Download Submission on New Zealand`s climate change target

Auckland Regional Public Health Service
Cornwall Complex
Floor 2, Building 15
Greenlane Clinical Centre
Private Bag 92 605
Symonds Street
Auckland 1150
New Zealand
Telephone: 09-623 4600
Facsimile: 09-623 4633
3 June 2015
Climate Change Consultation Contribution
Ministry for the Environment
PO Box 10262
WELLINGTON 6143
Submission on New Zealand’s Climate Change Target
Thank you for the opportunity for the Auckland Regional Public Health Service (ARPHS) to
provide a submission to the consultation on New Zealand’s Climate Change Target.
This submission represents the views of ARPHS and does not necessarily reflect the views of
the three District Health Boards it serves. Please refer to Appendix 1 for more information on
ARPHS.
The primary contact point for this submission is:
Stuart McKay
Policy and Workforce
Auckland Regional Public Health Service
Private Bag 92 605
Symonds Street
Auckland 1150
09 623 4600 ext 28243
[email protected]
Jane McEntee
General Manager
Auckland Regional Public Health
Dr David Sinclair
Medical Officer of Health
Auckland Regional Public Health
EXECUTIVE SUMMARY AND KEY RECOMMENDATIONS
1.
ARPHS supports the New Zealand government adopting ambitious targets for
greenhouse gas emission reductions because of the significant health and wellbeing impacts of climate change. There also needs to be an ambitious
implementation programme for achieving emission reductions which is equitable.
2.
ARPHS has a number of priority work areas and statutory obligations relevant to
climate change, including promotion of healthy built environments,
communicable disease control and surveillance, reducing health inequalities,
ensuring drinking and recreational water quality and emergency planning and
response. ARPHS is also involved in promoting healthy urban design and
sustainable transport because of the role of active transport (such as walking
and cycling) in improving public health outcomes.
3.
While the three objectives listed in the consultation document are relevant, the
accompanying information on economic impacts only covers short term costs of
mitigation. This is inadequate. In addition:
o A fair contribution should consider how a climate change target will impact
equity domestically. Costs should not exacerbate existing inequities in New
Zealand.
o Targets should reflect the scope to reduce per capita emissions. Our national
circumstances present opportunities for an ambitious approach on certain
aspects of our emissions profile.
o Discussions on the thematic and geographic balance in allocating climate
finance should ensure equity and fairness for Pacific Island Countries (PICs).
o Early adoption could present competitive advantages for the New Zealand
economy over the long-term. Economic assessment needs to be based on
discounting rates appropriate for the timescale of climate change.
4.
ARPHS supports basing targets on mitigation pathways that will avoid global
average surface temperature increases of 2oC as outlined in the
Intergovernmental Panel on Climate Change’s (IPCC) Fifth Assessment Report
This corresponds to emission reductions in the range of 40-70% by 2030.
5.
The health sector is a high user of carbon-based energy. The health sector’s
time horizons for planning for services, procurement, capital equipment,
construction, facilities management, energy and infrastructure are often over
several decades, similar to those of climate change mitigation and adaptation.
The health sector will face important long-term decisions that would benefit from
ambitious emission reduction targets supported by a clear national policy for
reducing emissions.
6.
ARPHS supports the New Zealand Emissions Trading Scheme (NZETS) as a
policy tool underpinning New Zealand’s domestic emissions reduction action.
The effectiveness of the NZETS depends on how it is structured and
implemented.
7.
ARPHS acknowledges that New Zealand has a unique emission profile. Sector
by sector analysis is required to idenitify activities which will best implement
rapid decarbonisation in New Zealand. ARPHS recognises there are
opportunities to realise a number of significant health co-benefits.
o Increased energy efficiency and energy affordability for low income earners
living in poor quality housing; and
o Support for sustainable and active transport options will reduce transport
emissions and promote physical activity.
8.
ARPHS strongly recommends that any increases in energy prices should be
coupled with energy reduction and efficiency programmes. Where other costs
for low income earners are increased, subsidies should be considered.
9.
ARPHS supports the approach by IPCC1 and the New Zealand Climate Change
Centre (NZCCC)2 in recognising the role of uncertainty in climate change
planning by exploring a range of scenarios.
10. ARPHS encourages New Zealand to utilise its unique position as a member of
the UN Security Council in 2015 to offer international leadership in these areas.
