Attachment 1: Tweed Shire Council Submission to the NSW Government Climate Change Fund Draft Strategic Plan 2017 – 2020 and Draft Plan to Save NSW Energy and Money
Overarching comments
Tweed Shire Council commends and supports the NSW Government for proactively seeking to reduce the state’s emissions to net-zero by 2050.
Just as Council itself is investigating how to save, create and provide cost effective zero-carbon power in the Tweed, Council supports zero-carbon energy supply in the state. As NSW emissions in 2014 were 130 million tonnes CO2-e, and 80% of those emissions were generated from the extraction, processing and burning of fossil fuels, primarily coal, Tweed Shire encourages the NSW Government to map out the full decarbonisation of NSW’s energy supply, and transition to net-zero energy
generation and transmission.
Council recommends a fiscally-responsible approach to the task of reducing
emissions. Council commends the independent evaluation of Climate Change Fund programs. Council encourages the NSW Government to evaluate the effectiveness of its proposed initiatives in terms of triple bottom line impacts, and review impacts across the whole life cycle of new initiatives that transition us to a low carbon global community are effective, and not just moving impacts and effects to other sectors.
For example, should rainwater for garden irrigation be managed at a suburb level rather than an individual household level?
Council encourages the revised plan to make greater acknowledgement of the strategic land-use planning and development assessment system as an opportunity for all three priority areas – advanced energy, energy efficiency and climate change adaptation measures – to merge in the context of the built environment. Avoiding any increase in the burden of over-regulation, while adapting to emerging responses to affordability and sustainability aspirations, such as tiny homes, will be an ongoing challenge for the sector.
Council encourages the state government to provide more detail about the rollout of the proposed actions, particularly those to be led by local government that intersect with the planning and building sector. Provision for resources in the local government sector to support the intent of the climate change fund and energy savings plan will be vital to effect change as the sector:
• targets actions at areas most impacted by climate change
• reforms its operations and utility services to meet climate change, net-zero carbon energy and low emissions scenarios
• includes carbon accounting and climate change impacts in spatial land-use planning and development assessment of the built environment
• supports behavioural change initiatives with community and industry.
The cumulative impact of all state government policies need to account for their impact on, and resiliency to, climate change. Council notes the conflicting objective of the climate change framework with the intent and direction of many of the state government’s planning policies. For example, urban tree canopy objectives conflict with proposed controls under exempt and complying development rules and
developer contribution caps under the Environmental Planning & Assessment Act (more details provided below).
Council commends the support proposed for regional NSW and intent to strengthen the agricultural sector’s response to climate change. The farming and food sector is a major consumer of non-renewables and is also at significant risk from climate change impacts.
The threat of climate change to Australian biodiversity is acknowledged as an acute risk in the Tweed, and Council remains concerned that recent biodiversity reforms will lead to poorer biodiversity outcomes. Allocating money from the Climate Change Fund for private land conservation is not the most effective response to improving biodiversity outcomes and resiliency to climate change. Stronger protection and enhancement of existing wildlife corridors and more effective biodiversity legislation including like-for-like biodiversity offsets close to impact sites, where offsets are required as a last resort, is recommended instead.
To achieve the desired outcomes of the Climate Change Framework, all government agencies will need to play a role. Council notes the Department of Planning and Environment’s absence on the Climate Change Fund Steering Committee, and encourages the Department’s involvement and deep engagement in the Fund’s roll out and achievement of the state’s climate change mitigation and adaptation
outcomes.
Council also encourages the NSW Government to demand more responsibility from electricity network providers to reduce barriers and to create more opportunities for locally generated, locally shared renewable energy.
Regional context
The Tweed Shire is located in the Northern Rivers of NSW and shares its borders with the Queensland’s Gold Coast and Scenic Rim councils, and Byron, Lismore City and Kyogle Councils in NSW.
The Tweed is home to internationally recognised unique and sensitive ecological and geological systems that support an international tourism industry and agricultural sector, which contribute an estimated $200.1m1 and $57.8m2, respectively, per year to the NSW economy. Recent rapid population growth due to inter- and intra-state migration is expected to continue.
The Draft North Coast Regional Plan identifies a target of 16,860 houses to be provided in the Tweed LGA by 2036, placing pressure on coastal zones in particular and necessary infrastructure to service this new demand on residential and other land-use activities.
