Our Submission: Draft Climate Action Plan

CoverBelow is the full text of our submission responding to the state governments Draft Climate Action Plan.

The finalised Action Plan was due for release in September 2016, however this launch has unfortunately been postponed to the end of the year – to take into account information from the Energy Security Taskforce and other government processes.

Submission by Climate Tasmania
on the Tasmanian government’s Draft Climate Action Plan (Embracing the Challenge).
22 March 2016


OVERVIEW


1.1 Introduction
Climate Tasmania welcomes the Tasmanian Government’s initiative to release the Draft Plan for public consideration. We especially welcome the extensive time made available ahead of the deadline for submissions. This is a very complex subject demanding a lot of thought and consultation.

Much of the following Overview is critical of the existing Draft Plan, but Climate Tasmania is firmly of the view that a positive outcome of this process is eminently achievable with a mutually cooperative approach, and offers itself to work with Government to achieve such an outcome. The final section of this Overview (1.4, Tasmania as a climate leader: the possibilities) is therefore focused on what can be done to make Tasmania a vibrant centre of excellence in climate action.

1.2 Lack of abatement action in the Draft Plan
CoverClimate Tasmania is concerned that the Draft Plan minimises the seriousness and urgency of Tasmania taking action on climate change and understates Tasmania’s true emissions footprint. We are also concerned that while the Plan claims the mantle of ‘global leadership’ for Tasmania, it contains very few abatement actions.

We have seen already this year the severe economic, social and environmental consequences for Tasmania of drought, wildfire and flooding. It is no longer tenable to consider these events as ‘natural’ disasters, given that the central prediction of anthropogenic climate change science is an increasing frequency and severity of extreme climatic events.

Much of Tasmania’s industry is directly and negatively impacted by climate change, including its agriculture, forestry and marine farming, its high-value and speciality- branded products, and tourism. Many Tasmanian jobs are at risk.

The Draft Plan lists 51 possible ‘actions’ to respond to climate change. Yet not a single one of these items would directly lead to reduced greenhouse gas emissions. Many reflect a continuation of business-as-usual. Collectively they amount to a wholly inadequate response to the urgency and strategic importance of this issue for Tasmania.

The Draft Plan’s proposed actions for ‘maximising our energy advantage’, ‘market led growth’, ‘advancing the case’, ‘consider facilitation’ and similar phrases suggest a lack of commitment to concrete action. The Government proposes leaving the transition from internal combustion engine vehicles to electric vehicles to ‘market forces’, but this fails to acknowledge that for such a significant paradigm shift some infrastructure investment will be needed. Even if much of this investment turns out to be private, that will still require a government ready to facilitate such a transition.

By way of example, Tasmania already has a shortage of renewable electricity relative to its demand. Clearly this shortage will be exacerbated by a shift from fossil fuels to electricity for the transport task. Therefore, if actions to encourage EVs are not accompanied by actions to promote renewable energy generation, the net result of this shift could be an increase in total greenhouse gas emissions, as more electricity is imported from Victoria.

1.3 Tasmania as a climate leader: the present situation
There is no credibility in claiming a position of global leadership without supporting evidence, as in the statement that ‘Tasmania is already a genuine global leader in the response to climate change’.

The headline claim in the Draft Plan that Tasmania has ‘low net emissions’ is in fact the result of two vastly different trends and components. Since 1990, annual emissions relating to energy have risen by 748,000 tonnes (20%), a change at least six times greater than the relatively small changes in emissions associated with industrial processes, agriculture and waste.

Overall, emissions from these four sectors, which have been very largely unmitigated by any abatement actions over that period, have risen by 7.2% between 1990 and 2012-13. Only in the waste sector has there been deliberate effort to reduce emissions, for example via methane capture.

Reporting requirements under the revised Kyoto Protocol now require signatories to include emissions from forest management. Combined with the collapse of forestry activity in Tasmania since around 2007, this has caused emissions associated with land use, land use change and forestry to dramatically change from net emissions of around 7 million tonnes CO2-e in that year to net sequestration of a similar amount in 2012-13.

The Draft Plan incorrectly attributes this reversal to ‘changes in our forestry management practices’, while its statement that ‘Our per capita emissions are amongst the lowest of any reporting jurisdiction in the developed world’ is mainly a result of a change in international emissions accounting rules and the collapse of Tasmania’s woodchip industry. These factors masked a rising trend in emissions from other sectors of the economy.

It is misleading to cite low total per-capita emission values which cannot in any way be attributed to past or present climate policies or behavioural change. The Draft Plan implicitly relies on continuing weak economic activity in forestry, while the Government is at the same time actively promoting growth in that sector. To the extent that Government succeeds in this, and/or there are favourable changes in international commodity prices, the past reduction in net emissions will be just as quickly reversed, in the absence of significant abatement action by Government.

It is untenable to use the vagaries of international woodchip markets to underpin an economy wide climate change strategy. Instead, Tasmania needs an abatement strategy that is conscious, considered and robust in the face of market and other contingencies.

