Submission to the Victorian government: Go early, go hard

The following is Centre for Climate Safety’s submission to the Victorian Government, which has called for comments from the public on the targets it will soon set in regard to how fast or how slowly it should aim to reduce the state’s greenhouse gas emissions.

This is probably one of the most consequential decisions the Andrews government will make this term: how to set emissions targets for 2025 and 2030. The official advice they received from a panel headed by Greg Combet was essentially inconsistent with any chance of 1.5C degrees global warming, so we call on the Andrews government to go higher:

The Independent Expert Panel’s recommended targets
The Independent Expert Panel recommends Victoria set greenhouse gas emissions reduction targets of: 32-39 per cent below 2005 levels in 2025 and 45-60 per cent below 2005 levels in 2030.

1: Do you support these targets recommended by the Panel?

1b: Why/why not?

Firstly, since the climate science is clearly telling us that we are now facing a climate crisis (of our own making), this would be far better expressed as a climate emergency, and not simply ‘climate change’. We need to call a spade a spade. Language matters, and in an emergency, it is crucially important that the wider community understands the urgency of the changes we all need to make, if we are to maximise public engagement and minimise the real climate dangers that lie ahead. An increasing number of LGAs and cities in Australia are declaring a ‘climate emergency’, reflecting a similar trend in many other countries. These language deficiencies should be rectified in the final report and in subsequent communications from the Victorian government.

Secondly, it would greatly assist community understanding and engagement if the emissions reduction targets are also explicitly expressed in CO2e tonnes per capita – i.e. in terms that will help to generate community understanding of our unsustainable present, as well as future projections and reporting of comparative carbon footprints, both between cities, States and nations and over time.

Thirdly, the report needs to explicitly link its final emission reduction targets to a Victorian carbon budget that is linked to the global carbon budget and a ‘fair share’ Australian carbon budget, for which the Climate Change Authority (CCA), the UN Intergovernmental Panel on Climate Change (IPCC), Meinshausen et al, and a number of other climate scientists have consistently advocated.

Fourth, the science is clear that there is an unacceptably low certainty of outcome for even 2°C degrees of average global warming above pre-industrial. We certainly wouldn’t board an aeroplane with only two chances in three of landing safely, which was the probability quoted in the CCA’s recommended target in 2014, and indirectly in the Panel’s current recommendations. Meinshausen’s 2018 updating of the 2014 Climate Change Authority findings improves the 2°C degree odds to a more comfortable 90 per cent, which though not ‘safe’ is at least ‘safer’. His analysis makes it clear that the procrastination of governments and the broader society during the last 20-30 years has now put the much safer 1.5°C degree target beyond reach until we can develop safe and effective methods to draw down carbon dioxide at scale from the atmosphere – hopefully from mid-century on.

Finally, it is helpful to recall that during the global financial crisis a decade ago, the Federal Labor Government listened to and quickly acted on the emergency advice from the Treasury to ‘go early, go hard’, adroitly preventing Australia from being dragged into a major world recession. We must now move just as quickly in the coming decade to ensure that average global temperature is held well below the critical 2°C degree rise. If Victoria’s Labor Government joins the vanguard in planning to achieve this, other governments will quickly follow.

For comparison, Denmark, which has a population similar to Victoria’s, has already written into law that the country must reach 70 percent below the 1990 level by 2030. Finland has legislated that it will be carbon neutral by 2035. Other nations are moving in a similar direction, with the UK conservative government recently declaring a climate emergency, as a prelude to improving its medium term emissions reduction profile and developing the necessary policies and actions to achieve zero emissions by 2050.

The higher targets of 40% reduction by 2025 and 65% by 2030 that we and others are proposing recognise that new technology relating to agriculture and to marine and air transport will likely require an extended development lead time. Some room to achieve the target gains for these sectors between 2030 and 2050 is needed, within the constraint of meeting Victoria’s carbon budget.

The Centre for International Economics (CIE) has confirmed the superior economic outcome from a ‘go early, go hard’ strategy. An ambitious early target would allow for an achievable tapering curve during the technically more challenging period between 2030 and 2050 (Fig. 5.50). The 65 per cent target for 2030 also reflects the recommendations from detailed analyses by Garnaut (2008 and 2011), Meinshausen et al (2009, 2018 and 2019), the CCA (2014), ClimateWorks and Towards Zero Carbon.

