Download HOUSING - Victorian Council of Social Service

VCOSS response to the Victorian Climate Change White Paper and
Climate Change Bill
1. Summary
The Victorian Climate Change White Paper (White Paper) and Climate Change Bill (2010) are
important steps to position Victoria to both substantially reduce our greenhouse gas emissions and
to adapt to the unavoidable impacts of climate change on our economy, health and communities.
The White Paper contains a number of significant commitments to reducing Victoria’s emissions,
planning for adaptation and assisting communities in these transitions. However, the real challenge
will be in the implementation of these high level goals in ways which ensure costs, risks and
opportunities associated with climate change are distributed equitably across the community.
Achieving equitable implementation will be the focus of VCOSS advocacy as the Victorian
Government develops its more detailed implementation plan.
VCOSS welcomes substantial commitments within the White Paper and Climate Change Bill (2010)
including:

a legislated greenhouse gas emissions reduction of 20 per cent (on 2000 levels) by 2020;

inclusion of equity and community participation as key principles in the Climate Change Bill;

upgrading of Victoria’s existing housing stock to achieve an average of 5-star standard by
2020, including through providing retrofitting support to low income households;

development of a statewide Climate Change Adaptation Plan;

inclusion of climate change in government decision making;

ongoing review of emergency services capacity to respond to extreme weather events; and

support for affected communities including small towns and the LaTrobe Valley.
Financing
How these measures are financed will be a key factor to consider in ensuring fair implementation of
these commitments. VCOSS is concerned to ensure that financing equitably distributes the cost of
transition throughout the community and does not disproportionately impact on low income and
vulnerable communities. For example, while reducing greenhouse gas emissions is important and
welcome, the Government needs to ensure that all households retain access to affordable energy
and water by applying fair pricing principles and ensuring that utility concessions hold their value.
Omissions
A number of critical areas of climate policy were also not directly mentioned in the White Paper or
Bill, creating a risk that important further work will stall. These include:

an absence of direct commitment to measures or further planning to address the impact of
climate change on health and wellbeing, including in the critical area of heatwave;

a lack of investment in community development based approaches to emergency
preparation and recovery;
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
lack of support for community organisations to prepare for and address the impacts of
climate change – including extreme weather - and associated increases in the costs of
service delivery;

no clear mechanism to ensure a strong whole of government approach to adaptation which
includes all relevant government departments;

the exclusion of critical planning legislation from the proposed Climate Change Bill (2010);
and

an absence of transport emission reduction measures that will benefit low income
households in transport poor areas.
2. Victoria back as a leader in reducing greenhouse gas emissions
In the absence of national action to address climate change, the Victorian Government has stepped
up to the challenge by committing to introduce a legislated emissions reduction target of 20 per cent
on 2000 levels by 2020.
VCOSS welcomes this strong commitment to addressing climate change. Now the challenge is to
ensure that the costs and benefits of achieving this target are fairly distributed across the Victorian
community. Measures are needed to shield low income and disadvantaged households from rapidly
rising energy and water costs, including adequate concessions, assistance to improve the efficiency
of their homes and energy pricing and infrastructure financing mechanisms that do not simply pass
the cost of new infrastructure into energy charges.
3. Increasing the efficiency of Victorian homes
The White Paper commits to a target of increasing the efficiency of Victoria’s existing housing stock
to an average 5-star rating by 2020 from a current average of 1-2 stars. As previously announced
through the Jobs for the Future Economy statement, all new Victorian homes will be built to a 6-star
standard from May 2011.
To achieve this goal, the White Paper outlines actions including:

doubling the target of the Victorian Energy Saver Incentive;

expanding the range of eligible energy efficiency activities under this scheme; and

delivering a comprehensive retrofitting program including support for low income
households and public housing tenants.
VCOSS believes that additional action will be required to meet the average 5-star target and to
ensure that this investment in household efficiency benefits those who need it most. As 24 per cent
of all Victorian households are renters – and 50 per cent of low income households – the private
rental sector is one critical area where further action will be needed to achieve the 5-star average.
This action should include:

phased introduction of mandatory minimum rental standards for public and private rental
properties to drive the uptake of energy and water efficiency;

a one off additional investment to fund retrofitting of public and social housing to meet
these standards; and

