​Download Content

Research from around the world — including Australia — has consistently found that NO₂ is linked to both:

• developing asthma, and
• triggering asthma attacks.

Children exposed to higher levels of NO₂, whether at home or school, tend to have:

• more frequent and severe asthma symptoms
• reduced lung function
• more trips to the doctor or hospital

One study found that children living in homes with gas stoves were:

• twice as likely to wheeze or feel short of breath
• four times as likely to experience chest tightness compared with children in homes without gas stoves. [11]

NO₂ doesn’t just affect kids, it can also make asthma worse in adults. Long‑term exposure can even play a role in developing and worsening chronic obstructive pulmonary disease (COPD), a serious lung condition that affects about 1 in 13 people over the age of 40. The elderly in particular are vulnerable to poor indoor air quality as they spend comparatively more time indoors. [12]

About 57% of homes in Lake Macquarie are connected to gas, [17] [18] Furthermore, Lake Macquarie is growing quickly, adding around 2,143 people and 860 new homes each year. [19]

Across NSW, gas use in homes is still increasing:

• 16,000–22,000 new gas connections are added each year [20]
• That’s 36–46% of all new builds [21]
• For Lake Macquarie, this would mean 300–400 new gas‑connected homes every year

​This locks in higher indoor air pollution for decades to come.

Lane Cove Council is a great example of how this can work in practice.

In September 2023, the council updated its DCP to require all new developments over $250,000 to be fully electric. Their rule is simple:

“All new developments are to use only electricity for all energy requirements associated with normal operations. Where outdoor barbeques require gas then only bottled gas may be used.”

They also included exemptions for specialised industrial uses that genuinely can’t electrify.
Crucially, Lane Cove based its decision on health (better indoor and outdoor air quality) and economic benefits (lower energy costs for residents). [30] This approach ensures the policy is consistent with state planning rules.
​

​​Download Content

The Clean Energy Association of Newcastle and Surrounds (CLEANaS) supports the overall strategy. However, we wish to raise concerns and provide feedback on the strategy.

CLEANaS is a not-for-profit association formed in 2012 by a group of locals passionate about clean energy. CLEANaS is dedicated to driving the uptake of clean energy so that our region can transition from its current dependency on fossil fuels to a more competitive and sustainable local economy. We achieve this by working with our partners to demonstrate profitable community-led and community-owned clean energy projects; raise the profile of clean energy in the local economy through education and awareness raising; and by improving access to financing mechanisms and affordable technologies so that investment and activity grow. Our initiatives must deliver a win-win for local community investors, local enterprise and, of course, our environment.[1]

The Need for Rapid Emissions Reduction
The amount of CO2 in the atmosphere keeps on going up and up from the burning of fossil fuels – principally coal, oil and gas.  Australia has set a legislated target to reduce our greenhouse gas emissions to net zero by 2050. To help drive the transition to net zero, the Australian Government has set a target to reduce emissions to 62-70% below 2005 levels by 2035.[2]

The Role of Local Councils in Driving Net Zero
Councils are uniquely positioned to help the drive towards net zero emissions through their connection to local communities, and their existing mandate to provide support and infrastructure to residents and businesses. Councils can drive new sustainable development through model Development Control Plans, and support community initiatives towards reducing emissions. Councils are well-placed to coordinate efforts between residents, businesses, and workers within their LGA to move towards reducing emissions.[3]

Lake Macquarie’s Current Emissions Profile
Lake Macquarie City’s Environmental Sustainability Strategy and Action Plan 2020-2027 details the planning management action to

"Investigate and implement energy efficiency and emissions reduction measures, and renewable energy opportunities, across the City for public, commercial and residential Developments.”

Furthermore, it states that Lake Macquarie City has a 2027 target of a

“57% reduction in City-wide per capita greenhouse gas emissions from 2007 baseline”. [4]

In the baseline year, city-wide total greenhouse gas (GHG) emissions were estimated to be 4,869,761 t CO2-e and a city population of 194,997 (25.0 t CO2-e per capita)[5]. By 2023/24, total GHG emissions had reduced to an estimated 3,592,200 t CO2-e with a population that had grown to 218,965 (16.4 t CO2-e per capita), a per capita reduction of only 34.3% from the baseline. It is expected that the 57% target by 2027 will not be reached.  

Lake Macquarie City’s Greenhouse Gas Emission Reduction Targets Policy specifies a 3% per annum reduction in greenhouse gases from the City’s emissions (measured on a per capita basis).[6] However, Greenhouse gas emissions in the Lake Macquarie LGA have flatlined over the past two years, with only an approximate 0.2% per capita reduction in 2023/24. [7]

Total emissions actually increased slightly by 0.5% in 2023/24, with emission levels across most sectors remaining static.  Emissions from the housing sector were also static over this period with a 0.5% increase in 2023/24.  Approximately 11% of emissions in the Lake Macquarie LGA are attributed to the housing sector.  However, emissions from home vehicle use are not included in this estimate.  If you include vehicle emissions it dramatically changes the mix of emissions for households.  Looking at average Australian household emissions, vehicles have the largest proportion of household emissions at 38% followed by electricity at 32%.[8] Vehicle use (excluding freight and public transport) currently represents approximately 10% of emissions in Lake Macquarie LGA and emission levels remain static.

Housing planning is one of the most powerful tools we have to reduce greenhouse gas emissions at a local government level. By shaping the types of homes we build and their locations, we can create more sustainable neighbourhoods, boost the environmental performance of housing, and ensure our homes stay comfortable and resilient as the climate shifts.

Housing Design - Sustainability
The strategy recognises community support for environmentally conscious development:

“Residents want environmentally conscious development that preserves green spaces and promotes sustainable living.”[9]

We acknowledge the strategy’s inclusion of urban-planning sustainability measures such as:  

• Urban heat mitigation through tree canopy and green space:

“Higher‑density neighbourhoods are designed to reduce urban heat and improve comfort, resilience and liveability.”

• Avoiding development in high ecological value areas

“Urban expansion into high value ecological and environmental land is avoided.”

• Liveability improvements (public spaces, walkability, cooling, amenity). 

However, the strategy needs to seek to improve housing resilience and sustainability.  The strategy should be amended to include the objectives that Housing promotes resilience and meets high-sustainability performance targets.

Planning for Housing Resilience
Good design helps households make everyday choices that lower energy use and emissions. It supports things like buying efficient appliances, using smart tech, switching to EVs, choosing active transport, and reducing waste through better recycling and on‑site composting.

Under the priority to “Prioritise liveability in a changing city” the strategy should be amended to include sustainable and resilient design. It is essential that we build homes that use less energy and create neighbourhoods that can better handle the challenges of a changing climate.  In addition to the impact on the environment, improving resilience has implications for the quality of life for residents.

Increasing resilience of housing is a recent focus of both state and federal governments.  Changes in state and federal policies have contributed to improved efficiency within new homes, resulting in lower energy use and reduced energy bills for residents. Council should advocate for higher BASIX standards in new developments, such as for medium density housing. It’s a simple way to cut emissions, save water and strengthen our community’s resilience to climate change.

Accompanying these changes, the Council can drive new sustainable development through Development Control Plans (DCP) and help encourage more sustainable living by supporting things like energy efficiency standards and guidelines, rooftop solar and storage battery-ready design, EV‑ready infrastructure, sustainable design including reverse cycle air conditioning and heat pumps, cool building materials, green infrastructure and embedding passive design principles to keep neighbourhoods cooler. We can also promote the use of locally sourced sustainable building materials, the use and re-use of recycled materials, reduce embodied energy, and help encourage the use of new, more efficient construction methods and equipment. We can make space for canopy trees and landscaping, improve the quality and reduce the quantity of stormwater by incorporating water sensitive urban design, such as provision of permeable surfaces and use of rainwater for toilets, and support gas‑free, all‑electric homes. We can also provide support for efficient and active modes of transport, for example by providing space for bicycle storage and shared vehicles and the ability to charge electric vehicles [10]. Sustainable design doesn’t just improve environmental performance, it also lowers energy bills and creates healthier, more comfortable homes.

Importantly, the strategy needs to commit the Council to reviewing its DCP provisions to ensure these meet best practice.

Case Study: Support for gas‑free, all‑electric homes
This would be achieved by Lake Macquarie City amending its planning rules (DCP) to discourage gas connections and gas appliances in all new developments for health, and economic reasons.[11]

All‑electric buildings avoid unnecessary gas infrastructure, reduce indoor air pollution, and deliver lower running costs:

• New developments are gas‑free by default.
• Community health improves through reduced exposure to NO₂ and other pollutants.
• Households and businesses save money — the NSW Government estimates $2,771 per year in savings, or $4,000 with solar.
• The city’s growth aligns with its climate strategy and net‑zero trajectory.

For larger developments, using a competitive design process for big developments is a great way to lift the quality of urban design and ensure residents benefit from better amenity and sustainability.

Research makes it clear that we need stronger sustainability standards for urban development, and better policy tools to support sustainable housing at the neighbourhood scale. It also recommends shifting to performance‑based expectations, supported by clear objectives and targets, so we can measure what’s working and compare outcomes across different projects. [12]

Transit Oriented Development and Low and Mid‑Rise Housing Policy
Transport oriented development (TOD) is all about creating neighbourhoods where people can easily walk to public transport. When more homes and services are built around transport hubs, it becomes easier to choose the bus, train, walking or cycling over driving. That means fewer emissions and better transport options for everyone. Research also tells us that denser cities generally produce fewer housing‑related emissions, both in construction and day‑to‑day living. [13]

Residents need proximity to jobs and schools to reduce commuting costs. Developers seek these locations because proximity to transit often unlocks higher density zoning bonuses and lowers mandatory parking requirements, saving construction costs. Access to transport and services benefits both.

NSW Government planning reforms for Transport Oriented Development will increase the capacity for more mid-rise housing and mixed-use development within 400 metres of railway stations over the next 15 years delivering much needed housing around transport hubs.  This in turn will increase the viability of public transport to these locations and provide greater incentive for improved services.

Within the Lake Macquarie LGA, this includes the locations of Cardiff,  Booragul, Teralba and Morisset stations. Cockle-Creek was originally included but now states that it is an “Alternative scheme under assessment”.  [14]

What will the alternative scheme for Cockle-Creek entail (assuming that it is council led)?  The Hunter Regional Plan states that over the next 20 years, the area east of Cockle Creek is set to grow, with around 10,000 new residents, more than 4,000 new homes and space for about 6,000 new jobs. Planning for this growth will focus on getting the right mix of housing densities, supporting new types of employment, improving open spaces and local centres, and making sure the right state and local infrastructure is in place to support a thriving community. [15]

 
The NSW Government will establish inclusionary zoning around these TOD locations to deliver affordable housing close to jobs, recreation, amenities, and services.   We welcome these reforms as TODs will decrease the need for cars and increase patronage of public transport and active transport use which will lead to better health outcomes and reduced GHG emissions. 

However, a paltry mandatory minimum 2% affordable housing contribution will apply to all new developments equalling 2000 square metres total gross floor area in these areas.  This is in no way sufficient in addressing the housing crisis affecting low-income residents in our community.  Furthermore, it is unclear how this applies to in-fill developments within these areas where the 2% affordable housing contribution also applies.

The Strategy says that mandatory affordable housing contributions in TOD areas make projects less feasible.  Contributions don’t really make a project unworkable; they mainly reduce how much a developer can pay for the land. Developers usually start with what they think the finished homes will sell for, then subtract all their costs and profit. What’s left is what they think the land is worth.  Feasibility only becomes an issue if the land price ends up higher than what developers think it’s worth.
All land to be developed for housing at the Transport Hubs must prioritise the delivery of a public benefit, not the delivery of profit. 

Beyond the TOD areas, the Low and Mid‑Rise Housing Policy also kicks in within 800 metres of major town centres and transport hubs in Lake Macquarie — including Morisset, Belmont, Jewells, Boolaroo, Cardiff and Charlestown. We’re not sure why Toronto missed out, because it seems to meet the same criteria.

This change will support more housing diversity and help meet the strong demand for medium‑density homes. The benefits are similar to TODs: more homes close to shops, services and transport, and more walkable, sustainable neighbourhoods.

The strategy mentions that this policy will boost affordable housing through mandatory contributions. It would be useful to confirm whether this refers to the 10–15% affordable housing allocation required for in‑fill developments in these designated areas.

Affordable housing
The Lake Macquarie LGA does have more social housing than the NSW average, but much of it is ageing stock from the 1960s and 70s. These older cottages no longer suit the number of people needing housing or the different needs of low‑income households. [16]

The strategy recognises the need for more affordable housing and includes:

• A priority to “Facilitate affordable housing” (Priority 3).
• Support for redevelopment of existing social housing stock:

“There is an opportunity to improve affordability outcomes by renewing and redeveloping about 3,100 social housing dwellings owned by Homes NSW.”

• Acknowledgement of low social housing supply (4.2% of stock) and long wait times.
• Recognition that mandatory affordable housing contributions apply only in State‑led TOD areas (2% of floor area).

However: the strategy has no strong social or affordable housing requirements.  For example the strategy does not propose any new local affordable housing contribution scheme or inclusionary zoning.  Other best practices in this area include council‑led delivery or partnerships and land‑use incentives tied to affordable housing outcomes.

The Council can play a direct role by identifying any suitable Council‑owned infill sites that could be used for new social and affordable housing, and then move quickly to tender these sites for development by a community housing provider. This would help deliver the affordable rental homes that low‑income households urgently need. 

It is noted that the strategy supports smaller, diverse housing types:

“Smaller dwellings typically have lower construction and purchase costs… an important component of improving housing affordability.”

However, this is a supply‑side affordability measure, not a social housing policy.

We welcome residential development where it delivers affordable and secure housing to the community. 
 
However, strategic planning must consider the actual or most likely amount and mix of affordable and social housing to be in a planning precinct.  For example, Housing Minister Rose Jackson committed to the delivery of 30% affordable and social housing on state-government owned land as part of the rezoning at Hunter Park.  Any government‑owned land that’s developed should deliver a minimum of 30% social and affordable housing, guaranteed permanently.

Furthermore, the Strategy makes no mention of requirements for affordable housing or any target for Affordable Housing. The City of Newcastle Housing Policy includes an overall affordable housing target of 15% to work towards, across the city that is monitored using benchmarks for affordable housing, housing diversity and homelessness. The City of Sydney has a target 7.5% of housing will be affordable rental housing and 7.5% will be social housing. [17]  Council should set ambitious but realistic timeframes for delivering its affordable housing targets, and make sure progress is regularly monitored and publicly reported.

In fact, with respect to housing affordability the strategy explicitly states:

“Local government is not equipped to take on that responsibility.”

This is a policy position, but it leaves Lake Macquarie behind best‑practice councils that do use planning powers to secure affordable housing.
​
To be effective, the Strategy needs a much clearer roadmap for how everything will be delivered. This includes outlining specific actions, who will lead them, who the partners are, when things will happen and how progress will be measured and reported. In particular, the performance measures are very broad, which makes it difficult to understand how success will be tracked over time.
Thank you for considering our submission,
Sincerely,

Alec Roberts
CLEANaS Chair on behalf of CLEANaS
​

​Download Content

​1. Problem (World‑as‑it‑is)

Lake Macquarie’s greenhouse gas emissions are not falling fast enough to meet the city’s own targets. Despite some progress, emissions have flatlined, with only a 0.2% per‑capita reduction in 2023/24, far short of the required 3% per year. The document notes that “total emissions actually increased slightly by 0.5% in 2023/24” and that the city is unlikely to reach its 2027 target of a 57% per‑capita reduction.
Gas use is a key contributor:

• Residential and commercial gas emissions have remained static, even though industrial gas use has declined.
• Methane is a powerful, fast‑acting greenhouse gas — “responsible for roughly 30% of global warming” and “breaks down in the atmosphere in about a decade,” meaning reductions have immediate climate benefits.

