Consultation on ‘All things considered’ Infrastructure Victoria’s Options Paper

Dear Secretariat,

Infrastructure Victoria 30 Year Strategy

About SECCCA

South East Councils Climate Change Alliance (SECCCA) is an incorporated association of 8 Councils to Melbourne’s south and east. These councils span the urban-rural divide, they include established suburbs and some of the fastest growing residential developments on the fringe of the metropolitan area. They feature extensive agricultural areas and forested foothills of the Great Dividing Range. They manage a significant percentage of Victoria’s coast, they support well-to-do communities and conversely provide services to the region’s many, many less well-off residents. Together, these councils serve over a million residents and this number is rising rapidly.

SECCCA develops and implements regional programs for climate change mitigation and adaptation. We work across many sectors within our communities, we have a range of innovative and successful projects underway and we are effective and efficient vehicles for regional action.

I make these comments on behalf of the South East Councils Climate Change Alliance (SECCCA). They do not necessarily represent the views of any member council.

Climate change impacts are felt most keenly at the local level at which councils work. Whether it is in the provision of aged care services to those at heightened vulnerability to heat stress, whether operating planning schemes in areas subject to over-land and/or coastal flooding or managing recovery from emergency events such as bushfires, local government is at the front line of climate change response. There is, however, significant disparity in councils’ capacity, in staff and finances, to care for and protect their communities. Many residents of our outer ring of councils face long commute times and so have little time in their families and in their communities. They cope with poor infrastructure (see below - Transport in the south-east) in so many facets of their lives.

Therefore it is most heartening to see the creation of Infrastructure Victoria and this first piece of work to develop a medium-term strategy to inform the roll-out of responses to these many infrastructure needs.

It is extremely important that this work should be conducted at the state level, where responsibility for many of the infrastructure issues resides. Where it might have been expected that local government could work in partnership with the state on relevant projects, it must be noted that rate capping will compromise local government’s ability to jointly fund necessary infrastructure. A Victorian Parliamentary inquiry has just found (Second report into rate capping policy, June 2016) that under rate capping councils lack operational capacity and budget certainty or flexibility to develop long term financial plans for infrastructure, which is essential to address uncertain and worsening climate change risks and impacts.

 

G/Environment/SECCCA/Administration/Correspondence/2016/Infrastructure Victoria Comment from SECCCA

c/- City of CaseyP O Box 1000Narre Warren Vic 3805ABN 638 845 648 42

We have not been good at deriving multiple benefits from the many investments that government makes across the range of portfolios. Does biodiversity enhancement causes issues for fire management for example, or does urban consolidation increase the area of impermeable surface such that localised flooding becomes more frequent? We need to know that portfolios and their respective responsibilities are aligned. Infrastructure Victoria’s 30-year Infrastructure Strategy should be developed in alignment with an amended Climate Change Act and a Victorian Climate Change Strategy prepared pursuant to the Act, as recommended by the Independent Review (IR) of the Climate Change Act 2010.

Infrastructure Sustainability (IS) rating schemeIS is Australia’s only comprehensive rating system for evaluating sustainability across design, construction and operation of infrastructure.  IS evaluates the sustainability (including environmental, social, economic and governance aspects) of infrastructure projects and assets. Areas considered as part of the rating tool include:

- Climate Change Adaptation- Energy & Carbon- Water- Materials- Emissions, Pollution and Waste- Discharges to Air, Land & Water- Land- Waste- Ecology

This rating tool should be used for all major infrastructure projects to ensure detailed consideration of these important areas.

Critical Asset Centralised Risk Management

Recommendation 17 of the IR that the Victorian Government should conduct a full analysis of climate change risks for the state must be adopted, as should Recommendation 19 that the Victorian Climate Change Strategy should include an adaptation and disaster risk reduction component that specifies climate change risks and costs for Victoria, objectives for mitigating risks and roles and responsibilities of state and local government in addressing risks. This option should be developed in line with that recommendation.

