Joint Submission by

58 Climate Action Groups

20 February 2009

Submission on draft Renewable

Energy Amendment Bill 2009

Renewable Energy Policy Overview

Climate Action Groups believe that the Federal Government’s current policies
on renewable electricity:
• Fail to map out a clean, renewable electricity future for Australia;
• Fail to recognise the substantial role that renewable electricity can play in
reducing Australia’s emissions;
• Fail to drive substantial investment in renewable electricity;
• Fail to promote investor certainty and confidence in renewable electricity;
and
• Fail to encourage Australia’s renewable electricity experts to remain in
Australia.
While we have prepared detailed comments on the Renewable Energy
Amendment Bill below, we believe that a major overhaul of renewable
electricity policy in Australia is required as there is little merit in commenting
on existing policies that will not drive the types of investment and innovation in
renewable electricity that are required.
Climate Action Groups believe that a comprehensive, holistic renewable
electricity policy is required for Australia and call on the Government to
urgently establish a Renewable Electricity Task Force to work on a timeline
and implementation plan for a rapid roll-out of renewable electricity in
Australia.

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This high-level task force should analyse and report back to the Australian
people by 31 July 2009 on the following key areas:
• Mapping out appropriate renewable electricity supply corridors (including
their proximity to the grid) for solar-thermal and photovoltaic (PV), geo-
thermal, wave, biomass, wind and other renewable energy technologies.
• Base-load energy supply through renewable electricity generation.
o Climate Action Groups note that base load solar-thermal is
already proven and available1.
o Climate Action Groups also note that substantial proven geo-
thermal reserves exist in Australia and that the technology for
retrieving and converting this energy to electricity is well
understood and frequently utilised around the world.
• Infrastructure investment requirements to improve the capacity of the
grid to efficiently integrate energy from a myriad of renewable sources.
• Current structural impediments to distributed energy in Australia.
• Detailed economic modelling of the costs and benefits of a rapid roll-out
of 100% renewable electricity into the Australian electricity grid, including
analysis on economic growth, employment and training / skills growth,
investment, energy prices and inflation.
o Climate Action Groups note that large-scale implementation of
renewable technologies has already led to economic, social and
environment benefits including growth in jobs, training and
investment in many countries (including Germany and Spain).
• A “Just Transitions” plan to ensure an equitable and fair transition for
employees and communities affected by a rapid transition to 100%
renewable electricity.

Comments on the Renewable Energy Amendment Bill

Comments on the draft Renewable Energy Amendment Bill 2009 are set out
in the following 6 key areas:
1. 100% Renewable Electricity in Australia by 2020
2. MRET Cannot Cut Emissions Under Current CPRS
3. Replacing MRET with a Gross National Feed-in Tariff
4. Continuing Renewable Energy Rebates
5. 2030 RET Phase-out Paves Way for a Return to Fossil Fuels
6. Removal of “wood waste” reference in MRET

1
The Solar Thermal technology pioneered by Ausra is price competitive with coal when
Government coal subsidies and the cost of pollution are taken into account. This technology
was developed in Australia by Professor Mills and taken to California by venture capitalist
Vinod Khosla. See: AUSRA Australia http://www.ausra.com.au.

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1. 100% Renewable Electricity in Australia by 2020
While the proposed Mandatory Renewable Energy Target of 20% by 2020
appears to be a step in the right direction, it is completely out of line with
current climate science.

Climate Action Groups from across Australia recognise that “if humanity
wishes to preserve a planet similar to that on which civilisation developed and
to which life on Earth is adapted” then “CO2 will need to be reduced from its
current 385ppm”2.

In this context, over 150 Climate Action Groups from across Australia recently
adopted a movement wide position of working towards stabilising global levels
of CO2 at 300ppm, enabling the Arctic sea ice to refreeze and thereby
facilitating a return to a safe climate zone3.

Australia’s current policy frameworks/agreements lock us into CO2

stabilisation targets of 500ppm or more, thereby committing us to dangerous
climate change.

