Submission to Tasmania’s draft climate change action plan

Submission to the ‘Embracing the Climate Challenge: Tasmania’s draft climate
change action plan 2016-2021’

‘Embracing the Climate Challenge: Tasmania’s draft climate change action
plan 2016-2021’ is referred to as the Draft Action Plan or the Plan.
Note regarding numbering: action tables are numbered 1 to 4 in the Draft
Action Plan. We have numbered the headings or objectives in first column and
each action in the column next to them.
Tasmania’s greenhouse gas emissions
This section includes numerous graphs and figures that give an overly positive
picture of Tasmania’s current carbon emissions and potential renewable
energy production targets. This approach is continued throughout the
document including to repeatedly depict energy efficiency as being
intrinsically positive, portraying the positive advantages of climate change for
business but not balancing it with the negative impacts.
Figure 2, shows total emissions made in Tasmania in 1990 and 2013. Given
recent events, we should also separately account for what is emitted on the
mainland to generate electricity used in Tasmania.
Figure 3 shows Tasmania’s per capita greenhouse gas emissions as being close
to world’s best but a valid comparison would require comparing Tasmania’s per
capita emissions with other similar developed economies of similar climate to us
e.g. Ireland, British Columbia.
It is rather cynical of the government to boldly proclaim in the Draft Action Plan
that there has been huge carbon emission reductions achieved by reductions
in per annum forestry activity and forest clearing and conversion, but to choose
not to include any actions regarding forestry and clearing in the plan. The plan
fails to commit to maintaining or reducing current logging and clearing levels.
The rate of forestry and clearing could dramatically increase.
The government’s stance is doubly cynical given the failure of the plan to
mention two important decisions it is soon to take regarding forestry and
The action plan is highly selective in terms of what other government policies,
plans and strategies are considered. There is no reference to the potential to
reduce carbon emissions through the current review of the Permanent Native
Forest Estate Policy (see section 1.5) or Forestry Tasmania’s likely need to reduce
the scale of logging to address non compliance issues related to its application
for Forest Stewardship Certification (see section 1.5).
The government has been developing a strategy for the future of the forestry
industry that provides a further opportunity to look at reducing carbon emissions
from forestry or by managing forests for other lower emission uses.
Setting our ambition
The government makes a number of very ambitious target suggestions,
including an aim for zero carbon emissions. This is duplicitous of the government
because it has produced a plan that could not possibly achieve such
ambitious goal, in particular it fails to include strategies for key industries and in
relation to key projected social changes. The plan fails to honestly account for
the likely increased emissions from a massive population increase promoted by
the state government, fails to rule out increased levels of forestry and clearing
and fails to identify the likely ongoing demand for electricity from coal-fired
electricity from the mainland.
We recommend targets for each major sector including that there is a
continued reduction in forestry activities and that there is a immediate end to
broad-scale clearing of native forests.
Incorporating Energy Crisis Inquiry recommendations
The Draft Action Plan provides a very optimistic picture of the possible
renewable energy production targets, most notably on page 11. This part of the
plan would clearly have been written very differently if it was prepared during
or after this summer. We recommend a new section be included in this plan
that is prepared following the conclusion of the government’s proposed inquiry
into the current energy crisis, addressing the relevant recommendations of that
1.1. Assessing the latest policy and projections
Action 1.1.1: fails to identify how the state government will “give careful
consideration to the Paris Agreement and any resulting policy developments to
understand the implications for Tasmania”? The action should be reworded to
make it clear to the Tasmanian community how they will find out what the
responses will be.
Action 2: Similarly, how will the results of the proposed review of Climate Futures
for Tasmania and CSIRO projections be made available to communities,
industries and all levels of government.
1.2. Preparing for climate extremes and managing emergency responses
Action 1.2.1: There is an assumption that the state government’s fuel reduction
program is being run in an effect manner to reduce the bushfire risk and in
particular that its work program has effectively factored in the impacts of
changing climate. The final plan should include a summary of how climate
change is being factored into this program and how the community can
monitor the results over time.
