REPS bulletins

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The Commission has prepared and will release Retailer Energy Productivity Scheme (REPS) Bulletins providing interpretations and advice on REPS issues from time to time.

REPSB1/1 - Bulletin no. 1 - Retailer Energy Productivity Scheme

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Bulletin no 1 - Retailer Energy Productivity Scheme

The Retailer Energy Productivity Scheme (REPS) is a South Australian government initiative that supports households and businesses to reduce their energy costs while also maximising the benefits to our power system to deliver a smarter, more affordable, reliable and sustainable energy future for all South Australians. REPS will support South Australia’s transition to a modern, flexible energy system and improve energy productivity for businesses and households, with a focus on low-income households.

The REPS commences on 1 January 2021, following the conclusion of the Retailer Energy Efficiency Scheme (REES) on 31 December 2020.

The REPS is given effect by the Electricity (General) Regulations 2012 and the Gas Regulations 2012 (together, Regulations) and is administered by the Essential Services Commission (Commission).  The Commission’s role is to ensure energy retailers comply with the requirements of the REPS and to publish annual ministerial and public reports on the REPS.

The REPS Code establishes the requirements on energy retailers in relation to their REPS obligations.

The REPS supports the delivery of energy efficient and energy productive activities to South Australian homes and businesses and supports the emerging technologies of demand management and demand response.

Obliged energy retailers are required to meet energy productivity targets (EPT) determined annually by the Minister for Energy and Mining (Minister) by offering incentives to households and businesses to implement energy productivity activities in homes and premises.  Retailers also have the flexibility to design and offer individual incentive programs to customers.

The Retailer File Validation System (REPS-R) will continue to provide retailers and third party providers with ‘real time’ information to support the provision of energy efficient activities and its functionality will be expanded and enhanced to meet the requirements of new REPS activities as they emerge.

The Commission may publish Bulletins to provide clarity and guidance to retailers and third party providers on matters raised in relation to REPS activities, administration and record management. Table 1 lists the REPS Bulletins that are applicable to REPS activities and administration with effect from 1 January 2021.  

REPS bulletin title Version Effective date
No 1 - Retailer Energy Productivity Scheme REPSB1/1 1 Jan 2021
No 2 - Installation of water heaters and low-flow showerheads REPSB2/1  1 Jan 2021
No 3 - Consumer protection obligations
REPSB3/1  1 Jan 2021 
No 4 - Addresses without a delivery point identifier REPSB4/1 1 Jan 2021 
No 5 - Retailer file validation system (REPS-R) REPSB5/1  1 Jan 2021 
No 6 - Standby power controllers REPSB6/1 1 Jan 2021 
No 7 - Mandatory training requirements REPSB7/1 1 Jan 2021 
No 8 - Electronic activity records   REPSB8/1 1 Jan 2021 
No 9 - Electronic activity records   REPSB9/1 1 Jan 2021 
No 10 - Electronic activity records REPSB10/1  1 Jan 2021 
No 11 - Electronic activity records REPSB11/1  1 Jan 2021
No 12 - REPS activities in government owned housing REPSB12/1   1 Jan 2021
No 13 - Commercial lighting  REPSB13/1   1 Jan 2021
Updated: 01/1/2021

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REPSB2/2 - Bulletin no. 2 - Installation of water heaters and low-flow

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Bulletin no 2 - Installation of water heaters and low-flow

Summary:

If a low-flow showerhead is installed on a date before the date on which the water heater is installed, the deemed Gigajoules for the showerhead can be counted for the purposes of REPS.

If a low-flow showerhead is installed on the same date as the water heater the deemed Gigajoules for the showerhead cannot be counted for the purposes of REPS.

If a low-flow showerhead is not installed on the same date as the water heater, the deemed Gigajoules for the water heater activity cannot be counted for the purposes of REPS until such time as:

  • the low-flow showerhead is installed (with the deemed Gigajoules for the showerhead unable to be counted for the purposes of REPS), or
  • a flow restrictor with a 3-star rating under the Water Efficiency Labelling and Standards (WELS) scheme has been fitted to the existing shower outlets, or
  • the retailer can satisfy itself that low-flow showerheads of flow restrictors were already installed at the premises at the time the water heater was installed.

If the water heater being replaced is unable to be removed from a premises due to being situated in a roof space, the water heater may be able to be left in its original location providing that the decommissioning of the water heater is specified on the plumbing Certificate of Compliance.

The replacement of multiple water heaters in a single submission for a premises is only permitted where it can be evidenced that the water heaters installed have replaced existing water heaters at the premises.


This Bulletin refers to the Retailer Energy Productivity Scheme (REPS) and is effective from 1 January 2021.  

This Bulletin provides guidance to the installation of water heaters and low-flow showerheads and the recording of low-flow showerheads in REPS-R.