Climate scientists from across the world are making it clear that strong,
decisive action is required to dramatically reduce emissions and facilitate a
global agreement that aims to return our planet to a safe climate zone within
the next few decades.

Climate Action Groups believe that every emissions reduction tool currently
being considered and explored in Australia should be underpinned by this
global imperative of stabilising CO2 at 300ppm.

Given that stationary energy accounts for around 50 % of Australia’s

emissions4, renewable electricity generation systems can play a critical role in
reducing Australia’s emissions.

Renewables are clean, emissions-free in operation and sustainable5. They

have been demonstrated to be commercially viable, with small, medium and
large-scale installations already operating in many countries that have
favourable renewable electricity policies.

Renewable electricity can also be rapidly rolled out – in years, rather than
decades (as is the case for CO2 Capture and Storage and nuclear power) –

2
Hansen, J. et al, (Nov 08) “Target Atmospheric CO2: Where Should Humanity Aim?”, pg 1.
3
Position adopted by the movement on 2 Feb 2009 in Canberra at “Australia’s Climate Action
Summit”, which included participants from 150 Climate Action Groups from across Australia.
4
Australian Government Fact Sheet (Dec 2008) “Australia’s Greenhouse Gas Emissions”,
pg1.
5
Climate Action Groups define renewables to include the full suite of wind, wave, solar
photovoltaic (PV), solar thermal, geothermal and sustainable biomass. NOTE: Sustainable
biomass does not include the use of native forest woodchip waste or the use of palm oil or
sugar cane grown specifically for biofuels (both domestically and internationally).

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which is a critical factor in our ability to truly mitigate dangerous climate
change.

Given our nation’s wealth and access to renewable resources, renewable

electricity is a viable and achievable policy response to the immense scale
and magnitude of the climate emergency before us. It is a “win-win” on every
front.

Consistent with the integral role that renewable electricity can play in reducing
Australia’s emissions, over 150 Climate Action Groups have adopted a policy
of 100% renewable electricity in Australia by 2020. This mirrors Al Gore’s call
for 100% renewable electricity in the United States within the next 10 years.

Climate Action Groups therefore call on the Government to commit to a

policy of 100% renewable electricity in Australia by 2020, along with
effective energy efficiency measures.

2. MRET Cannot Cut Emissions Under Current CPRS

Given that stationary energy accounted for 50% of Australia’s emissions in
2006, a back of the envelope calculation would suggest that an MRET target
of 20% by 2020 would cut Australia’s emissions by around 5% by 2020
(based on 1990 levels and if all other factors were held constant).

This would imply that Australia could easily meet (and exceed) the
Government’s proposed emissions reduction target of 4% by 2020 (on 1990
levels) by simply achieving the 20% MRET target.

However, the Government has proposed to implement a Carbon Pollution

Reduction Scheme (CPRS) to reduce Australia’s emissions.

While the CPRS will set a ‘cap’ on emissions, by issuing a fixed number of
permits to pollute equivalent to 4% below 1990 levels, it “will also impose a
‘floor’ below which emissions cannot fall.”6

As noted by the NSW Independent Pricing and Regulatory Tribunal (IPART),

“additional measures to reduce emissions in sectors covered by the scheme
would not result in an increase in emissions abatement … the emissions
avoided through undertaking an additional measure would result in an
equivalent increase in emissions elsewhere.7”

This means that the 5% emissions reduction achieved by the MRET target
would enable other industries covered by the CPRS (such as cement, steel
and aluminium) to increase their emissions by about 1%.

6
Denniss, R. (Nov 2008) “Fixing the floor in the ETS – the Role of Energy Efficiency in
Reducing Australia’s emissions”, Research Paper No. 59, pg 14-15.
7
IPART (Dec 2008) “Review of NSW Climate Change Mitigation Measures” pg 28

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As total emissions are unable to fall below the 4% emissions reduction target
under the CPRS, green industries (including renewables), State/Territory
governments, local councils, businesses, communities and households will be
completely disempowered and prevented from making a meaningful
difference when it comes to climate change.