A further important reason to go hard early is that of intergenerational equity. The generation born during the second half of the 1900’s have created most of the problem for the successive generations of the 21st century, both those growing up and those yet to be born. Fairness dictates that it is up to the present generation to create the lion’s share of the needed changes, at least up to 2030.

These more ambitious targets recognise the low-hanging fruit that can be harvested from:

  • A faster renewables-based electricity target pushing a faster coal generation phase-out;
  • Improving energy and water efficiency in all sectors;
  • Switching from gas to electricity-powered heat pumps to heat and cool commercial and residential buildings;
  • Switching govt capex away from new freeways and to more and better public transport (including trains, trams and local feeder buses), and well-planned pathways for bicycles and walking;
  • An incentive structure for vehicle owners to switch to EVs – electric cars and electric bicycles – and fuel cells for trucks and buses, with electricity generation from renewable sources being rapidly deployed at scale.

As required by the Climate Change Act 2017, the Independent Expert Panel considered a broad range of issues in reaching its recommended targets including:

  • Scientific evidence on the significant risks that climate change poses to Victoria;
  • The actions that Victoria and others (including the Commonwealth government) are already taking to reduce emissions – including the commitment of the international community, through the Paris Agreement, to limit warming to well below 2°C and to pursue efforts to limit the increase to 1.5°C above pre-industrial levels, in order to avoid the worst impacts of climate change;
  • The implications of Victoria contributing its fair share to limiting global temperature increases in accordance with the Paris goal (emission budgets for Victoria);
  • The availability of significant emissions reduction opportunities across the Victorian
  • economy; and
  • The potential economic, social and environmental benefits and costs of Victoria’s transition to a net zero emissions economy.

2: Are these the key issues influencing what the right targets are for Victoria? Are there other issues that should be considered?

One apparent omission from the above list of relevant issues is that of health. Apart from the regional air pollution impact arising from burning coal for electricity generation, there is also a serious health impact arising from the exhausts of petrol and diesel-powered cars, trucks, buses and trains on our roads and in our cities.

Given that the climate science in all its dimensions has become so concordant and so compelling during the past two decades, the rate of change in emissions reduction during the next two decades is as critical as the target of zero emissions by 2050. The financial cost to the economy, human health and biodiversity of ‘too little too late’ needs to be driven home in the overall analysis, rather than a focus on optimising the sequence and costs of the various interventions.

An inescapable reality is that if we wreck the climate then ipso facto we also wreck the economy, the environment and human civilisation as we know it. The policy priority is obvious, and the final report needs an explicit statement to that effect.

Victoria has choices about the emissions reduction trajectory needed to reach net zero emissions by 2050. Different trajectories imply different costs and benefits over time.

3: Do you agree with the Panel’s indicative trajectories to 2050?

3b: Why/why not?

(Refer to responses under Q 1b above – all relevant to this question).

The more ambitious targets for 2025 (minimum 40% reduction on 2005) and 2030 (minimum 65% reduction on 2005) that we have requested under Q 1b clearly imply a more aggressive trajectory during this period.

Meinshausen’s recent analysis indicates that under business as usual, Australia’s (and Victoria’s) ‘fair share’ carbon budget will be expended by 2034 – i.e. in only 15 years.

His analysis also showed that a 49 per cent drop by 2030 would be needed for a simple linear reduction to zero emissions by 2050.

A lower 2030 emissions level than this would leave unfinished the simpler transitions of the 2020s, diluting the technical, financial and social efforts that will be needed to address the more difficult sectors in the 2040s. On the other hand, frontloading the 2030 target to at least 65 per cent reduction on 2005 levels would allow the easier changes to taper off during this period, allowing time for the necessary technical developments needed to be focused within Victoria’s carbon budget.

Reducing Greenhouse Gas Emissions in Victoria

The Independent Expert Panel’s report also identifies opportunities to reduce Victoria’s greenhouse gas emissions (see Chapter 6 of the Panel’s report).

4: Are there other key greenhouse gas emissions reduction opportunities beyond those the Panel identified?

