ASBG's submission on the EPA's Climate Change Action Plan and Policy required clarification. Would the EPA rigorously stick with the NSW Net Zero targets regardless :
- Of the transition to a net zero end point, as a rough high cost path would cause financial difficulties on EPL holders within a competitive market?
- And ignore competitive products and their Greenhouse Gas (GHG) Intensity where EPLs are made less competitive or close enabling NSW to actually increase GHG globally?
- Also ignoring the likely price increases and supply unreliability associated with Eraring's closure in 2025?
Or work with NSW EPLs to assist and oversea their progress towards a low to zero GHG product intensity where competitive products are considered along with transitional difficulties NSW experiences in its electricity grid.
Obviously ASBG recommended that EPA consider these issue and work with, rather than against NSW EPL holders. Noting that as EPLs under NGERs etc are exempt from GHG EPL controls this largely leaves EPL holders who have product competition in the NSW market. In addition ASBG recommended:
- Duplication of GHG emissions, performance, future plans etc, be avoided with use of existing documentation over EPA variations.
- Use of EPL conditions to control GHG be limited to only those who are laggards - have no reasonable economic or technical excuse to reduce GHG.
- Load Based Licensing not be used to ensure NSW EPL's help NSW achieve its Net Zero targets, or other criteria
- Adaptation to deal with pollution incidents resulting from climate change bad weather events, be limited to ad-hoc changes to existing sites, and only use increased weather related design criteria (i.e. 1 in 100 yr rain events) if this applies across all new sites under the planning system.
 ASBG Submission on Climate Change Action Plan 2022 | 1196 kB |