Similarly, while Tasmania has a high share of renewable energy, this reflects decades old ‘hydro-industrialisation’ policies, while the small number of wind power developments in Tasmania have been driven by Australian Government policy settings, notably the national Renewable Energy Target. None of these factors reflects a Government decision or policy with any connection to climate change mitigation.

Tasmania is losing ground on renewables. We have pursued an energy policy which deliberately relied on importing electricity from Victoria to meet shortfalls. Emissions from Victorian brown coal power, with the highest greenhouse intensity of any electricity in Australia, are technically attributable to Victoria but are directly caused by Tasmania. This further clouds our real emissions profile.

In importing Victorian coal-fired electricity, and also importing fossil transport fuels, Tasmania also becomes a victim of economic leakage, whereby we routinely pay for goods and services brought in from outside, in return for which payments we receive little or no funds which might be recycled back into the Tasmanian economy.

1.4 Tasmania as a climate leader: the possibilities
Despite the above, Climate Tasmania believes there are huge possibilities open to the Government if it acts decisively on its headline aim of ‘embracing the climate challenge’. We submit that a cooperative effort can deliver an action plan able to meet that challenge, while also demonstrating genuine leadership by the Government.

Climate Tasmania supports the Draft Plan’s call for a focus on practical actions that should be prioritised over the next five years, starting immediately. There are many practical, effective, cost-effective and strategic actions readily available and proven in other jurisdictions. Risks associated with these measures are relatively very low, while the risks of inaction are very high.

Focusing on the urgent implementation of such practical actions will help to build wide community recognition of and support for the necessary changes, but will also move the discussion on from divisive and unproductive debates about climate science.

Stopping economic leakage and strengthening the local economy are key benefits of strong climate action. The emissions-reducing actions recommended in Parts 2 and 3 of this submission have that important dual benefit: while mitigating climate change they also strengthen the Tasmanian economy, and also improve energy security.

In broad terms we believe the Draft Plan should articulate the strategy and the measures that would make Tasmania a world leader in climate change knowledge, mitigation and adaptation activity. We believe it should commit Tasmania to achieve carbon neutrality in the latter half of this century.

Tasmania can become a globally recognised centre of excellence in climate change governance, whereby both economic development and economic security are achieved by fostering best practice in local emissions reduction and leading innovation for an adaptive and sustainable society.

Such a paradigm shift will require realignment of Tasmania’s energy and economic policies with climate policy to focus on global risk, change and opportunities, basing all government policies and actions on principles of sustainability, resilience and effective adaptation.

It calls for programs to develop, expand and deliver ecologically sustainable renewable energy and agriculture, including comprehensive conversion of Tasmania’s car fleet to electric vehicles and incentives for uptake of distributed (household and business) electricity generation and storage, to help build a more secure power supply system and deal with economic, climate and water supply variability.


RESPONSE TO QUESTIONS


Q1: What practical actions should we prioritise over the next five years in our response to the issue of climate change?

2.1 Renewable energy
Tasmania’s share of Australian renewable energy has been trending down for well over a decade. While the Draft Plan recognises renewable electricity’s key role in creating Tasmania’s low carbon strategic advantage, it fails to acknowledge that declining share and fails to articulate any policies or a strategy to reverse that trend. A lack of attention to investment in non-hydro renewable energy has increased our dependency on Victoria for dirty electricity, threatening our energy security and our reputation as a clean, green state.

In contrast, other jurisdictions including the ACT, SA and Victoria have shown much greater commitment to and success in expanding renewable energy production, including such initiatives as reverse auctions, renewable energy targets, direct investments and investment campaigns.

All states, however, have reduced their support for smaller scale renewable energy via feed-in tariffs. In Tasmania’s case that support has been slashed by 80%, which has reduced incentive to invest in this form of renewable energy generation at a time when drought and the Basslink interruption have so clearly highlighted the fact that Tasmania generates less electricity than it uses. The willingness of Hydro Tasmania to pay exorbitant costs for temporary diesel generation demonstrates the need to restore a fair and reasonable level of feed-in tariff. Had that earlier policy been in place, it would – at much lower cost than is now being incurred for diesel generation – have delivered a more diversified energy supply and lower costs for households, as well as lowering our greenhouse gas emissions.

A feed-in tariff should reflect appropriate values for the opportunity cost of energy in a distressed system (witness the current pool prices and the costs the Government is willing to incur to generate from highly-polluting diesel generators); and for avoided transmission costs; and for avoided greenhouse gas emissions (noting that Basslink’s operation means that the marginal unit of electricity consumed in Tasmania has the same greenhouse intensity as Victoria, the highest of any grid-based electricity in Australia).

A fair and reasonable feed-in tariff is fundamental to a credible Action Plan, because the state’s economic thrust is to attract new industry to the state on the basis that they can take advantage of low carbon power supply. It also must be recognised that reducing imports of electricity along Basslink will reduce economic leakage to the Victorian electricity generators. Of course, action should also be taken to encourage utility scale renewable energy generation as well, as set out below.

