Report of the Senate Environment, Communications, Information Technology and the Arts References Committee
The Heat Is On: Australia's Greenhouse Future
Table of Contents

Chapter 8

THE GREENHOUSE CHALLENGE         (Part b)

(Chapter 8 - Part a)

Accountability

8.86 The Greenhouse Challenge Program verification framework can only be effective to the extent that the results of verification carry some consequence for a Program participant. If a company is shown to be making progress in emissions-savings, then the full benefits of success should naturally accrue to it. By the same token, if a company is unable to demonstrate that they have made a genuine attempt to abide by the spirit of the Program, then a penalty of sufficient weight should be imposed. Mechanisms of accountability ensure that members continue to behave responsibly and are rewarded fairly. They are also fundamental to the practice of sound public administration.

8.87 An important way in which the Greenhouse Challenge Program promotes accountable behaviour by its members is by emphasising the importance of credible publicity about achievements under the Program. The following paragraphs discuss the role of public relations in the Program and whether it is used as an effective instrument for ensuring that the claims made by participants are credible.

The Role of Public Relations

8.88 The Greenhouse Challenge Program offers companies and industry associations an effective vehicle for publicising their commitment to environmentally-sensitive business practices. The Program encourages companies to highlight their association with the Program by using a Greenhouse Challenge logo as part of their business promotions. A Greenhouse Challenge Program newsletter published by the AGO and a well-developed internet site also help to profile the businesses and environmental practices of Program members. Approximately $260,000 was dedicated by the AGO toward Greenhouse Challenge public relations/communications in 1999 to 2000. [1]

8.89 As well as gaining recognition for individual actions toward abatement, participants also benefit from sharing in the successes of the Program as a whole. For many companies, participation in the Greenhouse Challenge Program helps to reassure the public that companies are playing their part in a national effort toward managing global warming. Many businesses are beginning to recognise the role of `corporate citizenship' in creating a sustainable basis for future business and in generating shareholder value. [2]

8.90 As members of the Greenhouse Challenge Program, companies receive the Government's endorsement to showcase their commitment to current best practice in the management of greenhouse gases. Endorsement by the Government of a company's environmental achievements can play a potentially valuable role in influencing public perceptions and share prices.

8.91 A question raised by the evidence presented to the Committee was whether a company's decision to join the Greenhouse Challenge Program was primarily motivated by the public relations benefit, rather than a genuine commitment to emissions reduction. The 1996 Wilkenfeld Report suggested that:

[t]he primary motivation for GCP participation would most likely be seen in terms of the opportunity to demonstrate corporate responsibility and the greenhouse reduction value of existing projects. [3]

8.92 The 1999 Harris evaluation of the Greenhouse Challenge Program reported that `approximately 20 per cent of surveyed participants stated that one of the reasons for joining the Program was to promote a `clean and green' image'. [4]

8.93 In the light of the value of positive publicity to participants, the Program has the option of using the public relations incentive as a penalty for non-compliance. The Draft Guidelines for Verification suggest that companies that do not achieve their targets could be penalised by:

… the removal of the enterprise's public profile and progress report summary from the Program literature and the AGO website… to stem possible damage to the Program's credibility. [5]

8.94 Companies are also likely to be aware that withdrawing from a relatively high profile program such as the Greenhouse Challenge Program could lead to public questioning about their performance in emissions reduction. The public relations penalty may be high enough to encourage a company to increase its efforts toward achieving its agreed level of emissions abatement.

The case of Coca-Cola Amatil

8.95 Evidence given to the Committee by Greenpeace Australia suggests that there is some potential for the public relations effort of the Greenhouse Challenge Program to displace a primary focus on verifiable emissions abatement. Greenpeace cited Coca-Cola Amatil (CCA) as an example of a company which has actively promoted its `Challenge credentials', but is accused of having misled the public about the nature of its contribution to the `Green Games' in Sydney 2000.

8.96 According to the AGO, CCA has been a member of the Greenhouse Challenge Program since December 1999. Its Cooperative Agreement covers soft drink production facilities around Australia and its Action Plan for 2000 is expected to achieve a 4 per cent reduction in emissions (approximately 7,000 tonnes CO2-e). [6]

8.97 An advertorial featuring the CCA appeared in The Australian in May 2000, endorsed by Senator Chris Ellison, Special Minister of State. [7] The advertorial was published as part of a series designed to profile the actions of Greenhouse Challenge members contributing to the Olympic Games. The series is funded by the AGO. The AGO stated the purpose of the series in an explanatory note to the Committee:

In response to the increased interest in environmental issues generated by the Olympic Games, Greenhouse Challenge has worked with SOCOG to increase membership of Greenhouse Challenge through the network of Olympic sponsors. To link climate change concerns with other environmental issues in the Olympic context, the actions of Challenge members contributing to the Olympic Games have been included in a series of advertorials placed in The Australian, running monthly from October 1999 to September 2000.

…..

In the case of the Olympics, the Green Games theme offered an excellent opportunity for the Challenge to promote the greenhouse gas reduction actions that specific SOCOG sponsors were undertaking as a means of encouraging similar actions from industry.

8.98 The AGO further explained that:

The Greenhouse Challenge does not advertise on behalf of members. While the AGO encourages organisations to join Greenhouse Challenge and to take as many actions to reduce greenhouse gas emissions as they are willing, the specific actions and achievements of members are not generally advertised.

8.99 The advertorial in this instance appears to have been funded by the AGO on the basis of CCA's contribution to the Olympics. It describes this contribution in the following terms:

As a leading manufacturer of soft drinks, Coca-Cola Amatil is supporting the Sydney 2000 Olympic Games through supplying soft drinks to athletes, volunteers and spectators at the Games. [8]

8.100 The main focus of the advertorial is CCA's use of efficient lighting systems at its production facilities, the basis of its Cooperative Agreement under the Greenhouse Challenge Program. The advertorial appears to suggest that the soft drinks supplied by CCA are manufactured at sites using efficient lighting systems

8.101 The AGO has explained that CCA is a separate company to Coca-Cola. [9] CCA does, however, appear to be responsible for the distribution of soft drink at the Olympics within the terms of Coca-Cola's contract with the International Olympic Committee to act as the official supplier of soft drink at the Sydney Olympics. The advertorial asserts that: `The Coca-Cola company is a Team Millennium Olympic Partner'. [10]

8.102 The advertorial clearly implies a close corporate relationship between CCA, the Greenhouse Challenge member, and Coca-Cola, an official corporate sponsor of the Olympics. This may have led readers of The Australian to believe that the environmental contribution of Coca-Cola to the Olympics is endorsed by the Program.

