Toll may be one of the largest energy users due to the carbon emissions from their transport network but the first thing you should consider is how the proposed CPRS relates to transport companies. The CPRS is not a carbon tax in the sense that user pays. Permits for large emitters may be required for power stations, large industrial and mining emitters but petroleum fuel users dont pay directly for the carbon they emit - the refiners have to pay for the users emissions - see the chapter on scope in the green paper.

Tolls approach is to be applauded as it will drive cost and productivity savings in its business. But Toll wont need any permits as the scheme currently stands for their fuel. Their fuel will embody carbon credits purchased by Caltex (if they buy from them). Or if they purchase fuel imported from singapore then they will get off scott free. There is no mechanism in the current scheme to change this. The excise reduction will hide real cost in the short term for the Caltex fuel, but one can expect that there will be no excise reduction for imports that dont need carbon credits. But in the long term the competitively exposed refiner will be a the mercy of the international market and subject to government handouts for survival.

The current green paper has picked the wrong point in the supply chain to impose the obligation to purchase permits. The government wants a simple scheme to collect permits for the transport carbon emissions and pass on the costs to all road users but by moving one step down the chain to fuel distributors rather than manufacturers would level the playing field.