We recommend consideration of the following:

  1. Establishment of measures in the very short term to create the appropriate conditions and incentives under which largely private sector investment in new generation capacity can occur to ensure the short term target under Q3 below is met.
  2. An immediate lifting of the feed-in tariff for smaller scale renewable energy generation in Tasmania so that it provides a fair and reasonable return on investment and reflects the public goods associated with that additional embedded generation, to a minimum of 15 cents per kWh (a little over half that which applied until 2013);
  3. Expansion of the maximum size for feed-in tariff purposes from 20kW to 100 kW installed capacity, reflecting the opportunity to encourage community-owned and larger commercial-sector renewable energy generation.
  4. Direction to TasNetworks to connect all such investments with mandated minimal delay, provided only that the connected equipment meets required technical and safety standards, at a nominal price (without any attempted recovery of theoretical ‘deep connection costs’ used by the network sector to discourage generating competition).
  5. Direction to Hydro Tasmania, TasNetworks and Aurora Energy to encourage, support and/or partner with private and community renewable energy investment while removing all investment barriers inherent in policies, practices, decision- making and pricing, and to deal with all renewable energy project proponents, large and small, and the wider public in an open, transparent, equitable and timely manner.

2.2 Manage climate risks, including fire
The current Government, as with its predecessors, consistently underestimates the physical, economic and strategic risks to Tasmania arising from climate change while overestimating economic benefits. While it acknowledges that Tasmania is exposed to the detrimental impacts of climate change, the Draft Plan notes that ‘these risks can be managed, provided we prepare for them adequately’ with reference to a fuel reduction plan and other existing fire awareness plans.

The implication is that these measures amount to a complete and adequate strategy to respond to climate risks. But we have seen this summer that uncontrollable wildfires have done as yet uncalculable damage to non-fire-adaptable wilderness which underpins Tasmania’s brand, its tourism industry and its unique ecology.

The call by the Senate for an inquiry into the management of the 2016 summer fires challenges the Draft Plan’s view that we are prepared for and appropriately managing the risks of climate change, and that Tasmania will be less impacted by climate change than other places. We are unaware of any science that supports such a contention.

It is gratifying that Tasmania introduced planning tools related to coastal inundation and erosion, including a planning allowance for sea-level rise, in 2012 and 2013. However, it is imperative that these are updated in line with the evolving science and are increasingly incorporated into Government decision-making.

We recommend that the Government develops a comprehensive climate adaptation plan relating to climate hazards, including bushfire. This should incorporate:

  • the State’s response to the 2015-16 summer fire emergency with a view to clearly establishing the extent of this risk and the shortcomings of our response to date;
  • risks and limitations of Hydro Tasmania’s power output;
  • recent disease problems experienced by marine aquaculture industries; and
  • risks associated with sea-level rise based on current science.

2.3 Initiate new simulations of future climate variability and change for
Tasmania

Effective adaptation to climate change relies on knowledge of future climate on a range of timescales, and this information is lacking, outdated, or not targeted for Tasmania.

Climate change is changing the frequency and intensity of extremes, such as the drought which is contributing to current energy security issues. We need targeted forecasts of climate variability for Tasmania on the 1-10 year scale to allow industry and environment to prepare for, and manage, periods of extremes.

We also need updated projections on longer (multi-decadal) time scales targeted for Tasmania. Climate Futures for Tasmania (CFT) was a modelling study that simulated future climate over Tasmania. Participants included the Antarctic Climate & Ecosystem Cooperative Research Centre, CSIRO and Hydro Tasmania. A number of technical reports were produced over the years 2010 to 2015; these are the only high- resolution projections that we have for Tasmania. Unfortunately, the results were based on the science of the 2007 Fourth Assessment Report of the Intergovernmental Panel on Climate Change (IPCC), and are now getting rather old.

A revived and improved phase of CFT is now required based on the latest science and using the current generation of supercomputers.

2.4 Active transport
Tasmanians spend well over $1 billion annually on petroleum products: the largest leakage from the state’s economy. Measures to reduce petroleum usage discussed in the next few sections will reduce that leakage and thereby strengthen the Tasmanian economy.

Walking and human-powered cycling are essentially emission-free, while an electric bicycle uses only about one tenth of the energy of a car. In addition, these modes of transport, which may be used for both commuting and leisure, confer significant health benefits.

The Draft Plan should therefore include measures to actively facilitate and promote walking and cycling through the provision of appropriate infrastructure, including physically separated bike lanes and greater priority for pedestrians and cyclists. These measures will also encourage the evolution of less car-dependent, more compact and more liveable urban centres.

2.5 Public transport

  1. Public transport offers a major opportunity to reduce transport-related greenhouse emissions. Service quality and affordability are the keys to attracting numbers of people to public transport. Measures to achieve this goal should include:
  2. greater number of services and a regularly upgraded bus fleet to preserve and enhance a public perception of attractive, efficient and comfortable services;
  3. enhanced electronic information services such as ‘next service wait time’ information in real time at all bus stops and via smartphone apps;
  4. greater use of bus lanes and priority for buses at traffic lights;
  5. attention to affordability and value for money, particularly of longer services; 5 flexible routing using technology such as smart phones and GPS;
  6. forward planning towards an eventual choice of transport mode technology for switching Metro’s public transport fleet to electric power, including a targeted timeframe to initiate and accomplish this task; and
  7. active support for alternative forms of public transport, including light rail and ferries.