8.103 According to a paper published by Greenpeace Australia, the main contribution of Coca-Cola to the Olympics lies in the supply of refrigeration units. Coca-Cola planned to use 1,800 units, only 100 of which are considered to be environmentally-friendly. About 1,700 fridges will use a cooling system which uses the synthetic gas, HFC. [11] HFCs have a extremely high global warming potential (GWP) of 33,000 times 1 unit of CO2. [12]

8.104 In the Committee's view, the basis of CCA's Cooperative Agreement under the Greenhouse Challenge - lighting systems - is only indirectly linked to its contribution to the Sydney Olympics. Of greater concern than this is the suggestion that the environmental practices of Coca-Cola are endorsed by the Greenhouse Challenge or the AGO.

8.105 The Committee believes that it is reasonable for the AGO to have pursued a specific and limited strategy of public relations to capture broader industry interest in the Greenhouse Challenge Program in the context of the Olympics. The Committee is concerned, however, that the AGO has in this instance failed to demonstrate transparency and accountability in the management of the Program's relationship with industry. The Committee's main concerns are that:

• the advertorial does not make the corporate relationship between CCA and Coca-Cola clear, and, that it seeks to create the impression that CCA activities under the Program are related to Coca-Cola's general environmental practices;
• the Greenhouse Challenge Program resources have been used to promote a company (CCA and Coca-Cola) whose record of actual emissions abatement is, at best, unclear;
• that the advertorial does not make clear that it has been funded by the AGO or provide the rationale for advertising sponsorship;
• the advertorial does not make clear that its purpose is to attract new members to the Program. The incentive for a prospective member to do so is implied - official endorsement of a company's `green credentials'- even if the verification of actual achievements remain outstanding; and
• that the scope for Program arrangements with industry members to be independently scrutinised is generally limited.

8.106 Greenpeace Australia argued that this:

… point(s) out the great flaws of… the Greenhouse Challenge… because someone like Coca-Cola was able to join the Program, get taxpayer funded advertising in national newspapers, yet continues with this global policy of using HFC refrigerants when clear and economic alternatives exist. [13]

8.107 The AGO's sponsorship of CCA highlights the potential for the Greenhouse Challenge Program to be undermined by a lack of transparency about the terms of the Government's relationship with Program members.

Recommendation 90

The Committee recommends that the terms of advertising for the Greenhouse Challenge Program be made clear in each advertisement.

Recommendation 91

The Committee recommends that advertising of the Greenhouse Challenge Program featuring one or more of its members, be funded through a contribution by all Program members to a consolidated advertising fund.

Foundations for the Future

8.108 Engaging industry in emissions reduction is necessarily a long term strategy which will continue to evolve as new knowledge emerges about the nature of climate change and as the international framework develops to manage the implications of this for national economies. This section considers the role of the Greenhouse Challenge Program as a catalyst for broadening industry awareness of greenhouse issues and for developing the capacity of Australian industry to prepare their response to the challenge of global warming.

Increased awareness of greenhouse issues

8.109 An important emphasis of the Greenhouse Challenge Program is fostering awareness of the role that management culture and processes can play in a company's overall strategy for emissions abatement. Both the Wilkenfeld and the Harris Reports identified changes in a company's strategic planning, management structure, systems, attitudes and priority-setting as factors which could significantly influence energy efficiency and greenhouse emissions among Program participants. [14] The Harris Report claimed that two-thirds of the organisations surveyed reported positive management and cultural changes, `with the most important changes relating to processes and practices shaping the way that decisions are made'. [15]

8.110 As well as raising industry awareness about the benefits of greater energy efficiency, the Greenhouse Challenge Program offers companies a `conduit into the Commonwealth greenhouse policy environment'. [16] In evidence to the Committee, Wesfarmers described itself as a `relatively small chemicals company on a world-scale' which sees a key benefit of the Program as the opportunity to gain access to current debates on greenhouse policy:

Even if you do not agree with everything the Australian Greenhouse Office does, at the very least you have got the ability to access information and find out where the debate is going. [17]

8.111 The Greenhouse Challenge Program has deliberately sought to influence the top level of decision-making in participating companies and associations. It has done this by requiring CEOs to sign off on Cooperative Agreements and by giving CEOs access to high level decision-makers in Government. The Government's agreement with the Cement Industry Federation (CIF) `was signed by the chairman of the CIF management committee and the then three relevant government ministers'. [18] Wesfarmers joined in 1997 signing an agreement with the AGO in the presence of 4 Government ministers. [19]

8.112 Many witnesses attested to the success of the Greenhouse Challenge Program in enhancing CEO understanding of the role of industry in national emissions abatement. This appears to have significantly contributed to the commitment of managers and staff throughout those companies to develop and manage effective greenhouse strategies. High level promotion of the Program by CEOs appears to have been a catalyst for the development of a range of specific, practical measures aimed at increasing energy efficiency and reducing emissions.

8.113 The Australian Industry Greenhouse Network (AIGN) explained that:

… in most cases Greenhouse Challenge played a role by requiring companies to formally focus on their emissions inventory and what opportunities existed to do something about that and by requiring CEOs, or top management, to sign off on agreements. [20]

8.114 The Minerals Council of Australia similarly recognised that the educative role of the Greenhouse Challenge Program could accelerate the introduction of efficiency measures by its members:

… a very significant Program in turning around the attitudes of a lot of people in the industry in embarking on the challenge of looking at energy efficiency… [it] really served as a process of alerting people, as a process whereby senior officers in companies recognised that in the interests of their shareholders it was a win-win and they should take this pathway. I think it is fair to say that some of those investments have been accelerated as a result of the Greenhouse Challenge and the net benefits are very significant. [21]

8.115 MIM Holdings Ltd, a member of the Minerals Council, stated that the Greenhouse Challenge Program had influenced the company to implement:

… environmental initiatives at all levels of the company, ensuring that all employees are trained in environmental awareness programs and inductions. All employees are also accountable for their environmental performance. [22]

8.116 Normandy Mining Services, a Greenhouse Challenge participant since 1998, outlined to the Committee its initiatives:

Each site has an energy efficiency management plan. It also has an energy management greenhouse coordinator who reports monthly to corporate management on energy use and greenhouse emissions. Each site undergoes a regular assessment… on a lot of risk areas and those include energy management and greenhouse emissions. [23]

8.117 The Greenhouse Challenge Program appears to have successfully influenced a number of business leaders to embrace emissions reduction strategies. The Harris evaluation of the Greenhouse Challenge indicated that over half the surveyed participants believed the Program had played an important role in stimulating abatement action. Dr Clive Hamilton, however, suggested an alternative conclusion: `nearly half said the Program played no role in stimulating abatement action'. [24]

Increased technical expertise

8.118 The emphasis of the Greenhouse Challenge Program on increasing awareness about greenhouse issues among senior managers may have led to greater company investment in new technical approaches to improving energy efficiency:

