Submission: Setting Victoria’s 2035 climate target

June 6, 2022 at 12:48 pm Leave a comment

Projection of carbon emissions reduction pathway for 1.5C, net zero by 2035.

What should Victoria’s 2035 emissions reduction target be? We strongly believe it should be science based taking into account our carbon budget with global equity considerations. The Victorian Government called for submissions by June 5, 2022. Our submissions concentrated on Transport, as we see that is a major policy blind spot with regard to public transport, active transport and aviation.

  • Victoria’s target for 2020 was to cut emissions by 15-20% below 2005 levels. That target was achieved two years early.
  • Victoria’s target for 2025 is to cut emissions by 28-33% below 2005 levels.
  • Victoria’s target for 2030 is to cut emissions by 45-50% below 2005 levels.

Read our submission for 2025 and 2030 targets in which we argued for at minimum the emissions cuts identified by the Combet review matching the science: of at least 43% by 2025 and 67% by 2030 to have any chance of limiting warming to 1. 5°C. (Download PDF version)

The next short-term target, for 2035, must be set by 31 March 2023. An independent panel of experts will advise on a target for 2035, the best action to reach that target and what the pathways to net zero emissions by 2050 could look like. The Panel will prepare a report with their advice to government by 1 March 2023.

Submission on Victorian 2035 Climate Targets

Executive Summary

We appreciate the opportunity to comment on the recommended emissions targets for Victoria (2031-2035) report prepared by the Independent Expert Panel. In addition to the survey which we have appended, we have elaborated further in a number of areas.

Science Based Target needed

We argue that the science strongly indicates we have a climate crisis and that Victoria (and Australia) needs to declare a climate emergency, and to focus resources on ambitious emissions reduction and climate adaptation. Targets should be science based according to carbon budget taking into account global equity requirements. The Climate Council has put forward the case for a strong science based target of 100 percent emissions reduction by 2035.(1) 

Equity issues

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. 

No community or social group should be left behind. 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.

Aviation emissions and Melbourne airport

We particularly highlight the need 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. (2)(3)(4)

We also have highlighted the importance of high speed rail to Victoria’s regional centres and as part of an east coast high speed rail network. This both addresses equity issues, reduces transport emissions, provides important high value employment during construction and operation, and provides an important alternative to aviation use between Melbourne and Sydney, one of the busiest domestic flights routes globally.

Transport Emissions

We understand the imperative for transition to EVs to reduce transport emissions, but to date there has been a high level of silence on the role of improving public transport to a high frequency service, and to improve active transport.

We note that moving to electric vehicles will only solve half the vehicle emissions problem, the other half being abrasive particulate emissions from brake use and tyre contact with the road.(5) 

Active Transport

There has been recent local Melbourne research on the potential for large cycling increase.

The study by Pearson et al (March 2022), The potential for bike riding across entire cities: Quantifying spatial variation in interest in bike riding, provides justification for separated cycling infrastructure to encourage people interested in cycling to start doing so.(6)

The researchers conclude that “Our results show the potential for substantial increases in cycling participation, but only when high-quality cycling infrastructure is provided.”

The research noted that:

Over half of participants owned a bike, however only one in five rode a bike at least once per week. Most participants were classified as Interested but Concerned, demonstrating a high latent demand for bike riding if protected bicycling infrastructure were provided.

On gender the research found that more men owned a bike, rode at least once a week. There were also less women who were Strong and Fearless or Enthused and Confident as men, but the proportion who were Interested but concerned was comparable for both men and women

The research also found a correlation between income and propensity to use cycling. Investing in cycling infrastructure would enhance social equity.

In this study, a higher proportion of people in the lower income categories rode a bike for transport purposes, and rode four or more days per week, compared to people in the higher income groups. Similar findings have been shown both in Australia and interna­tionally, where there was an association between increased household income, and a decreased proportion of people riding a bike for transport…. To support lower income groups in bicycle-commuting and reduce health inequities faced by low socioeconomic groups, high-quality and protected bicycling infrastructure should be provided equitably to support local travel and connections with public transport.

The research also highlights that painted bike lanes just don’t do the job of satisfying safety and moving substantially more people to cycling. Painted bike lanes are used as a cheap transport option which doesn’t actually increase safety and still leaves substantial numbers of people interested but concerned and not cycling.

