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A review of Leichhardt Council’s solar water heater policy

David Eckstein

Senior Environment Officer, Leichhardt Council

Background and intent

Nine years of pro-activity in the arena of local government energy efficiency and renewable energy promotion1 has placed Leichhardt Council somewhat in the spotlight regarding, community, government agency, energy industry and developer interest in how local government will (continue to) respond to the ‘enhanced greenhouse gas emission’ (GGE) challenge. This is sometimes an enviable, and sometimes unenviable situation! The pressure is certainly on to ensure that endeavours to review and modify policy over time (review that is inevitably needed in the fast-changing environment of energy-smart technology) (i) deliver ramped-up greenhouse outcomes, and (ii) don’t compromise the organisation’s perceived position as a leader in promoting renewable energy.

Where policy developed by an organisation contains a ‘stand-out’ feature, this often obscures much of the rest of the policy, irrespective of the importance/value of the overall package. This has been the case with Leichhardt Council’s Energy Efficient Housing policy — originally formalised as Development Control Plan 17, and now rolled into the Leichhardt comprehensive Town Plan DCP 2000. The Council’s energy smart homes policy was always about more than solar water heaters (site layout, shading, cross-ventilation, insulation and space heating all received thorough attention), yet not surprisingly the water heater component has dominated the public interest from: ‘How dare a council dictate the type of water heater we will use!’ through to ‘Love ya’ policy — how do I get my council to do likewise’?

This paper is as much concerned with the task of transparent policy review, and the ‘sometimes-agony’ associated with it, as it is with the challenge of making sure an established policy stays contemporary and delivers the intended outcomes — in this case energy efficiency in the residential sector.

Political support — silence is golden (sometimes)

Throughout its ten-year history of environmental pro-activity (i.e. since Council first created an Environment Offer position), staff promoting ESD-related projects have been blessed by political support — though often-time this comes in the benign form of hearing nothing back from Council other than (mute) approval (i.e. adoption) of the latest Environment Committee minutes and associated recommendations — the avenue that is used for Council review of environmental policy issues. Perhaps the politicians simply have bigger (local) fish to fry, perhaps the issues for which the public attend, and to which they speak at the monthly Ordinary Council Meetings demand more of their (and the attendant media’s) attention. Perhaps the existing meeting structure (Environment, Planning and Community Services committees have four councillors formally nominated as members, usually drawn from the range of political hues), no matter how frustrating at times, ensures that by the time the minutes have reached the floor of the chamber any issues have been resolved and time is not spent debating the content of the minutes or detail of the recommendations. Whatever the case, staff are certainly fortunate that councillors emerging from our generally socially progressive community appear (i) to trust us (staff), and (ii) by and large, support green initiatives even where there may be obvious short-term cost implications to the development sector — whether this be at the home owner or commercial end of the spectrum.

Summary comment: All Quiet on the Western Front? Verify informally that this is because most/all councillors are happy and trusting of progress. If its not you need to find out early rather than proceed, oblivious to a potential ‘late sting’ that would not only detail policy work but dishearten those staff and community members who have invested time and effort on a project.

Why water heating remains a ‘main-game’ in the residential sector

Irrespective of the comments in ‘Background and intent’, above, one thing is for sure — the water heater sector was (circa Council’s policy innovation, 1994) and remains a very logical residential sector target for greenhouse gas reduction policy because:

  • of the disproportionate emissions attributable to inefficient electric storage water heaters — a common feature of many Australian homes
  • once a more energy smart water heater system is installed in place of ‘bottom-end’ systems, home owners/occupiers (other than plumbers) are unlikely to meddle with (i.e. undo) a piece of technology that is likely to operate from ten or more years (i.e. accrued greenhouse gains are significant)
  • rebates have been available for some considerable period of time in various states and now that Renewable Energy Credits (RECs) are available, some of the ‘start-up’ cost-barriers that solar water heaters and heat pumps faced have been removed — in NSW at least, both the state government rebate and the RECs are available in accredited ‘Energy Smart Homes’ council areas for DA-approved developments (and councils should be doing all they can to facilitate home-owner access to this double funding opportunity while its available)
  • in inner city settings where re-development (‘alts and adds.’) is the main game rather than new dwelling construction, the opportunity to re-orientate a dwelling or re-organise its living spaces for improved energy efficiency are very constrained by existing street layouts/dwelling orientation/overshadowing — hence the need to look for GGE savings elsewhere — i.e. water heating
  • in rural and urban fringe areas where new single dwellings are the main game (how sustainable is this?), electric storage water heaters remain the common, cheap, quick (and dirty?) water heater solution (in part because gas supply infrastructure may not exist). Yet in these very locations uninterrupted solar access to ‘big roof space’ is standard — hence quantum GGE gains can be achieved by substitution of electric storage with even the most basic electric-boosted solar water heaters
  • show me a better way for the lay public to install, use, enjoy, benefit, learn from and be inspired by renewable energy, at moderate cost, such that they will preach its virtues to friends and family !
  • and finally: solar water heaters make sense in Australia (geddit!)

