Consultations

Public policy and regulatory engagement

Australian energy, emissions and industrial policy is made largely in the open, through consultation processes that anyone can respond to. Where Heliovulcan’s evidence base can answer a question a consultation is actually asking, a submission is made and recorded here — with the question, the evidence used, the findings and a link to the published document, so the reasoning can be checked rather than taken on trust.

The record

Published submissions

CCA · 2026 Annual Progress Advice Lodged 9 August 2026 · Response ID sbm3e7c25df367242f431d34

InstitutionClimate Change Authority

Consultation2026 Annual Progress Advice consultation paper (Part 3 — the Authority’s 2026 advice on the Safeguard Mechanism). Submissions closed 9 August 2026.

Question examinedQuestion 10 — whether the Safeguard Mechanism should play a stronger role in encouraging onsite abatement relative to ACCU flexibility, what objectives should guide that assessment, and whether additional incentives or constraints are warranted. Public-register evidence is also provided against Question 9. The submission does not address the other questions in the paper and says so.

Evidence usedCER Safeguard facility reported emissions, FY2024–25 and FY2023–24 — filed. CER ACCU Scheme Project Register, 31 May 2026 — filed. CER emissions-intensity determination data, 15 May 2026 — filed. Project-to-facility matching using two-stage name and corporate-group rules with project-location checking — derived. All shares use a denominator of 208 covered facilities and 132,797,928 tCO₂-e, which reconciles to the published 132.8 Mt; facilities disclosed under s58B as eligible but not covered for the year are excluded.

Key findingsThirty-six onsite abatement projects were matched to 25 Safeguard facilities, carrying a cumulative 5,161,903 ACCUs. Six were registered after reformed baselines commenced on 1 July 2023 — all coal mine waste gas electricity generation, four of them within four days in March 2025. Of 115 covered mining facilities, 46 report an Electricity generation production variable and 69 do not. Deployment at one site is a screening signal, not evidence that a technology is cost-effective across a subsector. Asset control and marginal abatement cost cannot be established from public registers at all — which is why the submission recommends a two-tier assessment rather than a limit set by industry classification.

Submission linkRead the submission (PDF, 5 pages). The Authority publishes submissions after a consultation closes; this entry will be updated with a direct link to its copy when that record appears.

Related workThe floor beneath the Safeguard baseline — the statutory minimum baseline and the cohort sitting on it. Most of the diesel is on wheels — national reconciliation of the replaceable diesel market. Mine decarbonisation funding map.

Not resolvedOne published figure was not reproduced exactly. The submission identifies 24 facilities surrendering ACCUs at or above 30% of baseline, where the Authority and Department report 23. The difference may lie in the treatment of deemed surrender. It is named in the submission rather than reconciled quietly, and nothing in the findings rests on it.

The analytical work this submission draws on is published in full on the research page — including the national diesel reconciliation, the mine decarbonisation funding map, and the facility exposure work described on the platform page.

Record format

What each entry will contain

A submission is only useful to a reader if they can trace it back to evidence. Every entry on this page carries the same seven fields, and any field that cannot be completed honestly is shown as unresolved rather than omitted.

Entry structure The fields every entry carries — see the record above for a completed example

InstitutionThe body running the consultation, named exactly as it names itself.

ConsultationThe formal title of the process, and the date the submission was lodged.

Question examinedThe specific question from the consultation paper that the submission addresses — not the whole paper.

Evidence usedWhich datasets, registers and reconstructions the argument rests on, and their evidence grades.

Key findingsWhat the evidence supports, stated at the strength it supports and no further.

Submission linkA direct link to the published document on the institution’s own site wherever one exists.

Related workThe research notes and underlying intelligence the submission draws on, so the chain is traceable.

Discipline carried over

The same evidence rules apply here as everywhere else on this site. A figure in a submission carries the grade it was established at — filed, licensed, disclosed or derived — and anything the public record cannot settle is named as unresolved rather than estimated into place. The evidence ladder is set out in full on the platform page.

Scope

Which consultations are in scope

Not every consultation is one this evidence base can usefully answer. The test is narrow and deliberately so: the process must be asking a question that facility, energy, emissions, project or spatial evidence can actually speak to, and the answer must be one the public record can support.

In scope

Questions this evidence base can answer

Which facilities or sectors are exposed to a proposed rule change, and by how much
Whether a stated national or sectoral quantity reconciles bottom-up
Where a proposed mechanism would and would not reach in practice
What the public record can and cannot establish about an industrial population

Out of scope

Questions better answered by someone else

Legal interpretation of instruments or drafting
Positions advocating a commercial outcome for a client
Matters requiring confidential operator data to answer honestly
Anything where the honest answer is that the evidence is not there

Bodies whose processes are monitored

Australian energy, emissions and industrial policy consultation is run by a small number of bodies. Their public processes are monitored for questions this evidence base can answer.

CCA

Climate Change Authority

DCCEEW

Department of Climate Change, Energy, the Environment and Water

AEMO

Australian Energy Market Operator

AER

Australian Energy Regulator

AEMC

Australian Energy Market Commission

No relationship implied

These bodies are named because they run open public consultation processes, and for no other reason. Heliovulcan has no formal relationship with, appointment from, accreditation by, or endorsement from any of them, and holds no regulatory or advisory role. Responding to an open consultation is something any member of the public may do, and nothing on this page should be read as more than that.

Why keep this record

A submission you cannot check is an opinion.

Consultation responses are usually published as PDFs and then forgotten. Keeping them here alongside the evidence they were built from means the reasoning stays inspectable — and means a later reader can see whether the argument held up.

Get in touch

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If you are preparing a submission and need facility-level, energy or emissions evidence to support it — or want to know whether a claim can be established from the public record at all — that is a question worth a short exchange.

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Heliovulcan does not provide legal advice, regulatory representation or lobbying services. Submissions made to public consultations are independent analytical contributions on its own behalf, not on behalf of any client.