NEW ZEALAND’S OBJECTIVES FOR OUR CONTRIBUTION TO EMISSIONS
REDUCTIONS
1: New Zealand’s contribution is seen as fair and ambitious internationally and
domestically
11. ARPHS considers that a fair contribution should not increase health inequalities:
o There will be different impacts depending on age, ethnicity, health status and
socio-economic vulnerability.
o Māori and Pacific people are, on average, more likely to be adversely affected
because of existing socio-economic situations.
o Costs should be distributed in a manner that does not cause further inequity
and should be based on ability to pay.
12. ARPHS notes the comments in the consultation document that our contribution
to climate change is only 0.15% of global emissions.
o We emphasise, however (as is stated in a following chapter), that New
Zealand’s annual greenhouse gas emissions per person are around 17
tonnes compared to the global average of 8 tonnes.
o ARPHS recommends that New Zealand’s target should reflect the scope to
reduce per capita emissions. Our national circumstance present opportunities
for an ambitious approach on certain aspects of our emissions profile.
13. ARPHS also recognises that developing and newly developed industrialised
countries are increasingly contributing to the global emissions profile.
o ARPHS recommends that the New Zealand government supports a new
international agreement which recognises that these countries have common
but differentiated responsibilities and that financial assistance is required.
o ARPHS recommends continued support for the Green Climate Fund (GCF) as
a mechanism for attracting new and additional funding.
o ARPHS understands that the GCF has now reached the 50 percent threshold
required to start allocating its resources for projects and programmes in
developing countries. We point to recommendations by the OECD Climate
Change Expert Group3 on how the Paris meeting can further mobilise climate
finance by:
i. Discussing thematic and geographic balance in allocating climate
finance;
1
IPCC 2007a. Climate Change 2007: Impacts, Adaptation and Vulnerability. Contribution of Working Group II to the Fourth
Assessment Report of the Intergovernmental Panel on Climate Change. Parry, M.L., Canziani, O.F., Palutikof, J.P., van der Linden,
P.J., Hanson, C.E. (eds). Cambridge University Press, Cambridge, United Kingdom, 976 p.
2
Reisinger, A., Mullan, A.B., Manning, M., Wratt, D.W., Nottage, R.A.C. 2010. Global and local climate change scenarios to support
adaptation in New Zealand. In: Climate change adaptation in New Zealand: Future scenarios and some sectoral perspectives.
Nottage, R.A.C., Wratt, D.S., Bornman, J.F., Jones, K. (eds). New Zealand Climate Change Centre, Wellington, pp 26-43.
3
OECD Climate Change Expert Group (2014) The Role of the 2015 Agreement in Mobilising Climate Finance, Paper No. 2014(7).
ii. Facilitating better co-ordination and co-operation amongst climate finance
institutions to minimise duplication of work and maximise the synergies
between different institutions; and
iii. Streamlining the climate finance allocation processes to improve
efficiency and effectiveness of managing and disbursing climate finance.
14. ARPHS is particularly concerned about the impact on Pacific Island Countries
(PICs) with which Auckland has long and close ties. These countries are highly
vulnerable to climate change and sea level rise. Auckland is likely to need to
provide for climate refugees from the Pacific. This will have implications for
housing, social infrastructure and the economy.
o ARPHS notes that adaptation funding should remain an objective of the GCF
and that New Zealand should actively support thematic and geographic
balances that address the concerns of PICs.
15. ARPHS encourages New Zealand to utilise its unique position as a member of
the UN Security Council in 2015 to offer international leadership in these areas.
2: Costs and impacts on society are managed appropriately
16. Any estimates of cost must recognise there is a public health cost of responding
inadequately. There is no indication that central government has undertaken
any research in this area and the consultation document fails to indicate this is a
limitation as is identified by the Infometrics research for the Ministry for the
Environment on which much of the consultation document is suggested to be
based on:
“Non-economic costs and benefits are generally not captured in CGE models.
For example, CGE models do not generally capture changes to social and health
outcomes that may arise from climate change mitigation policies, even though
these outcomes may have real economic costs and benefits.”
17. ARPHS recommends further research on public health costs. While information
on public health costs is limited, ARPHS is concerned about a number of
impacts:
o Public health infrastructure will be affected, including water supplies and
sanitation networks, including damage from storms and sea level rise.
o Changes in food production patterns and food security (for both locally
produced and imported food), including greater fluctuation in crop yields.
IPCC projections are for net decrease in crop yields globally with elevated
temperature, and adverse effects on marine food sources.
o Impacts from ecosystem changes, including increased risk of large vector
borne disease epidemics and food and water-borne disease in New Zealand
i. A New Zealand study has found that a 1°C increase in average monthly
temperature was associated with a 15% increase in salmonellosis
notifications4. Average mean temperature increases for Auckland to
2040 are projected to be 0.9 - 1.1°C5.
ii. Auckland may become suitable for mosquitoes that carry Dengue Fever
or Ross River Virus6,7.