1 Australian Bureau of Statistics, Value of Agricultural Commodities Produced, Australia, 2010-11.
Cat. No. 7503.0
2National Institute of Economic and Industry Research (NIEIR) ©2016
Council welcomes the proposed focus of the Climate Change Fund on regional NSW, to support local communities to reduce their exposure to natural hazards, and to improve understanding of climate change impacts on priority sectors. Access to consistent and reliable climate and population migration data will support Council’s services to protect our natural ecosystems and associated tourism and agricultural industries; and inform strategic spatial and land-use planning to model growth scenarios and test innovative, resilient and affordable adaptation solutions for the new and expanded communities and infrastructure.
Access to Climate Fund grants and other incentives that help farmers adopt practices that sequester carbon and reduce methane and nitrous oxide emissions will be vital. Low emission farming practices will have the additional benefit of improving their productivity, reducing reliance on non-renewables and building resilience to changing climatic conditions.
Accelerating Advanced energy
1. Tweed Shire Council has set an aspirational goal to be self-sufficient in
renewable energy. Our current power demand is 20GWh/annum. Council has limited in-house resource capacity to scope and embark on renewable energy projects capable of meeting our annual demand. We recommend the use of the Climate Change Fund to help high energy-use organisations with limited
capacity to advance low carbon energy solutions.
Some options to address this barrier could include:
• funding and resourcing for feasibility studies
• statewide market price indicators of low carbon energy generation costs vs cost to buy power from the grid
• preparing investment prospectuses on behalf of high-energy users.
2. Council supports the proposal to provide funding to accelerate innovation in advanced energy. Sponsoring energy innovation events such as the North Coast Energy Forum is recommended as an effective use of the Climate Change Fund which produced the following concepts as a result of the 2014 event held in the Tweed Shire:
• an offer to fund 5 anaerobic digestion bioenergy projects up to $200,000 each
• an offer to fund the feasibility stage of a community energy project in the region
• commitment to add the North Coast of NSW to a larger electric vehicle charging station network from Noosa to Ballina
• feedback about the factors that will influence community support or social licence for bioenergy projects.
3. Council supports the proposal to strengthen emissions-performance
requirements and monitoring in land-use planning approvals processes. Further detail is required about how emissions performance would be added to existing planning processes, and the role for councils.
4. Council supports the NSW Government’s objective of identifying cost-effective pathways to achieve net-zero emissions. Council also seeks guidance and support from the NSW Government to ensure rigour and consistency in carbon
accounting as the state and local government areas seek to calculate, monitor and report their transition to net-zero emissions by 2050.
National Leadership in Energy Efficiency
5. Council supports the draft plan’s objectives to embed climate change
considerations in government decision-making, particularly in the context of the environmental planning and assessment system.
6. Tweed Shire Council supports the proposed increase to BASIX targets for energy and water.
When launched in 2004, BASIX was recognised as an award-winning world class system and intelligent state policy response to important policy issues affecting sustainable housing development, including addressing 152 disparate local controls, split economic incentives and managing scarce resources in ever volatile climatic conditions.
Key strengths of the scheme are:
• it sets minimum savings targets that are variable to regional climatic conditions and development types
• the online assessment tool enables the market to explore and determine cost- effective technology and design solutions appropriate to the site and locality, rather than mandating prescriptive sustainability measures3.
• the sustainability commitments of a BASIX certificate are embedded in planning and development assessment and certification processes
• the wealth of data captured to report and monitor performance of outcomes and enable policy evaluation and review.
However, after 12 years, the BASIX scheme’s assumptions and policy settings have not been updated, do not meet changes to national standards of the Building Code of Australia, nor do they reflect technological advances and best practice in construction design.
The BASIX Target Review, exhibited in 2014, proposed an average target increase of 10% for detached dwellings to meet national standards and market trends and demonstrated overall positive benefit-to-cost ratio results for
homeowners and the NSW economy. Since this time, no action has been taken by the Department of Planning and Environment (DPE) nor decision announced by the Minister for Planning. Council notes from the DPE website of survey responses and submissions received, that there was significant support for a target increase beyond the proposed 10%, including from local government, building design professionals and occupants.
