Submission: Feedback on Victoria’s emissions reduction targets for 2035

The Victorian Government is seeking feedback on their Emissions Reduction Targets for 2035 – they have a simple survey that will take you 5 minutes to fill out. This is important because it signals to the Government that we want more ambitious targets. If we have more ambitious targets the need for a new gas terminal in Corio Bay is eliminated.

Friends of the Earth Melbourne and Environmental Justice Australia have written guides on what you should write. See below. Submissions close this Sunday the 5th of June 2022 – make a submission today!

Follow this link to make your submission via Friends of the Earth. Friends of the Earth is calling for a science-based target of net-zero emissions by 2035

Environmental Justice Australia
Photo of stacks producing pollution.

Now is the chance to have your say on climate action

Environmental Justice Australia wrote in a newsletter: 

In the busyness of the federal election campaign, you might have missed this important opportunity to voice your thoughts on climate action in Victoria.   

The Victorian Climate Change Minister is about to make a critical decision on how high the state will aim to cut climate pollution in the next 13 years. 

Right now, an expert panel is accepting submissions from you and your community about Victoria’s path to net-zero.

The panel must read every submission, and that’s why this is a powerful way to influence decision makers and make it known that climate action is an important issue.

You have until 5 June to write a submission or complete a short online survey on Victoria’s 2035 target to reduce climate damage.

Writing a submission is fairly simple – we’ve pulled together a handy three-step toolkit to guide you through the process.  

In your submission you could write about what issues matter to you – perhaps it is the health or justice impacts of climate change or the harm to people, places and wildlife you love.


You only have until 5 June 2022 to write a submission or complete the online survey (so get your skates on!). 

We would love for you to send us a copy of your submission when you’re done – just email it to That way, we can track how much of an impact the EJA community has, and also advocate on your behalf. You can also email us with any questions.

Good luck getting your submission in! And thanks for standing up for our climate and communities.

Nicola Rivers and Elizabeth McKinnon, Co-CEOs

Nicola Rivers and Elizabeth McKinnon
Co-CEOs, Environmental Justice Australia

Centre for Climate Safety submitted the following:

Victoria’s emissions reduction target for 2035
Centre for Climate Safety’s submission

First, we congratulate the Victorian Government for its leadership and continuing drive to ensure that Victorians do their fair share to cut greenhouse gas (GHG) emissions to zero as rapidly as possible. The ‘Issues’ paper is clear, comprehensive, and balanced – an excellent document to guide community involvement and support.

Some comments and suggestions follow.


The concept of a fair contribution to the world decarbonisation target is an important one. There are sceptics out there who point to the low absolute emissions of Australia (and Victoria) compared with China, India, and South American countries. This totally ignores the difference in cumulative contributions to the atmospheric carbon load, to comparative per capita emissions, and to comparative economic and technological capacities.


Victorians cannot ignore the plight of our Pacific Island neighbours, who are already seeing their livelihoods and homes being destroyed by inexorably rising sea levels. Australian targets need some weighting beyond comparative per capita targets to achieve at least some climate justice.

Victoria is a trading state, with substantial exports of agricultural and manufactured goods as well as specialist services. These revenues will be at risk if a failure to meet European and USA decarbonisation expectations are not met. Our export industries certainly don’t need the risk of climate-related import tariffs.


Victoria has lifted its pace in installing large-scale wind and solar generation and small-scale rooftop solar. However, the state government must now greatly expand its ground-breaking initiatives in supporting Victorian residents and businesses to modernise inefficient and fossil-fuel-based equipment, by upgrading to high-efficiency appliances and transport equipment powered with renewable energy.


We should be proscribing all new gas-related investments (on-shore fracking, off-shore drilling, storage terminals) and rapidly pulling gas out of our domestic and commercial sectors by ‘electrifying everything’. Water heating, space heating and cooking need to be urgently replaced with existing high-efficiency heat-pump, microwave, and induction-heating technologies that utilise expanding renewable energy capacity.


Upgrading the poor energy efficiency of much of Victoria’s housing stock through insulation and related measures is another high-priority area for state and local governments to address. Government ‘carrots and sticks’ policies and programs need to be substantially lifted if we are to implement these critical changes far more quickly than is currently happening. Saul Griffiths’ 2022 book ‘The Big Switch’ is a well-researched and compelling study of what is possible in Australia with the right level of ambition and determination by policy makers.


Both the consultative style and involvement of experts of the Victorian Government are commendable and important. However, in the end the State’s target-setting approach remains an essentially ‘top-down’ one. We see the lack of explicit involvement and accountability of local government in this process to be a serious deficiency. A fundamental objective is to win the hearts and minds of our communities, so that necessary behavioural changes and domestic investments will emerge as a new individual, family, and corporate ethic.