4
Britton, E., Hales, S. et al. (in press). Positive association between ambient temperature and salmonellosis notifications in New
Zealand, 1965-2006. Australian and New Zealand Journal of Public Health.
5
Ibid at 11.
6
Hales, S., de Wet, N., Maindonald, J., Woodward, A. (2002) Potential effect of population and climate changes on global distribution
of dengue fever: An empirical model. The Lancet 360: 830-834.
7
Woodruff, R., Guest, C.S., Garner, M.G., Becker, N., Lindesay, J., Carvan, T., Ebi, K. (2002) Predicting Ross River virus epidemics
from regional weather data. Epidemiology 13(4): 384-393.
o By 2100, Auckland is projected to have an additional 40 days or more per
year that exceed 25°C8. Studies have indicated that at least 70,000 people died
as a result of the extreme high temperatures in the European summer of 20039.
o Warmer temperature may promote increased outdoor time and exposure to
solar ultraviolet radiation10 (increasing risk of melanoma and other skin
cancers).
o Higher temperatures and lower rainfall can increase allergen-producing
pollens, dust storms and forest fires increasing the likelihood of hospital
admissions from respiratory and cardiovascular conditions11.
o Rising sea levels and increased incidence of storm surges will impact
emergency preparedness and response12,13.
18. Estimates of costs must also recognise that climate change mitigation policies
will also bring with them ancillary or secondary benefits14.
o For example there are benefits associated with reduced air pollution on
respiratory illness, energy efficiency improves energy security and there are
links between sustainable transport, physical activity, safety and obesity.
19. A 2011 New Zealand study found that shifting only 5% of vehicle kilometres to
cycling could15:
o avoid 116 deaths annually as a result of increased physical activity and
improved air quality, but with an additional five cyclist fatalities from road
crashes;
o produce net savings of about $200 million per year (using the NZ Ministry of
Transport Value of a Statistical Life); and
o reduce transport-related greenhouse gas emissions by 0.4%.
20. ARPHS recommends that further analysis on the benefits of climate change
mitigation should be undertaken.
o A broad array of tools is readily available. Energy scenarios can be employed
to produce scenario based risk assessments, which rely on emission
inventories and air pollution and dispersion models. Estimated changes in
concentrations and exposures from these scenarios can then be linked to
estimate incremental changes in public health from various policies16.
o Discounting rates used in sensitivity analysis need to consider the time scales
of climate change (50-100 years) rather than the standard 5-10 years.
3: It must guide New Zealand over the long term in the global transition to a
low emissions world
21. ARPHS agrees that the concept of a global carbon budget (as illustrated in
Figure 1 of the submission) should shape policy and action.
o ARPHS notes that current projections suggest the budget will be exceeded in
2035, so rapid decarbonisation is necessary.
8
Ministry for Environment (2008) Climate change effects and impact assessment: A guidance manual for local government in New
Zealand.
9
Robine, J., Cheung, S., Le Roy, S., Van Oyen, H., Griffiths, C., Michel, J. and Herrmann, F.R. (2008) Death toll exceeded 70,000 in
Europe during the summer of 2003, Comptes Rendus Biologies, 331, 2, pp 171 – 178.
10
Howder-Chapman, P., Chapman, Hales, S., Britton, E. and Wilson, N. (2010) Climate Change and human health: Impact on
adaptation in New Zealand: Future Scenarios and some sectoral perspectives. Nottage, R.A.C., Wratts, D.S., Bornman, J.F., Jones, K
(eds) New Zealand Climate Change Centre, Wellington, pp 112 – 121.
11
Emanual, S.C. (2000) Impact to lung health of haze from forest fires: The Singapore experience. Respirology 5(2): 175-182.on the
timing of pollen release in the Netherlands. International Journal of Climatology 22(14): 1757-1767.
12
van Vliet, A.J.H., Overeem, A., De Groot, R.S., Jacobs, A.F.G., Spieksama, F.T.M. (2002) The influence of temperature and climate
change on the timing of pollen release in the Netherlands. International Journal of Climatology 22(14): 1757-1767.
13
Auckland Council (2015) The Auckland Plan. Available at: http://theplan.theaucklandplan.govt.nz/.
14
OECD Climate Change Expert Group (2014) The ancillary health benefits and costs of GHG mitigation: scope, scale and credibility.
