The Federal Government announced in 2014 that it would be “reviewing its climate change policies to take stock of Australia’s progress in reducing emissions, and ensure the Government’s policies remain effective in achieving Australia’s 2030 target and Paris Agreement commitments”.

Submissions to this Review were called for in March 2017, and closed on 5 May 2017.  350 Australia made a submission.



Access the full text of our submission here:

350 Climate policy review submission rev



Action on climate change is more urgent than ever.  This is clear from the surge in global temperatures over the past two years, the bleaching events that have severely damaged the Great Barrier Reef, and the increasing frequency and severity of natural disasters, including four major cyclone events in Australia since 2011.

The overwhelming climate science consensus is that these changes are due to the level of carbon dioxide in the atmosphere, which now stands at 407 parts per million (ppm), compared to less than 350 ppm just 30 years ago, and that this rapid rise is due to the combustion of fossil fuels in electricity generation, transport and other sectors of the global economy.

We submit that Australia must do its fair share to limit global warming to well below 2ºC and preferably no more than 1.5ºC, as required under the Paris Agreement, and aim to return carbon in the atmosphere to 350 ppm.

We cite analysis showing that Australia’s fair share of the world’s remaining carbon budget to limit warming to 1.5ºC is 2.5 Gigatons of CO2 from 2015.  At the current rate of emissions, this budget will be exhausted by 2021. The need for urgent action is obvious.

The Discussion Paper sets out the Government’s eight current emission reduction policies but it makes no attempt to assess their effectiveness.  That Australia’s emissions have risen since July 2014 and climate impacts are intensifying is evidence that these policies fall well short of an effective response to the climate imperative.

The Government’s targets are consistent with a global warming outcome well above 2ºC and its policies, in the view of independent experts, will be unable to achieve even these inadequate targets.  Our submission provides an analysis of the shortcomings of all eight policies.  We contrast Australia’s performance, and its policies, with those of the United Kingdom, which has a robust carbon tax and an objective of closing all coal power stations by 2025. The UK’s emissions are now at their lowest level since 1894, and 36% below the reference year of 1990.  By contrast, Australia’s emissions have fallen by less than 4% since 1990.

We recommend additional policy measures that would provide more effective reduction outcomes for each of the sectors addressed in the discussion paper.

In relation to electricity generation, we argue that the need to reduce emissions is paramount, while recognising that Australia must also maintain stability and affordability.

Australia is currently powered by highly emissions-intensive electricity, as coal still plays a major role.  With no carbon price and no plan for the retirement of Australia’s coal-fired power stations, it is not surprising that the Interim Report of the Finkel Review stated: “current policy settings do not provide a clear pathway to the level of reduction required to meet Australia’s Paris commitments”.

We urge a more balanced national electricity objective, with a climate objective linked to the Paris Agreement goal.  We urge the Government to adopt a vision in which, by 2030, the Australian electricity generation system has no fossil fuel generators, but only renewable sources and storage (and balancing) facilities.

For this reason, we urge the Government to establish a clear policy framework that would ensure the orderly retirement of all major coal power stations by no later than 2030.  This framework should include consultation with affected communities, workers and their unions to develop a transition plan to support those affected.  Similarly, we advocate a clear plan for the closure of existing thermal coal mines, and an end to the use of public funds to support fossil fuel projects.

We cite research showing that a goal of 100% renewable electricity is both achievable and affordable.

The Discussion Paper also sought comments on opportunities for improving the efficiency of energy consumption in households and businesses. While appreciating the existence of the National Energy Productivity Plan (NEPP), we cite the views of experts that the NEPP target is not ambitious enough, lacks funding to support the transition to more efficient technologies, and could benefit from stronger leadership.

We draw attention to the need for a strategy to transition away from the use of gas and oil for space heating, including incentives for consumers to switch to renewable-sourced electricity.

We urge the Department of Industry, Innovation and Science to examine policy mechanisms to reduce emissions from heavy industry as part of an industry innovation program.

Noting the methane emissions which arise when organic waste is sent to landfill, we urge the Department of Environment and Energy, and its state counterparts, to identify examples of world best practice in this area, with California’s “75 Percent Initiative” being one candidate.

In relation to transport, we draw attention to our earlier submission made to the Ministerial Forum on Vehicle Emissions, in which we noted the opportunities to:

  • introduce strong fuel efficiency standards to reduce emissions from petrol vehicles;
  • create incentives for the take-up of plug-in electric vehicles; and
  • further reduce emissions by taking advantage of new modes of vehicle sharing as autonomous vehicles become a reality.

In relation to aviation, we note that technological changes to reduce emissions will occur slowly, and conclude that carbon offsetting is the only available option in the short term.  We propose that a mandatory Carbon Offset charge be imposed on domestic air travel at a level sufficient to offset Australia’s 8 Mt of domestic aviation emissions, and suggest that these funds be allocated to ARENA for the delivery of new renewable energy facilities.

In discussing land and agriculture, we note that the Government has spent around $670 million buying permits to stop land clearing emissions, whilst state governments are issuing more permits, so that Queensland alone will have negated the Federal spending in just 18 months of land clearing.   We urge state and territory governments to strengthen and enforce their land clearing regulations, to terminate the logging of all old growth and high conservation value native forest, and to ensure the revegetation of some cleared land, as recommended by the Zero Carbon Australia plan.

We note the significant methane emissions created by enteric fermentation in cattle, and we urge the continued funding of research into livestock feeds that promise to reduce such emissions.  We also note the opportunity of encouraging graziers to modify livestock feeds based on this research.

In relation to climate research more broadly, we urge the Government to ensure that the current level of funding is at least maintained.

The Discussion Paper asked for comment on the use of International Units for carbon offsetting.  We urge the Government to avoid the use of such units unless there are no practicable avenues for domestic action to reduce emissions in particular sectors.



The Government’s (very disappointing) response to the policy review was released on 19 December 2017.  It may be found here.     Comments by the Climate Council may be found here.


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