Victorian Green Paper submission by Lighter Footprints

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Submission from Lighter Footprints Climate Change Action Group (working draft)


Victorian Government Green Paper on Climate Change


<Address 1>
<Address 2>


Lighter Footprints Spokesperson and Administrative Committee member

Lighter Footprints is a local climate change action group with 300 supporters from in and around postcode 3127 in Melbourne.

NOTE: This submission (when finalised) will be endorsed and authorised by Lighter Footprints and issued on behalf of our supporters.

This wiki article will be used to formulate the final Lighter Footprints submission to the Green Paper.

Members are encouraged to contribute to this paper as this is the only way we will get it prepared. Further discussion at next meeting in August.

Submission text follows.

Discussion of Vic Gov Green paper on Climate Change

The whole paper assumes that there will be a national CPRS which sets a price for carbon. This was seen as the major driver for change and that the Vic Gov could do little to set targets in it own right. It also seems that the state is positioning itself more at adaptive modes while the federal government with its revenue base is oriented to mitigation.

There is a strong argument for govt intervention – the market has failed!

It (the paper) outlines initiatives which are predominantly targeted at individuals i.e. encouraging solar power, energy reductions through voluntary measures etc which are unevenly distributed and only marginally effective in reducing state wide emissions.

In targeting the community, the govt is ignoring the huge contribution being made to climate change by the Victorian energy sector, specifically coal.

The green paper outlines a range of policy “levers” but fails to recognise that voluntary measures have allowed many industries and sections of the community to fail to address their contribution to emissions. As the paper itself acknowledges, climate change has now reached a point that catastrophic tipping points are very near or may have even been passed. There is no longer time to delay; action must be immediate and it must be effective. Therefore a strong instrument such as legislation to regulate emissions and treat CO2 as a dangerous and harmful gas is required. The negative aspects of legislative measures outlined in the green paper have no place in the consideration of measures when such urgency is required. Industries that have failed to prepare for a carbon cost have acted irresponsibly and must accept their failure to prepare to transition to low carbon economy was a commercial risk for which the consequences are their commercial reality.

The benefits of legislation are that it provides predictability for business; it provides guaranteed outcomes for the community (reduced emissions); it is an act of risk management for the state; and it promotes long term investment. It is fair, and it ensures accountability (provided it has strong reporting and auditing mechanisms included). Legislation also allows the govt to address any legislative inconsistencies that may interfere with compliance with the new regulations. An emissions reduction target is vital to provide long term climate certainty and certainty for investment in a low carbon economy. The advice to the govt from the premier’s climate change reference group outlined in the green paper appears to have been largely ignored. For example, the group advises the establishment of targets at the state level of: a peak in emission by 2010, emission reduction targets of 25-40% below 1990 by 2020, and 80% of 1990 levels by 2050. It also recommends the establishment of an aggressive energy efficiency strategy. The reference in the green paper to the global financial crisis only serves to underscore the importance of shifting our economy to a low carbon economy so we do not face another financial crisis when we reach peak oil, or when industries emitting CO2 are forced to suddenly due to global carbon trading. The modelling in the green paper does not take into account the potential for strong cuts as demonstrated by the recent Nous Group report. Demonstrating to the world the benefits of the new economy by investing in low carbon industries could lead Victoria and Australian out of the financial crisis and set us up as global leaders in low carbon technology. Leaders do not wait for others to act first, and you can’t get ahead of the pack by starting last. Victoria is extraordinarily vulnerable to climate change, therefore we should act swiftly. Levels of climate science literacy in the community are generally poor and govt needs to do a great deal more to explain the risks we face and the consequences of inaction, or inadequate action. Emissions reduction must be planned for here, regardless of national action – this is all part of accepting our historical carbon debt and addressing our fair share of carbon emissions reductions. With the insecurity of this or any CPRS getting up, the group decided to focus on those issues which are in the Vic government control, eg car emissions, registrations, etc. Pressing for changes to targets, such as the dropped election promise of 60% by 2050, would be less successful because of the unknown impact of any CPRS. Acknowledged that Vic should have a higher target than others because of our high brown coal dependence. Not sure how to pressure for separate emissions targets for Vic. The argument that the costs of targets are too high (p.30) just doesn’t wash – the costs will be much higher later.