Available at: http://www.oecd.org/env/cc/economicsofclimatechangemitigation.htm
15
Lindsay, G., Macmillan, A., & Woodward, A. (2011). Moving urban trips from cars to bicycles: impact on health and emissions.
Australian and New Zealand Journal of Public Health, 35(1), 54-60.
16
Ibid at 12.
22. ARPHS notes comments from the Treasury17 that the costs of meeting targets
after 2020 are expected to rise significantly as our emissions are forecast to
increase and carbon prices are likely to be higher. We query however, why in
Treasury’s view, New Zealand’s objective should be to take a target that
imposes a roughly equal cost to other countries as a percentage of GDP, given
earlier adoption will provide competitive advantages to the New Zealand
economy in the post 2020 environment.
WHAT IS A FAIR CONTRIBUTION FOR NEW ZEALAND?
The ETS could be a valuable tool for encouraging emissions reductions
23. ARPHS supports the NZETS as the principal policy tool underpinning New
Zealand’s domestic emissions reduction action.
o ARPHS concurs with the concerns outlined by the Parliamentary
Commissioner for the Environment18 that the ETS as currently structured
distorts the carbon market and limits incentives to reduce emissions.
o ARPHS notes that review is required to consider the appropriateness of
industry exclusions and whether carbon credits are valued appropriately.
o ARPHS looks forward to the opportunity to provide comments on the review
of the ETS that will be carried out later this year
New Zealand’s emissions profile is unique and offers both challenges and
opportunities
24. ARPHS acknowledges that New Zealand has a unique emission profile. While
this creates challenges it also provides opportunities. Sector by sector analysis
is required to idenitify activities which will best implement rapid decarbonisation.
o ARPHS emphasises that there are also opportunities to realise a number of
significant health co-benefits. These are discussed in further detail under the
heading of Opportunities
HOW WILL OUR CONTRIBUTION AFFECT NEW ZEALANDERS?
Costs
25. ARPHS reiterates that the discussion document focuses on only short term costs
of mitigation, and does not consider the costs of uncontrolled climate change or
the economic and other benefits of mitigation and adaptation.
o ARPHS does not support this approach. It will favour short term expediency
over long term necessity. We disagree with this approach because of the
long term health impacts.
26. ARPHS reiterates that a fair contribution should also consider how both climate
change and climate change solutions will impact equity domestically.
o For example, increased energy prices could have substantial impacts on
health inequalities. If energy prices rise, low-income families, who often live
in poorly-insulated homes, are likely to be disadvantaged.
o Any increases in energy prices should be coupled with energy reduction and
efficiency programmes. Small scale sustainable energy supply and energy
17
The Treasury (2014) Treasury Report: Climate Change - Important Decisions Between Late- 2014 and Mid-2015. Available at:
http://www.treasury.govt.nz/publications/briefings/2014-climate-change.
18
Parliamentary Commissioner for the Environment (2012) Submission on the Climate Change Response (Emissions Trading and
Other Matters) Amendment Bill. Available at: http://www.pce.parliament.nz/publications/submissions-and-advice/submission-on-theclimate-change-response-emissions-trading-and-other-matters-amendment-bill/
efficient homes mean lower power bills, warmer homes and better health, as
well as reduced greenhouse gas emissions. Where other costs for low
income earners are increased, subsidies should be considered.
Opportunities
27. ARPHS reiterates that several mitigation activities offer significant co-benefits.
These include:
o Increased energy efficiency and energy affordability for low income earners
living in poor quality housing; and
o Support for sustainable and active transport options to reduce transport
emissions and promote physical activity.
28. The Parliamentary Commissioner for the Environment’s 2006 report ‘Healthy,
Wealthy and Wise – A health impact assessment of future currents: Electricity
scenarios for New Zealand 2005-2050’ used health impact assessment (HIA) to
assess the health effects of energy policy choices. The HIA found small scale
sustainable energy supply and energy efficient homes meant better health, as
well as lower power bills and reduced emissions of greenhouse gases.
29. Government could also realise significant savings through more efficient energy
measures.
o The health sector is a high user of carbon-based energy. Long term planning
for health services, construction, facilities management, procurement and
operational costs would benefit from ambitious emission reduction targets
supported by a clear national approach for reducing emissions.
o The District Health Boards in the Auckland region are each undertaking
programmes to improve energy efficiency and reduce emissions. These
include Certified Emissions Measurement And Reduction Scheme (CEMARS)
certification (Counties Manukau DHB) and upgrading energy generation,
energy management and travel planning.