The option should:

- Enhance coordination of climate change risk mitigation and planning, particularly in growth areas - Encourage and provide state assistance to develop consistent and best practice risk management strategies and practices across local government- Identify urgent climate change risk management issues and opportunities - Help resource-constrained councils to develop better climate change risk management.

Coastal Protection Infrastructure

A number of SECCCA member councils have significant coastal exposure, indeed Mornington Peninsula Shire hosts 10% of Victoria’s coast. Councils which face Western Port have been involved in the Local Coastal Hazard Assessment project with Melbourne Water and DELWP to assist in informing the implementation of councils’ planning responsibilities. Similar work on Port Phillip would be helpful. SECCCA supports the work of the Association of Bayside Municipalities in developing a Regional Coastal Adaptation Framework for Port Phillip Bay.

G/Environment/SECCCA/Administration/Correspondence/2016/Infrastructure Victoria Comment from SECCCA

It is vital to take the ABM’s work on the Framework into account in developing this option, as it contains detailed findings and recommendations based on robust research in relation to interdependencies between state and local authorities and coastal adaptation opportunities.

This option could:

- Develop business cases to develop and fund key coastal protection measures- Enhance collaboration between state and local government on coastal protection.

Landfill waste levy increase

An increase in the landfill waste levy needs to be assessed in light of its potential for positive environmental outcomes due to a reduction in waste at source and increased recycling. As a punitive measure to drive a reduction in waste it could be a useful foray into the market. This will be the case so long as it doesn’t drive negative outcomes such as increased likelihood of illegal dumping and cause equity issues through socio-economic considerations.

Energy Demand Management Efficiency

SECCCA supports inclusion of Project Based Assessments in VEET, which will allow stakeholders to do equipment or process upgrades that results in energy savings specific to a particular business/site. (Currently, stakeholders can only create VEECs for individual activities (lighting, hot water systems, etc) that have set VEEC calculations. The Project Based Assessments will allow for more tailored calculations for specific sites that should mean greater energy savings.)

Rooftop solar electricity, battery storage technology and smart energy management software solutions are developing that allow energy to be stored and supplied to the grid at times that supply is limited. A fully reflective feed in tariff provides those with solar electricity systems the wholesale value of the electricity they feed into the grid. Providing the option for retailers to offer a fully reflective feed in tariff will support the development of solutions to enable distributed generators to support the network at times when electricity is in demand and the wholesale price is high. This will not only support the network and reduce infrastructure requirements but also enable interested consumers to maximise their return on their renewable energy investment through smart energy management and assist with the growth in new technologies and jobs.

SECCCA is supportive of simplified time varying feed in tariffs also being available. A key part of this is a critical peak tariff. A critical peak tariff is crucial to recognise the full benefit of energy being provided to support the network during times of critical peak demand under a simplified feed in tariff structure. This will also encourage energy efficient behaviour at these times to enable electricity to feed into the network, rather than be used onsite. These changes are consistent with recommendations in the Essential Services Commissions recent report on the value of distributed generation.

Energy Efficient Development

There is an opportunity to embark upon reform of the building regulations to improve energy efficiency. While community-based not-for-profits such as SECCCA work bottom-up to bring about modest change, a bold government could in one fell swoop, deliver magnitudes of benefit through the preparedness to regulate. These benefits include the following:

- Significantly reduce energy consumption and directly reduce energy costs for residents- Increase jobs and skills in building construction and energy-efficiency advice and design- Raise awareness in the community of environmental and financial benefits from lower energy use in homes

G/Environment/SECCCA/Administration/Correspondence/2016/Infrastructure Victoria Comment from SECCCA

- Leverage and encourage energy-efficient development (e.g. Henley’s 8 star zero emissions house at Selandra Place in Cranbourne North http://www.selandracommunityplace.com.au/

SECCCA is supportive of incorporating Sustainable Design Assessment in the Planning Process (SDAPP) into the State Planning Policy Framework (SPPF). This will ensure that a high level of sustainable design is achieved for new development in a way that is practical and affordable. SDAPP will ensure that sustainability requirements are addressed early in the process of development at the planning stage making them easier and less costly to implement. SECCCA member councils have been working on requiring SDAPP for a number of years, the lack of inclusion of these principles in the SPPF has made this challenging.

