Home / ASMC Policy Priorities / Policy Positions & Submissions

Policy Positions & Submissions

ASMC prepares written submissions on a range of relevant policy, regulatory and legislative topics on behalf of our members. 


Submission to the Eco-Markets Australia consultation process on proposed amendments to the Reef Credit Scheme v2.1 | 7 May 2024

The ASMC in its submission to Eco-Markets maintains its position that the Reef Credits Scheme remains problematic due to its singular focus on environmental pursuits and because the incentives are not aligned to or seek to reinforce current industry best practice approaches – especially for DIN (dissolved inorganic nitrogen) abatement in the sugar industry.

The ASMC would like to see the objectives of the Reef Credits scheme as outlined in the draft Guide and Standard documents broadened to include references to:

  • The balanced pursuit of the four pillars of sustainability, and
  • Alignment and integration of broader and complementary industry approaches into the Scheme.

The full submission can be found here.


Submission to the Senate Rural and Regional Affairs and Transport Legislation Committee on the proposed Biosecurity Protection Levy | 12 April 2024

While the ASMC supports the sustainable management of Australia’s biosecurity systems, the BPL is fundamentally flawed as it stands, as:

  • Industry is being asked to further fund a biosecurity system that is likely to stay flawed, with funding not being linked to various recommended reviews of the system (e.g. Craik Review);
  • the entire Australian community benefits, not just the agriculture industry;
  • Other competing global jurisdictions support and subsidize their sugar industry, whilst the BPL places an unaffordable tax on a vulnerable, export orientated industry; and
  • The industry already makes a significant contribution to the biosecurity system through funding by sugar producers for the Emergency Plant Pest Response Deed and industry contributions of approximately $5 million per annum for biosecurity to Sugar Research Australia. Read More

ASMC submission to the Electricity and Energy Sector Decarbonisation Plan | 11 April 2024

The sugar manufacturing can provide up to 1,053 ML of ethanol, which can create enough SAF to meet 8% of Australia’s domestic aviation fuel needs, and a carbon abatement potential of 1.7 million tonnes per annum. Alternatively, feedstock can be dedicated to cogeneration capacity, increasing the sector’s electricity generation capacity from 440 MW to 1068 MW of installed capacity (enough to power 850,000 homes if fully utilised), with a 1.17 million tonne annual carbon abatement potential. However, there are significant operational, market and regulatory constraints that can only be addressed through government intervention and regulatory changes. Read More

ASMC Federal Pre-Budget Submission 2024-2025 | 25 March 2024

The ASMC submission puts forward a progressive agenda to ensure opportunities in renewable, synchronous electricity cogeneration and biofuels are captured, and ensure a credible sustainability pathway for the sector to ensure our future market access. Read More

Submission to the Department of Infrastructure, Regional Transport and Regional Development on the Aviation Green Paper | 30 November 2023

With access to feedstock, technology, capital and infrastructure, the sugar milling sector is
well-equipped for to invest in additional biofuel supply and capacity – including SAF. Sugar manufacturers provide early opportunities to develop biofuel supply chains noting our existing experience and capabilities in producing biofuels. Read More

Submission to the Queensland Government’s 2023 State Budget | 16 November 2023

The ASMC seeks a commitment for the following policy and funding measures:

  • Improved Government forecasting and public messaging of current and likely skills deficits and a more flexible and demand responsive vocational training framework;
  • Improved co-ordination of State Government land releases to encourage affordable housing in regional Queensland;
  • An Infrastructure partnership program to improve the efficiency and public safety and environmental benefits of the Queensland cane rail network;
  • Additional financial assistance for co-generation feasibility assessments:
  • Financial support to identify least-cost carbon abatement opportunities in milling; and
  • Financial assistance for bio-fuel R&D and commercialisation projects. Read More

Submission to Australian Energy Market Commission on enhancing investment certainty in the R1 process | 22 September 2023

The ASMC submission:

  • Supports the Clean Energy Council view that the regulatory processes for generation connections (new and existing) are lengthy and costly and reforms to the rules are urgently required;
  • Supports amending the rules to achieve a more workable balance between grid reliability and regulatory efficiency;
  • Does not support the scope of the reform which is just variable renewable inverter-based technologies; and
  • Supports rule changes that accommodate the unique operating requirements and specific concerns of the sugar manufacturers regarding the current generator approval processes. Read More

