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Chapter 4: The emissions reduction fund in the broader context

This chapter examines interactions between the ERF and other policies. It considers whether the ERF should focus on abatement or take account of the multiple environmental benefits of projects, and when it would be appropriate for ERF projects to access multiple sources of funding. It also comments on the potential contribution of the ERF to meeting Australia’s 2020 target and longer-term goals.

4.1. Interactions between the emissions reduction fund and other policies

The ERF operates in concert with a range of other government policies implemented, including the RET, energy efficiency schemes, land management and biodiversity programs and various regulations. If these other policies are sufficient to drive a project (and the associated emissions reductions), supporting them through the ERF would increase the cost to the community without necessarily providing any additional benefits. Managing these interactions is important to achieve multiple policy objectives in an efficient way.

Up to now, the CFI has managed policy interactions through the ‘additionality test’ and the ‘negative list’. The existence of simultaneous policies has not triggered a general exclusion from the CFI, although the impact of other policies has been considered in developing methods and setting baselines (Box 2).

Box 2: ERF Interaction with other schemes and regulation–the case of landfill waste

Most landfill operators are required to treat methane emissions from landfill waste in a particular way under state regulations. The current method for the capture and combustion of landfill gas must account for the emissions reductions achieved by the landfill under state regulation, and credits only the additional amount. The reduction in credits helps ensure that state regulation and the ERF operate relatively efficiently.

Some landfill operators use the captured methane to produce electricity and sell it into the grid. Many of these projects receive support under the RET. These projects displace electricity generated from other sources (particularly fossil fuels), leading to emissions reductions. The ERF does not provide credits for these emissions reductions, however, as they are already supported by the RET. In this case, an efficient outcome is achieved by separately identifying and rewarding the two distinct streams of abatement.

Under the recent amendments, the ERF ‘additionality test’ has been augmented by two new elements—the project must not have started prior to registration, and must be unlikely to be carried out under another government program if not approved under the ERF. The latter helps ensure the government avoids paying for the same emissions reductions twice.
The following sections explore three dimensions of policy interactions:

  • whether the ERF should focus on lowest cost abatement
  • when multiple sources of funding might be appropriate
  • the circumstances in which ERF is the right tool to reduce emissions.

4.1.1. Should the emissions reduction fund focus on lowest cost abatement?

The government’s stated overriding objective is that the ERF will reduce emissions at the lowest cost over the period to 2020. At the reverse auction stage, and once bidders have passed pre-qualification tests, the only consideration of bids is with respect to price.

This approach has distinct advantages. By focusing on price only, the ERF is likely to secure a greater volume of emissions reductions. This in turn improves the scheme’s contribution to meeting Australia’s emissions reduction goals. A singular focus also simplifies program administration, avoiding the need for different areas of expertise and complex rules to assess and weigh up different benefits (Australian Industry Greenhouse Network Issues Paper sub. 13, p. 3). Considering outcomes in a more holistic way, however, also could have advantages. All things being equal, it is desirable to support projects that deliver more benefits for the same cost. The ERF currently has no way of assessing which projects do so. Focusing on the cheapest abatement may also miss value for money (albeit more expensive, in $/tCO2-e terms) projects delivering a broader range of benefits. By way of example, some projects, particularly in the land sector, could deliver benefits such as biodiversity protection, reduced soil erosion and improved water quality, which contribute to the CFI Act objective of protecting Australia’s natural environment and improving resilience to climate change (Fares Rural sub. 3, p. 2, Kimberley Land Council sub. 12, pp. 1-2, and National Native Title Council sub. 14, p. 1).

On balance, however, the Authority considers the focus on lowest cost abatement appropriate for two main reasons. First, paying for other benefits through the ERF would reduce its capacity to achieve abatement, and in turn, reduce the prospect of meeting emissions reduction targets. Second, many of the broader benefits related to ERF projects are better assessed at a local or state level, or pursued through separate national policies, such as the National Landcare Program, that specifically target these types of benefits. Where there are barriers to ERF participation, the Australian government can establish enabling policies, such as the Extension and Outreach program that builds capacity for farmers and land managers.

Rather than dilute the ERF’s primary focus, the challenge for the ERF should be to interact efficiently with other programs to achieve the best overall outcomes.

4.1.2. When are multiple sources of funding appropriate?

If the ERF concentrates on lowest cost abatement, it needs to interact appropriately with other policies focused on other benefits. This could be facilitated by allowing projects to receive additional funding directed to those other benefits in appropriate circumstances.

