Introduction

The Biodiversity Council welcomes the opportunity to provide feedback on Victoria’s draft Adaptation Action Plans 2027-31 (the draft Plans). Anticipating, preparing and responding to climate impacts is critical for all Australian States and Territories.

Adaptation action is inadequate in Victoria

In 2021, the Australian Business Roundtable for Disaster Resilience & Safer Communities has calculated that natural disasters will cost Australia $73 billion by 2060, under a low emissions scenario. Infrastructure Victoria notes that climate-related damage in Victoria could cumulatively cost at least $115 billion by 2030, and more than $986 billion by 2100, but this is likely to be an underestimate.

The 2025 National Climate Risk Assessment states that existing adaptation actions and programs are likely to be insufficient to protect against climate change: “overall there is an adaptation action shortfall across all systems, risks, jurisdictions and geographies in Australia".

This is not new. In 2022, the IPCC’s Australasian chapter noted:

A step change in adaptation action is needed to address climate risks and to be consistent with climate resilient development. Current adaptation falls short on the assessment of complex risks, implementation, monitoring and evaluation. It is largely incremental and temporary given the scale of projected impacts; it has limits and is mainly reactive rather than anticipatory.

There is a significant gap between the findings and recommendations emerging from scientific papers and reports, and the approach of governments to climate change adaptation. Moreover, despite the scale of impacts, there is significant underinvestment in adaptation.

The Australian Institute for Disaster Resilience has estimated that ‘for every one dollar invested in resilience before a disaster, we can save between $3 and $8 in recovery’. This is consistent with international estimates for adaptation investment - the World Economic Forum has calculated that for every $1 spent, there are $2-$10 in benefits while the World Resources Institute estimates it is 10:1.

Victoria's underinvestment in adaptation is alarming. According to the Department of Energy, Environment and Climate Change Action ‘s Corporate Plan 2025-29, of their total departmental funding of $2.6 billion, just $18.4 million or 0.7% is spent on ‘Climate Action’ despite being the department dedicated to it.

It is important to note that Climate Action ‘leads the whole-of-government delivery of Victoria’s climate action’, which includes ‘net zero emissions, climate-ready economy and community’, in other words, both mitigation and adaptation. The Victorian Parliamentary Inquiry into Climate Resilience found that stakeholders identified gaps in implementation and funding for resilience and adaptation initiatives. The Victorian Government’s response notes billions of dollars have been invested in ‘climate change’. However the Parliamentary Inquiry notes that only a very small amount goes to adaptation.

This stands in sharp contrast to New South Wales’ Climate Change Fund which spent almost $162 million in 2024-25 to ‘increase community resilience and safeguard our communities from the effects of climate change’ (with additional funds for mitigation and energy bills).

Adaptation is treated as a nice-to-have as it comes in and out of vogue in Australia. It has fallen victim to political cycles which have stalled policy development and research. Australia has world-leading adaptation expertise, but key programs have been defunded or dismantled (such as CSIRO’s climate Adaptation Flagship 2008-2014 and the National Climate Change Adaptation Research Facility 2008-2019).

This is true of Victoria as well; with the government funding and initiating adaptation work prior to COVID-19, but discontinuing and or defunding programs post the pandemic. For example, the Regional Adaptation Strategies developed over four years with more than 8,000 Victorians involved were a once-off, from 2020-2025. Despite being the ‘centrepiece’ of the $9.32 million Supporting Our Regions to Adapt program funded by the Sustainability Fund, they are not continuing. Similarly, in 2021, delivered a one-off training program for Victorian local government councillors and executives on climate change risk and adaptation.

It is critical that climate adaptation is prioritised and receives sustained funding. Without this, capability and climate literacy are likely to be lost, organisational capacity is reduced (as experts including scientists, consultants, government and industry specialists move on to other problems), and community engagement breaks down (for instance, there can be loss of trust and communities become apathetic as their contributions don’t lead to action).

Confronting the significant impacts of climate change and implementing successful adaptation actions requires deep engagement with stakeholders that considers their local values and contexts. This requires supportive governance, capability and funding to work. The Victorian Council of Social Service (VCOSS) has undertaken research with the University of Melbourne regarding the vulnerability of communities to climate change. VCOSS is calling for transformative adaptation which dismantles barriers to adaptation and shifts the burden from individuals towards systems-level adaptation.

The National Climate Risk Assessment identified a range of governance problems in climate adaptation across Australia including inadequate collaboration across government, ambiguity in roles and responsibilities, inadequate resources, inadequate engagement, and being slow to adapt to the pace of change. These systemic issues are not being addressed.

The IPCC notes that climate impacts are cascading, compounding and aggregating across sectors and systems due to complex interactions. The Department of Home Affairs 2018 report, Profiling Australia’s Vulnerability notes:

There is little knowledge or understanding amongst decisionmakers and the general public of how complex and highly dynamic systems interact across our society. Extreme events create systemic shocks that disrupt these systems and quickly cascade to overwhelm the capacity of social, economic and natural systems to cope.

The draft Adaptation Action Plans

In 2022, Victoria was considered to have a strong, comprehensive and complex climate policy package,5 the current iteration of the Victorian Government's Climate Adaptation Action Plans reveals a significant decline in quality, detail, and accountability.

There are fundamental flaws across all plans:

• no vision, objectives or outcomes
• insufficient detail on how adaptation efforts have progressed, gaps and future challenges
• no detail on responsibilities or timeframes for actions
• no reporting on implementation or effectiveness of previous plans (required under s.35 of the Climate Change Act 2017).

Furthermore, climate risks remain siloed, ignoring complex cross-system impacts across natural, social, and infrastructure portfolios. The plans fail to address systemic issues.

Our key concerns are listed below. Please read the full submission for more detail.

1. There is no evaluation of the 2022-25 plans and the Victorian Government is not compliant with s.35 of the Climate Change Act 2017
2. The plans lack detail on accountability and implementation
3. Cross-system risks not adequately addressed
4. There doesn’t appear to be any funding to support implementation