Council encourages an increase of the BASIX energy target and policy settings as appropriate to achieve zero net-emissions housing forms. Council requests that BASIX targets for water are included in this investigation, as a key
component of climate change and hazard reduction for new communities.
Council also supports an investigation to extend the scope of sustainability criteria such as embodied energy of construction materials, waste, biodiversity,
3 Smit & Coombes, 2016. “Why we need to keep and extend BASIX” http://www.thefifthestate.com.au/columns/spinifex/why-we- need-to-keep-and-extend-basix/84471
transport accessibility, or expand the scheme’s application to larger spatial scales such as precincts, as seen with Landcom’s use of Precinx tool for new greenfield developments. This may be an important option to overcome the challenges faced by high-rise multi-unit developments.
7. Getting the subdivision design right: Establishing a stronger relationship between subdivision and house design to achieve sustainable objectives is at the core of the broader discussion on sustainability and greenfield housing development outcomes. Many of the opportunities to make significant and affordable
sustainability gains occur at the precinct, neighbourhood and subdivision level rather than house by house.
The subdivision design stage establishes the framework where subsequent development, including individual houses, is constrained by the parameters of the subdivision configuration. As such, there is an opportunity for greater leadership to further integrate contemporary best practice sustainability and urban design principles into the process and framework of subdivision design.
This process could be supplemented with subdivision design rating tools as a way of guiding a design methodology and measuring performance against a set of contextually calibrated criteria and performance targets. A rating tool which embeds spatial data could also be applied to individual allotments providing useful contextual and climatic information to inform house design choice. This contextual and climatic data could be linked to existing tools such as BASIX.
Whilst there is a range of rating tools which have been developed in recent years relating urban release subdivision areas, for example, Precinx, Greenstar
Communities (Green Building Council of Australia), One Planet,
EnviroDevelopment; there is a need for greater leadership in terms of when these tools should be used, how they can be calibrated with specific contextual conditions and how they can be integrated within the existing land use planning framework.
8. Build capacity and lead debate around housing affordability: It has been the experience of regional councils that the local project home industry are often unwilling to alter designs once new home purchasers are contracted to their standard range of housing products. Any challenges to developers or builders are often met with great resistance and conflict, even for most basic of design factors such as orientation. Councils are often blamed by these firms for the additional costs brought to the home purchasers when design changes are required. Whilst there are a number of niche, boutique housing design and construction firms, the consumers will often shop around and go with lower up- front costs of the major firms, despite good advice on the more affordable outcomes and environmental performance that can be achieved over the life cycle of a building. The effect is driving poor design and performance outcomes, and resulting in a pre-BASIX scenario, where councils are pitted against their neighbouring jurisdictions by the development industry to relax local controls. A state mandated BASIX target increase would reset a level playing field for industry, and may reinvigorate industry and consumers to drive uptake of
innovation and best practice design options and put downward market pressure on their costs.
A strong campaign is required to build capacity of building design professionals, planning assessors and certifiers, and match this with a program regulated by the state government to ensure integrity of the development assessment, construction and certification process by monitoring compliance and performance of outcomes4.
9. Likewise, a campaign is needed to inform and educate the consumer market about sustainability choices and true costs and benefits over the life of the building. Council supports the proposed Point-of-Sale disclosure of BASIX scores, or other sustainability rating, to inform the consumer market and drive the industry best-practice. A standard Homeowners Operating Manual might also serve as a resource for homeowners to understand the features and up- keep requirements of their home’s water and energy saving utilities and devices, so as to optimise the expected resource and financial savings over the product life.
10. Need for a stronger role from the Department of Planning and Environment.
There are significant opportunities and challenges for strategic spatial and land use planning practices and development assessment requirements to ensure considerations for advanced energy, energy efficiency and climate change adaptation are applied through land-use activities and the built environment.
DPE is responsible for a range of activities that manage environmental, social and economic issues relating to spatial growth of communities and investment in infrastructure, including:
• The preparation, delivery and review of Regional Growth Plans and State Environmental Planning Policies that operate over 10 to 25 year cycles;
• Regulating assessment processes and conducting major and significant developments and infrastructure determinations, including energy generation projects; and
• Administering BASIX.
Council calls for greater leadership and direction from the DPE to ensure the Environmental Planning and Assessment Act 1979, supporting Regulations and hierarchy of state and local instruments function in an integrated manner in order to deliver the objectives of the draft plans.