Some of these things certainly would make good economic sense to do. But I think what has happened is that the greenhouse debate, and particularly the debate surrounding Kyoto and the signatures of the various countries at Kyoto, has drawn more attention to that area of our business… [it] has made us focus more on that area and find we do have some control, we can do things more efficiently… . [25]

8.119 The Cement Industry Federation (CIF) explained to the Committee that it had developed a Greenhouse Energy Management System (GEMS) which allowed its member companies to systematically identify opportunities for greenhouse abatement and develop plans for action. [26] As a result CIF members have:

… introduced changes to their business practices to include GEMS evaluations in management decision-making. Operating practices have changed and options and actions for reducing greenhouse gas emissions have been identified. [27]

8.120 A number of industry representatives referred to the benefits of industry and government working together to build expertise in resolving problems in the implementation and monitoring of emissions abatement. The AIGN in its submission argued that industry experiences with implementing various abatement strategies could make a valuable contribution to the development of government policy:

Expertise is being built on how to identify, monitor, manage and report greenhouse gas emissions at the level of individual organisations. Within participating organisations, decision-making frameworks and processes are being developed to address emission reduction options. Within government, a more detailed understanding of the emissions profiles is emerging along with a greater understanding of how more efficient and effective policies and measures can be developed. [28]

8.121 Woodside Energy Ltd also emphasised the importance of `learning by doing':

The Greenhouse Challenge has industry workbooks that have refined the NGGI methodology and sufficient feedback mechanisms exist in the various Inventory processes to ensure a process of continuous improvement. [29]

8.122 The knowledge gained through the Greenhouse Challenge Program provides industry with an effective platform for influencing high-level development of greenhouse policy and the features of any future regulatory framework.

8.123 The CIF explained that the Greenhouse Challenge Program had prompted the development of modelling capable of providing `a richer analysis of sectoral behaviour and opportunities for greenhouse gas abatement'. [30] This would offer policy-makers and legislators a better understanding of the need for and impacts of specific policy measures:

Since greenhouse issues are impacting in so many areas in such a diverse number of ways, sectoral and enterprise impacts must be better understood if the real drivers for change are to be harnessed and if the real, rather than preconceived, challenges are to be addressed. [31]

8.124 Sectoral information could prevent decisions which `turn out to be unnecessary, with far reaching cost and competitiveness implications for Australian industry, and indirectly, for the Australian community'. [32] Sectoral information would also allow the Government to assign responsibility for abatement more clearly and apply pressure more selectively.

8.125 Greenpeace Australia alluded to the strategic use to which sectoral information could be put by the Government:

Without a national strategic vision which can be used to identify sector by sector and mechanism by mechanism what we are going to do, then we will continue to see a business as usual approach. [33]

8.126 Many companies would also see the development of greater expertise in measuring, monitoring and reporting as a logical way of preparing for the possible introduction of an emissions trading system. The Australia Institute pointed to the value of the Greenhouse Challenge in preparing for a future emissions trading framework:

The introduction of a cap-and-trade emission permit system will make the GCP redundant for all firms that have legislated emission caps. A baseline-and-credit trading system would probably draw heavily on information in GCP agreements in order to establish baselines for major polluters. The targets in the agreements themselves would be redundant, although the actions specified in the agreements would provide a guide to some of the activities that may generate credits. [34]

8.127 The Committee believes the Greenhouse Challenge should be viewed as a useful transitional mechanism to a national emissions trading system. It should increasingly incorporate features which assist in the identification and costing of abatement options available to firms. This would also require a greater focus on the calculation of baselines and BAU forecasts, and the development of sound reporting mechanisms.

Recommendation 92

The Committee recommends that the Greenhouse Challenge Program give greater attention to the development of sectoral analysis and reporting. This should be consistent with international reporting guidelines.

Recommendation 93

The Committee recommends that the Greenhouse Challenge Program be reviewed with a view to structure the Program as a transitional strategy to build industry capacity for a future emissions trading scheme.

Limitations of the Greenhouse Challenge Program

8.128 The effectiveness of the Greenhouse Challenge Program needs to be reviewed against the background of the Government's broader environmental philosophies and policies and their effect on business investment decisions. The introduction of international or domestic emissions trading, for example, would render the current Program framework obsolete.

8.129 The uncertainty surrounding the future features of an emissions trading system could inhibit managers from making decisions which result in emissions reduction because, perversely, this course of action could undermine competitiveness in the future. In this example, the objectives of the Greenhouse Challenge Program are directly undermined by the anticipated need to achieve the same objectives in the future (see `credit for early action' below).

8.130 This section of the chapter examines whether the current Greenhouse Challenge framework is capable of capturing the full potential of industry to reduce emissions in view of uncertainties about the future direction of Australia's policy response to global warming. In particular, this section will examine the limitations which arise from the voluntary nature of the Program and its current emphasis on `no regrets' measures.

Investment Strategies

8.131 A number of witnesses indicated that uncertainties in the future direction of government policy tended to inhibit strategic planning and investment for emissions abatement. Both industry and environmental representatives agreed that significant reductions in industry emissions would mostly likely require investment in large-scale capital projects. The Australian Aluminium Council, for example, emphasised that: `the investment and lead times for development of new technology and replacement of existing plant are substantial'. [35]

8.132 The Pulp and Paper Manufacturers Federation of Australia (PPMFA) stated in its submission that: `many potential `no regrets' and `low regrets' measures have yet to be exploited' and that `this should be done before other measures of a more mandatory measure are considered'. In evidence to the Committee, however, the PPMFA acknowledged that further emissions reduction would be difficult to achieve under a `no regrets' framework:

… industry has probably taken most of the so-called `no regrets' measures that are available to it. So, to reduce its emissions, it has taken the measures that it could take which made economic sense; it has really taken most of these… .

If you wanted to look at substantial further emissions, you would be looking at very significant capital upgrades… major new investment in new plant and equipment that would be more energy-efficient, for example. So it is really a quantum leap up the next level of performance that may be possible to be achieved. [36]

8.133 The voluntary nature of the Greenhouse Challenge Program and its current approach of `no regrets' are unlikely to prompt industry to invest beyond standard efficiency improvements. Great Southern Energy explained in its submission that:

… there is a limit to what individual companies can achieve in such a framework. Large emission reduction measures involving significant costs are not likely to be implemented with a `no regrets' approach. The magnitude of the Kyoto target would indicate that mandatory programs with legally binding targets are now required that go beyond `no regrets'. Major emission reduction programs require legally binding targets for commercial certainty. [37]

and

… you need certainty in this whole process if we are going to achieve the result in the time frames that appear to be required. [38]

8.134 Greenpeace Australia similarly argued:

Emission reduction measures requiring significant capital investment are not implemented in a voluntary approach. [39]

8.135 The Committee concludes that the current `no regrets' framework does not influence the market to reward investment in abatement beyond BAU.