Obliged retailers will be required to collect information sufficient to demonstrate how requirements in relation to this specification are being met for water heater activities conducted as part of REPS, before the Commission can determine whether or not REPS activities can be counted in fulfilment of any REPS targets.  The Commission expects each obliged retailer to have sufficiently robust systems and processes in place to ensure an adequate level of internal assurance of compliance with the water heater specifications.

Showerhead performance requirements following water heater installation


In addition to the various Australian Standards relating to the individual water heaters, the South Australia Government also requires a Water Flow Rate Performance Standard be met in relation to the installation of new water heaters in South Australia.  This means that when a new water heater is replaced or installed, all shower outlets connected to the installed water heater must have a flow rate of 9 litres per minutes or less (refer to 
SA Government website for more information on energy and environment).

For the purposes of REPS, in a situation where a new water heater is installed, any low-flow showerheads installed at the same time as (or subsequent to) the installation of the water heater cannot be counted in fulfilment of any REPS targets as this activity is “otherwise required by law”.  Furthermore, as the Water Flow Rate Performance Standard is “otherwise required by law”, the Commission would require evidence from obliged retailers that any water heaters installed for the purposes of REPS also comply with this requirement.

Requirement to remove replaced water heaters


For the purposes of REPS, in a situation where the water heater being replaced is unable to be removed from a premises because it is situated in a roof space, the water heater may be able to be left in its original location providing that the water heater is decommissioned by a licenced plumber and  the decommissioning of the water heater is specified on the plumbing Certificate of Compliance. 

This is the only exception to clause 5(3) in the Minister’s specification WH1 which requires that “any replaced water heater must be removed from the premises”.

Requirements for installing multiple water heaters at a premises


As the general specifications states that:

A REPS approved activity that involves the installation, removal, repair or upgrade of equipment in a premises may only be performed once in the premises, unless permitted in the activity’s specifications.

Activity WH1 may only be performed once per premises. However, replacement of multiple water heaters may be submitted in a single submission for a premises only where it can be evidenced that the water heaters installed have replaced existing water heaters at the premises. For example, where two water heaters are installed, two water heaters must be decommissioned and removed from the premises.

Updated: 09/06/2021

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REPSB3/1 - Bulletin no. 3 - Consumer protection obligations

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Bulletin no 3 - Consumer protection obligations

Summary:

  • Residential customers must be provided with an Information Statement, including information on how to access the complaints and dispute handling procedures in place, at the time the REPS activity is undertaken; and
  • Residential customers must be provided with access to complaint handling and dispute resolution procedures established in accordance with the applicable AS/NZ Standard, regardless of whether the REPS activity is being conducted by a REPS obliged retailer or a third party contractor.
  • Persons conducting a REPS activity must wear appropriate identification and meet minimum standards of conduct.
  • Persons conducting a REPS activity must be assessed as a fit and proper person and must have undertaken all necessary training.

This Bulletin refers to the Retailer Energy Productivity Scheme (REPS) and is effective from 1 January 2021.  
The Residential Energy Productivity Scheme Code (REPS Code) provides consumer protection measures for residential customers that receive an energy productivity activity under the REPS (refer to Clause 6 of the REPS Code).
 
These consumer protection obligations apply to all obliged retailers regardless of whether the retailer undertakes the REPS activity itself or uses a third party supplier of energy productivity services.
The requirements for information provision, complaints handling and dispute resolution, identification and general conduct standards are specified in the REPS Code. 

Information Provision

The REPS Code requires an obliged retailer to ensure that an Information Statement is provided to a residential customer where it undertakes an energy productivity activity in their household.
The Information Statement must include the following information, as a minimum:
  • The name and contact details of the person or entity that performed the REPS activity;
  • A description of the energy productivity activity undertaken in the residential premises;
  • Notification that the REPS activity undertaken will be counted in satisfaction of an obliged retailer’s REPS obligations; and
  • The process for accessing the dispute resolution procedures in place to address any concerns arising from the REPS activity undertaken.
The Information Statement must be provided to the residential customer at the time the activity is undertaken.