Requiring SDAPP across the state will also ensure that a consistent approach to this important area is followed and stop developers building low quality developments in municipalities with less resources to require SDAPP.

Currently low quality commercial development is occurring in Melbourne’s growth areas as the majority of outer suburban Council’s require support to incorporate SDAPP. SDAPP does require significant resources to implement and support from the State government with this resourcing requirement will help to ensure the success SDAPP’s incorporation and its many benefits.

Regulatory reform to strengthen building regulations to improve energy efficiency is also an important area, especially for buildings that do not require a planning permit (eg. new homes in growth areas). SDAPP however should be prioritised as it enables levels of sustainable design to be increased based on specific considerations for each development. SDAPP can achieve a greater level of sustainable design for a lower cost given the aim of achieving the highest level of sustainable design in the most practical way and the consideration of a broader variety of factors than the building code.

Environmental Upgrade Agreements

Now that legislation has passed to allow the involvement in Environmental Upgrade Agreements with local governments across Victoria, there is a communication and marketing program needed to promote them. For many councils, they are a new concept and without support for their implementation, including sources of capital to support their uptake, it should not be expected that uptake at the rate needed will occur.

Residential Tenancies (Caravan Parks and Movable Dwellings Registration and Standards) Regulations 2010

SECCCA is significantly concerned regarding the current regulations for movable dwellings. These regulations do not require energy ratings for movable dwellings regardless of their size. This is leading developers to create retirement from movable dwellings that do not meet energy rating requirements.

These types of developments are placing elderly members of the community in sub-standard housing. With extreme heat set to increase due to climate change this presents a significant health risk to those most vulnerable. The regulations should be changed to ensure unregistered movable dwellings meet energy rating requirements to stop the proliferation of substandard housing infrastructure.

Ageing coal generation asset transition

This option should consider a proposal to rapidly decarbonise the economy by shutting down brown coal-fired power stations, contained in Brown coal exit: A market mechanism for regulated closure of highly emissions intensive power stations, 2015, by Frank Jotzo from Centre for Climate Economics and Policy, Crawford School of Public Policy, ANU, and Salim Mazouz, Principal, Centre for International Economics.

G/Environment/SECCCA/Administration/Correspondence/2016/Infrastructure Victoria Comment from SECCCA

Local solar energy generation

Policies directed to increasing local solar generation should be conducted in alignment with the closing down of dirty coal-powered electricity generation. Barriers to the implementation of solar need to be identified as they are different in different markets. Further, along with the move to different sources of energy, there should be a reduction in the amount of energy used through programs for improving energy productivity. Actions to be considered include:

- Encourage solar in sluggish or non-existent markets, e.g. low income business, households, rental market, (30KW and higher)- Encourage innovation, e.g. microgrids in commercial and industrial precincts hold significant potential in the SECCCA region Wind and solar energy generation large-scale investments (WSE)

Renewable energy infrastructure is critical to achieve a transition to zero net emissions by 2050 as outlined in the recently announced state government target. A targeted grants program to support this infrastructure development is supported by SECCCA.

Natural Disaster Financial Assistance to provide support for betterment

Currently natural disaster financial assistance is provided after a natural disaster to recover infrastructure to current standards. In some cases it makes sense to replace damaged infrastructure with alternative assets on land that is less subject to climate change impacts including flooding and inundation, or go beyond current standards to increase infrastructure resilience. The state government should advocate that natural disaster financial assistance (provided by the federal government) is available for betterment where appropriate. This will assist with rebuilding damaged infrastructure to a level that is more resilient.

