Aerial view of an industrial plant in a land development

On 16 April 2020 the Environmental Protection Authority (EPA) of Western Australia released the Environmental Factor Guideline for Greenhouse Gas Emissions (Guideline). The Guideline is an updated version of the draft released in December 2019.

The EPA has identified environmental factors that may be impacted by an aspect of a proposal or scheme. The environmental factors assist with organising information for the purpose of environmental impact assessments. The Guideline is aimed at achieving the objective for the Greenhouse Gas Emissions factor, which is to reduce net greenhouse gas (GHG) emissions in order to minimise the risk of environmental harm associated with climate change.

The Guideline is consistent with the State Government Policy on GHG and Australia’s commitment to reduce GHG emissions by 26 to 28 per cent below 2005 levels by 2030 and the UNFCCC Paris Agreement, which states that net zero emissions will be required by 2050 in order to limit global warming below two degrees Celsius above pre-industrial levels.

The intent of the Guideline is to inform the development and assessment of a proposal where GHG emissions are identified as key environmental factor.

The types of proposals that the Guidelines apply to include, but are not limited to, the extraction, processing and refining of oil and gas, mining and processing of metallic and non-metallic minerals, waste to energy plants, infrastructure development and development that clears vegetation. The Guidelines will apply to both new proposals and expansions to existing projects.

GHG emissions from a proposal will be assessed where the proposal will exceed 100,000 tonnes of scope 1 emissions each year. Scope 1 GHG emission are the emissions released to the atmosphere as a direct result of an activity, for example those which are released by burning coal to produce electricity. However, the Guideline notes the EPA will also maintain a flexible approach to the assessment of proposals on a case-by-case basis.

How It Works

In carrying out its functions under the Environmental Protection Act 1986 (WA) and the Guidelines, the EPA may require a proponent to provide information for the environmental impact assessment (EIA) of a proposal in the following categories.

  1. Estimates of scope 1, 2 and 3 emissions (both annual and total) including the source, intensity and how the emissions are likely to change over the life of the proposal.
  2. Greenhouse Gas Management Plans that demonstrate how a proposal will contribute towards the aspiration of net zero emissions by 2050. Such plans should, as a minimum, show an intention to reduce scope 1 emissions, outline regular and long term targets that reflect the reduction in scope 1 emissions and demonstrate that all reasonable and practicable measures have been taken to avoid, reduce and offset scope 1 emissions over the lifetime of the proposal.
  3. Additional information which demonstrates that a proponent has taken reasonable and practicable measures to avoid, reduce and offset emissions. Such information may include how emissions have been avoided through adopting best practice design, what continuous improvements will be made in order to reduce emissions through the life of a project or how emissions will be offset.

Looking Forward

The Guideline provides for proponents to adopt more effective mitigation and adapted alternatives in the Greenhouse Gas Management Plans for proposals as they become available. It is clear that proponents should have an ongoing responsibility to ensure a project is operating in the most environmentally sensitive manner through continuous improvements which adopt best practice design and meets emission reduction targets set in the Greenhouse Gas Management Plan.