Action 1.2.2: Will projections regarding flooding be incorporated into the
Statewide planning scheme?
Action 1.2.3: While the creation of a information portal is probably a positive
contribution to providing information to the community, even highly educated
people should not be expected to be able to access and use this information
without support. Support should be provided to raise awareness and
understanding among communities in high risk areas and those with limited
literacy and education.
Action 1.2.4: It is sensible to update Tasmania’s 2012 State Natural Disaster Risk
Assessment with a greater focus on future risks, but the review needs to suggest
changes to ensure that the strategy identifies those disasters that are manmade
and assess whether they need to be dealt with differently.
1.3. Managing our public assets
No comments.
1.4. Managing our marine resources
Action 1.4.1: The response should include a review of the appropriateness of
existing Fisheries Management Plans and Marine Farm Development Plans as
means of managing the impacts of changing climate on marine resources and
industries that utilise them.
1.5. Managing our natural assets and cultural heritage
Action 1.5.1: This action deals only with provision of information and advice and
does not propose any concrete actions by government nor does it suggest an
active role by other sectors. Nor does it identify objectives in relation to the
natural environment.
Objectives should included to identify and take measures to improve
protection of biodiversity that is most at threat from climate change.
In terms of the terrestrial environment, the priorities should be to:
- maximise the protection of values in the existing reserve estate to ensure
it is managed to maintain or improve resilience of biodiversity to climate
change; and
- increase the resilience, implement policies that restrict other key drivers
of biodiversity loss or decline, in particular by ceasing broad-scale
clearing and conversion of native forest on private land (as per the
commitment contained in the Permanent Native Forest Estate Policy.
While Tasmanian’s terrestrial reserve estate is larger and more representative
than the marine system, some vegetation types and species habitats have
inadequate levels of reservation at a statewide or bioregional level, putting
them at higher risk from the combined effects of climate change and other
threats such as clearing and invasive species. There are also many areas where
existing reserves are isolated and vulnerable to the impacts of climate change.
As a part of a more comprehensive strategy to protect Tasmania’s terrestrial
biodiversity, the states’ reserves estate should be strengthened by expanding
reservation on public land and implementing off-reserve conservation
measures. Protected areas should be designed to maximise their resilience to
changes caused by climate change.
As much of the most under reserved habitats and vegetation types are on
private land, the state government should work with land owners, conservation
groups and the Australian government to design and seek funding for property
conservation programs.
In terms of the marine environment, the priority should be to establish a
representative system of marine protected areas, designed to maximise their
resilience to changes caused by climate change, to provide protection for
representative areas of marine ecosystems in each marine bioregion. Reserves
would include sufficient areas free from impacts of fishing and other
exploitative uses. Reserves would provide crucial assistance to scientists to
monitor the impact of climate change in areas that are fished and unfished.
Forestry Tasmania has applied for FSC certification and been found by its
auditors to be critically non-compliant in regard to protection of threatened
species habitat and oldgrowth logging. To achieve required improvements it is
certain that they must seek government approval to reduce the legislated
wood volumes and this would help obtain FSC certification and further reduce
the annual emissions loss from native forest logging. The state government can
help this process by including a commitment in this plan to scale down the
legislated wood volumes.

2.1. Maximising our contribution to Australia’s renewable energy
Increasing renewable energy generation in isolation from reducing carbon
emissions is a flawed objective that could lead to increased renewable energy
generation and increased carbon emissions. Increasing energy production from
current Hydro asset base needs to be conditional on improving environmental
management outcomes.
This objective should be re-worded to state “Maximising our contribution to
Australia’s renewable energy generation while minimising carbon emissions”.
Action 2.1 should state that “The government will intervene to assist in achieving
market-led growth in renewable energy generation”
It seems clear from the Draft Action Plan that the state government intends to
leave it to market forces entirely to drive the demand for an increase in
renewable energy generation but that it intends for Hydro Tasmania to benefit
from this change by increasing its renewable energy supply. 