2.6 Electric vehicles

The motor vehicle market is already changing rapidly. Research by Bloomberg New Energy Finance (published 25 February 2016) indicates that by 2040 global sales of electric vehicles will be almost 90 times the 2015 level, representing 35% of light vehicle sales. Bloomberg estimates that by that year they will amount to a quarter of all cars on the road. Tasmania needs to prepare early for what will amount to an EV revolution.

Electric vehicles comprise far more than just cars and buses. They can include bicycles, boats, a wide range of commercial vehicles and even aeroplanes. Each of these sectors requires carefully crafted policies to maximise the future benefit to Tasmania, possibly through manufacture as well as usage.

We submit that the Government should:

  1. 1 Actively promote the uptake of electric and fuel efficient vehicles while discouraging the uptake of inefficient vehicles by applying a ‘feebate’ scheme to vehicle registration charges and stamp duty. Well-designed feebates can be revenue neutral by transferring registration and stamp duty costs from high efficiency/low carbon to low efficiency/high carbon vehicles.
  1. 2 Ensure that a substantial Tasmania-wide EV public charging network is installed by 2020. Today’s charging units can accommodate all connector types with multiple connectors, so units can be installed with reasonable confidence that they will meet vehicle needs well into the future. We submit that the government should support any private initiative to get a basic network on trunk routes started, while also helping to complete the network by subsidising charging stations for other routes.

2.7 Major infrastructure
The huge amount of public money spent on infrastructure projects – a significant proportion of total public spending – has by far the biggest impact on the state’s future transport, and is locking Tasmania into unsustainable patterns of urban development that would be difficult to reverse.

The prioritising and funding of infrastructure projects are undertaken with minimal public consultation, contrary to the spirit of a recent pronouncement from the Prime Minister’s office in early March 2016 seeking ‘better outcomes from public infrastructure investment, including opportunities for urban renewal and regional development’. Tasmania should be replicating the current trend in major Australian cities to think beyond very expensive engineering solutions to urban transport.

Besides being more transparent and open to public discussion, all significant public and private infrastructure projects should be subject to thorough climate impact assessments under statutory processes.

2.8 Saving household energy
We submit that the Government should continue and significantly enhance household energy conservation programs, on the model of recent programs funded by state and federal governments. Tasmania’s housing and building stock performs poorly in terms of energy efficiency and there is great scope for improving liveability of homes and reducing energy use. The greatest energy reductions can be achieved by targeting high energy use households but equity will demand that low income/low energy users also be able to access programs.

2.9 Divestment
The greatest potential weapon available in the battle to reduce fossil-fuel use is the transfer of investor funds out of coal, oil and gas projects and into renewable energy and related development, such as electrified transport and battery R&D. It is recommended that the Government require all its investing agencies to pursue a process of divestment from all fossil-fuel businesses in accordance with procedures currently operating in other jurisdictions and government agencies, including the Australian National University.

Q2: What targets, both legislated and policy driven, should Tasmania adopt in pursuing our greenhouse gas abatement effort?

It is clear from the large apparent change in Tasmania’s emissions over the past decade, driven almost entirely by forest management accounting, that no climate change action plan is complete without an accompanying and consistent forest strategy; this should be developed now and integrated with the action plan.

2.10 Overall emissions target
In order for global temperatures to be constrained below 2 deg. C above preindustrial (the upper limit of commitments at COP 21), global emissions need to approach almost zero during the latter half of this century (a simple and clear discussion of the ‘carbon budget’ is given at www.wri.org//ipcc-infographics). Given that there are presently no conceivable methods of drawing greenhouse gases out of the atmosphere in sufficiently large quantities over long periods of time, it follows that the emissions of each sector of the economy also need to approach zero during the latter half of this century. This leads to an overall ‘long-term’ target for every sector of the economy of near-zero (say 1% of current) emissions by some prescribed year (say, 2080). It is recommended that this approach be taken for Tasmania.

At COP-21 there was recognition that a more stringent target of 1.5 deg. C may be necessary, in light of the current climate impacts occurring globally. In the near future, emission targets may need to be more ambitious so any interim targets set for a 2 degree warming should be seen as our least ambitious pathway. In addition, it is generally accepted that the developed world should make deeper and faster emission cuts than the developing world (the ‘contraction and convergence’ principle). This, and our aspiration to be a ‘world leader in the response to climate change’, are good reasons to seek even more ambitious targets.

An important element in establishing targets is a need to embed in abatement policy an acceptance that under the State Government’s vigorous economic growth strategy Tasmania’s electricity consumption, transport needs and waste production will inevitably rise to new levels, thus requiring a higher level of carbon abatement than current emissions would call for in order to achieve the above reductions.

