c/- Moreland Energy Foundation Limited
Level One 200 Sydney Road Brunswick
Postal Address PO Box 276 Brunswick 3056
P: 03 9385 8514
Australia’s post 2020 Emissions Reduction Target
Thank you for the opportunity to make a submission to the Federal Government’s consultation on the Post
2020 Emissions Reduction Target.
The Northern Alliance for Greenhouse Action (NAGA) supports a strong and effective national emissions
reduction target that reflects the latest climate science and that underpins the necessary and urgent
transition to a low-carbon economy.
About Northern Alliance for Greenhouse Action
The Northern Alliance for Greenhouse Action (NAGA) is an alliance of Moreland Energy Foundation and
the nine councils spanning the northern metropolitan region of Melbourne from the CBD to the rural/urban
fringe (see footer). The Alliance covers a quarter of Melbourne’s population; the region spans major
industrial, commercial, and residential areas, activities and types, as well as forests, agriculture, and water
catchments on the urban fringe.
NAGA is working to ensure urgent, regional action in our transition to a climate-changed, low-carbon future.
To achieve this, we share information, coordinate emission reduction and adaptation activities, and
cooperate on the development and implementation of innovative regional projects. NAGA is actively
involved in implementing regional scale climate change projects and developing approaches to
governance, project management and business cases to support this work.
Local government climate action and leadership
Climate change mitigation requires urgent, wide-ranging responses from all levels of government and the
community, as it will be impossible to adapt to climate change if ‘business-as-usual’ emissions continue
unabated. Local government is at the forefront of this action; NAGA’s members have demonstrated a
serious and sustained commitment to climate change action through the implementation of projects, and
policies and supporting their communities, businesses and households to take action. Local government
partnership approaches are underpinned by their communities’ concerns about climate change and
complement actions at state and federal government levels.
Many of the NAGA member councils have set their own emission reduction goals; three have recently
achieved carbon neutral certification (Cities of Yarra, Moreland and Melbourne) for their own operations. All
NAGA member councils have dedicated staff, resources and funding to achieving their emission reduction
targets and are actively working to support their communities to reduce their businesses’ and households’
emissions.
MEMBER ORGANISATIONS
BANYULE CITY COUNCIL, DAREBIN CITY COUNCIL, HUME CITY COUNCIL, MANNINGHAM CITY COUNCIL, CITY OF MELBOURNE,
MORELAND CITY COUNCIL,MORELAND ENERGY FOUNDATION LIMITED, NILLUMBIK SHIRE COUNCIL, CITY OF WHITTLESEA, CITY OF YARRA
This submission addresses each of the three questions posed in the issues paper as well as other relevant
issues. Please consider the following key points for consideration in setting a post 2020 target:
Q1. What should Australia’s post-2020 target be and how should it be expressed? In responding to this
question you could consider the base year (e.g. 1990/2000/2005), the end year (e.g. 2025/2030), the type
of target and why the suggested target is preferred.

NAGA supports a strong ambitious target that is consistent with the need to limit an
increase in global temperatures to 2 degrees Celsius as agreed to by the global community.
Scientific evidence is increasingly supporting the need to keep warming to no more than 2 degrees
Celsius below pre industrial levels to avoid the more extreme effects of dangerous climate change.
The IPCC states that in order to stay under this threshold of warming, the world has only 485
Petagrams of Carbon (PgC) left in its “carbon budget”. It is predicted that at current rates of
emissions the world will exceed this amount by 2045 1.
For Australia, to fairly contribute to the target of restricting warming to 2°C, total emissions need to
be limited to around 8-11 billion tonnes between 2013-20502. On current emissions levels this
budget would be exhausted by 2030-2035. There is no mention of the 2 degrees Celsius limit in the
issues paper, despite international consensus and previous commitments of the Australian
Government, and this should be rectified.

Adopting a strong ambitious target will offer a clear signal to the Australian economy to
transition to a clean energy and low carbon future.
It is in Australia’s national interest to support effective global action on climate change because
Australia’s strong economic reliance on carbon-intensive resource exports and high domestic per
capita emissions mean that the economy will be particularly exposed in a carbon-constrained
context. Early action to support the transition to a low-carbon economy is therefore in Australia’s
best interests.

Specifically, NAGA recommends a target of approximately 40% below a 2000 baseline by
2025, and a target of 65-75% below the 2000 baseline by 2035.
This is a realistic and equitable target and is broadly in line with the latest Special Review report
from the Climate Change Authority3 and previous recommendations in its Targets and Progress
review4. The CCA review recommends a target of between 40-60% by 2030 below 2000 levels and
zero net emissions by 2050. NAGA recommends adopting a 2025 target and an indicative
emissions pathway for 2035 as is recommended by the Climate Institute5. Providing for 2035 allows
for longer term policy directions to be set. These should be possible to strengthen over time if
circumstances change, but not weaken.

