Submission to: Consultation on proposed legislative changes to incorporate an emissions reduction objective into the national energy objectives

10.02.23 By
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The Climate Council’s recommendations are summarised below; further discussion and supporting data on each is outlined through this submission.

Recommendation 1

As part of implementing a national emissions reduction objective in the national energy objectives, Australian governments should issue a strong statement of expectations to market bodies about how this should be interpreted, to ensure appropriate priority is given to clean, affordable renewable energy and storage infrastructure.  

Recommendation 2

To help drive strong emissions reduction, market bodies should be empowered to make decisions with reference to: ‘at least achieving current targets for reducing Australia’s greenhouse gas emissions and advancing the decarbonisation of Australia’s energy system as rapidly as possible in the context of stable and reliable supply.’ 

Market bodies should have the widest possible scope to consider both legislative and policy commitments, with a process being established for federal, state and territory governments to notify market bodies of a relevant target or policy that they wish to be taken into account in the application of the National Energy Laws. 

Recommendation 3

To ensure that all essential forms of energy supply and storage are captured by new legislative definitions, these should be updated across the relevant legislative instruments to reflect the language of: ‘consumers of energy including energy storage’, and with ‘energy’ being given the definition of: ‘electricity, renewable energy storage, gas or a combination of the three’. 

Recommendation 4

To ensure market bodies and participants commence making decisions under the updated framework as soon as possible, the amended objective should take formal effect on the date of passage through the South Australian Parliament. Its application by market bodies should be back-dated to applications and processes commencing from August 2022 when Energy Ministers announced their intention to insert this into the national energy objectives.

Market bodies should also have strong discretion to apply the new objective to processes that are underway, particularly where there is a clear case that long-term consumer outcomes would be served.