2.11 Short-term sectoral emissions targets
Following the arguments of Section 2.10, it makes good sense to prescribe short-term emissions targets for each significant sector of the economy (e.g. transport), so that no sector gets left behind as its emissions are reduced, and no sector gets a ‘free ride’ because it appears to be doing well (e.g. the misleading case of the Tasmanian forestry sector over the past few years).

This leads to a simple and transparent method of defining sectoral targets and an illustrative example is given here. Suppose that one sector presently (i.e. in 2016) has emissions of 1000 Gg pa of CO2-equivalent and that it is determined that these need to reduce to near-zero in 2080, then a simple linear reduction of emissions over the 64 years would yield a 2020 target of 1000 x 60 / 64 = 937.5 Gg pa or a 6% reduction relative to 2016.

Although the ‘carbon budget’ approach is based on roughly linearly reducing emissions, each sector need not strictly obey such a relationship. However, if one sector lags behind and ‘overshoots’, other sectors need to reduce emissions faster in order to compensate. In any event, the individual sector trajectories should be prescribed and transparent. It is recommended that short-term sectoral targets be prescribed across the whole economy at a five or ten year interval, with reporting and review of progress on a similar time scale.

2.12 Transport energy targets
Consistent with the above, we submit that the Government should set five-year targets for (a) transitioning to electric private vehicles; (b) development of cycle and pedestrian routes; (c) upgrading and further development of public transport services. The ultimate aim should be underpinned by a graded and targeted annual reduction of imported petroleum fuels.

2.13 Renewable energy target
(See under Q4 below.) We submit that the Government should set a 2020 target for 100% renewable electricity consumption on a net basis. That is, if any imports occur across Basslink, these must be at least fully offset by a similar volume of exports, on an annualised basis.

2.14 Energy saving targets
We submit that the Government should set a binding, legislated target each and every year (Energy Savings Scheme or similar – see under Q4 below) for electricity, gas and coal consumption savings in Tasmania of at least an additional 1% point of a historical benchmark (eg, 2014-15), supported by a proven and cost effective scheme to ensure these targets are met every year.

2.15 Community education targets
The Tasmanian community has never benefitted from clear, comprehensive and authoritative information from government about the facts of climate change and what it means for Tasmania. At the same time, there has been a great deal of disinformation circulated in some media. Added to this is an enticement complacency implicit in the often-repeated message that Tasmania is already ‘clean and green’.

All this makes it unlikely that the majority of the community understands what is actually at stake and why we need to take genuine, strong abatement actions. It follows that most Tasmanians would be disinclined to participate actively in such actions.

The Tasmania Government should accept that it has the responsibility to appropriately inform and educate the community, to set targets (such as ‘when asked, 90% of Tasmanian’s agree that climate change is caused by humans and a serious problem for Tasmania’) and to commit to a detailed and sustained multi-media campaign until the target is reached. The Government could exercise genuine leadership by the Premier and relevant Ministers participating personally in this communication campaign.

Q3: How can our natural advantages best be used to maximise Tasmania’s contribution in the effort to combat climate change?

Few abatement or adaptation measures can be implemented without cost. Dealing with major industrial emissions will require expensive interventions, while there will also be significant costs involved in adapting cities, buildings and infrastructure to inevitable climate change. In some cases, these costs may be reduced by Tasmania’s natural advantages. Where abatement reduces economic leakage, there will also be long-lasting benefits to the Tasmanian economy.

2.16 Renewable energy
Put in place a policy framework that encourages investment in community-scale or larger wind and solar energy generation, and where necessary fast-tracks such development. Increase the domestic feed-in tariff to 15c/kWh and allow an installed capacity of 100kW to encourage greater take-up of domestic rooftop solar PV.

2.17 Electric transport
In conjunction with a renewed push to develop renewable energy resources, and recognising the exceptionally high proportion of Tasmanian emissions from the transport sector, put in place measures to encourage Tasmanians investing in new vehicles to make the switch to fully-electric. Such measures will need to include either direct state investment or strong financial incentive for private investment in EV charging facilities throughout the state.

2.18 Primary industry sector
Undertake a thorough risk analysis across this entire sector, recognising that 1) agricultural activities are a major cause of emissions, 2) some existing farm and fisheries operators are already suffering hardship as a result of drought and climate extremes and 3) that a warming climate may advantage the growing of some crops whilst displacing others.

2.19 Tasmania as a global centre for climate research
Tasmania is a global centre for climate research, with CSIRO, the Antarctic Division, the Antarctic Climate & Ecosystems Cooperative Research Centre and the University of Tasmania providing numerous contributions to the scientific and technical literature, including the IPCC Assessment Reports. It is important that the Tasmanian Government continues to foster this resource and to ensure that local climate studies benefit from this concentration of scientific expertise, and that it actively advocates for the state’s interests in this regard. In particular, and as noted earlier, the time is ripe for a revived and improved phase of the Climate Futures for Tasmania project.

