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Pages tagged "submissions"

Public Submissions

Our Policy and Submissions volunteer team provide parents' perspectives on a range of climate and related policy matters. They develop submissions relating to proposed legislation, government policy (mainly at federal and state level) and certain emissions intensive development projects.

On this page you can find some of our previous submissions. All are vetted by a member of AP4CA's leadership to ensure they represent our goals of non-partisan, respectful & professional, parent-led climate action. 

 

Do submissions work? In a word, yes!

Many of our submissions have been referenced or included in final decisions. Though sometimes, even overwhelming support for a particular outcome doesn't move fossil-fuel-obsessed governments or a legislatively-hamstrung administration. It's important to understand who will read your submission (hint: it's normally a public servant, rarely a politician), and whether the argument you are making is within their legislative or regulatory remit to act upon. One of the challenges we face is that Australia's laws often don't actually work to protect our environment or safeguard our rights to a safe climate, except in very specific circumstances. On the other hand, sometimes governments seek genuine consultations, and are willing to be swayed or even guided by submissions received. Context matters.

Interested in joining our Policy and Submissions team? Sign up to volunteer here.

 

Recent submissions

Submission To (Government) Submitted   Notes / Outcomes

ACCC Environmental & Sustainability Guidance

Australian Competition and Consumer Commission (ACCC) Sep-23

ACCC has come out with a good set of draft guidelines to clamp down on greenwash, and we have been part of the consultation process to try to improve it.

ACT Integrated Energy Plan

ACT Government Sep-23

ACT has been leading in the energy transition and we were pleased to contribute to this thoughtful consultation.

Murdoch Media Inquiry Bill

Inquiry related to a Private Members Bill proposed by The Greens Sep-23

Significant parts of the mainstream and fringe media are active participants in spreading climate denial and delay messaging. Australian Parents for Climate Action would welcome an inquiry into the impact the Murdoch Media has had in delaying and minimising climate action.

Minerals Legislation Amendment (Offshore Drilling and Associated Infrastructure Prohibition) Bill 2023

NSW Government (legislation proposed by the Coalition opposition) Aug-23

Following its defeat in the NSW election in March, the state Coalition proposed legislation  from opposition (based on principles proposed before the election by independent candidates) that would ban offshore oil and gas exploration. This would kill once and for all the toxic PEP-11 proposal but more broadly recognise that people generally don't want oil and gas drilling off our pristine coastlines.

Southern Ocean Region Offshore Wind

Australian Department of Climate Change, Energy, Environment & Water Aug-23

Offshore wind farms provide exceptional capacity factors (how much a turbine produces over the year relative to if it was consistently operating at its "nameplate" capacity) due to the more consistent and stronger winds (if well situated). They can help provide habitat and restore fisheries. However, there are significant community concerns with visual amenity, impacts to marine life (including migratory marine mammals and sea birds) and restrictions on recreational and commercial fishing. On balance AP4CA supports offshore wind done well, as the impacts of climate change outweigh the local environmental risks.

National Hydrogen Strategy Review

Australian Department of Climate Change, Energy, Environment & Water Aug-23

We recommended a pause in the hydrogen strategy pending the development of sectoral emissions reduction pathways. We expect the latter would provide a more nuanced view of the overall prospects for hydrogen. 

SA Energy Transition Green Paper

South Australian Department of Energy and Mining Aug-23

Prepared in conjunction with the AP4CA SA Group

Climate Change Authority Setting, tracking and achieving Australia’s emissions reduction targets

Australian Climate Change Authority Jun-23

The CCA is the independent body whose role as specified in the Climate Change Act (2022) is to provide advice to the Minister for Climate Change on climate targets and progress towards those targets. This was a broad consultation with 32 questions, giving us a great opportunity to speak powerfully as parents and carers of our children, while drawing from technical content we have previously prepared for other submissions.  

Greenwash

Australian Senate Inquiry Jun-23

 

SA Hydrogen and Renewable Energy Bill

South Australia Jun-23

A disappointing piece of legislation apparently influenced by fossil fuelled hydrogen hopium.

