The In Program Design

ANAO Report No.11 2014–15 The Award of Grants under the Clean Technology Program 50 is additional to those that are likely to occur regardless of whether the application is successful. This is referred to as ‘additionality’. There was no criterion or provision in the program guidelines that prevented projects that were being implemented without funding assistance from being assessed as eligible or meritorious. This reflected that the programs were administered as ‘transitional adjustment assistance’ for the carbon price. In this regard, the program manager noted in May 2012 that: Some applicants are likely to choose to order andor part pay for plant and equipment with significant supply lead times prior to making an application or the project start date. There is no additionality requirement in the Program and it is consistent with the policy intent of the Program to allow applicants to claim remaining costs for these plant items that are paid within the project period. It is recognised that there may be risks associated with meeting the Australian National Audit Office Granting Guidelines value for money test for funding project activities for an ERM [emissions reduction measure] that is largely complete at [the] time of application. An extreme example would be a project to put a roof on an otherwise completed replacement manufacturing facility. This risk is mitigated by the requirement for the project to rate highly against all program merit criteria.

2.20 However,

ANAO analysis was that:  the lack of an additionality criterion was inconsistent with the policy because the implementation arrangements in the policy proposal stated that funding would not be provided for projects that were intended to be undertaken privately in the absence of the programs;  none of the program merit criteria specifically required consideration of additionality, nor was information that would inform the consideration of additionality sought in application forms; and  it was not until December 2012 that benchmarks were set to reflect the score required for applications to be considered to rate highly against all program merit criteria. 61 61 Specifically, on 21 December 2012, program management advised staff in AusIndustry’s State Office Network that the overall merit score must be greater than 50 out of 100 for grants of less than 1.5 million or 60 out of 120 for grants of 1.5 million or more for the project to be approved.