The three review documents
Three review processes address related parts of the scheme, and each hands work to the next.
The Carbon Leakage Review, led by Frank Jotzo and published in February, closed with a recommendation to introduce a border carbon adjustment for cement and clinker first, to consider lime, hydrogen and ammonia, steel and iron, and glass later, to refuse export rebates outright, and — the part that matters here — to remove concessional trade-exposed baselines for any commodity once a border adjustment covers it. Its recommendations were handed to the Safeguard review.
The Climate Change Authority was given a deliberately narrow brief: the post-2030 baseline decline rate, and the extent to which the reforms are actually driving abatement at the facilities themselves. Its preliminary arithmetic puts a decline rate of about 4.5 per cent a year against the bottom of Australia’s 2035 target range and about 7 per cent against the top — against an indicative 3.285 per cent currently written into the rules. It says explicitly that the coverage threshold and international units are outside its scope.
The department’s consultation paper is the wide one. It carries the decline rate, credit restrictions, trade-exposed concessions, the border adjustment, banking and borrowing, coal baselines, road-versus-rail coverage, and the coverage threshold. It opens by stating that the review “is not intended to make fundamental reforms” and that changes will generally take effect from 1 July 2030.
Within that, the coverage threshold gets a short section and a clean table: drop from 100,000 tonnes to 75,000 and 48 more facilities come in, carrying 4.1 Mt of newly covered emissions; drop to 50,000 and it is 108 facilities and 7.8 Mt. The biggest increases, the paper notes, are in metal ore mining and oil and gas extraction.
Method, reconciliation and limitations
How we rebuilt the baseline calculation and checked it
No published table contains this analysis, so we rebuilt it. We reconstructed the Safeguard baseline calculation from the rule text and the published register. We rescaled each facility’s baseline by the legislated emissions reduction contribution, from 0.902 to 0.657, then tested the result against the statutory minimum at four candidate thresholds. Floored means raised to that statutory minimum.
We identify covered facilities from the published table’s own note that a facility is an eligible facility under section 58B, not from its emissions. The FY2024–25 table carries 228 rows; 19 are eligible facilities that have dropped below the coverage threshold and remain listed. The remaining 209 rows are the Regulator’s 208 covered facilities (Telfer Gold Mine is on two rows after a mid-year change of operator) with 132,797,928 tonnes of covered emissions, which reconciles exactly with the Regulator’s published totals. One covered row has no production variable and therefore no baseline; it cannot sit on the floor and drops out of the floor counts. Every floor figure in this article is on that basis.
We validate the reconstruction by reproducing figures the department published from its own data. Offset credits surrendered come out at 10,831,682 against the paper’s 10.8 million; scheme credits at 2,582,112 against 2.6 million; coal mining at 68 facilities and 31.8 Mt against the paper’s “around a third of covered facilities” and 31.7 Mt. Facilities surrendering credits above 30 per cent of baseline come out at 24 against the paper’s 23, and the count is 24 whether or not deemed surrenders are included; it is the one number we do not match exactly, and we have not established the cause.
Correction, 10 August 2026. As first published, this article counted the floor cohort over all 227 rows of the published table rather than the 208 covered facilities, which put 19 facilities that had already left the scheme inside the cohort. The FY2029–30 figures were 64 facilities and 1.51 Mt; they are 45 and 0.99 Mt. The tightening a 75,000-tonne threshold would deliver was 1.4 Mt; it is 0.92 Mt. The sentence describing floor-bound facilities as facing no declining constraint was wrong in the other direction, and has been replaced: a covered facility on the floor has no headroom at all. The mechanism, the exhibits’ construction and the offset-credit figures are unchanged. Correction, 16 September 2026: the median covered emissions of the 24 covered facilities on the floor was stated as 127,780 t; the median of the 24 published values is 127,011 t (the two middle values are 126,242 and 127,780). The 24-versus-23 count of facilities surrendering credits above 30 per cent of baseline had been attributed to the treatment of deemed surrenders; the count is 24 on either basis, so that explanation is withdrawn and the cause is open.
The ownership evidence is a separate build and a slower one. Station ownership, storage and contract expiry exist in no national register, so each is either established from a named public source or recorded as unchecked. Forty-four of the 88 gold sites are verified; 22 are explicitly not yet checked and are excluded from the percentages rather than assumed. A blank storage field means no disclosure was found, never that no battery exists — behind-the-meter storage has no register in Australia, and reading a blank as a zero has put a site with nine megawatts of installed battery at the top of a target list before now.
