Download MAV submission to Climate Change Adaptation Plan Directions Paper

Victoria’s Climate Change Adaptation Plan Directions Paper
Submission
September 2016
© Copyright Municipal Association of Victoria, 2016.
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Table of contents
1
Introduction ......................................................................................................................... 4
2
Vision and goals.................................................................................................................. 4
3
Adaptation principles ........................................................................................................... 6
4
Priority Action Areas ........................................................................................................... 6
5
Conclusion .......................................................................................................................... 8
1 Introduction
The Municipal Association of Victoria (MAV) appreciates the opportunity to provide a brief
submission in response to the Department of Environment, Land, Water and Planning’s
(DELWP) Victoria’s Climate Change Adaptation Plan Directions Paper. As noted in a number of
MAV submissions to the Victorian Government over the last 12 months, the MAV and Victorian
councils welcome and support the State’s ambition to be a strong leader on climate change.
The Directions Paper indicates that the final Adaptation Plan will be released in early 2017. While
we acknowledge that DELWP ran climate change related workshops with councils in early June,
we consider the State’s decision not to circulate a draft plan for public comment to be a missed
opportunity to gather more targeted input and support for the final plan. The Directions Paper is
very high level and therefore lacks detail on how the various goals, principles and action areas
will be progressed particularly in relation to roles and responsibilities and funding.
2 Vision and goals
The vision put forward in the Directions Paper reads as follows:
`Victoria will meet the challenges and act on the opportunities of climate change, and will
be a healthy, prosperous, safe and vibrant place to work and live.’
The MAV supports adopting a vision that is optimistic and ambitious, however we question
whether the proposed vision is something that the plan can reasonably be expected to achieve.
While we agree that effective climate change adaptation is critical to Victoria’s ongoing liveability
and prosperity, it is important to acknowledge that climate change is only one of a diverse range
of factors critical to the health, safety and vibrancy of Victoria. We recommend that further
consideration be given to the vision to ensure that it is directly relevant and tailored to the
objectives and actions set out within the Plan.
In its response to the Independent Review Committee’s (IRC) review of the Climate Change Act,
the Victorian Government agreed to introduce the following objectives into the Act to provide
overarching policy direction for Victoria’s response to climate change:
a) To reduce GHG emissions consistently with the best available science and the long-term
emissions reduction target;
b) To build the resilience of Victoria’s infrastructure, built environment and communities
through effective adaptation and disaster preparedness action;
c) To manage Victoria’s natural resources, ecosystems and biodiversity to promote
resilience;
d) To promote and support Victoria’s regions, industries and communities to maximise the
opportunities that arise from a transition to a low-carbon economy through coordinated
whole-of-government action and partnerships; and
e) To support vulnerable communities, and promote intergenerational equity and social
justice.
The six goals put forward in the Direction Paper largely align with these objectives, albeit with
some amendments and additions. We consider it appropriate and important that the objectives of
the Act and the adaptation plan align as closely as possible.
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The proposed goals and the MAV’s comments are set out in the table below:
Adaptation Plan goals
(page 5 of Directions Paper)
Leadership
Demonstrate leadership by embedding climate
change adaptation considerations across all
levels of Victorian government decision-making,
policies, planning and service provision;
acknowledge and support other leaders across
businesses and the community.
A healthy environment
Manage and promote the resilience of Victoria’s
natural resources, ecosystems and biodiversity
Collaboration and shared responsibility
Work together effectively across all levels of
government, business, academia and the
community, to prepare for and adapt to a
changing climate.
Strong, resilient and safe communities
Build the resilience and adaptive capacity of
Victoria’s infrastructure and communities through
effective adaptation and disaster preparedness
action; ensure integration of climate change risks,
impacts and projections into all phases of
emergency management.
Priority support for vulnerable communities
and ecosystems
Consider matters of equity in decision-making
and seek to ameliorate disadvantage through
adaptation action; foster diversity and equal
participation across the community.
A flexible and prosperous community
Enable Victoria’s industries to adapt to climate
change impacts and maximise opportunities in a
low carbon economy.
MAV comments
The MAV welcomes the inclusion of a goal in
relation to the Victorian Government
demonstrating leadership on climate change
adaptation across all portfolios.
This goal aligns very closely with the IRC’s
recommended objective c). The MAV supports
the inclusion of this goal.
The MAV is supportive of this goal. We consider
the resourcing and sharing of information and
best practice as critical to effective adaptation
action and would like to see the State’s role in
this regard articulated within the plan.
The first part of this goal aligns very closely with
the IRC’s recommended objective b). We support
the first part of the goal. We question the second
part of the goal in relation to ensuring integration
of climate change risks, impacts and projections
into all phases of emergency management. We
consider that the State needs to give further
consideration to what this would mean in terms of
during an emergency event.
This goal appears to seek to align with the IRC’s
recommended objective e). The goal as drafted is
unclear. “Ecosystems” appears in the heading but
not in the text. We recommend that DELWP use
the IRC’s wording, ie. `support vulnerable
communities, and promote intergenerational
equity and social justice’.
