Review of climate change policies
Submission
May 2017
1
© Copyright Municipal Association of Victoria, 2017.
The Municipal Association of Victoria (MAV) is the owner of the copyright in this publication.
Due to time constraints this submission has not benefited from consultation with our members
and instead reflects established positions of the MAV that are supported by our membership.
No part of this publication may be reproduced, stored or transmitted in any form or by any
means without the prior permission in writing from the Municipal Association of Victoria.
All requests to reproduce, store or transmit material contained in the publication should be
addressed to the MAV on (03) 9667 5533.
The MAV does not guarantee the accuracy of this document's contents if retrieved from
sources other than its official websites or directly from a MAV employee.
The MAV can provide this publication in an alternative format upon request, including large
print, Braille and audio.
2
Introduction
The Municipal Association of Victoria (MAV) welcomes the opportunity to provide a brief
submission in response to the Department of the Environment and Energy’s `Review of
climate change policies’ discussion paper.
The MAV is the statutory peak body for local government in Victoria. Formed in 1879, we
have a long and proud history of representing and advancing the interests of all Victorian
councils.
Given the critical importance of climate change and the complexity of developing policies
that are effective and efficient, it must be said that the brevity of the discussion paper – 38
pages in total including cover pages, contents pages, appendices and multiple pages of
repeated text – is striking. The paper provides a brief high level overview of Australia’s key
emissions reduction policies and then notes the emissions contributions of five “sectors”.
Missing altogether is any detailed discussion or analysis of the relative merits of current or
possible policy settings, let alone any consideration of whether Australia’s emissions
reduction target of 26 to 28 per cent below 2005 levels by 2030 is appropriate.
Notwithstanding the clear inadequacies of the discussion paper, and the questions this
raises about how seriously the Government is taking the review, the MAV appreciates the
opportunity to raise some points of common interest to Victorian councils.
Climate change and the three tiers of government
In our view it is incumbent on the Australian and state governments to lead efforts to reduce
greenhouse gas emissions and to be at the forefront of adaptation planning and investment.
Clear, stable and appropriate policy settings and targets are critical in order to ensure
Australia continues to thrive whilst reducing our emissions and improving resilience to
climate change impacts.
Councils are committed to working collaboratively with other levels of government, industry
and the community to deliver outcomes that help support sustainable living and preserve the
environment for future generations. The effects of climate change and an increase in
extreme weather events are critical considerations in local government land use planning,
asset management and service delivery decisions. Councils continue to actively pursue a
range of renewable energy and energy efficiency initiatives, recognising that these activities
are both financially and environmentally beneficial.
In the absence of stable and enduring climate change leadership at state and national
levels, communities have often relied on local government to fill the void. Surveys show that
the current Australian Government’s position on climate change and clean energy lags
behind not only local government but also wider community attitudes and expectations.
Victorian councils have been supportive of the Victorian Government’s commitment to
positioning our state as a leader in responding to climate change. The State’s decision to set
emissions reduction targets and a renewable energy target was welcomed by the local
government sector. A recent survey undertaken by Wallis Research for the Victorian
3
Government found that 93 per cent of Victorians want the State to take action on climate
change and 84 per cent support the State’s renewable energy targets.
Previous Australian government programs such as the Community Energy Efficiency
Program (CEEP) have been critical in helping councils achieve significant emissions
reductions, including via installation of energy efficient street lighting. There are many more
projects that councils are keen to advance but struggle to do so because of lack of external
funding support. While councils are eligible to apply for funding under the federal
government’s Emissions Reduction Fund (ERF), very few have done so because they’re
unable to meet the minimum emissions reduction threshold and aggregation of projects is
considered too costly and complex to progress.