Adopting a strong ambitious target will restore Australia’s international climate change
reputation and promote stronger contributions from other nations.
The level of Australia’s ambition will have significant political sway on the contributions of other
nations and NAGA believes that Australia has a responsibility to be a leader not a follower. This is
consistent with a 2014 Lowy Institute Poll that found 63% of Australians believe Australia should be
taking a leadership role internationally6. Australia is an important middle power and its climate
change targets, and carbon laws package have been recognised globally. Climate change, by
definition, is an issue that spans national boundaries, requires effective action from all nations, and
1
http://www.wri.org/ipcc-infographics
2
http://www.climateinstitute.org.au/verve/_resources/AustraliasPost2020EmissionChallenge_FINAL_LM.pdf
3
http://www.climatechangeauthority.gov.au/special-review/first-draft-report
4
http://www.climatechangeauthority.gov.au/reviews/targets-and-progress-review/part-c/chapter-9-australia%E2%80%99s-2020-and-2030-goals
5
http://www.climateinstitute.org.au/verve/_resources/AustraliasPost2020EmissionChallenge_FINAL_LM.pdf
6
http://www.lowyinstitute.org/publications/australia-and-climate-change-negotiations#_edn5
NAGA submission
Post 2020 Emissions Reduction Target
page 2 of 6
Australia has a responsibility to be part of global efforts. Australia’s efforts can contribute to and
constructively support increasing global action and ambition.

NAGA recommends maintaining existing obligations under the Kyoto Protocol for future
targets in that the target is economy wide, unconditional and carbon budget based.
An economy wide target is the best way to avoid carbon leakage, manage risks and ensure equity
and transparency. The final target should be unconditional to increase confidence between nations.
Maintaining a carbon budget approach is preferred as it will allow countries to meet their goals
whilst allowing for flexibility between years.

NAGA recommends making a clear commitment date to when the Australian economy will
be decarbonised.
As well as adopting a shorter term target of 2025 and/or 2030, an explicit date for decarbonisation
will allow for long term direction in climate policy and guide investment decisions. Decarbonisation
would see Australia have zero net emissions, and would require ambitious energy efficiency, low
carbon technology, electrification and fuel switching, as well as reduced non energy emissions in
agriculture and industry. As above we recommend that Australia work towards 2050 as a date for
decarbonisation, in line with the science and the recommendations of the CCA. A recent report by
Climate Works has demonstrated the many economic opportunities for Australia in decarbonising
the economy7
Q2. What would the impact of that target be on Australia? In responding to this question you could, for
example, consider the impact on our economy, jobs, business and on the environment.

A strong target will likely strengthen not weaken the national economy, by unlocking
barriers to new industries and jobs.
NAGA, along with the other Victorian greenhouse alliances have a long history of demonstrating
how emissions reductions activities can lead to positive economic and social benefits. Studies such
as NAGA’s Towards Zero Net Emission for the NAGA Region and Climate Works Australia’s Low
Carbon Growth Plans demonstrate significant low or no cost opportunities for emissions reductions,
as well as the suite of more expensive actions needed for substantial transformation. For example,
ClimateWorks Australia estimated that if we improved the energy efficiency of our economy alone,
by 2020 Australian homes and businesses would save $5 billion every year.
A new report by WWF/ANU has demonstrated that Australia can make deep cuts to its emissions
whilst still growing the economy, and that Australia can meet all of its electricity needs from
renewable energy by 20508. This is in line with many independent analyses over the past few years
that all point to the economic opportunities from moving to a low carbon economy (see Box 1).
Box 1: What the major reports say (Source: WWF/ANU 2015)
“Australia has extensive opportunities to reduce emissions at a relatively low cost” - Climate
Change Authority
“Australia can achieve net zero emissions by 2050 and live within its recommended carbon budget,
using technologies that exist today, while maintaining economic prosperity.” - ClimateWorks
Australia/ANU
“Australia’s energy needs can be met with 100% renewables”. University of Melbourne Energy
Research Institute
“The Australian economy has good prospects of reducing emissions by 80% or 90% by midcentury, alongside continued strong growth in living standards.” – The Garnaut Climate Change
Review
“Australia’s wide range of low-emission technology options suggests electricity generation could
deliver large emission reductions over time, even if some technologies do not prove cost-effective.”
– Australian Treasury
“Renewable energy technologies, a critical element of the low-carbon pillar of global energy supply,
are rapidly gaining ground” – International Energy Agency
7
http://www.climateworksaustralia.org/project/current-project/pathways-deep-decarbonisation-2050-how-australia-can-prosper-low-carbon
8
http://awsassets.wwf.org.au/downloads/fs077_australia_can_cut_emissions_deeply_and_the_cost_is_low_21apr15_v2.pdf
NAGA submission
Post 2020 Emissions Reduction Target
page 3 of 6
9