In assessing when multiple sources of funding are appropriate, it is helpful to consider whether the additional government funding is directed towards the same outcome as the ERF. One of the main objectives of state energy efficiency programs is to reduce emissions and if projects supported under these programs are simultaneously allowed to access the ERF, they would be paid twice for essentially the same outcome. This is obviously undesirable.

The assessment would prove more difficult where other programs have multiple objectives:

  • a scheme that supports forestry projects for biodiversity benefits, for example, may also have a carbon sequestration objective. In this case—particularly if the biodiversity program provides sufficient support for the forestry projects to proceed—it would be inappropriate to allow ERF support as well.
  • a landfill waste project could receive funding from the ERF and the RET. While both programs share the objective of reducing emissions, in this case ERF support could be appropriate as it supports a distinct stream of abatement (Box 2).

In contrast, some projects achieve multiple outcomes because they are able to secure support from multiple programs. The Kimberley Land Council submission highlighted the importance of co-funding to the success of the North Kimberly Fire Abatement Project:

This project has already successfully abated over 200,000 tonnes of carbon dioxide equivalent, while providing jobs, training, and supporting cultural aspirations for native title holders. The success of the North Kimberley Fire Abatement Project has been the result of a number of factors, including the strong relationships between project partners, investment in governance and business planning processes and prioritisation of training and capacity building for Traditional Owners. This success has been made possible through access to support from multiple channels, including Working on Country and [Indigenous Protected Area] programs, the Biodiversity Fund and the sale of carbon credits. (sub. 12, p. 2)

These examples highlight the need to test whether the project would have proceeded on the basis of support from the other program. One of the new elements of the ERF additionality test—that the ERF will not support activities that are likely to go ahead under another government program—is likely to prove helpful. The draft ERF rules elaborate on this test, listing specific government programs such as the 20 Million Trees Programme and various state energy efficiency schemes (DOE 2014b, s. 20). Projects that receive support from these schemes would be ineligible for ERF support. This should help enhance the cost-effectiveness of the ERF.

Further, by assessing additionality at the program level (rather than on a project-by-project basis), the new approach should reduce transaction costs and improve predictability. Consultation with the relevant program administrator(s) will be important to identify programs that provide sufficient support for their participating projects to proceed. While it is possible that allowing ERF support to some individual projects may enhance abatement outcomes, this program-listing approach should provide a reasonable guarantee of additionality with relatively streamlined administration. The list of excluded programs will need to be reviewed and updated periodically to avoid creating perverse outcomes.

Finally, where other policies share the ERF’s objective of reducing emissions, the government could consider establishing a mutual recognition arrangement. This would allow certificates from one scheme to be sold into the other (and then cancelled). This would avoid double-paying for reductions, but would also give project proponents the flexibility to access both schemes. Linking schemes in this way would require an assessment of the eligibility, measurement, reporting and verification arrangements, as well as the administration and objectives of the respective schemes, to ensure they are compatible. While this assessment would take some time and resources, it could expand options for project developers, and (by broadening and deepening the set of participants) may also make the ERF (and the linked schemes) more efficient.

4.1.3. Choosing between the emissions reduction fund and regulatory approaches

Determining when the ERF is preferred to regulatory approaches, such as minimum standards or disclosure obligations, is difficult. The choice principally comes down to when incentives are more effective at unlocking emissions reduction opportunities. If the benefits of lower emission activity clearly outweigh the costs, the costs are fairly evenly spread across the sector, and the government has sufficient information to craft efficient rules, regulation may be more appropriate. If the costs and benefits vary greatly across the sector, or the government has little information, ERF incentives may be more effective.Depending on the circumstances, the best approach may be incentives provided by the ERF, regulation or a combination.

To illustrate, the Minimum Energy Performance Standards (MEPS) specify standards that appliances must meet before they can be offered for sale. The government has based the standards on solid information about the performance levels of appliances in a way that does not impose a big burden on any particular producers or purchasers. In this case regulation is suitable (see Commonwealth of Australia 2014c, p. 40).1

On the other hand, the costs and associated benefits of many forestry and agriculture opportunities vary greatly from location to location and the government does not possess good information about them. Applying a regulatory standard for these activities would impose greater costs on some landholders than others, and the government would have difficulty in setting appropriate standards. Applying incentives through the ERF still requires a level of knowledge to set methods and measure projects; in this case, however, landholders can decide for themselves whether to (voluntarily) participate. Incentives in this case are likely to be more cost-effective in driving abatement than regulation.