At the biannual MAV State Council meetings councils have adopted a range of resolutions
that are relevant to this review of climate change policies. Recent resolutions have called on
the MAV to advocate for:





Australian and state governments to develop and vigorously pursue integrated policy
frameworks targeting substantial reductions in carbon emissions
Australian and state support for the Workshop Statement on Implementation of the
United Nations Sustainable Development Goals in Australia
stricter controls in the national Air Quality – National Environment Protection
Measure (NEPM)
continuation of the moratorium on onshore unconventional gas exploration in Victoria
until any social and environmental impacts are definitively demonstrated not to be
detrimental; an appropriate level of community support is evident; and there is an
appropriate regulatory framework in place to ensure protection of the natural
environment, local communities, rural industries and private property rights
the provision of a community feed-in tariff to encourage, reward and support the
establishment of community solar projects.
Electricity generation
As noted in the discussion paper, there is currently an independent review underway into the
future security of the national electricity market (the `Finkel Review’). The preliminary report
of the Finkel Review makes a number of findings in relation to emissions reduction in the
electricity sector, including that:



current policy settings do not provide a clear pathway to the level of reduction
required to meet Australia’s Paris commitments
the Emissions Reduction Fund has not been successful at attracting large-scale
projects and the Safeguard Mechanism for the electricity sector is ineffective as it is
set well above the current level of emissions from the sector
the lack of clarity about emissions reduction policy beyond 2020 has been a major
contributor to the current investment uncertainty in the electricity sector.
The preliminary report also notes that the Government’s review of climate policy settings,
namely this review, is expected to clarify the electricity sector’s role in helping meeting the
2030 emissions reduction target. This is concerning given the total absence of discussion or
analysis in the discussion paper of the relative costs and benefits of possible policy
solutions.
4
We understand that a range of stakeholders, including independent experts in the energy
field, have recently expressed support for an emissions intensity scheme for the electricity
sector. We call on the Government to heed the advice of the Climate Change Authority, Dr
Alan Finkel AO and other credible independent expert bodies. There is an urgent need for
the Government to show strong leadership, to trust in science, and to support regulatory
settings that foster innovation and investment in clean energy. A steady, evidence-based
approach that has bipartisan support is essential.
Households, small to medium-sized enterprises and the built environment
The discussion paper notes that the energy efficiency requirements for new buildings and
major renovations are being advanced. We note that progress on this front has been
frustratingly slow and that unless genuine leadership is shown a substantial proportion of
buildings that are built over the next decade will, like much existing building stock, be
inefficient in terms of energy use, and certainly not in line with the global push toward zero
net emissions by 2050.
The expansion of the disclosure program for the energy performance of commercial
buildings is welcomed. The expansion of mandatory disclosure into residential buildings
should be progressed with urgency. The Victorian Government’s Residential Efficiency
Scorecard is a supported tool in delivering this for existing buildings. The use of similar tools
including the Built Environment Sustainability Scorecard (bess.net.au) should be considered
for use in disclosure related to new buildings.
In lieu of strong Australian and state leadership in legislating for energy efficient and low
carbon new building design, local governments have been working together through the
MAV and through the Council Alliance for a Sustainable Built Environment (CASBE).
Twenty-two councils have developed a framework that has been proven over 18 years to
deliver improved energy efficiency, reduced carbon emissions and more resilient buildings
for the wellbeing of the community.
Compliance with the building regulations including the requirements related to energy
efficient design is an area requiring further action. The MAV and CASBE councils have
assisted the Victorian Building Authority in this area. Strong leadership at a national level
should include clear messaging to the building industry that action will be taken against
those who are non-compliant.
Resources, manufacturing and waste
The discussion paper notes that the `resources, manufacturing and waste’ sectors account
for 28 per cent of Australia’s total emissions. No further breakdown is provided of each
sector’s contribution and there is no discussion or analysis of possible policy options to
achieve emissions reductions. With local government a key player in waste management,
we look forward to the Australian providing a credible discussion and analysis of possible
policy options.
5
Concluding comments
The sheer brevity and lack of discussion and analysis in the discussion paper is concerning.
Climate change is an international, national and local concern and Victorian councils want
and expect the Australian Government to develop policy settings that will ensure Australia
can reach zero net emissions before 2050.
It’s currently unclear what further consultation or action the Department of the Environment
and Energy intends to take prior to finalising the review by the end of the year. We call on
the Government to develop policy that is informed by credible science and to become a
leader in climate change policy.
6