This goal appears to seek to align with the IRC’s
recommended objective d). We would like to see
the words ` To promote and support Victoria’s
regions, industries and communities’ included in
the goal.
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3 Adaptation principles
The Directions Paper sets out 12 principles to `articulate values and directions for decisionmakers and the community’. The MAV considers the principles as drafted to be unclear and too
numerous as to be helpful to decision makers. It’s also unclear if the principles are intended to
apply just to Victorian Government decision makers or also to local government, business and
the community.
It’s our understanding that the revised Climate Change Act will contain the following principles:
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Principle of informed decision making
Principle of integrated decision making
Principle of compatibility
Principle of equity
Principle of community engagement
We consider it important that there be a high level of consistency between the principles within
the Act and the principles set out within the Adaptation Plan.
4 Priority Action Areas
The Directions Paper sets out six priority action areas that will form the focus of the plan. The
MAV welcomes the numerous undertakings made within this section of the paper, including that
the Plan will:
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focus on building understanding of the risks to the community, developing priorities for
the reduction of health impacts of climate change, and supporting communities to
understand the many co-benefits of taking action
outline actions and directions that support adaptation for Victoria’s biodiversity,
complementary to the Victorian Biodiversity Strategy
focus on embedding consideration of climate change risks into Government infrastructure
and major projects decisions, the land-use planning framework and urban liveability
policies; and the management of essential services such as water
support state and local government to identify and understand areas of particular
vulnerability
foster best-practice approaches and strategies to drive effective long-term responses to
climate change.
An area that has been of particular concern for councils, is the funding of climate change
adaptation at a local level. The undertakings relating to support and funding are particularly
important:
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provide targeted support to local governments, recognising that climate change impacts
are felt locally, and councils are leading the way in responding to climate change
drive creation of sustainable funding mechanisms to support local government and the
wider community to meet the costs of adapting to climate change.
Councils are keen for the State to lead by example and for the Plan to demonstrate a clear
whole-of-government commitment to embedding climate change considerations into decision
making and service delivery.
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The Plan should also include a commitment from the State to work in partnership with local
government to improve clarity around adaptation roles and responsibilities as well as funding
arrangements. It is essential that roles and responsibilities align with organisations’ strengths,
capacity and capabilities.
There is a pressing need for the State, local government (and regional groupings of councils
such as greenhouse alliances) and other agencies such as the Catchment Management
Authorities (CMAs) to work together to identify what information and data is needed in order to
develop evidence-based and defensible plans and strategies. Key information priorities include
vulnerability mapping, benchmarks and planning scenarios. Climate change hazard and risk
assessments are an area of immediate priority for councils and targeted State support would be
appreciated by councils. Sharing the learnings should also form an important part of any cooperative work between the State and councils.
Councils remain concerned about their liability in relation to planning decisions and climate
change impacts. The MAV calls on the State to clarify councils’ position and to provide effective
protection to councils where they act in good faith and decisions are based on best information
available at the time the decisions are made.
In relation to the built environment and the planning system, the MAV again calls on the State to:
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Review State Planning Policy and provisions to ensure the policy backing and tools are
available for councils to make sound decisions
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Commit to adopting a state-wide ESD planning policy, consistent with the Sustainable
Design Assessment in the Planning Process (SDAPP) policies already adopted by six
Victorian councils. This will facilitate a much-need long-term and tangible improvement in
the quality of building stock across the State.
Councils are also mindful of the increasing frequency and intensity of natural disasters. Currently
natural disaster financial assistance is provided in stages to local government, with the majority
of funding being provided following recovery works. Disaster recovery can cost millions of dollars
and significantly interrupt cash flow. Reform to natural disaster financial assistance programs is
required to direct funding immediately following a natural disaster, rather than requiring councils
to wait for a lengthy period to access it. The funding should also support betterment of
infrastructure and facilities to increase the resilience of assets subject to climate change impacts.
We consider it important that the State’s role as an advocate on behalf of Victorians to the
Commonwealth Government should be acknowledged in the Plan. The Commonwealth
Government has a critical role to play in adaptation in terms of funding, national standard setting,
and supporting science, research and information dissemination. The State’s recent and future
advocacy in relation to climate change adaptation should be articulated within the Plan.
Finally, there are a range of State reviews and reforms underway that include adaptation
elements, including the new Biodiversity Strategy, the new Water Plan, the new Marine and
Coastal Act and the Victorian Floodplain Management Strategy. The final Adaptation Plan should
make clear the relationship and any hierarchy between the various Acts, strategies and plans.
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5 Conclusion
The MAV is supportive of a Victorian Climate Change Adaptation Plan and the proposed
goals and broad action areas set out in the Directions Paper. However, further work is
required to ensure that the principles can best assist decision makers when responding to
often uncertain circumstances.
We would welcome the opportunity to work with Government to provide further targeted input
and support for the final plan.
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