The case of Pacific Power

8.136 The importance of a national policy approach to greenhouse abatement capable of aligning economic and environmental incentives was highlighted to the Committee by Pacific Power, a major investor in both coal and the generation of renewable energy.

8.137 In evidence to the Committee, Pacific Power explained how the current electricity market favoured the generation of electricity from coal over gas. The low cost of conventionally produced electricity as a result of market deregulation directly undermined the production of less emissions-intensive energy. Pacific Power stated that its contribution to the Greenhouse Challenge Program was no longer feasible in light of the disincentives at work in a market in which companies compete to deliver cheap electricity at the expense of environmental outcomes:

In particular regard to the Greenhouse Challenge, Pacific Power, considered at the start of the Program that a gas-fired combined cycle plant would be commercially viable by around the year 2000. To this end, preliminary design and detailed environmental studies were carried out for a 400 MW plant at Wollongong and Development Consent was gained. That particular plant would have produced electricity with approximately 1,300,000 tonnes of carbon dioxide emissions each year less than the equivalent amount of electricity from NSW coal-fired plant. This was the principal initiative in Pacific Power's Greenhouse Challenge agreement.

Due to current conditions in the electricity market, and the introduction of new coal-fired plants in Queensland, this plant is unlikely to proceed for several years. [40]

8.138 Current standards in contractual arrangements also meant that it was generally more economical to generate potentially surplus electricity by using back-up systems than to face hefty fines when demand cannot be met: `Generators operate in modes that optimise their own commercial performance, but to the detriment of the environmental outcome'. [41] According to Pacific Power, investment in greenhouse friendly energy production, `… could be justified on environmental grounds only if the mix of policies were in place to create the market conditions that would enable the sale of the output'. [42]

8.139 The example of Pacific Power highlights the need to ensure that Australia's greenhouse policies are developed and implemented within a `whole-of-government' framework that minimises, as far as possible, tensions between Australia's commercial and environmental interests. In Pacific Power's view:

The inadequacy of the current mix of measures is highlighted by the fact that millions of dollars are being invested in coal-fired generation in Queensland whereas, current market conditions preclude the development of gas-fired generation. [43]

8.140 A submission by Mr Peter Kinrade of the University of Melbourne, commented on the negative effects of the current contradications in government policy-making. Drawing on work by the Allen Consulting Group, he writes:

We still have the situation where different jurisdictions are adopting often inconsistent and conflicting greenhouse-related policies and objectives. Even within the Commonwealth there is little indication that the greenhouse implications of other major policies and reforms are considered. For example, the greenhouse implications of the national energy market reforms have been largely overlooked, leading to a situation where the reforms are likely to lead to a net increase in greenhouse gas emissions, at least in the short-to medium-term. [44]

8.141 In the Committee's view, Government expenditure on the Greenhouse Challenge Program and similar incentives is wasted, if the operations of the market render its objectives unviable. This is very much the case in the national electricity market.

Credit for Early Action

8.142 A number of industry representatives expressed concern to the Committee about the lack of Government assurance that industry would not be penalised for taking early action. Their concern stems from the possibility that future governments could impose greater demands on industry to increase its contribution to national emissions savings. If participants in the Greenhouse Challenge introduce measures which result in emissions savings in the short-to medium-term, they may be less well placed in the future to make further significant gains.

8.143 This means that under an emissions trading system or a less well-developed system with limited mandatory features, companies which have already implemented efficiency measures may find it more difficult to generate tradeable credits. The Business Council of Australia expressed a common concern:

What those companies are becoming concerned about is that at the point where the Government says, `More yet is needed by everyone', and those who are not contributing are going to be forced to contribute, then those who have made the satisfactory contribution to date are going to be hit with a double whammy, to be asked to do yet more when they have in fact gone a long way down the track. [45]

8.144 The AIGN proposed to the Committee that any achievements recorded under the Greenhouse Challenge Program should be the basis of estimating the extent of early credit. [46] The CIF similarly advocated `that any verifiable action to reduce greenhouse gas emissions since 1990 should be fully recognised under any future emissions reduction policy'. [47] The AIGN suggested that the lack of assurance by Government may inhibit some companies from either participating or extending their existing plans. There was, however, insufficient evidence presented to the Committee to determine whether this in fact deterred companies from joining the Program. [48]

8.145 The Sydney Futures Exchange suggested that establishing a mechanism for `protecting baselines' could ensure that emitters who take early action are not disadvantaged. This involves the Government and companies agreeing on a baseline level of company emissions that is net of any greenhouse abatement activity. The Exchange provided an international example of how this might work in a voluntary context:

Canadian Government and industry are currently moving to incorporate baseline protection into their voluntary action program. Under their approach companies apply for emissions reductions that have occurred since Jan 1, 1990 to be registered for the purposes of baseline protection. Eligible emissions must be real, measurable and verifiable. [49]

8.146 A number of witnesses stated that uncertainties in the ratification and rules of the Kyoto Protocol made decision-making about domestic abatement difficult. The current lack of clarity about international flexibility mechanisms (such as the Clean Development Mechanism) meant that industry was unsure about whether to invest in domestic abatement measures or to initiate projects overseas which might generate carbon credits in the future. If international agreement is reached on flexibility mechanisms at CoP 6 (the 6th Conference of the Parties) in November 2000, the Greenhouse Challenge Program would need to consider the possibility of business choosing to pursue abatement measures outside Australia.

8.147 Credit for early action was a significant area of concern for witnesses, and is discussed in more detail in chapter 9. Discussion particularly focused on how early action would be recognised after the introduction of mandatory emissions reduction measures such as emissions trading. While the Committee considers that proposals for the reward of early action may be problematic, it would be relatively easy to design an emissions trading system so that companies were not penalised for early action vis-à-vis companies who had failed to take early action.

Recommendation 94

The Committee recommends that a future emissions trading system be designed to ensure that companies are not penalised for early emissions abatement activity.

Australian Democrats Recommendation 11

The Australian Democrats recommend that the Government explore mechanisms for protecting the baseline of each Greenhouse Challenge Program member, on the basis that such baselines record reductions that are independently verified.

