NELA has taken the opportunity to make a submission on the proposed changes to the Safeguard Mechanism. In summary, NELA submitted that:
1. prescriptive and ambitious baselines will be crucial, and new facilities in particular should be required to meet the highest possible standards, right from the outset;
2. Baselines for all medium-to-high emitting facilities should be reduced in a predictable way over time, and clearly and consistently enforced; and
3. it expresses qualified support for the introduction of a Safeguard Mechanism Credit. A crediting scheme of this kind may be extremely useful but, if it is to be established, it should be supported by the highest integrity standards and rigorous approaches to scrutiny and accountability.