Section 56(4) in the register
| Provision | Effect | How the model applies it |
|---|---|---|
| s 10(1) | A compliance baseline calculated below 100,000 t is set at 100,000 t. | Applied after the emissions reduction contribution, at each candidate threshold. |
| s 11 | The baseline declines each year by the legislated emissions reduction contribution. | Each published baseline is rescaled from 0.902 to 0.657. |
| s 56(4) | Credits are issued against the baseline that would apply without s 10(1). | Used to identify facilities credited below their floored baseline. |
| s 58B | A facility below the threshold may remain listed as an eligible facility without an obligation. | The 19 such rows are excluded from the floor counts. |
A covered facility cannot sit between the two baselines, because emissions in that band are below the coverage threshold. A facility reaches that band by leaving the scheme, not by abating within it. Nineteen facilities in the FY2024–25 table are in that position: still listed, still showing a baseline of 100,000 tonnes, emitting below it, and carrying no obligation because they are no longer designated large facilities. One was issued 1,138 credits against emissions of 81,563 tonnes, measured against an unfloored baseline of 82,701 rather than the 100,000 the table prints. That is section 56(4) applied as drafted, and it is the one place in the register where the effect is visible.
Those nineteen are the whole of the group emitting less than its floored baseline; one reported under 300 tonnes against a 100,000-tonne allowance. They sit outside the scheme, so a lower minimum baseline would not reach them. The 45 covered facilities counted in the main article are the ones it would.
Sector composition of the floor cohort
The three movers are labelled, in percentage points. Shares are of the 208 covered facilities and of the 45 in the cohort; facilities that have ceased to be covered are excluded from both. The five sectors shown cover 38 of the 45 — the remaining seven sit one apiece in seven further sectors. Road freight moves because all three of its covered facilities land on the floor.
Show the numbers
| Sector | Of the covered register | Of the floor cohort | Change, points |
|---|---|---|---|
| Metal ore mining | 24.0% (50) | 37.8% (17) | +13.7 |
| Coal mining | 31.7% (66) | 22.2% (10) | −9.5 |
| Oil and gas extraction | 13.0% (27) | 11.1% (5) | −1.9 |
| Road freight transport | 1.4% (3) | 6.7% (3) | +5.2 |
| Non-ferrous metal manufacturing | 6.2% (13) | 6.7% (3) | +0.5 |
| Seven further sectors, one each | — | 15.6% (7) | — |
Source: Clean Energy Regulator published Safeguard baselines and emissions, FY2024–25, classified by the register’s own industry field. Analysis by Heliovulcan. Percentages are of the 208 covered facilities and of the 45 projected onto the floor in FY2029–30.
Where a lower floor would bite
This is why the relationship between the threshold and its effect is a cliff rather than a slope. Twenty-four covered facilities are filed at exactly 100,000 tonnes today, so they project to exactly the same number in 2029–30 — and they sit just under 75,000. A 75,000-tonne floor leaves almost all of them floored; a 50,000-tonne floor releases every one. No covered facility projects below 50,000 tonnes. The 116 facilities above 150,000 tonnes are off the right of the chart and are nowhere near the floor. The distribution above 100,000 tonnes is unchanged by the coverage filter — every facility it removes sits below the floor.
Show the numbers
| Projected 2029–30 baseline, before the floor | Facilities |
|---|---|
| Below 65,000 t | 0 |
| 65,000–70,000 t | 2 |
| 70,000–75,000 t | 23 |
| 75,000–100,000 t | 20 |
| 100,000–150,000 t | 47 |
| 150,000 t and above | 116 |
| Total | 208 |
Source: Clean Energy Regulator published Safeguard baselines and emissions, FY2024–25, covered facilities only, each facility’s baseline rescaled from its filed contribution factor to 0.657. Analysis by Heliovulcan. For facilities already at the statutory minimum the filed baseline is itself the floored number, so their position in this distribution is an upper bound — the true values sit further left.
Credit surrender by sector
Eight sectors are shown, not all of them; the tail below 150,000 credits is omitted and the totals below are of everything. Coal alone surrenders more than every non-resource sector on the register put together.
| Sector | Offset credits surrendered | Share of all surrender | Scheme credits surrendered |
|---|---|---|---|
| Coal mining | 5,050,594 | 47.9% | 1,351,561 |
| Oil and gas extraction | 1,941,035 | 18.4% | 646,868 |
| Metal ore mining | 1,562,804 | 14.8% | 299,698 |
| — three sectors combined | 8,554,433 | 81.1% | 2,298,127 |
| Non-ferrous metal manufacturing | 681,168 | 6.5% | 212,070 |
| Rail freight transport | 328,427 | 3.1% | 13,513 |
| Air and space transport | 218,307 | 2.1% | 0 |
| Ferrous metal manufacturing | 204,177 | 1.9% | 0 |
| All facilities | 10,549,152 | 100% | 2,582,112 |
Source: Clean Energy Regulator published Safeguard baselines and emissions, FY2024–25. Analysis by Heliovulcan. Shares are of offset credits surrendered; the largest sectors are shown, not every sector. Adding deemed surrenders brings the offset total to 10,831,682 — reconciling to the 10.8 million stated in the consultation paper, and putting the three-sector share at 79.0 per cent on that wider basis. The scheme-credit total reconciles to the paper’s 2.6 million.
