- Submissions
Submission to the Standing Committee on the Environment and Energy: National Greenhouse and Energy Reporting Amendment Bill 2020
The Minerals Council of Australia (MCA) representing Australia’s minerals exploration, mining and processing industry, supports decarbonisation of the minerals sector consistent with the climate and development goals of the Paris Agreement and based on a nationally coordinated approach to cliimate and energy policy.
The MCA supports the National Greenhouse and Energy Reporting Scheme (NGERS) as an important and effective complliance element of the Australian Government’s approach to addressing climate change.
The MCA considers it important that all emissions be accurately recorded, but it does not support additional regulation that compels individual companies to report their scope 3 emissions under the NGERS for compliance purposes.
The MCA considers that the current greenhouse gas accounting rules already provide for an accurate accounting of emissions. In practice a facility’s scope 3 emissions is fully and accurately accounted for as another sector’s scope 1 regardless of whether they are emitted domestically or internationally. There is no policy argument that supports any need for firms to compulsorily report their scope 3 emissions under the NGERS as represented by this bill.
At the national level the NGERS requires liable firms to report their scope 1 emissions (direct) and scope 2 emissions (indirectly generated from the generation of purchased energy) annually. This recognises that these emissions fall within their scope of influence to manage, control and indeed reduce over time. There is clearly a legitimate policy argument for the inclusion of these emissions in national compliance-based reporting.
Scope 3 emissions on the other hand are generated from external sources not owned or controlled by local facilities. These so-called indirect (or non-scope 2) emissions are emitted at various points in the value chain, often far removed from the point of raw material extraction. The generation and management of scope 3 emissions are exogenous to the decision-making of the facility extracting the minerals in the first place.