Notwithstanding the actions under section 4.1 to “Ensure 100% of NSW Government agencies are taking action to manage their climate change risk”, there is a notable absence of the DPE in the directions to specific agencies5, and in the governance structure of the Climate Change Fund Steering Committee.
4 Final Report - National Energy Efficient Building Project Phase 1
Prepared by Pitt&Sherry and Swinburne University for the Council of Australian Governments (COAG) Energy Council © State of South Australia, 2014.
http://www.sa.gov.au/topics/water-energy-and-environment/energy/government-energy-efficiency- initiatives/national-energy-efficient-building-project
5 NSW Health, Department of Primary Industries, Division of Resources and Energy, and Office of Environment and Heritage
Council calls for greater acknowledgment of the role of DPE to:
• develop a framework for necessary regulatory and operational changes in the strategic land-use planning and development assessment of the built
environment, and
• support council and industry stakeholders to understand how climate change considerations are to be included, tested, monitored and reviewed within these processes.
11. Council notes and supports the draft plans emphasis on increasing tree coverage to manage urban heat island effects in communities and for flooding mitigation and coastal erosion solution6. Local environmental plans and development control plans provide mechanisms for deep soils and minimum lot sizes, set-backs and Floor Space ratios to ensure development includes landscaping for larger trees and vegetation.
However, state planning provisions currently prevail over these local controls and would limit achieving objectives of the draft plans, including:
• Current cap on developer contributions to provide for open space and
landscaping in new greenfield developments, resulting in these requirements often not being met.
• Draft proposed changes to the Exempt and Complying Housing Code for medium density development that proposes permissibility for dual occupancy dwellings on 450m2 lots as complying development. Council is concerned this will lead to dual occupancy developments built to the lot boundary will not allow space for green cover.
12. Council supports the extension of the Government Resource Efficiency Program (GREP) reporting requirements to councils to help identify where and how to make more energy savings. Council also encourages the program to be extended to other agencies such as state-owned corporations.
The requirement to meet the NABERS 4.5 star rating for tenanted buildings would put considerable cost on Council. Council’s Civic Centre at Murwillumbah, for instance, uses 1,000 MWh/annum. A 60kW rooftop solar installation is
planned once asbestos and roof leak issues have been addressed, which would reduce the site’s annual use to 900 MWh. The cost of greenpower for the
remaining 500 MWh could cost up to $30,000 per annum from an already over- stretched operating budget. Arguably, this money would be better spent
investing in energy efficiency or renewable energy projects, therefore flexibility in how agencies meet operational emissions reduction targets is recommended
Assistance will be vital to enable Tweed Shire Council to meet many of the GREP targets e.g.
• Enabling councils to have access to the Office of Environment and Heritage team of energy efficiency specialists will be vital to assist agencies with identifying and managing projects, ensuring projects are of a high quality
• NABERS energy ratings and minimum water standards for offices:
scholarships to enable councils’ building certifiers to complete NABERS ratings for buildings could generate flow on benefits in providing cost-
6 Section 4.5 Increase canopy in heat exposed suburbs and regional towns
effective building performance advice within local communities’ commercial building sector.
Preparing for a Changing Climate
13. Adapting to the anticipated effects of climate change will create greater demands on Council’s resources. A risk management assessment from 2009 identified pest management (fauna, flora and invertebrate pests), flooding, water security and hazard exposure of water distribution infrastructure as high risk priorities in the Tweed. Sharing risk management assessments between agencies such as health facilities, power providers and the wider business and residential
community will be important to ensure localised efforts to manage climate change risks are coordinated.
14. Council supports the proposal to develop a framework for reporting government agencies’ (and councils’) adaptations needs and initiatives to foster opportunities for partnerships and best practice.
15. Council also recommends broader modelling of intra state migration due to the potential impacts of climate change on agriculture. Migration to the coast from inland areas is anticipated, and needs to be built into future population forecasts.
16. Council calls for more activity to strengthen natural ecosystems’ response to climate change. Strengthening funding for biodiversity conservation will be vital to improving the resiliency of natural communities. Coastal habitat in particular will need provision for landward migration as coastlines and sea levels change.
Achieving effective planning outcomes that protect built and natural assets will be crucial.
