Safeguard update: Do you need to tighten your baseline?
The safeguard mechanism kicks-off in one month, and about 85 percent of designated large facilities (i.e. facilities covered by the safeguard mechanism) have received their draft reported emission baseline numbers from the Clean Energy Regulator.
Now, it’s time to consider if activity changes at your facility mean that your proposed baseline number should be decreased. If you fail to notify the Regulator of changes to facility activities, then you may be struck with a retrospective baseline reduction down the track. This is important because most facility operators have focused on whether they might exceed their reported baseline, but may have overlooked whether the reported baseline number should in fact be reduced.
This is relevant to any designated large facility that has changed its activities since its highest NGER-reported scope 1 (direct) emissions.
A spokesperson for the Regulator has confirmed that baselines should be reduced where:
- activities previously reported as occurring at the facility no longer occur, and
- activities of a similar kind are unlikely to occur for the next three years.
This includes where activities previously reported for one facility are now reported against another facility.
Baselines will be reduced where changes are considered “significant”, meaning changes to emissions that are greater than five percent of the reported baseline number that would otherwise apply.
When providing the Regulator with feedback on your reported baseline, you may also want to provide additional information that you think is relevant to determining your baseline accurately.
As you may already be aware, if, after considering your reported baseline number, you are concerned you will exceed it in the next few years, there are several flexible compliance mechanisms you can utilise. These include calculated emissions baselines and multi-year monitoring.
For further enquiries about the safeguard mechanism, contact Ndevr Environmental Director Matt Drum or Consultant Amy Quinton: