tasmanian climate change office, dpac low carbon tasmania – issues paper: tascoss submission

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Submission to

Tasmanian Climate Change Office, DPAC Low Carbon Tasmania – Issues Paper 26 June 2013

About TasCOSS TasCOSS is the peak body for the Tasmanian community services sector. Its membership comprises individuals and organisations active in the provision of community services to low-income, vulnerable and disadvantaged Tasmanians. TasCOSS represents the interests of its members and their clients to government, regulators, the media and the public. Through our advocacy and policy development, we draw attention to the causes of poverty and disadvantage and promote the adoption of effective solutions to address these issues.

Authorised by Kath McLean, Acting Chief Executive / Manager, Social Policy & Research For inquiries Wynne Russell, Policy and Research Officer [email protected]

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TasCOSS submission on Low Carbon Tasmania Issues Paper, June 2013

Introduction

TasCOSS appreciates the opportunity to respond the Low Carbon Tasmania Issues Paper.

TasCOSS strongly supports the overall thrust of this paper. As the peak body for the Tasmanian community services sector and an advocate for the low-income and disadvantaged Tasmanians that this sector supports, TasCOSS has obvious reasons for concern about climate change. Globally and locally, all evidence indicates that that low-income and disadvantaged individuals and communities are among the most vulnerable to the harmful effects of climate change; recent research also indicates that the Australian community sector is highly vulnerable as well.1 TasCOSS therefore strongly supports the principle of taking action to address the causes of climate change, including reducing carbon emissions.

Happily, many of the measures outlined in this Issues Paper for reducing carbon emissions also have the potential to benefit low-income and disadvantaged Tasmanians beyond the realm of climate change mitigation. These include measures that improve access to affordable and appropriate public transport and to affordable, well-situated and amenable housing, or that help households and not-for-profit community sector organisations save money by reducing their energy use.

Nevertheless, TasCOSS is concerned that some of the actions proposed in this Issues Paper to achieve a low carbon Tasmania could have the unintended consequence of making essential services—in particular housing, household energy supply, and transport—not simply more expensive, but exponentially less affordable for Tasmanians who live on low incomes. We therefore recommend that all actions proposed in this paper be rigorously assessed in relation to not only their efficacy in reducing greenhouse gas emissions, but also their possible economic and social consequences for vulnerable Tasmanians. In particular, care should be taken to ensure that incentive programs for shifts to low emissions technologies do not harm those who cannot afford to purchase new appliances, energy generation systems, or fuel efficient vehicles, either by imposing penalties on non-adopters or by increasing the basic price of utilities. This is not to say that programs that impose costs should not be considered; rather, they should not be implemented without adequate compensation strategies for those in need who may be adversely affected. Beyond these general points, our comments will focus on two of the Issues Paper’s areas for action: low carbon transport and saving energy costs in homes and businesses. We will address each of the subsections of these issue areas in turn.

1 Mallon, K et al. (2013) Adapting the Community Sector for Climate Extremes. National Climate Change Adaptation Research Facility, http://www.nccarf.edu.au/sites/default/files/attached_files_publications/SI1106-Mallon-Adapting-Community-Sector-Climate-Extremes.pdf

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4.2 Low carbon transport Vision

A more equitable vision statement would begin “Tasmanians will enjoy a healthy, safe, quiet, clean and affordable transport network.”

Context

We believe that this section would benefit from a clear description of the current public transport context. We suggest as potential wording: “Public transport services in the State, both for-profit and not-for-profit, currently are largely characterised by:

Limited hours and frequency of operations, Limited geographic scope, Limited integration in ticketing, physical location and timetables, Limited affordability, and Limited eligibility.”

Opportunities and Challenges

Opportunities: We would add another opportunity: the potential for a better integrated, more accessible public transport sector as well as for better-publicised, more widely available carpooling and car-sharing schemes.

Also, strong co-benefits are associated not only with active transport modes, but with public transport modes as well. For example, research from Victoria indicates that proximity to public transport stops increases not only the use of such transport, but also healthy activity.2 However, it is worth noting that neither of these are ‘opportunities’ per se—they are fringe benefits.

Challenges: We would add another challenge: the lack of a single entity overseeing the whole public transport sector, both for-profit and not-for-profit.

Future Directions

Organisation: We find the organisation of Actions in this section confusing. Actions 4.2.2 and possibly 4.2.3, for instance, do not actually reduce travel demand; they simply redirect it from single-occupancy car use to other travel forms. They really belong under Modal Shift. Meanwhile, most of the actions under the heading of Fuel Efficiency (all except for 4.2.13 and 4.2.14, in fact) actually do not address this issue. Increasing vehicle occupancy levels (Action 4.2.9), for instance, does not increase fuel efficiency, although it does reduce overall fuel use through a modal shift. Similarly, ethanol content has less to do with fuel efficiency than with the emissions from the fuel being burned.

