VfCA welcomed the opportunity to provide a submission to the Federal Government's request for feedback on Reforms of the Safeguard Mechanism. We commend the Government on their progress towards addressing climate change and recognise that the Safeguard Mechanism has the potential to become a powerful mechanism to rapidly reduce Australia’s emissions and tackle harmful climate change. However this will only occur if it is strengthened and the following recommendations are adopted:

1. The Safeguard Mechanism, alongside other Government strategies to reduce emissions, should align with the Paris Agreement that aims to limit global warming to 1.5°C
2. The baseline should be progressively lowered
3. High emitting companies that come under the umbrella of the Safeguard Mechanism cannot purchase ACCUs until they have first demonstrated genuine and significant cuts to their emissions at all their project sites
4. the current proposal for SCGs should not apply to the 215 highest Australian emitters currently within the Safeguard Mechanism
5. The Safeguard Mechanism must not be derailed by new coal and gas projects
6. Safeguard Mechanism should support Australia’s export trade
7. scope of the Safeguard Mechanism should be expanded to include all emitters in the country
8. the name Safeguard Mechanism be changed to Emissions Reduction Safeguard Mechanism to be more easily understood.

This submission would not have been possible without the time and energy of our volunteer Janet Berry. We send our thanks for your work on this important issue.

A copy of the submission is available here.