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Policy Positions & Submissions

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

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