Consultation on decommissioning wood-fired room heaters (as baseline for VEU activities 9 and 10)

Accredited persons sought guidance on wood-fired room heater decommissioning, and the meaning of ‘permanently inoperable’ in this context.

The safety of professionals during the activity, and of residents and consumers after the activity, is our main concern. We sought feedback on:

• the appropriate level of assurance to demonstrate compliance with our regulations and safety considerations, and
• what other decommissioning methods might allow wood-fired room heaters to remain safely within premises.

We received one submission which can be found in the resources section of this page.

The consultation assisted in informing us of changes to the Water heating and space heating/cooling activity guide. Updates of which can be found in the resources section of this page.

For further detail on the changes made to the activity guide please see the full program update.

Background

Activities 9A(iii) and 10A(iii) enable accredited persons to generate Victorian Energy Efficiency Certificates (VEECs) for the installation of gas, liquefied petroleum gas (LPG) room heaters or room air-to-air heat pumps (also known as reverse cycle split system air conditioners).

As part of these activities, we needed evidence to show that:

• the gas, LPG room heater or room air-to-air heat pump has been installed
• an existing plug-in electric heater or a wood-fired room heater^[1] has been decommissioned.

The need to decommission is detailed in the Victorian Energy Efficiency Target Regulations 2018. It provides assurance that a reduction in electricity consumption and greenhouse gas production is likely to occur in alignment with the VEECs generated from the upgrade.

The Water Heating and Space Heating/Cooling Activity Guide requires accredited persons to provide geo-tagged photos showing the wood-fired room heater ‘rendered permanently inoperable^[2]’.

As a regulator, we must balance effective and efficient decommissioning with ensuring that the practice is safe for professionals as well as consumers, both during and after the upgrade. As such, we require professional licensing or relevant industry standards to be met for several upgrade scenarios.

Before the changes, we required a plumber licensed by Victorian Building Authority (VBA) under the ‘Mechanical Services’ category to perform the decommissioning. In addition, accredited persons had sought clarity on the evidentiary requirements for wood-fired heater decommissioning.

This consultation aimed to gather feedback on our considerations.

What is safe wood-fired room heater decommissioning?

To clarify our expectations, we considered the meaning of ‘rendered permanently inoperable’ for these activities.

The risks to safety of future residents and integrity of buildings are significant. As a result, we believed the proportional approach is to require a high level of assurance. This would include evidence demonstrating the removal of the wood-fired heater and flue up to the ceiling (or fireplace), repair of the ceiling, and either:

• leaving the flue in the roof space and through the roof
• removing and repairing of the roof.

Documentation would have to demonstrate the following aspects of decommissioning:

• disconnection and removal of the flue from the heater
• removal or disabling of any combustion air intake or damper
• removal or disabling of any supply air fan (where fitted)
• disassembling of the heater and flue
• removal and disposal of the door from the heater and the heater itself
• having the heater recycled at a metal recycling firm, with evidence of disposal via an invoice from an appropriately permitted waste management operator
• repair and plastering of the ceiling ore roof / wall penetration, including a Certificate of compliance if repair work is greater than $750.
• in the case of a fireplace, the full structural removal of the fireplace.

Any removal of wood-fired room heaters needs to safely manage the spread of and exposure to ash, soot and creosote, and must be undertaken by a plumber licensed by the Victorian Building Authority under the ‘Mechanical Services’ category. Roof penetrations must be rectified by a licensed roof plumber.