Submission: Setting Victoria’s climate targets for 2025 and 2030

July 22, 2019 at 3:33 pm 1 comment

Submission on Victorian Climate Targets

Executive Summary

We appreciate the opportunity to comment on the recommended emissions targets for Victoria as contained in the Interim Emissions Reduction Targets for Victoria (2021-2030) report prepared by the Independent Expert Panel.

We argue that the science strongly indicates we have a climate crisis and that Victoria (and Australia) needs to declare a climate emergency, to focus resources on ambitious emissions reduction and climate adaptation.

While we appreciate the work of the expert panel, we think the recommended targets are still too low, even by their own assessment of the targets required to meet the 1.5C temperature target as contained in the Paris Agreement.

Reducing emissions needs to address equity issues, so we also call for transition programs that address equity, both on the local level and as part of addressing the problem globally. As a matter of global equity and justice Australia as a developed country should decarbonise faster than the many developing countries that need to address poverty and social issues and already have low carbon footprints.

We particularly highlight that the Expert panel failed to address the growth in aviation emissions as part of transport emissions, and the expansion of Melbourne’s airports which induces growth in these emissions. This is a difficult niche area to decarbonise, but the first step should be to stop airport expansion which will cap the growth in aviation and aviation emissions.

This submission (PDF) was a collaborative work by members of Climate Action Moreland and follows the suggested question survey for consultation.

John Englart
Convenor, Climate Action Moreland

Question 1:

The Independent Expert Panel recommends Victoria set greenhouse gas emissions reduction targets of:

  • 32-39% below 2005 levels in 2025 and
  • 45-60% below 2005 levels in 2030.

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


1b: Why/why not?

The proposed targets are not consistent with keeping global warming to 1.5 degrees, and the numerous risks enumerated in the IPCC Special Report on Global warming of 1.5C1.

The lower target is particularly catastrophic. Targets need to be higher to ensure we are doing our part to prevent the worst impacts of climate change.

This point cannot be overstated. The reports of the Breakthrough Institute, most particularly What Lies Beneath (2018)2, bring out the unacceptably high risks of catastrophic scenarios accompanying a failure to limit climate change to 1.5 degrees C of warming. It is the height of recklessness to accept a one half, or even one third, chance of 2 degrees of warming, given the fact that this risks crossing tipping points that would lead to runaway climate change, the death of the majority of people on Earth and the destruction of human civilisation. All efforts have to be devoted to ensuring that there is no appreciable risk of warming exceeding 1.5 degrees.

The Combet Review identifies emission cuts of at least 43% by 2025 and 67% by 2030 to have any chance of limiting warming to 1. 5°C (Figure 5.2), yet appears to justify lower targets, even though there is scientific research3 that indicates there are several dangerous tipping points that should require substantial risk minimisation in setting ambitious targets.

Victorian 2025 and 2030 Climate targets consistent with 1.5C – DELWP

It should also be pointed out that, though Victoria alone cannot prevent climate change, strong targets in Victoria are vital to emissions mitigation at the national and global level.

Within Australia, a strong Victorian emissions target will drive structural economic change that reduces emissions nationally and puts laggard States under pressure to improve their efforts. Internationally, Australia is the highest per capita emitter in the OECD (and one of the highest in the world) and Australia’s status as effectively a free rider is a strong disincentive to other countries taking up their own share of the necessary decarbonisation. Effective action in Victoria, and Australia, therefore, makes effective global action easier.

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?

This list of issues to be considered by the Panel is appropriate.

Another important issue to consider is intergenerational equity and international equity between developed and developing countries: even if acting to cut emissions now has an impact on current Victorians, the impacts of climate change will be significantly greater on future Victorians (including most of those alive today) and will particularly impact the poorest both in Australia and on a global level.


Victoria has choices about the emissions reduction pathway, or trajectory, to follow to reach net zero emissions by 2050. Different trajectories imply different costs and benefits over time. The Panel’s advice includes indicative trajectories to 2050 associated with its recommended targets (see figure above and Chapter 5 of the Panel’s report).

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



3b: Why/why not?

The Panel’s indicative trajectories to 2050 are not compatible with limiting warming to a 1.5 global average temperature increase. Reaching 45% cuts by 2030 would fully exhaust the 1.5 carbon budget, and reaching 60% by 2030 would require Victoria to dramatically accelerate emissions reduction to become carbon neutral by 2034 – a very unlikely prospect.