2.20 Ancillary benefits of abatement
The Draft Plan should acknowledge that when communities engage with actions to reduce emissions, a range of ancillary benefits follow for the community. Such abatement can be promoted on grounds of lower household energy bills through energy conservation and solar energy, improved comfort, greater business competitiveness, greater fuel-efficiency, and greener and more liveable cities with improved transport options, a higher level of state energy security (power supply and fuel security) and greater social cohesion and resilience. These benefits should be highlighted in the communications campaign described above.

Q4: What amendments or enhancements would you propose to the Climate Change (State Action) Act 2008 to ensure that Tasmania is responding effectively to the issue of climate change?

2.21 Targets
Legislate targets as outlined under Q2 above.

2.22 Energy-saving scheme
Legislate for an energy-saving scheme (ESS in NSW, VEET in VIC, REES in SA or EEIS in ACT) to give substance and effect to the energy efficiency target. As suggested in the National Energy Productivity Plan (December 2015), ensure the scheme is fully harmonised with one of the existing state schemes, and if possible capable of being administered by agreement with another state, reducing administrative costs for Tasmania as well as the required start-up time.

The scheme must cover both residential and commercial energy use, and electricity and gas at a minimum (including minor fuels such as LPG, to avoid creating fuel substitution incentives).

2.23 Major industrials
Mandate independent audits of every major emitting facility, identifying scope of abatement opportunities and associated costs.

Legislate under the Energy Savings Scheme or related legislation to provide that all opportunities with a two-year payback or less must be implemented within three years (or the enterprise will face significant financial penalties), and all opportunities with a 2 to 4 year payback must be implemented within five years.

As these opportunities are cost effective for the businesses concerned, no financial incentives would be appropriate or necessary.

2.24 Reverse auctions
Establish reverse auctions for large scale but high cost/long payback abatement opportunities to ‘buy down’ the cost of securing these abatement opportunities from the private sector, without risking harm to these major enterprises.
Note that such a process could be treated as a last resort after private sector, CEFC, ERF and other funding has been sourced. This will require further legislation beyond specific climate legislation.

2.25 Administration
While it has been useful having administration of climate policy residing within the Department of Premier and Cabinet, that does constrain the size of the administrative body, the current Tasmanian Climate Change Office, and makes for some awkward ministerial arrangements. There is a long term need to augment the TCCO expertise to address an expected increase in demand for information and policy services covering both adaptation and emissions reduction.

We submit that administration of climate policy should have its own portfolio and department, and recommend:

  1. creation of a Department for Climate Action committed to leading excellence in climate change adaptation and mitigation, and
  2. appointment of a Minister for Climate Action, responsible for leading the development of Tasmania as a global leader in climate change knowledge, mitigation and adaptation activity.

2.26 Legislation

At present, the Climate Change (State Action) Act 2008 (CC(SA) Act) contains no enforceable or binding legal obligations in respect of climate change. This is especially problematic since Tasmania also lacks a comprehensive framework for environmental impact assessment of major decisions. It is imperative that climate change assessment is incorporated into policy, relevant legislation, conservation and land use planning, and all major infrastructure activities.

One option would be to amend the statutes under which major decisions are made or actions authorised that either have a significant impact on Tasmania’s mitigation efforts, or that will themselves be affected by the impacts of climate change. This would create a burdensome task of legislative amendment, and may not capture the full range of statutes. A preferable, approach, therefore, would be to amend the CC(SA) Act so that it imposes a climate impact assessment obligation on decision- makers or officers taking decisions or actions prescribed in regulations. Using regulations would give the list greater responsiveness to new circumstances. The CC(SA) Act should also stipulate the process for undertaking a climate impact assessment (CIA), while regulations should outline the default minimum content of such an assessment. For completeness, section 74 of the Environmental Management and Pollution Control Act 1994 should also be amended to explicitly require climate impacts to be considered as part of any environmental impact assessment.

Climate impact assessments should consist of two elements. The first should be an assessment of whether the proposed activity will contribute directly or indirectly to Tasmania’s mitigation effort or whether it will actually increase greenhouse gas emissions. Where a proposed activity is likely to be ‘carbon positive’ there should be a requirement to use best available technology, and where emissions are unavoidable, the use of offsets to achieve at least no net emissions.

The second element is an assessment of whether the projected future impacts of climate change are likely to place the project or activity in jeopardy, undermine its overall effectiveness or cost-effectiveness, or lead to the activity creating potential hazards for human health or natural values. For example, conservation measures will need to demonstrate that they have considered the impacts of future climate range shifts and other climate impacts on the likely effectiveness of strategies and actions to achieve specified goals. Activities or new infrastructure in coastal hazard areas or in high bushfire-prone areas should only be considered if they build in plans for retreat and relocation or other measures.