No Regrets and Beyond

8.148 With some exceptions, measures under NGS are premissed on `no regrets' as a basis for industry action on greenhouse gas emissions. An article published in 1994 by former ABARE Director, Mr Brian Fisher, states that `regrets' policies directly target the greenhouse problem and so involve costs to national income. By contrast `no regrets' policies involve indirect greenhouse measures. These are policies which `improve, or at least do not reduce, national income while at the same time lead to complementary reductions in greenhouse gas emissions'. [50]

8.149 Advocates of this approach argue that those measures with the lowest net costs or highest net benefits should be undertaken before more costly measures. In the context of the Greenhouse Challenge Program the `no-regrets' principle implies that companies are not required to undertake measures which will impact on normal business development interests. Woodside Energy Ltd referred to The Third Draft of the NGS which defines `no regrets', in broad terms, as:

Measures which have financial, social and environmental benefits to the community at large, in addition to reducing greenhouse gas emissions, and which, over time, are sufficient to outweigh the direct and indirect cost associated with such measures. [51]

8.150 This definition does not necessarily exclude measures which result in a direct or immediate financial penalty for a given company. The financial costs of reducing emissions may be adequately balanced by other benefits which contribute to the social good.

8.151 It was clear from evidence presented to the Committee that industry would like greater assurance from Government that the future profitability of companies would not be undermined by the adoption of `beyond no regrets' measures. The AIGN stated:

We expect that there are likely to be a range of measures, both regulatory and potentially market mechanisms. So what we are really looking for at a broad level is a clear commitment from Government to say, as we move forward in all of this, that companies which have tried to do the right thing through programs such as the Greenhouse Challenge have a documented track record there and will not be disadvantaged compared with those who have not done that. [52]

8.152 Great Southern Energy expressed a common view that: `Major emissions reduction programs that go beyond a `no regrets' approach require certainty, a long timeframe and flexibility'. [53] Wesfarmers CSBP Ltd highlighted the current lack of recognition for early action as an impediment to progress beyond no regrets: `… without assurance that reductions will be credited when policy is developed, further progress beyond `no regrets' may be limited'. [54]

Are Voluntary Measures Enough?

8.153 It is clear that industry saw the Greenhouse Challenge Program as a viable alternative to proposals for the introduction of a carbon tax in 1994-95. [55] The Harris Report notes:

In the belief that it was possible to demonstrate that voluntary action by the private sector could produce significant results in emissions abatement, Australian industry approached the then Commonwealth Government with a proposal for a voluntary greenhouse abatement program. [56]

8.154 A number of witnesses believed that industry enthusiasm for the Greenhouse Challenge Program stemmed from a concern that more restrictive greenhouse policies would be introduced. A submission provided by the Australia Institute quotes a coal industry newsletter as evidence that industry was primarily concerned with avoiding the imposition of stricter measures:

The release of Australia's Greenhouse Challenge Evaluation Report has demonstrated the value of voluntary action, and provided industry with an argument against mandatory measures to curb greenhouse gas emissions. [57]

8.155 The Australia Institute further claimed that:

Industry has frequently used the existence of the Program to deflect demands to take more serious action to cut emissions. It has also been of value to the Government; while appearing to act on the issue it has not alienated industry. It has also provided it with ammunition with which to respond to the sustained attacks on Australia abroad. [58]

8.156 The Australia Institute suggests that the Greenhouse Challenge Program has arguably done more harm than good by `blunting public demands for more effective action'. [59]

8.157 National Inventory figures released in July 2000 indicate that Australia faces a greater challenge in meeting the Kyoto target of 108 per cent than originally anticipated. Australia in 1998 exceeded our international commitment by 16.9 per cent, excluding emissions from land clearing. Given that this trend is likely to continue, the question arises whether the current contribution of industry to emissions reduction will be sufficient to meeting our overall national target. The scope for flexibility and cost-effectiveness in Australia's response to meeting the Kyoto target will clearly reduce as the binding period of 2008 to 2012 draws closer. As was put to the Committee by Australia's Ambassador for the Environment: `That is when you actually have to do things that will make you comply'. [60]

8.158 The AGO recognises that the current balance of voluntary and regulatory measures may need to be adjusted as the challenge of meeting Australia's obligations becomes clearer. [61] The introduction of mandatory targets for the use of renewable energy in the generation of electricity and the proposal for a `greenhouse trigger' are examples of the Government's efforts to reign in Australia's escalating national emissions profile:

The fact that, prior to Kyoto, Government negotiated and put in place, with the support of industry, a broader range of measures beyond just Greenhouse Challenge, indicates that Government did not believe, and neither did industry at that point, that a target that came out of Kyoto could necessarily be met by voluntary action alone… . We now have a range of activities that include voluntary action and regulatory action, where it makes sense, and mandated targets for example in renewable energy. [62]

8.159 The Australian Conservation Foundation argued for greater intervention by Government in the management of emissions, a position that goes beyond the Government's current preference for market-based solutions:

… you have to have a carrot and stick approach from the national Government and you have to have leadership. At the moment the AGO focuses on the carrot approach - the incentives. Without the ability to mandate targets, without legislative mechanisms much more thoroughly developed at the Commonwealth level, there is a limit to what you can achieve through voluntary initiatives. That is where the attention is needed. The role of the AGO could be deepened and could be far more effective at delivering incentives where they are needed… perhaps it would have a role to play particularly in monitoring and evaluating and informing to help with legislative initiatives… . [63]

8.160 Whilst the Greenhouse Challenge Program has gone some way toward harnessing the potential for industry to significantly reduce the national emissions profile, it may not in itself be sufficient to delivering the outcomes sought by the Government. Pacific Power summed up this viewpoint:

The Greenhouse Challenge seems to have been effective in reducing emissions on a `no-regrets' basis. However a review of the forecast emissions reductions by organisations signed up for the greenhouse challenge fall far short of Australia's Kyoto target. Additional mechanisms, well beyond those likely to result from Greenhouse Challenge, will be needed if Australia ratifies the Kyoto Protocol. [64]

8.161 Pacific Power also argued that `it is also unreasonable to expect volunteers to carry the burden of emissions reduction'. [65] A number of witnesses argued that binding targets and a regulatory framework to ensure compliance with those targets are necessary for going beyond what purely voluntary measures can achieve. Greenpeace highlighted a common concern with the Government's current approach: `… our main concern with the voluntary approach that is put forward is that it is not underpinned by any hard place, by any real hard targets'. [66]

8.162 From an international perspective there are, in the main, two attitudes that Australia can adopt on `beyond regrets' measures. The first body of opinion argues that we should not undertake unilateral measures which carry a cost to our economy before other countries agree also to abide by the same rules. The critics of this approach argue that Australia's reputation on environment issues has already been considerably damaged by Australia's argument of `special circumstances' at Kyoto. The likelihood that Australia will not meet the Kyoto target may reinforce the view that Australia is unwilling to adopt the necessary measures to effectively manage the challenge of climate change.

