In September, the Northern Territory Government called for public submissions in response to the release of the Northern Territory Government’s proposed draft Greenhouse Gas Emissions Offsets Policy. This policy forms part of a suite of initiatives that the Northern Territory Government is introducing in response to pressure to commit to a 2050 net zero emissions economy target.
Following consultation with Northern Territory based members and a briefing with the NT Government's Environmental Policy office, ICIN made a formal submission in response to the draft Policy; expressing a number of concerns, highlighted below.
ICIN welcomes the development of the NT Governments Offsets policy. However, ICIN members were shocked to discover that a Large Emitters policy was already in force prior to consultation on the Draft Offsets policy. We understand that the Large Emitters policy was released for ‘targeted consultation’ earlier in the year which did not include ICIN, or the largest producer of carbon credits in the NT (ALFA NT). It is now in force with extremely high caps on greenhouse gas pollution, particularly for land clearing. We are very concerned that this is already generating perverse outcomes, such as encouraging a boom in land clearing applications and new large industrial proposals, several of which have already been granted by the Minister without requiring any offset of emissions. It appears that the large emitters policy essentially incentivises greenhouse gas pollution by unintentionally giving false licence to new developments below the caps (up to 100,000t) and especially land clearing (up to 500,000t) with little regard for cumulative impacts. These caps render the Draft Offsets Policy mostly meaningless and limit its application unless it is for a single, extremely large development application.
Both policies have been written and released prior to the Emissions Reduction Strategy, which we understand to be in progress and due for release as a draft in early 2022. This essentially means that neither the Large Emitters policy nor the Offsets Policy are tied to any actual emissions reduction targets. Current data available should enable the Northern Territory Government to estimate the degree of change required to reduce the NT’s greenhouse gas emissions footprint (21 Mt in 2019 based on the State Greenhouse Gas Inventory) to zero emissions by 2050.
We also note that the policy is dependent on a determination by the Minister at every stage, given that under the Environment Protection Act the EPA only has powers to make recommendations rather than require an offset. Therefore, this policy is vulnerable to decisions based on the politics of the day rather than science. We urge the Northern Territory Government to strengthen the EPA’s role and powers in assessing and determining whether or not an offset is required; and how.