An indicative, but by no means exhaustive list would include:

  • Development of the Statewide Planning Provisions, Local Provisions Schedules, regional land use strategies and planning directives, and assessment of development applications under the Land Use Planning and Approvals Act 1993;
  • The preparation of State Policies under the State Policies and Projects Act (SPP Act);
  • Integrated impact assessment under the SPP Act;
  • Development and implementation of management plans for protected areas under the National Parks and Reserves Management Act 2002 and the Nature Conservation Act 2002;
  • Development of strategies and actions under the Weed Management Act 1999;
  • Threatened species strategy development and conservation measures under the Threatened Species Protection Act 1995;
  • Environmental impact assessments and the issuing of Environment Protection Notices under the Environmental Management and Pollution Control Act 1994;
  • Allocation of fisheries licences and development of guidelines under the Living Marine Resources Management Act 1995;
  • Development and amendment of marine farming development plans under the Marine Farming Planning Act 1995;
  • Certification of forest practices plans and development of the Forest Practices Code under the Forest Practices Act 1985;
  • Planning for significant infrastructure under the Major Infrastructure Development Act 1995; and
  • Assessment of tenement applications and development of codes of practice under the Mineral Resources Development Act 1995.

The statutory framework for CIA should require that CIAs are made publicly available and that the decision-maker must expressly have regard to the Assessment document. Given that a CIA requirement of this sort is intended to impose a binding obligation on Ministers, agency officers and local government decision-makers to consider the climate implications of their action or decision, it should be backed up by the inclusion of open third party standing laws, to ensure that there is accountability and scrutiny.

In addition to this broad CIA amendment to the CC(SA), it may be appropriate to amend the Mineral Resources Development Act 1995 to expressly ban future fossil fuel exploration and exploitation. In particular, the current moratorium on hydraulic fracturing to identify and exploit hydrocarbon resources should be extended indefinitely and given legislative effect.


EMBRACING THE CHALLENGE


The extracts from the Draft Plan below are among many seeds contained in the document from which a thoroughly forward-thinking strategy can grow, in which Tasmania’s economic advancement is – and is seen to be – in lock-step with developing a resilient and sustainable community.

FROM Embracing the climate challenge: Tasmania’s draft climate change action plan 2016-2021:

Page 1 — “Tasmania has the potential to be the best in the world when it comes to responding to this issue. That is our aspiration. That is our challenge. And that is also our opportunity. …a future low carbon economy can help deliver Tasmania increased investment, jobs and economic growth.”

Page 4 — “Our aspiration is for Tasmania to be the best in the world in responding to climate change, renowned for our renewable energy expertise and our world class science and research, and prepared to meet the challenges and seize the opportunities climate change presents.”

Page 4 — “The global shift towards low carbon and sustainable products and services provides a clear opportunity for Tasmania. Our status as a low emitter of greenhouse gases will enhance our reputation as an attractive place to do business as the world begins the transition to a low carbon future.”

Page 5 — “If Tasmania embraces the challenge of climate change it can enhance its natural liveability advantages and increase its appeal as an attractive place to live, work, invest and raise a family.”

Page 7 — “We have many natural advantages which afford Tasmania the opportunity to be a genuine world leader in the response to climate change. This is an opportunity we must embrace. Not only can it enhance our clean brand by ensuring we are at the forefront of the transition to a low carbon world, we can position our economy to maximise the opportunity for investment and growth, which in turn can help secure our future prosperity.”

Page 18 — “With other nations, states and regions already working fast to prepare their electricity grids for future changes, Tasmania must act now to capitalise on its early- mover status in renewable energy. It is the ideal time to prepare for increasing our renewable energy production… and to invest in technology that helps reduce our reliance on energy imports to secure Tasmania’s position at the frontline of renewable energy expertise.”

Page 35 — “…the Government is developing a suite of planning policies that, in combination, will provide strategic guidance in the planning system for future settlement and growth that is supported by efficient and sustainable transport and infrastructure, and meets the current and future needs of communities.”

Climate Tasmania accepts that the Government’s aspiration ‘to be the best in the world’ in responding to the issue of global climate change is sincerely stated. However, the present Draft Plan does not give effect to this aspiration. Following is a list of recommendations, arising out of Part 2 above, which would achieve that outcome.


Our Recommendations


Our thirty nine specific recommendations.
[Note: Bracketed text at the end of each subheading refers to the relevant Draft Plan question.]

Renewable energy (Question 1)

  • Immediately establish measures to create conditions and incentives sufficient to enable private sector investment in new generation capacity to ensure that the short-term target under Q3 below is met.
  • Immediately lift the feed-in tariff for smaller scale renewable generation in Tasmania to provide a fair and reasonable return on investment and reflect the contributed public good, to a minimum of 15 cents per kWh.
  • Expand maximum size for feed-in tariff purposes from 20kW to 100 kW installed capacity.
  • Direct TasNetworks to connect all such investments with minimal delay and at a nominal price.
  • Direct Hydro Tasmania, TasNetworks and Aurora Energy to encourage, support and/or partner with private/community renewable investment while removing investment barriers in policies, practices, decision-making and pricing.

Manage climate risks, including fire (Q1)

  • Develop comprehensive climate adaptation plan relating to climate hazards, including bushfire, incorporating response to the 2015-16 summer fire emergency, risks and limitations of Hydro Tasmania’s power output, and recent disease problems experienced by marine aquaculture industries.

New future climate research (Q1)

  • Instigate a revived and improved phase of Climate Futures for Tasmania based on latest science and using current supercomputer generation.

