Sender: City of Greater Geelong
Address:
Po Box 104
Geelong VIC 3220
Tel: 03 5272 5272
Fax: 03 5272 4277
Email: contactus@geelongcity.vic.gov.au
Web: www.geelongaustralia.com.au
29 September 2015
To: Hon. Lily D'Ambrosio MP
Minister for Energy and Resources
Address:
Department of Economic Development , Jobs, Transport and Resources
GPO Box 4509
MELBOURNE VIC 3001
Dear Minister
Re: Victoria's Renewable Energy
Roadmap
Thankyou for the opportunity to provide Feedback on Victoria's Renewable Energy
Roadmap as we believe that there is significant leadership opportunity at the State and
local government levels to drive further action on renewable energy generation.
Due to the limited time available provided for feedback , the below comments have not
been endorsed by Council and should be viewed as Officer comments at this stage.
The City of Greater Geelong recognises the opportunity for the Greater Geelong region to
take a leadership role in climate change action to enable strengthening of the
municipality's environment, economy and community. Providing effective leadership will
require partnerships between State Government, Council, community groups and
businesses to reduce greenhouse gas emissions and increase the uptake and further
development of the renewable energy sector.
Background
The City of Greater Geelong is committed to providing effective advocacy to promote
sustainable design and development, provide support to the Geelong community and
provide leadership through Council's own operations and services. The following priorities
are a key part of Council's City Plan:

Minimise our environmental footprint – Continue to seek methods of reducing
energy, water and waste consumption

Support our community to live sustainably – We will investigate and facilitate
renewable energy opportunities