Page 19 states that “The government will seek to maximise the potential for
market-led growth in renewable energy generation” and this is repeated in
action 2.1 on page 22.
Page 18 states that “As global demand for renewable energy increases, energy
exports from Tasmania can play an important role in helping other Australian
states and territories find a solution to managing their carbon emissions.”
Page 18 also states “As coal-fired power stations in other states are retired,
Tasmania has the opportunity to increase its renewable energy supply to fill the
Mainland states may choose to increase their energy use by importing some
additional electricity from Tasmania but to also continue carbon producing
electricity generation at the same or higher level. Closure of coal-fired power
stations is by no means guaranteed and government should not leave it to
market forces or other state governments to drive these changes.
Such a hands-off approach by the government to driving change in demand
may have the opposite effect and lead to increased carbon emissions.
As a condition of investment in increasing Hydro’s renewable energy
production, the state government should commit to acting to hasten the
closure of coal fired power stations, including by ensuring that Hydro Tasmania
refuses to receive power from coal-fired power plants.
Until this is achieved the state government should implement measures to
require Hydro to tell electricity consumers when imported electricity may be
sourced from coal-fired stations and when it is guaranteed coal free. This would
assist the consumers to reduce power use to avoid carbon emissions or install
their own renewable generation systems. Giving customers this information may
also lead to consumers putting greater pressure on the owners of coal power
plants and other non-renewable plants to reduce emissions.
2.2. Advancing the case for biomass
This objective should be reworded to state “Advancing the case for biomass
but only where it comes from appropriate sources and is true waste from other
The Action 2.2 should state that in regard to industrial scale biomass energy
production the government will put in place measures to ensure that only
verifiable post logging or post milling waste is used from plantation forests and
that the logging is not the primarily reason for the logging.
We do not believe that the forest industry and Forestry Tasmania in particular
can be trusted to establish industrial scale biomass energy production in native
forests using only true waste. To support any such industry we would need to be
convinced that the biomass would not become the primary reason for the
logging and not rely on waste.
2.3. Reinvest in our renewable energy asset base
Action 2.3.1 should include a commitment by the state government to allocate
funding to Hydro on the strict condition that it improves management of natural
values as recommended below.
Conserving natural values
A new action is recommended to ensure that the environmental risk created by
the dramatic draw-down of Hydro Tasmania’s lakes over the last twelve months
does not happen again. In particular, the action should require that all lakes
are managed to maintain water levels within a range that ensures the
maintenance of critical ecological values, in particular threatened native fish
and their habitats, and that these lake levels are given statutory basis through
legislative change.
2.4. Attracting investment in energy innovation and energy efficiency
No comment.
2.5. Leveraging our clean energy brand
The strategy seeks to attract industries including energy intensive industries to
Tasmania without any recognition of the risks that this would provide to
maintaining domestic electricity supplies when storage levels get low, as is
currently the case.
The strategy also aims to attract industries to Tasmania who want to “reduce
their emission profile”. While this provides a potential business benefit to Hydro
Tasmania and possible employment benefits, there is no guarantee that this
reduces the carbon emissions from energy generation in the state where the
company relocates from.
Action 2.5 should be amended to state that “Facilitate the further promotion of
Tasmania’s clean energy brand to prospective investors, while ensuring
domestic energy security and that there is a net reduction in carbon emissions.”
2.6. Becoming more energy independent
No comment.
The back ground information identifies the significant changes to Tasmania’s
climate but only identifies the business advantage from Tasmania’s relatively
less severe impacts from climate change than mainland states. There is no
analysis of the negative impacts on business of these changes and how
government might assist businesses to close or relocation.
For example, while the strategy correctly identifies two wine companies that
have relocated to Tasmania from the mainland to take advantage of our
wilder climate, there may well be existing wine makers that cannot continue in
Tasmania and cannot relocate to a cooler climate.