It will also lead to the end of the voluntary offset market in Australia, which will
mean that Australian businesses wanting to reduce their carbon footprints will
most likely have to purchase offsets in emissions reduction projects overseas
rather than investing in emissions reduction projects in Australia.

The CPRS, combined with this low target range, will not only “lock Australia
into inaction on climate change until 20208”, it will also severely impact
international agreement for a meaningful 2020 target range as part of the new
climate deal to be agreed this December in Copenhagen.

• Climate Action Groups note that the EU and UK have already

committed to reduce emissions by 20-30% and 26-32% below 1990
levels respectively9.

• Under the current CPRS, the Government will need to compensate

industries covered by the CPRS if they decide to change Australia’s
emissions reduction target before 2020. For example, if the
Government decided to reduce emissions by another 5% by 2020 it
would roughly result in a compensation payment to industries covered
by the CPRS of around $684 million10.

• With the CPRS legislation scheduled for approval by June 2009, the
Australian delegation attending the Copenhagen talks in December
2009 will have little choice but to push for lower global emissions
reduction targets (closer to the Australian 4-14% target range) as any
decision to substantially change the target will result in billions of
dollars of compensation to be paid by the Government to Australian
industries covered by the CPRS.

In light of the substantial flaws in the CPRS, over 150 Climate Action
Groups from across Australia have decided to oppose the current CPRS
and prevent it from becoming law before the Copenhagen talks.

We note that the House of Representatives had planned to hold an enquiry

into whether emissions trading is the most appropriate way for Australia to
reduce its emissions. Climate Action Groups will be submitting their position
into that process as well.

8
Denniss, R. (Jan 2008) “Climate policy strategy – where to from here?”
9
Australian Government Fact Sheet – What the rest of the world is doing on climate change,
December 2008.
10
Back of the envelope calculation = 5% x 547 million tonnes CO2 (Australia’s total net
emissions in 1990) = 23.7 million tonnes x $25 (estimated carbon price) = $684 million.
[Emissions source: Australian Government Fact Sheet (Dec 2008) “Australia’s Greenhouse
Gas Emissions”.]

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3. Replacing MRET with a Gross National Feed-in Tariff
When the MRET model was originally chosen by the Howard government
over a feed-in tariff (FIT), it was a theoretical assumption that an MRET style
model would produce least-cost renewable energy generation options and
would therefore be the cheapest way to achieve a renewable energy target.
However, in practice this has not been the case11.
While early achievement of MRET was initially deemed a success12, the
failure by the Howard Government to expand or extend MRET resulted in
MRET effectively becoming a cap on renewable energy development in
Australia.
This uncertainty meant that key players in the wind industry had to postpone
or cancel substantial planned investment in wind projects in Australia, leading
the market to stall.
The “stop-go” nature of the MRET model combined with the short (politically
malleable) time frames did not promote investor confidence or certainty,
thereby further impeding growth of the renewable energy market.
Finally, the “least cost” nature of the MRET model meant that only the
cheapest forms of renewable energy were promoted, such as wind power.
This has led to a lack of diversity in the renewable energy market and
provided little incentive for renewable energy experts in other areas (most
notably solar PV and solar-thermal) to remain in Australia.
FITs, on the other hand, have proven to be a highly successful policy
instrument in driving substantial investment in a wide range of renewables.
This has been most evident in Germany, whereby, “Germany’s feed-in law,
introduced in 1990 has led to a massive boom in investment. There was a
3025% increase in its solar capacity from 64 million kWh in 2000 to 2 billion
kWh in 2006.”13
In addition to promoting substantial investment in renewables, FITs have also
been proven through implementation to14:
• Have lower transaction and administrative costs when compared to
MRET;
• Promote investor certainty – the tariff rate is usually guaranteed for a
period of around 20 years, thereby reducing investment risk;

11
Most concepts on the MRET/REC model are from: Prest, J. (Aug 2008) “Inquiry into the
Renewable Energy (Electricity) Amendment (Feed-in Tariff) Bill 2008”.
12
The 2010 MRET target of 9,500 GWh was achieved in 2005.
13
Prest, J. (Aug 2008) “Inquiry into the Renewable Energy (Electricity) Amendment (Feed-in
Tariff) Bill 2008”, pg 2.
14
All dot points in this section are paraphrased from: Prest, J. (Aug 2008) “Inquiry into the
Renewable Energy (Electricity) Amendment (Feed-in Tariff) Bill 2008”, pg 14-15.