Summary comment: There are plenty of solar water heater knockers out there. But speak to almost anyone who has a well-installed system and knows to how to use it well (i.e. manage it to avoid unnecessary boosting) and you’ll find satisfied customers all around. Plumbers who don’t specialise in solar/heat pump installations can be especially negative. It takes longer to install solar systems so they prefer and promote quick and easy electric and gas options.

First policy ‘owners’ prove the most rigorous ‘scrutineers’ of proposed change

Proposed amendments to Leichhardt Council’s solar water heater policy2 were consistently contested by several members of the Environment Committee who had a long association with the policy, specifically they had driven its original formulation and defended it staunchly. Their principle concern: that the lifting of the solar mandate from the existing dwelling redevelopment sector represented a shift away from renewables back to the traditional, fossil fuel energy sector. Certainly the ‘alterations and additions’ sector represents by far the largest swag of Leichhardt’s development applications (Council processes over 1000 DAs per annum), but what proportion of solar systems installed on existing dwellings are positioned sub-optimally?

The crux of the debate came down to the personal values frameworks of those involved. For some the crucial issue was the net greenhouse gain achieved from the policy review and changes proposed, for others the key, and non-tradeable, issue was public perception of Council’s position on ‘solar’ — any shift to ease up on the solar mandate represented a ‘cave in’, irrespective of the GGE outcomes. At times these different personal priorities resulted in tense and even acrimonious atmosphere at Environment Committee meetings.

Summary comment: Reviewing policy? Painful though it may be, engage, if possible, ‘architects’ of the first version(s) of the policy — passionate and precious though they may be about modification, the rigour of the debate can often-times deliver better outcomes, and certainly adds transparency to the review process.

The devil’s in the (technical) detail

One of the strongest drivers for the policy review was that the cluster of stated policy objectives in the original DCP 17 document provided an opportunity for a claim that at times policy objectives might be at odds with each other. Specifically the original policy stated both the intents of ‘reducing greenhouse gas emissions’ and ‘increasing the use of renewable energy’. The boat has been rocked for these seemingly cordial partners because of a combination of technological improvements, water heater user ‘behaviour’ and (in the inner city setting) the frequency sub-optimal installations dictated by existing roof forms/orientation and/or overshadowing from neighbouring structures.

Gas water heaters, storage or continuous flow (‘instantaneous’) are consistently better GGE performers than electric storage systems. Furthermore, over the past decade the efficiency of gas water heaters has been further improved by the manufacturers and the Australian Gas Association have pro-actively ramped up their own energy efficiency star rating system which has served as a ‘driver’ for improved efficiency. While a range of electrical goods, including water heaters, are included in the MEPS (Minimum Energy Performance) standards debate at the national level, the speed at which this (MEPs) dialogue and associate agreements and then product improvements have occurred has been at times agonisingly slow for those watching from the sidelines with a strong interest in energy efficiency.

As top of the range gas water heaters, both storage and continuous follow, have ‘reached for the stars’, the gap between their GGE performance and that of solar water heaters using electric element boosting systems has diminished significantly — being virtually eliminated in cases where electricity is produced by burning poorer grade (brown) coal — the case in Victoria. This is a very practical/demonstrable case of gas technology meeting the (gas) industry claims of it being ‘the fuel of transition’ — carrying society from unsustainable to ‘sustainable’ development in the 21 century.