30. As well as reducing emissions, active transport options such as cycling and
walking have the potential to reduce motorised transport congestion, improve
health and fitness, and is an affordable form of transport that promotes social
inclusion.
o Physical activity such as cycling and walking can protect against obesity and
cardiovascular disease19.
o Cycling and walking can be a significantly less expensive transportation
option for households than car usage. Households in car dependent cities pay
significantly more of their household income on transportation costs than
those in cities better served by public transportation20.
o Cycling and walking when used in conjunction with other modes of transport
can extend the reach of public transport and contribute to a reduction in
inequalities.
o Community cohesion and safety are also enhanced, not only due to a
reduction in motor vehicle use and vehicle emissions, but because an
increase in cyclists and pedestrians increases the level of observation,
thereby discouraging crime21.
31. ARPHS also notes that action as well as research is required to reduce
emissions from agriculture. ARPHS notes that:
19
Joyner, Michael J. and Daniel J. Green, Exercise Protects the Cardiovascular System: Effects Beyond Traditional Risk Factors,
Physiol (2009) pp 5551–5558.
20
Statistics NZ. (2013). Household Economic Survey: Year ended June 2013. Statistics New Zealand, Wellington
21
Department of sustainability and Environment, Safer Design Guidelines for Victoria. 2005.
o Nitrous oxide emissions are a cost to agricultural businesses. Nitrogen inputs
are wasted through emissions, water quality can be adversely affected and
agricultural yields may be reduced.
o There is opportunity for better diets through encouraging less consumption of
animal based products and more plant based material.
ACCOUNTING FOR UNCERTAINTIES WHEN SETTING A TARGET
32. ARPHS supports the approach by the Intergovernmental Panel on Climate
Change (IPCC)22 and the New Zealand Climate Change Centre (NZCCC)23 in
using scenario planning for dealing with uncertainty about climate change
impacts, mitigation and adaptation.
33. The UK National Health Service’s Sustainable Development Unit, for example,
has developed a set of scenarios based on climate change severity and policy
options for mitigation and adaptation. These have been used extensively in the
UK NHS for health service sustainability planning.
34. ARPHS notes that the use of scenarios also respects Principle 15 of the Rio
Declaration24 (the Precautionary Principle). New Zealand generally supports this
principle in international law.25
“In order to protect the environment, the precautionary approach shall be
widely applied by States according to their capabilities. Where there are threats
of serious or irreversible damage, lack of full scientific certainty shall not be
used as a reason for postponing cost-effective measures to prevent
environmental degradation”
22
IPCC 2007a. Climate Change 2007: Impacts, Adaptation and Vulnerability. Contribution of Working Group II to the Fourth
Assessment Report of the Intergovernmental Panel on Climate Change. Parry, M.L., Canziani, O.F., Palutikof, J.P., van der Linden,
P.J., Hanson, C.E. (eds). Cambridge University Press, Cambridge, United Kingdom, 976 p.
23
Reisinger, A., Mullan, A.B., Manning, M., Wratt, D.W., Nottage, R.A.C. 2010. Global and local climate change scenarios to support
adaptation in New Zealand. In: Climate change adaptation in New Zealand: Future scenarios and some sectoral perspectives.
Nottage, R.A.C., Wratt, D.S., Bornman, J.F., Jones, K. (eds). New Zealand Climate Change Centre, Wellington, pp 26-43.
24
United Nations (1992) The Rio Declaration Available at: http://www.un.org/documents/ga/conf151/aconf15126-1annex1.htm
25
The Treasury (2006) Environmental Risk Management in New Zealand -Is There Scope to Apply A More Generic Framework?
Available at: http://www.treasury.govt.nz/publications/research-policy/ppp/2006/06-06/06.htm
Appendix 1 - Auckland Regional Public Health Service
Auckland Regional Public Health Service (ARPHS) provides public health services
for the three district health boards (DHBs) in the Auckland region (Auckland,
Counties Manukau and Waitemata District Health Boards).
ARPHS has a statutory obligation under the New Zealand Public Health and
Disability Act 2000 to improve, promote and protect the health of people and
communities in the Auckland region. The Medical Officer of Health has an
enforcement and regulatory role under the Health Act 1956 and other legislative
designations to protect the health of the community.
ARPHS’ primary role is to improve population health. It actively seeks to influence
any initiatives or proposals that may affect population health in the Auckland region
to maximise their positive impact and minimise possible negative effects on
population health.
The Auckland region faces a number of public health challenges through changing
demographics, increasingly diverse communities, increasing incidence of lifestylerelated health conditions such as obesity and type 2 diabetes, infrastructure
requirements, the balancing of transport needs, and the reconciliation of urban
design and urban intensification issues.