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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.