R&D and capital are needed to reduce energy demand and emissions from cement manufacture in Victoria. This can include partial substitution of limestone raw material with a variety of waste products.

Zero waste (i.e. a ‘circular economy’) should be included in the list of opportunities, with emphasis finding processes and markets for highly recycled metals, plastics and materials ( moulded containers, road materials, building products and others), with processes based on electricity from renewable energy rather than gas.

Professor Ross Garnaut has recently proposed that hydrogen can be produced using Australia’s ample renewable energy resources, but this gas should not be exported (difficult, dangerous and expensive), but instead should be used to reduce Australia’s oxide and sulphide ores to the relevant metals (e.g. iron, manganese, aluminium, zinc, copper), at the mine sites.

The much higher added-value metals can be used in local manufactures and also exported, offsetting the export impact of phasing out thermal coal and ultimately, liquefied natural gas. There is also ample scope to convert renewable energy-based hydrogen to ammonia, for agricultural and mining applications Major employment opportunities would flow from such investments.

In Victoria, which has both high grade silica (sand) resources, as well as wind and solar energy, the same technology could produce purified silicon for PV panels, either as the basis of a PV industry here, or else as high added value export product – again, offsetting phased out thermal coal exports and providing new employment opportunities.

5a: Across the Victorian economy, which activities do you think the Victorian government should prioritise in reducing Victoria’s greenhouse gas emissions?

The top priority is to replace coal-generated electricity with renewables – faster than presently targeted (see responses to Q1b and Q2).

5b: What policies or programs are needed to drive these emissions reductions?

  • More ambitious 2025 and 2030 renewable energy targets and incentives are needed. To help achieve these targets, the Victorian (and all State) governments should uniformly agree to tax what we don’t want, and to subsidise what we do want. A key element of such a philosophy is a carefully constructed carbon tax, that is reliably scheduled to ratchet up at intervals. If necessary, the Victorian Government may initially need to go it alone, as California is doing.
  • More generous subsidies and loans for heat pump-based domestic, commercial and industrial water and space heating is an imperative, given the high contribution of this category to total emissions and to more rapidly phase out direct gas combustion.
  • Strategies are needed to retrofit the older Victorian housing stock with effective insulation, draught control and shading, in order to more rapidly phase out gas and to reduce the high heating and cooling energy load on our electricity generation system.
  • Subsidies are needed to encourage replacement of electric vehicles – cars as well as bicycles. Add special lanes for EVs on the roads in congested areas and allocate free spaces in car parks for EVs.
  • Redirect State capital expenditure away from roads and car parks and towards widespread recharging stations with low-priced electricity, and towards more and safer bike paths and walk-ways.
  • Regulate all levels of government in Victoria with deadlines (e.g. 2025 and 2030) to change their car, truck, bus and V-line train fleets to EVs or fuel cell-powered vehicles. If you think this sounds too ambitious, take a look at Norway, which plans to ban sales of petrol powered cars by 2025.
  • There is scope for existing car fleets to be converted to electric, in a similar way to the subsidised LPG conversions of the past. The facilities at the closed Victorian car plants in Melbourne and Geelong would be perfectly situated as centres for these conversions. This would overcome much community kickback against EVs, particularly among people with relatively new cars who otherwise stand to absorb large capital losses.
  • Raise business and consumer awareness by regulating the inclusion of standardised emissions-related product labels that would guide consumer choice.
  • Explore and promote the growing, processing and production of hemp for textiles, while at the same time reducing LPG / LNG-based synthetics, soft plastics pollution of waterways and our ocean, and adding to the state’s carbon sequestering capacity.
  • Promote regenerative farming methods similarly for more powerful carbon sequestering capacity and reduced water losses and chemical runoff to our waterways.
  • Exemplify and promote reductions in international, interstate and regional flying in the government, business, NFP and academic sectors through the use of high-quality teleconferencing and encourage the community to progressively replace overseas tourist travel with local trips by adding a levy to international air fares – saving on emissions and increasing local employment.
  • Protect Victorian coastal sea grasses and herbage and reforest bare ground to provide the CO2 sinks that can perform at least some of the drawdown that will be required in the decades ahead.

6: Are there any emissions reduction opportunities identified by the Panel that you would not support Victorian government action on? Why not?


