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This is the second submission made by the Property Council and Green Building Council on the NSW Government’s soon to commence NSW Greenhouse Benchmarks Scheme. Our first submission1 proposed a demand side abatement methodology to maximise participation from the property industry and therefore maximise reductions in greenhouse emissions.
The submission argued that a well structured demand side abatement methodology will drive a transformation towards the adoption of more energy efficient practices within a short timeframe. We believe the majority of institutional owners of property will be participating in the scheme within four years.
To this end, we are pleased to see many of our recommendations have been adopted in the draft methodology set out in the Ministry of Energy and Utilities paper, Methodology for Calculating NSW Greenhouse Gas Abatement Certificates from Demand Side Abatement released in November 2002.
This new submission builds on our earlier recommendations and responds to new detail set out in the Ministry’s paper. Key recommendations of this submission include:
We reiterate our strong support for the NSW Government’s initiative of creating a NSW Greenhouse Benchmarks Scheme that involves the property industry.
The establishment of an incentives fund to fund further abatement measures.
Consider including action that occurred prior to 1 January 2002 in the scheme.
Ensure that building owners can chose to either use an engineering method or the ABGR as a basis for earning NGACs.
Lower the proposed 4 star benchmark for new buildings to a more appropriate 2 star level.
Undertake more analysis on whether the 10% limit on baseline variability is feasible.
Engage the industry in the education process to ensure maximum involvement in the scheme.
Due to the very short period provided to respond to the Ministry’s paper, this submission has been prepared with only limited consultation from the industry. We would be happy to provide further advice to the Government on any aspect of this submission.
1 Property Council of Australia, Maximising Greenhouse Cuts from the Property Industry: A demand side abatement methodology for the NSW Greenhouse Benchmarks Scheme, November 2002. This submission was endorsed by the Green Building Council of Australia.