The NSW EPA’s new Climate Change Mitigation and Adaptation Program (CCMAP) will require certain Environment Protection Licence (EPL) holders to better understand their emissions and climate risks while identifying practical opportunities to reduce emissions and improve business performance.

CCMAPs require EPL holders emitting more than 25,000 tonnes of CO₂-e annually to prepare and publish plans outlining their emissions profile, emissions reduction pathway and approach to managing climate risks.

Who will be affected?

The measure is expected to capture around 10% of the State’s EPL holders, potentially up to 280 facilities. Facilities likely to be affected include:

• Coal mines
• Power stations
• Large waste and resource recovery facilities
• Large wastewater treatment facilities and water utilities
• Chemical manufacturers
• Steel and metals processing
• Cement, lime, brick manufacturing and other large process heat industries
• Other large EPL holders above 25,000 t CO₂-e

While only around 10% of EPL holders are expected to be captured, these facilities account for a substantial share of emissions from licensed premises across NSW.

CCMAPs will require:

• Emissions inventories
• Emissions forecasts
• Emissions reduction targets
• Emissions mitigation action plans
• Climate adaptation plans (future phases)

Coal mines and Safeguard Mechanism facilities will be required to publish their first CCMAPs by 31 March 2027, with other covered EPL holders required to publish CCMAPs by August 2027. As developing a CCMAP is likely to require emissions analysis, stakeholder engagement and identification of mitigation opportunities, organisations should consider commencing preparation well before the publication deadlines.

NSW CCMAP Timeline: Reporting and Publication Deadlines for EPL Holders

Why CCMAP matters for large EPL holders

For many EPL holders, CCMAP may initially be viewed as a new compliance obligation. However, the process of preparing a CCMAP can also help organisations better understand their emissions sources, future regulatory exposure and opportunities to improve operational performance.

Many organisations are already facing growing expectations from customers, investors, regulators and supply chains to understand and manage their emissions. At the same time, electricity, gas and fuel remain significant operating expenses for many facilities. CCMAP provides a structured framework to assess emissions reduction opportunities, improve energy productivity and support broader business objectives.

For many facilities, the largest emissions sources are also significant cost centres. Understanding these emissions sources can help organisations identify opportunities to reduce emissions, lower operating costs and strengthen long-term competitiveness.

Prioritising practical emissions reduction actions

Many large facilities have already implemented energy efficiency projects and operational improvements. The challenge is often determining which opportunities will deliver the greatest emissions reductions, operational benefits and return on investment.

A structured emissions mitigation plan process typically starts with understanding current energy use and emissions sources. From there, organisations can identify practical opportunities to reduce emissions, improve efficiency and strengthen business performance, such as:

• Energy productivity improvements and technology upgrades
• Waste heat recovery
• Electrification of gas and diesel equipment
• Renewable energy and battery storage
• Fleet transition
• Waste reduction and resource recovery
• Methane capture and utilisation
• Refrigerant management

While emissions reduction is one objective, the broader goal is often to support organisational priorities such as reducing operating costs, improving operational performance, managing risk and strengthening competitiveness.

Decarbonisation can deliver benefits beyond emissions reduction. Organisations that understand their emissions profile and develop a clear transition pathway are often better positioned to manage risk, improve efficiency and respond to changing stakeholder expectations.

We work with organisations to measure emissions, plan their transition, manage climate risks and meet reporting requirements. CCMAP currently focuses on understanding emissions and identifying emissions reduction opportunities, with climate adaptation guidance expected to be incorporated into future plans.

Need help developing your CCMAP?

100% Renewables has extensive experience supporting government and industry to measure emissions, identify emissions reduction opportunities and develop practical decarbonisation roadmaps.

If your organisation is preparing for the NSW EPA’s CCMAP requirements, we can assist with emissions measurement, emissions reduction planning, target setting and the development of practical mitigation roadmaps.

Contact Barbara or Patrick to discuss how we can support your CCMAP requirements.

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