Benefits of reducing greenhouse gas emissions in Victoria

7: In addition to those identified by the Independent Expert Panel (see Chapter 7 of the Panel’s report), are there other key benefits of reducing greenhouse gas emissions?

Victoria’s climate policy should stand on a foundation of three basic principles:

a) Inter-generational equity: The world is facing a series of high-risk tipping points – loss of polar and glacial ice and the gulfstream that warms Europe, loss of fresh water resources, loss of arable land, loss of agricultural productivity, loss of biodiversity and loss of wilderness. The generation of the 20th century who have ‘lived the good life’ have an obligation to protect those born in the 21st century and later from the long-term consequences of our mindless exploitation of our plant’s resources.

b) Citizens’ right to a safe climate: Climate change is a global phenomenon, as we all share the same atmosphere. Our level of action on emissions reduction and the pace of our actions will determine whether or not we can secure a safe climate. The 2015 Paris Climate Agreement is a step in that direction but is not unambitious enough to save us from a long list of long-term climate-induced disruptions and losses. Most Victorians want governments to do better.

c) Taking a fair share of the transition load: Although Australians represent a small percentage of the world’s population, we have the infamous reputation of being the world’s highest per capita emitter, as well as the largest exporter of thermal coal and liquified natural gas. Four out of five Victorians have pledged that they are ready to take their fair share, according to Wallis Market and Social Research’s interviews with 3,333 Victorians in 2016, but everyone is also aware that individual actions won’t have much effect unless the Victorian government does the same.

No person, state or country can avoid the peril of dangerous climate change by acting alone. There is great power in committing to ‘leading by example’, and in accepting more than a simple population-based share of the world’s emissions reduction load.

By partly compensating the developing countries for our comparatively profligate consumption of our planetary resources and sinks, we give those countries some headroom to lift their standard of living while also contributing to the global emissions goal. The ‘modified converge and contract’ per capita model advocated by Garnaut and Meinshausen provides just that ‘fair share’ basis that most Victorians would accept.

8: Of all the benefits of reducing emissions, which are the most important and why?

Physical health, food costs, minimising economic disruption, protecting habitat and biodiversity, minimising massive social disruption (including from climate refugees) and mental health issues caused by collapsing economies and environments – all these are critical issues.

Barriers to reducing greenhouse gas emissions in Victoria

9: From your experience, are there any barriers to reducing Victoria’s greenhouse gas emissions that the Independent Expert Panel didn’t identify?

More emphasis is needed on long-term planning for the unavoidable labour transitions – importantly, by generating effective consultation, collaborations and messaging.

More integration of goals and strategies between State and local governments and with community groups is needed – important in distributing leadership downwards and integrating with rapidly emerging bottom-up initiatives from local governments, businesses and community groups.

Eemission reductions vs. a variety of base years and carbon budgets are too amorphous for most people, important as they are. Personalising emissions targets on a per capita (‘carbon footprint’) basis is important – as per current electricity, gas and water bills, where such community education is well underway.

The absence of a carbon price is a serious impediment to rapid progress. This must be addressed with political savvy and courage – perhaps with a group of like-minded states, as is happening elsewhere.

10: Of all the barriers, which are the most important to address and why?

  • An adjustable carbon tax.
  • An infra-structure budget focussed on public transport, electric cars / bicycles and safe walking / bicycle tracks.
  • Regulations/incentives that accelerate the transition from hydrocarbon fuels to efficient electricity-powered heating, cooling and transport.

11: How can the key barriers you identified in Question 10 be overcome?

Sell it and do it! Dare to go further than you ever thought was possible. This could be the decade of emerging statesmen and women.

Impacts of reducing greenhouse gas emissions in Victoria

The impact of greenhouse gas emissions reduction policies will vary across sectors and communities in Victoria.

12: In addition to those identified by the Independent Expert Panel (see Chapter 7 of the Panel’s report), are there other impacts of reducing greenhouse gas emissions?

13: Of all the impacts, which are the most important to address and why?

  • Potential regional unemployment is the most urgent consequence to anticipate.
  • Planning to constructively manage the expected surge in climate refugees – including regional distribution, training and non-exploitative employment.
  • Forward planning to anticipate and smoothly adjust to changes in world, national and regional economies, both positive and negative, some of which will arise directly from global warming and others from necessary adaptations.