The IPCC 6th assessment report also stresses in numerous places the importance of investment in active transport for walking and cycling as a vital component in urban areas for climate mitigation and adaptation.(7)

Comparing NSW and Victorian Government active transport funding

We particularly note a huge disparity between NSW and Victoria with investment in active transport. NSW now has an Active Transport Minister, Rob Stokes, with a five year budget for cycling and walking of $980 million (8), an amount which Stokes wants to double.(9)

Victorian State Government budget 2022 on cycling: “There is roughly $21.8 million allocated for active transport, with the Department of Transport earmarking a number of bike projects across metropolitan and regional Victoria.” says Bicycle Network, who also highlight some cycling infrastructure being built as part of major road projects and upgrades.(10) 

It seems the Victorian state government is far behind in funding active transport infrastructure as compared with north of the border.

We think the Victorian government needs to prioritise funding for active transport which will reduce transport emissions, reduce congestion, increase liveability, and add substantial health co-benefits. On a dollar for dollar basis this is of much greater value for money than expanding the freeway network which locks in car dependency and emissions. 


Our submission has especially focussed on transport as we believe this is an area that requires substantially more work at the Victorian government level, especially improving public transport and active transport. 

We note that the City of Moreland is well on its way of achieving 80-100 per cent in its operational emissions by 2030, has set a community target of 75 percent emissions reduction by 2030, net zero by 2035, and carbon negative by 2040.(11)  

Achieving these community targets will require substantial progress on decarbonising the electricity grid at the state level and improving the public transport network and network service frequency, and greatly improving the dedicated infrastructure for walking and cycling.

This submission was a collaborative work by members of Climate Action Moreland.

John Englart
Convenor, Climate Action Moreland


About Climate Action Moreland

Climate Action Moreland is a grassroots climate action group that was started in 2007, 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 according to science based targets and policies and development of carbon drawdown techniques.

John Englart
Climate Action Moreland

General survey

Please answer the following questions. You do not need to answer every question.

The issues paper available on this website provides background information relating to these questions.

1. Are you completing this survey on behalf of an organisation or as an individual?

  • Organisation: Climate Action Moreland

Which sector are you completing this survey on behalf of?

  • Community and non-profit

2. What do you think is most important when setting a Victorian emissions reduction target for 2035?

  • If the target is a fair contribution to help keep global warming well below 2°C / 1.5°C
  • The environmental benefits in meeting the target
  • The health benefits (including lower health costs) in meeting the target
  • Other (Moving to a doughnut economic model of ensuring social limits are met while staying within planetary boundaries.)
  • If the target puts Victoria on a sensible pathway to net zero emissions by 2050
  • If the target will give Victoria an economic advantage
  • How effectively the target drives Victoria’s economic growth
  • If options are available to meet the target
  • The cost to reach the target

If you selected ‘Other’ in question 2, please specify:

  • Moving to a doughnut economic model of ensuring social limits are met while staying within planetary boundaries.

3. What emissions reduction target do you think Victoria should set for 2035?

  • 100%

4. What three things do you think will cut Victoria’s emissions the most in the period 2031-2035?

  • Renewables and storage, sustainable agriculture, sustainable transport including moving to EVs, investment in active transport for urban areas, limiting aviation demand, High speed rail connection to Sydney

5. What benefits can you see in a low emissions economy for Victoria in 2031-2035?

  • Less pollution, better air quality, 
  • more people walking and cycling contributing to health co-benefits. 
  • Restoration of habitats, conservation of biodiversity.
  •  Better integration of sustainable farming practices increasing sequestration both in vegetation and soil organic carbon. 
  • More jobs in conservation, reafforestation, renewables, so that no-one is left behind, and Victorian economy stays within planetary boundary limits, especially for pollution, greenhouse gases

6. What challenges might Victoria face in reducing emissions in the period 2031-2035?

  • Decarbonising transport will need further work, especially limiting aviation demand. 
  • Decarbonising Agriculture will require long term changes to farming practices for sustainability which may require both education and support to farmers, and landcare groups. We should be endeavouring to reduce methane emissions from agricultural animal husbandry both through feedlot supplements and in reduction in herd due to consumer behaviour change in adopting a largely plant based diet as recommended by the IPCC. 
  • Suburban rail loop is a good idea, but present timeline is too slow. Development should be accelerated. 
  • Upfield Rail line should be extended to Wallan as a priority. This will reduce car dependency and increase levels of equity in people living in new residential developments in the northern peri-urban suburbs. 
  • Federal Labor is committed to establishing a High speed Rail Authority. Victoria should commit to planning and building Melbourne to Albury High speed rail as part of the east coast network with a timeline for Melbourne to Albury of in the next decade.

