Fuel Efficiency Standards

Following the release of the National Electric Vehicle Strategy the government called for detailed submissions regarding the development of a Fuel Efficiency Standard (FES). In one of our most detailed and technical submissions yet, we urged an agressive FES at least in line with best practice examples abroad.

Measuring What Matters. Our thoughts on a new dashboard for Australia

We ran a virtual consultation with parents via our member-only social media.

National Greenhouse Emissions Reporting Standards (NGERS) 2023 Consultation - Fugitive Methane Measurement

Methane is a critical greenhouse gas to get on top of this decade. While methane breaks down in the atmosphere in only 12 years, net emissions are rising very quickly. Australia recently joined the Glasgow pledge to slash methane emissions by 30% by 2030. But first, we need to measure them properly.

NGERS is the framework by which large organisations (with emissions above 25,000 tonnes per annum) are required to disclose their emissions. While the requirements are based on the United Nations Framework Convention on Climate Change rules, there has been little rigour around the measurement of fugitive methane emissions (such as leaks from wells and pipes; deliberate venting; incomplete combustion during flaring and so on). Facilities are currently permitted to estimate their fugitive emissions largely based on decades-old industry benchmarks rather than requiring independent measurement and verification.

Given revelations gleaned from independent satellite and ground based measurement that a number of Bowen Basin coal mines in QLD are emitting massively more methane than has been reported, the government is seeking to improve measurement standards. We argued that they should go much further and require independent measurement of all methane sources, with a new agency funded indirectly by levies on fossil fuel firms.

Hunter Offshore Wind

It was refreshing to have a proposal that was one we could support, to establish an offshore wind zone off the NSW Newcastle Coast. While there are some concerns about visual amenity and environmental issues for migratory whales and so on, on balance this proposal makes a lot of sense given Newcastle's great wind resource and the proximity to existing transmission connections (given the nearby retiring coal power stations). Worth doing, but worth doing right.

Tasmanian Draft Climate Action Plan

A great submission prepared by the Tasmanian group with suggestions from the national submissions team. If your local AP4CA group wants help with a submission, please reach out!

Nature Repair Market

Would it surprise you to learn - we understand - that the idea for the nature repair market came from management consultants PwC? Nuff said. We are currently finalising our third submission on this topic, which even big business groups seem to be struggling to work out how and why they would use, based on their own submissions.

Safeguard Mechanism reform:
our recommendations on proposed design

The Safeguard Mechanism legislation was updated early May 2023 with modest amendments to the draft proposals. The most important of these was to ensure a hard declining cap for overall (aggregate) emissions from facilities covered by the scheme, though the government appears to have limited mechanisms to enforce this. While some have celebrated the fact that it effectively puts a price on industrial emissions (the cost of offsets), it still allows uncapped use of offsets (including dubious methodologiesand only tackles a tiny fraction of the lifecycle emissions from coal and gas mines/wells.

"Energy Performance" in this context basically means energy efficiency: boring but critically important. The strategy will focus on buildings (residential/commercial) and lighter industry. We proposed a more holistic approach given that electrification of buildings and transport delivers efficiency benefits but also creates new loads on the distribution network. On the other hand, water heaters, EVs, rooftop solar, batteries etc. can be used cleverly to balance supply and demand in ways that will greatly reduce the amount of new investment in the distribution network that would be needed otherwise.

We also stressed the comfort, health and cost of living benefits of electrified buildings and transport and noted that we need effective minimum efficiency standards for rental properties (not just electrification but also insulation and draft proofing), which would also drive change through the strata apartment sector given that many apartments are rented.

AP4CA's submission urged an end to fossil fuel subsidies, which would free up funds to #SolarOurSchools amongst other initiatives. The budget will be released in May.

Legal intervention by Environmental Justice Australia on behalf of the Environment Council of Central Queensland (ECoCeQ) resulted in the requirement for 18 fossil fuel projects around the country to be reconsidered in the light of thousands of pages of new evidence about how climate harms from such projects would incrementally directly and deleteriously affect sensitive Australian ecosystems. AP4CA was proud to help amplify this amazing initiative.

Establishment of an authority to coordinate the transition to clean energy and sunset of the fossil fuel industry - including justice for workers and communities in affected sectors - is sorely needed and it was refreshing to see the new government launching this consultation. However, as we point out in our submission, to limit it to coal mine and power plant workers, when the real scope is far, far broader.

This consultation was triggered by the successful legal action taken by the Environmental Defenders Office on behalf of the courageous Bushfire Survivors for Climate Action in 2021, which forced the NSW Government to direct the Environmental Protection Agency to consider the impacts of climate pollution in its assessments.

The Department is now developing the National Electric Vehicle Strategy. Meanwhile in December the government announced a range of supports for EV purchases, including measures designed to accelerate uptake by fleet buyers.

The Renewable Energy Target (RET) has allowed companies to monetise investments in renewable energy generation by creating and selling renewable energy certificates (RECs). While most RECs are for solar and wind generation, there has been a seldom used capability in the scheme to burn wood waste to generate electricity. We are hoping the new Labor government will shut this down. 

In December 2022 it was announced that native forest wood waste would not be permitted as part of RET projects. Over 2,900 submissions were received, almost all opposing the concept.

The Greens introduced legislation to add a "climate trigger" that would require the Environment Minister to take account of a project's impact on climate change when evaluating under the Environmental Protection and Biodiversity Conservation Act. AP4CA strongly supports the introduction of a climate trigger, as it would inevitably mean (if implemented correctly) that new coal and gas projects (and expansions) requiring assessment under the Act could not be approved. 

The Review was established by the ALP to seek views on the integrity of ACCUs, and the broader impacts of activities incentivised under the ACCU scheme framework. In findings handed down in early 2023, "the Panel concludes that the ACCU scheme arrangements are essentially sound, incorporating mechanisms for regular review and improvement, and recommends a number of changes to clarify governance, improve transparency, facilitate positive project outcomes and co-benefits, and enhance confidence in the integrity and effectiveness of the scheme." This was somewhat disappointing given evidence presented to the Review.

The Safeguards Mechanism was regulated by the Turnbull Government in a tokenistic effort to reduce emissions by Australia's largest emitting facilities. These 213 (or so) facilities collectively emit 28% of Australia's total reported  domestic emissions (and rising). Over half of those emissions are from the operation of gas and coal mines - the energy associated with getting the stuff out of the ground and the  (woefully under-reported) fugitive methane and carbon dioxide emissions. Over half the emissions are from facilities controlled by just ten companies.

The new Labor Government is trying to tighten the scheme, with the intention that it will reduce emissions by 5 million tonnes of carbon dioxide equivalent per annum between now and 2030 in order to align with the 43% national target.

Project approved by the NSW Independent Planning Commission :(

If constructed it will be one of the highest emitting coal mines in Australia as there is a lot of methane in the coal seam.

Despite a concentrated opposition campaign the project was approved. Inexplicably, the project was not sited near a suitable gas service, and the pipeline has not yet been approved.

AP4CA jointly ran a Submissions Workshop, which resulted in dozens of additional submissions.