3.1. Getting our primary industries climate ready
Action 3.1.1: Change the wording to incorporate a role for the state
government in identifying industries threatened by climate change and to
facilitate their relocation.
Actions 3.1.2 and 3.2.3: The state government should identify a role to help the
agricultural industries to undertake extension services and produce
management tools for themselves on sustainable basis.
Action 3.1.4 and 3.1.5. No comment.
Action 3.1.6: There should be acknowledgement of the state government’s
significant progress in preparing twenty first century biosecurity legislation that
will assist with protecting agriculture from biosecurity risks, including those
associated with a changing climate.
3.2. Using our climate advantages to attract investment
Action 3.2.1: This action should be reworded to ensure that potential new
industries and investors are given information regarding both the advantages
and disadvantages of Tasmania’s climate.
Action 3.2.2: No comment.
Action 3.2.3. As above, both the advantages and disadvantages should be
addressed in Tasmania’s Advanced Manufacturing Strategy.
Action 3.2.4: The state government could greatly increase interest of farmers
with forest in participation in the Emissions Reduction Fund by ceasing all
clearing and conversion of forests on private land.
3.3. Growing our science and research capability
Action 3.3.1: This action should include a commitment for the state government
to maintaining the funding for climate research by the CSIRO in Tasmania.
Action 3.3.2: No comment
3.4. Improving energy and resource efficiency
Action 3.4.1.: No comment
Action 3.4.2. This action should state that industries should be assisted in
establishing sector wide emissions targets and mechanisms to deliver sector
wide decrease in emissions.
Action 3.4.3: No comment
This section makes the outrageous unsubstantiated claim that Tasmania does
not having any major constraints to population expansion, in particular that
Tasmania “does not have any shortages of land or water” and that we do not
have “the same congestion issues that some cities in mainland Australia are
facing.” There is also no consideration of the increased emissions of another
150,000 people in Tasmania that the governments population strategy aims for.
Hobart’s recent traffic problems show just how absurd the claim regarding
congestion is. This strategy needs to commit to assessing the potential for
congestion to worsen with population growth and the resulting increase in
carbon emissions.
In terms of water supply and waste water treatment, I would assume that
TasWater does not share the view that there are no constraints. TasWater is
undertaking an estimated $1.5 billion upgrade of infrastructure statewide and
this is not predicated on the government’s population target. There will be
further costs and emissions associated with providing these services for more
A new objective is proposed to review the government’s population targets to
determine a truly sustainable population for Tasmania. This would involve taking
into account the impacts of climate change on our capacity to
accommodate more people and the carbon emissions that would result from
increasing population, including from building more houses, roads and other
infrastructure and their likely consumption during their lifetime.
4.1. Managing climate impacts to enhance liveability.
No comments.
4.2. Improving energy efficiency in homes and communities.
The purported benefits from greater energy efficiency need to be clarified.
Research may need to be done to determine how electricity consumption
changes with greater efficiency.
If people use electricity more efficiently by purchasing a more energy
efficiency appliance or by installing insulation in their home, they may consume
just as much or more electricity, and pay the same amount in their bill, by
heating more of the house, staying at home more and going to bed later. This
may have health and wellbeing advantages but it may not result in less
electricity use and has no apparent benefit for reducing carbon emissions
unless taken in concert with other actions (see Action 2.1).
4.3. Reducing emissions from waste.
While this action is supported, it would be improved by the government
committing to some key waste management objectives that would assist with
emissions reduction, such as:
- Acknowledging that diversion of waste from landfill can reduce
emissions by diverting methane producing compostable material and
reducing demand for new materials.
- Supporting the need for landfill diversion targets and commit to the
strategy establishing them.
- Support an increase in landfill levy to fund greater investment in waste
reuse, recycling and reprocessing.
4.4. Government leading by example
No comments.
4.5. Building stronger community engagement
No comments.
4.6. Facilitating sustainable transport
No comments.