ASBG's submission on the Emissions Reduction Fund Green Paper focused on provision of ideas on how the ERF could be structured. ASBG proposed a model using both absolute and emission intensity baselines as an alternative option for the design of the system. Credits would be paid only if emissions are below the absolute baseline, but any penalties would only apply if both the intensity and the absolute baselines were exceeded. Advantages and disadvantages are discussed. The submission considered a number of issues with ERF and how the ASBG model could reduce administrative costs and potentially better align with international carbon markets. Having a carbon credit market with international trading potential could provide an income for manufacturing sites which are shrinking or considering closure. Click here for pdf of the submission.