The document addresses seven areas for discussion in part 3 of the green paper. These were outlined and the group looked at the ways that Government should be taking action.

Discussion highlighted the need to look at some of the work already done to show what would be feasible – like the McKinsey Report – eg it says that for a Gov expenditure of $300 per household, 30% reduction in emissions could be achieved. May revisit this report in writing up our response.

Transport (3.3)

This is described as having no simple solution which seemed to be quite wrong. It offers nothing in terms of modal shifts to trains which could achieve big changes. Concern that our lack of work in building rail means we’ve lost the skill. Other states esp WA, Qld are building rail so the skill is still in the country. Highlight that Vic must build more lines, and more rolling stock. They are doing this to some extent for freight, but have a long way to go for public transport.The green paper claims there is no simple solution to reducing transport emissions (p. 37) – this is untrue, California has done it very successfully and remains a thriving economy.


Need pressure to move through short term hybrid to electric. One mechanism that is easy to use and has not yet been proposed is differential registration of vehicles based on emissions levels – very much reduced for electric. Weight of car could also be a factor in registration. This can apply to freight vehicles as well –electric vans now available. Buy back scheme for old vehicles.

Clean Energy Industry (Stationary Energy Sector 3.1)

The energy sector is responsible for 67% of Victoria’s greenhouse gas emissions – therefore this is a good place to start cutting emissions. The CPRS will not reduce emissions as it currently stands. Want to see more action to take up solar and in particular wind energy, but also more local community co generation projects- keeping generation of power closer to communities that use it. Could refer to Boroondara and its trial for co-gen for pools. Need emphasis on Smart Grid for renewable energy. Are looking at smart meters for houses, and this should be an associated project. Must keep up pressure on getting out of coal as the biggest energy provider, and supporting alternatives.

Look at freeing up provision of permits particularly for wind power.

The govt should be focussing on the opportunities offered not procrastinating and delaying.

Transforming the energy sectors over several decades (as proposed on p. 34) will not avert dangerous, irreversible climate change. The Green paper has failed to document the consequences of excessive carbon emissions.

We may have to just walk away from coal.

Energy Efficiency (3.2)

Needs to be beefed up. Most powerful contributor is insulation and double glazing and draft stripping (back to McKinsey). Support for house audits, and commercial as well and local communities assisting. Need more incentives.

Built environment (3.4)

Address expanding city boundaries and re-iterate need for denser living esp along transport corridors and around rail for activity centres. The issue of building standards for both houses and other buildings must be addressed - currently unacceptable.

Go beyond 5 star, and insist that they address passive solar issues of aspect as well as insulation and other fundamentals.

Planning of the built environment is poor – innovative options exist but are not being utilised, but must include strong regulations of emissions standards.

Forest policy (3.6)

To be discussed further.

Land use

Need to consider land use (p. 44) for emissions cuts (e.g. carbon sinks). Need to see significant investment in planting trees, improved land management, stopping deforestation.


Waste management – need to mandate recycling; tax non-recyclable materials; subsidise recycling of all materials. Need to look at cradle to grave product regulation.

Green jobs

Carbon leakage is unlikely because: the costs of relocation are very high; there will be lack of skilled labour; will only delay the onset of carbon price for short time. Need more funds for innovation (and implementation) research. Need more incentives for businesses (p.56) to cut emissions. Shifting to renewables is the best thing we could do for the Latrobe Valley (p. 58)in terms of long term job security.


Water security is already a huge problem, making action on climate change mitigation even more important for Victoria.

Other points

Insurance projections and liability risks are not being considered inGreen Paper .

Some sectors are completely ignored in Green Paper – all are important in reducing emissions, including transport, manufacturing, IT, logistics, food, health, education tourism, and the arts. Govt must outline policy for each sector and identify the responsible government department. Climate change requires cross sectoral, cross departmental responses.

Overall the idea of talking to the community about Climate Change needs more attention. Look at US precedence here. (Peter Campbell to follow up). Also we will revisit the ClimateCare proposal as part of our response to this issue for the green paper.

There was a view that Victoria could become the advocate for the rest of Australia.

In addition a proposal for a climate change bill will be worked on. This may be broad and consist of a vision and principles but may also include some of the points raised here. This element is being worked up separately at this point ( in conjunction with FOE and CEN) but will come together before we finalise out response in September.

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