Perth Hills Climate Change Interest Group recently put in a submission to the Environmental Protection Authority’s draft Greenhouse Gas Assessment Guidelines (GGAG).  The Conservation Council of Western Australia (CCWA) submission guide informed the PHCCIG submission.  Thanks CCWA.

The GGAG Guidelines are used by the State Government to determine how new projects should be assessed and what controls and limits should be placed on emissions from polluting industries.

Here are the main points that PHCCIG made in its submission:

1. Are there any additional measures which should be included to meet the EPA’s objective?

The measures should be in line with the findings and recommendations of the IPCC. They should also be consistent with the Australian government’s climate legislation. Therefore, they should require all fossil fuel companies (FFCs) to reduce their Greenhouse Gas Emissions (GGEs) by at least 43% (preferably 75%) by 2030, and 100% by 2050. This requirement should apply to all FFCs. There must be clear direction provided to reflect the urgent need to reduce climate destabilisation. The measures must assertively encourage steep GGE reductions and immediate action. They should require all emitters to do as much as possible, not the bare minimum.

• Are there any measures which could constrain innovation or adoption of best practice emissions avoidance and reduction?

Any measure that gives a choice to any FFC to avoid its emission reduction responsibilities is likely to constrain innovation and increase the risk of avoidance.

• Are there any measures which are not practical?

Given the harm that climate destabilisation is doing, and could or will do, to the environment and to humanity, it is not practical to do anything other than ensure the measures are consistent with the scientific consensus.

• Are there any other comments you would like to include with your submission?

The Guidelines should be upgraded to Policy, so that discretionary decision making, and undue influence, risks are reduced.