Options for the Future

Comprehensiveness and burden-sharing

8.163 Industry emissions make up a significant proportion of Australia's national emissions. Around half of Australia's emissions however, issue from non-industry sources. A number of industry representations to the Committee argued that managing Australia's emissions profile would therefore mean drawing in other parts of the Australian economy. The following comments by Western Australia Minerals and Energy were typical:

… the greenhouse issue is an important issue for the whole community… . Certainly, everyone will feel the impact of response measures, particularly if they cause economic upheaval… response measures must be undertaken across the whole community. [67]

Measures confined to just a few sectors, typically comprising relatively small numbers of comparatively large emitters, will fall short of the success policy-makers would wish for them. [68]

8.164 To date, the Greenhouse Challenge Program has primarily focused on capturing major emitters. The AIGN asserted that the Program had:

… excellent coverage in some key areas including 100 per cent coverage of aluminium and cement production, 98 per cent of oil and gas extraction and electricity generation and distribution and 91 per cent of coal mining. [69]

8.165 The Minerals Council stated that:

… 78 per cent of emissions from mining (including 91 per cent from coal mining) are covered by companies participating in the Greenhouse Challenge. On the minerals processing side, 89 per cent of emissions from machinery and metals manufacturing is covered by the Challenge with 100 per cent coverage from aluminium and iron and steel. [70]

8.166 The Australian Coal Association stated that,`at present 75 per cent of black coal produced is covered by companies which are participants in the Greenhouse Challenge'. [71]

8.167 A number of the current participants of the Greenhouse Challenge Program expressed the view that they had already made a significant contribution to emissions savings and that further demands for abatement should be extended to other parts of society.

8.168 The Australian Aluminium Council argued that it had a limited capacity to make further savings and that more effort should be made to engage other parts of the community in emissions reduction:

There is a tendency so far for Governments to focus mainly on the energy producers and energy-intensive users, because these are visible and relatively easy to deal with. However it is important to understand that very significant emissions are related to other sectors such as the commercial business sector, the household and service sectors, the transport sector (especially motor vehicles), and the agricultural sector. Australia's abatement strategies must focus on the full range of possibilities and it is in these other sectors that many of the most effective actions may rest. [72]

8.169 The Pulp and Paper Manufacturers Federation of Australia (PPMFA) similarly argued that it should not be required to deliver significant emissions savings beyond its achievement to date:

We consider that we have already performed very well in reducing our emissions. The same cannot be said for many other areas of the economy… before focussing on an industry that already has a good record in reducing its emissions, there are many other sectors of the economy where the focus should be put where there are relatively low measures that could be taken which would substantially reduce Australia's emissions. [73]

8.170 In the main, industry bodies saw the promotion of energy efficiency by all users as a necessary step before considering the introduction of more stringent measures for industry. Industry representatives offered a number of suggestions on how this should be done:

• extending the coverage of the Greenhouse Challenge Program to untapped sectors, such as transport and agriculture; [74]
• where appropriate, negotiated agreements with companies and sectors; [75]
• tailoring greenhouse response measures to target sectors; [76]
• increasing the number of businesses registered with the Program; [77]
• better management of land clearance and the pursuit of forestry and land rehabilitation programs that have economic and/or environmental benefits as well as greenhouse abatement; [78]
• increasing the contribution of government services to national emissions savings; [79]
• increasing coverage of energy-intensive manufacturing; [80]
• increasing the focus on end user efficiency, eg buildings, transport, potential for long term changes to urban design and transport modes; [81] and
• extending the Program to cover small-to medium-size businesses. [82]

8.171 The 1996 Wilkenfeld Report notes that:

… it is not the largest emitters but the second rank (say 20 to 500 Kt per annum) where the greatest untapped potential lies, and where the GCP is more likely to prompt actions that would not otherwise have been taken. [83]

8.172 The Committee broadly supports the integration of these recommendations into the framework of the Greenhouse Challenge Program, as far as is practicable. However, the Committee notes that the practice of this large industry sector in pointing to other energy users could be said to be an attempt to distract from its own obligations.

8.173 The current costs of verification make it prohibitive for Government to extend the coverage of the Greenhouse Challenge Program. Incorporating the vast number of small emitters in Australia (small business, farmers, householder, motorists) on a voluntary basis is administratively burdensome and unlikely to result in significant or sustained savings. The Committee also recognizes that that it would be unreasonable to require small emitters to fund the verification of their assessments and concludes that this factor and the `no regrets' framework of the Program does not provide a suitable mechanism for capturing the broader community of smaller emitters.

Recommendation 95

The Committee recommends that the Australian Greenhouse Office assess whether proposals to extend the Greenhouse Challenge Program would be more effectively dealt with other programs or by legislation.

Taking the Lead

Industry

8.174 The primary benefit of the Greenhouse Challenge Program is the scope it provides for industry to play an active - even leading role in contributing to Australia's commitment to greenhouse gas reduction. The Program provides a platform for continuing dialogue and cooperation between government, industry and the community on the development of practical strategies for emissions abatement. From the point of view of industry the effectiveness of the Program is affected by a range of uncertainties:

• the likely costs to business of compliance with government imposed targets;
• the design features of a domestic or international future emissions trading system and the timing of their introduction;
• the Government's likely approach to giving businesses credit for early action;
• options available to business for reducing the domestic cost burden through the use of international flexibility mechanisms (with or without a trading system); and
• the effects of the interaction of a number of Government policies on the environment, new industries, regionalism, employment and our international relations.

8.175 In the light of these uncertainties, industry representatives, in general, expressed a clear preference for the Greenhouse Challenge Program to remain a Program based on voluntary measures.

8.176 Many witnesses saw scope to build on the current framework and insights gained from the Greenhouse Challenge Program. The main advantage cited by industry of refining the existing framework lay in avoiding the need for the complex legislation and management changes that would accompany the introduction of an emissions trading system. The following view put by the Business Council of Australia was common:

… the voluntary Greenhouse Challenge Program provides an institutional framework and basis which could, we believe, be further enhanced and expanded to achieve the Government's objectives in this instance. [84]

8.177 The Cement Industry Federation (CIF) suggested that Greenhouse Challenge agreements provide a framework for considering the concept of negotiated, legally binding agreements between Government and each industry/sector:

The basic elements of a negotiated agreement - inventory, abatement actions and forecasts are already part of each Greenhouse Challenge agreement, as is the process for annual reporting of achievements, and independent verification of results. The main additional step would be to negotiate the target to be achieved by the industry/sector by an agreed date (the means of reaching the agreement a matter for the industry or sector). [85]

8.178 Energetics Pty Ltd brought to the Committee's attention the implementation of a Voluntary Energy Efficiency Programme (VEEP) by the European chemical industry since 1992. The Program commits its members to significant and quantified improvements in specific energy consumption. Energetics considered this approach `a logical extension to the existing Greenhouse Challenge'. [86]

8.179 In response to a question by the Committee about the desirability of introducing mandatory components to voluntary agreements, the PPMFA said:

That is certainly worth exploring. If we are looking at the next generation of greenhouse challenge type agreements, to use the Government's phrase of `mutual obligation'. I think you can have a situation where more is required of industry. Potentially industry or sectors or individuals could be required to meet a specific target… . You could have penalties for not meeting that target. [87]

8.180 A number of witnesses however, argued that as a purely voluntary scheme, the Greenhouse Challenge Program has a limited capacity to influence industry toward climate change actions:

• George Wilkenfeld and Associates:

  Australia can meet its commitment under the Kyoto Protocol, but only if far more vigorous and effective action is taken than currently envisaged. [88]

• The Australia Institute:

  … there must be penalties. It goes without saying. I believe large segments of industry often prefer a mandatory approach because it actually levels the playing field. If you look at the international evidence on voluntary agreements, the essential conclusion is that they do not really have much impact… they conclude that they are not very effective at achieving their objectives. [89]

• Greenpeace Australia:

We are not suggesting that the GCP should be abolished. It clearly has a role to play as part of Australia's greenhouse policy response. However, given the shortcomings in the Program, it must not be used, as it is by industry and government, to deny the necessity of more substantial efforts to reduce emissions, including mandatory measures.

Furthermore, until the GCP can be made more rigorous, and genuine emission reductions can be adequately measured, the Program should not be used as a tax-payer funded exercise to improve the corporate image for greenhouse polluting companies. [90]

8.181 The Committee believes that the present voluntary arrangements do not encourage industry to adopt systematic and comprehensive approaches to emissions reduction which go beyond `no regrets'. Voluntary participation means that taking the lead in abatement is largely unrewarded by the market. This has resulted in a minimum level of action by a relatively small number of emitters, undertaken largely in the interests of avoiding current market or Government penalties.

Government

8.182 The Committee emphasises that the Government has a critical leadership role to play in establishing and enforcing a regulatory framework for long term, sustainable emissions abatement. Many witnesses to the inquiry urged the Government to acknowledge that the current regime of voluntary abatement will not support Australia's long term interests:

• Australian Conservation Foundation:

  … a lot of what we are putting in front of you today actually requires Government leadership, legislation and policy changes that the Greenhouse Office is not responsible for… . One of our challenges is finding a point of receptivity and a policy dialogue at the national level where one can adequately put forward these perspectives and really form a view that does include mandated action on how we tackle greenhouse in Australia. [91]

• Friends of the Earth (Victoria):

  Voluntary measures have a place but they do not actually replace having a regulatory framework. That needs to come at a Commonwealth level. [92]

• Australian Conservation Foundation:

  I think the central issue is the capacity for national leadership and coordination through legislation. [93]

• The Australia Institute:

When you have something as important and urgent as reducing Australia's greenhouse emissions, the past evidence in Australia and the international evidence strongly suggest that mandatory measures are required. [94]

8.183 The Committee believes that the Greenhouse Challenge Program partnership model does not appropriately balance the Government's desired outcomes with the capacity of industry, as a whole, to reduce its emissions. Under the current framework of the Program the risk of not achieving a significant and sustained level of abatement is borne mainly by Government. The voluntary nature of the Program means that Government is reluctant to impose penalties if agreed targets are not achieved, recognising that this may deter prospective participants from joining. Ultimately, the consequences of not sharing the burden of abatement equitably across all of industry at an early stage in our abatement effort could impose a severe penalty on the Australian economy in the future.

Conclusions

8.184 The Committee is of the view that, in the absence of an established domestic or international emissions trading system, the Greenhouse Challenge Program can play a valuable role in encouraging industry to adopt emissions abatement strategies.

8.185 The Committee is not convinced that the administration of the Greenhouse Challenge Program conforms to acceptable standards of transparency. The Committee recognises that the voluntary nature of the Program may have resulted in minimal conditions being imposed on participants. However, the Committee firmly believes that the Program must demonstrate complete integrity in setting emissions reduction targets and reporting of industry achievements.

8.186 The current emphasis of the Greenhouse Challenge Program on voluntary participation and compliance affords industry considerable flexibility in deciding how and when it will reduce emissions. The Committee recognises the value of undertaking least cost measures in the immediate to short term, but emphasises the need for industry to prepare for `beyond no regrets' measures and to implement all cost-effective emissions reduction measures.

8.187 In the Committee's view, the Government has a critical role to play in establishing an integrated national framework - with an appropriate balance of voluntary and mandatory features - capable of promoting the long term interests of the Australian community as a whole. This means managing Australia's transition to a new forms of economic wealth based on principles of environmental sustainability.

 

Footnotes

[1] Email to the Committee from Linda Powell, Executive Manager, Partnerships Group, Australian Greenhouse Office, 26 July 2000.

[2] `… new currents in society influence the degree to which business is accepted as a respected and relevant player in the development of public policy. At the level of individual corporations there is an impact on the so-called licence to operate, taking that term to mean a company having a sufficient level of community support to enable it to continue operations, let alone to realise its full potential' (Campbell Anderson, President of the Business Council of Australia, The Changing Nature of Public Policy, www.bca.com.au/docs/eng/speech.html, p 7).

[3] Wilkenfeld Report, 1996, p 20.

[4] Greenhouse Challenge, Evaluation Report, 1999, p 59.

[5] Greenhouse Challenge Independent Verification Program, 2nd Discussion Paper (Draft), April 1999, p 42.

[6] Email to the Committee from Linda Powell, Executive Manager, Partnerships Group, Australian Greenhouse Office, 3 August 2000.

[7] See advertisement at appendix 7 of this report.

[8] `Coca-Cola Amatil Taking up the Challenge', The Australian, 25 May 2000, p 19.

[9] Email to the Committee from Linda Powell, Executive Manager, Partnerships Group, Australian Greenhouse Office, 3 August 2000.

[10] `Coca-Cola Amatil Taking up the Challenge', The Australian, 25 May 2000, p 19.

[11] Coca-Cola: Ice Cold Coke - Boiling Hot Planet, http//www.greenpeace.org.au, p 5.

[12] Senator Bob Brown, Proof Committee Hansard, 22 June 2000, p 718.

[13] Proof Committee Hansard, Canberra, 23 June, p 678.

[14] Wilkenfeld Report, 1996, p 26; and Harris Report, p 42.

[15] Greenhouse Challenge, Evaluation Report, 1999, p 42.

[16] Australian Greenhouse Office, Submission 169, p 1691.

[17] Proof Committee Hansard, Perth, 17 April 2000, p 523.

[18] David Cusack, Chairman, Greenhouse Gas Working Group, Mitigation of Greenhouse Gas Emissions from the Australian Cement Industry, http://www.engaust.com.au/other/CIA0699-2.html.

[19] Proof Committee Hansard, Perth, 17 April 2000, p 520.

[20] AIGN, Proof Committee Hansard, Melbourne, 20 March 2000, p 139.