Complaint handling and dispute resolution procedures

Clause 6.2.1 of the REPS Code requires that the obliged retailer to ensure that customers have ‘access to’ complaints and dispute handling procedures established in accordance with the relevant and applicable AS/NZ Standard.
It is the Commission’s expectation that this avenue be made available to customers at the time the activity is undertaken, even where the specific retailer is not known at that time.  The requirement that all obliged retailers ensure customers have access to the same procedures would require that all contracts with a third party provider include such a term (unless the retailer was providing this avenue itself).
In  instances where activities are carried out by a third party provider at a time when the retailer for which the activity was undertaken is not known, the retailer must ensure (through third party contractual arrangements) that the third party provider provides the customer with:
  • contact information should a complaint or dispute arise, and
  • access to the relevant AS/NZ Standard applicable at the time the activity is being conducted.
Updated: 1/1/2021

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REPSB4/1 - Bulletin no. 4 - Addresses without a delivery point identifier

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Bulletin no 4 - Addresses without a delivery point identifier

Summary:

  • The Commission will accept data relating to addresses that have no DPID provided that, where no DPID exists for that household/business, the data is identified with an Address Declaration in the REPS-R reporting template and a signed declaration relating to those addresses is provided by the obliged retailer.
  • Obliged retailers are encouraged to provide signed declarations to the Commission on a quarterly basis (or more frequently).
  • REPS-R users can extract a ‘Pending’ data report from REPS-R to assist provision of declarations to the Commission.
  • The declaration must be signed by the senior officer nominated under clause 4.1.3 of the REPS Code and must contain the wording specified below.

This Bulletin refers to the Retailer Energy Productivity Scheme (REPS) and is effective from 1 January 2021.  

Obliged retailers must provide a legitimate physical address for every REPS activity undertaken and reported to the Commission for the purposes of the REPS.  Under the REPS Code, obliged retailers are to record legitimate addresses by reference to a Delivery Point Identifier (DPID) issued by Australia Post.

In those cases where an address does not have a DPID and the address is not found on the QAS Postal Barcoding database, the Commission will accept data files that contain addresses that have no DPID provided that the data line is identified with an Address Declaration in the REPS-R reporting template and a signed declaration relating to those addresses is provided by the obliged retailer.

Reporting Template

Where an Address Declaration is required for a REPS activity, the ‘Declaration Type’ field must be completed as follows:

REPS bulletin no 4 - address declaration graphic
 
A signed declaration must also be provided to the Commission.  The declaration must be signed by the senior officer nominated under clause 4.1.3 of the REPS Code and must state the following:

After due inquiry, I, the undersigned, declare that:
  1. In my opinion, the addresses that have been reported in the following data file/s with no Delivery Point Identifier (DPID) are legitimate households/businesses in which REPS activities were undertaken for the purposes of the Retailer Energy Productivity Scheme and no DPID exists.
  2. [insert name of file e.g. AAA_210101_Activities]
  3. [insert the line number of the address]
  4. [insert name of obliged retailer] has in its possession or control records that sufficiently evidence that REPS activities were undertaken in each household/business reported with no existing DPID, which will be made to the Commission upon request.
Signed: ________________________________________________
Name: _________________________________________________
Position: _______________________________________________
Dated: _____________

Provision of signed declarations to the Commission

Data lines with a declaration can be lodged in REPS-R but cannot be submitted towards an annual target by an obliged retailer until an appropriate signed declaration has been received and assessed by the Commission.  These data lines will be categorised as ‘pending’ in REPS-R until the Commission has received and assessed the applicable signed declaration.  Obliged retailers are encouraged to provide signed declarations to the Commission on a quarterly basis (or more frequently) to allow for ongoing assessment of those declarations.

To create a report of ‘pending’ data in REPS-R to accompany the signed declaration, the user should navigate to ‘Reporting – Transaction Reporting’ using the REPS-R menu and set the ‘Status’ report parameter to ‘Pending’.  Set the ‘Type’ and time period for that you wish to report on.  Export the report to an Excel spreadsheet by selecting the ‘Export’ button.

A separate signed declaration must be provided for each declaration type (Address, Occupant, or Compliance).  This can be done by setting a filter on the spreadsheet and creating a worksheet for each declaration type.

In accordance with clause 4.4.4 of the REPS Code, the Commission will reject any data where an appropriate signed declaration has not been received within 20 business days after the end of a REPS year.

In circumstances where the DPID has been reported to the Commission in error or reported incorrectly, the Commission will reject the data line and the relevant REPS activities can be re-lodged in the REPS-R in the correct format.

Updated: 01/1/2021

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REPSB5/1 - Bulletin no. 5 - Retailer file validation system (REPS-R)

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Bulletin no 5 - Retailer file validation system (REPS-R)

Summary:

  • Enhancements and amendments to REPS-R will be communicated to obliged retailers and third party providers as they occur.
  • REPS-R does not provide assurance that any individual REPS activity contained within a file which has been validated for data format and address format will be accepted as compliant for the purposes of achieving overall REPS Energy Productivity Targets.

This Bulletin refers to the Retailer Energy Productivity Scheme (REPS) and is effective from 1 January 2021.  
 
Third party providers can utilise the REPS-R by contacting the appropriate retailer.  The Retailer Instruction Manual for the REES-R is applicable to the REPS-R.
 