The mine population outside the register
Four hundred and thirty-three Australian mines sit outside the Safeguard register today. Two hundred and forty-five of them are operating. Of those, 98 are off-grid — 49 gold and silver operations, 19 iron ore, the balance spread across mineral sands, base metals and bauxite. A further 54 sit on a weak connection.
Whether any individual one crosses a 75,000 or 50,000-tonne threshold depends on emissions we cannot compute from outside, and this analysis does not claim to identify them. What it does establish is the character of the population: a lower threshold does not mainly admit factories. It admits remote sites that make their own electricity, where the abatement lever is a physical power station with a fuel bill and a contract, and where — on the gold evidence above — the odds are that the station belongs to a third party.
A threshold change converts a discretionary cost decision at an off-grid power station into a regulated one. It does not change the physics or the capital cost. It changes who has to have the conversation, and when.
Station ownership at mine power stations
This evidence supports the ownership point made in the main article. Heliovulcan built it site by site; none of the three facts below appears in any national register.
At an off-grid mine, onsite abatement means changing what the power station burns or adding solar and storage in front of it. That is the only lever of any scale, and at most sites the mine does not hold it.
We have gone through the Australian gold sector site by site — 88 operations carrying a Safeguard or pollutant-inventory identity, with station ownership, storage and contract expiry established from contractor project registers, state generation licences and company filings.
Station ownership was examined for 39 gold operations with onsite generation. Thirty-five stations were contractor-owned, typically by one of about seven fund-owned independent power producers under a build-own-operate contract with a term of a decade or more; two were miner-owned and two remained unresolved.
- Storage sits inside the contractor’s asset. Fifteen of the operations disclosed battery storage; in each identified case, the battery was installed within the power provider’s asset and contract structure.
- The obligation and the asset sit with different parties. The mine reports the generation emissions and holds the baseline. The contractor may own the plant, choose the fuel and receive the fuel saving.
- Contract expiry is rarely public. A contract expiry date was identified in public sources for nine of the 88 operations. No public expiry date was found for the remainder.
A higher credit price affects the mine, shown in the left box, because that is where the obligation sits. The investment decision it is meant to trigger, whether to change the fuel or add solar or storage, is made in the right box, by a counterparty whose contract does not price carbon and typically has years left to run.
Source: Heliovulcan site-by-site build over 88 Australian gold operations carrying a Safeguard or pollutant-inventory identity, from contractor project registers, state generation licences and company filings. None of the three facts — station ownership, storage, contract expiry — appears in any national register. Percentages exclude 22 sites recorded as not yet checked; a blank storage field means no disclosure was found, never that no battery exists.
This creates a split incentive. The mine holds the Safeguard obligation, while the contractor may own the generating asset and control investment in fuel switching, solar or storage. A higher offset price raises the cost on the miner and leaves the investment decision where it already sits, with a counterparty whose contract does not price carbon and typically has years left to run. Before strengthening the price signal, the review should consider whether the party carrying the obligation also controls the relevant abatement asset; for this class of facility that is knowable only site by site.
The same caution applies, for a different reason, to coal: tightening coal baselines creates a compliance cost at mines that are all grid-connected, and no generation-side market. The reasoning is in the appendix →
The department projects the largest increase in facility numbers under a lower threshold in metal ore mining and oil and gas extraction. Heliovulcan’s mine screen indicates that many potentially relevant mining facilities are remote, off-grid or weak-grid operations with onsite power systems; the population figures are in the appendix. The gold-sector sample indicates that third-party power-station ownership may be common, but ownership would need to be verified facility by facility and across other commodities. For project developers and policymakers, the relevant unit is therefore not only the covered facility but also the ownership and contract structure of its power supply.
Coal baselines and the generation-side market
The same caution applies, for a different reason, to coal. Both papers raise ending the concession that lets existing coal mines keep half of their baseline on facility-specific intensity past 2030 while everyone else converges to the industry average. Doing so would raise the liability on gassy mines — correctly, on the scheme’s own logic. But of 102 Australian coal mines in our screen, none is off-grid, and the emissions at issue are ventilation air methane and haul fleet diesel. Tightening coal baselines creates a compliance cost. It does not create a generation-side market, and any business case built on the assumption that it does will be wrong by an order of magnitude.