Submission to QRIDA on the Proposed changes to the Primary Industries Productivity Enhancement (PIPE) Scheme  | 5 September 2023

The ASMC seeks more flexibility with the proposed PIPE scheme.  Read More

ASMC has made a submission to the Department of Energy and Public Works regarding the Sustainable liquid fuels strategy  | 14 August 2023

ASMC submission details that, for Queensland to take advantage of the very significant emerging opportunities for substitute bio-fuels, there must be a suite of integrated Queensland and federal policies that support production scale to reduce price gaps. This is likely to require demand side interventions such as progressive and enforceable mandates as well as supply side support for ongoing technology innovation and demonstration and other production incentives.
There are also regulatory constraints to mills investing in bio-fuels and for industry to expand sugarcane and bio-fuel feedstock supply that are unique to the sugar industry that also require solutions. Read more

ASMC has made a submission to the Department of Climate Change, Energy, the Environment and Water in regards to Renewable Electricity Certification  | 6 February 2023

ASMC supports an enduring renewable energy certificate mechanism to support and create value for existing and new low emissions industries to support Australia’s renewable transition.  ASMC believes that proposed REGO framework will have an important role to play in assisting the market attribute a value on the externality benefits (environmental, economic and social) of various low emissions technologies. Read more

ASMC’s response to the AEMO Draft 2022 Integrated System Plan (ISP)
| 16 February 2022

ASMC responds to Australian Energy Market Operator’s (AEMO’s) Draft Plan addressing two specific matters:

  • The absence in the ISP of the (bagasse) co-generation potential of the Australian sugar industry and the associated consumer and network benefits; and
  • The absence in the ISP of a credible approach to addressing variable renewable energy (VRE) social licence matters, including conflicting land-use. Read more

ASMC evaluation of the FIRB framework following the implementation of the 2021 reforms | 31 August 2021

ASMC’s submission offers a number of suggested changes to the framework for Government’s consideration which would foster changes in land ownership, improve the productive and economic efficiency of cane growing and raw sugar manufacturing in Australia, and encourage employment growth and regional development. Read more.

Inquiry into the current circumstances, and the future need and potential for dispatchable energy generation and storage capability in Australia | 10 May 2021

ASMC’s submission to the Standing Committee on the Environment and Trade focuses on:

  • ASMC’s understanding of Australia’s (the National Energy Market’s (NEM’s)) future dispatchable capacity needs;
  • The Australian sugar industry’s ability to triple its supply of zero to low emission semidispatchable power from current, but highly under-utilised bagasse feedstock; and
  • Barriers to fully utilising this latent bagasse supply for power generation Read more

ASMC response to the Queensland Productivity Commission’s  Improving Regulation Research Paper | 31 March 2021

ASMC welcomes the opportunity to outline our current priorities of government in relation to improving the policy and regulatory environment; to present the findings of our 2019 analysis into the industry’s
regulatory burden; and provide our views on how government regulation could be further improved. Each is outlined in detail Read more

For a copy of the ASMC and McCullough Robertson Lawyers Regulation Overload report click here

Consultation on the Environmentally relevant activity (ERA) standard for Commercial cropping and horticulture in the Great Barrier Reef catchment (prescribed ERA 13A) and the updated draft standard conditions for new or expanded commercial cropping and horticulture activities in the Great Barrier Reef catchments under the Reef protection regulations | 16 February 2021

This submission is provided by the Australian Sugar Milling Council (ASMC) in response to consultation by the Queensland Government’s Office of the Great Barrier Reef, on the updated draft standard conditions for new or expanded commercial cropping and horticulture activities in the Great Barrier Reef catchments under the Reef protection regulations.
Read more

Inquiry into expanding membership of the Comprehensive and Progressive Agreement for Trans-Pacific Partnership (CP-TPP) | 5 February 2021

ASMC outlines the importance of Government vigorously pursuing new and revised bi-lateral and multi-lateral free trade agreements as a source of comparative advantage for Australian sugar exports. Read more

Response to Consultation Paper on the Australian Energy Market Commission (AEMC) National Electricity Rules (NER) Amendment (Generator Registrations and Connections) Rule | 22 December 2020

ASMC believes the proposed rules will only serve to increase regulatory burden, resulting in a less efficient market by limiting the choice of available generation for investment and undermining the important role incidental generation plays in sugar milling. Read more