targets for delivery of the Victorian Energy Saver Incentive to low income households.
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4. Climate change in government decision making
The Climate Change Bill introduces requirements for climate change to be a consideration in some
areas of government decision making including in planning approval processes administered by the
Environmental Protection Agency (EPA).In particular, the Government has indicated that the new
powers granted to the EPA could be used to limit greenhouse gas emissions from new power plants.
The Bill also requires the development of a statewide Climate Change Adaptation Plan and a Climate
Report to track Victoria’s progress and document developments in climate change research and
knowledge.
While these are important commitments, strong requirements are also needed to consider both
climate change mitigation and adaptation in other areas of government decision making, especially
in the areas of planning and major infrastructure as well as service delivery.
While the decision making provisions outlined in section 14 of the Bill are relatively comprehensive
and include ‘long and short term economic, environmental, health and other social impacts’, ‘direct
and indirect impacts’ and ‘cumulative impacts’ they are restricted to specified decisions under a
limited selection of Victorian legislation.
VCOSS is concerned that critical pieces of legislation are excluded from the proposed Climate Change
Bill including:
 the Planning and Environment Act (1987), and

the Major Transport Project Facilitation Act (2009).
This presents the risk that government decisions critical to addressing climate change such as those
related to major transport projects, planning of new developments, urban density and significant
infrastructure will not be covered by decision making requirements that compel changes in practice
from business as usual.
Without setting new infrastructure and development on a pathway to reducing emissions, there is a
risk that the future cost of building in efficiency and the capacity to withstand a harsher climate will
be higher. In addition, there is a risk that public investment will be sunk into long-lived infrastructure
that will not serve the Victorian community well in a changing climate and a carbon constrained
economy. This will then transfer a significant burden onto other areas of the economy to reduce
emissions in order to meet Victoria’s emission reduction targets of 20 per cent on 2000 levels by
2020.
Extending the proposed Climate Change Bill to cover critical legislation and strengthening the
requirements to consider climate change in government decision making will help ensure that the
costs of meeting the challenge of climate change are reduced in the long run.
5. Adapting to unavoidable climate change
Victoria is on the front line of climate change impacts – facing higher temperatures, more
heatwaves, more frequent and severe bushfires, drought and storms. As the climate changes,
households, businesses and services will have to adapt. Low income and disadvantaged households
may have less capacity to make these changes and may face complex barriers to avoiding the
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impacts of climate change. In addition, it is essential that our public infrastructure, essential services,
health system and community facilities adapt in ways which ensure service delivery and are
economically efficient to minimise the drain on public funds.
VCOSS welcomes the announcement of a statewide Climate Change Adaptation Plan to be
developed by 31 December 2012 and to be renewed every four years thereafter. VCOSS also
supports the commitment to providing information to support local adaptation for Victorian
industries and communities through the Climate Change Preparedness Program. In particular,
support for adaptation planning for small towns is welcome, particularly if it is well integrated with
broader regional development and adaptation policy.
It will be critical to ensure that the statewide Climate Change Adaptation Plan addresses issues of
equity and barriers to adaptation for different parts of the Victorian community. This will require the
plan to be a ‘whole of government’ policy process linked to clear recommendations for government
action and funding to ensure that these actions can be achieved. This will require capacity across all
relevant government departments to fully participate in both the development of the plan and its
implementation.
6. Health and wellbeing overlooked
VCOSS is particularly concerned that the health impacts of climate change on Victorian communities
are not directly addressed in the White Paper. The Victorian Climate Change Green Paper (Green
Paper) outlined the serious challenges of climate change to the health of Victorian communities and
acknowledged that:
‘the adverse health impacts will be greater among people on lower incomes, the elderly, people
with disabilities and the sick.’
There are currently significant gaps in our understanding of the local health impacts of climate
change and the drivers of poor health outcomes and inequalities related to climate change in
Victoria. Research to address these information gaps and associated policy development was begun
by the Department of Human Services /Department of Health following the Our Environment, Our
Future: Sustainability Action Statement 2006. However this work has received no further funding and
has now stalled.
VCOSS is concerned that if this work is not continued other objectives of the White Paper will be
compromised. In particular, relevant local knowledge about the impacts of climate change and their
distribution across Victorian communities will be essential to develop meaningful municipal and
state public health and wellbeing plans, given that these will be subject to the climate change
decision making requirements outlined in the Climate Change Bill. VCOSS also expects that health
will be a major theme of the statewide Climate Change Adaptation Plans and that without accurate
local information these will also be ineffective.
The White Paper includes a commitment to expand Community Registers which enable vulnerable
community members to be contacted or monitored during an emergency. While VCOSS believes that
registers can be a useful tool in identifying people who may require assistance in extreme weather,
they do not in themselves deliver any support or assistance. A plan that maps out how people
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identified on registers are to receive essential supports in emergencies will be needed to
complement the registers.
7. Heatwave
In the summer of 2009, at least 374 people are estimated to have died as a result of heatwave and
Victoria’s health and emergency services were placed under intense strain. In response to this event,
and building on work already undertaken by the Department of Human Services, Victoria developed
the Statewide Heatwave Plan and provided funding to local governments to develop heatwave
strategies.
This was the first step in ensuring that vulnerable Victorian communities are at less risk of extreme
heat which is predicated to become more frequent as the climate changes. However, further funding
is needed in order to:

