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Policy Submissions

We prepare written submissions on a range of relevant policy, regulatory and legislative topics to advocate on behalf of our members .

15 March 2019 ASMC submission to the Innovation, Tourism Development and Environment Committee on the Environmental Protection (Great Barrier Reef Protection Measures) and Other Legislation Amendment Bill 2019

ASMC has acknowledged in earlier submissions on this matter that all sugar industry stakeholders need to do more in terms of reducing the impact of farming activities on reef water quality. We believe the best way to do this is in a true partnership approach between industry, government and community stakeholders. Any measures introduced need to have a clear and positive impact on the sustainability of the stewards who manage the land and natural resources in the GBR catchments. Negatively impacting the business viability of local sugarcane growers will threaten their capacity to optimally manage their operations, and in turn significantly affect the viability of sugar milling areas. Subsequent mill closures would result in major social, environmental and economic setbacks for GBR catchment communities. See more 

26 November 2018 Joint ASMC and CANEGROWERS submission on an EU Australia Free Trade Agreement (FTA)

In the protected global sugar market, the Australian sugar industry seeks preferential, duty-free trade deals to broaden its market opportunities and ultimately, to increase the demand for, and value of, Australian high-quality sugar.

The proposed Australia Europe FTA represents an opportunity for Australia to considerably improve our Tariff Rate Quota to this market. The current TRQ of 9,925 tonnes is commercially insignificant. The punitive in-quota CXL duty of €98/tonne means it is uneconomic to fill this quota and the quota is currently unfilled. . The proposal to split this between the EU-27 and UK would further reduce the commercial viability of the quota, making supply to this market unfeasible.

The combination of Australia’s freight cost disadvantage and high CXL tariff rates, and the preferential duty treatment now (and potentially) given to competitive suppliers under recently negotiated bi-laterals, means Australia is currently not competitive on a straight best return basis into this market.

There are however a number of trends in the EU sugar market that in conjunction with a meaningful TRQ and Australia’s strong supply characteristics (high reliability and consistency and quality of product) would significantly improve Australia’s competitiveness and attractiveness to EU sugar refiners See more

15 October 2018Supplementary Submission on the Federal Review of the Sugar Code of Conduct 

In this supplementary letter, ASMC comments on specific issues raised in other submissions to the review See more 

 3 October 2018: Joint Standing Committee on Foreign Affairs, Defence and Trade inquiry into access to trade agreements by small and medium sized enterprises

Recommendations to improve the global marketability of Australian sugar

  • The ASMC seeks repeal of those provisions of the Act and Code that regulate who can market sugar (the so-called marketing choice) and the right of a third party to control decisions usually vested between commercial entities (the so-called pre-contract arbitration provisions). Repeal would reduce sovereign risk and encourage greater investment as well as improve marketing efficiencies.
  • A further escalation of Australian Government representations to the Indian Government, and to canvass support from like-minded sugar exporting nations, including Brazil, to seriously consider pursuit of action against India at the WTO.
  • Seek to re-negotiate access opportunities into China and the US and an ambitious duty-free quota into the EU-27 and the UK post BREXIT.
  • For the Australian government to work with the Australian sugar industry as it develops its Industry Trade Strategy over the coming 12 months. The strategy will use quantitative and qualitative analysis to identify market opportunities most likely to maximise export revenues over the coming five years.  Over time, the ASMC would seek to align our commercial and policy efforts to these identified markets see more

22 August 2018: Federal Review of the Sugar Code of Conduct 

ASMC believes the Sugar Code of Conduct has only added uncertainty, complexity and cost to sugar industry operations. It has deterred investment, and undermined competitiveness see more

13 July 2018: Energy Security Board’s National Energy Guarantee: draft Detailed Design Consultation Paper 

ASMC’s submission examines the implications for the sugar milling industry and makes recommendations for improvements. Sugar mills are self-sufficient in electricity, and industry co-generation adds significant value to the environment and local economies as:

  • electricity production uses cane waste from the milling process (bagasse) to generate renewable energy
  • the synchronous, high inertia generators support local network operations in relatively remote parts of the electricity network characterised by low system strength, and as
  • an invaluable source of revenue to maintain viability of the mills (especially during periods of low sugar prices such as currently being experienced) see more

 6 July 2018: Senate Select Committee Inquiry into Obesity  from Australian Sugar Industry Alliance 

Obesity is clearly a problem in Australia .  As sugar growers and producers, we are concerned about over-consumption of sugar by some in the community. We believe sugar can play a role in a balanced diet, and we certainly do not want our products to result in harm.Rather than singling out sugar as the major ‘cause’ of the problem, we believe the focus needs to be on measures that change behaviour, particularly for people who are already overweight or suffering from a lifestyle/non-communicable disease see more

19 June 2018: Review of the Queensland Energy Legislation – Issues Paper

To promote the viability of the Australian sugar industry and the objectives of clean, reliable and affordable energy, ASMC believes state policies and legislation should facilitate lower delivered energy costs by:  promoting greater competition in the generation, transmission, distribution and retailing of energy, and in the absence of effective competition, and providing for price intervention and controls that replicate competitive market outcomes. State policies should also facilitate an increase in the supply and flexible consumption of cogenerated electricity by:

  • removing federal and state duplication
  • increasing the speed of administrative processing of approvals (potentially through the imposition of minimum time periods)
  • providing for the ability to enter into a preferential supply arrangement with cane growers e.g. at the cost of supply, through more flexible retailing controls, and by
  • promoting investment certainty by imposing legislative requirements on third-parties to fund upgrades to the grid when new supply is likely to exceed agreed export capacities nominated see more see more

11 May 2018: Queensland solar farm guidelines: Practical guidance for communities, landowners and project proponents 

ASMC members are strong supporters of renewable energy.  Sugar mills are self-sufficient in energy, burning the renewable sugar processing by-product, bagasse to generate electricity and steam for milling operations.  Up to 50% (500 GWh) of the electricity generated annually is exported to the grid, providing power for the equivalent of 170,000 Queensland homes.Our key concerns relate to ongoing commitments to:

  • protect “Good Quality Agricultural Land” (GQAL) 
  • honour existing legislation and the planning instruments against which the sugar milling industry has made long-term investment decisions
  • consider the flow-on effects on business, like sugar mills, in the areas surrounding a proposed solar farm, and to
  • consider the cost/benefit implications on local businesses and community members when selecting sites e.g. proximity to grid connection points See more