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The Property Council strongly supports the NSW Government’s initiative of creating a NSW Greenhouse Benchmarks Scheme that involves the property industry.
The property industry provides the NSW Government with an exciting opportunity to achieve significant greenhouse gas savings within a short space of time. A well structured demand side abatement methodology will drive a transformation towards the adoption of more energy efficient practices within a short timeframe, hence maximising the impact of the NSW Greenhouse Benchmarks Scheme.
If our recommendations are adopted, we believe the majority of institutional owners of property will be participating in the scheme within four years.
This submission proposes the following recommendations to deliver a demand side abatement methodology to maximise participation from the property industry and therefore maximise reductions in greenhouse emissions:
the scheme be based on the principles of measurable abatement, rigour and simplicity,
NGAC should only accrue where rigorous baseline data exists,
no distinction needs to be made between industrial and commercial uses of electricity,
no special dispensation should be allowed for companies with no historical data,
a limited approach be taken to allowing the deeming credits to be created for a range of commercial building equipment due to administrative concerns,
owners should not be able to opt out of deeming factors,
AGBR should be used as a measure for creating NGACs and potential new sustainability rating schemes should also be used,
abatement should be created for new buildings through either ABGR commitment agreements or equipment credits,
only demand side abatement undertaken in NSW should be recognised under the scheme,
state-wide factors should be applied rather than a system of losses calculated according to franchise areas,
measurement and verification required should be appropriate to the demand side abatement activity being undertaken,
the International Measuring and Verification Protocol should only used in some cases,
discounting measures should apply to ensure no double accounting between AGBR and actual measurement abatement practices.
Due to the very short period provided to respond to the Ministry’ options 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.
