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EPA unveils emissions guidelines for public consultation – CCWA notes areas for concern

WA’s Environmental Protection Authority (EPA) has released a draft amendment to its Environmental Factor Guideline – Greenhouse Gas Emissions (GHG) which sets out a framework for tougher rules on carbon emissions from industrial proponents.


The draft guidelines are now open to an eight-week public consultation period and the EPA has invited submissions from environment groups, businesses and members of the public.

WA is the only Australian state in which emissions levels have risen since 2005 – by over 20 per cent – driven primarily by pollution from an expanding gas export industry.

Gas, which is a fossil fuel, is more than 25 times more potent than CO2 in trapping heat in the atmosphere and is a direct contributor to ongoing climate change which increases the frequency of floods, bushfires and droughts in Western Australia.

In announcing the draft amendment, EPA Chair, Professor Matthew Tonts, said that the regulator ‘acknowledges the need for deep and substantial emission reduction this decade, consistent with the Paris Agreement and the conclusions of the Intergovernmental Panel on Climate Change (IPCC)’.

The Conservation Council of WA (CCWA) welcomed this acknowledgement but stressed that in order to meet the objectives of the Paris Agreement an immediate and sustained reduction in greenhouse gas emissions was required – a requirement which is incompatible with the current trajectory of gas pollution in WA.

“The Paris Agreement does not advocate for a continuation of the status quo until 2050. Rather, that steps be taken now which establish immediate emissions reductions”, said Maggie Wood, Executive Director of CCWA.

The draft guidelines recommend the addition of new lines relating to scope 3 emissions – namely that industrial proponents would be expected to take “all reasonably practicable steps to (…) consider what measures they can take to reduce scope 3 emissions”.

“It is vital that the EPA is considers and assesses all emissions, throughout the entire lifecycle of a project, in order to properly understand and reduce those emissions. That includes scope 3.

“Western Australia is hugely exposed to Scope 3 emissions due to the unchecked growth of the gas export industry. If we are going to mitigate the risks of climate change, scope 3 emissions must be accounted for”.

What are Scope 3 emissions?

For the purposes of environmental regulation, greenhouse gas emissions are split into three distinct categories.

Scope 1 Emissions: The emissions which are produced from facilities or equipment owned by the company. For example, the exploitation and processing of gas to make it ready for sale and transportation,

Scope 2 Emissions: Emissions which are the result of the production of electricity or other fuels used by the company to power its facilities.

Scope 3 Emissions: All other emissions associated with the product the company sells. In the case of gas, this includes the burning of the fuel by the end user (or customer). Scope 3 emissions are usually the highest proportion of emissions generated by fossil fuels.

CCWA is also concerned by the suggestion that proposals will only be assessed by the EPA is they are likely to exceed 100,000 tonnes of CO2 equivilant scope 1 or scope 2 emissions.

“The threshold for triggering assessment must be lowered. The 100,000 tonne threshold is an arbitrary measure”, said Maggie Wood.

“As the need to reduce emissions becomes more urgent, controlling pollution from projects of all sizes is becoming ever more significant. Pollution is pollution, no matter what the size of the facility it comes from.”

“A strong greenhouse gas policy must apply to all polluters and account for all pollution.”

At the head of the EPA’s revisions is that the ‘factor objective’ – the ideal which underpins the policy, as a whole – should be amended to read ‘minimise the risk of environmental harm associated with climate change by reducing greenhouse gas emissions as far as practicable’.

“The wording of this principle is unnecessarily vague”, said Maggie Wood, Executive Director of the Conservation Council of WA.

“Unless there is a strict and binding definition of what ‘practicable’ actually means in relation to the proponents’ efforts to reducing greenhouse gas emissions, there is no genuine way in which polluters can be held to account.

“For instance, a proponent should not simply be able to say ‘we tried’ or ‘it was too hard’. They must be able to demonstrate they made a genuine and exhaustive effort to reduce emissions”, she added.

CCWA has questioned the application of guidance which would require proponents to take ‘best practice measures to avoid and reduce their scope 1 emissions’ including applying ‘best practice design and operations’. Such a condition was not applied to Woodside’s highly polluting North West Shelf expansion proposal, which was recently recommended for approval by the EPA.

“It is important to note that the North West Shelf – one of Australia’s oldest and dirtiest fossil fuel facilities – was very recently given the EPA’s seal of approval without any conditions to improve the standard of the sites design and operation”, said Maggie Wood.

The public consultation on the EPA’s draft revised greenhouse gas guidance will close on 21 September 2022.



MEDIA INFORMATION: The Conservation Council of WA (CCWA) is the state’s foremost non-profit, non-government conservation organisation representing more than 100 environmental organisations across Western Australia.

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CONTACT: For any enquiries relating to this release, please contact Robert Davies

08 9420 7291 / 0412 272 570 or by email, [email protected]

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