A submission by ACF and Environmental Justice Australia on theEmission Reduction Fund Safeguard Mechanism Consultation Paper says the ERF will make “at best only a limited contribution to achieving the 2020 target and it will do nothing for the structural adjustment needed to achieve the more significant reductions”.
The submission raises serious concerns about the consultation paper’s proposal to allow ‘increased baselines’ for pollution from certain industries, such as mining, oil and gas.
“The proposal to allow emissions growth in the mining, oil and gas sectors – industries that are responsible for much pollution already – shows this policy is not prepared to do the heavy lifting,” said ACF’s climate change program manager, Victoria McKenzie-McHarg.
“The proposed setting of limits at the highest, rather than lowest, level of emissions seems to be at odds with the purpose of having a baseline.
“Pollution limits for large facilities should be set at the facility’s lowest level of emissions during a five year period, as the facility has demonstrated it is capable of operating at those lower levels,” Ms McKenzie-McHarg said.
The ACF-EJA submission recommends the safeguard mechanism’s coverage be expanded to all facilities that report under the National Greenhouse and Energy Reporting Act 2007.
“The proposed baseline for electricity generators is inconsistent with the scheme set out in the NGER Act,” said EJA’s Felicity Millner.
“Therefore, we don’t think the government has the power to allow sector-wide baselines.
“We are also concerned the proposed mechanism is not broad enough to guarantee that pollution reduced in one part of the economy will not simply be replaced in another sector.
“The safeguard mechanism has the potential to be a foundation for the structural adjustment that needs to occur across the economy, but instead it simply imposes a nominal limit on certain facilities while overall pollution is allowed to grow,” Ms Millner said.