Exemptions and the scope of the ban
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A majority of submitters agreed that all of the exemptions considered in the discussion document should be incorporated.
The size of new fossil-fuel baseload generation plant in scope of the ban
Limited submissions were received specifying the size of plant which should be in scope of the ban.
One submitter suggested the ban should cover all fossil fuel baseload generation irrespective of size. However, they suggested that exemption applications could be allowed.
Other submitters believed that difficulties in defining the scope of the ban were the result of unnecessary regulation.
Exemption for the replacement of existing baseload fossil-fuelled electricity generation with new fossil fuel baseload plant of a prescribed efficiency and emissions standard
Some submitters identified difficulty in designing an exemption for the replacement of an existing baseload fossil-fuelled electricity generator with another of a prescribed efficiency and emissions standard. Setting standards and distinguishing between replacement and refurbishment were seen as challenges.
Exemption for new baseload electricity generation plant that uses blended fuels
Limited submissions were received about blended fuels.
A few submitters identified the role of blended fuels as an important ‘bridge’ in the energy transition.
One submitter stated that there should not be an automatic exemption for blended fuels and that it should be established that “an exemption is in the national interest.”
Exemption for new fossil-fuelled co-generation plants
Submitters generally favoured an exemption for co-generation plants as an efficient way to make use of process waste heat.
A gas supplier identified that “for many processes, there is currently no alternative to the use of fossil fuels for process heat. In these settings, co-generation of electricity from these industrial processes is a logical, economic and efficient way of increasing industrial efficiency by using waste heat.”
One submitter stated that an exemption should only be granted where it is established to be in the “national interest.”
Exemption for new fossil-fuel baseload electricity generation plant with carbon capture, usage and storage (CCUS)
Most submitters were in favour of an exemption for fossil-fuel baseload generation utilising CCUS technology.
A few submitters argued that focus should be on the overall goal of reaching net zero carbon emissions instead of ‘preferred solutions’ in reaching this goal.
For example, one submitter compared a natural gas fired baseload plant with CCUS, and a geothermal plant with CCUS, which would both have close to net zero emissions, but which would be treated differently under the ban without an exemption for CCUS.
Submitters were concerned not to shut out development of carbon-capture technologies prematurely, characterising this technology as a crucial part of the energy transition.
However, this appears inconsistent with the consensus that there is a low likelihood of new fossil-fuel baseload generators being constructed. It is difficult to see how development of CCUS technologies would be impacted.