7. How could Victoria overcome potential challenges to reducing emissions in 2031 – 2035?

  • For Transport, Victoria needs to be investing to a much greater extent in active transport which requires funding and building safe protective bike lanes and more pedestrian crossings, and expanding public transport network to cover peri-urban developments and ensuring a turn up and go frequency of service of at least 10 minutes.
  • Victoria should look to oppose the third runway at Melbourne airport to cap flight demand, as aviation is highly carbon intensive form of travel with no short term solutions, and further increase in demand for aviation should be discouraged. Part of the solution is building an east coast high speed rail network, of which the Melbourne to Sydney link would be of importance in reducing flight demand on one of the busiest domestic flight routes globally.
  • Victoria should be well on the way to phasing out all commercial and residential gas use.

8. What can be done to make sure the benefits and costs of climate action are fairly shared?

  • For transport, investment in the rail and bus public transport network to a turn up and go service of 10 minutes frequency. 
  • For the Northern suburbs transport corridor the Upfield line should be duplicated to Upfield, extended to Roxburgh Park, Craigieburn and on to Mickleham and Wallan. This should be a priority project and has been identified as an important project by Infrastructure Australia, but without a sponsor. This will improve equity of people living in peri-urban new residential developments in Melbourne’s north, reducing their car dependency.
  • Much more investment in active transport should be funded from the present. Recent research shows up to 78 percent cohort of people across Melbourne who are interested but concerned category regarding cycling and it requires separated bike infrastructure to move many in this cohort to cycle on a regular basis. Moving people to cycling and e-mobility will also reduce congestion leaving more room for those who need to drive, and reduce transport emissions, and increase health co-benefits.
  • In the northern region of Melbourne: 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 liveability.
  • 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 Authority needs to be continued and adequately funded and 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.
  • 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.

9. Is there anything else you would like to share with us?

  • 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.

10. Do you consent to your comments being referenced by the Panel’s published report?

  • Yes


  1. Professor Will Steffen, Professor Lesley Hughes, Dr Simon Bradshaw, Dinah Arndt, Dr Simon Rice, Climate Council, 15 April 2021, Aim High, Go Fast: Why Emissions Need to Plummet this Decade,
  2.  see Elephant in the Sky. The hazards of Aviation Emissions and how we can avoid them (2018) Mark Carter
  3. Alice Bows-Larkin (2015) All adrift: aviation, shipping, and climate change policy, Climate Policy, 15:6, 681-702, DOI: 10.1080/14693062.2014.965125 
  4. Submission: Melbourne Airport flying blind on aviation emissions danger October 8, 2018, Climate Action Moreland, 
  5. Roy M. Harrison et al (2021), Non-exhaust vehicle emissions of particulate matter and VOC from road traffic: A review, Atmospheric Environment, Volume 262, 2021, 118592, ISSN 1352-2310,
  6. Pearson et al (March 2022), The potential for bike riding across entire cities: Quantifying spatial variation in interest in bike riding, Journal of Transport & Health, Volume 24, March 2022, 101290, 
  7. John Englart 3 June 2022, Extend the Upfield Bike Path, What does the IPCC 6th assessment climate report say on cycling, and addressing local Melbourne transport mode shift 
  8. Bicycle Institute of NSW, 5 May 2022, Sydney’s Fastest Growing Bike Network 
  9. Sydney Morning Herald, 6 February, 2022, Rob Stokes aims for doubling in spending on cycleways, footpaths 
  10. Bicycle Network, 5 May 2022, Victorian Budget 22/23: what’s in it for bikes? 
  11. Zero Carbon Moreland, 20 December 2021,  Moreland endorses new aspirational zero carbon targets for 2030 

Entry filed under: aviation, climate change info, cycling, Policy, public transport, submission, transport, Victorian Government, walking. Tags: , , , .

Submission: Keep building Protected bike lanes in City of Melbourne Climate and sustainability Comment on Council agenda 13 July 2022

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