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Emissions Reduction Fund - Green Paper Submission

2014-04-08 05:22:54
Emissions Reduction Fund - Green Paper Submission

During February this year, ISCA made a submission in response to the Department of Environment's Emission Reduction Fund Green Paper.

We acknowledge the support of a member, pitt&sherry, in assisting with the preparation of this submission, and the review by Scott Losee of Scott Losee Consulting. 

The Emission Reduction Fund Green Paper presents the Government's preferred design for the Emissions Reduction Fund policy which sits at the centre of the Direct Action Plan, launched in 2010. The Direct Action Plan outlines how the Government will meet its five per cent emissions reduction target. The Government proposes that the Emissions Reduction Fund should follow three key principles; Lowest-cost abatement, genuine reductions and streamlined administration.

The Government invited written submissions on the Green Paper to be considered in a consultative process leading up to the release of the White Paper in early 2014.

ISCAs submisson was based on our view that the infrastructure sector, and in particular ISCA and the IS rating scheme can assist the Government to meet all three of the principles.

The Green Paper implies that ERF abatement opportunities will arise mainly from existing, heavy industries (alongside Carbon Farming Initiative credits). ISCA invites the Government to open it's mind to the possibilities within the infrastructure sector.

Infrastructure investments tend to be large scale with emissions associated with construction as well as operation, and both phases influenced through design. Depending on the type of infrastructure, use of the facilities can also cause significant emissions (most notable with road networks). Within the IS rating scheme, the Government has access to an existing framework that:

  • Is robust.
  • Incorporates  industry-standard means of performance assessment, including NGERS.
  • Effectively determines and monitors best practice while encouraging and closely following innovations that improve performance

IS can also deliver important social, environmental and economic co-benefits alongside GHG abatement.

The submission incorporates the results of a recent survey of ISCA members on GHG emissions reduction and the ERF.

Visit our Publications page to view our submission. Publications.