New development is locking in decades of future gas demand, worsening emissions, household costs, and indoor air pollution.


2. Platform (World‑as‑it‑should‑be)

A Lake Macquarie where all new homes and businesses are built all‑electric, protecting health, lowering bills, and aligning with climate commitments.
The document frames this ideal future clearly:

• “The easiest emissions to deal with are the ones we never create.”
• Councils can “drive new sustainable development through model Development Control Plans.”
• All‑electric buildings avoid unnecessary gas infrastructure, reduce indoor air pollution, and deliver lower running costs.

In this preferred future:

• New developments are gas‑free by default.
• Community health improves through reduced exposure to NO₂ and other pollutants.
• Households and businesses save money — the NSW Government estimates $2,771 per year in savings, or $4,000 with solar.
• The city’s growth aligns with its climate strategy and net‑zero trajectory.

3. Solution (What must be done)

The document proposes a clear, actionable solution:
Update Lake Macquarie’s Development Control Plan (DCP)Council should amend its DCP to discourage or prevent gas connections in all new developments on health and economic grounds.
The document states:

• “NSW councils can require all‑electric, gas‑free new buildings via their planning schemes without waiting for state government approval.”
• “DCPs… act as a discouragement on gas connections and appliances in new builds.”
• Other councils — Newcastle, Lane Cove, Parramatta, Inner West, City of Sydney — have already done this.

The recommended action is explicit:
“Lake Macquarie City should amend its planning rules to discourage gas connections and gas appliances in all new developments for health, and economic reasons.”
This is framed as a low‑cost, high‑impact climate action that Council can take immediately.

​Lake Macquarie has a real opportunity right now to protect community health, cut energy bills, and prevent avoidable emissions — simply by ensuring new homes and businesses are built all‑electric from the start. The evidence is overwhelming: gas is a major driver of climate pollution, it worsens indoor air quality, and it’s more expensive than efficient electric alternatives. As the document below notes, “the best way to reduce community emissions is to avoid creating them in the first place” and banning gas in new developments is one of the simplest, lowest‑cost ways to do exactly that.
Lake Macquarie City Council can act immediately by updating its Development Control Plan to discourage new gas connections on health and economic grounds — just as other NSW councils have already done. This doesn’t require state approval. It only requires leadership.

Now is the moment for Lake Mac to step up.
Let’s call on councillors to:

• Support amendments to the DCP that require all‑electric new developments
• Prioritise community health by reducing exposure to indoor air pollutants from gas
• Lower household and business energy costs by avoiding unnecessary gas infrastructure
• Ensure the city’s growth aligns with its climate commitments and community expectations

Tell Lake Macquarie City Council: it’s time to go gas‑free for all new homes and businesses.
Every new development built today will shape our city for decades. Let’s make sure those decades are cleaner, healthier and more affordable for everyone.

Presentation by Alec Roberts for Greater Charlestown Sustainable Neighbourhood Group
​Saturday 31 May 2025.

Please note that the NSW Household energy saving upgrades – Battery Discount (a.k.a. NSW Solar Battery Rebate) (Slide 25 and 26) has been cancelled.  This is also known as PDRS (Peak Demand Reduction Scheme) .  The "Sign your battery up to a Virtual Power Plant" component is still available.
In particular, please note that payback periods including PDRS in the presentation (Slide 30) are no longer applicable.

28/02/2025
 
Transport for NSW
231 Elizabeth Street
Sydney NSW 2000
 
 
Draft Hunter Strategic Regional Integrated Transport Plan Submission
 
To whom it may concern
 
Thank you for the opportunity to provide input to the Draft Hunter Strategic Regional
Integrated Transport Plan (Draft Plan) and taking the time to consider our submission.
 
The Clean Energy Association of Newcastle and Surrounds (CLEANaS) supports the overall draft plan. However, we wish to raise concerns and provide feedback on the draft plan.
 
CLEANaS is the Clean Energy Association of Newcastle and Surrounds, a not-for-profit association formed in 2012 by a group of locals passionate about clean energy.[1] CLEANaS is dedicated to driving the uptake of clean energy so that our region can transition from its current dependency on fossil fuels to a more competitive and sustainable local economy. We achieve this by working with our partners to demonstrate profitable community-led and community-owned clean energy projects; raise the profile of clean energy in the local economy through education and awareness raising; and by improving access to financing mechanisms and affordable technologies so that investment and activity grow. Our initiatives must deliver a win-win for local community investors, local enterprise and, of course, our environment.
 
Transport Emissions in the Hunter 
Utilising Snapshot[2], the estimated emissions for the Transport sector in the Hunter Region for 2022/2023 were 2.8 Mt CO2-e representing 15.2% of the Hunter Region’s GHG emissions. Between 2018/2019 and 2022/2023 transport emissions have decreased by only 6.1% (0.18 Mt CO2-e).

The transport sector is currently the region’s second largest source of CO2 emissions, after the stationary energy sector.  In 2021/2022, 97% of these emissions were from road transport[3]. 

Insufficient emphasis has been placed on reducing emissions in the transport sector for the Hunter Region in the Draft Plan.  There are many supporting studies and policy documents that detail the problem and policies, targets, plans and actions on how to address this thorny issue.  Below is a synopsis of these that should be reviewed for incorporation into the plan where possible to address this shortfall.

Please note that the majority of this material was derived from the Newcastle Emission Reduction Plan developed in 2023 and presented at the Newcastle Climate Action Summit held in November 2023[4].

NSW Policies and Plans
The Future Transport 2056 Strategy[5], first released in 2018 and updated in 2022, sets the strategic directions for Transport for NSW and provides an integrated vision for passenger and freight transport in NSW[6].  The strategy affirms the Transport for NSW commitment to the NSW Government emissions targets of 50% emissions reduction by 2030 with a plan to achieve net zero emissions from their operations and fleet by 2035.  Towards achieving this target, a number of initiatives have been undertaken or are planned. Sydney Metro, Sydney Trains and urban NSW TrainLink services are already powered by100% renewable energy as of July 2021[7]. Transport for NSW has committed to transitioning its bus fleet of approximately 8000 to Zero Emission Buses to be powered by renewable energy, with Greater Sydney buses fully transitioned by 2035.  However, over half of the bus fleet residing in outer metropolitan (including Newcastle) and regional regions will not be transitioned until 2040 and 2047 respectively[8] [9]. Note that this initiative should be brought forward, as implementation in 15 and 22 years probably exceeds the lifespan of the current bus fleet in the Hunter region, and replacing end of life diesel buses with diesel buses does not make sense in the current climate crisis.  Furthermore, the purchase of new diesel buses as part of any expansion of public transport also does not make sense.

Other planned actions include: prioritising electric ferries in new ferry procurement and refit of the existing fleet, and assessing the feasibility of trialling a hydrogen train on the NSW train network.
However, Transport for NSW is responsible for around 3% of transport emissions in NSW.  Without a significant shift to use of public transport, the impact of these changes to reduce emissions will be minimal on the overall transport emissions for NSW. 

Mode shifts from road and air to rail
The Office of the Chief Scientist and Engineer stated that movement of passengers and freight transportation to more efficient modes can decrease congestion, costs and emissions[10].  They noted that “as passenger and freight tasks increase due to population growth, a mode shift from road to rail can improve transport network productivity through alleviated congestion and provide further benefits such as cost and time savings, reduced carbon emissions and improved air quality”. For example, for every passenger travelling by rail, instead of by car, saves an additional 50g of CO2-e/km being emitted[11]. Rail freight itself produces 16 times less carbon emissions than road freight per tonne kilometre travelled.

Freight emissions, policies and plans
It should be noted that about 31% of NSW transport emissions come from trucks, aviation and shipping. Transport for NSW stated that “persistent growth in emissions is projected from heavy vehicles and little improvement is forecast in emissions from rail freight, aviation and shipping.“

Last mile freight refers to the final delivery to the consumer or store.  NSW Transport intends to pilot freight programs to reduce congestion and emissions, including new options for last-mile freight deliveries, including use of small electric vehicles for last-mile urban deliveries and freight consolidation centre models[12] [13] [14].  Light commercial vehicles and smaller last mile delivery vehicles are the perfect target for electrification, due to their high utilisation rates, kms travelled, and frequent stops[15].  The use of cargo bikes and e-cargo bikes for last mile delivery offers another alternative for low/zero emission transport.  In London this has been shown to offer a much cleaner way to deliver freight and services and deliver considerable air pollution savings, contributing to healthier and safer streets and enabling better use of urban space[16]

Shipping FreightInternational shipping freight to and from NSW accounts for 30% of transport freight emissions of approximately 1.4 Mt CO2-e (Centre for Transport Energy and Environment, New South Wales Transport, 2015)[17] [18]. In 2020-21 Newcastle port exported 157.8 million tonnes of product (mostly coal) and imported 4.4 million tonnes of product.  Collectively, this represents approximately 85% of NSW’s International Shipping Freight w/w (NSW Total approximately 191 million tonnes)[19].  Therefore the annual transport freight emissions from international shipping at Newcastle Port would be approximately 1.2 Mt CO2-e.

Active Transport Strategy
Walking and bike riding are the most sustainable modes of transport. The NSW Transport Active Transport Strategy[20] [21] draws on the Future Transport Strategy and its vision for walking, bike riding and personal mobility.  The Active Transport Strategy has the long term aim of doubling active transport trips in 20 years and supports the NSW Government’s commitment towards net zero by the promotion of sustainable travel behaviour.

The ambitions raised in the Active Transport Strategy include:
Enable 15-minute neighbourhoods
Increase the percentage of short trips made on foot and decrease those made by car by enabling walkable and connected 15-minute neighbourhoods across all six NSW cities and in regional centres across NSW.  This is based on Carlos Moreno’s 15-minute concept to reduce urban carbon emissions, reimagining towns not as divided into discrete zones for living, working, and entertainment, but as “mosaics of neighbourhoods in which almost all residents’ needs can be met within 15 minutes of their homes on foot, by bike, or on public transit” [22].
Deliver connected and continuous cycling networks
Through the Strategic Cycleway Corridors program, it will deliver over 100km of safe, connected, and continuous cycling networks linked to local cycle networks by 2028 across the six NSW cities.  Planning has commenced for 3 Sydney based networks, with  similar exercises planned for Lower Hunter and Greater Newcastle, Central Coast and Illawarra-Shoalhaven cities[23]. These networks will also allow sustainable freight via active transport.
Provide safer and better precincts and main streets
Improved roads, streets and precincts will encourage walking and bike riding by people of all ages and abilities.  It is hoped that redesigned streets will contribute to halving fatalities and reducing serious injuries by 30% for pedestrians and cyclists[24].
Promote walking and riding and encourage behaviour change
Only 14.5% of students currently travel to school by active transport.  The Active Transport strategy seeks to double the number of children walking or riding to school across all six cities  facilitating children’s and young people’s independent mobility by improving safe walking and bike riding options for travel to and from school, with a trial of the Active Travel to School program with 50 schools by 2028.
NSW Transport will trial behaviour change interventions such as Green Travel Plans which “explore practical ways to implement sustainable commuting solutions into workplaces by using behavioural insights, workplace initiatives, incentives and interventions.”

Hunter Region Policies and PlansHunter Regional Plan 2041
The Hunter Regional Plan 2041[25] is a 20-year land use plan focusing on the next 5 years for the Hunter Region[26] which supports net zero emissions as a guiding principle for all planning decisions with a shift to a net zero economy. One of the plan’s objectives is to “reach net zero and increase resilience and sustainable infrastructure”. To achieve this objective a number of strategies are identified to be implemented through local strategic planning.  These include:

• identify opportunities to increase active transport choices
• establish minimum electric vehicle parking requirements in new development
• consider opportunities to deliver micro-mobility transport infrastructure in areas of the region where topography, distance or climate makes walking and cycling challenging.
• support the rollout of electric vehicle charging infrastructure by identifying potential sites for charging stations, including council-owned land, and how these locations can be activated as places.

The Hunter Regional Plan 2041, as part of its objective of inter-connected and globally-focused Hunter without car dependent communities, supports the concept of the 15-minute neighbourhoods.  This aims to reduce car dependency and reduce GHG emissions for new communities and in retrofitting existing residential areas.  The plan proposes a number of Active Transport strategies supporting 15-minute neighbourhoods to be implemented through local strategic planning which include:

• connect existing coastal walkways and cycleways to enhance the user experience and link coastal towns and villages
• integrate walking and cycling networks into the design of new communities
• prioritise walking and cycling in areas around schools, health services, aged care facilities, sporting, cultural and recreational facilities
• spatially identify key activity destinations and key transit corridors and consider strategies to integrate land use and transport planning
• aligning active transport strategies (within and across LGA boundaries) with future growth areas and local infrastructure contribution plans to ensure development supports movement through walking and cycling
• councils to consider minimum bicycle parking standards to reflect the aspirations of 15-minute neighbourhoods

Other Transport strategies supporting 15-minute neighbourhoods include:

• consider transport initiatives to complement increased diversity of land uses and housing typologies in neighbourhoods
• consider maximum parking limits in neighbourhoods and centres well served by walking, cycling and public transport and consider opportunities for park and ride, carpooling, car sharing and other initiatives that can help to reduce car dependency.

The Hunter Regional Plan 2041 also supports the 30-minute strategic centres concept. The plan notes that “key corridors between strategic centres should be the focus of high frequency public transport services such as light rail or bus rapid transit.”

Transport strategies detailed in the plan to be implemented through local strategic planning supporting this concept include:

• spatially identify key activity destinations and key transit corridors and consider strategies to integrate land use and transport planning in collaboration with Transport for NSW
• places maximise sustainable transport opportunities, including active and public transport that supports compact urban area
• ease of use and connection across the network, including mobility, accessibility, parking and how people get to and from transport
• inclusive and accessible systems for people of all ages and abilities.

Supporting the NSW Government’s Six Cities vision the 90-minute region concept will connect the Hunter to the other cities, with fast rail essential to this vision. Supporting this, the plan included the strategy that:

• Local strategic planning will ensure land is protected to enable the long-term fast rail vision by preventing incompatible development occurring near alignments once corridors are identified.

Figure 6 details potential improvements to the Central Coast and Newcastle rail line which would result in a faster rail corridor.

NSW Fast Rail Strategy will form the blueprint for the future fast rail network including the fast rail corridor from Newcastle to Sydney.

Hunter Joint Organisation Strategic Plan 2032
The Hunter Joint Organisation (JO) is a collaborative body that brings together the ten Councils in the Hunter region (including City of Newcastle) to “provide a united and local voice for our communities”.  The Hunter JO acts as a hub for local intergovernmental collaboration with statutory mandates to identify and advocate for key regional strategic priorities and to build collaborations around these priorities with other levels of government, industry and community[27].

The Hunter Joint Organisation Strategic Plan 2032 is the Hunter JO’s Statement of Strategic Regional Priorities  sets out a vision for the region and provides an overview of the strategic actions required to deliver that vision.  To identify the highest regional priorities the plan draws from the Community Strategic Plans of Member Councils, regional-level plans and other state strategic documents.

In preparing the Strategic Plan, Hunter JO identified priorities and potential areas for collaboration.  These included:

• Sustainability – net zero targets
• Light rail expansion
• Richmond Vale rail trail / cycleways

Key regional priorities identified included:

• Cycling Networks
• Transport Infrastructure and Connectivity
• Light Rail Expansion
• Public transport links to the airport and key services (health, education, jobs, recreation and strategic centres)
• Sustainability – Net zero targets
• Climate Change Action

One area of collaboration identified was EV Charging, with collaboration on

• Regional approach to EV infrastructure
• Regional coordination to placement of charging stations and links to tourism
• Enabling infrastructure

The Strategic Plan identified a number of regional challenges and opportunities in Transport in the Hunter.  It found there are poor connections to and from major employment, transport hubs and international gateways for both freight and people and noted that planning for road network improvements, EV, park and ride, heavy rail, light rail, bus, cycleways, and pedestrian infrastructure is fundamental for this growing region.