Any enhancements and amendments to the REPS-R will be communicated to obliged retailers and third party providers as they occur.
 
The REPS-R does not provide assurance that any individual REPS activity contained within a file which has been validated for data format and address format will be accepted as compliant for the purposes of achieving overall REPS Energy Productivity Targets.

 

Updated: 01/1/2021

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REPSB6/1 - Bulletin no. 6 - Standby power controllers

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Bulletin no 6 - Standby power controllers

Summary:

  • REPS obliged retailers must obtain prior approval from the Commission for the manner of installation for a Standby Power Controller (SPC); and the form and manner of training (including ongoing support) that must be provided to the residential customer.
  • The Commission’s additional requirements on the manner of SPC installation and the form and manner of training are set out in this Bulletin

This Bulletin refers to the Retailer Energy Productivity Scheme (REPS) and is effective from 1 January 2021.  

This Bulletin provides guidance on the Commission’s approval processes for both Audio Visual (AV) and Information Technology (IT) Standby Power Controllers (SPC) installation and training requirements.

The Activity Specification for SPCs sets out the minimum product and installation requirements required.  The Commission’s additional requirements on the manner of SPC installation and the form and manner of training are set out below.

Manner of Installation

 Additional minimum installation requirements for an SPC installation are that:

1. The SPC installer must:

a) advise the resident on the optimal operation of devices connected to the SPC;
b) gain an adequate understanding of the resident’s use of relevant appliances from interviewing the resident; and
c) in general, install the SPC(s) in a manner that meets all the specifications, addresses the resident’s needs, whilst also maximising the potential for energy savings.

2. In order to be able to install an SPC in an appropriate manner, an SPC installer must receive:

a) sufficient safety training, with the training consistent with that achieved from meeting the REPS Code mandatory safety training requirements as necessary for the safe installation of SPCs and sufficient operational training for SPC installers to:
b) be fully conversant with the REPS SPC specifications;
c) enable them to engage appropriately with residents;
d) be able to fully instruct residents on the operation of SPCs to be installed and be able to answer any operational questions posed by residents;
e) be able to assess the resident’s use of AV, IT and peripheral appliances and advise on which appliances would be suited to be connected into the SPC and which appliances should not be connected to an SPC (and therefore remain directly connected to a power source); and
f) be able to install the SPC device safely and to maximum effect, having regard to the needs of the resident.

The SPC(s) must not be left to the resident to install, even after providing instructions to the resident.  The principal appliance plugged into an SPC needs to be:

  • A desktop computer or laptop, in the case of an IT SPC; and
  • A television or projector, in the case of an AV SPC.

Form and Manner of Training for Residents

The level of customer training should be designed to minimise the risk of residents subsequently removing, or otherwise rendering inoperable, the SPC due to a misunderstanding of the operation of the SPC.

A REPS obliged energy retailer should provide copies of its internal documents (e.g. systems and training manuals) and other supporting materials to the Commission, to assist the Commission in considering approval for the manner of installation and the form and manner of training.

Approved SPC's

Brand Model SPC type
Belkin F7C013au (AV) AV
Belkin F7C013au (IT) IT
Belkin SEA128AU AV
Carbon and Energy Reductions Australia ESPB5-AV AV
CREST Earthsmart ESPBS5 IT
EETECH EETECH-AVIR-01 AV
EETECH EETECH-PC-01 IT 
Electomatic EM-AV-7272 AV
Embertec EmbertecAV-ET-01 AV
Embertec EmbertecPC-ET-01 IT
Emerald Planet EP4340 IT
Emerald Planet EP4357 AV
Emerald Planet EP4371 AV
Emerald Planet EP4388 AV
Kambrook EPAUAV-KA-01 AV 
Kambrook  EPAUPC-KA-01 IT
Kambrook  KPA620 AV
Kambrook  KPA820 IT
Savasocket PS6WAU AV
Tricklestar  180SS-AU-6ATF(AV) AV
Tricklestar  180SS-AU-6ATF(IT)  IT
Watts Clever ES-AUS1110 IT
Watts Clever  ES-AUS1111 AV
Watts Clever  ES-AUS1221 AV

Approval Process for SPC’s

An approved laboratory test is a test approved by the Essential Services Commission of South Australia (the Commission). 

Before proceeding with testing, a laboratory test proposal must be submitted to the Commission for review, comment and potential approval.

The following should be considered when proposing a laboratory test:

  • The laboratory test shall be undertaken by a third party, independent to the SPC manufacturer, supplier and the Commission. 
  • Tests may only be undertaken by accredited test laboratories.
  • The general conditions for all tests, including the test room, power supply, voltage waveform, power measurement accuracy, and the selection and preparation of appliances and equipment, shall be performed in accordance with Australian Standards of household electrical appliances – measurement of standby power. 
  • One sample of each SPC model, selected at random by an independent party (for example, the test laboratory) shall be tested. For master/slave SPCs intended for use in both IT and AV environments, the tests for both types of devices shall be performed.
  • A test report or test certificate confirming compliance or otherwise of the switching device to the appropriate standard, should be provided.

