Submission to the Independent Review of the Victorian Climate Change Act 2010
The submission has been prepared in the context of the Business Council’s energy and climate change vision and policy principles.
It argues that the independent review of the Victorian Climate Change Act 2010 should adopt a best practice approach to reviewing regulations and programs, including:
• the use of comprehensive cost–benefit analysis, collection of data and other evidence to provide the justification for legislative change
• the consideration of pathways, other than legislation, to achieve the outcome being sought and assess costs and benefits of such pathways relative to legislation
• ensuring regulations are only introduced where there is clear evidence of a continuing market failure and where the costs of the market failure outweigh the costs of the introduction of additional regulation
• where there is state-based climate change legislation, ensure it is consistent with national legislation, minimises variations between jurisdictions and is only enacted to address clear gaps or unique state circumstances
• any new measures including possible state-based emissions reduction targets or renewable energy initiatives should not be proceeded with until a comprehensive cost–benefit analysis is completed, the interaction with national emissions reduction targets is assessed and extensive consultation with the community, including business, is undertaken.