review and improve these plans;

practically support vulnerable community members;

build the capacity of at risk communities to prepare for and recover from heatwave; and

address the root causes of heatwave vulnerability.
This is a significant gap to be urgently addressed.
8. Transport
The transport initiatives outlined in the White Paper include:

further support for the Victorian automotive industry to develop electric vehicles;

a commitment to purchase locally manufactured hybrid vehicles for the Victorian
Government fleet;

advocating through the National Energy Efficiency Strategy for better vehicle emissions
standards;

reduced registration fees for hybrid and electric vehicles and the establishment of a
voluntary vehicle emission offsets program.
These initiatives will not directly benefit low income households struggling with the costs of multiple
car ownership in Melbourne’s public transport poor outer suburbs. In addition, exclusion of the
Planning and Environment Act from the Climate Change Bill limits the contribution that urban and
regional planning can make to meeting Victoria’s emission reduction targets.
Section 73 of the Climate Change Bill amends the Transport Integration Act (2010) to include
stronger requirements to consider reductions of greenhouse gases and adaptation to climate
change. This indicates that future government decision making in transport, including future reviews
of the Victorian Transport Plan, will need to consider climate change.
Lower emissions and improved adaptation for low income communities could be achieved by
delivering improved public transport links in communities on the urban fringe and through better
integrating public and school bus services in rural and regional Victoria.
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9. Supporting government funded services to transition to a low
carbon economy
The White Paper announces a further investment of $100 million in the Greener Government
Buildings Program (in addition to $60 million announced earlier in the 2010). This investment in
efficiency of government services is an effective use of public money to minimise long term
recurrent costs. Undertaking a similar investment to upgrade wider community services
infrastructure would also reduce long term costs and would carry significant social co-benefits.
Currently, community service organisations struggle to have adequate capital to commit to
improving the efficiency of properties. A rolling fund to provide capital for investment in efficiency
for community service organisations would help guard against rising operational costs while
reducing emissions, and would provide further jobs in emerging efficiency industries.
10.
Support for community action on climate change
VCOSS welcomes the inclusion of Climate Covenants under the Climate Change Bill as a mechanism
for formalising and supporting regional, sectoral and community level climate change initiatives.
Similarly, further commitment of funds to the Climate Communities program creates opportunities
for local initiatives which reduce the impact of climate change on low incomes households and
community organisations.
Climate change and the transition to a low carbon economy present many challenges that will affect
some Victorian communities more than others. VCOSS commends the announcement of the LaTrobe
Valley Advantage Fund and skills program which will reduce the impact of necessary changes to
Victoria’s coal fired electricity system. This support needs to also be made available to other
communities affected by the impact of climate change and related economic restructuring.
11.
Where to from here
The Victorian Government has committed to release a more detailed implementation plan for the
Climate Change White Paper. VCOSS intends to continue working with government on mechanisms
to fairly distribute the costs of these commitments across the community and better address the
needs of low income and disadvantaged communities.
In order to meet the commitment to an average 5-star standard for Victoria’s existing housing stock
by 2020 VCOSS will advocate for:

phased introduction of minimum rental standards for public and private rental to drive the
uptake of energy and water efficiency;

a one off additional investment to fund retrofitting of public and social housing to meet
these standards; and

targets for delivery of the Victorian Energy Saver Incentive to low income households.
To ensure that Victoria is able to equitably meet, and exceed, the proposed target of 20 per cent
reduction on 2000 levels by 2020 VCOSS will advocate for:
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
financing mechanisms which ensure the fair distribution of the costs of these commitments
across the Victorian community, including through fair pricing and maintaining the value of
utility concessions;

extension of the Climate Change Bill to include the Planning and Environment Act (1987), the
the Major Transport Project Facilitation Act (2009) and other relevant legislation;

review of the Victorian Transport Plan to further prioritise public and active transport; and

investment in the energy and water efficiency of government funded community services to
mitigate against rising prices.
To support communities already affected by climate change VCOSS will advocate for:

funding towards on-the-ground assistance for people at risk during heatwaves and ongoing
improvements to local and state heatwave planning policy; and

emergency management policies which provide additional support for people who are
particularly vulnerable in bushfires to evacuate or relocate and focus on community
development approaches to preparation and recovery.
To ensure that Adaptation Planning and decision making are well informed and to support
community transition to a low carbon future VCOSS will advocate for:

mechanisms which ensure the active involvement of all relevant government departments in
the development and implementation of the statewide Climate Change Adaptation Plan;

accessible and high quality Victorian research on the health, social and economic impacts of
climate change;

the commitment to transition support for the LaTrobe Valley to be extended to other
climate change affected communities; and

support for community sector organisations to access comprehensive environmental
auditing, efficiency, training and risk management planning.
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