Non-building based lighting upgrades (Activity 35) update

10 April 2024

Clarifying requirements for LED floodlight installations

We have identified a number of instances where LED floodlights have been installed in existing enclosed light fittings in open air public car parks and public spaces. The existing fittings were likely designed for the specific lamps they previously contained and may not be suitable to house LED floodlights. 

LED floodlights are generally suitable for outdoor installation without the need for any type of casing and installing them in this manner has raised concerns regarding the possibility of:

• poor light distribution due to installation method not being considered in the lighting designs
• product warranty issues and shorter lifespan due to installations deviating from the manufacturer’s recommendations and product specifications.

Under the Victorian Energy Efficiency Target Regulations 2018 (VEET Regulations), all prescribed activities must be undertaken in compliance with the Electricity Safety Act 1998 and the regulations under the Act as follows:

• lighting upgrades must comply with Australian Standards, AS/NZS 3000: 2018 – Electrical Installations, which stipulates that electrical equipment must be selected and installed to ensure safe and reliable operation[1]
• the installation process should follow the Australian Standards as well as manufacturer’s instructions, incorporating safe work practices to protect against mechanical, environmental, or other external influences[2]. 

Compliance with lighting standards and lighting designer requirements

To create certificates under prescribed activity 35, Accredited Persons must engage a suitably qualified lighting designer to confirm that the design and installation of the lighting upgrade either meets, deviates from, or should be exempted from the relevant parts of the Australian Standards (AS/NZS 1158 – Lighting for roads and public spaces or AS 2560 – Sports lighting). 

The lighting designer must be one of the following:

• member of the Illuminating Engineering Society of Australia and New Zealand (MIES)
• fellow of the Illuminating Engineering Society of Australia and New Zealand Limited (FIES)
• a Registered Lighting Practitioner (RLP) - Illuminating Engineering Society of Australia and New Zealand.

If the lighting upgrade deviates from the relevant part or parts of AS/NZS 1158 or AS 2560 you must specify why it is unreasonable to meet that standard, as well as demonstrate that the energy consumer has accepted the lighting design prepared by the lighting designer.

If the lighting upgrade is not of a kind for which AS/NZS 1158 or AS 2560 is designed, you may seek an exemption from the need to comply with those standards prior to the commencement of the upgrade.

The Non-Building Based Lighting Upgrade Activity Guide under sections 4.5 and 4.6 outlines the requirements that need to be met by Accredited Persons if the installation deviates from requirements under AS/NZS 1158 or AS 2560 or is not of a kind for which AS/NZS 1158 or AS 2560 is designed.

Changes to the Non-Building Based Lighting Upgrade (Activity 35) Guide

We have updated the non-building-based lighting (activity 35) documents in response to changes in the AS 2560 and/or AS/NZS 1158 lighting standards. These standards have been updated since the regulations for these activities were gazetted.  Clause 9 of the VEET regulations provide that a reference to an Australian Standard or an Australian/New Zealand Standard is a reference to that Standard as issued or published from time to time. 

We have amended the below documents to remove specific references to the “’year’ of the standards and to update specific references to the standard as needed (e.g. the number references of tables in the standard): 

• Non-Building Based Lighting Upgrade Activity Guide
• AS 2560 (35) Compliance Declaration Template 
• AS/NZS 1158 (35) Compliance Declaration Template 
• Training Identification Matrix and Installer Qualification Declaration Template. 

The changes to the activity guide and compliance declarations reflect the changes to the lighting standards, in particular changes to section and table references.  

Stakeholders should ensure they are complying with the relevant requirements under the current version of AS 2560 and/or AS/NZS 1158 lighting standards when undertaking non-building based lighting upgrades under the program.  

Obligations of the Accredited Person

We remind you that it is the responsibility of the Accredited Person to ensure that installations meet all legislated requirements. Installations that do not meet the requirements may be referred to the relevant authorities for further action.

We are focused on ensuring compliance with the program rules and strongly advises Accredited Persons to review their current practices and controls around this activity to ensure program compliance. We will not register non-compliant certificates and will consider enforcement action when VEU program rules are broken. 

Where to get help 

If you have any questions with respect to the information set out in this update, please contact VEU support on (03) 9032 1310 or veu@esc.vic.gov.au