Following on from ASBEC’s submission to the Direct Action Emissions Reduction Fund White Paper, the ASBEC Direct Action Working Group have reviewed the Green Paper and make a number of specific recommendations, in summary:
- That participation in complementary government emission reduction or energy efficiency programs not preclude access to the ERF; however, double dipping will be forestalled by ensuring there is a verifiable nexus between ERF-related incentives and ERF-related abatement.
- Normalisation methods be adopted for the Facility Method to ensure fluctuations in building occupancy, hours of operation and climatic conditions are appropriately taken into account.
- Live bid prices be made available during auction rounds until the finalisation of each auction. This will encourage competition.
- Contract terms be extended beyond five years with a provision to deem and pay extended abatement upfront.
- Successful bidders be provided with 50% of ERF funding upfront, with the remaining 50% payable on delivery of abatement instalments.
- Full payment for abatement based on NSW Energy Savings Scheme ‘Default Savings Factors’ be made once installation of plant or equipment is verified.
- International permits not be allowable to make-good contract shortfalls.
- ERF payments to be classified as passive income for the purposes of Managed Investment Trust legislation.
- The coverage threshold for the safeguard mechanism be based only on Scope 1 emissions, in keeping with existing rules for Liable Entities.
- Baselines for the safeguard mechanism be set with reference to individual facility history.
- International permits not be used by companies to meet their baseline requirements within the safeguard framework.
Read the submission
This submission is endorsed by eleven members of ASBEC who work together in the ASBEC Direct Action Working Group.