The example of landfill waste is illustrative of a case where the choice is not clear cut. To date, many larger landfills have participated in the CFI (and are expected to participate in the ERF). This might indicate that the costs of implementing methane capture and flaring equipment are relatively low and even and, combined with the government’s increased knowledge about the landfill sector, may be suited to a stronger regulatory approach.

The ERF may be more effective in combination with other policies. The Commercial Building Disclosure Program, for example, requires owners to disclose the energy use of commercial buildings. This makes valuable information accessible to building users and to the government, and in turn makes it easier to identify when ERF support is appropriate, and might enhance participation in building energy efficiency projects.

There is a risk that ERF incentives may discourage other levels—and areas—of government from pursuing other policies. If the national government funds an activity, the state government may be reluctant to regulate it, as it secures the desired outcome without any effort. That said, policies are typically implemented for a variety of reasons, and the ERF may not be a major consideration. Good coordination within and across government would help minimise this risk.

Regular assessments would help to maintain a reasonable balance between incentives through the ERF and regulation. The pattern of costs and benefits of an opportunity might change, and the information held by the government might improve over time. While regular reviews of methods by the ERAC will help identify whether activities are still additional, they will not answer the broader question of whether the ERF is and remains the right tool for the job. On-going independent periodic reviews could determine whether an ERF method is still the best approach for unlocking the opportunity, or whether another approach might achieve abatement at lower cost. Such reviews should consider a broad range of policy instruments.

Government policy is that regulation should not be adopted as the default position; rather the policy option offering the greatest net benefit should be pursued (Commonwealth of Australia 2014).


R 2. The ongoing appropriateness of the ERF for achieving emissions reductions in particular situations should be monitored and subject to independent and periodic review.

4.2. The emissions reduction fund in the context of the 5 per cent target

The ERF is the centrepiece of the government’s Direct Action Plan to reduce Australia’s emissions, and the primary measure to achieve the minimum 5 per cent target by 2020. In assessing the ERF, it is therefore appropriate to consider how much abatement it is likely to deliver in its current form—including its current budget of $2.55 billion—and taking account of the government’s intention that the safeguard mechanism will prevent emissions growing beyond business-as-usual levels.

As noted at the outset, these are still early days for the ERF. The government has not published any modelling of the likely emissions reductions under the ERF. It plans to purchase emissions reductions at the lowest cost through reverse auctions or other purchasing processes. ‘Official’ estimates of the likely price and quantity of emissions reductions could influence bidding behaviour and increase the price of emissions reductions, so it is understandable the government is reluctant to release such data (Commonwealth of Australia 2014b). The Authority has, however, considered publicly available material on Australia’s abatement opportunities and the potential impact of the ERF.

4.2.1. Australia’s emissions reduction challenge and opportunities

Australia’s abatement challenge to 2020

While Australia has made an international commitment to unconditionally reduce its emissions by 5 per cent compared with 2000 levels by 2020, and by up to 15 or 25 per cent if ambitious international action is agreed (Commonwealth of Australia 2013, DOE 2014a), the government has recently focused only on meeting the minimum 5 per cent target (DOE 2014c, p. 1). It has also indicated it plans to use Australia’s carryover of an estimated 131 Mt CO2-e under the Kyoto Protocol toward meeting this target (Commonwealth of Australia 2014a, p. 15).

Official estimates of the abatement task to meet a 5 per cent target have been declining in recent years. In 2012, official projections suggested the task was a cumulative 754 Mt CO2-e over the period 2013–20 (DCCEE 2012). In 2013, the Authority estimated the task to be 593 Mt CO2-e (CCA 2014a, pp. 132-133). Taking account of the carryover under the Kyoto Protocol, and the emissions reductions achieved by two years of the fixed carbon price, the current government estimate suggests 421 Mt CO2-e of cumulative abatement over the period 2015–20 (including 131 Mt CO2-e in 2020) would be required to meet the 5 per cent target (Figure 16). This estimate assumes existing policies (including energy efficiency schemes, the RET and some existing projects under the CFI) would remain in place.

Figure 16: Australia’s abatement challenge to 2020

Source: Commonwealth of Australia 2014a, p. 7.