Following approval of laboratory testing, once testing has been undertaken, the information outlined below have to be submitted to the Commission for consideration in the  SPC approval process:

  1. test report summary sheet 
  2.  laboratory test report , including test configuration diagram, testing details and time series data and plots
  3.  details of the SPC
  4. electrical authority approval
  5. photographs of the tested SPC

 

Updated: 30/03/2021

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REPSB7/1 - Bulletin no. 7 - Mandatory training requirements

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Bulletin no 7 - Mandatory training requirements

Summary:

Relevant industry recognised training units or in-house training schemes will satisfy the mandatory training requirements.  In-house training must be of comparable quality to recognised external training units and be relevant to the performance of REPS activities.


This Bulletin refers to the Retailer Energy Productivity Scheme (REPS) and is effective from 1 January 2021.  

This Bulletin outlines the mandatory training requirements for the delivery of Retailer Energy Productivity Scheme (REPS) activities.

The REPS Code imposes mandatory safety requirements on retailers in respect of the provision of REPS activities.  Assurance that all installers have completed the required training is to be provided annually by a retailer’s Chief Executive Officer (or equivalent) in the retailer’s Compliance Plan. 

In addition, the minimum specifications for the REPS activities of installing low-flow showerheads (WH2), building sealing activities (BS1A, BS1B & BS2) and installing residential LED General Purpose Lamps (L1) (refer to the minimum specifications of the Activity) require that:

‘The person undertaking this activity must satisfy the REPS Code mandatory safety training requirements.  Registered plumbers, Gas Fitters, Electricians and Building Work Supervisors are exempt from this requirement.’

The implementation of mandatory training requirements is to ensure REPS activities are undertaken safely and that customers can be confident that individuals installing devices in their premises have received a basic level of training, particularly in areas such as occupational health, safety and welfare.

Registered plumbers, gas fitters, electricians and building work supervisors are exempt from the REPS Code mandatory safety requirements because in order to gain trades registration they have undertaken an appropriate level of safety training.  It is not necessary to include the mandatory safety training requirements in the specifications for REPS activities where those activities are only permitted by law to be undertaken by registered tradespersons.

Mandatory safety requirements have not been specified for REPS activities that do not require installation of a product to be a valid REPS activity e.g. the purchase of high efficiency appliances.

For those retailers and/or third party providers developing their own in-house training, the adequacy of such training in meeting the REPS mandatory safety requirements will be assessed by the Commission when reviewing obliged retailer compliance plans.  The Commission will verify that any in-house training schemes have been developed to a standard of comparable quality to recognised external training units as relevant to the performance of REPS activities.

Updated: 01/1/2021

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REPSB8/1 - Bulletin no. 8 - Electronic activity records

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Bulletin no 8 - Electronic activity records

Summary:

  • Compliance with storage and communication requirements can be met using the appropriate electronic communication and storage methods in accordance with the Electronic Transactions Act 2000.
  • An Information Statement must be left with the customer at the time a REPS activity is performed and a copy of the signed activity form must be made available upon request to the customer. 
  • Customers must sign electronic devices using a stylus pen and not via a confirmation button.


This Bulletin refers to the Retailer Energy Productivity Scheme (REPS) and is effective from 1 January 2021.

This Bulletin outlines the process for the creation of ‘in-field’ activity records for REPS activities through the use of electronic devices.

Each electronic activity record must be in a form which contains the mandatory information and fields provided for in Schedule 3 of the REPS Code. Further, the customer must sign any electronic record through the use of a stylus pen rather than a simple confirmation button. Compliance with these requirements can be met using the appropriate electronic communication and storage methods set out in the Electronic Transactions Act 2000.

The electronic record must be fully completed before the customer signs electronically. No records are to be altered after obtaining a signature unless the installer has received express approval from the customer, and the customer and installer have initialled the change. The Commission may request documentation on how this requirement is monitored. The Commission’s preference is for electronic activity records to be time, date and geographically stamped.

When using electronic activity records, a copy of the signed record and/or an Information Statement must be provided to the customer at the time the activity is performed. If the customer receives an Information Statement, and not a complete copy of the signed activity record, a copy of the signed complete activity record must be made readily available at the customer’s request, either electronically or by post. The Information Statement left with the customer must include all the information required in clause 6.1.2 of the REPS Code.

The Commission can review and provide feedback on electronic activity records at the request of an obliged retailer.