Increasing renewable energy and energy efficiency will lead to a net increase in
employment.
There is significant potential for Australian businesses to succeed globally in the following six key
green markets; renewable energy, energy efficiency, green buildings, sustainable water systems,
biomaterials and waste and recycling. With the right policy settings, these industries that are
currently valued at $US15.5 billion and employ about 112,000 people could grow by 2030 to a
value of $243 billion and 847,000 jobs.9 Twenty one thousand Australians are currently employed
in the renewable energy industry, and this is expected to grow to 32,000 in 15 years with the right
supportive policy settings 10. If Australia develops policies to strengthen energy efficiency, there
could be 75,000 jobs in energy efficiency by 203011.

Economic modelling of different climate change targets must consider the benefits, not just
the costs of reducing climate change impacts through strong action.
When considering the costs and benefits of Australia’s target, the high costs to the Australian
economy of damages from climate change inaction should be comprehensively assessed. This
recognises that less mitigation will require significantly higher costs of adaptation. On this basis
NAGA supports stronger action now that can help reduce costs and smooth Australia’s transition to
a low-carbon adaptive society, as well as preserve options and leave a manageable task for the
next generation.

Strong ambitious mitigation action will reduce the costs of adaptation and impacts of
climate change on our local economy, people and the environment.
Climate change is happening now and is being felt adversely by local governments across
Melbourne. NAGA has recently undertaken a regional climate change vulnerability assessment,
which identified that increasing temperatures and drier conditions, combined with an increase in the
frequency, severity and duration of extreme events such as heatwaves, bushfires and flooding
pose significant risks to the region. Climate change is impacting multiple sectors, including regional
economies, infrastructure and assets, community health and wellbeing, emergency management,
and the natural environment. The magnitude and costs of these risks is strongly dependent on the
degree of mitigation.

A strong target must acknowledge the necessity to transition Australia to a clean energy
future.
Little emphasis is placed within the issues paper on the role of renewable energy and instead the
focus is on low emissions fossil fuels programs. Achieving adequate emissions reductions will
inevitably require the rapid phasing out of Australia’s coal fired power plants and facilitating more
renewable energy. Emissions reductions will require substantial transformation to our existing fossil
fuel based economy, with Australia’s high per capita emissions.
Such transitions may create significant economic and social impacts if delayed. The value of taking
early action, and positioning Australia to be a leader in our transition to a low carbon economy, has
been highlighted by a number of key studies and reports, including the Garnaut Climate Change
Reviews. Early action is more cost-effective and establishes competitive advantages, as well as
contributing to reducing the risk of stranded assets.

Australia’s high level of coal use should be seen as an opportunity for a stronger target and
not be used as a justification for a weaker target.
Australia has the opportunity for greater emissions reductions by restructuring our energy system
and reducing the use of coal and gas. Consistent policy (such as a strong Renewable Energy
Target) and price signals should be used to incentivise the energy market to shift towards
renewable energy. Australia has abundant renewable energy resources, given that it has the
highest land area per capita, high quality wind speeds and low wind power production costs, one of
the highest levels of solar radiation per square metre as well as one of the most expensive
electricity distribution networks. The current debate of there being too much supply in the electricity
market is a signal to phase out the coal fired power stations, not to hamper the development of the
renewable energy industry.

Discussion of coal and gas exports in the issues paper is not consistent with a 2 degree
target and should not be a basis for a weak Australian target.
http://apo.org.au/research/green-gold-rush-how-ambitious-environmental-policy-can-make-australia-leader-race-green
10
http://www.climatecouncil.org.au/uploads/ee2523dc632c9b01df11ecc6e3dd2184.pdf
11
http://www.asbec.asn.au/wp-content/uploads/Energy%20Efficiency%20Council%20Platform%2024%20June%202010.pdf
NAGA submission
Post 2020 Emissions Reduction Target
page 4 of 6
Wedding the nation to coal exports into the future is economically dangerous as the world moves
away from fossil fuels 12. China, Japan, Korea and India account for 80% of Australia’s fossil fuel
exports. These countries are already signalling dramatic changes away from fossil fuels to a clean
energy economy. For example, China is in the process of introducing a national emissions trading
scheme, India has doubled its tax on coal and intends to stop importing coal within 2-3 years,
Japan is ramping up energy efficiency efforts and Korea has introduced a coal tax of
AU$18/tonne13.
The issues paper references the IEA estimate that by 2040 74% of the world’s primary energy
needs will be met through carbon based fuels. However, the IEA also states that if this estimate
were to come to fruition it would mean a temperature rise of close to 4 degrees Celsius. Thus
Australia should recognise that strong efforts need to be made to reduce global demand for fossil
fuels in coming decades, and proactively wean the national economy off these export industries.
Q3. Which further policies complementary to the Australian Government’s direct action approach should be
considered to achieve Australia’s post-2020 target and why?

