Anglican Ecocare has made a submission to the Inquiry, and will give evidence at its hearing in Perth on 31 January 2014:
The view of the Anglican EcoCare Commission (AEC) is that the Direct Action Plan (DAP) is an ineffective pollution reduction policy. The DAP would benefit from increased pollution reduction targets and the advice of the independent Climate Change Authority (CCA).
1. That the existing carbon pollution legislation be retained until a credible alternative can be presented that will transition the economy from carbon-intensive energy sources to low or no-carbon renewable sources.
2. That Australia’s climate policy meets its existing international commitments for emissions reduction.
3. Review the existing emissions reduction targets and increase to a more realistic level such as 40% below 1990 levels by 2020, with a view to ‘doing our bit’ to holding global climate warming to below 2 degrees C.
4. Increase the existing renewable energy target beyond the existing 20% by 2020
5. Retain the Climate Change Authority as an independent advisor, providing oversight on the performance and adequacy of the climate policy.
That the existing carbon pollution legislation be retained until a credible alternative can be presented
The Coalitions’ voluntary, no penalty, non-independently reviewed and half funded scheme is not sufficient to deal with the serious challenges of our changing climate. AEC recommends that the existing carbon pollution legislation be retained until a credible, ethical and effective alternative can be presented that will transition the economy from carbon-intensive energy sources to low or no-carbon renewable sources.
The carbon pricing mechanism, famously lambasted by Tony Abbott as Labor’s “carbon tax” is actually a cap and trade scheme. It caps emissions within a defined and legislated target. Repealing this effectively means that there is no cap on emissions. The Coalition has promised $2.6 billion over 4 years to curb emissions, meaning that Australia has a monetary cap rather than a legislative cap and, rather than companies paying the government based on how much they emit, taxpayers pay companies to emit less.
There is also doubt that the DAP can achieve the Coalition’s stated target. A number of reviews of the Coalition’s DAP policy by Ernst and Young, the law firm Allens, Treasury and the Climate Institute (TCI), have concluded there is considerable uncertainty as to whether the proposed measures can achieve a 5% reduction of emissions on 2000 levels by 2020. Indeed, emissions are likely to increase under this regime.
The independent analyses also find that the money made available for the ERF is insufficient to reduce Australia’s emissions in line with the bipartisan target range, let alone drive greater emission reductions over the longer term. Indeed, TCI estimates $4 billion more would be needed to achieve the 5 per cent target. However, Prime Minister Abbott has publicly ruled out increasing the spending, even if this means we fall short of the 5 per cent target.
By contrast, the existing carbon pollution legislation is already beginning to take effect in slowing emissions. Although Minister Hunt argues Australia’s emissions have continued to grow under the existing legislation, this is caused by increases in fugitive emissions (from coal and coal seam gas mining) and transport – both areas not covered by the legislation. The existing legislation has been effective in reducing emissions in the sectors which it covers, such as electricity generation, and has created incentives for industry to move toward low-polluting alternatives.
By repealing the existing legislation, Australia would find itself out of step with the international community. Indeed, in a speech on October 2013 OECD General Secretary Angel Gurria said:
“There has to be progress on every front, but notably with respect to carbon pricing, and we don’t have any time to waste. Unlike the financial crisis, we do not have a ‘climate bailout’ option up our sleeves. …. In our view, any policy response to climate change by any country must have at its core a plan to steadily make carbon emissions more expensive while, at the same time, judiciously giving non-fossil energy and energy efficiency an advantage at the margin. This is fundamental.”
Australia’s climate policy must meet existing international commitments
The DAP as it is currently articulated, is structured around a decarbonisation target which fails to honour Australia’s existing international pollution reduction goals. A mere 5% reduction is inconsistent with commitments made at the UN Framework Convention on Climate Change (UNFCCC) in 2010 and 2012. Furthermore, a 5% decarbonisation pledge will greatly harm Australia’s reputation as a responsible global citizen, and will hinder Australia’s ability to play a positive role in future discussions.
Review the existing emissions reduction targets and increase to a more realistic level
The IPCC released its long-awaited fifth assessment report in September 2013. The report concluded that warming of the climate system is now deemed to be “unequivocal”, with many of the observed changes unprecedented over decades to millennia. The atmospheric concentration of greenhouse gases is unprecedented in at least the last 800,000 years and is primarily from fossil fuel emissions.
Improved modelling of future scenarios predict that, by the year 2100, temperature change is likely to exceed 1.5°C to relative to 1850 to 1900, and more likely than not to exceed 2°C. Most aspects of climate change will persist for many centuries even if emissions of CO2 are stopped now.
Studies by numerous climate scientists, such as the eminent Professor James Hansen and the prestigious Potsdam Institute for Climate Impact Research (PIK), are predictive of 3 - 4°C global warming. This will not only be disastrous for the developing world, but in the words of the PIK executive summary: “there is also no certainty that adaptation to a 4°C world is possible.”
The Global Humanitarian Forum estimated in 2009 that the health of 325 million people is currently affected by climate change, principally because of loss of food security, changes in disease patterns and flooding. These issues already cause an extra 300,000 deaths per
year, and these shocking figures are bound to increase further. 