To address this, we are advocating for more explicit State Government direction to Local Government Area Councils relating to mitigation of GHG emissions within their boundaries, as well as development of effective climate-change adaptation measures to protect their citizens. There would be great benefit in establishing both a high-visibility peer comparison structure and an accountability structure within the Local Government Area network. In this context, a bottom-up synthesis of community-wide LGA targets could at least inform the setting of State-wide targets for 2030 and beyond.


To further assist Local Government Areas in managing the transition to a low carbon economy we are strongly advocating for the local formation of thoughtfully constituted and well-resourced Citizens Assemblies. These would greatly help local government councils with effective community messaging, resolving conflicting priorities and publicising and celebrating progress and successes, which could occur throughout Victoria.

There is Council support in principle for this concept in the City of Greater Geelong (which in 2021 adopted a 2035 community-wide zero emissions target); however, no budget progress for this is in sight, with lack of financial and human resources being blamed. There is a clear role for immediate state government support for this initiative, with the potential of extending such a pilot program state-wide.

As with the indigenous ‘Voice to Parliament’, this concept is aimed at complementing and supporting local government. There are several excellent overseas examples where Citizens Assemblies have smoothed the way for implanting difficult community changes (e.g. in Catholic Ireland: the passing of a pro-abortion law). In fact, a few years ago the City of Greater Geelong’s then administrators adopted just this model to guide community deliberations for a 30-year vision and strategy. The Victorian Government should quickly develop a program along these lines to facilitate decarbonisation programs within Victoria’s LGAs.


Finally, there are many economic health-related costs of remaining on a longer pathway to a decarbonised future. There are obvious health and environmental and climatic risks of particulates, gaseous toxins, methane, and temperature increase arising from mining and burning coal, liquid fuels, and gas, we have an ageing society which is increasingly vulnerable to heat waves and to more violent weather patterns – extremes that also exact a large and growing economic cost on families, businesses, and governments. As the Issues paper makes clear, the cost of inaction is very high, greatly exceeding the costs of mitigation and adaptation.  


The 2021 IPCC report on climate change science acknowledges that the world will at least temporarily overshoot its much-preferred warming limit of 1.5°C degrees – but it emphasises that we must continue to aim for well below 2 degrees, and as close to 1.5 degrees as possible.


In setting a 2035 target for Victoria, we propose that the ‘range’ concept be dropped in favour of a single firm target. This would avoid the perception that the government is reluctant to commit to a firm target and needs wriggle-room in case of a shortfall. The last thing we need now is a public perception of government uncertainty or lack of resolve.

The Issues paper refers to a range of 1.5–2 degrees as “the IPCC target” without making this point – and there is a very big difference in climate outcomes between the two ends of this range. It would be reckless to base our strategy on future potentially dangerous large-scale carbon drawdown or solar shielding technologies in mid-century, just to compensate for timid policies and programs in the 2020s.


A straight-line projection from the current 2030 target to net zero by 2050 is too simplistic a basis for striking the target for 2035. This ignores the fact that we should be expanding and accelerating the ‘lower-hanging fruit’ opportunities in energy efficiency, electricity generation and storage from renewables, and all-electric public and private transport. Aggressive earlier targets will allow some scope for the difficult ‘residual’ sectors of agriculture, heavy industry, shipping, and aviation to develop relevant low-emissions technologies. There also is a clear inter-generational equity imperative in this approach.


The critical importance of setting an aggressive target for 2035 has been well understood by the ACT in Australia, and by countries like Germany and Scotland, who have set targets in the range of 85-96% emissions reduction on their equivalent 2005 levels. Denmark is targeting a 70% reduction by 2030 and Finland strives to reach net-zero carbon emissions by 2035.

The well-resourced Climate Council is advocating for a 75% reduction by 2030, based on solid science from the IPCC, which although more ambitious than the Victorian target, is very consistent with the 85% plus examples mentioned in the Issues paper.


Based on all the above, and given the existential climate emergency resulting from 30 years of relative policy inaction, we strongly recommend that the Victorian Government decide on an ambitious 80% emissions reduction on 2005 levels by 2035 –immediately prioritising everything that achieving this critical goal will require.

Alan Barlee
Mik Aidt
Centre for Climate Safety

16 May 2022

One comment

  1. Hi to all submitters

    Please add a paragraph about nasty implications for emissions targets of opening gas pipelines to hydrogen (clean or dirty). It prolongs methane use for decades because our system can cope with no more than 10% hydrogen.


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