But what of claims of gas leakage (a potent greenhouse contributor) and the environmental impacts from gas exploration raised vigorously by one member of the Environment Committee? Certainly historically, gas network-leakage prior to end use has been poorly factored into the GGE calculations for different types of water heaters (if it has been factored in at all). However the industry can present a valid case that the Gold Line project (insertion of plastic pipes within the aging sub-surface infrastructure to eliminate leakage) has delivered.

Submissions received during the May 2001 exhibition of the draft policy

The public exhibition of the proposed amendments to the solar energy section of the town plan brought 14 written responses — a relatively high level of response to proposed amendments. Not surprisingly the submissions largely came from those with a commercial interest in the policy (i.e. the solar energy industry), or research interest. Two responses were received from residents.

Hearing the industry case … and the challenge of lack of gas-solar service providers

The Council actively sought industry input to the policy revision. Mailing draft material to known industry players within and beyond the ‘solar circuit’. Industry input needed to be well-sieved to separate genuine technical expertise from ambit claims for more work in the local government area. There was no shortage of written feedback to the draft material and the issue of the lack of solar-gas boost suppliers was well-flagged (i.e. Should policy result in giving a marketing advantage to a reduced number of commercial players ? Answer: Why not, if an agency has a well stated and sound environmental objective, in keeping with state government (ESD) legislation ?). This remains a persistent problem in the Australian water heater industry. Yes it is more of a technical and economic challenge to design and mass-produce gas-boosted water heaters — but at present it is a market opportunity going begging. Councils can and do have a role in transforming markets.

Value-adding to the policy review in anticipation of photovoltaics in the urban environment

The solar water heater review provided an opportunity to insert guidelines and controls, and develop detailed conditions for the installation of photovoltaic systems that generate electrical power for a dwelling and may export surplus power to the mains grid power system. At least seven dwellings in Leichhardt already have p.v. systems upon them, achieved without policy guidance. However in anticipation of continued steady uptake in the residential sector, and the need to manage this to ensure systems deliver their intended renewable energy outcome and to protect neighbouring amenity, a policy for p.v. installation was deemed necessary. The policy developed has focused upon ensuring systems meet Australian Standards. Wording in the ‘controls’ section of the policy is flexible — indicating, but not dictating, the angle of orientation (as long as manufacturer’s energy output guarantees hold true). Ventilation of roof space, or heat capture and re-use where heat gain in roof space is likely is also required — flagging an important energy efficiency issue that may well have escaped the attention (and therefore the questioning of suppliers by purchasers) of the soon-to-become system owner.

Under Council’s Development Control Plan 35 Exempt and Complying Development Person wishing to install just a photovoltaic systems without undertaking other works that would require development approval may well be able to install photovoltaics without any need for Council approval avoiding any Council administration/inspection fees.

Finally, in the P.V. section of the policy, to improve promotion of photovoltaics generally, Council now offers a ‘p.v. in place of solar hot water’ option for those developers (single home-owner or larger-scale projects) wishing to install this technology. An energy efficient water heater is still required but solar water heating is not stipulated .

What’s on the cards …

No sooner has Council adopted provisions for the latest wave of domestic scale renewable energy technology (p.v) that residents and others might realistically seek to install, new technologies appear on the scene. Combined heat and power solar (CHAPS) (p.v. and hot water production in one linked unit) and micro-hybrid solar turbine generators suited to domestic installation are either commercially available or close to commercial production. Another option, gas engined generators, make electricity that feeds into the grid and/or house while also making hot water, operating twice as efficiently as existing power stations and with utilities in Melbourne thinking about providing such technology free to residences where peak load on grid is due to residential demand.

These technologies may require more intensive policy research to ensure urban amenity, as valid a part of the ESD equation as energy efficiency, is not compromised, but it would be hard to imagine that such systems, obviously well suited to remote areas, could not be accommodated in an urban context. Meanwhile in the ‘traditional’ sector of passive solar design, window coatings to reduce solar heat gain and glass products with much-improved thermal properties (together with a Window Energy Rating System) are well worthy of attention from building owners and council planning sections seeking improved energy efficiency ahead of the ‘renewable energy system installation’ (e.g. P.V. or solar water heating) option.

Summary comment: Reviewing policy? Triple-think and get external advice about emerging technology that is on the horizon. Consider accommodating it, or at least flagging it, within policy to ensure policy lifespan is maximised.