Anglican EcoCare supports the call of many representatives of developing countries who advocate that we keep global warming below 1.5° C and return carbon dioxide in the atmosphere to 350 parts per million. This recognises that a 2° C increase would mean massive losses for the world’s poor. Indeed, it is unknown when critical tipping points will be reached and it is quite possible that two degrees of warming may be enough to precipitate irreversible and catastrophic climate change
The DAP’s proposed 5% reduction are now recognised to be much too low a target, given the mitigation measures required for Australia to contribute to global efforts to keep temperatures even within a 2 degree rise. A more realistic target of 40% reduction in pollutants based on 1990 levels by 2020 are required in order to effectively transition to the low-carbon economy required. Repealing the Clean Energy Act will leave Australia without a legislated cap on even a 5% reduction. It is inaccurate for the Coalition to claim that the DAP is costed because they have announced how much they’ll spend. Costing something inherently involves measuring whether the amount you’ve budgeted will achieve what you think it will.
Increase the existing renewable energy target beyond the existing 20% by 2020
The AEC is concerned that proposed measures do not extend beyond 2020, risking Australia’s economy as one which is non-transitioned to a zero-emissions market. Implementing a short term ‘fix’ to a long term issue such as climate change means that little certainty is provided to companies to make long-term investment decisions. Such policy uncertainty leads to poor outcomes for business and the environment.
Certainly Australia has shown remarkable growth in the uptake of small-scale renewable energy systems, with over one million households now contributing to the grid view solar panels. This increased capacity is shown in what utility companies refer to as ‘reduced demand’ over the last 2-3 years. Much more, however, could be accomplished. For example a global status report for renewable energy published in 2011 found that renewable energy accounted for approximately half of the estimated 194GW of new electric capacity added globally during the year, and Bloomberg revealed 2011 was a record investment year for clean and renewable energy. As the Climate Change Network Australia asks on its website: ‘Is Australia making the most of its abundant natural resources of solar and wind energy? Despite being amply endowed with renewable energy resources, Australia has so far failed to consistently pursue the opportunities of the emerging renewable energy age.’
Perversely, business interests are now reported to be lobbying the government to abandon the existing 20/20 target on the grounds that it is likely to be over-reached! Effectively this argument is that 20/20 should be a cap, rather than a minimum target. For reasons outlined above, we feel that Australians should be congratulated for their technological innovation in the field of renewable energy, and encouraged to aspire to a much higher target, for example 40% renewable energy by 2020 and rising to 100% by 2050.
Retain the Climate Change Authority as an independent advisor
Repealing the carbon pricing mechanism also means that a number of institutions established to support and implement the scheme, will no longer exist or are under threat. For example the Government has already dismantled the Climate Commission and the Climate Change Authority, bodies established to provide independent advice to government on emissions reduction targets. Under threat if the Government’s repeal legislation is passed by the Senate are the Clean Energy Finance Corporation and the Clean Energy Regulator.
This is a particularly worrying possibility as the Clean Energy Finance Corporation has been delivering a net return to the public purse. If it were allowed to invest the full $10 billion planned, it would create a net return of $200 million a year, yet there is still the intention to close it.
The Climate Change Authority must be retained, with a mandate to monitor Australia’s performance against decarbonisation targets. A comprehensive system of compliance measures which effectively, independently and transparently monitor the effectiveness of the DAP is essential.
Furthermore, it is particularly important that accurate baselines are developed in a manner which does not create a perverse incentive for companies to pollute; and that penalties for non-compliance apply to companies who exceed their baselines and fail to meet the objectives of their tenders.
Finally, the AEC is concerned that while over 20 Nobel Prize winners in economics have endorsed emissions trading or prices on carbon, none have supported reducing emissions through a tender scheme.
Environmental degradation is not simply a scientific or political issue. Greed and exploitation have accompanied and often overshadowed beneficial economic development. Unjust political and social structures have led to displacement of people and to poverty. Many scientific reports are now recommending an urgent transition from the use of fossil fuels to renewables as the dangerous effects of Climate Change become more obvious.
Transformation to wise and sustainable use of the environment is at heart a spiritual matter. Environmental concern is a legitimate and necessary part of a Christian's response to God's loving provision for us. At a practical level we must remember the economy is a subset of the environment not as is often assumed the other way around.
About the Anglican EcoCare Commission
The Anglican EcoCare Commission (AEC) strives to sustain the earth through initiatives that promote environmental responsibility in a range of diverse settings – from worshipping to school and local communities. They do this through education, advocacy and expressions of eco theology.
We are proud to belong to a Diocese that considers the environment as something integral to the life and mission of the Church, as well as central to our spirituality. We act in accordance with the Anglican EcoCare Statute (2006).
Our current policy priorities are sustainability, energy, water and pollution. We hold membership with the Ecumenical Social Justice Roundtable, the Council of Churches WA, and the WA Civil Society Climate Roundtable.
Our commissioners are committed Anglicans, lay and ordained who promote the responsible stewardship of our creation through theological action and reflection.
The Reverend Evan Pederick
Acting Chair, Anglican EcoCare Commission
The Reverend Evan Pederick
c/o Anglican EcoCare Commission
Wollaston Education Centre
5 Wollaston Road
Mt Claremont WA 6010
T +61 (0)8 92860270
 Human Impact Report: Climate Change – The Anatomy of a Silent Crisis, commissioned by the Global Humanitarian Forum, June 2009.
 ”Clean Energy Finance Corp warns shutdown will hit budget”, ABC online news, 27/11/13
 Green by Grace; a report prepared for the General Synod 2004.