On 19 February 2021, the Clean Energy Regulator published a consultation paper seeking feedback on a possible design of the Corporate Emissions Reduction Transparency (CERT) report and its proposed guidelines. We would like to take this opportunity to thank everyone who took time to participate and provide their valuable feedback on the CERT consultation paper and guidelines.
We received 57 submissions in response to our consultation paper. Most submissions stated that they valued an independently published report, such as the CERT report, that presented the net emissions position of participating companies as well as progress against their voluntary commitments. Stakeholders also expressed support for the CERT report to align with other domestic and international sustainability reporting frameworks and flexibility to provide context for their targets and emissions reduction strategies. Key themes arising from our consultation are outlined below.
Stakeholders told us that many companies have formulated a range of emissions reduction commitments that may not align with the National Greenhouse Emissions Reporting (NGER) scheme framework. They expressed a wish for flexibility in how progress is reported against these commitments. Stakeholders also highlighted the importance of providing context for the setting of targets, and for the description of emissions reduction strategies to assist with interpreting progress. Submissions also asked for greater flexibility around reporting periods so that companies with calendar year emission reduction commitments could report their progress on that basis.
It was important to stakeholders that the CERT framework aligned with Climate Active, as well as other international frameworks (such as the Taskforce for Climate-related Financial Disclosures), for net emissions reporting where practical. Stakeholders submitted to us that this would avoid confusion and reduce administrative burden on participating companies.
Stakeholders told us that in addition to showing their position on net Scope 1 emissions (emissions released to the atmosphere as a direct result of an activity, or series of activities at a facility), that they also wanted CERT to show their net Scope 2 emissions position (emissions released to the atmosphere from the indirect consumption of an energy commodity).
Many stakeholders saw benefit in presenting the proportion of electricity consumed that came from renewables, but some had questions around how the renewable electricity percentage was calculated. Stakeholders asked for further clarity on the proposed methodology for CERT, given that there are different approaches available.
Following our consultation paper, the Clean Energy Regulator is conducting a co-design process with existing NGER scheme reporters to better understand and address the matters raised during public consultation. We have also established a reference group of leading experts to help guide the approach taken in the guidelines and to evaluate whether the pilot design is fit-for-purpose.
Where appropriate, we will undertake further consultation before the launch of the pilot CERT program in late 2021. We will also keep NGER reporters and stakeholders informed of our progress on a regular basis.
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The Clean Energy Regulator is a Government body responsible for accelerating carbon abatement for Australia.