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• Allow cooperatives and companies to participate;
• Apply across a range of technology bands, rather than simply focusing
on the cheapest forms of renewable energy; and
• Recognise the network benefits from reduced transmission losses and
generation closer to the source of consumption.
Climate Action Groups believe that a Gross National FIT would greatly
facilitate major investment in the renewable energy sector in Australia and
would play a crucial role in our transition to 100% renewable electricity by
2020.

Climate Action Groups therefore call on the Government to replace

MRET and existing State and Territory FITs15 with a Gross National FIT
modelled on the German FIT by July 2009.

To effectively encourage investment in renewables, the new FIT would need

to:
• Apply to a range of renewable energy technologies, including solar
thermal, solar PV, geothermal, sustainable biomass, wave and wind
power.
• Apply to ALL the electricity generated from the renewable energy system
(gross generation) NOT just the electricity that is surplus and exported to
the grid (net generation);
• Be open to all sectors, including residential, commercial, business, local
councils, public buildings, schools, churches, agricultural, light industrial
and large scale commercial;
• Guarantee purchase and transmission of all electricity generated by
connected renewable energy systems;
• Guarantee payments for at least 20 years, thereby providing investment
certainty and confidence (these payments can be reduced when
incremental generation capacity milestones have been reached);
• Provide a payback on electricity generated of around 4 times the
standard domestic electricity tariff (this would reduce the payback time
on many small – medium scale installations to less than 10 years); and
• Be introduced with retrospectivity, thereby allowing those early adopters
to join the scheme from the date of enactment or when the law is
passed.
Climate Action Groups note that work may need to be done by the
Government to effectively harmonise the new 100% renewable electricity
2020 target/Gross National FIT with the existing MRET/Renewable Energy
Certificates (RECs) system.

15
FITs are currently in South Australia, Victoria, Queensland and the ACT.

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4. Continuing Renewable Energy Rebates
Climate Action Groups note that the Rudd Government has had 2 major policy
changes on rebates for solar photo-voltaic installations since coming into
office 15 months ago:

• the first was to introduce a means test for the $8,000 rebate; and

• the second was to cancel the means test and switch to a system of solar
credits, which would amount to a rebate of around $7,500 (this new policy
comes into effect on 1 July 2009).

Climate Action Groups believe that these annual policy changes and back-
flips reflect a failure by the Government to take renewable electricity in
Australia seriously. Overnight cessation/changes to policy promotes
substantial uncertainty for investors, industry, businesses and households.

Climate Action Groups believe that renewable energy rebates have an

important role to play in driving investment in renewable energy and
would therefore encourage a continuation of rebates (along with a
Gross National FIT) as an integral measure to achieve 100% renewable
electricity in Australia by 2020.

As stated above, Climate Action Groups believe that a major overhaul of

renewable electricity policy in Australia is required and call on the
Government to urgently establish a Renewable Electricity Task Force to work
on a timeline and implementation plan for a rapid roll-out of renewable energy
in Australia.

5. 2030 RET Phase-out Paves Way for a Return to Fossil Fuels

The Renewable Energy Amendment Bill currently states a timeline for
renewable energy generation of:

2020 45,000 gigawatt-hours (equivalent to 20% renewables)

2024 45,000 gigawatt-hours

2030 23,000 gigawatt-hours

This phase-out plan would suggest that the proportion of renewables in

Australia’s energy mix will fall well below 20% by 2030. This once again
promotes substantial investor uncertainty and does little to promote a viable,
long-term renewable energy industry in Australia.

More worryingly, this would appear to be paving the way for a return to fossil
fuels, presumably through Carbon Capture and Storage (CCS) for coal fired
power stations and nuclear power.

As stated above, Climate Action Groups call on the Government to take

renewable energy seriously and to commit to a policy of 100%
renewable electricity in Australia by 2020.

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Climate Action Groups do not support continued use of fossil fuels in Australia
outside of a 10-year transition (by 2020) to an emissions-free economy. In
particular, Climate Action Groups call for:
• An urgent ban on all new coal-fired power stations in Australia, effective
immediately.
• An urgent moratorium on all new coal exploration and mining in Australia.
• A suspension of all subsidies, tax incentives and financial support to the
fossil fuel industry, effective immediately.
• A detailed national review of existing Coal Fired Power Plants, with a view
to preparing comprehensive phase-down plans for each plant over the
next ten years.
• The Government to redirect the $500 million Clean Coal Fund as well as
any other funding / support for CCS into promoting and advancing
renewable energy technology, growth and infrastructure.
• A commitment by the Government that Nuclear Power will NOT be used
as part of the energy mix in Australia. Australia has abundant resources of
solar, wind and geo-thermal power and, as such, investment should be
focussed in these areas instead.
o Significant greenhouse gas emissions are produced at every
stage of the nuclear fuel cycle and uranium is not a renewable
resource. The inherent dangers with nuclear energy, from the
lack of a long-term storage solution, to nuclear waste, to the risk
of accidents and sabotage, make its use unacceptable16 .

6. Removal of “wood waste” reference in MRET

Climate Action Groups believe that “wood waste” in native forests play a vital
role in maintaining healthy bio-diverse native forest ecosystems.
The use of native forest “wood waste” for the production of bio-energy would
place immense pressure on an already fragile ecosystem. These ecosystem
impacts are sufficient to render bio-energy from native forest “wood-waste” a
non-renewable energy source.

As such, native forest “wood waste” should not be considered a

“renewable” source of energy under MRET and Section 17 of the Act
should be amended accordingly.

Continued inclusion would allow inappropriate burning of woodchips from

native forests for electricity and fails entirely to take into account the
greenhouse gas emissions that come from clear felling native forests, not to
mention the associated habitat destruction17. In addition, the burning of

16
Nature Conservation Council (Feb 2009), MRET Recommendations.
17
Campbell, P. "Submission on Draft Renewable Energy Billl 2009”, http://greenliving
pedia.org/Submission_on_draft_Renewable_Energy_Amendment_Bill_2009

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woodchips from native forests would also produce significant carbon
emissions. Native forests are far more valuable protected as carbon sinks.
The recent ANU report http://epress.anu.edu.au/green_carbon_citation.html
has detailed how our native forests are massive storehouses of carbon, and
logging them to burn or turn into low value products such as paper means the
release of that carbon from the trees and soil into the atmosphere.

More about Climate Action Groups

Climate Action Groups are collectives of ordinary but impassioned Australians

who have come together in their local communities to act on climate change.

Climate Action Groups have experienced extraordinary growth over the past
few years, with over 200 groups (representing thousands of people) currently
operating in local communities across Australia.

The dedication and determination of these groups is testimony to a deeply felt

community concern about the threat of climate change and increasing unease
in the community about the direction of climate policy in Australia.

Climate action groups generally have no political affiliations, and often

represent the people and sentiments of ‘middle Australia’ and beyond.

In early February 2009, the first ever Climate Action Summit was held in
Canberra, bringing together over 500 participants representing around 150
Climate Action Groups. The summit was a tremendous success and has lead
to greater organisation, communication and collaboration among groups.

Climate Action Groups are rapidly proving themselves to be a powerful force

in the public climate debate in Australia.

Contact for this Submission:

Tracey Tipping (Climate Action Pittwater): tracey@eternalsource.com.au

Ph: 0411 861 269

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Signatories to this Submission:
58 Climate Action Groups from across Australia have signed this submission.
They have a combined membership of well over 13,000 people and are doing
phenomenal work in each of their communities to raise awareness on climate
change and facilitate the transition to a safe climate zone.