Senate Inquiry into Foreign Investment Reform (Protecting Australia’s National Security) Bill 2020 and the Foreign Acquisitions and Takeovers Fees Imposition Amendment Bill 2020 | 7 November 2020

In the face of increasing competition for mobile global capital, ASMC believes it is crucial that Australia implements a FIRB regime that is: clear and supports decision certainty; is flexible so that higher risk transactions are targeted through careful policy and legislative design; is streamlined with low transaction costs; and that penalties are commensurate to the risk to the national interest and offence. Read more

Energy Security Board (ESB) Consultation Paper and Draft Rules – Interim Renewable Energy Zone (REZ) Planning | 8 September 2020

ASMC remains concerned that the mechanisms designed to protect Good Quality Agricultural Land (GQAL) from competing uses and that promote mill viability, will become increasingly compromised under the proposed REZ planning framework. ASMC’s concerns and two suggested remedies – an “equally viable locational requirement” and a “minimum public consultation requirement” are outlined – Read more.

Joint ASMC/CANEGROWERS Submission to JA-EPA Review | 13 August 2020

ASMC states that 2 important steps could be taken to reinvigorate the now largely redundant Japan Australia Economic Partnership Agreement (JA-EPA was superseded for sugar by CP-TPP provisions) and restore its relevance for Japan’s purchases of Australian hi-pol raw sugar: i) reduce import levies to levels below the terms of CP-TPP & ii) address a technical issue associated with product testing. Read more

Joint ASMC/CANEGROWERS Submission on ChAFTA (China Australia Free Trade Agreement) Post-Implementation Review | 4 August 2020 

The submission focuses on raw sugar’s exclusion from the agreement and the industry’s ongoing desire for improved, preferential access. It also outlines concerns over the non-tariff barrier in relation to the requirement for exports of Australian raw sugar to be accompanied by a phyotosanitary certificate, the only importing country to demand this measure. Read more

Submission to the ARENA Bioenergy Roadmap | 10 June 2020 | An analysis of the potential and constraints to bioenergy diversification of the Australian sugar industry.

ASMC urges development of a National Bioenergy Roadmap that provides a clear vision and objectives. Our analysis demonstrates that under the right commercial and policy settings, total ethanol production from molasses could increase from 60 ML to 216.25 ML per annum and total bagasse cogenerated electricity production could increase from 0.9 million MWh to 2.86 million MWh per annum. Relative to current consumption patterns and fuel uses, the annual estimated greenhouse gas savings under both scenarios would be 348,000 and 1,948,702 tonnes CO2-e respectively. Read more

Inquiry into Diversifying Australia’s Trade and Investment Portfolio | Joint Standing Committee on Trade and Investment Growth | 23 April 2020

It is crucial in the face of growing trade protectionism and increasingly mobile global capital that Australia continues to diversify its trade markets and encourage foreign direct investment (FDI). Read more

A review of government regulations impacting the Australian Sugar Industry and their implications for industry revitalisation and long-term sustainability | February 2020

ASMC asked its most experienced milling company executives to assess the impacts of the 21 interventions against four regulatory metrics. Their scores were tallied and averaged to create a ranking from ‘most’ to ‘least’ burdensome. Respondents also indicated how each intervention impacted the three Revitalisation pillars promoted by the ASMC. Read more

Review of regulated retail electricity prices for 2020/21 | Queensland Competition Authority | 13 January 2020

Per the government’s delegation to the 2020-21 price review, ASMC welcomes the stated commitment of delivering lower electricity bills and the adoption of the various initiatives in the QCA Interim paper.  ASMC  remains concerned however about the increase in the miller and grower regulated tariffs over the past period and the non-affordability of these tariffs (and subsequent impacts) during the current deep trough in global sugar prices. Read more

ASMC also made the following policy submissions in 2019:

Inquiry into Modernising the Research Development Corporation (RDC) system | Department of Agriculture 19 December 2019 | Read more

Inquiry into supporting Australia’s exports and attracting investment  Joint Standing Committee on Trade and Investment Growth | 23 September 2019 |  See more

Environmental Protection (Great Barrier Reef Protection Measures) and Other Legislation Amendment Bill 2019 | Innovation, Tourism Development and Environment Committee 15 March 2019 | See more 

Earlier ASMC submissions from 2018 and 2019 are available to read here