Nature Repair Market Bill

Australian Department of Climate Change, Energy, Environment & Water Jun-23

Our third submission on this complex and contentious topic. 

Fuel Efficiency Standards

Australian Department of Infrastructure May-23

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

Australian Treasury May-23

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

Tasmanian Climate Action Plan

Tasmanian Government Apr-23

A great submission prepared by the local group with review and minor input from the policy & submissions team.

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

Australian Department of Climate Change, Energy, Environment & Water Apr-23

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

Australian Department of Climate Change, Energy, Environment & Water Apr-23

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

Tasmanian Government Apr-23

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

Australian Department of Climate Change, Energy, Environment & Water Feb-23

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

Australian Department of Climate Change, Energy, Environment & Water  Feb-23

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.

National Energy Performance Strategy (NEPS) Australian Department of Climate Change, Energy, Environment & Water Feb-23

"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.

Pre-budget submission Commonwealth Jan-23

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.

"Living Wonders" submissions x18 (example AP4CA submission attached here) Minister for the Environment Nov-22

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.

National Energy Transition Authority Senate Standing Committee on Economics Nov-22

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.

NSW EPA Climate Action Policy NSW Environmental Protection Agency Nov-22

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.

National Electric Vehicle Strategy Australian Department of Climate Change, Energy, Environment & Water Oct-22

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.

Native Forest Wood Waste in the Renewable Energy Target (RET) Australian Department of Industry, Science & Resources Oct-22

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.

EPBC Climate Trigger Senate Inquiry Oct-22

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. 

Chubb Review into Australian Carbon Credit Units (ACCUs) Australian Department of Industry, Science & Resources Sep-22

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.

Safeguards Mechanism Consultation Australian Department of Climate Change, Energy and Water Sep-22

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.

Biodiversity Offsets Consultation Australian Department of Agriculture, Fisheries and Forestry Sep-22 New Environment Minister Tanya Plibersek has announced that she supports the use of biodiversity offsets. While there can be valid uses - to protect sensitive ecosystems that might not otherwise be protected (including, for example, where nature-based carbon credits are don't work) - there are many issues with their use and regulation, as has been exposed most recently by the damning findings of the NSW Audit Report.
Comment on Central Queensland Coal Refusal Australian Environment Minister Aug-22 Comment on the Minister for the Environment's draft decision to refuse permission for a new coal mine. Apparently the first time this has happened, though for reasons primarily related to the project's proximity to the Great Barrier Reef. Early in 2023 the Minister confirmed that Clive Palmer's mine would be blocked.
Climate Change Bill (2022) Australian Senate Inquiry  Aug-22 The Climate Change Act became law in September 2022 without material further changes. It legislates 43% off 2005 emissions levels by 2030 (as a floor) and net zero by 2050, and includes the requirement for advice from the currently-compromised Climate Change Authority. Since then, Minister Bowen has appointed three additional members to the board of the CCA, which AP4CA welcomes (but has not removed contentious members such as the current Chair Grant King, a former head of Origin Energy).
Select Committee on Public and Active Transport South Australia Aug-22 Prepared by the SA local AP4CA Group!
Narrabri Underground Mine Stage 3 Extension Project NSW Independent Planning Commission Feb-22

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.

