New guideline for greenhouse gas emissions as good as you can get

The WA Environmental Protection Authority’s (EPA) guideline for greenhouse gas emissions is the document many have been waiting for.

After the March 2019 Environmental Factor Guideline (EFG) was released, and then withdrawn, the 2020 version aligns with both Federal and State Government policy and tidies up the uncertainty that was bothering industry last year.

There is a clear and present focus on net zero emissions by 2050, a target which is steadily lining up across the globe. While some of the biggest emitters have already made corporate commitments based on a 2050 timeframe, this guideline requires industry subject to the threshold of 100,000 tonnes per year of Scope 1 emissions to get specific with the things they are going to do to manage emissions on their WA projects.

The onus is back on industry to develop Greenhouse Gas Management Plans which include the following key components:

• intended reductions in Scope 1 emissions over the life of the project;
• targets to reduce Scope 1 emissions over time, and
• measures to avoid, reduce and offset emissions.

The plans will be published for all to see and performance reports will have to be regularly submitted, and made public, to show how the big corporates are performing.

The EPA has demonstrated how to play its regulator role exactly as it should – with evidence-based policy translating into clear guidelines – sticking to the important elements of clarity, certainty, transparency, and good process.

While not as hard-nosed as its previous incarnation, especially around the issue of offsets, the consultation process, and subsequent revisions, have ultimately led to a more workable and practical outcome.

Some of the content in the neat six-page document is subtle but important.

The threshold for what is known as “Scope 1” emissions – those emissions that are released directly into the atmosphere from project activities – is relatively low at 100,000 tonnes per year. This is consistent with the Australian Government’s threshold for large facilities, but it may also capture projects and activities not used to thinking of themselves as big emitters.

How the guideline will apply to land clearing might also surprise some operators, particularly in the Pilbara or Kimberley – where large-scale irrigation or agriculture projects could find themselves having to consider plans for offsetting the removal of vegetation.

Nonetheless, the guideline has clearly been based on contemporary policy settings, broad consultation, advice from experts and negotiations with industry.

Apparent acceptance from peak bodies such as the Chamber of Minerals and Energy and Conservation Council would seem to indicate the EPA has struck the right balance, which is never an easy task.

There are other jurisdictions in Australia which have been watching with interest to see where WA lands with this, perhaps looking to replicate rather than design their own attempt.

The EPA may just have demonstrated an approach which is as good as you can get.

Dr Paul Vogel AM is the current Chair of the Northern Territory EPA, and previously chaired both the SA EPA (2002-2007) and WA EPA (2007-2015). He provides strategic advisory services across the full range of complex environmental and regulatory processes. To get access to Dr Vogel’s insights about your project, contact our Director of Stakeholder Engagement, Charlie Wilson-Clark.

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