14: How can these impacts be addressed?

Plan well in advance, consult widely, invite collaboration – and act with wisdom, courage and decisiveness.

Other Comments

15: Do you have other comments about action on climate change in Victoria?

Excellent review and planning process – consultation with experts and the wider community has been great.

[Submission ends]

Send in your own submission

If you’re keen on making a your own submission to the public consultation on emission reduction targets, Environment Victoria, Friends of the Earth Melbourne and the Australian Wind Alliance each have provided a quick and easy way to do this. Extinction Rebellion Victoria also have suggestions for you, see further down.

You can send a pre-written submission (open for your editing before sending) via Friends of the Earth Melbourne’s or the Australian Wind Alliance’s websites, or you can use Environment Victoria’s guide.

Have your say on Victoria’s Emissions Reduction Targets:
→ Friends of the Earth Melbourne: Send a submission calling for climate ambition
→ Environment Victoria’s guide to help answer the questions in the survey
→ The Australian Wind Alliance also has made it really easy to send a submission, click here to head to their submission form.

→ The Victorian government’s Department of Environment’s Have Your Say survey

Rebel response
to the Victorian Government’s emissions targets

The Victorian Government is seeking input from residents on the states emission reduction targets. Their expert panel recommends emissions reduction targets of 32–39% below 2005 levels by 2025, and 45–60% below 2005 levels by 2030.

Extinction Rebellion Victoria wrote in a newsletter: “These targets are based on assumptions of a remaining carbon budget. There is no remaining carbon budget. The earth is already too hot. These targets if agreed upon demonstrate how our government is failing to protect us and future generations in the face of the climate and ecological emergency.” 

Extinction Rebellion has put together a submission, which states their demands and their intent to rebel until the state and federal government meet them… and act as if the truth is real. Here is an excerpt from their newsletter:

Tell the truth – Part One: “Clicktivism” disruption and asking nicely

“If you have the time to make a submission, we encourage you to submit the Extinction Rebellion response (downloadable here) as an attachment for number 16 of the emissions reduction target survey.

Feel free to do your own research and submit your own answers to the survey questions.

However, if you are time poor, an option is to respond to the survey questions in a way that will catch the attention of the government, for example copy and paste the following:

The proposed emissions reduction targets by the independent expert panel are grossly inadequate in the face of the climate and ecological emergency we are in. As part of the international network Extinction Rebellion, I’m informing you that we will rebel, by means of mass participation disruptive events, until the Victorian government meets our demands: 

1.     The Victorian government must tell the truth by declaring a climate and ecological emergency, working with other institutions to communicate the urgency for change.

2.     The Victorian government must act now to halt biodiversity loss and reduce greenhouse gas emissions to net zero by 2025.

3.     The Victorian government must create and be led by the decisions of a Citizens’ Assembly on climate and ecological justice.

Part Two: Your vision of a disruptive action.

The Department of Land, Environment, Water and Planning (DELWP), who is responsible for climate change policy under Minister Lily D’Ambrosio have 7 offices across Victoria. The submissions are open until Monday 22nd July. We want to put together a disruptive action on Monday and want your ideas and help to do so. This action may be at a regional office, the head office in Melbourne CBD, at the State Parliament, at the Ministers office in Mill Park or wherever you think best!

We know that there is a vast talent of creative and passionate rebels out there in Victoria, so we want to hear from you about what kind of disruptive action we should take. Please fill out this form and share your ideas, and particularly if you want to be involved in making it happen. This is a great opportunity to explore your potential as part of the Extinction Rebellion movement, and learn more about how it works. We recommend you consult the Action, Art and Logistics Manual to help vision your action.

Thank you for taking the time to do this.
Peace and Rebellion
Extinction Rebellion Victoria

And don’t forget, 7 October 2019 is the beginning of the international rebellion. Take two weeks off of work and be ready for a great time, a historic time.”

Government Survey

XR Submission

→ Form for submitting your ideas on an action

→ Extinction Rebellion Action, Art and Logistics Manual

The Independent Expert Panel received around 3,300 written submissions with over 80 from organisations and around 3,200 from individuals. The submissions from organisations are published along with a summary of the submissions from individuals on this page: