9 February 2016
Energy White Paper Submission
ACF welcomes the opportunity to provide the following submission to the Draft Energy
White Paper (EWP) consultation, in advance of a Green Paper.
ACFs mission is to work across society to ensure urgent, transformative action to deliver
lasting change on the scale required to secure a sustainable environment.
The EWP process comes at an ideal time for Australia. We face the decade most critical to
transformation towards the clean energy economy we require if we are to avoid the worst
impacts of climate change. Toward that goal it is vital that we utilise every existing
opportunity in order to efficiently and flexibly move towards a lasting, competitive, low
carbon economy.
The Energy White Paper process provides government with an opportunity to consider
critical reforms to Australian energy policy that will allow Australia to:



Meet our global responsibility to reduce greenhouse gas pollution.
Integrate 360 costing of externalised costs of energy production into decision making
concerning Australian energy policy – whether from damage to the environment,
damage to communities, or contributions to climate change.
Remain competitive in a changing international marketplace.
While the Energy Issues paper focuses primarily on fossil fuelled energy, it is important to
acknowledge that a global transition is occurring and that global demand and supply for
renewable energy is rapidly increasing.
Recent times have seen significant moves in a range of markets towards increased use of
renewable energy, a trend that is anticipated to accelerate. 2011 saw a record $260 billion
spent globally on renewable energy generation,[1] the first year in which global investment in
[1]
Bloomberg New Energy Finance, Solar Surge Drives Record Clean Energy Investment in 2011,
http://www.bnef.com/PressReleases/view/180
renewable energy outstripped investment in fossil fuels.[2] At the same time, an international
trend away from nuclear energy was seen following the Fukushima tragedy. That trend has
not reversed.
2012 saw fossil fuel use achieve weakest recorded growth relative to its historical averages.
On the other hand, renewable use power generation grew by 15% in the same year.[3]
A recent Bloomberg New Energy Finance report showed that new built wind delivers
cheaper electricity to the NEM than either new built coal and gas, a trend that will accelerate
as the cost of renewables continues to decline, and the externalised costs of greenhouse gas
pollution are increasingly internalised into fossil fuel energy generation pricing structures.
Energy policy should also look to issues of energy security. A range of studies [Diesendorf
2014, AEMO 2013] have shown that NEM energy security needs can be met by electricity
generation blends that approach 100% renewable energy. Arguments that fossil fuelled
generation is required to meet ‘baseload’ energy supply requirements are misleading.
A recent example of the ability of renewable energy to reliably supply electricity to the grid
during periods of peak demand is provided by the January 2014 east coast heatwave, which
saw 9% of South Australia’s electricity demand met by solar PV. During that heatwave,
AEMO statistics showed that low periods of reserve corresponded not to failures of
renewable energy output, but to heatwave related failures by major coal fired power stations
at Loy Yang and Torrens Island.[4] The heat wave of 30 January, 2009 caused financial loss
estimated at $800 million, mainly caused by the power outages and disruptions to the
transport system. [5]
The Energy White Paper process presents Australian with an opportunity to realign our
energy industries and priorities to a more sustainable social, economic and environmental
footing, in a carbon constrained context. It is crucially importance that government gives due
consideration to the major role that energy policy will play in determining Australian
environmental quality over the coming years. Australia must, over coming years, enact
policies that allow us to accelerate the decoupling of energy production and economic
productivity.
At a very high level of generality, ACF’s view is that energy policy must:
1.
Satisfy Australia’s international commitments. Energy policy must be calibrated to
ensuring that Australia satisfies international commitments to GHG pollution
reduction. An indication of the scale of shifts in Australian energy use required to
[2]
Bloomberg New Energy Finance, Renewable Power Trumps Fossil Fuels for First Time as UN Talks Stall,
http://www.bloomberg.com/news/2011-11-25/fossil-fuels-beaten-by-renewables-for-first-time-as-climate-talks-founder.html
[3]
http://www.bp.com/content/dam/bp/pdf/statistical-review/statistical_review_of_world_energy_2013.pdf
http://www.businessspectator.com.au/article/2014/2/5/energy-markets/aemos-verdict-wind-solar-and-boilinghot-weather
[5]
http://climatecommission.files.wordpress.com/2013/09/the-critical-decade-2013_website.pdf
[4]
achieve that goal will be provided by the forthcoming Climate Change Authority
target recommendations (late Feb 2014);
2.
Increase use of renewable energy. If Australia is to meet these obligations, an
increasingly proportion of our energy must be met by renewable or low carbon
sources of energy. This is true of all users, from residential to industry and resource
sector energy consumers. In particular, the Renewable Energy Target should be
strengthened, and a strong 2030 target should also be set;
3.
Incentivise efficient use of energy. Energy must ensure that energy productivity is
maximised, with strong incentives to reduce energy use throughout the economy;
4.
Move away from fossil fuel mining. Decisions regarding approvals for coal, natural
gas, and petroleum mining must consider the full externalised costs of that mining on
local environments, on the environment, and as a driver of global climate change.
Detailed Comments on the Energy Issues Paper
1.
General
 The development of an Energy White Paper presents an opportunity to
realign Australia’s energy industries and priorities to a more sustainable
social, economic and environmental footing. The Issues Paper sets a
course for the opposite.
 Australia should aim for energy supply and use that has zero impact – 100
per cent renewable (or high renewable content supported by low-carbon
sources at times), internationally consistent passenger, commercial and
freight vehicle efficiency standards, support for energy efficiency, support
for rail and public transport.
2.
Energy supply
 Energy consumption has declined, leading to an oversupply of electricity
generation capacity. This can be addressed through closure of Australia’s
most emissions intensive generation stock. Coal-fired generators have
already received compensation from the Federal Government for loss of
asset value. No further compensation is needed.
 Regulatory barriers, including overly restrictive planning arrangements in
Victoria, have led to a reduction in new renewable generation. These
barriers should be removed.

The current suite of incentives for renewable energy should be retained
and/or strengthened, inclusive of RET, ARENA and the CEFC




Electricity reliability standards can be relaxed, subject to meeting
community standards (particularly for low-income households). Increased
generation share for distributed renewable energy should be encouraged.
Liquid fuel security can be improved by reducing demand. Improved
energy efficiency, modal shift (i.e. investment in freight and passenger
rail, public transport) and new technology innovation will help to bring
Australia in line with its IEA obligations. Additional domestic extraction
and refining capacity should be avoided given large negative costs (e.g.
pollution, health, risk of stranded assets).
CSG, shale and tight gas mining, along with LNG processing, comes at a
high economic, social and environmental cost. The absence of full cost
accounting has masked this. Greater exposure to export markets is
increasing demand for unconventional gas sources and LNG, at the
expense of Australian consumers and our shared environment. Fuels are
sold to nations without carbon constraints, leading to unpriced global
environmental damage. For these reasons, further fossil fuel
developments should be prohibited.
Energy networks should be developed in the interests of consumers,
rather than network businesses and revenue maximising state
governments. Network regulation and pricing should reward avoided
network costs associated with distributed renewable generation.
3.
Regulatory reform
 Energy sector regulatory reform needs to protect the interests of energy
users along with Australia’s interests, which means regulating against
unsustainable energy supply and use that damages Australia’s long-term
sustainability.
 The RET should be strengthened with a higher target and removal of large
user exclusions.

Energy regulation should ensure energy use is cost reflective, taking into
account the unique needs of low-income households. Network related
costs should factor avoided costs attributable to distributed generation
and energy efficiency.
4.
Growth and investment
 All exploration and development must account for the full cost to society
and the environment of that exploration/development activity.
 Demand for fossil fuels will decline, in part as a result of effective climate
policies. The costs associated with burning fossil fuels, and the cost of
locking in investment in ‘unburnable coal’ can be avoided by cutting
funding and banning further exploration.
 Existing fossil fuel generation stock should be allowed to close in an
orderly fashion, reflecting the declines in household, commercial and
industrial demand.
 Renewables and other zero carbon technologies should be supported.
 On streamlining environmental approvals: process must be strengthened,
stringently applied, with strong compliance conditions. Some industry
development must be impeded.
5.
Trade and international relations
 Australia should lead global efforts to move away from all fossil fuel use.
 Australia should promote opportunities for technology development and
transfer to ensure all nations can develop and alleviate poverty without
the costs of fossil fuels. A strong priority should be placed on the Green
Climate Fund and related programs.
 There should be no further exploration or development of fossil fuel assets
for export, and no more corporate subsidies to develop alternate fossil fuel
technologies (e.g. coal to liquid).
 The benefits of existing resource extraction and export must be better
captured by all, rather than a few wealthy Australians and international
businesses. Australia should introduce a Norway-style wealth fund, with
proceeds directed towards environmental sustainability.

Uranium exploration, development and export should halt immediately,
with legal restrictions on any future development.
6.
Workforce productivity
 ACF have no comment
7.
Energy productivity
 Restore and expand on programs that help households and business save
energy, including the HESS.
 Expand EEO.
 Introduce a transport fuel standard consistent with the EU, USA and
Japan, as appropriate.
 Recommendations of the Prime Ministers Task Group on Energy
Efficiency should be implemented.

Modal shift to rail and public transport should underlie decision making
relevant to transport policy.
8.
Alternative and emerging energy sources and technology
 Incentives for renewable and zero/low carbon energy should remain, at
least until Australia’s carbon price reflects the full cost of carbon.
 Time of use pricing should be introduced, with appropriate measures for
low-income households.
 Distribution costs should reflect the benefits from avoided investment
associated with distributed generation. Distribution costs should not be
changed to help distributors capture lost asset value associated with
declining demand from remote generation.
 Nuclear should remain banned. Small modular reactors should not be
supported.
 System reliability and load variability should be addressed by spinning
reserve from super-efficient gas.
 No further government funds should be directed to CCS.
 Electric vehicle infrastructure should be supported.
 EU or US fuel economy/GHG standards should be phased in by 2015-16.
 All fuel tax credit arrangements should be phased out by 2015-16.
 Investment in freight rail should take precedence over investment in
heavy vehicle gas infrastructure.
 Biofuels should only be considered if there are no negative impacts on
Australia’s landscape, natural capital and regional communities.
ACF Comments Specific to Uranium and Nuclear Energy


There is no acknowledgment that Australian uranium was in the Fukushima reactor
and no articulation of any subsequent enhanced safety or export considerations or
review mechanisms.
The consideration of small modular reactors (SMR) fails to identify the significant
cost, safety and waste concerns involved in this fledgling technology and assertions
that nuclear technologies continue to present an option for future reliable energy that can be
readily dispatched into the market lack a clear evidence basis in the post Fukushima
energy landscape.
If Australia is to be taken seriously in relation to claims that it has a leadership role in ensuring
the sustainable development and responsible use of uranium then Australia must actively engage
with and reflect the lessons of Fukushima. The role of Australian uranium in the continuing
Fukushima nuclear crisis was confirmed by Dr Robert Floyd, the Director General of the
Department of Foreign Affairs nuclear watchdog, the Australian Safeguards and NonProliferation Office, on 31 October 2011:
“We can confirm that Australian obligated nuclear material was at the Fukushima Daiichi site and in
each of the reactors – maybe five out of six, or it could have been all of them; almost all of them.”
A detailed UN report into Fukushima released in September 2011 found the accident ‘caused
hundreds of billions of dollars of property damage’. Around 150,000 people remain unable
to return to their homes. The fishing industry, agriculture and other sectors have been
deeply affected. Three per cent of Japan’s land mass has become unfit for permanent human
occupation and the French Institute for Radiological Protection and Nuclear Safety (IRSN)
describes it as “a situation of chronic and lasting contamination of the environment”.
The Issues Paper states that Australian policy ensures that Australian uranium can only be sold
to countries committed to peaceful uses of nuclear energy. Negotiations are currently underway on a
Nuclear Cooperation Agreement with India to enable sales of uranium for power generation purposes,
providing opportunities for development and expansion of uranium projects (p 31). However the
paper fails to address the fact that India is not a signatory to the Nuclear Non-Proliferation
Treaty (NPT), is actively expanding its nuclear arsenal and the proposed sale is not
consistent with Australia’s international non-proliferation obligations under the South
Pacific Nuclear Weapons Free Zone Treaty (1985)
The Issues Paper further states that the Government’s policy is that uranium exploration and
mining will only be approved subject to stringent environmental and safety requirements in line with
world’s best practice. However successive Australian governments and all Australia’s uranium
producers have done nothing to alter or review export arrangements, production processes
or safeguards and oversight arrangements in the light of Fukushima and it is deficient for the
White Paper to not acknowledge this fact or require any review of Australia’s uranium sector
and related international supply conditions.
The Issues Paper fails to acknowledge the greenhouse gas emissions involved in uranium
mining, processing and transport or make reference to the work by the European
Commission’s Joint Research Centre seeking to quantify the extent of greenhouse emissions
generated by the ‘front end’ of the nuclear fuel chain.
AJRC technical paper Towards a Sustainable Front End of Nuclear Energy Systems, (2010) states:
A comprehensive assessment of the full life cycle energy costs of uranium mining, milling and
subsequent decommissioning and remediation of the related infrastructure is required...

The paper clearly leaves the door open for future consideration and possible
adoption of domestic nuclear power. This is in clear contravention of the Australian
Radiation Protection and Nuclear Safety Act 1998 which states:
Section 10 Prohibition on certain nuclear installations
(1) Nothing in this Act is to be taken to authorise the construction or operation of any of
the following nuclear installations:
(a) a nuclear fuel fabrication plant
(b) a nuclear power plant;
(c) an enrichment plan;
(d) a reprocessing facility.
(2) The CEO must not issue a licence under section 32 in respect of any of the facilities
mentioned in subsection (1).
The Issues Paper fails to respond to growing medical and public health concerns over the
health impacts of uranium mining. In particular the resolution of the International
Physicians for the Prevention of Nuclear War’s (IPPNW) 2010 Basel Congress concluded
that:
Uranium ore mining and the production of uranium oxide (yellowcake) are irresponsible and
represent a grave threat to health and to the environment. Both processes involve an
elementary violation of human rights and their use lead to an incalculable risk for world peace
and an obstacle to nuclear disarmament.
The International Council of IPPNW therefore resolves that: IPPNW call for appropriate
measures to ban uranium mining worldwide.
This unequivocal position from a highly regarded medical body demonstrates a
strengthening of international expert concern about the human health and wider adverse
impacts of uranium mining and requires, at minimum, a measured assessment and public
response from uranium producing and exporting nations, especially given successive
Australian governments mantra of strict conditions and best practice in relation to uranium
mining and export. The White Paper is deficient in not addressing what steps have any
Australian producers, agencies or regulators taken to assess the health impacts of uranium
mining and export subsequent to the Basel resolution.
(For further detail on the Basel resolution see: http://www.nuclearrisks.org/fileadmin/user_upload/pdfs/Resolution_Uranium_ban_final.pdf )
Existing European Parliament resolution on uranium mining
In January 1998 the European Parliament passed a comprehensive resolution with direct
relevance to the Australian uranium sector (Resolution on the protection of the aboriginal people
of Australia – B4-0078/98).
This called, inter alia, for the European Commission to have an independent study drawn up into
the uranium imports of the European Union analysing the impact of uranium mining and processing
on health and the environment, on the rights of indigenous peoples, and the waste produced by the
mining operations in the respective country of origin.
ACF strongly supports such a study as a fundamental part of any evidence based export
regime and notes that this issue remains a matter of concern to the European Parliament and
featured in the deliberations of the 2011 EP Mission to Australia. Seventy per cent of global
uranium reserves are located on Indigenous lands and this industry has a disproportionate
and adverse impact on Indigenous people in Australia and internationally. The Issues Paper
again fails to detail what steps have been taken by Australian governments and agencies, in
concert with European partners or unilaterally, to address the issues identified in this
resolution.
Recommendations
-
Explicitly preclude nuclear power as a domestic energy source (consistent with the
extant legislative position in the ARPANS Act 1998)
-
Implement the outstanding recommendations from previous federal Inquiries into
uranium mining to improve domestic industry performance
-
Remove federal support for Australian uranium companies operating off-shore,
particularly in Africa, and require any such operations to comply with Australian
domestic standards and practices
-
Review Australian uranium export arrangements and bi-lateral agreements to ensure
improved accountability, transparency and end user competence, in response to the
fact that Australian uranium fuelled the Fukushima nuclear crisis.
-
Conduct an audit of the greenhouse gas emissions of the Australian uranium sector
to build on similar work conducted and further recommended by the European
Commission’s Joint Research Centre.
-
Initiate, as recommended in the United Nations system-wide study on the implications of
the accident at the Fukushima Daiichi nuclear power plant (September 2011), an in-depth
assessment of the net cost impacts of uranium, with particular regard to impacts on
local communities and ecosystems.
For more information, please contact
Jamie Hanson Mobile: +61 437 242 950 Email: j.hanson@acfonline.org.au
The Australian Conservation Foundation is committed to achieve a healthy environment for all
Australians. We work with the community, business and government to protect, restore and sustain
our environment.
www.acfonline.org.au
For more information contact:
Jamie Hanson Mobile: 61 3 9345 1133 Email: j.hanson@acfonline.org.au
The Australian Conservation Foundation strives to advance lasting solutions to Australia’s
environmental problems and to create a sustainable future and better quality of life.
www.acfonline.org.au