Chapters 6 and 7 of the report show that there are many cost-effective abatement opportunities in Victoria which will yield the most benefits if they are quickly adopted. Earlier deep cuts give us the best opportunity to resolve harder-to-eliminate emissions after 2030.

Reducing Greenhouse Gas Emissions in Victoria

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

While the panel properly identified the categories of greenhouse gas emissions reduction opportunities, the Panel’s modelling was too conservative. For example, despite South Australia’s plans to reach net one hundred percent renewable electricity generation by 2030, the Panel estimated that the opportunities for Victoria were limited to emissions cuts from electricity in the 16-52% range.

A faster roll-out of renewable energy would lead to a faster phase-out of coal generation and would enable much greater cuts from the electricity sector. This would in turn unlock GHG emissions reduction opportunities in other sectors through replacing direct combustion processes (such as transport and residential gas usage) with renewables-based electricity.

Further, while the Panel correctly identified transport mode shift as an opportunity, it was not sufficiently explored or emphasised. Emissions can be mitigated further and faster through a comprehensive program of improvements to public transport and cycling than through the conversion of the private car fleet to batteries. This would have major co-benefits for Victorians, both in Melbourne and the regions.

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

The three factors that the Victorian government should prioritise are cost-effectiveness (highest reduction activities with the lowest cost of abatement), whether an activity unlocks further greenhouse gas emissions reduction opportunities and whether the activity acts to provide a just transition. A just transition is essential for maintaining public support for the necessary emissions reductions.

Decarbonising the electricity grid is one of the most cost-effective solutions available. Additionally, it unlocks further emissions reductions opportunities which if adopted could put us on an emissions trajectory compatible with a 1.5 degree objective.

After energy transition, addressing transport emissions should be addressed through policy, regulation and priority budget funding including but not limited to:

  • transition to Electric vehicles, commercial and Freight Vehicles
  • Mode share change to public transport and active transport
  • Upgrade and extend Melbourne public transport to a ‘turn up and go’ service
  • Upgrade of regional rail to high speed rail service
  • Start on Victorian component of an east coast high speed rail network (which will also provide a partial alternative to domestic aviation for Melbourne-Sydney, the 2nd busiest domestic flight route globally4)

More emphasis on reducing gas use in residential and commercial infrastructure. Gas should not be installed in new residential developments.

Within the northern region of Melbourne:

  • Priority project to upgrade and extend the Upfield rail line to Wallan to serve the new suburbs being created on Melbourne’s peri-urban edge to reduce traffic congestion, parking congestion, and transport emissions.
  • Priority Construction of the Northern region cycle and walking trails, estimated at a cost of $162 million and 650 FTE jobs, to boost active transport and liveability5

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

The fundamental program is the Victorian Renewable Energy Target. This should be the mechanism to ensure that enough renewable energy is constructed to drive decarbonisation. The individual power station owners would decide themselves, subject to the requirement for giving three years notice, the closure dates of their brown coal generators.

Supporting this should be:

(a) A strong program of pursuing energy efficiency, with a special focus on overcoming the split incentive in the built environment between landlords and tenants and between developers and building owners.

(b) A program of construction of public transport facilities and the provision of “turn up and go” service levels across Melbourne and Victoria’s regional cities to drive transport mode shift. An improved V-Line service, together with adequate bus services in rural and regional areas, would assist in themselves as well as being an equity measure to ensure that the program is broadly supported. The Government’s existing public transport investment program is obviously part of this, as well as the proposed Melbourne Metro 2. The Melbourne Ring Rail should be brought forward to be completed by 2040 at the latest and preferably by 2030.

(c) The construction of a dense network of separated bicycle paths, especially but not confined to the CBD and inner suburbs, to drive transport mode shift. As well as being very inexpensive, promotion of cycling is complementary to promotion of public transport through taking pressure off trams and trains as they near their morning CBD destinations and leave the CBD in the evening. Outside of the inner areas, provision of facilities for cycling to school would be the single most effective means of taking cars off the road and averting their emissions.

(d) A Just Transition strategy. The necessary decarbonisation of society can only be achieved if the means of doing so are broadly supported. Many workers and communities, not least in the Latrobe Valley, are currently reliant on unsustainable industries for their livelihoods. It is both unjust and politically unviable to use these workers and communities as human sacrifices for the necessary zero carbon transition. The Just Transition strategy should therefore be thoroughly thought through, well designed and adequately funded. The Latrobe Valley should be the initial focus, but all sectors and localities of society should be examined from this perspective, to ensure that no community is left behind.

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

Offsets should only be acceptable as an option of last resort, not a first port of call.

