PLG RESPONSE
The Public Lighting Group supports the proposal to establish a new small loads metering option as outlined in the document commissioned by the Commonwealth Department of the Environment and Energy released on the 26th of February 2018 – Proposal for a new ‘Small Load’ Metering Regulatory Framework for street lighting.
In addition to that outlined within the paper our organisation believes that the new metering option would best meet our needs as customers if the following were considered:
- Covers all outdoor lighting options up to 2.4 kW. This would enable the inclusion of standalone lighting such as flood lights to be included
- Allow this to be available for any small loads including standalone outdoor loads such as BBQs, small pumps etc. This would enable a significant transaction cost reduction for many public services delivered by local and state governments.
OTHER RESPONSES
Maximum load
Refers to MV lights changing to 20-30W LED. It’s unlikely that many of these lights will incorporate a smart PE Cell in the near future given the cost/benefit is very low. The initial cost for a Smart PE cell is approximately $150 in Victoria which can increase the cost of a Cat P LED purchase by over 35%. A substantial decrease in the cost of smart PE cells is required in order for it to be applied to Cat P lighting. A more appropriate example is a 150W HPS conversion to 70W LED.
Selection of Type 7 metering
The paper proposes this as optional but it is not clear as to whether the choice would be Council’s or the distributor. The paper should be clear on whether distributors should be obliged to offer Type 7 metering for eligible lights. Similarly it should be clear whether the distributor would be obliged to offer dimming as a service. Type 7 metering without dimming would have minimal benefit to Council and would potentially even increase costs. It should also be clear on whether there is a justifiable additional cost from the distributor for offering this service (Type 7 metering and dimming), over and above the cost of traditional billing methods.
Road Manager obligations
The paper does not address Council’s obligations as the road manager to maintain suitable lighting levels. For example it may be possible to dim a Cat P4 street to P5 late at night but further dimming of an existing P5 Street is unlikely to be suitable. Given this it will be essential for Councils to be able to specify to the distributor exactly which lights to dim and therefore which ones should be transferred to Type 7 metering. In addition Council’s will need support to model lighting outcomes from dimming to determine where it is suitable. Modelling for Cat V lighting design is expensive and needs to be accounted for in the cost/benefit.
Cost/Benefit
Further to the above the paper should explore in more detail the real cost/benefit analysis to Councils from the potential for dimming for both Cat P and Cat V lights. Based on the initial smart cell cost, light level modelling, energy savings and any additional metering costs. The CBA needs to be done on a per light basis as not all lights will be suitable for dimming.
Distributor response times
Modern LED lights ‘fail on’, as such Type 7 metering would allow Councils to negotiate improved response times that account for the additional energy cost prior to repair.