Setting Australia’s post 2020 target for Greenhouse gas
emissions. Issues paper.
Submissions can be made at
https://www.dpmc.gov.au/taskforces/unfccc
<April 25
SUBMISSION FROM B CATON AND D MOYLE
Thank you for the opportunity to comment on the Greenhouse
Gases emissions target issues paper, found at:
http://www.dpmc.gov.au/pmc/publication/setting-australiaspost-2020-target-greenhouse-gas-emissions-issues-paper
It is a surprise that this important paper has been so little
publicised, nor has been the subject of comment.
The writers of this submission are most disappointed with the
tone and content of the Issues Paper which appears satisfied
with existing efforts to reduce carbon emissions, fails to address
alternative approaches to emissions control and eschews any
leadership role that Australia may play in the setting of global
emission targets for post 2020.
The tone of the Issues Paper assumes it is satisfactory to choose
to delay action on climate change (while the governments recent
energy white paper further assumes it is desirable to do so).
Many, well qualified to judge, disagree with this position; for
example:-
“1The emission of greenhouse gases such as carbon dioxide
harms others in a way that is not reflected in the price of
carbon – based energy, that is, CO2 emissions create a
negative externality. Because the price of carbon – based
energy does not reflect the full costs, or economic damages,
of CO2 emissions, market forces result in a level of CO2
emissions that is too high. Because of this market failure,
public policies are needed to reduce CO2 emissions and
thereby to limit the damage to economies and the natural
world from further climate change.”
We believe a nation with the world's second highest per capita
level of carbon emissions has no reason to be satisfied with its
post-Kyoto emissions performance. Australia's continued
reliance on fossil fuel energy production and focus on the use
and export of coal, as presented in the recent Federal
Government energy white paper, is hard to justify in a world
facing major disruptions and economic impact from climate
change. Australia has said it is committed to actions that will
limit global temperature rise to 20 C; the issues paper does not
appear to support this position.
Our comments below are based on the extensive involvement of
the writers in natural resources management and the natural
sciences. It is not a political statement but focuses on the real
and urgent need to control Australia's carbon emissions and
provide leadership as part of an accelerated global response to
global warming.
“The cost of delaying action to stem climate change” Office of the President of the
United States, July 2014
1
The sections below address the specific questions at the end of
the issues paper.

What should Australia’s post-2020 target be
and how should it be expressed? In responding
to this question you could consider the base
year (e.g. 1990/2000/2005), the end year (e.g.
2025/2030), the type of target and why the
suggested target is preferred.
The target for 2030 should be 40% - 60% below the year 2000
level of emissions. This target would set a trajectory for
emissions to be minimal by 2050.
These targets are suggested because they were recommended by
the Climate Change Authority2 as Australia’s fair share in the
critical task of keeping warming below 20 C. We view the
Climate Change Authority as the appropriate group to evaluate
the best available advice from scientific and economic
publications in this area.

What would the impact of that target be on
Australia? In responding to this question you
could, for example, consider the impact on our
economy, jobs, and business, and on the
environment.
Climate Change Authority, ‘Targets and Progress Review, Final Report, February
2014.’
2
The response to the question 1 made above would result in the
following impacts:
Economy – would transition to an alternative-energy based
economy, taking advantage of Australia’s natural resources
potential for development of solar power (at all scales, and using
salt, and battery storage), wind power and wave power (in
southern Australia). Electric and hybrid cars would become a
necessity.
Jobs – in manufacture, construction, servicing of alternatives
many jobs will become available, and will be seen as preferable
to unhealthy coal mining jobs.
Business – It is anticipated that a number of factors will
influence business in seeing the need and possibility to invest in
change. Firstly, much of the global community is moving more
rapidly than Australia in dealing with climate change, with the
strong possibility of penalties for a coal dependant economy.
Secondly, evidence for climate change is becoming clearer, and
the implications are becoming better understood. Thirdly,
investors have grandchildren, who will face the realities of
inaction.
Environment – in species adaption and evolutionary terms,
current climate change and consequent sea level rise3 is
extremely rapid. Plant and animal species already stressed by
habitat loss and lack of investment in the management of
reserves, will be reduced in number or lost. This massive
biodiversity loss will have profound implications for soil, water
and plant resources.4 As the implications are potentially
3
Harvey N and Caton B, Coastal Management in Australia, Oxford, 2003.
Caton B, Fotheringham D, Krahnert D, Pearson J, Royal M and Sandercock R,
Metropolitan Adelaide and Northern Coastal Action Plan,Adelaide and Mt Lofty
Ranges NRM and SA Department of Environment and Heritage, 2009. See analysis of
saltmarsh and mangrove areas in cell descriptions, vol.2.
4
catastrophic and uncertain, an extremely cautious approach in
dealing with climate change would be appropriate.
Which further policies complementary to the
Australian Government’s direct action
approach should be considered to achieve
Australia’s post-2020 target and why?
It is difficult to suggest policies complementary to ‘Direct
Action’ as published analysis of this, as yet untried, policy
suggests it will have so little effect as to be a waste of money.
If this government paper is to be taken as a serious contribution
it should consider a range of options, rather than concentrate on
political point scoring. There are a variety of tools to steadily
effect a change from a carbon based economy to a low carbon
economy: there is no evidence that ‘Direct Action’ is an
efficient contributor to such a change; indeed to suggest that the
Australian government is “playing its part” appears to be
disingenuous.
Other Comments
The paragraph on ‘Australia’s action on climate change’
mentions earlier government investment in a range of renewable
energy technologies, while not mentioning that the continuation
of this investment has now been largely cut, or the government’s
attempted cuts have been stalled in the Senate. At the same time,
it has allowed protracted uncertainty over the RET to greatly
reduce private investment in this area. Appointing climate
change deniers to review the RET and to lead business advice to
the government shows a position which is not revealed frankly
or honestly in this paper. A position underlined by the failure of
the governments recent white paper on energy future to mention
climate change, but merely suggests future dependence of coal.
The section in the emissions issues paper ‘Australia’s present
position’ suggests the nation’s high reliance on fossil fuels is
due to natural resources and the lack of opportunity for hydroelectricity, while failing to mention its many opportunities to
develop alternative energies. Again, this appears disingenuous.
The lack of mention of climate change in its energy future
white paper (8th April, 2015) undermines many statements
in this proposed response to the UN. Increasing use of fossil
fuels to the levels envisaged in the white paper would lead
rapidly to mean global temperatures well above 2 0C, with
disastrous consequences to the very SE Asian nations to
which the paper envisages selling coal and gas.
In conclusion, the issues paper released for comment by the
Australian government suggests it supports global action on
climate change, while proposing policies that appear
ineffective and insufficient. World reviews by the IPCC of
past, present, and near future climate show a near
unanimous position by the scientific community: it is
shameful that a government of an advanced country chooses
to play political games with negotiations on the response to
climate change.
Brian Caton MA
David Moyle AO, MSc, Commissioner SA ERD Court.