Meet growing demand for access to economic activity in central Melbourne - Train station car-parking improvement (TSC)

Car parking expansion works are ongoing. The example below shows Beaconsfield railway station in early 2016. The car-park is at capacity, though it was increased in size in late 2012 by over 50%. Car parking issues at train stations are a symptom of a broader issue of increased urban development in areas underserviced by public transport. Residents of these areas have no option but to drive to train stations.

Increasing efficient bus connections to train stations, safe bicycle paths to train stations and increased medium to high density development in walking distance of train stations will help to combat this problem. The extension of rail lines and new train stations being developed in growth areas will also take stress off existing stations.

With train station car-parks expanding, it is important that adequate protection from extreme heat is provided. Cars sitting all day in hot car parks exposed to extreme temperatures increase heat stress on commuters. These large uncovered car-parks also contribute to the urban heat island effect, creating hot zones in areas that should be the central activity areas of our suburbs.

There is a significant opportunity to cover these car-parks with large solar electricity systems to generate renewable energy as we transition away from coal-fired power plants. This will not only produce clean energy, it will also protect commuters from extreme heat as they make their way to and from train stations and reduce the urban heat island effect.

G/Environment/SECCCA/Administration/Correspondence/2016/Infrastructure Victoria Comment from SECCCA

Beaconsfield train station example in the Cardinia Shire.

Insufficient capacity leading to ad hoc parking on grass and non-sealed areas. Also note large areas of paved surface with all spaces taken. There are many examples of similar public transport interchanges across the metropolitan area.

Clyde rail extension (CRE) – Extend the metropolitan rail network to Clyde from the current terminus at Cranbourne in Melbourne’s south east

With ongoing urban growth in Cranbourne East and Clyde it is critical that the metropolitan rail network is extended to Clyde. This will make these new urban areas more connected and improve the quality of life of their residents. Without a railway station residents in this area are disadvantaged and have fewer opportunities. With many young families in this area it is crucial that their children have the same opportunities to access work and study opportunities as other Melbournians.

This extension should be completing with the foresight and planning to accommodate a future additional extension of this rail line to the planned Koo Wee Rup airport.

Pakenham East metropolitan rail network extension and train stationA metropolitan railway extension is also required to Pakenham East with a new urban growth area being planned for this region. Pakenham East will accommodate 16,000 residents in the coming years. As with residents in Clyde and Cranbourne East, these residents will be disadvantaged without a train station on the metropolitan rail network.

Recycled treated wastewater for non-potable peri-urban agricultural use (TWR) – Greater use of recycled wastewater for new agricultural activities in peri-urban areas.

It is important that our most productive agricultural soils are supported by secure access to recycled water. Previous studies have indicated the feasibility of utilising Class A recycled water from the Eastern Treatment Plant and delivering it to the Bunyip Food Belt region which extends through the southern agricultural regions of Casey and Cardinia. This connection would enable the intensification of food production in this region to provide economic and food security benefits for Victoria. It would also help to build resilience as increased periods of drought are expected due to climate change.

G/Environment/SECCCA/Administration/Correspondence/2016/Infrastructure Victoria Comment from SECCCA

SECCCA is pleased to offer these comments and would welcome the opportunity to expand upon them as you wish.

Yours sincerely

Executive Officer 17 June 2016

Transport in the south-east

G/Environment/SECCCA/Administration/Correspondence/2016/Infrastructure Victoria Comment from SECCCA

Bus interchange example at Fountain Gate, Narre Warren in the City of Casey - south facing meagre shelters on a windswept poorly-furnished plaza.

There are many examples of similar public transport interchanges across the metropolitan area.

It is hardly possible to suggest more comprehensively that public transport is a residual service and that anyone who can would drive a car rather than take a bus.

Photograph: SECCCA 2016