Saturday, February 04, 2012
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Submissions

Submission to the Australian Prudential Regulatory Authority

As governments inevitably move to reduce greenhouse gas emissions, carbon pricing will have an effect on the values of a broad range of companies across the global economy. As the value of the companies in which superannuation funds are invested is impacted by policies to deal with climate change, the future retirement incomes of all Australians will be impacted.

This submission outlines The Climate Institute’s views, in the context of proposed Prudential Standard SPS 220 Risk Management, on how the Australian Prudential Regulatory Authority’s new prudential standards for the superannuation can help facilitate Australia’s transition to a low-carbon economy and in doing so help safeguard the financial future of Australia’s present and future retirees.

Download Submission
(PDF, 200KB)
APRA Submission
 

Submission on the Clean Energy Finance Corporation

Perhaps the most important aspect is the response of the investment chain in delivering low carbon solutions. It is this investment chain that defines the behaviour of investee businesses and that controls the movement of capital between asset classes such as equities, fixed income, infrastructure, private equity, property and hedge funds. It is the investment processes, cultures and decisions that determine whether money is invested in low carbon or high emitting assets. It is also the investment system that either feeds or strangles companies of their oxygen-like capital depending on their long term prospects.

This submission outlines The Climate Institute’s views on how the Clean Energy Finance Corporation can help facilitate the financing of Australia’s transition to a low-carbon economy.

Download Submission
(PDF, 315KB)
CEFC Submission
   

Submission to the Joint Select Committee on Australia's Clean Energy Future Legislation

The Climate Institute (TCI) welcomes the opportunity to submit its views to the Joint Select Committee on Australia's Clean Energy Future Legislation on the Clean Energy Future legislative package released by the Government in July 2011.

Overall the amendments to the Bill substantively address many of TCI concerns with the draft legislation. Appendix 1 outlines outstanding issues that remain to be resolved in a satisfactory manner and TCI would be happy to speak to this submission at the Committee's convenience.

However, it is critical that the Bills are now passed, without delay, to put a price and limit on pollution, provide the certainty to invest in clean energy and begin contributing to Australia's fair share internationally.

Download Submission
(PDF, 220KB)

joint select committee
   

Submission on the Clean Energy Legislative Package

The Climate Institute described the Clean Energy Future package as a vital and long overdue step forward. It captures the potential for Australia to cut pollution, clean up the economy, reduce energy waste and join the global effort to tackle climate change.

The drafting and implementation of legislation supporting this package will be critical to ensuring this potential realised.

In this submission three key issues that been indentified that need particular attention to ensure an economically, environmentally and politically robust set of Clean Energy legislation passes the Australian Parliament.

Key changes need to be made to the legislation:

  1. Honour Australia’s global commitments: Ensure the legislation, and its implementation, is consistent with Australia?s international commitments – this is relevant to Objects, Definitions and decision making criteria in the Bill.
  2. Instill integrity in carbon budgeting: Link shorter term pollution limits and reviews to the longer term cumulative 2050 carbon pollution budget.
  3. Ensure greater accountability and clearer liability: This applies to actions taken by the Minister in setting pollution caps and ability of third parties to challenge breaches of the Bill. The unusual ability of the Regulator to remit and waive penalties for non-compliance should be removed.

Other critical issues include more clearly defining the actions of other nations, carbon leakage and fuel arrangements in Productivity Commission reviews, and ensuring Clean Energy Investment Plans are consistent with the required reduction in pollution intensity of the sector.

In addition, to better mobilise finance to encourage clean energy investment, the Government should, alongside the Clean Energy Future package, implement changes to disclosure and reporting requirements upon corporations and institutional investors.

Finally, The Climate Institute sees no valid reason to either reduce the starting price or defer the introduction of this legislation. Failure to implement pollution pricing will see Australia?s pollution levels increase to around 20 per cent above 2000 levels by 2020. Delay is already costing the economy.

Download Submission
(PDF, 460KB)
CELP Submission
   

Submission to the House & Senate on the Carbon Farming Initiative

The Climate Institute welcomes the opportunity to present the Committees with our views on the Bills currently before the Parliament, and, consequently, the proposed Carbon Farming Initiative (CFI or ‘the scheme’).

On the whole, The Climate Institute is reasonably confident that the Bills strike a balance between the scheme’s twin principles of environmental integrity and broad participation. The Institute is therefore broadly supportive of the proposed scheme, although we submit that a better balance is still possible, and that other policy measures are prerequisites to the scheme’s success. In essence, these are:

  • A price on industrial carbon pollution—linked to the CFI—without which demand for abatement in the land sector will remain low; and
  • Additional funding, of at least $200 million over four years—drawn from carbon price revenue if necessary—to establish a strong mitigation research, development, extension and commercialization programme for the land sector.


This submission touches on the importance of a price on pollution, the managing of risks to the price signal and revenue, the minimisation of perverse outcomes and maximising of participation, environmental co-benefits and the issues of permanence, leakage and additionality.

Download Senate Submission
(PDF, 290KB)
Download House Submission
(PDF, 290KB)
Senate House
   

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