Several factors, and particularly falling electricity demand projections, suggest that the next official estimate of the abatement task to 2020 will be lower again. Frontier Economics estimates the cumulative abatement task to 2020 is closer to 225–279 Mt CO2-e, assuming there is no change to the RET (Frontier Economics 2014). On the other hand, any further relaxation of land clearing laws, and/or any changes to the RET would add to the abatement task.

As discussed in Chapter 2, as at 3 December 2014, 10.6 million CFI credits had been issued. The highest contributions have come from landfill gas flaring and avoided land clearing projects. This abatement has been driven by a carbon price of $23 in 2012–13 and $24.15 in 2013–14. This indicates that activity under the ERF would need to be scaled up, substantially relative to the CFI performance, to meet the 2020 target.

Australia’s emissions reduction opportunities to 2020

The Authority has conducted a detailed assessment of Australia’s emissions reduction opportunities (CCA 2014a). This highlighted substantial opportunities across the Australian economy in the electricity, energy efficiency, transport and land sectors. These opportunities vary considerably in scale, reflecting each sector’s proportion of Australia’s total emissions and its responsiveness to incentives (Table 4).

Table 4: Australia’s emissions reduction opportunities




Electricity offers the largest opportunity for emissions reductions by lowering the emissions intensity of generation, including through the continued deployment of wind and solar technologies, energy efficiency improvements, and retrofitting of existing fossil fuel-fired plant and equipment.

Direct combustion, fugitives and agriculture (export driven sectors)

Sectors that are primarily driven by export demand—direct combustion, fugitives and agriculture—present the greatest challenge. Emissions growth is projected for these even with a high carbon price.
Direct combustion emissions could be reduced through improvements in emissions intensity—such as increased gas turbine and machinery efficiency—and a switch to alternative lower emissions energy sources, such as biofuels.
Fugitive emissions could be reduced through a shift away from higher to lower emissions mines, and the deployment of additional pre- and post-mine drainage, where gas could be flared or used to generate electricity.
Agriculture emissions could be reduced by improved manure management, animal feed supplementation, feedlot finishing and pasture improvements. Most technologies and practices for reducing livestock emissions are still in development and not ready for commercial use.


Transport emissions can be reduced in three ways:
increasing vehicle efficiency
reducing the emissions intensity of fuels
improving demand management through mode shift from road freight to rail or shipping, and from private vehicles to public transport and physical activity (cycling and walking).

Industrial processes

Industrial processes Industrial process emissions are projected to be highly responsive to an incentive. Emissions could be significantly reduced through the use of nitrous oxide conversion catalysts for nitric acid production and the destruction and replacement of synthetic greenhouse gases.


Greater reforestation and afforestation activities, avoided deforestation and improved land management could deliver emissions reductions from the land sector.


Waste emissions reductions are still available through the expansion of alternative waste treatment facilities to reduce waste volumes being sent to landfill.

Source: Climate Change Authority, based on Targets and Progress Review (CCA 2014a, Chapter 11)
Similar results are evident in other studies. ClimateWorks (2010) conducted a comprehensive analysis identifying the 54 lowest-cost opportunities across the economy; ClimateWorks estimated that adoption of all these opportunities would be sufficient to achieve a 25 per cent reduction in Australia's emissions below 2000 levels by 2020. The opportunities were identified across six key sectors of the economy—power, forestry, industry, buildings, agriculture and transport (Figure 18).

4.2.2. Potential scale and costs of emissions reductions to 2020

A number of studies have examined the scale of available emissions reduction opportunities, and their potential cost.

The Authority’s Targets and Progress Review showed how much abatement a broadly applied, mandatory carbon price in force from 2013 might deliver (CCA 2014a, pp. 139-140). It examined three different carbon price levels. The low price scenario, with a carbon price rising to around $6/tCO2-e in 2020, was projected to drive 162 Mt CO2-e of domestic abatement over the period 2015–20. A high price, growing to $65/tCO2-e in 2020, was projected to drive sufficient domestic emissions reductions to meet the 5 per cent target (CCA 2014a, pp. 140, 151; Figure 17).

The ERF scheme is likely to drive fewer emissions reductions at any given price. This is because the ERF is voluntary, can only deliver abatement where and when the necessary methods are in place and projects are approved, and involves transaction costs in registering and verifying all abatement. Further, it will only support emissions reductions at the project and facility level, rather than change incentives at the sector- and economy-wide level. Many of the emissions reductions in the Targets and Progress Review scenarios are not suited to project-based crediting—for example, changing the generation mix in the electricity sector toward low-emission generators, or making less-gassy coal mines more attractive to develop than more-gassy mines. Only a subset—such as improving the energy efficiency of an industrial facility, or capturing and flaring methane from a coal mine—will be well-suited to the ERF. For these reasons, the likely abatement under the ERF could be expected to be less than the modelling-generated volumes shown in Figure 17.

Figure 17: Potential emissions reductions at different carbon prices, 2015–20

Note: The modelling underpinning this figure applied a carbon price from 2013. The potential emissions reductions arising under different carbon price incentives are calculated from 2015 to align with the current government estimate of 421 Mt CO2-e over the period 2015–20. All scenarios start from a carbon price of $5.49, with the low price rising to $6/tCO2-e in 2020, the medium price $27/tCO2-e and the high price $65/tCO2-e.
Source: Climate Change Authority, based on modelling undertaken as part of Targets and Progress Review (CCA 2014a)
The ClimateWorks analysis tells a broadly consistent story. Its results are presented in a marginal abatement cost curve (Figure 18). The width of each box on the curve represents the potential scale of the opportunity in 2020 compared to a business-as-usual scenario. The height of each box represents the average cost for each tonne of abatement; this does not include policy-related transaction costs that would be needed to realise the opportunities. If abatement is purchased up the cost curve to meet the minimum 5 per cent target, ClimateWorks’ analysis suggests a marginal price of $25 per tonne would be required. This assumes that all of the energy efficiency and half of the land sector abatement would be purchased, and no abatement opportunities would be missed.

Figure 18: Climateworks investor cost curve, 2020

Note: The cost curve shows the cost (or return) to the investor for various opportunities across the economy, with opportunities stacked from the least expensive on the left to the most expensive on the right.
Source: ClimateWorks 2011, p. 3
In summary, these studies suggest low incentives are unlikely to deliver sufficient emissions reductions to meet a 5 per cent target. Other appropriate policy drivers will be required. Even if the abatement task was significantly smaller, a substantial incentive might still be required.

4.2.3. What can the emissions reduction fund achieve by 2020?

While the Authority modelling and ClimateWorks analysis point to possible emissions reduction opportunities, they do not attempt to estimate how many of these opportunities are likely to be captured by the ERF. Other studies have tried to address this question, in the absence it has to be said, of any practical experience with the ERF (no reverse auctions have been conducted, and methods for newly covered sectors are yet to be approved); the studies, therefore, involve many assumptions. That said, these published studies suggest that, based on the current funding provision, ERF purchasing alone will not achieve emissions reductions of the scale required to reach the minimum 5 per cent target.

RepuTex has been estimating possible ERF activity throughout 2014 and in its November 2014 update (released after the CFI amendment legislation had passed the Senate) it concluded (Figure 19):

[T]he ERF as currently funded will purchase between 40 and 130 million ACCUs cumulatively by 2020. This range is highly dependent on the price of abatement paid by the government, primarily influenced by the benchmark price set to cap abatement bids. (RepuTex 2014, p. 8)

Figure 19: Reputex erf credit supply forecast, 2013–20

Source: RepuTex 2014, p. 8
The RepuTex projections are based on assumptions about reverse auction rules, possible benchmark prices and expected early bidders but do not include the safeguard mechanism. They also project that existing CFI participants are likely to be advantaged at the beginning of the ERF before this trend is reversed as projects ramp up under new methods. By 2020, RepuTex projects approximately 80 per cent of all credits purchased will come from high-emitting companies (Figure 20).

Figure 20: Reputex estimates of share of credits bid into erf under existing and new methods, 2015–20

Source: RepuTex 2014, p. 9
In its July 2014 study, Bloomberg New Energy Finance forecast that the ERF may contract 51–178 Mt CO2-e of abatement in an efficient market, or as little as 23 Mt CO2-e if there is limited participation or the market is gamed (because of the auction design) (Bloomberg 2014a and 2014b). Bloomberg speculated that auction design will encourage participant bids to deviate from the cost of abatement, increasing the unit costs paid under the scheme.
The Climate Institute has calculated that the ERF and other policies could realise emissions reductions of around 180 Mt CO2-e in the period 2015–20 (The Climate Institute 2013a; based on modelling by SKM–MMA and Monash University Centre of Policy Studies). This forecast was made in August 2013, prior to the detailed development of the ERF. It assumed the ERF was implemented in accordance with the government’s election commitments (including a safeguard mechanism using historical baselines) and that the RET continued unchanged. At the time the Institute forecast an additional $4 billion of ERF funding to 2020 would be required to achieve the minimum 5 per cent target (The Climate Institute 2013b).
In short, these studies suggest that the ERF’s contribution to reducing emissions is likely to fall some way short of what is required to meet Australia’s minimum 2020 target.

Buying up the cost curve—limitations of the emissions reduction fund

Australia can achieve its emissions reduction goals at lowest cost to the community by undertaking the cheapest opportunities first and unlocking more expensive opportunities over time.

The ERF is likely to unlock some low-cost opportunities such as industrial energy efficiency, better waste management, industrial building retrofitting and waste coal mine gas capture (ClimateWorks 2013). Where sector-wide change or long-lived investment is required, however, the ERF is likely to be less effective. Activities like increasing the share of lower emissions electricity generation are more likely to benefit from a sector-wide policy, rather than project or facility-level incentives. Policy uncertainty and limited ERF contract periods may deter some long-lived projects such as reforestation and afforestation.

Even some of the cheapest opportunities may prove hard to unlock (ClimateWorks’ cost curve suggests transport fuel efficiency is the cheapest abatement opportunity in Australia; the Authority investigated options to improve vehicle efficiency and identified mandatory standards as the best approach (CCA 2014b, pp. 31-38)).

Some other factors that could reduce the ERF’s ability to purchase abatement efficiently up the cost curve include:

  • Additionality concerns will mean some low-cost abatement opportunities will be missed. Some genuinely additional commercial forestry and waste coal mine gas projects, for example, are likely to be excluded from the ERF because they are hard to distinguish from non-additional projects. At the same time, it is likely that some non-additional abatement, which would have occurred without ERF support, will be purchased, reducing the funds available to purchase genuine emissions reductions.
  • Some companies will choose not to participate because of the cost and complexity of the scheme. The ERF’s voluntary nature makes it less effective at picking up all abatement opportunities relative to a compulsory approach.
  • Uncertainty regarding prices and likely demand may affect participation. It may take a number of auctions before participants can form reasonable expectations for ERF contract prices. Prices for any purchasing outside the ERF auctions (for example, through make-good or safeguard provisions), and the extent of market demand beyond the government contract period, are also highly uncertain at this time.
  • CFI experience shows that it will take time for the ERF to achieve large-scale emissions reductions. Early emissions reductions have resulted from well-established technologies and activities, and pre-existing projects that transitioned into the scheme. Similarly, the Greenhouse Gas Abatement Program (a $400 million national program to purchase abatement) also experienced significant take-up problems, mainly due to a lack of competitive proposals and the termination of approved projects (ANAO 2010, p. 85). While the ERF has made significant improvements on earlier schemes, the inherent limitations of project-based baseline and credit schemes (discussed in Chapter 3) remain.

These limitations mean that the ERF will not pick up all the lowest-cost opportunities—only a subset of opportunities are likely to be realised. It is likely that the scheme will leave gaps along the cost curve where projects are excluded, opportunities are not taken up and methods do not exist. The scheme will also take some time to deliver actual emissions reductions.

Ultimately, scheme impacts will be determined by the budget allocation (see Grattan Institute 2014, p. 4), currently set at $2.55 billion, with possible further funding to be considered in future budgets. Based on the most recent official estimate, the abatement task to the 5 per cent target in 2020 is 421 Mt. For the ERF to meet the target with only its current allocation, and without other policies, it could only spend an average of $6/tCO2-e. While the abatement task appears to be shrinking, even if it halved to 210 Mt CO2-e the average price could only be $12/tCO2-e. These are very low prices. Existing state energy efficiency schemes in New South Wales and Victoria have paid an average of $14-35/tCO2-e (NSW Government 2014, p. 10, DSDBI 2014, p. 20) to capture some of the lowest cost opportunities available in the economy. To the extent that some of the tonnes purchased are non-additional (which is not an unrealistic assumption) and some of the abatement is delivered after 2020 (which is likely given that contract periods will extend beyond 2020), the number of purchased credits actually contributing to the 2020 target would be reduced.