The Hunter Region’s long-term priorities and aspirations together with the strategies that detail how to get there were elucidated in the Strategic Plan. Ones related to Transport and emission reduction include:

• Robust integrated transport solution - Identify and facilitate regional approaches for active transport outcomes that deliver connectivity, health, liveability and economic benefits; and Private and public transport solutions operate on a net zero basis.
• Region built around sustainable transport outcomes - Embed the direction of net-zero in all our connectivity strategies to provide a pathway and level of confidence to investors and community to support the transition to more sustainable transport outcomes.
• Supporting our region to be on the path to net zero emissions and paving the way with smart innovative solutions that increase liveability - Provide support and identify opportunities on regional collaboration around Electric Vehicles and Support regional collaboration around clean energy and future energy initiatives and industries
• Council capacity building and policy support for climate change action, resilience and disaster preparedness - Provide guidance and support packages to embed Climate Change action, resilience and disaster preparedness into Councils Integrated Planning and Reporting (IP&R) framework.
• Drive regional best practice in climate action - lead the way in regional best practice and work with all levels of government to drive policy and strategy on climate change; and Engage and provide thought leadership in local, national and global climate change and resilience networks.

Draft Hunter Regional Transport Plan 2041.The car is the dominant form of transport within the Hunter accounting for around 91% of commuter trips, of which 90% are within the Hunter resulting in congestion on the road network during peak periods[28].  Furthermore, past developments of car-dependent urban growth has resulted in dispersed settlement patterns that are hard to service with public transport and where active transport is impractical. The plan notes that the effective integration of transport planning and land use can result in revitalised growth areas and centres and increased public and active transport within the region, with a shifting of behaviour from private car use (which is ultimately unsustainable) contributing to increased sustainable travel.
The Hunter Regional Plan 2041 supports the principle of 15-minute neighbourhoods which encourages more sustainable and efficient forms of transport, where most of residents’ daily needs can be reached within 15 minutes by public transport, walking or cycling rather than taking the car.
To support and improve local connectivity within regional centres, the plan seeks to improve public transport journey times, frequencies, and service catchments to make public transport a more viable option within the Hunter. and seeks to expand the active transport network within regional centres (encouraging walking and cycling for short trips), including integration of first and last mile active travel connections.  For example,  NSW Transport is working with Newcastle and Lake Macquarie councils to develop a connected cycleway network.

To help achieve such aims, two pivotal NSW Government road use policies prioritise active and public transport over cars.  The Providing for Walking and Cycling in Transport Projects Policy requires that every transport project funded by Transport for NSW include provision for walking and cycling, and the Road User Space Allocation Policy requires all roads (except motorways) in the allocation of road user space to consider all road users in order of: walking, cycling, public transport ahead of cars[29] [30].

Towards the target of a net-zero transport system by 2050, to help improve sustainability across the Hunter, the plan presents the following objectives:
Increase the number of trips made by walking, cycling and public transport across the Hunter
NSW Transport are working with local Hunter councils to close gaps in active transport networks, with funding from the Walking and Cycling Program[31].  They will also support new and existing neighbourhoods with improved walking and cycling networks.
NSW Transport intends to support efficient and sustainable transport methods for the whole journey such as Mobility as a Service, On-Demand shared services, and micro-mobility options such as electric bikes, scooters and shared e-bike solutions.  Micro-mobility offers potential alternatives for first and last mile travel between homes and key destinations such as public transport hubs and in areas where topography, distance or climate makes walking and cycling challenging. 
Transition to lower emission technologies to improve health and amenity

To enable the transition to lower emission technologies, NSW Transport will incorporate EV fast chargers into transport projects and assets, work with local councils in the Hunter to transition their fleets to lower emissions technologies, and support innovation that supports transition to lower emission technologies in the Hunter.
 
Greater Newcastle Policies and PlansGreater Newcastle Metropolitan Plan 2036
The Greater Newcastle Metropolitan Plan 2036[32] aligns with the Hunter Regional Plan and details strategies and actions to drive sustainable growth across Greater Newcastle city, providing a guide for local planning across the 5 Greater Newcastle councils. A key outcome of this plan is to “Improve connections to jobs, services and recreation”.
 
Greater Newcastle consists of dispersed strategic centres, some of which are specialised / destination centres for work services and recreation, with options for different transport modes (cars, trains, buses, cycling, walking) available in most centres. This presents an opportunity to integrate land use policies with transport planning to enable a transport system that favours walking, cycling and public transport. To help enable this strategy Transport for NSW plans to work with Greater Newcastle councils to:
 

• improve public transport services between Newcastle City Centre, Broadmeadow, John Hunter Hospital, Callaghan, Cardiff, Charlestown and Kotara
• provide early and effective public transport services and active transport infrastructure in priority housing release areas that is well-connected to key destinations and public open space
• identify improvements to active transport networks, and provide unobstructed well-connected pedestrian paths and a network of off-road separated cycleways to key destinations, including schools, employment hubs, shops and services.

Greater Newcastle Future Transport Plan
The Greater Newcastle Future Transport Plan[33] supports the implementation of the Future Transport Strategy 2056 within the Greater Newcastle area and provides the overarching strategic transport vision and network that will guide future transport planning for Greater Newcastle.
Key objectives identified in the Greater Newcastle Future Transport Plan include the proposed faster rail connections between Sydney and Newcastle, the development of an integrated public transport network hierarchy, investigating extensions to the light rail, and further development of active transport networks.
To help enable these objectives the plan identified a number of initiatives “intended to be investigated for potential commitment or implementation within the next 20 years”. No initiatives supporting these objectives were committed (i.e. have committed funding, in planning or in delivery). These initiatives “for investigation” include:
The Sydney-Central Coast-Newcastle Faster Rail improvement initiative is a program of fleet and targeted fixed infrastructure improvements (for example, new deviations to eliminate curvatures and flatten grades) which could include a new rail crossing of the Hawkesbury River.
The Bus Head-start initiative involves the early introduction of bus services on road networks that are designed for buses to serve housing release areas and connect them to key destinations in Greater Newcastle[34].
A place strategy or plan is a strategic plan for a precinct which establishes a vision for how a precinct will look in the future, and provides a high level plan with actions which detail how that vision will be achieved[35]. It seeks to identify the ideal outcome for an area that takes into consideration environmental constraints, infrastructure needs, economic or social requirements and local community values[36].
Greater Newcastle Place Plans initiative involves the planning and delivery of an integrated transport network to improve access to/from/within key precincts within Greater Newcastle by all modes, and includes the development of an active transport network including identification of bicycle parking and initiatives for behaviour change to support more sustainable travel options.

For example, the City of Newcastle is developing a Broadmeadow Place Strategy for the proposed Broadmeadow precinct with the following outcomes for Active and Public Transport identified in the Hunter Regional Plan 2041:

• Improve walking and cycling connections across Styx Creek, the rail line and Griffiths, Lambton and Turton roads.
• Improve public transport, including potential light rail connections.
• Create accessible spaces for all members of the community.
• Protect and secure land for transport upgrades, including potential light rail and fast rail.

Cycling improvements initiative involves the Investment in the Greater Newcastle Regional Bicycle Network (a connected cycleway network for Greater Newcastle) in collaboration with local councils.
Newcastle Ferry Network extension initiative involves the extension of ferry services between Stockton and Queens Wharf to Wickham which will facilitate interchange with heavy rail services.

Transport use and opportunities for change
This Greater Newcastle Future Transport Plan noted that the majority of people (84%) travel in Greater Newcastle by private vehicle (see Figure 7), with use of public transport very low compared to other cities.  They found that only 3% of people used public transport during the week.  This compares poorly to Greater Sydney where 12.8% use public transport on an average weekday (Note that this is down from pre-pandemic levels of 16%-23%)[37] [38] [39]. Public transport use dropped to only 1% on weekends.  Active Transport fared better with 12-14% of people walking or cycling.
 
​

The plan identified a number of opportunities where public and active transport could be used rather than by car:

• Commuting trips occur primarily in AM and PM peaks where public or active transport could be used.
• Over half of trips made were less than 5km.  These shorter journeys could be undertaken by walking or cycling.
• Most trips are for discretionary purposes such as shopping, social and recreation which are generally shorter and within the region.  Such trips could utilise more sustainable forms of travel.

The plan noted that the majority of trips (90-95%) by Greater Newcastle residents were within the Greater Newcastle area with strong travel demand (>1000 trips per day) between:

• Broadmeadow and Newcastle city centre
• Charlestown and Newcastle city centre
• Kotara and Charlestown/Broadmeadow
• Newcastle port and Newcastle city centre (TfNSW, 2018c).

Improvements in public transport and active transport infrastructure between these centres could lead to significant reductions in emissions where public transport and active transport form viable alternatives to car use.

The Greater Newcastle Future Transport Plan set a modest target of 25% of total trips to be made by public and active transport by 2056 (only 8% increase over 28 years).

Newcastle Climate Action Plan
The themes and objectives of the Newcastle Climate Action Plan[40] include the Zero Emissions Transport theme supported by the objective “Supporting the transition to clean, efficient, emissions-free transport” across the City of Newcastle.  Transport emission related actions supporting this objective are:

• Support cycling through provision of adequate cycle lanes, bike parking and end-of-ride facilities.
• Provide publicly accessible electric vehicle charging infrastructure at key locations throughout the city, powered by onsite renewables where possible.
• Procure electric vehicles for all passenger fleet replacements where options are available and identify opportunities to accelerate removal of fossil-fuel based vehicles from operations.
• Transition all Council light trucks to electric options where available and monitor and trial improvements.
• Transition all Council heavy trucks including waste collection vehicles to electric options where available and monitor and trial improvements in technology.
• Encourage sustainable transport options for all staff travel and offset emissions where options are not available.

The theme associated with Community Emission Reduction in the Climate Action Plan is not surprisingly “Towards a Net Zero Emissions City”, with the supportive objective of “To create a resilient city that reduces its share of emissions to ensure a cleaner and more sustainable future”. Transport emission related actions in the Climate action plan supporting this objective are included under “Supporting an Electric Transport Future” and include:

• Work with the NSW State Government, electricity network operator (Ausgrid), technology providers, neighbouring Councils and electricity retailers to provide suitable charging solutions for electric vehicle owners (both off street and on street parking).
• Work with the NSW State Government, councils and other stakeholders to encourage and incentivise the uptake of electric vehicles and zero-emission transport.
• Actively work with Newcastle Transport, Fleet and Freight operators to reduce transport emissions (including advocating for electric buses, ferries, taxis and delivery trucks in the City).

As the first Australasian port to join the International EcoPorts network, the Port of Newcastle has committed to integrating sustainable practices, including its transition to a fully electric vehicle fleet [41].

Although not mentioned under emission reduction, under the theme Liveable Newcastle, and the priority of “Safe, active and linked movement across the city”, the following Council objectives could reduce transport emissions within the city:

• Connected cycleways and pedestrian networks - Provide safe and connected networks, making active movement a convenient, accessible way of getting around.
• Effective public transport - Support the implementation of regional transport strategies and plans and public transport network improvements to allow easy movement across the city.

Active Transport and Newcastle
With approximately 78% of weekday trips in Newcastle by private car, with an average trip of less than 8 km [42], and as the vast majority of trips made by bicycle are under 10km [43] , there is a great opportunity for cycling to replace private cars for average trips within the Newcastle LGA.

Institute for Sensible Transport conducted a study[44] to identify hotspots for both high latent demand for cycling and high concentrations of short car trips in four NSW cities using census data.  The study report emphasised the importance of this, as a new cycling trip that replaces a trip formally done by car is more ‘valuable’ from a benefits perspective, in terms of its positive impact on congestion, emissions, physical activity and transport affordability than a trip coming from another mode .
 
The study found that Newcastle was a standout city, with a strong correlation between areas of car dependency for short trips and a propensity for bicycle use compared to the other NSW cities studied. In particular there was strong clustering around the inner Newcastle area as shown in Figure 13. The study report noted that such identified areas are ideal for investment in bicycle infrastructure as they are likely to see higher modes shift away from cars to more energy efficient transport modes compared to other areas.
 

In  2020 the City of Newcastle conducted a survey[45] to understand the cycling experience in Newcastle LGA. Separating respondents into cohorts of frequent cyclists and infrequent cyclists they found that the top factors that would encourage cyclists to ride more included:

• More physically separated on-road lanes (77% frequent, 59% infrequent riders)
• More off-road paths (75% frequent, 68% infrequent riders)
• More considerate, courteous behaviour by drivers (48% frequent, 30% infrequent riders)

Infrequent cyclists noted the top reasons they do not ride/ride on a regular basis was that they don’t feel safe riding (30%) and there is no safe route to where they want to go (24%).

They also found the majority of cycling collisions reported by respondents over 2 years were with motor vehicles (56% frequent, 72% infrequent riders).

The survey also looked at cyclists’ perception of cycling in Newcastle LGA. They found that only a minority of respondents thought that the Newcastle LGA is a cycle-friendly area (26% frequent, 20.5% infrequent riders). Very few respondents thought that there was insufficient bike parking in the public domain (18% frequent, 14.5% infrequent riders). Furthermore, the majority respondents thought that Cycle routes were not well connected (72% frequent, 65% infrequent riders) and Vehicle Drivers were not courteous towards cyclists (65% frequent, 57% infrequent riders).

Newcastle Cycling Plan
The Newcastle cycling plan, titled On our bikes: A plan for safe and connected cycling in the Newcastle LGA [46], has a goal that
 “By 2030, City of Newcastle will have a safe, connected cycling network of principal routes and low stress streets. Riding and walking will be the natural choices for short trips, for all members of our community.“

The Cycling Plan noted that not enough progress has been made translating strategic goals for more active and sustainable transport use into action on the ground such as articulated in the Cycling Plan’s predecessor, Newcastle Cycling Strategy and Action Plan 2012[47].

Although very little mention is made in the Cycling Plan to cycling’s role in emission reduction, some objectives in the plan align with the Climate Plan objective to Support the transition to clean, efficient, emissions-free transport across the City of Newcastle.

The Cycling Plan is structured around four key themes and their objectives:

• Improve safety and comfort - Design and implement new cycle routes that are separated from motorised traffic or achieve a low speed, low traffic volume environment, and where possible, allow dedicated space for both cyclists and pedestrians.
• Connect and improve the network - Establish a bike network that provides safe, convenient connections between our centres, key attractors and homes.
• Support people to ride - Understand and address the challenges and enablers of more riding in Newcastle, in particular by the network of safe routes will be supported by clear wayfinding and convenient parking and facilities.
• Facilitate active transport in centres - Prioritise space for walking and riding in our City Centre, local and neighbourhood centres so as to encourage mode shift to walking and cycling for short trips. (CoN, 2021c).

The Cycling Plan set targets that by 2030 Newcastle will:

• Increase the proportion of residents who ride a bike in a typical week from 16% to 30%
• Double the mode share for journeys to work to 4% (1.6% in 2021 (ABS, 2021)[48].

 
Transport Oriented DevelopmentNSW Government planning reforms for Transport Oriented Development (TOD) will increase the capacity for more mid-rise housing and mixed-use development within 400 metres of stations over the next 15 years delivering much needed housing around transport hubs.

This includes the locations of Newcastle Interchange, Hamilton, Kotara, Cardiff, Cockle-Creek, Booragul, Teralba and Morisset stations[49]. 

The NSW Government will establish inclusionary zoning around these locations to deliver affordable housing close to jobs, recreation, amenities, and services. 

We welcome these reforms as TODs will decrease the need for cars and increase patronage of public transport and active transport use which will lead to better health outcomes and reduced GHG emissions.  The option to pursue TOD along the Hunter Line is also appreciated.