Updated: 01/1/2021

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REPSB9/2 - Bulletin no. 9 - Energy credits and retailer arrangements

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Bulletin no 9 - Energy credits and retailer arrangements

Summary:

  • The Minister has determined the maximum energy credit that a retailer may apply to have taken into account in determining whether a retailer has met its REPS targets.
  • Retailers may transfer an energy credit (normalised gigajoules) to another retailer, or apply an energy credit against its own Energy Productivity Target (EPT), in the year following its accrual.  Any energy credit not applied to an EPT in the year following its accrual is considered spent. 
  • Where energy credits are transferred between retailers, both retailers must notify the Commission in writing.
  • A retailer may enter into an arrangement for another person (including another retailer) to undertake energy productivity activities on its behalf.
     

 

The Retailer Energy Productivity Scheme (REPS) commenced on 1 January 2021.  This Bulletin outlines the process for transferring or applying an energy credit accrued under REPS. It also provides guidance regarding retailer arrangements.

Energy credits

The Electricity (General) Regulations 2012 and the Gas Regulations 2012 (the Regulations) state that ‘energy credit’ means:

in relation to energy productivity activities, means the difference between the amount of normalised gigajoules actually achieved by a retailer through the conduct or acquisition of energy productivity activities under this Part 4 [of the Regulations] and the EPT that applies to the retailer for that year (if the difference is positive).

Activities do not become energy credits (normalised gigajoules) for REPS purposes until the reporting year has closed and those activities have been accepted by the Commission as compliant.

Accrual of an energy credits

Where a retailer accrues an energy credit for a REPS year, the Commission will notify the retailer of the amount of excess in accordance with clause 3.5 and 5.4 of the REPS Code.

Credits will automatically be ‘banked’ until further advice is received from retailers on the transfer or application of those credits.  Credits remain 'banked' until transferred to another retailer or applied to REPS targets in the subsequent year (in accordance with Ministerial requirements).

Ministerial requirements – Maximum energy credit

The Minister has determined the maximum energy credit that a retailer may apply to have taken into account in determining whether a retailer has met its REPS targets. The outcome of this determination is an energy credit may only be applied against a target in the year following its accrual, and not in any subsequent years. If an energy credit is not applied to a target in the year following its accrual by any retailer, it is considered spent.

 

Transfer of Credits between Retailers

The Regulations provide that retailers may enter into arrangements to transfer an energy credit to another retailer.  If a retailer accrues a REPS credit, the retailer may, at any time in the year following its accrual, transfer the credit to another retailer.

If energy credits are transferred between retailers, the Commission must receive formal advice from both retailers participating in the arrangement detailing the transfer.  The request must be signed and dated by an authorised person as outlined in clause 4.1.2 of the REPS Code.

Application of Energy Credits

A retailer may apply to the Commission, to take an energy credit into account in determining whether the retailer has met a target that applies to the retailer in the subsequent year. This application is completed thought the Retailer file validation system (REPS-R).

In a particular year, a retailer may apply towards the achievement of its EPT and subtargets: 

an energy credit it accrued in the previous year, and/or
an energy credit accrued in the previous year that has been transferred from another retailer.

Energy credits can be applied to meet electricity and/or gas targets regardless as to how such credits were created, noting that energy credits can only be applied against the target type against which they were accrued.

Example of Application of REPS energy credits

Retailer arrangements

The Regulations provide that a retailer may enter into an arrangement for another person (including another retailer) to undertake energy productivity activities on its behalf.

A retailer who arranges for another person to undertake energy productivity activities on its behalf, must lodge the activities in the Retailer file validation system (REPS-R) for those activities to count towards the achievement of its EPT.

If a retailer enters into an agreement for another person (including another retailer) to undertake energy productivity activities on its behalf, the retailer is still personally liable for any offence or penalty for failure to meet the energy productivity target, primary subtarget or secondary subtarget that applies to the retailer. 

As such, where a retailer engages another person to undertake energy productivity activities on its behalf, it should have appropriate measures in place to monitor the work undertaken to ensure that applicable targets are met. The submitting retailer is accountable for ensuring the compliance of those activities and for identifying in its Compliance Plan, the person or retailer undertaking the work on its behalf.

Updated: 09/06/2021

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REPSB10/1 - Bulletin no. 10 - Installation of standby power controller activities (SPC) in a household where the occupant has changed

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Bulletin no 10 - Installation of standby power controller activities (SPC) in a household where the occupant has changed

Summary:

  • The Commission will accept data files that contain addresses where standby power controllers have previously been reported to the Commission, provided that it can be demonstrated that the occupants have changed and the data file is accompanied by a signed declaration from the obliged retailer.
  • The declaration must be signed by the person who signs the responsibility statement accompanying the data file and must contain the wording specified in this Bulletin.
  • The declaration must be provided on submission of the associated data files and does not guarantee that the reported standby power controller activity will be accepted as compliant at the end of year compliance assessments.

