CONSULTATION ON THE OPERATION OF THE SAFEGUARD MECHANISM

Similar documents
Emissions Reduction Fund: Safeguard Mechanism Consultation Paper. submission

RE: NATIONAL ENERGY GUARANTEE DRAFT CONSULTATION PAPER

Joint submission on the National Energy Guarantee: Commonwealth Elements

FOREWORD. Dear Reader

MINERALS COUNCIL OF AUSTRALIA

SUBMISSION TO THE HOUSE STANDING COMMITTEE ON ECONOMICS: INQUIRY INTO THE CLEAN ENERGY AMENDMENT BILLS 2012

Getting to Zero. Climate Action Points

A workable roadmap for Australia s climate change policies

New Zealand Emissions Trading Scheme Review 2015/16. Australia-New Zealand Climate Change and Business Conference October 2016

IETA-IEA-EPRI 9th Annual Workshop on Greenhouse Gas Emission Trading

An update on Australia s Climate Change Policy

SEPTEMBER 2007 ABATEMENT INCENTIVES PRIOR TO THE COMMENCEMENT OF THE AUSTRALIAN EMISSIONS TRADING SCHEME

CONSUMERS CALL FOR GOVERNMENT AND INDUSTRY TO SET HIGHER ENERGY PERFORMANCE STANDARDS FOR ALL AUSTRALIAN HOMES

AUSTRALIA. Submission under the Cancun Agreements February 2011

Parliamentary briefing: Second reading of the Agriculture Bill

Climate Change Authority Review of the Carbon Farming Initiative Legislation & the Emissions Reduction Fund. submission

The National Generators Forum (NGF) welcomes the opportunity to provide the following submission to the Garnaut Climate Change Review.

UK Committee on Climate Change Call for Evidence: Scottish Climate Change Bill. Response from Stop Climate Chaos Scotland February 2017

Profitability measures for regulated network businesses. Response to the AER Discussion Paper December 2017

EMISSIONS REDUCTION PLAN: BUILT ENVIRONMENT POLICY RECOMMENDATIONS

HIGH-LEVEL MEETING ON A GLOBAL MARKET-BASED MEASURE SCHEME

Proposal for a REGULATION OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL

Inquiry into solar feed-in pricing in Queensland

Operationalizing Article 6 of the Paris Agreement

Low-down on the new emissions caps for European countries

Carbon Pollution Reduction Scheme. Green Paper. Submission to the Department of Climate Change

25th March The Secretary Senate Standing Committee on Economics PO Box 6100 Parliament House CANBERRA ACT

DEFINING A CORPORATE CLIMATE FINANCE COMMITMENT

Australian Aluminium Council submission to Senate Select Committee on Climate Policy

GHG emissions per capita. (tco 2. e/cap) Source: UNDP, data for 2015 Source: World Bank Indicators, data for 2012 Source: IEA, data for 2013

Submission to Independent Expert Panel on Interim Targets. May 2018

Policy Brief_ Australia and the Future of the Kyoto Protocol l

Submission to inquiry into the retirement of coal fired power stations

Project financed by the

POLICY GUIDELINES by the Energy Community Secretariat

Clear price signals in the NZ ETS

The science of climate change

UNITED NATIONS FRAMEWORK CONVENTION ON CLIMATE CHANGE

COP21 and the Paris Agreement: what it means for UK businesses

O-I NEW ZEALAND SUBMISSION ON THE PRODUCTIVITY COMMISSION S LOW EMISSIONS ECONOMY INQUIRY

Tracking progress to net zero emissions

About Energy UK. Introduction

australian network of environmental defender s offices

New Zealand Emissions Trading Scheme Review: Improving the ETS framework

Regulatory Impact Statement: Human Rights Amendment Bill

Interim Emissions Reduction Targets for Victoria ( )

Building the Foundations for a Low Pollution, Clean Energy Economy

Emissions Reduction Fund. Savanna Fire Management Determinations: Sequestration and Emissions Avoidance; and Emissions Avoidance (only)

Carbon Impacts on Local Government. Prepared by: Carbon Solutions Group, Commonwealth Bank Date: November-09

Responsible carbon impacts new buildings and fitouts

European Commission DG Energy Unit B2: Wholesale markets, electricity & gas Office: DM24, 6th floor Rue De Mot 24 B 1049 Brussels/Belgium

Cap-and-Trade: The Basics

Submission on Special Review Second Draft Report Australia s climate policy options

GAINS Mitigation Effort Calculator

on the Vocational Education and Training Fee and Funding Review

REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL. The state of the European carbon market in (Text with EEA relevance)

EFET Response to EC Consultation on. Structural Options to Strengthen the EU Emissions Trading System. 28 th February 2013

Draft LGNSW submission to the Aboriginal Cultural Heritage Bill April 2018

Defining a Corporate Climate Finance Commitment

Craigmore Sustainables NZ

6842/12 SH/mp 1 DG I

NSW Government Climate Change Framework. Submission to the Climate Change Fund Draft Strategic Plan