The policy review ‘wash up’

The table in Appendix 1 summarises the new solar water heater requirements and photovoltaic components of the policy — the outcome of the best part of eighteen months of iteration, in-house debate and committee meetings. Not everyone was happy with the outcome, but all the stakeholders we could identify had a good chance to make their various ‘pitches’. An early suggestion that a scorecard/points system be introduced (that provided a range of ‘ESD technology’ options including water conservation (as opposed to energy focused) fittings) was shelved due to negative feedback. Industry concern that the solar-gas mandate would eliminate ‘solar–electric only’ manufacturers/suppliers was heard, and the policy amended to accommodate solar–electric systems within the solar mandate for developments featuring one and two new dwellings.

Historically there has been a persistent problem of a proportion of development applicants coming back to Council post-DA approval seeking a variation to the solar water heater conditions due to overshadowing, a wish to re-use an existing gas system, or inappropriate roof orientation. There are costs for those applicants to lodge formal variation documentation (a fee applies for applicants seeking to vary conditions of consent) and there are technical and administrative staff resource implications (time spent processing/reviewing applications for variation). Virtually all these variation requests are for existing dwellings. Under the original DCP 17 installation of solar systems was often mandated (i.e. a condition requiring a solar water heater or heat pump was placed on the development approval). The revised policy now allows best-performing gas systems (5 AGA stars) as well as solar/heat pump systems. This was a major issue of debate amongst the Environment Committee (those with strong attachment to the original policy felt this was a retrograde step, a move away from the ‘Going Solar’ position Council had promoted since 1994). However the case for a pragmatic policy that did not result in regular requests for exemption/modification and which responded to both the relative parity of top-performing gas systems (with electric-boosted solar) and (the often) sub-optimal installations of solar electric systems won out.

The policy review sought to accommodate a range of issues (i) raised in submissions received about the proposed amendments, and (ii) derived from council staff in-house experience to date regarding the existing policy. We feel this was achieved via a thoroughly thrashed out review process. Appendix one summarises the new water heater requirements and p.v. options.

Appendix One

Amendments to Leichhardt Town Plan DCP, Section B 2.6 Design Element 14 — Using Solar Energy Actively

  • Require gas-boosted solar water heaters for new townhouse/terrace style dwellings featuring more than 2 new dwellings
  • Require solar (electric-boosted or gas-boosted), or heat pump water heaters for single new dwellings and developments featuring only two new dwellings, including approved conversions from industrial and commercial buildings to residential stock
  • for development applications for alterations and additions to existing residential dwellings: installation of solar-gas, solar-electric, stand-alone solar, heat-pump or minimum 5-star energy efficient gas systems required (re-use of existing gas, heat pump or solar water heaters, and electric water heaters proven to be less than 7 years old is also approved)
  • for multi-unit dwellings (residential flat buildings) installation of gas-boosted solar or heat pump (with gas-boosting if required) systems; five–star efficient individual (per dwelling) gas water heaters acceptable when a viable case has been presented that roof-space for centralised solar-gas systems is inadequate to accommodate sufficient water heating panels to supply a minimum of 50% of the annualised hot water demand of the dwellings.
  • for development proponents that would be required to install solar or heat-pump water heaters (i.e. new dwelling scenarios), provide the option to elect to install a photovoltaic system or systems (minimum 450 watts per dwelling) in lieu of solar water heating, but that an energy efficient water heating system (i.e. not via traditional electric element technology) also be required.

About the author

Working within Leichhardt Council’s Strategic Environmental Planning team since 1996, David Eckstein’s ‘brief’ covers the full range of local government environmental and sustainability challenges — including conservation of biodiversity, stormwater protection initiatives, environmental education, renewable energy and energy efficiency programs, organisational change fatigue and support of community-based environmental action.

1 For a brief history (in PowerPoint format) of the Leichhardt Council sustainable development, energy efficient housing, and solar water heater experiences and to see the new Town Plan see the Council website at: www.mycommunity.com.au/leichhardt. And follow the links through ‘Council’ ‘Environment’

2 Copies of the new Using Solar Energy Actively’ policy will be available at the Conference and from leichhardt@lmc.nsw.gov.au

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