Submission · Climate Change Authority · August 2026

Public registers cannot show whether onsite abatement is practical or cost-effective

A project at one facility shows that a technology may be worth investigating. It does not show that the same technology will be practical or cost-effective across the subsector. The registers show where abatement projects are located. They do not show who controls the asset or what the abatement costs.

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InstitutionClimate Change Authority

Consultation2026 Annual Progress Advice, Part 3 — the Authority's advice on the Safeguard Mechanism

StatusLodged 9 August 2026 · response ID sbm3e7c25df367242f431d34

ScopeQuestion 10; public-register evidence also provided against Question 9

36onsite abatement projects matched to 25 Safeguard facilities, carrying 5,161,903 ACCUs

6registered after reformed baselines commenced on 1 July 2023 — all coal mine waste gas electricity generation, four within four days in March 2025

46 of 115covered mining facilities report an Electricity generation production variable; 69 do not

The question

Question 10 of the 2026 Annual Progress Advice consultation: 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.

Key findings

The registered projects use one technology and were registered within a short period.
Six projects were registered after the reformed baselines commenced. All are coal mine waste gas electricity generation; four were registered within four days of each other in March 2025.
A project at one site does not show that the measure is cost-effective across a subsector.
It shows only that the technology may be worth investigating. Whether the same measure is available to the next facility depends on who controls the plant and what it costs there.
Public registers do not show who controls the relevant equipment or how much the next tonne of abatement would cost.
The submission therefore recommends assessing the facility first and the subsector second, rather than setting a limit only by industry code.

Recommendation

Two-tier assessmentBefore tightening the limits on ACCU use, assess whether each facility controls the asset that would deliver the abatement, and whether a practical option is available at a reasonable cost. Use subsector evidence only after that facility-level test. Facilities or asset owners will need to provide both pieces of information.

Open questions

Our count is 24 facilities surrendering ACCUs at or above 30% of baseline; the Authority and the Department report 23. The difference may reflect how credits treated as surrendered under the rules are counted. It does not affect the conclusions.

Sources

Evidence used

CER Safeguard facility reported emissions, FY2024–25 and FY2023–24 (regulatory filing). CER ACCU Scheme Project Register, 31 May 2026 (regulatory filing). CER emissions-intensity determination data, 15 May 2026 (regulatory filing). Project-to-facility matching using two-stage name and corporate-group rules with project-location checking (calculated).

All shares use a denominator of 208 covered facilities and 132,797,928 t CO₂-e, which reconciles to the published 132.8 Mt; facilities disclosed under s 58B as eligible but not covered for the year are excluded.

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