However, the NSW Government stated that a paltry mandatory minimum 2% affordable housing contribution will apply for all new developments in these areas.  This is in no way sufficient in addressing the housing crisis affecting low-income residents in our community.

Residents of affordable housing are also more likely to utilise public and active transport.

The City of Newcastle Local Strategic Planning Statement includes a goal of providing at least 30% affordable housing within all new Catalyst Areas. This applies to the Broadmeadow precinct. Furthermore, the City of Newcastle Housing Policy includes an overall affordable housing target of 15% to work towards, across the city that is monitored using benchmarks for affordable housing, housing diversity and homelessness.

Given a target of affordable and social housing of 30%, such as within the City of Newcastle, the mix may be 15% affordable or 15% social housing or it may be 5% to 25%. These different housing mix scenarios will require different strategic planning considerations including requirements for social infrastructure for each location.  These different housing mix scenarios will require different strategic planning considerations including requirements for social infrastructure for each location.  All land to be developed for housing at the Transport Hubs must prioritise the delivery of a public benefit, not the delivery of profit.
 
Utilise Maitland to Cessnock Rail LineThrough the Draft Plan mention is made of the expected large increase in population and the lack of effective public transport along the corridor that the disused Maitland to Cessnock rail line.

Port Melbourne and St Kilda railway lines were converted to light rail in 1987. The resulting tram lines are highly used by residents, workers and tourists, linking Melbourne with the St Kilda restaurant and tourist precinct and with Port Melbourne businesses.  Furthermore, the replacement of the lines allowed for the development of parallel shared pathways for cyclists and pedestrians which are also very popular.

The development of light rail along the former Maitland to Cessnock Rail Line would help address the burgeoning problem of a rapidly increasing population and sub-optimal public transport facilities in this area and could be a drawcard for tourists to this area.  It would also be prudent to develop a parallel shared pathway for cyclists and pedestrians to help promote the use of active transport in this area.
 
Richmond Vale Rail TrailRichmond Vale Rail Trail (RVRT) is a planned multi-purpose, shared pathway, 40km long (with all connections), typically comprising a 3m wide sealed pavement. The Newcastle LGA section will run from Shortland to Tarro and from Hexham to Lenaghan (Pambalong Nature Reserve), with Fletcher and Minmi connections. The Lake Macquarie and Cessnock LGA section will run from Stockrington to Kurri Kurri.  The historic RVRT will form the backbone to the proposed 100+km Shiraz to Shore cycle trail (S2S).  However, there is no mention of the RVRT in the draft plan.

Whereas the Draft Plan mentions the potential for tourism growth and sustainability for the S2S, the benefits to the region of economic growth and development, active transport benefits, connectivity of precincts, and recreational possibilities are missing.

The S2S (latest iteration) does not include the RVRT link from Minmi to Shortland (via Hexham and Tarro).  This key link provides an essential connection between communities, a much safer off-road link for cyclists than the New England Highway and Hexham Straight, and enables access to the world renown Hunter Wetlands National Park.
​
The RVRT, together with its benefits should be included in the draft plan in association with the S2S.
 
Thank you for considering our submission,
Sincerely,
 
Alec Roberts
CLEANaS Chair on behalf of CLEANaS
 
REFERENCES

[1] http://www.cleanas.org.au/

[2] 2022 Snapshot emissions profile – Ironbark Sustainability and Beyond Zero Emissions.

[3] Ironbark Sustainability and Beyond Zero Emissions. (2025). 2023 Snapshot emissions profile – Ironbark Sustainability and Beyond Zero Emissions. Snapshot. Retrieved 27 February 2025, from https://snapshotclimate.com.au/

[4] https://www.newcastleclimatechangeresponse.org.au/newcastle-climate-action-summit.html

[5] © State of New South Wales (Transport for NSW) [2022].

[6] TfNSW. (2022a). Future Transport Strategy. Future Transport. Retrieved 01 March 2023, from https://www.future.transport.nsw.gov.au/

[7] Office of Energy and Climate Change (OECCb). (2022). Net Zero Plan Implementation Update 2022. NSW Climate and Energy Action. Retrieved 31 March 2023, from https://www.energy.nsw.gov.au/sites/default/files/2022-12/NSW-Net-Zero-Plan-Implementation-Update-2022.pdf

[8] © Transport for New South Wales.

[9] TfNSW. (2021a). Zero Emission Bus Transition Strategy. Retrieved 09 March 2023, from https://www.transport.nsw.gov.au/system/files/media/documents/2021/zero-emission-bus-transition-strategy.pdf
 

[10] Office of the NSW Chief Scientist & Engineer (OCSE). (2020). Opportunities for prosperity in a decarbonised and resilient NSW Decarbonisation Innovation Study. Retrieved 08 April 2023, from https://www.chiefscientist.nsw.gov.au/independent-reports/decarbonisation

[11] Deloitte Access Economics. (2017). Value of Rail: The contribution of rail in Australia. (for Australasian Railway Association). Retrieved 08 April 2023, from https://www2.deloitte.com/au/en/pages/economics/articles/value-rail.html

[12] ©Transport for New South Wales.

[13] TfNSW. (2020). Freight and Servicing Last Mile Toolkit: A guide to planning the urban freight task. Retrieved 08 April 2023, from https://www.mySydney.nsw.gov.au/lastmilefreight
 

[14] TfNSW. (2021b). Future Transport Technology Roadmap 2021–2024. Retrieved 09 March 2023, from https://www.transport.nsw.gov.au/projects/strategy/technology-roadmap
 

[15] Adiona Tech. (2023). Connected Thinking: An Adiona Tech report on Australian transport electrification priorities. Retrieved 11 May 2023, from https://www.adionatech.com/resources/connected-thinking-report

[16] Ellis, P. (2023). London’s first Cargo Bike Action Plan launched. Transport for London. Retrieved 11 May 2023, from https://tfl.gov.uk/info-for/media/press-releases/2023/march/london-s-first-cargo-bike-action-plan-launched

[17] Transport for NSW (TfNSW). (2018a). NSW Freight and Ports Plan 2018-2023. Retrieved 09 March 2023, from https://www.transport.nsw.gov.au/projects/strategy/nsw-freight-and-ports-plan

[18] Department of Climate Change, Energy, the Environment and Water (DCCEEW). (2022c). National Greenhouse Accounts 2020: State and Territory Greenhouse Gas Inventory, Australian Government Department of Climate Change, Energy, the Environment and Water.. Retrieved 26 March 2023, from https://www.dcceew.gov.au/climate-change/publications/national-greenhouse-accounts-2020/state-and-territory-greenhouse-gas-inventories-annual-emissions  

[19] Bureau of Infrastructure and Transport Research Economics (BITRE). (2023b). Australian Sea Freight 2020-21. Retrieved 14 October 2023, from https://www.bitre.gov.au/publications/2023/australian-sea-freight-2020-21

[20] © State of New South Wales (Transport for NSW) [2022].

[21] TfNSW. (2022b). Active Transport Strategy. Retrieved 09 March 2023, from https://www.future.transport.nsw.gov.au/future-transport-plans/active-transport-strategy
 

[22] O'Sullivan, F., & Bliss, L. (2020). The 15-Minute City—No Cars Required—Is Urban Planning’s New Utopia. Retrieved 07 April 2023, from https://www.bloomberg.com/news/features/2020-11-12/paris-s-15-minute-city-could-be-coming-to-an-urban-area-near-you

[23] TfNSW) (2023a). Strategic cycleway corridors for Greater Sydney. Retrieved 07 April 2023, from https://www.transport.nsw.gov.au/operations/walking-and-bike-riding/strategic-cycleway-corridors

[24] Bicycle NSW. (2023). The first NSW active transport strategy. Retrieved 07 April 2023, from https://bicyclensw.org.au/the-first-nsw-active-transport-strategy/

[25] 2022 Department of Planning and Environment.

[26] DP&E. (2022a). Hunter Regional Plan 2041. Retrieved 09 April 2023, from https://www.planning.nsw.gov.au/Plans-for-your-area/Regional-Plans/Hunter/Hunter-regional-plan-2041

[27] Hunter Joint Org (Hunter JO). (2022). Hunter JO Strategic Plan 2032 Statement of Strategic Regional Priorities. Retrieved 20 April 2023, from https://www.hunterjo.com.au/hunter-jo-strategy/
 

[28] TfNSW. (2022c). Draft Hunter Regional Transport Plan 2041. Retrieved 09 March 2023, from https://www.future.transport.nsw.gov.au/future-transport-plans/draft-hunter-regional-transport-plan
 

[29] Staples, R. (2021a). Road User Space Allocation Policy. Retrieved 13 April 2023, from http://www.transport.nsw.gov.au/system/files/media/documents/2021/road-user-space-allocation-policy.pdf

[30] Staples, R. (2021b). Providing for Walking and Cycling in Transport Projects Policy. Retrieved 13 April 2023, from http://www.transport.nsw.gov.au/system/files/media/documents/2021/providing-for-walking-and-cycling-in-transport-projects-policy.pdf

[31] © Transport for NSW.

[32] Department of Planning and Environment (DP&E). (2018). Greater Newcastle Metropolitan Plan 2036. Retrieved 14 April 2023, from https://www.planning.nsw.gov.au/Plans-for-your-area/Greater-Newcastle-metropolitan-planning/Resources
 

[33] TfNSW. (2018c). Greater Newcastle Future Transport Plan. Retrieved 09 March 2023, from https://www.future.transport.nsw.gov.au/future-transport-plans/greater-newcastle-future-transport-plan

[34] TfNSW. (2022d). Hunter Regional Transport Plan Initiatives - Lower Hunter Sub Region. Retrieved 10 April 2023, from https://www.future.transport.nsw.gov.au/documents/hunter-regional-transport-plan-lower-hunter-electorate-initiatives

[35] McLaren, A., & Van Veen, J. (2022). North Parramatta Place Strategy Community Visioning Workshops. Retrieved 10 April 2023, from https://www.planning.nsw.gov.au/-/media/Files/DPE/Strategy-documents/Plans-for-your-area/Planning-for-local-communities/Parramatta-CBD/North-Parramatta-Place-Strategy-Community-Visioning-Workshops-202212.pdf?la=en

[36] Port Stephens Council. (n.d.). Fullerton Cove Place Strategy. Retrieved 10 April 2023, from https://www.portstephens.nsw.gov.au/development/strategies-and-planning-guides/fullerton-cove-place-strategy

[37] idcommunity. (2021). Australia Method of Travel to Work. Retrieved 18 April 2023, from https://profile.id.com.au/Australia/travel-to-work?BMID=260

[38] Loader, C. (2022). Update on Australian transport trends (December 2022). Charting Transport: Looking at Transport through graphs and maps. Retrieved 18 April 2023, from https://chartingtransport.com/2022/12/31/update-on-Australian-transport-trends-december-2022/

[39] NSW EPA. (2021). NSW State of Environment: Transport 2021. Retrieved 16 April 2023, from https://www.soe.epa.nsw.gov.au/all-themes/human-settlement/transport-2021

[40] CoN. (2021a). Newcastle Climate Action Plan 2021-2025. Retrieved 17 April 2023, from https://newcastle.nsw.gov.au/living/environment/climate-action

[41] TfNSW. (2021b). Future Transport Technology Roadmap 2021–2024. Retrieved 09 March 2023, from https://www.transport.nsw.gov.au/projects/strategy/technology-roadmap
 

[42] CoN. (2021c). On our bikes: A plan for safe and connected cycling in the Newcastle LGA. Retrieved 23 April 2023, from https://newcastle.nsw.gov.au/getmedia/19c3e8a0-e5b5-4c87-b8d6-4dc2ac12c567/On-our-bikes-Cycling-Plan-2021-2030#:~:text=We%20are%20dedicated%20to%20building,people%20to%20ride%2C%20more%20often.

[43] City of Newcastle (CoN). (2012). Newcastle Cycling Strategy and Action Plan 2012. Retrieved 24 April 2023, from https://bicycleinfrastructuremanuals.com/wp-content/uploads/2019/02/Newcastle-Cycling-Strategy-and-Action-Plan_Australia-Newcastle.pdf

[44] Institute for Sensible Transport. (2019). Understanding the spatial relationship between cycling propensity and car dependence. Retrieved 23 April 2023, from https://opendata.transport.nsw.gov.au/dataset/cycling-propensity
 

[45] CoN. (2020). Newcastle Cycling Strategy and Action Plan Consultation Report. Retrieved 23 April 2023, from https://newcastle.nsw.gov.au/have-your-say/projects-archive/draft-cycling-plan-on-our-bikes

[46] CoN. (2021c). On our bikes: A plan for safe and connected cycling in the Newcastle LGA. Retrieved 23 April 2023, from https://newcastle.nsw.gov.au/getmedia/19c3e8a0-e5b5-4c87-b8d6-4dc2ac12c567/On-our-bikes-Cycling-Plan-2021-2030#:~:text=We%20are%20dedicated%20to%20building,people%20to%20ride%2C%20more%20often.

[47] City of Newcastle (CoN). (2012). Newcastle Cycling Strategy and Action Plan 2012. Retrieved 24 April 2023, from https://bicycleinfrastructuremanuals.com/wp-content/uploads/2019/02/Newcastle-Cycling-Strategy-and-Action-Plan_Australia-Newcastle.pdf
 

[48] ABS. (2021). Australian Bureau of Statistics 2021 Census of Population and Housing. Newcastle 2021 Census Community Profiles.Australian Bureau of Statistics. Retrieved 24 April 2023, from https://www.abs.gov.au/census/find-census-data/community-profiles/2021/LGA15900

[49] Department of Planning, Housing and Infrastructure (2023) Transport Oriented Development Program. https://www.planning.nsw.gov.au/policy-and-legislation/housing/transport-oriented-development-program  ​

​My favourite climate read from the festive season:
Climate Clangers: The Bad Ideas Blocking Real Action by Jennifer Rayner.

Rayner stated that we cannot fix the massive problem of #cimatechange by relying on the same social, political and economic structures that got us here in the first place.  We have left it too long and let the risks mount too high to follow the path of incremental change.  We need to be flipping the switch to warp speed, but the three bad ideas detailed in the book are holding us back from taking action at the speed and scale that Science demands.
 
Rayner notes that these climate clangers are more like perspectives or conceptual frameworks that usually go unsaid and unnoticed because they're so embedded in how politicians, policy makers, businesses, and maybe some of us think and view the world, blinkering us from what is necessary and what is possible for tackling climate change right now.

The three climate clangers are:

• That our economy must keep growing as fast as it always has as we decarbonise.
• That Net Zero accounting can keep Global Heating within survivable limits. and
• Looking at the cost of action but ignoring the cost of inaction.

Each of these clangers is ceremonially discredited in turn by Rayner and valid alternatives proposed.
Our economy is measured by GDP, which is the sum of everything produced and sold for money, including all wealth / profits going overseas.  So, fossil fuel exports by overseas companies inflate the GDP but bring little terms of direct economic contribution (jobs, taxes) to the country, whereas electrification and solar PV reduces costs to families and businesses but is bad for GDP even though it's great for Australians.

The paradigm of net zero puts the focus firmly on requiring businesses to balance their carbon ledger. Carbon offsets allow companies to keep polluting as usual if someone somewhere else does something like plant a tree to offset that pollution on paper.  The carbon cycle doesn’t work that way. Rayner states that we need to make cuts to pollution right now and lay to rest ill-founded idea that counting carbon offsets equals climate action.

The expected costs of climate action are very visible, but we rarely hear about the costs of inaction.  The costs of business as usual (Direct costs of continuing to power ourselves with fossil fuels) alone nearly match the cost to decarbonise our economy.  Added to that are the significant costs of inaction, the indirect costs.  These include the huge and escalating price we will all pay from more unnatural weather disasters which the Insurance Council of Australia estimates will cost about 35 billion dollars a year by 2050 if we keep going on our current path.

