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CEMENT INDUSTRY FEDERATION
SUBMISSION
National Greenhouse and Energy Reporting
Scheme – 2022 Proposed Amendments
Discussion Paper
April 2022
The Cement Industry Federation Limited ABN 59 008 468 639 ███ PO Box 4178 Manuka ACT 2603
Telephone +61 2 6260 7222 ███ www.cement.org.au
INTRODUCTION
The Cement Industry Federation (CIF) appreciates the opportunity to provide comments on the National
Greenhouse and Energy Reporting Scheme – 2022 Proposed Amendments.
The CIF is the national body representing all Australian integrated cement manufacturers and comprises the three major Australian cement producers – Adbri Ltd, Boral Cement Ltd and Cement Australia Pty Ltd.
Cement is a critical input for Australia’s residential and commercial construction industry, as well as for major infrastructure projects.
Cement is an indispensable material to produce concrete. After water, concrete (including cement) is the most used material in the world and will continue to be crucial in supporting a modern world.
As a key data source supporting Australia’s reporting obligations and informing domestic climate and energy policies, it is imperative that the Measurement Determination and NGER Regulations are regularly scrutinised and updated where necessary.
KEY COMMENTS
1. Methodology for calculation of Scope 2 emission factors
The CIF supports the proposed change to the methodology for calculation of Scope 2 emission factors - specifically, removing the three-year moving average in favour of using data from the latest available reporting year.
As stated in the Discussion Paper, this approach in general recognises the increasing levels of renewable electricity generation in the grid and is likely to more accurately reflect the emissions intensity of each jurisdiction.
This approach should be reviewed over the next year or two if volatility of the factors once again becomes a concern.
Sourcing the latest renewable generation data from AEMO for the time-period matching the latest available
NGER generation data also makes sense.
2. Waste Tyres
The CIF supports the proposal to add two new stand-alone fuel types to more accurately reflect emissions from the combustion of tyres.
Australian cement manufacturers typically use coal or natural gas to fuel their kilns, which need to be heated up to 1,450oC. Like in many countries around the world, Australian cement producers take advantage of certain alternative fuels to offset primary fuel use. This not only contributes to the saving of fossil fuel resources but can have a direct and indirect effect on CO2 emissions.
Cement kilns are ideally suited to the safe recovery of energy and co-processing of a range alternative materials – including certain types of waste that can have very limited disposal options, such as end-of-life tyres. The high-temperature sintering process and alkaline conditions lead to the absorption of combustion products and other materials into the clinker.
Examples of the types of alternative fuels currently used in the Australian cement industry include wood waste, carbon powders, used oils and solvents, as well as spent cell liners from aluminium production.
While the use of tyres as an alternative fuel is currently permitted in existing environmental licences, they are not currently used in significant amounts for energy and material recovery in Australian cement kilns.
Tyres have been used extensively in the past and there remains significant potential for their renewed uptake to offset fossil fuel emissions.
Increasing the use of tyre derived fuel at cement kilns will have several environmental benefits and contribute to the circular economy.
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As such, the proposal to more accurately reflect emissions from the combustion of tyres has the potential to incentivise the use of end-of-life tyres in Australian cement kilns – provided other important issues such as long-term supply, transport as well as storage infrastructure can be addressed.
As noted in the Discussion Paper, the proposed changes align Australia’s treatment of waste tyres biomass content and associated combustion emissions with that of other UNFCCC Annex-1 reporting parties (i.e.
UK, Switzerland, Netherlands, Finland and New Zealand) – which is supported.
3. Further Contact
Thank you for the opportunity to provide the above comments. For further information relating to this submission please contact Margie Thomson, Chief Executive Officer, using the details below.
Margie Thomson
Chief Executive Officer, Cement Industry Federation
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