Property Upgrade Climate Bonds

Yorkshire Forum for Water Customers

Unlocking value for the Queensland economy with land and agriculture offsets

What does the 2030 climate and energy framework mean for Ireland? November 2014

Carbon Market Institute Business Roundtable. Tas Sakellaris Department of Climate Change and Energy Efficiency

Reflections on the new role of the National Water Commission. Water Law & Policy Conference Canberra, 7 December 2012

A UK Perspective on Carbon Markets

U.S. Legislation to Address Climate Change: The Lieberman/McCain Climate Stewardship Act. Tim Profeta November 16, 2004

RE: GBCA SUBMISSION - CLEAN ENERGY FINANCE CORPORATION STATUTORY REVIEW

The announcement effectively makes it harder to decarbonise the power sector by 2030 to help meet our climate change targets.

Leaders Event at COP 21 UNFCCC, Paris, November 30 th Statement by the President of the Swiss Confederation Simonetta Sommaruga

Subsidiary Body for Scientific and Technological Advice

australian network of environmental defender s offices

GEMS Review Taskforce Appliance and Building Energy Efficiency Branch Department of the Environment and Energy GPO Box 787 CANBERRA ACT 2601

environmental defender s office new south wales

Submission. Emission Reduction Fund Terms of Reference. Key Recommendations

Emissions Reduction Fund Workshops Energy & Fuel Efficiency

AUSTRALASIAN RAILWAY ASSOCIATION SUBMISSION

Sweden s view on EU-policy for renewable energy after 2020

SUBMISSION ON NEW ZEALAND EMISSION TRADING SCHEME REVIEW 2015/ April 2016 FONTERRA CO-OPERATIVE GROUP LIMITED

Climate Change Position Statement and 2020 Action Plan

Queensland Renewable Energy Expert Panel Issues Paper

Carbon Market Institute. Submission - Review of the National Carbon Offset Standard and Carbon Neutral Program

Planning Institute of Australia Submission on Accredited Professionals Scheme Discussion Paper Released for Public Comment February 2018

Consultation on the Zero Carbon Bill. Ravensdown Submission to the Ministry for the Environment

Energy Efficient Lighting Consultation RIS. Submission response

Session SBI42 (2015)

Additional information on progress in implementing enhanced action prior to 2020 in accordance with decision 1/CP.21, section IV

Visiting fellow in the School of Economics at the University of Queensland

How transport CO2 reduction pledges fall short POLICY BRIEF

Submission Emissions Trading Scheme Discussion Paper

The Australian Industry Group

Opportunities and challenges created for JI and CDM by the EU ETS Directive

ACHIEVING AUSTRALIA S EMISSIONS REDUCTION TARGETS IN THE CONTEXT OF A DIRECT ACTION APPROACH

News from COP21 Latest on Climate Change Standards and Financing Opportunities

CLEAN ENERGY PACKAGE

Informal information note by the Co-Facilitators

CAMAC DISCUSSION PAPER CORPORATE SOCIAL RESPONSIBILITY

Transcription:

Investor Group On Climate Change (IGCC) Submission to: CONSULTATION ON THE OPERATION OF THE SAFEGUARD MECHANISM 4 April 2018

4 April 2018 Safeguard and Industrial Policy Section Department of the Environment and Energy GPO Box 787 CANBERRA ACT 2601 Consultation on the operation of the Safeguard Mechanism The Investor Group on Climate Change (IGCC) welcomes the opportunity to provide input into the review of the Safeguard Mechanism. IGCC represents over 68 Australian and New Zealand institutional investors with more than $2 trillion of funds under management, along with members of the investment community focused on the impacts of climate and energy issues. IGCC members are invested across the Australian economy and are part owners of most of Australia s large companies. As managers of retirement savings and pooled investments we are concerned with the evident and increasing impacts of climate change on the global and Australian economies and the flow through impacts for investment returns. Australia s response to climate change needs be inclusive of considerations for the economic and investment implications of the global response to climate change. This includes the setting out a practical pathway for ensuring Australia s economic competitiveness in a carbon constrained global operating environment over the longer term. We are concerned that the Safeguard Mechanism does not currently deliver on Australia s commitments under the Paris Agreement to limit global warming to below 2 C. Further weakening the constraints established through the Safeguard Mechanism, will further undermine Australia s ability to reduce emissions in a cost efficient manner.