An excellent book – recommended reading. - Alec Roberts

Download a copy of the submission here or ready the submission online below.

​27/02/2024
 
Department of Infrastructure, Transport, Regional
Development, Communications and the Arts
GPO Box 2154
Canberra ACT 2601
 
 
Australian New Vehicle Efficiency Standard Submission
 
To whom it may concern
 
Thank you for the opportunity to provide input to the Australian New Vehicle Efficiency Standard (NVES) and taking the time to consider our submission.
 
The Clean Energy Association of Newcastle and Surrounds (CLEANaS) strongly supports the implementation of an aggressive Australian New Vehicle Emission Standard (Option C: Fast start).  Option C catches up with US and European emission targets, makes the Australian vehicle market highly appealing for low- and zero-emissions vehicles, maximises savings to the consumer, and accelerates and maximises the reduction of carbon emissions. An effective and strong NVES aligns with the vision and goals of CLEANaS.
 
However, due to the size and increasing nature of transport emissions in Australia, the NVES alone, whether through the government preferred Option B or Option C, will be insufficient to tackle this difficult problem. Additional policies and measures are necessary.  These should include:

• Removal of Parallel Import Restrictions,
• Policies and measures to curb increased use of cars and kms travelled,
• Policies and measures to curb increased sale of larger cars, and
• Regulation to ban the import of HFC-charged automotive air conditioners.

 
CLEANaS is the Clean Energy Association of Newcastle and Surrounds, a not-for-profit association formed in 2012 by a group of locals passionate about clean energy.[1] CLEANaS is dedicated to driving the uptake of clean energy so that our region can transition from its current dependency on fossil fuels to a more competitive and sustainable local economy. We achieve this by working with our partners to demonstrate profitable community-led and community-owned clean energy projects; raise the profile of clean energy in the local economy through education and awareness raising; and by improving access to financing mechanisms and affordable technologies so that investment and activity grow. Our initiatives must deliver a win-win for local community investors, local enterprise and, of course, our environment.
 
The government is responsible for the environment, the health and wellbeing of its citizens, and the financial security of the nation. As we see the impact of increased carbon emissions, we also find evidence of the deleterious impact on Australian native wildlife, the Australian people and the wealth of the nation.  There is only 3 years left at present emission rates of the 2013-2050 emission budget to stay below 1.5°C with Australia having exceeded its carbon budget for 2050 by 2027. By 2055 Australia will experience economic losses on par with covid, getting worse every single year due to unchecked climate change.3
 
The IPCC stated that global emissions need to reach net zero by 2050 to be consistent to limiting warming to 1.5 °C.14 However, last year Australia’s emissions increased by 0.8% (3.6 Mt CO2-e), fueled primarily by a 7.8% (7.1 Mt Co2-e) increase in transport emissions.14
In 2020 Australia emitted 1.1% of world greenhouse gas emissions. This made Australia the world’s 16th biggest emitter of greenhouse gas pollution, despite having just 0.33% of world population.[2]  On a per capita basis. Australian emissions are the highest in the OECD and among the highest in the world. The only countries with higher per capita emissions than Australia are smaller petro-states like Kuwait, Qatar and UAE and some Small Island Developing States. [3] [4] [5]
 
Climate Change ImpactsThe impacts of climate change on the environment are significant and severe. The present scientific consensus is that the earth's climate is warming due to human activity, and the negative impacts of increased greenhouse gas emissions are measurable globally and nationally.[6]
 
Australia’s climate has warmed on average by 1.47 ± 0.24 °C since national records began in 1910, which has led to an increase in the frequency of extreme heat events.[7] The Bureau of Meteorology and CSIRO reported that there has been an increase in extreme fire weather, and in the length of the fire season, across large parts of the country since the 1950s, as evidenced by the catastrophic bushfires in the summer of 2019/2020.  They also noted changes in rainfall, with decreases in the southeast and southwest of Australia as shown by the devastating drought in 2019.  Oceans around Australia they stated are acidifying and have warmed by about 1°C since 1910 bringing longer and more frequent marine heatwaves.  In the past 5 years there have been three major mass-bleaching events at the Great Barrier Reef resulting from these marine heatwaves, and resulting in the destruction of over half of the reef’s corals.[8]  The Great Barrier Reef has an economic, social and iconic asset value estimated at $56 billion, contributes around $6.4 billion annually to the Australian economy and supports over 64,000 jobs.[9]  Sea levels are also rising around Australia, increasing the risk of coastal inundation and damage to infrastructure and communities.6
Economic risksDeloitte Access Economics noted that some of the most significant risks to Australia’s economic growth trajectory are from the physical risks associated with a changing climate and the unplanned economic transition risk from the world’s response to this changing climate.[10]
Their analysis showed that the Australian industries hardest hit by the Covid 19 pandemic would also be the most vulnerable to the effects of a warming world and climate change. Australia’s agriculture, construction, manufacturing, tourism related industries and mining sectors all featured consistently in the top industries exposed to the risks of covid, climate change and the unplanned economic transition as the world responds.  Deloitte Access Economics estimated that by 2055 Australia will experience economic losses on par with Covid 19.10
The government is responsible for the environment, the health and wellbeing of its citizens, and the financial security of the nation. As we see the impact of increased carbon emissions, we also find evidence of the deleterious impact on Australian native wildlife, the Australian people and the wealth of the nation. 
 
Net Zero Emissions by 2050The IPCC stated that global emissions need to reach net zero by 2050 to be consistent to limiting warming to 1.5 °C.14  Modelling has shown that moving towards a net zero emissions economy would unlock financial prospects in sectors including manufacturing and renewables triggering a $63 billion investment boom.[11]  Deloitte Access Economics estimates such a new growth recovery could grow Australia’s economy by $680 billion (present value terms) and increase GDP by 2.6% in 2070 – adding over 250,000 jobs to the Australian economy by 2070.10 
 
The Australian Government has now committed to developing a 2050 Net Zero plan and 2035 emission reduction targets consistent with Australia’s international and domestic commitments.[12] 
 
Emission goalsTo address the issue of dangerous climate change, Australia, along with 196 other parties, is a signatory to the Paris Agreement, which entered into force on 4 November 2016. The Paris Agreement aims to strengthen the global response to the threat of climate change, by:
Holding the increase in the global average temperature to well below 2°C above pre-industrial levels and pursuing efforts to limit the temperature increase to 1.5°C above pre-industrial levels, recognising that this would significantly reduce the risks and impacts of climate change.[13]
Australia has a target to achieve net zero emissions by 2050. Furthermore, in 2022, The Australian Government increased the ambition of its 2030 target in 2022, committing in legislation to reduce greenhouse gas emissions 43% below 2005 levels by 2030[14].
 
Australia’s current emissions and trendsAustralia’s emissions for the year to June 2023 have declined by 24.5% since 2005 primarily due to the “continuing shift in the generation of electricity from coal towards renewable fuel sources”.  At the current rate of decline, emissions will have reduced by approximately 38% by 2030 missing the legislated target by approximately 5%.15
 
Australia’s emissions for the year to June 2023 were approximately 465.2 Mt CO2-e, which is an increase of 0.8% (3.6 Mt CO2-e). This was fueled primarily by a 7.8% (7.1 Mt Co2-e) increase in transport emissions.15
 
The transport sector is the third highest emission sector after electricity and stationary energy with 21.1% of Australia’s emissions. In the year to June 2023, transport accounted for 21.1% of Australia’s national GHG inventory which represents 98.0 Mt CO2-e[15].  Road transport is close to 85% of those emissions[16]. Cars and Light commercial vehicles (LCVs) alone contribute over 60% of Australia’s transport emissions and around 13% of Australia’s total greenhouse gas emissions.
 
Whereas emissions from the electricity sector continue to go down as renewable energy uptake continues, emissions from the transport sector are trending upwards. Transport emissions have increased 19.5% (16.0 Mt CO2-e) since June 2005, despite recent volatility due to the impacts of the COVID pandemic.  Over the year to June 2023 GHG emissions increased by 7.8% (7.1 Mt CO2-e) in actual terms, compared with the previous year.15  Similarly, transport emissions from cars and LCVs grew by 5.6% in the same period, with an long term trend of an estimated 1% growth in emissions each year.16
 
Australia needs real and rapid reductions in CO2 emissions from the transport sector. The Australian government is at risk of not achieving its legislated target to reduce greenhouse gas emissions 43% below 2005 levels by 2030 due to the continued increase in emissions in the transport sector. Urgent action is required to address this issue.
 
Deliver steep reductions earlyEarly and deep emission reductions are essential in meeting the agreed temperature goal of holding the increase in the global average temperature to well below 2°C above pre-industrial levels and pursuing efforts to limit the temperature increase to 1.5°C above pre-industrial levels.13 Moving fast on emission reduction in sectors where technologies are advanced (such as electricity generation and transport) allows more time to deal with sectors that are harder to decarbonise whilst still meeting the ultimate temperature goal. This needs to be considered with policies and measures to reduce Transport emissions.51
 
Australian car emissions intensityAustralian cars produce up to 40% more carbon dioxide than their European counterparts due to high polluting and inefficient fleet[17].  In 2021, CO2 emissions of Australian passenger vehicles were found to be 53% and LCV’s 32% higher than the average for other major markets (China, Japan, US and EU).50
 
The Carbon Dioxide Emissions Intensity for New Australian Light Vehicles Report for 2021 showed Australia falling further behind other countries. Of all new passenger cars sold in Australia that year, 45% had an emissions intensity of 160 g/km or less, compared with 90% of all new cars sold in Europe[18].  The National Transport Commission noted that if all cars sold in 2021 were ‘best in class’ for emissions, Australia’s total 2021 emissions for new vehicles would have reduced by 91% for passenger vehicles and small SUVs and 47% larger SUVs and utes.18
 
Analysis of Options for NVES policy settings 
NVES Objective and principlesThe Government’s key objective of the NVES is to reduce CO2 emissions from new cars to support the achievement of the Government’s legislated 2030 emissions reduction targets.[19]  An NVES is a cost-effective way to facilitate the transition of the Australian vehicle fleet to low- and zero-emissions, to promote higher energy efficiency, lower fuel consumption and running costs, and to reduce the dependence on fossil fuels.50
 
The NVES Impact Analysis provided 3 possible policy options, Option A - slow start, Option B - fast but flexible and Option C - fast start, with Option B the documented preferred option.
In the impact analysis, a number of principles were proposed to assist, together with a cost-benefit analysis, in analysing the merits of these proposed options.  These design principles are: Effective, Equitable, Simple and Transparent, Credible and Robust, and Enabling.  Although these are sometimes referred to as objectives in the impact analysis which is confusing.  It is unclear what the relative ranking/weight of the principles are and whether any are mandatory, only that they are “adequately addressed”.  In comparing options the principles of Equitable and Enabling appear conflated.
 
Based on current transport emissions for Cars and LCVs and the rate that transport emissions are increasing, the proportion of emissions abated from the NVES by 2030 for each option would be:  Option A: 0.2%, Option B: 5.3%, and Option C: 6.9%.15   Therefore, additional policies and measures will need to be taken to ensure the Government’s legislated 2030 emissions reduction targets are met for the Transport sector.
 
Option A does not achieve Government’s key objectiveAs noted in the impact analysis and above, Option A generates negligible abatement and does not support achievement of the Government’s legislated 2030 emissions reduction targets.  As Option A - slow start does not achieve the Government’s key objective of the NVES to reduce CO2 emissions from new cars to support the achievement of the Government’s legislated 2030 emissions reduction targets it should be discarded.
 
Comparing Option B and Option C financial benefitsThe financial benefits of Option B - fast but flexible and Option C - fast start appear comparable with Option C having a greater net benefit but slightly lower benefits cost ratio to 2050.  It would have been preferable to also have the figures to 2030 in line with the Governments legislated targets.  The figures provided in the report have to be taken on face value as there is insufficient information to determine how they are calculated.
 
It is important to remember the complementary health benefits from replacing high-emission cars that are often also highly-polluting cars with low-emissions low-polluting cars.  The current transport sector is brimming with highly-polluting cars that are increasing transport emissions and contributing to poor air quality. University of Melbourne research has found that air pollution from cars, trucks and buses can cause up to 11,100 deaths each year.53
 
Other potential benefits that may change the overall financial benefits of these two options are included further below.
 
Availability of affordable new vehicles will increase not decreaseIn assessing options versus stated design principles, under the principle “Enabling:vehicles with the best emissions and safety technology to be available to Australians”, the impact analysis stated that under Option C there would be “Potential reduced access to affordable new vehicles, partially offset by greater availability of relatively affordable low and zero emissions vehicles.”  There is little to support the assertion of reduced access to affordable new vehicles.
 
Choice of vehicles will increase with an NVESImplementing an effective NVES will increase the diversity / choice of vehicles available in Australia.  An NVES will create an incentive to bring more efficient and electric models to
market.[20]  Car manufacturers in managing their fleet emissions, will literally need to provide greater choice to the market rather than less.[21] IEA noted that stringent NVES’s have promoted EV adoption in most leading EV markets and “should be adopted by all countries seeking to hasten the transition to electromobility.”[22]
 
Prices of cars will not increaseModelling indicates the NVES will increase the cost of ICE vehicles by a marginal 0.3% per annum due to the adoption of the latest technology. This is no evidence that this has actually led to real-world increases in end user prices for ICE vehicles in other countries. Furthermore, modelling indicated the NVES would lead to a decrease EV prices by 2.8% per annum.[23]
 
Implementation of changes for manufacturers should be straightforwardAustralia has been clear about its intention to introduce an NVES for a number of years, so no big surprises.  Both Option B and Option C allow manufacturers 2 years grace period before stringent limits are imposed.
 
Car manufacturers have implemented processes and procedures to manage Vehicle Efficiency Standards across more than 85% of their global markets including the European Union, USA, Canada, Brazil, China, South Korea, Mexico, and right-hand drive markets of India, Japan, United Kingdom and New Zealand.[24]  Australia is a very late comer to this field and existing processes and procedures can be readily adapted by manufacturers to the Australian market.
 
Furthermore, using known fuel-saving strategies, manufacturers can make existing vehicle models comply with emissions standards while saving consumers money and dramatically reducing fuel consumption. Research indicates that for ICE vehicles an NVES can be addressed based upon improving existing ICE vehicle models.[25]
 
Why comparing to US standards is not a good thingThe US standard (of which the NVES is compared) does not appear stringent enough. Fuel efficiency gains have stagnated over the last 9 years, with only an approximate 1.2% average improvement in fuel efficiency per annum.  At this rate the US will miss their 2026 standards target.[26] Following US targets may set Australia up for failure.
 
The European Union, UK and New Zealand have stricter standards than the US.  Stronger targets will deliver greater financial benefits and greater greenhouse gas emissions abatement.  Australian policymakers should adopt standards that align with leading markets and with world's best practice and adopt a standard in line with the strongest standard, the European Standard.  Option B – fast but flexible falls short of what is being done in Europe.50 Option C - fast start is the globally competitive case that catches up with the European Standard in 2029 and should be adopted.
 
