Submission on the Possible Design for a National Greenhouse Gas Emissions Trading Scheme discussion paper

This discussion paper proposes a cap and trade greenhouse gas trading scheme for Australia. While AEBN does not support a trading scheme at this stage, the likely hood of its introduction promoted the submission and recommendations.

Key issues raised in AEBN’s submission includes:

  •  In setting the cap wider issues, such as economic growth, war etc also need to be considered
  • Setting the cap too high is likely to result in a consumer back-lash
  • The cap should consider the performance of developed countries to their greenhouse targets, not their targets alone (many are not meeting Kyoto obligations)
  • Special credits be provided for companies that undertook early action, especially under the Greenhouse Challenge program
  • Concern that the cost of energy measurement and auditing has been considerably underestimated by government

Recommended actions to control the costs of energy measurement / audit / verification include:

  • Increase the efficient use of energy auditors, by limiting their official requirements.
  • Increase the number of energy consultants and auditors through education programs.
  • Government to set appropriate measurement/audit standards on emitters according to their scale of the emissions.
  • Provide a means to review measurement/audit standards —Use an independent panel to review cases for lowering the cost and improving the accuracy of measurement and auditing.
  • The government develop special energy-intensive trade-exposed credits for specific industry sectors based on energy use and sector wide emissions calculations


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