21 February 2014
CPA Australia Ltd
ABN 64 008 392 452
Mr Greg Hunt
Minister for the Environment
Emissions Reduction Fund Submissions
Department of the Environment
GPO Box 787
CANBERRA, ACT 2601
Level 20, 28 Freshwater Place
Southbank VIC 3006
Australia
GPO Box 2820
Melbourne VIC 3001
Australia
Phone 1300 737 373
Outside Aust +613 9606 9677
Website cpaaustralia.com.au
Via email: [email protected]
Dear Mr Hunt
Emissions Reduction Fund - Green Paper
CPA Australia welcomes the opportunity to comment on the Emissions Reduction Fund - Green Paper
(the Green Paper). CPA Australia is one of the world’s largest accounting bodies and represents the
diverse interests of more than 150,000 members in finance, accounting and business in 121 countries
throughout the world. Our vision is for CPA Australia to be the global professional accountancy
designation for strategic business leaders. We make this submission on behalf of our members and in the
broader public interest.
This submission focuses on the importance of a robust assurance framework to underpin the veracity and
operation of the proposed scheme. CPA Australia supports the green paper’s assertion that “the existing
National Greenhouse and Energy Reporting Scheme (NGERS), including its audit framework, will help
streamline the process for reporting and verification”. We also recognise the importance of ensuring
requirements for assurance are appropriately designed so as to achieve the required level of integrity
without imposing unnecessary costs.
To be effective, an assurance regime must recognise the critical importance of independence, ethics and
quality control frameworks, the key requirements of assurance, which professional accountants must
currently comply. The NGERS audit regime has been developed through extensive consultation with the
assurance profession, including the development of an internationally equivalent assurance standard,
ASAE 3410 Assurance Engagements on Greenhouse Gas Statements and related guidance, GS 021
Engagements under the National Greenhouse and Energy Reporting Scheme, Carbon Pricing
Mechanism and Related Schemes. CPA Australia strongly recommends that an assurance regime to
underpin the veracity of the scheme proposed in the green paper is developed based on these already
established foundations.
CPA Australia supports the adoption of a risk-based model for assurance requirements as proposed in
the green paper, “for smaller projects, with minimal impact on the environmental integrity of credits”. We
would recommend the detail of such a model be determined in consultation with both the assurance
profession and potential project owners. Subject to other aspects of the model to be determined, CPA
Australia’s preferred recommendation would be for risk-based flexibility in the timing or extent of reporting
and assurance requirements, rather than a model where some projects are not subject to assurance at
all.
If you require further information on any of our views expressed in this submission, please contact Amir
Ghandar, CPA Australia by email at [email protected].
Yours sincerely
Paul Drum FCPA
Head of Policy