Each signatory is listed below:

1. Ararat Greenhouse Action Group Inc, VIC

2. Bathurst Community Climate Action Network, NSW

3. Beenleigh Community for Cool Change, QLD

4. Bendigo Sustainability Group, VIC

5. Beyond Zero Emissions, VIC

6. Boroondara Sustainability Network, VIC

7. Citizens Climate Campaign, NSW

8. Clean Energy For Eternity - Bega, NSW

9. Clean Energy For Eternity - Bermagui, NSW

10. Clean Energy For Eternity - Cooma-Monaro, NSW

11. Clean Energy For Eternity - Snowy River, NSW

12. Clean Energy For Eternity - Eurobodalla, NSW

13. Clean Energy For Eternity - Mosman, NSW

14. Clean Energy For Eternity - Manly, NSW

15. Climate Action Canberra, ACT

16. Climate Action Coogee, NSW

17. Climate Action Fairfield, NSW

18. Climate Action Newtown, NSW

19. Climate Action Newcastle (CAN), NSW

20. Climate Action Pittwater, NSW

21. Climate Change Balmain-Rozelle, NSW

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22. Climate Emergency Network, VIC

23. Dandenong Ranges Renewable Energy Association Inc, VIC

24. Darebin Climate Action Now, VIC

25. Environment Tasmania Inc (Tasmania Conservation Council), TAS

26. Families Facing Climate change, VIC

27. 450ppm, NSW

28. Gold Coast & Hinterland Environment Council (GECKO), QLD

29. Great Lakes Environment Association Inc, NSW

30. Hills Against Global Warming, NSW

31. Lismore Climate Action Group, NSW

32. Lighter Footprints, VIC

33. Locals into Victoria’s Environment (LIVE), VIC

34. Mount Alexander Sustainability Group, VIC

35. National Toxics Network Inc, VIC

36. Otway Ranges Climate Action, VIC

37. Outdoor Lighting Reform Action Group, ACT

38. ParraCAN, NSW

39. Plug-In Australia, NSW

40. Quest 2025, QLD

41. Resistance, National

42. Ryde Gladesville Climate Change Action Group, NSW

43. See-Change, ACT

44. Six Degrees, QLD

45. Supreme Master Ching Hai Association Melbourne, VIC

46. Surf Coast Energy Group, VIC

47. Sustainable Environment Education Development Inc, VIC

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48. Sustainability in Stonnington, VIC

49. Sutherland Climate Action Network, NSW

50. Tasmania's Southern Forests: Still Wild Still Threatened, TAS

51. The Crisis Coalition, NSW

52. The Coastwatchers Association Inc, NSW

53. The Greenleap Strategic Institute, VIC

54. The South-East Region Conservation Alliance (SERCA), NSW

55. The Epping Beecroft Climate Action Group, NSW

56. Transition Towns Triangle Plus, NSW

57. Yarra Climate Action Now, VIC

58. Zero Carbon Network

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References:

1. AUSRA Australia http://www.ausra.com.au.

2. Australian Government Fact Sheet (Dec 2008) “Australia’s Greenhouse

Gas Emissions”.

3. Australian Government Fact Sheet (Dec 2008) – “What the rest of the
world is doing on climate change”.

4. Campbell, P. "Submission on Draft Renewable Energy Billl 2009”,

http://greenliving
pedia.org/Submission_on_draft_Renewable_Energy_Amendment_Bill_
2009

5. Denniss, R. (Nov 2008) “Fixing the floor in the ETS – the Role of
Energy Efficiency in Reducing Australia’s emissions”, Research Paper
No. 59.

6. Denniss, R. (Jan 2008) “Climate policy strategy – where to from here?”

7. Hansen, J. et al, (Nov 08) “Target Atmospheric CO2: Where Should

Humanity Aim?”, pg 1.

8. IPART (Dec 2008) “Review of NSW Climate Change Mitigation

Measures” pg 28

9. Nature Conservation Council (Feb 2009), MRET Recommendations.

10. Prest, J. (Aug 2008) “Inquiry into the Renewable Energy (Electricity)
Amendment (Feed-in Tariff) Bill 2008”.

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