NAGA supports a broad-based approach, including a carbon market and complementary
measures, to reduce greenhouse gas emissions in the short term, and to contribute to
delivering science-based emissions cuts in the medium and long-term.
Emissions reductions require a broad mitigation program that incorporates a wide range of actions
and complementary measures to promote energy efficiency and the uptake of renewable and low
carbon energy production in a just and equitable transition to a low carbon future. The need for
structural adjustment measures for specific regions and industries is a high priority; local
governments have played a key role in supporting communities affected by previous economic and
industry adjustments.

This is an opportunity to set long term climate change policy objectives beyond current day
policies and politics.
The issues paper places too much emphasis on current policies, such as the Direct Action policy, in
determining future post 2020 targets. It is highly unlikely that the same policy mechanisms being
used today will be in place beyond 2020. Carbon pricing schemes are being adopted en masse
across the world, including 39 national and 23 subnational jurisdictions with either emissions
trading schemes or carbon taxes, valued at $30 billion 14. China is home to the second biggest
carbon market after Europe and this will continue to shape our domestic climate policy in the years
to come. The choice of target should align with the review the Climate Change Authority is currently
undertaking on whether Australia should adopt an emissions trading scheme into the future and
what other countries are doing to reduce their emissions 15. These outputs should be aligned and
integrated into the target setting.

Long term renewable energy goals should also be set as a key way to reduce emissions
Australia cannot claim to have ambitious climate change targets whilst acting to reduce the uptake
of renewable energy. NAGA recommends that any climate policy should also include a strong
renewables energy target of at least 50% by 2030. This will inevitably require the staged closure of
older coal fired power plants.

It is acknowledged that the Climate Change Authority is currently working on a
recommendation for a future emissions reduction target for Australia.
This will be based on how Australia compares to other countries. The recommendations of the CCA
in the Special Review report should be adopted. The Federal Government dismissed the previous
recommendation of Australia increasing its 2020 target to at least 19% below 2000 levels, rather
than the current low 5% target. It is unlikely that the conditions and science have changed
significantly since the previous CCA review in 2014, and on the basis of the previous CCA Targets
and Progress review, NAGA recommends a target consistent at a minimum 30-40% below 2000
levels by 202516.
12
http://www.abc.net.au/news/2015-03-27/most-polluting-power-stations-named-risks-economy-environment/6353712
13
https://theconversation.com/australias-coal-and-gas-exports-are-being-left-stranded-34496
14
http://www.theclimategroup.org/what-we-do/news-and-blogs/global-emission-trading-schemes-now-total-us30-billion-led-by-china-and-europe/
15
http://www.climatechangeauthority.gov.au/node/293
16
http://www.climatechangeauthority.gov.au/special-review
NAGA submission
Post 2020 Emissions Reduction Target
page 5 of 6

NAGA supports the work of the Climate Change Authority.
It is important that an independent body exists to undertake research and analysis to inform
Australia’s climate change policy development, and to monitor and evaluate the level of national
emissions, and the effectiveness of the policy platform driving emission reductions and the
economic transition to a low carbon future.

Australia should not disproportionately rely on the land sector (e.g. soil and reforestation
projects) for meeting its emissions reductions obligations at the expense of other sectors.
Although these are important initiatives that should continue to be supported, there are risks of
placing too much of a burden on these sectors. Achieving our post 2020 targets should recognise
that carbon built up in soil or within forests can be easily lost to the atmosphere following
disturbance events such as tilling or forest fires.
In conclusion, the Post 2020 Emissions Reduction Target Issues paper recognises that a strong and
effective global agreement is in Australia’s national interest.
NAGA supports an ambitious, strong and effective emission reduction target, informed by the climate
science that indicates urgent and substantial action is required, and underpinned by community support for
climate change action at all levels. NAGA is happy and willing to work with the Government to ensure
consistent and robust approaches to emission reduction which represents the best value proposition for
Australia and the global climate.
Please contact me if you would like to discuss any of the issues raised in this submission in more detail.
Yours sincerely
Rob Law
Project Manager
The views represented in this submission do not necessarily represent the views of all NAGA members individually.
NAGA submission
Post 2020 Emissions Reduction Target
page 6 of 6