Further, offsets should only be considered subject to some key principles: offsets should not have a negative impact on biodiversity; offsets must be subject to a rigorous monitoring and accounting regime; communities need to be involved in planning local offsets; and international offsets should be excluded.

Finally, offsets are a temporary measure to buy time for decarbonisation to be achieved. They are not a substitute for decarbonisation.


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?

The panel did an excellent job identifying the key benefits of reducing GHG emissions.

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

There are many important benefits. The single most important, though, is that this would contribute to avoiding the worst case scenario of the destruction of industrial civilisation.

Reducing coal fired power will reduce pollution impact on health of people in the La Trobe Valley. Transition to EVs and mode share change to public transport and cycling will also reduce air pollution which will increase population health in urban areas.

Mode share change to public transport will produce substantial co-benefits in health assisting in the reduction of obesity levels in the population.6

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?

Yes. The Panel didn’t mention the increasing emissions from aviation and expansion of airport infrastructure which will induce more flights and greater aviation emissions and aviation climate impact. This sector currently has no credible pathway to reducing its greenhouse emissions significantly.7 Aviation emissions are a growing component of transport emissions and are very difficult to mitigate.8

Worse, the state government is supporting expansion to airport infrastructure which will induce expansion and growth of aviation emissions. In our submission to the preliminary Draft Melbourne Airport Masterplan 2018 we highlighted our grave concerns9:

The preliminary Draft Melbourne Airport Masterplan 2018 is predicated on a continuance of growth in air travel, and the aviation emissions that this engenders. The Masterplan fails to outline in any way the necessary links between growth in airport infrastructure facilitating growth in passenger numbers and flight numbers, and thus aviation emissions, which will increase the global climate change impact.

We note that while the Australia Pacific Airports (Melbourne) (APAM) Corporation has undertaken to participate in the TAKE2 Climate Change Pledge involving it’s Collaboration with the Victorian Government and other businesses to support the Victorian Government’s commitment to reach net zero emissions by 2050, it does not highlight that this does not apply to aviation emissions. Growth in the terminal and Runway Development Programs will foster a huge growth in aviation greenhouse gas emissions.

We have called for a moratorium on airport expansion10 to limit aviation demand and propose this should remain in place until low carbon commercial aviation has been developed.

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

The most significant barrier that must be addressed is the fact that workers and communities in the Latrobe Valley and elsewhere in Victoria currently have their livelihoods tied to unsustainable and carbon-intensive industries.

We have already seen the way in which people in coal mining communities can be used as a smokescreen for vested interests who wish to prevent or delay the necessary decarbonisation of society.

The Victorian government must adopt policies that ensure a fair and just transition for all Victorians. This would be called for on equity grounds alone, but experience demonstrates that the only possible transition is a Just Transition.

Another significant barrier to reducing emissions in Victoria is the lack of a comprehensive transition plan which involves rapidly increasing the share of renewable generation while at the same time managing an accelerated phase out of coal-burning power stations and improving energy efficiency. We acknowledge that Victoria has some significant policies to deliver renewable energy, but these do not yet form part of a comprehensive strategy to decarbonise our electricity, transport and buildings.

Finally, aviation emissions are growing rapidly worldwide and, if not addressed, will become a major barrier to decarbonisation. The sector currently has no credible pathways to decarbonisation.(See answer to Question 9)

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

The Latrobe Valley Authority needs to be strengthened, with improved funding and made pro-active, probably with a different name. It firstly needs to investigate the extent and timing of the structural changes to the Victorian economy that will accompany decarbonisation. Having done this, it needs to work with affected workers and their unions, and with communities in the Latrobe Valley and elsewhere where applicable, to develop a participatory transition plan so that they will not be victims needing rescue but actors on their own account for a sustainable future.

New industries arising directly from decarbonisation should be prime candidates for inclusion in these plans, but plans should not be confined to them. Taking advantage of communities’ knowledge of their own skills and resources, and providing adequate funding to put them into operation, will enable their ownership of the transition and the continued broad support of the Victorian public that will be necessary.

A transition plan for the electricity system is necessary. This will include a strong VRET, analysis of the nature and timing of improvements to the electricity grid, indicative timings of the closure of brown coal generators, plans for transport mode shift and the spread of electric vehicles and the amount and timing of pumped hydro and battery storage that will be necessary as the electricity generation system approaches 100% renewables.

The La Trobe Valley Authority has provided an important role in economic diversification and transition for the La Trobe Valley communities. We would like to see either a statewide Just Transition Authority, or even a Ministry of Transition to devise and drive individual plans tailored for each Victorian region’s needs.