Active transport (Q1)

  • Implement measures to actively facilitate and promote walking and cycling through the provision of appropriate infrastructure, including physically separated bike lanes and greater priority for pedestrians and cyclists.

Public transport (Q1)

  • Increase number of bus services and regularly upgrade bus fleet to preserve and enhance a public perception of attractive, efficient and comfortable services.
  • Enhance electronic information services such as ‘next service wait time’ information in real time at all bus stops and via smartphone apps.
  • Increase creation and use of bus lanes and priority for buses at traffic lights.
  • Improve public transport affordability particularly for longer services.
  • Offer more flexible routing using technology such as smart phones and GPS.
  • Begin planning for switching Metro’s public transport fleet to electric power, including a targeted timeframe to initiate and accomplish this task.
  • 15 Actively consider alternative forms of public transport, including light rail and ferries.

Major infrastructure (Q1)

  • Ensure that prioritising and funding of infrastructure projects are fully transparent and open to public discussion, and that they accord with national aspirations for urban renewal and regional development.
  • Ensure that all infrastructure project proposals are subjected to thorough climate impact assessments before being approved.

Electric vehicles (Q1)

  • Actively promote uptake of electric and fuel efficient vehicles while discouraging uptake of inefficient vehicles by applying a ‘feebate’ scheme to vehicle registration charges and stamp duty.
  • Ensure that a substantial Tasmania-wide EV charging network is installed by 2020, by facilitating private investment in charging stations on major routes and subsidies for stations on less-travelled routes.

Divestment (Q1)

  • 20 Require all government investing agencies to pursue a process of divestment from fossil-fuel business in accordance with established procedures.

Targets (Q2)

  • Prescribe short-term emissions targets for each major economic sector, such as transport, at five- or ten-year intervals, with reporting and review of progress on a similar time scale.
  • Structure sectoral targets to ensure that sectors are neither unduly penalised nor get a ‘free ride’ over specified longer-term periods.
  • Transport energy targets: Set short-term targets for (a) transitioning to electric private vehicles; (b) development of cycle and pedestrian routes; (c) upgrading and further development of public transport services.
  • Renewable energy target: Set a 2020 target for 100% net renewable electricity consumption, whereby Basslink imports must be fully offset by a similar volume of exports, on an annualised basis.
  • Energy saving targets: Set a binding yearly electricity/gas target for consumption savings of at least 1% below a historical benchmark, supported by a scheme to ensure this target is met every year.
  • Community education targets: Design and implement a sustained multi-media communication campaign to support the achievement of community education targets on climate change, such as ‘90% of Tasmanians, when asked, report that human-induced climate change is real and a serious problem for Tasmania’.

Renewable energy (Q3)

  • Create policy framework encouraging investment in community-scale or larger wind and solar energy generation, and where necessary fast-tracking such development.
  • Increase the domestic feed-in tariff to 15c/kWh and allow an installed capacity of 100kW to encourage greater take-up of domestic, commercial and industrial rooftop solar PV.

Electric transport (Q3)

  • Implement measures to encourage Tasmanians buying new vehicles to switch to fully-electric; such measures to include either direct state investment or strong financial incentive for private investment in EV charging facilities throughout the state.

Primary industry (Q3)

  • Undertake risk analysis across the primary industry sector, recognising (a) that agricultural activities are a major cause of emissions, (b) pre-existing hardship suffered by some existing farm and fisheries operators, and (c) varying viability of crops in warming climate.

Tasmania as global research centre (Q3)

  • Foster and support Tasmania’s climate science resource (including revived Climate Futures program), ensure that local studies benefit from its concentrated scientific expertise, and actively advocate for Tasmania’s interests in this regard.

Ancillary benefits of abatement (Q3)

  • Foster, support and promote community abatement actions on grounds of lower energy bills, improved comfort, greater business competitiveness, fuel-efficiency, improved transport options, greater energy security, greener and more liveable cities and greater social resilience.

Energy-saving scheme (Q4)

  • Establish an Energy Saving Scheme (ESS) fully harmonised with an existing state scheme to reduce administrative costs and required start-up time, to cover both residential and commercial users, and electricity and gas.

Major industrials (Q4)

  • Mandate independent audits of every major emitting facility, identifying scope of abatement opportunities and associated costs.
  • Provide (with penalties for non-compliance) that all ESS opportunities must be implemented within a given time.

Reverse auctions (Q4)

  • Establish reverse auctions allowing major enterprises to ‘buy down’ the cost of securing high cost/long term abatement opportunities from the private sector.

Administration (Q4)

  • Create a Department for Climate Action committed to leading excellence in climate change adaptation and mitigation.
  • Appoint a Minister for Climate Action, responsible for leading the development of Tasmania as a global leader in climate change knowledge, mitigation and adaptation activity.

Legislation (Q4)

  • Amend the Climate Change (State Action) Act 2008 to require that decisions with major impacts on Tasmania’s climate mitigation efforts, or that might be affected by the impacts of climate change, undergo climate impact assessment.
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