Advocate for and promote sustainable design and development.
The City of Greater Geelong adopted a Sustainable Building Policy in 2012 to ensure
Council is providing leadership to the Geelong community in relation to Council's
extensive building portfolio and any newly constructed buildings. The standards have
resulted in a significant increase in renewable energy systems on Council buildings.
Newly constructed renewable energy systems are now planned in conjunction with a
whole of building sustainability design. Examples of this include the 5 Star Green Star
Geelong Library and Heritage Centre and 30kW solar array and the construction of an
80kW solar array on the state of the art Ocean Grove Integrated Child and Family Care
centre (refer to media release attached).
Council is committed to providing a leadership role in supporting the community to make
a transition to a low carbon community and increase the uptake of renewable energy.
The City of Greater Geelong is currently working with the Geelong community to develop
a Greenhouse Strategy. The objective of the Strategy is to reduce Council's corporate
emissions and core operating costs and engage with the Greater Geelong community to
support broader emissions reductions. The new Strategy will establish an emission
reduction target and a renewable energy target.
The City of Greater Geelong is also leading the way in relation to influencing commercial
and residential development through the development of Sustainability Management Plan
Guidelines for the Armstrong Creek Town Centre. These guidelines apply to new
commercial and residential development and assist developers early in the planning
process to incorporate Ecologically Sustainable Development (ESD) and measures to
reduce their energy demand. Council is now investigating how this approach can be used
more broadly for other commercial and residential developments in Geelong.
The City of Greater Geelong also provides guidance and support for the increased uptake
of residential solar through the EcoChallenge@home Program. The program has carried
out over 20 evening information sessions to approximately 400 residents and has
provided information on residential renewable energy.
Diversification of the economy and skills development in the renewable energy sector will
support the continued growth of local job opportunities. Council is committed to showing
leadership in supporting the community to make this transition.
To help facilitate this a Low Carbon Growth Plan was developed in 2011 and updated in
2014 to assist a community wide approach to achieving emissions reduction. The Plan
identifies a broad range of cost effective greenhouse gas mitigation opportunities in the
Geelong region. The Plan recognises the importance of Local Government's role in
facilitating partnerships with other greater Geelong peak industry organisations to align
strategic priorities and programs to drive investment in energy efficiency and renewable
energy projects. Future Proofing Geelong is an example of this and is a partnership
program that has assisted industry and business to identify abatement opportunities and
funding opportunities.
The Future Proofing Geelong program also aims to support the local community and
industry through a program called CleanTech Innovations Geelong, launched in 2013 .
The program brings together business, industry and academia to develop new markets
by stimulating demand for CleanTech goods and services that harness renewable energy
materials and sources. The aim is to establish Geelong as a Centre of Excellence for
CleanTech in Australia , by attracting investment , creating jobs and building skills.
Sect. 1. Victoria's Energy Sector Challenge
Local Government is well placed to support the State Government to re-establish itself as
a global leader in renewable energy development. Local government's high profile role in
building and operating community assets on behalf of the community , Council's advocacy
and influencing role in relation to industry and administrative role through the planning
scheme in relation to commercial and residential development , provides significant
opportunity to expand the Geelong renewable energy investment.
Increasing investment in renewable energy is a significant challenge in a highly
competitive investment environment such as local government where increasing financial
pressures on delivering core business is clearly apparent. Local government Rate caps to
be introduced may restrict the ability for local governments to invest in renewable energy
due to initial capital costs.
Recommendation: Strengthening of the State Government renewable energy target
and associated funding programs, such as the New Energy Jobs Fund, should be targeted
to drive investment in renewable energy to reduce business and local government core
operational costs. The deployment of funding should take advantage of local
government's unique position in facilitating increased community uptake of renewable
energy.
The development of a Victorian Renewable Energy Roadmap Action Plan will need to
recognise local government as a key partner and clearly articulate ways in which local
government can play a key leadership role.
Sect 1.1 " Victoria's energy sector challenge." "Victoria has a dynamic and
competitive energy industry in which participants have the flexibility and commercial
imperative to respond to emerging market trends, and it is well endowed with the energy
resources of the future. However, the sector needs government policy leadership to reach
its full potential in this new environment'
Recommendation: An increased incentive for existing energy suppliers to diversify their
offer to the market in supplying more renewable energy sources is required. At present
there are few, if any, incentives for existing energy generators to remove barriers in
relation to renewable energy access, storage and distribution. This is largely due to the
renewable energy sector being in direct competition with their existing traditional coal
fired generation to the market. Government policy which provides for incentives to
encourage existing energy generators and distributors to develop their renewable energy
offer to the market (beyond off-setting or Green Power) would be welcome.
Sect.1.2 "Shifting Victoria's economy to a low-emissions future" and 2. "Initiating
state actions to drive down carbon emissions across all industry sectors, supported by the
review of the Climate Change Act 2010 and investigation of a state emission reduction
target".
Recommendation: While the Victorian Government's Renewable Energy Roadmap
focuses on renewable energy development , it continues to be an important part of any
strategy at the state and federal level to acknowledge the importance of pursuing energy
efficiency measures to maximise renewable sources used to supply energy. In support of
this the City of Greater Geelong's Low Carbon Growth Plan 2015 Update states that
"Energy efficiency opportunities continue to present the lowest-cost options for reducing
emissions. Opportunities in commercial and residential buildings, including energy
efficiency and solar PV, now represent the greatest share of emissions reductions, with
one third of the total identified opportunity for Geelong' .
Sect. 4. Addressing Barriers to distributed
generation and storage
The City of Greater Geelong reports to the Federal Government under the National
Greenhouse and Energy Reporting (NGER) Act 2007 . Under the NGER requirements, there
are no benefits of retaining or selling small-scale technology certificates (STCs) or largescale generation certificates (LGCs) associated with solar PV installations. Both the NGERs
and STC requirements are Federal Government initiatives administered via the Renewable
Energy Target (RET) scheme and the Clean Energy Regulator.
Currently there appears to be little integration between NGER reporting and retaining or
selling STCs. Council is currently able to sell STCs when installing solar PV and offset a
significant portion of the total system cost, whilst still offsetting emissions profile. It
would appear that this financial incentive can occur whilst STCs are created at the
renewable energy certificate registry and bought by another company to offset their
emissions.
The financial incentive that the STCs provide to local government are significant and may
be the difference between a solar PV installation being installed or not. A recent City of
Greater Geelong example for the installation of an 80kW system provided a 38%
reduction of total system cost through STCs.
Recommendation: That the State Government advocate for improved provision of
information and potentially improved system integration in relation to various emissions
reporting requirements and renewable energy certificate processes.
Sect. 5. "Encouraging household and community
renewable energy generation"
The City of Greater Geelong has undertaken a pre-feasibility study into large scale solar
renewable power generation and the study has recommended Council continue with
investigations for a 3 MW solar PV system at the former Corio landfill site.
Recommendations include searching for potential electricity offtakers, financiers and/or
developers, as well as preliminary discussions with PowerCor (Grid operator) for grid
connection approvals.
Recommendation: An opportunity exists for a network of Councils and businesses to
procure renewable energy locally or from neighbouring regions. Victoria's Renewable
Energy Roadmap could provide a reference to this type of network and encourage the
facilitation of such a network through the MAV's suggested Dedicated Renewable Energy
Advocate/Agency.
If you have any questions in relation to any of the above recommendations please call
Burke Renouf (Coordinator Sustainability) on (03) 5272 4877.
Yours sincerely,
KELVIN SPILLER
INTERIM CHIEF EXECUTIVE OFFICER
Copy: Municipal Association of Victoria