Warratah Coal Call In - Qld state government realising that it was inappropriate for a local council to be in the position of determining a substantial coal mine Queensland Nov-21 The project was called in and is now being reconsidered at State level. Outcome pending
Victorian Renewable Energy Inquiry Victoria Nov-21 Our submission was cited about a dozen times in the inquiry's report. In October 2022, the Victorian Government announced targets for 2035 of 95% renewable electricity and 75-80% off economy-wide emission (vs 2005 levels). This is one of the most ambitious targets in the world!
Inquiry into the Response of Western Australian Schools to Climate Change Western Australia Nov-21 Our submission was cited in the committee's report in a context that suggests that our comments that participation in climate action conveys positive mental health benefits for children and young people may in part have inspired one of the main themes of the report: "Making Hope Practical."
NSW Future Transport Transport for NSW  Nov-21 We have not been advised of outcomes from the consultation.
National Construction Code Public Comment Australian Building and Construction Board Oct-21 We supported a Zero Emissions Homes campaign led by building sustainability professionals and academics. The NCC changes have not yet been determined.
NT Greenhouse Gas Emissions Offset Policy Northern Territory Oct-21 "A Northern Territory government promise to ensure all greenhouse gas emissions from fracking the Beetaloo Basin will be offset is in doubt, according to a government-appointed policy watchdog."
Senate Economics References Committee: Australia's Oil and Gas Reserves  Australian Senate Inquiry Aug-21 The committee's report's recommendations can be found here. In particular it was refreshing to see this: "As Australia transitions to net zero emissions by 2050, the committee recommends that the Australian Government consider supporting the diversification and transition to clean and renewable energy especially in areas like green hydrogen, with a role also for blue hydrogen. It is critical to ensure workers are not left behind and this could be achieved through measures like new energy apprenticeships to ensure that the necessary skills are developed."
Proposal to open the NSW Hawkins Rumker region for coal mining NSW Department of Planning, Industry & Environment Aug-21 Hawkins Rumker was formally ruled out for coal exploration.
Victorian Gas Substitution Roadmap Victoria Jul-21 The Victorian Government has acknowledged that gas emissions must be reduced and proposed a combination of "energy efficiency, electrification, hydrogen and biogas to drive down bills and enhance access to an affordable, secure, reliable and safe supply of energy."
Inquiry into Oil and Gas Exploration and Production in the Beetaloo Basin Senate Environment and Communications References Committee Jul-21 The new federal government reopened submissions in August and will accept previous submissions in its assessment, with the report due by 14 February 2023. Meanwhile, NT Labor has passed resolutions opposing fracking in the NT and Origin Energy, one of several firms with gas exploration licenses in the Beetaloo Basin, has walked away from its holding, selling it at a loss. 
Hunter Power (Kurri Kurri Gas Power Plant) NSW Department of Planning, Industry & Environment (proponent: Snowy Hydro, at the direction of the Australian Government Jun-21

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.

Post 2025 Market Design Options Paper Australian Energy Security Board Jun-21 Not yet concluded. The ESB has indicated a preference for a so-called capacity mechanism and other regulation that could result in coal fired generators being paid to stay open longer than necessary. In August 2022, State & Federal Energy Ministers were again urged to reject these reforms.
Inquiry into the Prudential Regulation of Investment in Australia's Export Industries Joint Standing Committee on Trade and Investment Growth Apr-21 This inquiry was called for by the previous Federal Resources Minister (Keith Pitt) in an attempt to shame banks who had announced moratoria on their funding of coal projects. The committee's report called for a number of further reviews. To our knowledge, no regulatory changes or legislation has come out of the inquiry.
NSW Design & Place SEPP NSW Department of Planning, Industry & Environment Apr-21 The SEPP was the first attempt  by the NSW Government to require serious planning for climate resilience. It was bitterly fought by property developers as documented in this article, and was dumped by the new Planning Minister earlier in 2022.
Future Fuels Strategy consultation Department of Industry, Science, Energy and Resources Apr-21 The former government's resulting climate-related transport policy was a disappointment, with transport emissions projected to increase 6% during the decade.
EPBC (Standards & Assurance) Bill 2021 Senate Environment and Communications Legislation Committee Mar-21 The new Federal Environment Minister has vowed to implement the findings of the Samuels Review, something the previous government did not.
More to come - watch this space as we populate this page!      

 


Australian Parents for Climate Action meet and work on the lands of Aboriginal & Torres Strait Islander people and respect that sovereignty of those lands was never ceded. We pay respect to Elders, past and present and emerging, and acknowledge the pivotal role that Aboriginal & Torres Strait Islander people continue to play within the Australian community.