[21] Minerals Council of Australia, Official Committee Hansard, Canberra, 10 March 2000, p 70.

[22] Cooperative Agreement, A Report on the Greenhouse Challenge 1998-99, Tabled document, 10 March 2000, p 5.

[23] Normandy Mining Services Pty Ltd, Proof Committee Hansard, Perth, 17 April 2000, p 477.

[24] Proof Committee Hansard, Canberra, 10 March 2000, p 56.

[25] Western Australia Chamber of Minerals and Energy, Proof Committee Hansard, Perth, 17 April 2000, p 475.

[26] Cement Industry Federation (CIF), Submission 135, p 1424; see also David Cusack, Chairman, Greenhouse Gas Working Group, Mitigation of greenhouse gas emissions from the Australian cement industry, http://www.engausyt.com.au/other/CIA0699-2.html.

[27] Cement Industry Federation (CIF), Submission 135, p 1424.

[28] Australian Industry Greenhouse Network (AIGN), Submission 113, p 923.

[29] Woodside Energy Ltd, Submission 129, p 1312.

[30] Cement Industry Federation (CIF), Submission 135, p 1424.

[31] Cement Industry Federation (CIF), Submission 135, p 1424.

[32] Cement Industry Federation (CIF), Submission 135, p 1424.

[33] Proof Committee Hansard, Canberra, 23 June 2000, p 681.

[34] Dr Clive Hamilton, Submission 79d, p 2305.

[35] Australian Aluminium Council, Submission 167, p 1671.

[36] Proof Committee Hansard, 23 June 2000, p 778.

[37] Great Southern Energy, Submission 150, p 1559.

[38] Proof Committee Hansard, Canberra, 23 June 2000, p 689.

[39] Greenpeace quoting experts in energy reform (Lovins, Moskovitch), Submission 183, p 1937.

[40] Pacific Power, Submission 98, p 804.

[41] Pacific Power, Submission 98, p 806.

[42] Pacific Power, Submission 98, p 804.

[43] Pacific Power, Submission 98, p 802.

[44] Mr Peter Kinrade of the University of Melbourne, Submission 164, p 1651.

[45] Official Committee Hansard, Melbourne, 21 March 2000, p 181.

[46] Proof Committee Hansard, Melbourne 20 March 2000, p. 138.

[47] Proof Committee Hansard, Canberra, 23 June 2000, p 712.

[48] `The expansion of participation and extension of the action plans would be greatly enhanced by a clear commitment from Government that organisations will not be disadvantaged for taking voluntary actions now relative to those not taking such actions' (Mr John Maxwell Eyles, Executive Director, AIGN, Proof Committee Hansard, Melbourne, 20 March 2000, p 137).

[49] Sydney Futures Exchange, Submission 161, p 1623.

[50] Mr Brian Fisher, Executive Director, ABARE, `The Development of International Climate Change Policy', Australian Commodities, vol 1, March 1994, p 51.

[51] Woodside Energy Ltd, Submission 129, p 1306.

[52] Australian Industry Greenhouse Network (AIGN), Submission 113, p 138.

[53] Great Southern Energy, Submission 150, p 1560.

[54] Wesfarmers CSBP Ltd, Submission 103, p 845.

[55] David Cusack, Chairman of the Greenhouse Gas Working Group of the CIF, stated in a 1999 paper that `Industry was not in favour of such a measure because of the potential adverse effects on business competitiveness.'

[56] Greenhouse Challenge, Evaluation Report, 1999, p 11.

[57] Dr Clive Hamilton, Submission 79d, p 2301, quoting Ecoal, a quarterly newsletter of the World Coal Institute, Vol 32, December 1999.

[58] Dr Clive Hamilton, Submission 79d, p 2306.

[59] Dr Clive Hamilton, Submission 79d, p 2298.

[60] Ambassador Ralph Hillman, Proof Committee Hansard, Canberra, 9 March 2000, p 15.

[61] `A key matter for on-going attention is whether our current package of policies and measures will in fact lead to the required net reduction in emissions by 2008 to 2012' (Ms Gwen Andrews, Chief Executive Officer, AGO, Proof Committee Hansard, Canberra, 9 March 2000, p 4).

[62] Ms Gwen Andrews, Chief Executive Officer, AGO, Proof Committee Hansard, Canberra, 9 March 2000, p 17.

[63] Australian Conservation Foundation (ACF), Official Committee Hansard, Melbourne, 21 March 2000, p 195.

[64] Pacific Power, Submission 98, p 804.

[65] Pacific Power, Submission 98, p 803.

[66] Greenpeace Australia, Proof Committee Hansard, Canberra, 23 June 2000, p 676.

[67] Proof Committee Hansard, Perth, 17 April 2000, p 473.

[68] Proof Committee Hansard, Perth, 17 April 2000, p 473.

[69] Australian Industry Greenhouse Network, Submission 113, p 923.

[70] Cooperative Agreement, A Report on the Greenhouse Challenge 1998-99, Tabled document, p 3.

[71] Australian Coal Association, Submission 140, p 1462.

[72] Australian Aluminium Council, Submission 167, p 1671.

[73] Proof Committee Hansard, 23 June 2000, p 778.

[74] The Minerals Council, Proof Committee Hansard, Canberra 10 March 2000, p 70.

[75] Australian Industry Greenhouse Network, Submission 113, p 914.

[76] Cement Industry Federation (CIF), Submission 135, p 1424.

[77] Cement Industry Federation (CIF), Submission 135, p 1424.

[78] Australian Industry Greenhouse Network, Submission 113, p 915.

[79] Australian Industry Greenhouse Network, Proof Committee Hansard, Melbourne, 20 March 2000, p 137.

[80] Australian Industry Greenhouse Network, Submission 113, p 932.

[81] Australian Industry Greenhouse Network, Submission 113, p 932.

[82] Australian Aluminium Council, Submission 167, p 1674.

[83] Wilkenfeld Report, 1996, p 25.

[84] Official Committee Hansard, 21 March 2000, p 176.

[85] Cement Industry Federation (CIF), Submission 135, p 1432.

[86] Energetics Pty Ltd, Submission 143, p 1493.

[87] Proof Committee Hansard, 23 June 2000, p 706.

[88] George Wilkenfeld and Associates, Submission 85, p 659.

[89] Dr Clive Hamilton, Proof Committee Hansard, 10 March 2000, p 65.

[90] Greenpeace Australia, Submission 183a, p 2422-23.

[91] Official Committee Hansard, Melbourne, 21 March 2000, p 198.

[92] Proof Committee Hansard, Melbourne, 20 March 2000, p 167.

[93] Official Committee Hansard, Melbourne, 21 March 2000, p 195.

[94] Dr Clive Hamilton, Proof Committee Hansard, Canberra, 10 March 2000, p 65.