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Submission: NSW Net Zero Commission – 2025 Consultation Paper

July 24, 2025
Anne-Louise Knight and Johanna Bowyer and Andrew Gorringe and Jay Gordon and Kevin Morrison
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10 July 2025


To: NSW Net Zero Commission
Re: Consultation paper

Thank you for the opportunity for the Institute for Energy Economics and Financial Analysis (IEEFA) to provide input to the NSW Net Zero Commission (NZC) 2025 Consultation Paper. 

IEEFA is an independent energy finance think tank that examines issues related to energy markets, trends and policies. The Institute’s mission is to accelerate the transition to a diverse, sustainable and profitable energy economy.

In summary, our recommendations for consideration by the NSW Net Zero Commission include the following.

  • Accelerating Emissions Reductions:
    • Model scenarios that adjust reported fossil fuel methane emission upwards by 30-100% to project potential greenhouse gas emissions. 
    • Recommend that the Department of Climate Change, Energy, the Environment and Water (DCCEEW) and the Clean Energy Regulator (CER) urgently review the National Greenhouse and Energy Reporting Scheme (NGERS) to improve methane emission measurement, reporting and verification (MRV).
  • Electricity and energy:
    • Review NSW energy upgrade schemes to ensure they fairly value the cost savings, emissions savings and peak demand reduction potential of household energy upgrades.
    • Enable big batteries acting as virtual transmission to accelerate emissions reductions in the electricity sector.
  • Transport: 
    • Develop an EV-grid integration strategy to minimise electricity system costs and maximise the potential benefits from EVs.
  • Industry: 
    • Introduce green-hydrogen offtake requirements for mining explosives to support the decarbonisation of ammonia production in NSW. 
    • Introduce comprehensive programs (combining financial support with capability building) to support industrial energy efficiency and electrification.
  • Resources: 
    • Recommend that DCCEEW and the CER bring forward the review of the Safeguard Mechanism, and ask for further clarification on increasing facility baselines.
    • Recommend that DCCEEW and the CER amend the Australian Carbon Credit Unit (ACCU) scheme to extend its reach in coalmining to curtail unlimited use of offsets, and encourage new abatement projects.
    • Include gas demand management measures in NSW’s gas decarbonisation roadmap.
    • NSW government approvals for any new fossil fuel projects or expansions should require companies to submit comprehensive methane plans.
    • Introduce an emissions reduction scheme in parallel to the Safeguard Mechanism to apply to all facilities in high-emitting industries in the NSW, or; 
    • Implement a methane tax in NSW.
    • Option to provide additional funding or tax incentives for proven abatement projects in NSW.
    • Implement more stringent state-based methane regulations in NSW.
  • Built environment:
    • Require new homes built in NSW to be all-electric. 
    • Require gas appliances to be replaced with efficient electric alternatives at end of life.
    • Require resistive electric appliances to be replaced with efficient electric alternatives at end of life.
    • Update energy upgrade schemes and rental minimum standards to include a broader range of thermal efficiency upgrades of NSW homes.
    • Develop a plan to efficiently and equitably phase-down gas networks.
    • Require heat pump hot water systems and reverse-cycle air conditioners (RCACs) to use low global warming potential (GWP) refrigerants to be eligible for rebates.
  • Developing the monitoring framework to assess progress: 
    • Develop sector-specific targets to better monitor progress.

 

Kind regards,

Anne-Louise Knight – Lead Analyst, Australian Coal
Johanna Bowyer – Lead Analyst, Australian Electricity 
Andrew Gorringe – Energy Finance Analyst, Australian Coal
Jay Gordon – Energy Finance Analyst, Australian Electricity
Kevin Morrison – Energy Finance Analyst, Australian Gas

 

Anne-Louise Knight

Anne-Louise Knight is IEEFA’s Lead Coal Analyst for Australia. Her work examines the long-term outlooks for coal in Australia and major thermal and coking coal markets.

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Johanna Bowyer

Johanna Bowyer is the Lead Analyst for Australian Electricity at IEEFA. Her research is focused on trends in the National Electricity Market, energy policy and decarbonisation.

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Andrew Gorringe

Andrew Gorringe is an Energy Finance Analyst, Australian Coal, at IEEFA. Andrew researches and produces expert analysis on topics covering the Australian and global coal industry and energy finance investment.

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Jay Gordon

Jay Gordon is an Energy Finance Analyst at IEEFA, focusing on the Australian electricity sector. He brings experience in modeling Australia’s energy system transition, including investigating the role of the electricity sector in helping the broader economy transition towards a net-zero future.

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Kevin Morrison

Kevin Morrison is an Energy Finance Analyst, Australian Gas. Kevin works closely with the global oil and gas team to examine issues facing the Australian LNG and gas sector.

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