Perhaps this section would be clearer if one replaced the three current subheadings with four:

2 Boyce, C (2011), “Proximity to transport is a health, gender and equity issue.” Equity Justice Access, 5 June, Victoria Walks, http://www.victoriawalks.org.au

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Possible actions to reduce travel demand: Actions 4.2.1, 4.2.5 Possible actions to encourage modal shift: Actions 4.2.2, 4.2.4, 4.2.6, 4.2.7,

4.2.8, 4.2.9, and possibly 4.2.3 Possible actions to encourage fuel efficiency: Actions 4.2.13, 4.2.14 Possible actions to encourage the use of low-emissions fuels and vehicles:

Actions 4.2.10, 4.2.11, 4.2.12, 4.2.15

Actions: As overall, we would urge that many actions contain specific reference to equity concerns. For Action 4.2.1 (alternatives to travel), for instance, community service organisations may need assistance in providing or accessing videoconferencing / teleworking facilities; consequently, we would urge the wording “Facilitate, promote, and support equitable access to alternatives to travel…” Similarly, for Action 4.2.2, we would urge that the needs of elderly or disabled Tasmanians be strongly taken into account when developing car parking strategies, and that parking should not be made unaffordable for low-income Tasmanians with no other transport options. Equally, for Action 4.2.11, care must be taken to ensure that increasing vehicle registration fees for fuel-intensive vehicles does not harm low-income Tasmanians who cannot afford to purchase a new high-efficiency vehicle.

Under Modal Shift, we would include an additional action: Promote better communication, collaboration, integration and innovation in public transport, both for-profit and not-for profit, to increase efficiency and effectiveness. Rationale: Active measures will be required to overcome the shortcomings identified under Context.

Finally, Action 4.2.3 is not clear—more detail and/or a clearer explanation are needed.

Priorities

From the perspective of low-income and disadvantaged Tasmanians, the most pressing need is for a well-integrated, broadly accessible public transport system that draws and builds on the capabilities of both the for-profit and not-for-profit sectors. Low-income and disadvantaged Tasmanians also have the potential to benefit from other measures that help reduce the cost and increase the availability of lower-cost transport options, including better-publicised, more widely available carpooling and car-sharing schemes and better active transport infrastructure.

4.3 Saving energy costs in homes and businesses

Vision

A more equitable vision statement would be “Tasmanians will be embracing and have equitable access to energy efficient technologies and practices…”

Context

It may be worth adding some information on Tasmania’s housing stock to the discussion of context. For example, Tasmania has the oldest housing stock in the

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country and the highest proportion of timber homes; low incomes have contributed to lower than average rates of insulation as well (as of 2008, a quarter of Tasmanian homes were still uninsulated). As a consequence, Tasmanian houses have a particularly low energy rating overall. Unsurprisingly, given this stock and our cool climate, Tasmanians use more heating than the rest of the country, with around 85% of Tasmanian homes using heaters for more than three months of the year.3

Opportunities and Challenges

Challenges: We would suggest making specific mention in the first two dot points of the challenges faced by low-income tenants and home owners/buyers, to ensure that their needs are kept in mind when solutions are formulated and targeted.

Future Directions

TasCOSS supports moves to encourage greater residential and business energy efficiency, although incentives and penalties should be designed with equity as a key factor. TasCOSS particularly supports:

Action 4.3.1: The idea of a specific target for reducing average annual household and small business energy consumption, for which good baselines will need to be developed.

Action 4.3.2: Energy efficiency upgrades to all Housing Tasmania properties by 2020. We urge that this program also apply to Housing Tasmania-owned properties that are managed by community sector organisations under the ongoing stock transfer process.

Actions 4.3.3 and 4.3.4: Subsidised energy efficiency assessments and advice for small to medium-sized enterprises (SMEs) and the concept of a Save Energy Loan fund for SMEs. However, we also strongly recommend energy efficiency grants be made available for smaller community service organisations, which are on limited (and diminishing) incomes and often will find even a no-interest loan impossible to take on.

While we support other actions in this section, we note the potential for negative impacts on low-income and disadvantaged households.

Actions 4.3.7 and 4.3.8: Implementing mandatory disclosure of energy efficiency ratings of residential properties for sale and lease and strengthening the energy efficiency provisions of the Building Code are worthy measures that have the potential not only to reduce emissions but also to cut running costs and to help consumers make more informed choices. However, they are also likely lead to increased transaction and construction costs—an outcome that will have a sharper impact on low-income sellers/buyers/renters, and may exacerbate Tasmania’s existing shortage of affordable housing unless some form of complementary incentive scheme is developed.

Action 4.3.9: A mandated phase-out of electric hot waters heaters has the potential to impose substantial costs on low-income households, particularly

3 Australian Bureau of Statistics (2000), Australian housing survey 1999 — housing characteristics, costs and conditions, cat. no. 4182.0, ABS, Canberra, p. 7; Australian Bureau of Statistics (2008), Environmental issues: energy use and conservation — Australia, cat. no. 4602.0.55.001, ABS, Canberra.

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low-income tenants whose landlords will pass on the costs of replacement heaters. Built-in protections for vulnerable households in all tenures (including access to no interest loans/grants) will be needed.

We also would like more information about how a ‘Re-energising Tasmania’ energy savings scheme (Action 4.3.6) might function and the possible impacts on energy costs.

Priorities

From the perspective of low-income and disadvantaged Tasmanians, the most pressing short-term priority is energy efficiency retro-fitting of public and community housing dwellings and the immediate re-funding and re-introduction of the Power Savings for Tenants program – a very successful (effective and relatively cheap) energy efficiency program for private rental properties.

TasCOSS also supports the introduction of energy efficiency assistance for low-income home owners/buyers, targeting concession card holders in particular. Ideally, these programs should include subsidised insulation (particularly in-roof insulation) for low-income home owners/buyers and for properties rented to low- income and disadvantaged tenants, as well as education and behaviour change programs particularly aimed at these groups. Such measures will decrease energy use and its attendant carbon emissions, while simultaneously increasing amenity and reducing the burden of high energy costs on low-income households.

Thank you for the opportunity to comment on this Issues Paper. We appreciate being included in these consultations, and are happy to provide any additional information required.

tasmanian climate change office, dpac low carbon tasmania – issues paper: tascoss submission

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