Principles and priorities for investors In reviewing the efficacy of Australia s climate change policies, it is crucial to consider the role and impact of each policy mechanism in the context of the wider economy and the transition towards decarbonisation. Across the suite of policies, the overall goals and outcomes must be consistent with the commitments made under the Paris Agreement, and the long-term goals that it sets out for both national and the global economies. Australia has a carbon intensive economy which is exposed to the regulatory, physical and market risks of climate change. Investors are seeking an integrated climate change policy framework where the key elements are grounded in broad-based bipartisan support, credible emissions reduction ambition and an ability to deliver investor certainty. IGCC notes that the Australian Government, along with the COAG Energy Council and the Energy Security Board, is currently undertaking design work towards the establishment of the National Energy Guarantee. With the right design parameters, an effective policy mechanism applied to the electricity sector could make significant contributions towards reducing Australia s emissions. However, the proposed emissions reduction task allocated to the electricity sector under the National Energy Guarantee, a proportional reduction equivalent to a 26% emissions reduction from the electricity sector by 2030, will be insufficient to achieve the Australian Government s national 2030 emissions reduction target alone, let alone deliver a credible longer term pathway to decarbonisation. As highlighted in a recent update to Australia s Emissions Projections by the Department of Environment and Energy, further policy action is required to meet Australia s 2030 emissions reduction commitments under the Paris Agreement. As Australia seeks to achieve ambitious reductions in greenhouse gas emissions, a whole-ofeconomy approach is essential to ensure emissions reductions goals are achieved at lowest cost. A policy response for other major emitting sectors of the economy, such as the Safeguard Mechanism, is therefore an integral part of the Government s suite of climate change policies. The Safeguard Mechanism must therefore provide a credible means of driving emissions reductions across other sectors of the Australian economy. Attention should be given to how the mechanism may be strengthened to support increased investment in low-carbon technologies throughout industry, not weakened.

The Operation of the Safeguard Mechanism The Safeguard Mechanism was intended to provide a framework for the monitoring and reporting of emissions, and a means by which growth in Australian emissions could be constrained. To operate as a credible emissions reduction mechanism, the design parameters of the Safeguard Mechanism must therefore demonstrate a clear contribution by covered sectors towards meeting the goals of the Paris Agreement. A credible pathway towards meeting the Paris Agreement commitments is an essential feature of any climate policy suite that seeks to provide certainty for investors to drive a transition to a low carbon economy and to provide a clear and transparent market signals which support investment confidence. Where those policy settings are credible, investment capital will flow. As such, there is no clear case for amendments to be made to the Safeguard Mechanism that would lead to a weakening of the limits to emissions growth placed on large emitters through the safeguard mechanism. A transition to a low emissions economy will require limitations on the ability for unmitigated growth in emissions from emissions intensive industries and a clear signal for new investment to be made in achieving emissions reductions across all sectors of the Australian economy. Proposed Changes to the Safeguard Mechanism IGCC supports the principle that the setting of baselines for covered entities should be relatively straightforward, transparent and efficient. It should promote comparability across facilitates for investors, and allow for proper analysis and assessment of ongoing operational performance against regulatory constraints in an up to date manner. The Safeguard Mechanism should aim to actually constrain emissions growth across covered sectors. IGCC is concerned that the proposed changes to the Safeguard Mechanism towards calculated emissions baselines tied to levels of production and reviewed on an on-going basis is likely to significantly diminish the ability of the Safeguard Mechanism to effectively constrain further growth in Australia s emissions. While acknowledging the need for regular review and adjustment to reflect up to date production levels and unforeseen production expansion, by linking the emissions number

under the Safeguard Mechanism to the levels of actual production by facilities, adjusted annually, the effectiveness of the scheme to constrain increases in emissions is undermined. For example, with an ability to adjust emissions baselines annually, the emissions number (the baseline) would simply increase as the actual volume of emissions from a company increases. If the emissions baselines set for companies before which offsets are required are continuously increased proportionally to production levels, then companies will face little need to invest in reductions to their emissions levels. This undermines the incentive to invest over the medium term to improve the emissions intensity of operations. If the intent of the scheme is to encourage companies to increase their emission efficiency as they increase their production levels, the proposed changes to the Safeguard Mechanism would not achieve the stated climate policy aim to constrain emissions growth. Further, any weakening of the Safeguard Mechanism will lead to a diminished market for emissions reductions generated under the Emissions Reduction Fund. With limited remaining funding allocated for the purchase of further emissions reductions under the Emissions Reduction Fund, the Safeguard Mechanism is likely to remain the only source of future demand for ACCUs. If emissions intensive industries are provided further flexibility to increase their levels of emissions without an obligation to source appropriate levels of offsets, the market for ACCUs will remain limited, restricting growth in further investments in low carbon technologies and industry and stymie the emergence of a domestic market for emissions offsets. This works to further undermine any business case for investment in reducing emissions within high emissions industries in Australia, increasing the difficulty of achieving Australia s long-term emissions reductions goals. Finally, IGCC in-principle supports the establishment of agreed production variables, while noting the challenges of determining an industry standard in areas with substantive variance across covered entities and with facility level complexities. With Australia s commitments under the Paris Agreement to further review and increase the level of emissions reduction ambition, the Commonwealth Government must work to establish a set of policies that can enable a scaling up of the Australian abatement task. With the electricity sector now expected to deliver less abatement, other industry sectors will be expected to deliver more emission reductions to help achieve Australia s national

commitments. Real caps capable of delivering real emission reductions across the economy are therefore required. The IGCC thanks the Department for Environment and Energy for the opportunity to provide a submission to the review of the Safeguard Mechanism and would be happy to facilitate further this discussion of the issues raised in this submission. Kind regards Emma Herd CEO Investor Group on Climate Change