This Bulletin refers to the Retailer Energy Productivity Scheme (REPS) and is effective from 1 January 2021.  

This Bulletin outlines how obliged retailers can demonstrate that the occupants of a premises have changed for the purposes of point (3) of the Installed Product Requirements of the Activity Specifications for Standby Power Controllers (SPCs).

Point (3) of the Installed Product Requirements for SPCs states:

(3) Where it can be demonstrated that the occupants have changed at a premises where standby power controllers were installed for the purposes of REPS, a maximum of three (3) further standby power controllers (IT and AV) may be installed at that premises.

For the avoidance of doubt, this point refers to situations where:

  • SPCs have been installed previously at a premises; and
  • A service provider identifies that the resident will benefit from the installation of SPCs; and
  • There is proof of a change in occupancy at the premises since the previous SPC installation.

Where all three of these situations are met, an obliged retailer can report subsequent SPC installations at a premises if the REPS data file is accompanied by a declaration stating the following:

“After due enquiry, I, the undersigned, declare that:
In my opinion, the addresses of household premises that have been reported to the Commission in the following date file(s) and listed below have changed occupants and the current occupants have not previously had standby power controllers installed for the purposes of the Retailer Energy Efficiency Scheme and the Retailer Energy Productivity Scheme at the nominated address.”

Name of current occupant Phone number of current occupant Name of file (text file) Line number (within text file) Address of current occupant  Length of current occupancy (1) 
           
           

 

   
 
 
   

Notes: (1) – State clearly whether months or years.  A ‘best estimate’ is required.

[insert name of obliged retailer] has in its possession or control records that will verify the information above and which will be made available to the Commission upon request.

Signed:___________________________________________
Name: ___________________________________________
Position: _________________________________________
Dated: ___________________

The declaration must be signed by the same person who signs the responsibility statement that accompanies the data file.

A completed declaration does not guarantee that the reported SPC activity will be accepted as compliant at the end of the year assessments.  The Commission will undertake audits of declarations submitted, and if found that the occupant has not changed, the date file will be removed from the REPS-R system and the obliged retailer will be asked to re-submit the file without the non-compliant data line.

Obliged retailers must retain evidence from the householder demonstrating the length of their occupancy.  Evidence may consist of a signed statement from the householder on the activity form, a voice recording etc.  

Obliged retailers must fully utilise the REPS-R Retailer File Validation System prior to undertaking and submitting REPS activities to the Commission.  The declaration can only be provided at the time the data is reported to the Commission.

The Commission expects each obliged retailer to have robust systems and processes in place to ensure compliance with the REPS activity minimum specifications.

Updated: 10/1/2021

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REPSB11/1 - Bulletin no. 11 - Compliance framework

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Bulletin no 11 - Compliance framework

Summary:

  • Obliged energy retailer’s Compliance Plans and processes should enable retailers to adequately identify and appropriately respond to their obligations and report any breaches to the Commission at the earliest opportunity.
  • Obliged energy retailers are required to submit a Compliance Plan for each REPS year (due by 31 March).
  • REPS obligations are directly placed on obliged energy retailers – not on third party providers. 
  • The Commission takes a ‘risk based’ approach towards REPS compliance.

This Bulletin refers to the Retailer Energy Productivity Scheme (REPS) and is effective from 1 January 2021.  

This Bulletin provides an outline of the Commission’s compliance framework for the REPS.

Obliged energy retailers’ compliance systems and processes should enable retailers to adequately identify and appropriately respond to their obligations and report any breaches to the Commission at the earliest opportunity.

The Commission’s REPS compliance regime consists of:

  • Requiring obliged retailers to develop annual Compliance Plans;
  • Compliance reporting;
  • Conducting compliance audits in response to identified areas of risk; and
  • Administering the penalty regime.

In undertaking its compliance role, the Commission is guided by its legislative objectives and in particular the need to protect the long-term interests of South Australian energy consumers.  The Commission has an Enforcement Policy providing guidance on the criteria and processes it uses in determining the type of enforcement action required on a case by case basis. The Commission takes a ‘risk based’ approach towards REPS compliance.  

While obliged energy retailers may elect to engage third parties to assist in the achievement of REPS targets, retailers cannot ‘out-source’ their REPS compliance obligations contained in the Ministerial specifications or other regulatory instruments.  The Regulations clearly place the obligations directly on retailers.

Compliance plans

Obliged energy retailers are required to submit a Compliance Plan for each REPS year (due by 31 March) outlining the information specified in clause 4.1 of the REPS Code.