Penalty rates should be consistent with other countriesPenalties are levied against suppliers who fail to meet the CO2 target.  These should be consistent with other major countries. Penalties need to be sufficient to impact the profitability of the supplier. Too small and manufacturers will ignore the fines and not make the necessary changes to reduce emissions. Given that per capita incomes between the EU and Australia are similar, there seems no reason to adopt a lower penalty rate in Australia than in the EU. Penalties may also need revision to maintain their deterrence value relative to the trading price of credits. Option C penalty rate is closest to EU and UK standards.[27] [28] [29]
 
WLTP testing adoptedThe official Australian test protocol New European Driving Cycle (NEDC) is outdated and increasingly underestimates on-road emissions. It provides an unrealistic and skewed picture, undermining effective emission reduction. Previous checking has revealed emissions averaged around 25% and up to 40% higher than claimed.28 50  Australian passenger vehicles emissions were found to be underestimated by 46% and LCV’s by 29% for 2021.  Where NEDC continues to be used, these increasing gaps diminishes the effectiveness of an NVES and other measures to reduce transport emissions. Due to this widening gap between NEDC and real-world emissions, the European Union replaced the NEDC test procedure with the Worldwide Harmonized Light-vehicles Test Procedure (WLTP) in 2017.50
 
Real-world testing is critical. It’s vital to measure real-world fuel efficiency and emissions of new vehicles through WLTP and to make this information public to ensure standards are achieving their goals. The standards should also include on-board fuel consumption
monitoring to monitor the real-world fuel efficiency and emissions of new vehicles. To be credible with Australian distributors and consumers, the NVES must replace Australia’s obsolete emissions testing scheme with real-world testing of emissions utilising WLTP as global best practice as soon as possible.49  Monitoring and real-world testing is critical to ensure NVES standards are being met and on track.50
 
Why Option C over government preferred Option BCLEANaS supports Option C over the government preferred Option B.  Option B is very similar to Option C, obtaining a high benefit, and strong positive benefits cost ratio. However, benefits to consumers are 19% higher for Option C. The exclusion of technology credits in Options B and C provides transparency, reduces complexity and avoidance of potential dilution of the NVES. Option B also looks to achieve a large abatement supporting the Government’s legislated 2030 emissions reduction targets.
 
The continued increase in Transport emissions, of which Cars and LCVs form a significant proportion, pose a significant impediment to the achievement of Australia’s commitments under the Paris Agreement and legislated 2030 emissions reduction targets. The NVES alone (either Option B or Option C) will not address this increase in emissions and additional policies and measures will be required. Recent research indicates that to keep up with the pace of technological advancement and decarbonization in other major markets and developed countries, Australian policymakers should consider adopting a stringent, mandatory NVES alongside additional policies.50
 
With a more ambitious headline CO2 target, Option C delivers steep reductions in emissions early and has over 30% additional emission abatement than Option B by 2030.  Reducing emissions early allows more time to deal with sectors that are harder to decarbonise, whilst still meeting Australia’s commitments.
 
Due to transport emissions going in the wrong direction and diluting the gains made in other sectors, where possible emissions reduction abatement from transport policies such as the NVES should happen early and be maximised to ensure any chance of achieving Australia’s commitments under the Paris Agreement and Australia’s legislated 2030 emissions reduction targets.  Therefore Option C is the appropriate choice.
 
Addressing documented risks of Option CVehicle manufacturers will be able to readily adapt existing processes and procedures to the Australian market already used to manage Vehicle Efficiency Standards in the majority of their world markets to “adapt the technology offerings and vehicle supply to Australian consumers” (see above).
 
The impact analysis found that the consumers in rural, regional and remote areas would benefit more financially from the NVES than those in major cities.
 
The justification of weaker standards by evoking the purported needs of certain groups and populations such as farmers and people in regional areas needs to stop.  Farmers should not be stereotyped as they are often keen to be involved in the transition to low emission vehicles and EVs[30] [31] [32] [33].  Jake Whitehead, the head of policy at the Electric Vehicle Council stated that farmers don’t want to pay more for fuel, be dependent on foreign oil, or cause more pollution, and noted that where there are specific issues that make it difficult for some groups to capture benefits of an NVES, the issues should be addressed up front and not use these groups as a shield to push for weaker standards.47
 
 
Other NVES Benefits / Savings 
Fuel SecurityLiquid fuel security is a serious economic and national security issue for Australia. Australia is currently reliant on imports for around 91% for fuel consumption of which 73% are transport fuels including 54% for road transport.  Australia’s transport fuels are highly vulnerable to international prices and supply chains as shown by the Ukraine War and instability in the middle east.34
 
Furthermore, Australia is currently in breach of the IEA stockholding obligation to maintain emergency fuel reserves equivalent to at least 90 days of net oil imports with only 68 days of liquid fuel in reserve. Dependency on imported liquid fuel and lack of reserves makes Australia ill-prepared to deal with a disruption to supply, particularly with the heightened geopolitical risks the nation currently faces.34
 
Improving fuel efficiency and diversifying Australia’s energy mix would increase energy security by reducing overall demand for imported oil and decreasing the potential impact of oil supply chain disruptions.34
 
Under Options B and C, the demand for imported oil would decrease each year as the Australian car fleet was progressively replaced by fuel efficient ICE vehicles, hybrids and EV’s with demand dropping faster with Option C than Option B.  With 25% of the passenger fleet EV’s, 8% of total imports would not be needed (oil displacement impact), with 50%, that would increase to 16%.[34]
 
Trade ImbalanceIn FY 2021-2022, Australia’s top import was Refined Petroleum, with $39.8 Billion expended that year.  Together with imports of $8.3 Billion in Crude Petroleum, oil imports contribute significantly to Australia’s trade balance each year.[35]
 
Coal and Natural Gas exports ($113.8 Billion and $70.6 Billion respectively for FY 2021-2022) are collectively the top export for Australia.35  As demand for fossil fuels decreases overseas as the reliance on fossil fuels diminishes, Australia’s trade balance is expected to worsen impacting on Australia’s current account balance with Australia’s current account deficit expected to grow.  Without a drop in imported oil over this period the effect on the trade balance and current account deficit would be exacerbated.  As noted above, under Options B and C, the demand for imported oil would decrease each year as the Australian car fleet was progressively replaced by fuel efficient ICE vehicles, hybrids and EV’s with demand dropping faster with Option C than Option B, buffering the effects of a potential trade deficit and current account deficit as the world decreases its reliance on fossil fuels.
 
 
What the NVES does not coverThe NVES addresses a cap on emissions intensity but there is no cap on actual emissions. The effectiveness of this policy in reducing emissions are diminished by:

• Manufacturers selling more cars,
• Manufacturers selling larger cars, and
• People driving more kilometres in cars.[36]

 
Curb increased use of carsThe total kms driven each year in Australia increases by approximately 2%16. This directly leads to increased transport emissions that have outpaced improvements in fuel efficiency. The benefits of the NVES will be degraded by this increased use of road transport.  More efficient demand management can reduce transport emissions by changing the way people are moved, and reducing the need for movement while maintaining living standards.37 These changes improve the emissions intensity of travel or reduce transport demand. Passenger mode shift - changing passengers from higher to lower emissions modes, e.g. from road to public transport, walking, cycling and rail lead to reduced emissions.  Urban and transport planning can help reduce travel requirements and encourage mode shift to active and public transport; for example, by locating employment and schools close to communities that need them, or creating urban environments that encourage walking rather than driving.[37] 
 
Research has identified numerous measures and policy instruments that have reduced car use in European cities that should be applicable in Australian cities where 85% of Australians live.  These include: Congestion Charges, Parking & Traffic Control, Limited Traffic Zones, Workplace Parking Charges, and Mobility Services for Commuters.[38] [39]
 
“We don’t need to see more cars on the road, but better planning to get Australians out of their cars as the primary means of travel”.  Doctors for the Environment Australia’s Executive Director and GP, Dr Kate Wylie stated that:
 
Active transport such as walking, cycling, or public transport are needed and will save time, money and lives. A shift away from private car use will give more rapid and deeper reductions in transport pollution while improving physical health, make our cities better places to be, and reduce congestion.[40]
 
Curb increased sale of larger carsThere is a continued long-term shift towards Sport Utility Vehicles (SUVs) in major automotive markets across most of the world. Between 2010 and 2019, sales-weighted average new light-duty vehicles became 6.2% heavier, 20% more powerful and had a 7% larger footprint, with a key cause of this trend being a shift from cars (sedans) to SUVs and light trucks.  SUVs’ global share of new light-duty vehicle sales rose from 20% in 2010 to 44% in 2019.  Even in markets with high SUV sales, such as the United States, SUVs continue to claim a larger share of the market. Australia is little different to the US and Europe with SUV purchases growing at over 7% per annum.  In 2023, 55.8% of all car sales were SUVs.[41] This has underpinned increases in larger, heavier, and more powerful vehicles, which has led to increased oil consumption, direct CO2 emissions and vehicle weight, size and power. On average, SUVs consume around 20% more oil than an average medium-size car. The combustion-related CO2 emissions of SUVs increased by nearly 70 million tonnes in 2022. In Europe, the net effect of heavier, more powerful vehicles and of small increases in hybrid electric vehicle and electric vehicle sales shares was a 5.4% increase in fuel consumption between 2017 and 2019. Without the shift towards SUVs, energy use per km for combustion engine vehicles could have fallen at an average annual rate that is 30% higher than it did from 2010 to 2022.[42] [43]
 
In Australia, the number of light commercial vehicles (category mostly representing utes) continues to increase at a rate of around 5% each year.16  In 2023, 22.5% of all car sales were utes. This is despite there being more than 1.5 times as many utes as technical and trade workers.41
 
As seen in Europe and the US, vehicle efficiency standards alone are insufficient to address the erosion of reduction of CO2 emissions gained through vehicle efficiency standards by the adoption of larger vehicles such as SUV’s.
 
The “breakpoints” in the NVES policy Options B and C work to address manufacturers simply increasing the weight of the vehicle to allow for higher emissions per km, and Option C further limits this ability through a reduced slope of the fleet limit curve (less increased emissions per km allowed for each kg of increased weight than Option B).  However, further disincentives are needed to reduce emissions.  The Climate Council recommends curtailing tax policies that incentivise the purchase of larger, heavier, high emission vehicles such as the Fringe Benefits Tax exemption and the recently ended Instant Asset Write-Off.[44] Furthermore, IEA Global Fuel Economy Initiative details numerous policy options and recommendations, including adapting existing policy and regulatory instruments to help address this issue.43
 
Remove Parallel Import RestrictionsAustralia’s parallel import restrictions is a hangover from when Australia had a domestic car industry and bans the parallel imports of second-hand vehicles.  Allan Fels found that New Zealand consumers pay an average of 41% less for second-hand electric and hybrid vehicles – $9,025 on average – because that country does not ban parallel imports of second-hand vehicles like Australia does.  Tariffs and restrictions on the import of electric vehicles are no longer sensible since the exit of car manufacturers from Australia in the preceding decade. Unless this changes, restrictions on imports create unnecessarily high prices for consumers resulting in lower uptake of EVs resulting in continued high transport emissions for Australia. The regulations in the Road Vehicle Safety Act 2018 which block parallel imports of electric vehicles should be immediately lifted.[45] [46]
 
Regulate to ban import of HFC-charged automotive air conditionersNVES impact analysis Option B and Option C do not allow for air conditioning credits together with other technology credits including super credits and off-cycle credits.  This is a good thing as it provides simplicity and transparency to the policy and does not cater to the needs of individual car makers.  Any dilution of the NVES through the inclusion of these bonus credits risks further delaying the supply of more low and zero emission vehicles to Australia.[47] These technologies are generally already included and/or will soon be required for Australian vehicles.[48]
 
However, Australian vehicles continue to be imported with air conditioners charged with the refrigerant HFC-134a.  This is a greenhouse gas with a global warming potential of 1430 times that of CO2.  Although banned from original supply in Australia, it is not banned when imported via pre- charged automotive air conditioners. The import of HFC-charged automotive air conditioners should be banned directly through regulation.[49]
 
SummaryAn NVES provides an affordable method to support the shift of Australia's vehicle fleet toward low- and zero-emission vehicles. It aims to enhance energy efficiency, reduce fuel consumption, lower operational expenses, and decrease the reliance on fossil fuels.[50]
 
The Clean Energy Association of Newcastle and Surrounds (CLEANaS) strongly supports the implementation of an aggressive Australian New Vehicle Emission Standard (NVES Option C:Fast start) that catches up with US and European emission targets, makes the Australian vehicle market highly appealing for low- and zero-emissions vehicles, maximises savings to the consumer, maximises the reduction in greenhouse gas emissions and delivers steep reductions in emissions early.[51]
 
Similar to Australia, transport emissions in the Hunter region represent over 21% of our region’s emissions and around 6% of Australia’s overall transport emissions.  In 2021/2022, 99% of these emissions were from road transport.[52] Road transport is currently filled with highly-polluting cars that are driving up transport emissions and contributing to poor air quality and deleterious health outcomes.[53]
 
Consequently, the implementation of a strong NVES has the opportunity to provide significant benefits to the local community through reduced emissions, reduced dependence on fossil fuels, and significant health and financial benefits in the near future.
 
CLEANaS is dedicated to driving the uptake of clean energy in our region, reducing our dependence on fossil fuels to a more competitive and sustainable local economy.  Clean energy initiatives must be a win-win for our local community and business, and of course the environment.  An effective and strong NVES aligns with the vision and goals of CLEANaS.
 
The continued rise in transport emissions poses a significant challenge to Australia's commitments under the Paris Agreement and its legislated 2030 emissions reduction targets. The NVES, whether through Option B or Option C, is insufficient to tackle this emission surge. Additional policies and measures are necessary.  These should include:

• Removal of Parallel Import Restrictions
• Regulate to ban the import of HFC-charged automotive air conditioners
• Policies and measures to curb increased use of cars and kms travelled
• Policies and measures to curb increased sale of larger cars

 
Option B and Option C are comparable in most respects. However, Option C offers over 19% additional benefits to consumers and over 30% more emission abatement compared to Option B by 2030. Given that transport emissions are moving in the wrong direction and offsetting gains in other sectors, it is crucial to maximise emissions reduction efforts through transport policies like the NVES. This approach is essential for Australia to fulfil its commitments under the Paris Agreement and meet its legislated 2030 emissions reduction targets. Therefore, Option C is the appropriate choice.
 