More emissions reductions could be purchased if the government provided additional funding to the ERF in future budgets but this is not assured. The safeguard mechanism could drive additional reductions beyond those purchased by the government through the ERF but again there is no certainty on this front—the mechanism is still being designed, and will only apply to facilities with direct emissions over 100,000 tonnes a year (about 130 companies covering 52 per cent of national emissions; Commonwealth of Australia 2014a, p. 52).

The safeguard mechanism has the potential to complement ERF purchasing by driving emissions reductions below business-as-usual levels, but even if that potential is tapped, the existing RET and other policies (including the possible purchase of international credits) are likely to be necessary to achieve the minimum target. The Authority has previously recommended international emissions reduction units be used to help meet stronger 2020 targets (CCA, 2014a). International units could also play a role in closing any gap between domestic reductions achieved, and the minimum 5 per cent target.

4.3. The emissions reduction fund in the context of longer-term goals

The preceding discussion has focused on the role of the ERF in meeting Australia’s minimum 5 per cent target by 2020. In an earlier report the Authority expressed its view that not only was the minimum 5 per cent target inadequate, but that even with a somewhat stronger 2020 target Australia would need to pursue deeper cuts beyond 2020 if it were to play its part in combatting the dangers posed by climate change. This raises the question of the possible role of the ERF in this longer-term endeavour.

The government supports the global goal of limiting warming to less than two degrees, and will consider a longer-term target for Australia in 2015 (DFAT 2014). The Authority’s previously recommended set of targets for Australia comprised a minimum target of 15 per cent below 2000 levels by 2020 (rising to 19 per cent with the carryover from the Kyoto Protocol), a target range of 40–60 per cent below 2000 levels by 2030, and a national emissions budget of 10,100 Mt CO2-e for the period 2013–50. The Authority considered these goals to be consistent with Australia’s contribution to meeting the overall goal of keeping global warming below two degrees. Its recommendations were based on the latest climate science and the actions of other countries, and took account of the cost of meeting the targets (CCA 2014a, pp. 10-11).

Adopting stronger longer-term targets necessarily means the abatement task will become larger each year as the gap between business-as-usual emissions reductions and the target trajectory widens over time. As the cheapest opportunities are taken up, the cost of unlocking the next opportunities on the cost curve also increases on a per tonne CO2-e basis (possibly offset to some extent by advances in relevant technologies). This combination of greater emissions reductions and higher unit cost implies that funding for the ERF would need to increase steeply year after year, if it were to remain the central policy in reducing Australia’s emissions.

This exposes the limitations of government-funded models like the ERF in achieving longer-term targets. As the abatement task grows, the scale of the budget outlays required becomes unrealistic. On the basis of modelling for its Targets and Progress Review the Authority indicated that a marginal carbon price of $65/tCO2-e would be required in 2020 to meet a 5 per cent target through domestic abatement; if the projected 2020 abatement task of 131 Mt CO2-e was purchased at this price it would require spending of $8.5 billion in 2020 alone. In short, it is not feasible for governments to buy their way to decarbonisation.

As discussed in Chapter 3, project-by-project crediting against business-as-usual baselines has its inherent limitations, which have been demonstrated through international experience. The Clean Development Mechanism is a project-based baseline-and-credit scheme that encourages emissions reductions in developing countries. That scheme’s documented problems with scalability have meant that is has become widely regarded as an introductory mechanism, to be complemented or supplanted eventually by more effective mechanisms as the level of development of the host country increases.

Ultimately, if Australia is to decarbonise its economy, credible long-term price signals will be needed to change behaviours and investment decisions. Government purchasing arrangements will always struggle to provide such signals that are credible, comprehensive and long-term.

The Authority has recently been tasked to conduct a special review under section 59 of the Climate Change Authority Act over the next 18 months. This review will consider future national emissions reduction targets, emissions trading and other measures relevant to Australia pursuing its post-2020 goals. The Authority will undertake extensive public consultation throughout the review.


C 9. The size of Australia’s abatement task to 2020 is unclear, and it is difficult to estimate precisely the amount of emissions reductions the ERF purchasing scheme will deliver. It is clear, however, that by itself and as currently funded, the scheme is unlikely to deliver sufficient emissions reductions to reach even Australia’s minimum 2020 target of 5 per cent below 2000 levels. A range of complementary actions will be required, now and beyond 2020.