energy efficiency obligation without a comprehensive consultation process, detailed modelling and costing, and a regulatory impact assessment.
The BCA has previously outlined its principle that energy efficiency policies should pass a test to provide evidence that the benefits associated with the implementation of the policy outweigh the costs of implementation. At this stage, a compelling case for the need for an energy efficiency obligation has not been made.
In particular, the BCA would expect that a rigorous regulatory impact assessment would consider a range of options in ensuring that the benefits of an obligation outweigh the costs in terms of:
- barriers to energy efficiency
- cost of abatement
- compliance costs
- impact on innovation.
Consultations to date have provided no further clarity on the future policy process, including the timing of the government’s response and the opportunity for further consultation prior to policy decisions being locked in.