Thank you for considering our submission,

Sincerely,
 
Alec Roberts
CLEANaS Chair on behalf of CLEANaS
 


[1] http://www.cleanas.org.au/

[2] World Population Review. (2023).  CO₂ Emissions by Country 2023. Retrieved 23 November 2023, from https://worldpopulationreview.com/country-rankings/co2-emissions-by-country

[3] Swann, T. (2019, July). High Carbon from a Land Down Under: Quantifying CO2 from Australia’s fossil fuel mining and exports. https://www.tai.org.au/sites/default/files/P667%20High%20Carbon%20from%20a%20Land%20Down%20Under%20%5BWEB%5D_0_0.pdf

[4] Ritchie, H. (2019, October 4). Where in the world do people emit the most CO2? Retrieved 18 February 2024, from https://ourworldindata.org/per-capita-co2

[5] Statistica. (2023). Per capita carbon dioxide emissions worldwide in 2022, by country. Retrieved 18 February 2024, from https://www.statista.com/statistics/270508/co2-emissions-per-capita-by-country/

[6] NASA (n.d.) Scientific Consensus: Earth's Climate is Warming. https://climate.nasa.gov/scientific-consensus/

[7] BOM (2022) State of the Climate 2022.  http://www.bom.gov.au/state-of-the-climate/2022/documents/2022-state-of-the-climate-web.pdf

[8] Readfearn, G. (2020, April 7). Great Barrier Reef's third mass bleaching in five years the most widespread yet. https://www.theguardian.com/environment/2020/apr/07/great-barrier-reefs-third-mass-bleaching-in-five-years-the-most-widespread-ever

[9] Deloitte Access Economics (2017, June 23). At what price? The economic, social and icon value of the Great Barrier Reef. https://www.barrierreef.org/the-reef/the-value

[10] Deloitte Access Economics (2020, November) A new choice: Australia’s climate for growth.  https://www2.deloitte.com/content/dam/Deloitte/au/Documents/Economics/deloitte-au-dae-new-choice-climate-growth-051120.pdf?nc=1

[11] Cox, L. (2020, Oct 12). Net zero emissions target for Australia could launch $63bn investment boom.  https://www.theguardian.com/australia-news/2020/oct/12/net-zero-emissions-target-for-australia-could-launch-63bn-investment-boom

[12] Department of Climate Change, Energy, the Environment and Water (DCCEEW). (2023). Net Zero, Australian Government Department of Climate Change, Energy, the Environment and Water. https://www.dcceew.gov.au/climate-change/emissions-reduction/net-zero

[13] IPCC (2018). Global Warming of 1.5°C: An IPCC Special Report on the impacts of global warming of 1.5°C above pre-industrial levels and related global greenhouse gas emission pathways, in the context of strengthening the global response to the threat of climate change, sustainable development, and efforts to eradicate poverty, Intergovernmental Panel on Climate Change.  https://www.ipcc.ch/sr15/

[14] Australian Government. (2022). Australia’s Nationally Determined Contribution: Communication 2022. UNFCCC Nationally Determined Contributions Registry. Retrieved 24 March 2023, from https://unfccc.int/sites/default/files/NDC/2022-06/Australias%20NDC%20June%202022%20Update%20%283%29.pdf

[15] Department of Climate Change, Energy, the Environment and Water (DCCEEW). (2023). Quarterly Update of Australia’s National Greenhouse Gas Inventory: June 2023, Australian Government Department of Climate Change, Energy, the Environment and Water. Retrieved 18 February 2024 from https://www.dcceew.gov.au/climate-change/publications/national-greenhouse-gas-inventory-quarterly-update-june-2023

[16] Bureau of Infrastructure and Transport Research Economics (BITRE), 2023, Yearbook 2023: Australian Infrastructure and Transport Statistics, Statistical Report, BITRE, Canberra ACT. Retrieved 18 February 2024, from https://www.bitre.gov.au/publications/2023/australian-infrastructure-and-transport-statistics-yearbook-2023

[17] Climate Council. (2022a). Everything you need to know about how Australia can boost Electric Vehicle supply. Retrieved 25 March 2023, from https://www.climatecouncil.org.au/how-Australia-can-boost-electric-vehicle-supply/

[18] National Transport Commission. (2021). Carbon Dioxide Emissions Intensity for New Australian Light Vehicles 2021. Retrieved 03 April 2023, from https://www.ntc.gov.au/sites/default/files/assets/files/Carbon%20Dioxide%20Emissions%20Intensity%20for%20New%20Australian%20Light%20Vehicles%202021.pdf

[19] Department of Infrastructure, Transport, Regional Development, Communications and the Arts. (2024, February). Cleaner, Cheaper to Run Cars: The Australian New Vehicle Efficiency Standard: Consultation Impact Analysis. https://www.infrastructure.gov.au/department/media/publications/cleaner-cheaper-run-cars-australian-new-vehicle-efficiency-standard-consultation-impact-analysis
 

[20] Quicke, A. (2022, Aug). Fuelling efficiency. The Australian Institute. https://australiainstitute.org.au/wp-content/uploads/2022/08/P1269-Fuel-Efficiency-Standards-WEB.pdf

[21] Basford Canales, S. (2024, Feb 21). More efficient cars could almost halve Australians’ yearly petrol costs, new analysis shows. https://www.theguardian.com/australia-news/2024/feb/21/more-efficient-cars-could-almost-halve-australians-yearly-petrol-costs-new-analysis-shows

[22] IEA. (2022). Global EV Outlook. Retrieved 18 February 2024, from https://www.iea.org/reports/global-ev-outlook-2022

[23] Mandala. (2023, June).  Raising standards, cutting costs: How an effective new vehicle efficiency standard can reduce vehicle emissions and save consumers money. https://electricvehiclecouncil.com.au/wp-content/uploads/2023/07/Raising-standards-cutting-costs.pdf

[24] Naidoo, V. (2023, Nov 12). What would fuel efficiency standards mean for Australia? https://www.drive.com.au/caradvice/australia-fuel-efficiency-standards-explained/

[25] Cooke, D. (2019, Sep 5).  Today’s Vehicles, Tomorrow: How Automakers Can Meet Strong 2025 Efficiency Standards. https://blog.ucsusa.org/dave-cooke/automakers-2025-efficiency-standards/

[26] Calma, J. (2023, Dec 22). American automakers are losing the race to make more fuel-efficient vehicles. https://www.theverge.com/2023/12/21/24010938/car-suv-truck-fuel-efficiency-emissions-epa-trends-report

[27] European Commission. (n.d.). CO₂ emission performance standards for cars and vans. https://climate.ec.europa.eu/eu-action/transport/road-transport-reducing-co2-emissions-vehicles/co2-emission-performance-standards-cars-and-vans_en

[28] Engineers Australia. (2023, May 31). Fuel Efficiency Standard submission. https://www.engineersaustralia.org.au/publications/fuel-efficiency-standard-submission

[29] Vehicle Certification Agency. (2022). New UK Car and Van CO2 Regulations: Guidance for manufacturers on the legislation governing CO2 emissions from new cars and vans sold in the UK. https://www.vehicle-certification-agency.gov.uk/download-publication/3899/New-Car-and-Van-CO2-Regulations-Guidance-2022/#:~:text=3.2%20The%20latest%20Regulation%2C%20(EU,for%20cars%20and%20vans%20respectively

[30] Somerville, P. & Hollingworth, K. (2022). Electric vehicles help farmers drive savings and lower carbon footprint. https://www.abc.net.au/news/rural/2022-06-05/electric-vehicles-side-by-side-farm-inputs-environment/101121922

[31] Credintino, J. (2023). Australian farmers show electric cars can work in the middle of nowhere.  https://www.carexpert.com.au/car-news/australian-farmers-show-electric-cars-can-work-in-the-middle-of-nowhere

[32] Farmers for Climate Action. (2023, February 23). Electric Vehicles on Farms - 23 Feb 2023. [Video]. Youtube. https://www.youtube.com/watch?v=jrWCO_fhL7s

[33] Quattromani, G. (2022, Oct 27). I Made The Switch To An Electric, Battery Powered Dirt Bike: Here’s How It Went. https://menshealth.com.au/surron-storm-bee-f-electric-motor-bike-review/

[34] Carter, L. Quicke, A. & Armistead, A. (2022, April). Over a barrel - Addressing Australia’s Liquid Fuel Security. The Australia Institute. https://australiainstitute.org.au/report/over-a-barrel/

[35] Department of Foreign Affairs and Trade. (2023). Australia’s trade in goods and services 2021-22. https://www.dfat.gov.au/trade/trade-and-investment-data-information-and-publications/trade-statistics/trade-in-goods-and-services/australias-trade-goods-and-services-2021-22

[36] Joshi, K. (2024, Feb 17). Big cars are dead weight dragging down climate policy. https://ketanjoshi.co/2024/02/17/car-companies-are-wrecking-climate-efforts-to-make-money/

[37] Climate Change Authority. (2023, Jun 29). Opportunities to reduce light vehicle emissions in Australia. https://www.climatechangeauthority.gov.au/reviews/light-vehicle-emissions-standards-australia/opportunities-reduce-light-vehicle-emissions

[38] Musso, A., & Dalla Chiara, B. (2017). Case studies on transport policy. Case Studies on Transport Policy, 5(2), 389–391. https://doi.org/10.1016/j.cstp.2017.04.001

[39] Kuss, P., & Nicholas, K. A. (2022). A dozen effective interventions to reduce car use in European cities: Lessons learned from a meta-analysis and transition management. Case Studies on Transport Policy, 10(3), 1494–1513. https://doi.org/10.1016/j.cstp.2022.02.001

[40] Doctors for the Environment Australia. (2024, February 7). Doctors: New Vehicle Efficiency Standard will save lives on our roads. https://dea.org.au/doctors-new-vehicle-efficiency-standard-will-save-lives-on-our-roads/

[41] Thrower, J. (2024, Jan 12). SUVs and utes are no longer just work vehicles, but tax-subsidised behemoths.  https://australiainstitute.org.au/post/suvs-and-utes-are-no-longer-just-work-vehicles-but-tax-subsidised-behemoths/

[42] Cazzola, P., Paoli, L. and Teter, J. (2023, November). Trends in the global vehicle fleet 2023: Managing the SUV shift and the EV transition. Global Fuel Economy Initiative. IEA. https://www.globalfueleconomy.org/data-and-research/publications/trends-in-the-global-vehicle-fleet-2023

[43] IEA (2021), Global Fuel Economy Initiative 2021, IEA, Paris https://www.iea.org/reports/global-fuel-economy-initiative-2021 , Licence: CC BY 4.0

[44] Climate Council. (2023, May 30). Submission to: Fuel efficiency standard consultation. https://www.climatecouncil.org.au/resources/submission-to-fuel-efficiency-standard-consultation/

[45] Fells, A. (2024, Feb). Inquiry into price gouging and unfair pricing practices. Final Report. https://pricegouginginquiry.actu.org.au/wp-content/uploads/2024/02/InquiryIntoPriceGouging_Report_web.pdf

[46] Braue, D. (2024, Feb 15). EVs in Australia cost $9,025 more than they should - But regulatory changes are about to fix that. https://ia.acs.org.au/article/2024/evs-in-australia-cost--9-025-more-than-they-should.html

[47] Bleakley, D. (2023). EV Council says vehicle standard needs to catch up with rest of world before 2030. The Driven.  https://thedriven.io/2023/05/25/ev-council-says-vehicle-standards-needs-to-catch-up-with-rest-of-world-before-2030/

[48] Whitehead, J. (2023). Recommendations for an Australian New Vehicle Efficiency Standard. Electric Vehicle Council. https://electricvehiclecouncil.com.au/reports/recommendations-for-anaustralian-new-vehicleefficiency-standard/

[49] Pocock, D. (2023, May 31). Response to: The Fuel Efficiency Standard – Cleaner, Cheaper to run Cars for Australia. https://www.davidpocock.com.au/strong_fuel_efficiency_standards

[50] Smit, R., Khan, T. & Yang, Z. (2024, Feb). How Australian light-duty vehicle CO2 emissions compare with the rest of the world. ICCT. https://theicct.org/publication/australian-ldv-co2-emissions-compare-to-the-rest-of-the-world-feb24/

[51] Climate Council. (2021, Aug 30). Emission Reduction Targets: What you need to know. https://www.climatecouncil.org.au/wp-content/uploads/2021/10/Explainer-Emissions-Reduction-Targets-October-2021.pdf

[52] Ironbark Sustainability and Beyond Zero Emissions. (2023). 2022 Snapshot emissions profile – Ironbark Sustainability and Beyond Zero Emissions. Snapshot. Retrieved 24 February 2024, from https://snapshotclimate.com.au/

[53] Bicycle Network (2024, Feb 15). Share your thoughts on Australia's new fuel efficiency standards. https://bicyclenetwork.com.au/newsroom/2024/02/15/share-your-thoughts-on-australias-new-fuel-efficiency-standards/
 

Download a pdf copy of the submission here or read the submission online below.

23/11/2020
 
Committee Secretary
Senate Standing Committees on Environment and Communications
Parliament House
PO Box 6100
Canberra ACT 2600
ec.sen@aph.gov.au
 
Climate Change Amendment (Duty of Care and Intergenerational Climate Equity) Bill 2023
 
To the Senate Standing Committees on Environment and Communications regarding the Climate Change Amendment (Duty of Care and Intergenerational Climate Equity) Bill 2023
 
Dear Committee Secretariat,
 
Thank you for the opportunity to provide a submission into the Climate Change Amendment (Duty of Care and Intergenerational Climate Equity) Bill 2023 and taking the time to consider our submission.
 
This is a submission supporting the Climate Change Amendment (Duty of Care and Intergenerational Climate Equity) Bill 2023.
 
The government is responsible for the environment, the health and wellbeing of its citizens, and the financial security of the nation. As we see the impact of increased carbon emissions, we also find evidence of the deleterious impact on Australian native wildlife, the Australian people and the wealth of the nation.  There is only 4 years left at present emission rates of the 2013-2050 emission budget to stay below 1.5°C. Therefore, at current emissions rates, Australia will have exceeded its carbon budget for 2050 by 2027. By 2055 Australia will experience economic losses on par with covid, getting worse every single year due to unchecked climate change.5
 
However, those that will suffer the most from the effects of climate change, children and future generations, are the least protected, with current Australian climate change legislation lacking on the rights of children and future generations.
 
The IPCC stated that global emissions need to reach net zero by 2050 to be consistent to limiting warming to 1.5 °C.5 Furthermore, The IEA (2021) stated that to achieve net zero by 2050, no new oil and gas fields should be approved for development together with no new coal mines or mine extensions.[1]
 
CLEANaS is the Clean Energy Association of Newcastle and Surrounds, a not-for-profit association formed in 2012 by a group of locals passionate about clean energy.[2] CLEANaS is dedicated to driving the uptake of clean energy so that our region can transition from its current dependency on fossil fuels to a more competitive and sustainable local economy. We achieve this by working with our partners to demonstrate profitable community-led and community-owned clean energy projects; raise the profile of clean energy in the local economy through education and awareness raising; and by improving access to financing mechanisms and affordable technologies so that investment and activity grow. Our initiatives must deliver a win-win for local community investors, local enterprise and, of course, our environment.
 
Climate Change ImpactsThe impacts of climate change on the environment are significant and severe. The present scientific consensus is that the earth's climate is warming due to human activity, and the negative impacts of increased greenhouse gas emissions are measurable globally and nationally.[3]
 
Australia’s climate has warmed on average by 1.47 ± 0.24 °C since national records began in 1910, which has led to an increase in the frequency of extreme heat events.[4] The Bureau of Meteorology and CSIRO reported that there has been an increase in extreme fire weather, and in the length of the fire season, across large parts of the country since the 1950s, as evidenced by the catastrophic bushfires in the summer of 2019/2020.  They also noted changes in rainfall, with decreases in the southeast and southwest of Australia as shown by the devastating drought in 2019.  Oceans around Australia they stated are acidifying and have warmed by about 1°C since 1910 bringing longer and more frequent marine heatwaves.  In the past 5 years there have been three major mass-bleaching events at the Great Barrier Reef resulting from these marine heatwaves, and resulting in the destruction of over half of the reef’s corals.[5]  The Great Barrier Reef has an economic, social and iconic asset value estimated at $56 billion, contributes around $6.4 billion annually to the Australian economy and supports over 64,000 jobs.[6]  Sea levels are also rising around Australia, increasing the risk of coastal inundation and damage to infrastructure and communities.2
 
The government is responsible for the environment, the health and wellbeing of its citizens, and the financial security of the nation. As we see the impact of increased carbon emissions, we also find evidence of the deleterious impact on Australian native wildlife, the Australian people and the wealth of the nation. 
 
Emission goals and carbon budgetsTo address the issue of dangerous climate change, Australia, along with 196 other parties, is a signatory to the Paris Agreement, which entered into force on 4 November 2016. The Paris Agreement aims to strengthen the global response to the threat of climate change, by:
Holding the increase in the global average temperature to well below 2°C above pre-industrial levels and pursuing efforts to limit the temperature increase to 1.5°C above pre-industrial levels, recognising that this would significantly reduce the risks and impacts of climate change.[7]
In 2020 Australia emitted 1.1% of world greenhouse gas emissions. This made Australia the world’s 16th biggest emitter of greenhouse gas pollution, despite having just 0.33% of world population.[8]  On a per capita basis. Australian emissions are the highest in the OECD and among the highest in the world. The only countries with higher per capita emissions than Australia are smaller petro-states like Kuwait, Qatar and UAE and some Small Island Developing States. [9] [10] [11]
 
 
Australia has a target to achieve net zero emissions by 2050. Furthermore, in 2022, The Australian Government increased the ambition of its 2030 target in 2022, committing to reduce greenhouse gas emissions 43% below 2005 levels by 2030[12] .
 