Finally, while tackling decarbonisation of aviation is outside the sphere of responsibilities of the Victorian Government, one thing that should be done is that no expansion of Melbourne or Avalon Airports should be permitted unless and until the sector has discovered a viable pathway to decarbonisation and is committed to implementing it.

Impacts of reducing greenhouse gas emissions 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?

The most important impact will be ensuring Victoria avoids the devastating impacts of global warming. While other impacts such as regional economic disruption or energy supply challenges need to be monitored and managed, they should not outweigh the need to protect all our communities from climate chaos.

The panel correctly identified positive impacts of ambitious climate policy such as reduction in air pollution, further availability of water, health benefits and economic benefits as Victoria harnesses the opportunities of new clean technology industries.

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

The most important impacts to address are the ones that touch on issues of justice. To ensure a fair and just transition the government must provide support for impacted regions such as the Latrobe Valley and for low-income or vulnerable households.

14: How can these impacts be addressed?

A strengthened and re-named Latrobe Valley Authority, as above. Either a Transition Department or a Victoria-wide Transition Authority established to draw up economic and climate transition plans specifically targeting each region.

As also noted by the Panel, energy efficiency for both homes and businesses will serve to reduce the impacts of any changes in energy prices. Scaling up energy efficiency policy creates a clear win-win situation.

Other Comments

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

We have the opportunity to advance decarbonisation along with achieving other necessary and desirable goals such as equity, improved health outcomes and better functioning cities. Our children will not thank us if we don’t take it.


About Our Group

Climate Action Moreland is a grassroots climate action group that was started in 2008, with a strong local focus addressing climate issues in Moreland, and advocacy at local, state, federal and international levels for strong and rapid climate action.

Climate change is an important imperative for Moreland citizens:

  • We know that climate change is already affecting us in Moreland with more frequent and intense heat events, more torrential rainfall events producing flash flooding.
  • As a highly urbanised municipality, Moreland is has a strong urban heat island effect.

Climate Action Moreland recognizes climate change is an existential problem that needs to be addressed through declaration of a climate emergency and plans for rapid implementation of emissions reduction to zero carbon emissions and development of carbon drawdown techniques.

John Englart
Climate Action Moreland


1 GLOBAL WARMING OF 1.5 °C – an IPCC special report on the impacts of global warming of 1.5 °C above pre-industrial levels and related global greenhouse gas emission pathways, in the context of strengthening the global response to the threat of climate change, sustainable development, and efforts to eradicate poverty (October 2018), Myles Allen, Barbiker Mustafa, Priyadarshi R. Shukla, etal, IPCC

2 What Lies Beneath: The scientific understatement of climate risks, September 2017, David Spratt and Ian Dunlop, Breakthrough Institute

3 Trajectories of the Earth System in the Anthropocene

Will Steffen, Johan Rockström, Katherine Richardson, Timothy M. Lenton, Carl Folke, Diana Liverman, Colin P. Summerhayes, Anthony D. Barnosky, Sarah E. Cornell, Michel Crucifix, Jonathan F. Donges, Ingo Fetzer, Steven J. Lade, Marten Scheffer, Ricarda Winkelmann, Hans JoachimSchellnhuber
Proceedings of the National Academy of Sciences Aug 2018, 115 (33) 8252-8259; DOI:10.1073/pnas.1810141115

6 Obesity-related health impacts of active transport policies in Australia – a policy review and health impact modelling study.
Brown, Vicki, Moodie, Marj, Cobiac, Linda, Mantilla, Herrera and Carter, Robert 2017, Obesity-related health impacts of active transport policies in Australia – a policy review and health impact modelling study, Australian and New Zealand journal of public health, vol. 41, no. 6, pp. 611-616, doi: 10.1111/1753-6405.12726.

7 Elephant in the Sky. The hazards of Aviation Emissions and how we can avoid them (2018) Mark Carter

8 Alice Bows-Larkin (2015) All adrift: aviation, shipping, and climate change policy, Climate Policy, 15:6, 681-702, DOI: 10.1080/14693062.2014.965125

9 Submission: Melbourne Airport flying blind on aviation emissions danger October 8, 2018, Climate Action Moreland,

10 Call for Moratorium on Melbourne Airport expansion, October 1, 2018, Climate Action Moreland,

Entry filed under: climate change info, Climate Emergency, Just Transition, submission, Victorian Government. Tags: , , .

Just Transition: An Idea Whose Time has Finally Come? Melbourne airport third runway will induce aviation emissions growth

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