Retailers are required to advise the Commission of any material changes to the information provided in their Compliance Plans (such as a change in the activities it intends to undertake or a change to contracted third party providers) within twenty (20) business days of such a change occurring.

The Commission reviews retailers’ Compliance Plans to assess the extent to which obliged retailers have put into place mitigation and management strategies aimed at ensuring that they are able to meet their REPS obligations and manage various risks.

A comprehensive Compliance Plan reduces the risk that activities reported towards annual REPS targets will be precluded by the Commission for failing to comply with the REPS Code or other relevant legal requirements.

Compliance reporting

In accordance with its reporting obligations under the Electricity (General) Regulations 2012 and the Gas Regulations 2012 (the Regulations), the Commission reports annually on energy retailers’ compliance with REPS and the terms of any relevant Code established by the Commission for the purposes of REPS. 

The Commission publishes the REPS annual report to inform stakeholders of REPS compliance outcomes, including retailer achievement against Energy Productivity Targets. 

The Commission may also, from time to time, publish ad hoc reports of compliance matters on its website.

Compliance audits

In addition to Compliance Plan requirements, the Commission monitors obliged energy retailers’ compliance with the REPS Code by undertaking:

  • Targeted audits on obliged energy retailers’ compliance systems from time to time to ensure compliance with the REPS Code provisions.
  • Targeted audits on identified areas of risk for non-compliance or where specific issues are brought to the Commission’s attention

Follow-up calls to consumers in response to complaints received to ensure that REPS activities have been implemented in accordance with the relevant activity specification. 

The Commission, as the Administrator of the REPS, has functions and powers for the collection of information necessary to perform and inform compliance audits.

Penalty Regime

The penalty regime applicable to REPS is set out in the Electricity Act 1996 and the Gas Act 1997 and in the Regulations.

 
Updated: 01/1/2021

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REPSB12/1 - Bulletin no. 12 - REPS activities in government owned housing

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Bulletin no 12 - REPS activities in government owned housing

Summary:

  • REPS activities in residential rental premises are subject to any necessary landlord permission.
  • Public or community residential premises owned by the South Australian Government are only eligible to receive REPS activities that are not a standard service provided by the manager of the premises.

 

This Bulletin refers to the Retailer Energy Productivity Scheme (REPS) and is effective from 1 January 2021.  

The REPS Activity General Specifications apply to all REPS energy productivity activities.

The General Specifications state:

“Activities undertaken in buildings are relating to assets owned by the South Australian Government are not eligible activities under the REPS unless:

The recipient is a residential tenant; and
The activity is not a standard service provided by the manager of the property.”
and:
“Where an activity is undertaken in a rental premises it may be necessary to first obtain the permission of the landlord or landlord’s agent.”

For South Australian Government owned public or community residential premises, the following REPS activities are not considered to be a standard service and may be delivered, subject to any necessary landlord permission:

  • Building sealing activities
  • Replacement of inefficient lamps with more efficient lamps
  • Replacement of inefficient showerheads with more efficient showerheads
  • Installation of standby power controllers
  • Installation of new efficient reverse cycle air conditioner (at tenant’s expense only)
  • Removal and disposal of refrigerator or freezer
  • Installation of high efficiency pool pump
  • Purchase of energy efficient appliances (at tenant’s expense only)
  • Switch electric (HP or resistance) water heater to tariff with solar sponge and off-peak blocks
  • Switch household electricity plan from single rate tariff to time of use (ToU) tariff
  • Connecting a new or existing battery to an approved virtual power plant 
  • Connecting a new or existing pool pump to an approved demand response aggregator
  • Connecting a new or existing HVAC to an approved demand response aggregator (ducted and non-ducted) 
  • Connecting a new or existing electric vehicle charger to an approved demand response aggregator 
  • Connecting a new or existing electric heat pump water heater to an approved demand response aggregator 
  • NABERS Building Demand Savings (NB1)

Other REPS energy productivity activities are not eligible to be delivered in South Australian Government owned public or community residential premises.

For community housing that is not South Australian Government owned, any REPS activity is eligible to be delivered subject to REPS eligibility rules and any necessary landlord or landlord’s agent’s permission.

 
Updated: 30/03/2021

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REPSB13/1 - Bulletin no. 13 - Commercial lighting

REPS bulletin header

Bulletin no 13 - Commercial lighting

Summary:

All products installed under the Retailer Energy Productivity Scheme (REPS) Commercial Lighting upgrade must be on the list of products accepted for installation under the NSW Energy Savings Scheme (ESS), or for LED Linear tube products, be listed on the Product Register of the Victorian Energy Upgrades Program Product Register.


This Bulletin relates to Retailer Energy Productivity Scheme (REPS) Commercial Lighting upgrade activities undertaken from 1 January 2021 and outlines the minimum reporting and evidence requirements.