It should be noted that Australia’s commitment is insufficient to limit warming to 1.5C.  The IPCC calculated level of GHG reductions required by 2030 to limit warming to 1.5C is a 43% GHG reduction based on 2019 emissions.  Adjusting this figure for Australia’s baseline year of 2005 (a particularly high emission year) results in a required 48% reduction in emissions (below 2005 levels) required by 2030 to ensure a >50% chance of limiting warming to 1.5°C[13] [14]. The Climate Council and Climate Targets Panel both recommend that Australia cut its emissions 74-75% (based on 2005 levels) by 2030, and aim to reach net zero by 2035 to remain within 1.5C warming[15] [16] .
 
The IPCC report provides an estimate for a global remaining carbon budget of 580 GtCO2 (excluding permafrost feedbacks) based on a 50% probability of limiting warming to 1.5 degrees relative to 1850 to 1900 during and beyond this century and a remaining carbon budget of 420 GtCO2 for a 67% chance.[17]
 
Committed emissions from existing and proposed energy infrastructure represent more than the entire carbon budget that remains if mean warming is to be limited to 1.5 °C and perhaps two-thirds of the remaining carbon budget if mean warming is to be limited to less than 2 °C.  Estimates suggest that little or no new CO2-emitting infrastructure can be commissioned, and that existing infrastructure may need to be retired early in order to meet the Paris Agreement climate goals.[18]
 
From Jan 2017 until 2050 Australia’s remaining emission budget for a 50% chance of warming to stay below 1.5C warming relative to pre-industrial levels was estimated to be 5.5 GTCO2e.7  Adding the GHG emissions expended from 2017 until 2022[19] [20], this leaves just 2.5 Gt CO2e remaining as at December 2022 which equates to only 4 years left at present emission rates of the 2013-2050 emission budget to stay below 1.5°C.  Therefore, at current emissions rates, Australia will have exceeded its carbon budget for 2050 by 2027.
 
Economic risksDeloitte Access Economics noted that some of the most significant risks to Australia’s economic growth trajectory are from the physical risks associated with a changing climate and the unplanned economic transition risk from the world’s response to this changing climate.16
Their analysis showed that the Australian industries hardest hit by the Covid 19 pandemic would also be the most vulnerable to the effects of a warming world and climate change. Australia’s agriculture, construction, manufacturing, tourism related industries and mining sectors all featured consistently in the top industries exposed to the risks of covid, climate change and the unplanned economic transition as the world responds.  Deloitte Access Economics estimated that by 2055 Australia will experience economic losses on par with Covid 19.16
 
Net Zero Emissions by 2050The IPCC stated that global emissions need to reach net zero by 2050 to be consistent to limiting warming to 1.5 °C.5  Modelling has shown that moving towards a net zero emissions economy would unlock financial prospects in sectors including manufacturing and renewables triggering a $63 billion investment boom.[21]  Deloitte Access Economics estimates such a new growth recovery could grow Australia’s economy by $680 billion (present value terms) and increase GDP by 2.6% in 2070 – adding over 250,000 jobs to the Australian economy by 2070.[22] 
 
The Australian Government has now committed to developing a 2050 Net Zero plan and 2035 emission reduction targets consistent with Australia’s international and domestic commitments.[23]  However, since May 2022, 4 new coal mines or expansions were approved in Australia that will result in an additional 147 million tonnes of carbon emissions. An additional 25 additional proposals for new or expanded coal mines are currently awaiting Federal Government approval that would release over 12 billion tonnes of carbon emissions if approved.[24]  The International Energy Agency (2021) stated that to achieve net zero by 2050, no new oil and gas fields can be approved for development together with no new coal mines or mine extensions.[25]
 
Intergenerational EquityFailing to act on climate change today will result in the costs and damages of climate change increasing over time, with these burdens being borne by future generations.[26] [27] The Principle of Equality states that all generations should bear a similar weight for the burdens of climate change, and that all generations are obligated to not violate intergenerational or intragenerational equality.[28] So future generations should not bear substantially greater burdens or responsibilities for climate change compared to previous generations, and that individuals and groups within generations ought to bear comparable burdens and responsibilities to each other.
 
Weiss (2008)[29] in their seminal article on the theory of intergenerational equity stated that global climate change induced by human activities “raises serious issues of justice between the present generation and future generations, and between communities within future generations”. Weiss claimed that as all generations interact with the earth, every generation needs to pass the Earth and its resources on in at least as good a condition or a better condition than it was received. Weiss proposed 3 principles of intergenerational equity, specifically that present generations conserve the diversity of natural resources for future generations, ensuring the quality of the environment is comparable between generations and generations have similar access to the earth and its resources.  However, the environment is deteriorating at an increasing rate due in part to climate change, such as increasing temperatures, rising sea levels, and species extinctions.  Furthermore, natural resources likely impacted by climate change include land for habitation or agriculture, and fresh water sources. Nguyen (2021) noted that if we do not act to address climate change, resources over time will dwindle which will threaten the prospects of future generations having equitable access to resources as compared to present or past generations.
 
Weiss (2008) concluded that to fulfil our responsibility to future generations we must respect the principles of intergenerational equity and strategies to combat climate change need to reflect the principles of intergenerational equity.
 
Children and Climate ChangeAustralia is a signatory to the Convention on the Rights of the Child (CRC) which recognises that children have the same human rights as adults, while also needing special protection due to their vulnerability.  The guiding principles of the CRC includes putting the best interests of the child first in all decisions that affect them.  The Committee on the Rights of Children, that monitors implementation of the CRC, recently emphasised the urgent need to address the adverse effects of climate change on children’s rights and that “Governments should consider children’s rights in all decisions made about climate change and consider climate change in all decisions being made about children”[30] .
 
Children are especially vulnerable and will suffer disproportionately to the effects of climate change.  They have little say in climate policy decisions that will contribute to future climate impacts and have little or no control over the environment that they will inherit.  Children are already experiencing the impacts of climate change through climate change fueled climate and environmental hazards, impacting on their current and future wellbeing. UNICEF stated that approximately 1 billion children are at an “extremely high risk” of the impacts of climate change.[31]
 
Those that have contributed the least to climate change, children, those in poverty, and future generations are the most affected. Save the Children stated that due to climate change:

• The education of around 38 million children is disrupted each year,
• Almost 160 million children are exposed to increasingly severe and prolonged droughts,
• 90% of diseases resulting from climate change are likely to affect children under the age of five,
• By 2040, it is estimated that one in four children will be living in areas with extreme water shortages, and
• By 2050, a further 24 million children are projected to be undernourished,[32]

 
This BillCLEANaS supports the passing of this Duty of Care and Intergenerational Climate Equity bill. 
 
Currently, Australian legislation is ill-equipped to address the human rights impacts of climate change for both children and future generations.  This bill establishes a clear obligation for Government Ministers and decision-makers to consider the potential impacts of climate change on future generation’s wellbeing.
 
In particular the bill would create a new duty of care of decision makers to consider the health and wellbeing of current and future generations when considering decisions that may worsen the effects of climate change such as commissioning new fossil fuel infrastructure (such as the Gas fired power station currently being built in Kurri Kurri here in the Hunter Valley that will be incapable of running on more than 30% hydrogen even with additional investment[33]) or the approval of new fossil fuel mines or mine extensions (such as the Mount Pleasant Coal Mine in the Hunter Valley that will result in 876 million tonnes of emissions).
 
Furthermore, the bill would prohibit decisions that would lead to levels of emissions that pose a risk to the health and wellbeing of children and would promote intergenerational equity within government decision making. 
 
As additional emissions result in greater impacts of climate change no matter where they are created (in Australia or Overseas), the impact of this proposed legislation on a decision to approve a fossil fuel project would not depend on location of the infrastructure or where the emissions are created. This would also include decisions on public funding and loans for fossil fuel infrastructure projects.  The decision maker would also need to take into consideration if the emissions resulting from such a decision would impact on Australia’s emission reduction targets.
 
 
CLEANaS strongly supports imposing a duty of care on decision-makers to consider the health and well-being of current and future children in Australia when making administrative decisions that contribute to climate change and urges the Commonwealth Government to support the Duty of Care and Intergenerational Climate Equity bill.
 
Thank you for considering our submission,

Sincerely,
 
 
Alec Roberts
CLEANaS Chair on behalf of CLEANaS
 
 
 


[1] IEA. (2021). Net Zero by 2050. A Roadmap for the Global Energy Sector. Retrieved from https://www.iea.org/reports/net-zero-by-2050

[2] http://www.cleanas.org.au/

[3] NASA (n.d.) Scientific Consensus: Earth's Climate is Warming.  Retrieved from https://climate.nasa.gov/scientific-consensus/

[4] BOM (2022) State of the Climate 2022.  Retrieved from http://www.bom.gov.au/state-of-the-climate/2022/documents/2022-state-of-the-climate-web.pdf

[5] Readfearn, G. (2020, April 7). Great Barrier Reef's third mass bleaching in five years the most widespread yet. Retrieved from https://www.theguardian.com/environment/2020/apr/07/great-barrier-reefs-third-mass-bleaching-in-five-years-the-most-widespread-ever

[6] Deloitte Access Economics (2017, June 23). At what price? The economic, social and icon value of the Great Barrier Reef. Retrieved from https://www.barrierreef.org/the-reef/the-value

[7] IPCC (2018). Global Warming of 1.5°C: An IPCC Special Report on the impacts of global warming of 1.5°C above pre-industrial levels and related global greenhouse gas emission pathways, in the context of strengthening the global response to the threat of climate change, sustainable development, and efforts to eradicate poverty, Intergovernmental Panel on Climate Change.  Retrieved from https://www.ipcc.ch/sr15/

[8] World Population Review. (2023).  CO₂ Emissions by Country 2023. Retrieved 23 November 2023, from https://worldpopulationreview.com/country-rankings/co2-emissions-by-country

[9] Swann, T. (2019, July). High Carbon from a Land Down Under:  Quantifying CO2 from Australia’s fossil fuel mining and exports. Retrieved from https://www.tai.org.au/sites/default/files/P667%20High%20Carbon%20from%20a%20Land%20Down%20Under%20%5BWEB%5D_0_0.pdf

[10] Ritchie, H. (2019, October 4). Where in the world do people emit the most CO2? Retrieved from https://ourworldindata.org/per-capita-co2

[11] Statistica. (2023). Per capita carbon dioxide emissions worldwide in 2021, by country. Retrieved 23 November 2023, from https://www.statista.com/statistics/270508/co2-emissions-per-capita-by-country/

[12] Australian Government. (2022). Australia’s Nationally Determined Contribution: Communication 2022. UNFCCC Nationally Determined Contributions Registry. Retrieved 24 March 2023, from https://unfccc.int/sites/default/files/NDC/2022-06/Australias%20NDC%20June%202022%20Update%20%283%29.pdf

[13] Intergovernmental Panel on Climate Change (IPCC). (2023). Climate Change 2023: Synthesis Report. Contribution of Working Groups I, II and III to the Sixth Assessment Report of
the Intergovernmental Panel on Climate Change. Retrieved from https://www.ipcc.ch/report/ar6/syr/

[14] Australian Bureau of Statistics (ABS). (2008). 4613.0 - Australia's Environment: Issues and Trends 2007. Australian Bureau of Statistics. Retrieved 25 March 2023, from https://www.abs.gov.au/ausstats/ABS@.nsf/2f762f95845417aeca25706c00834efa/4FC4AA7DF35CC331CA2573C60010400D?opendocument#:~:text=Australia's%20net%20greenhouse%20gas%20emissions,were%20102.2%25%20of%201990%20levels.

[15] Climate Council (2022) Labor’s 2030 emissions targets must aim higher and go faster. Retrieved 4 June 2023, from https://www.climatecouncil.org.au/resources/labors-2030-emissions-targets-must-aim-higher/

[16] Climate Targets Panel (2021) Australia’s Paris Agreement Pathways: Updating the Climate Change Authority’s 2014 Emissions Reduction Targets. Retrieved 4 June 2023, from https://www.climatecollege.unimelb.edu.au/files/site1/docs/%5Bmi7%3Ami7uid%5D/ClimateTargetsPanelReport.pdf

[17] Meinshausen, M. (2019, March 19). Deriving a global 2013-2050 emission budget to stay below 1.5°C based on the IPCC Special Report on 1.5°C.  Retrieved from https://www.climatechange.vic.gov.au/__data/assets/pdf_file/0018/421704/Deriving-a-1.5C-emissions-budget-for-Victoria.pdf

[18] Tong, D., Zhang, Q., Zheng, Y., Caldeira, K., Shearer, C., Hong, C., Qin, Y., & Davis, S. J. (2019). Committed emissions from existing energy infrastructure jeopardize 1.5 °C climate target. Nature, 572(7769), 373-377. https://doi-org.ezproxy.newcastle.edu.au/10.1038/s41586-019-1364-3

[19]  Department of Climate Change, Energy, the Environment and Water (DCCEEW). (n.d.). Australia's National Greenhouse Accounts: Paris Agreement inventory. Retrieved 19 Nov 2023 from   https://greenhouseaccounts.climatechange.gov.au/

[20] 2022 Snapshot emissions profile – Ironbark Sustainability and Beyond Zero Emissions.

[21] Cox, L. (2020, Oct 12). Net zero emissions target for Australia could launch $63bn investment boom.  Retrieved from https://www.theguardian.com/australia-news/2020/oct/12/net-zero-emissions-target-for-australia-could-launch-63bn-investment-boom

[22] Deloitte Access Economics (2020, November) A new choice: Australia’s climate for growth.  Retrieved from https://www2.deloitte.com/content/dam/Deloitte/au/Documents/Economics/deloitte-au-dae-new-choice-climate-growth-051120.pdf?nc=1

[23] Department of Climate Change, Energy, the Environment and Water (DCCEEW). (2023). Net Zero, Australian Government Department of Climate Change, Energy, the
Environment and Water. Retrieved 23
November 2023, from https://www.dcceew.gov.au/climate-change/emissions-reduction/net-zero

[24] The Australia Institute. (n.d). Project Coal Mine Tracker. Retrieved 23 November 2023 from https://australiainstitute.org.au/initiative/coal-mine-tracker/

[25] IEA. (2021). Net Zero by 2050. A Roadmap for the Global Energy Sector. Retrieved from https://www.iea.org/reports/net-zero-by-2050

[26] Gardiner, S. (2001) The Ethical Tragedy of Climate Change: A Perfect Moral Storm. Oxford University Press, p. 143.

[27] Nguyen, J.M. (2021). Cosmopolitan Intergenerational Justice and Climate Change. [PhD thesis, University of California, Irvine]. eScholarship. https://escholarship.org/content/qt2h50d7p0/qt2h50d7p0.pdf?t=r052rd

[28] Schuppert, F. (2011) Climate Change Mitigation and Intergenerational Justice. Environmental Politics. Vol 20, No.3.. p. 307.

[29] Weiss, E.B. (2008). Climate Change, Intergenerational Equity and International Law. Vermont Journal of Environmental Law. Retrieved from https://scholarship.law.georgetown.edu/cgi/viewcontent.cgi?article=2637&context=facpub

[30] Committee on the Rights of the Child (2023). CRC/C/GC/26: General comment No. 26 (2023) on children’s rights and the environment with a special focus on climate change.  Retrieved 123 November 2023 from https://www.ohchr.org/en/events/events/2023/launch-general-comment-no-26-2023-childrens-rights-and-environment-special-focus

[31] UNICEF. (2021). The impacts of climate change put almost every child at risk.  Retrieved from https://www.unicef.org/stories/impacts-climate-change-put-almost-every-child-risk

[32] Save the Children. (n.d.).  The Climate Crisis: Climate Change Is a Grave Threat to Children’s Survival. Retrieved from https://www.savethechildren.org/us/what-we-do/emergency-response/climate-change

[33] Snowy Hydro. (n.d.) Hunter Power Project. Retrieved from https://www.snowyhydro.com.au/hunter-power-project/