NELA Submission on the National Greenhouse and Energy Reporting (Safeguard Mechanism) Amendments Rules
February 28, 2023/Law Reform Submissions
NELA welcomed the opportunity to comment on the National Greenhouse and Energy Reporting (Safeguard Mechanism) Amendments Rules (Safeguard Rules) on 28 February 2023.
NELA’s submission included:
- NELA generally supports the proposed method of calculating baselines for new and existing facilities, along with the proposed hybrid model;
- In relation to compliance options, NELA submits that the availability of ACCUs to meet Safeguard Mechanism baselines should not be unlimited and should be reduced overtime;
- There should be further clarification on when, if at all, international best practice will be taken into account when calculating for existing facilities;
- NELA supports the decision to disallow Safeguard Facilities from counting ACCUs sold to the Government through existing carbon abatement contracts toward their baseline for the first two years following the reforms;
- Safeguard Mechanism Credits should be the exclusive credit for reduction in emissions covered by Safeguard Mechanism facilities, and that ACCUs are only to be available for emissions reduction outside of the Safeguard Mechanism;
- NELA supports the adoption of a framework which is based on the comparative impact of emissions reductions efforts on Safeguard Mechanism facilities to ensure that businesses are not comparatively disadvantaged; and
- NELA recommends that the review period, which is currently scheduled for the 2026-2027 financial year, be brought forward to the 2025-2026 financial year.
Read our full submission here.