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VfCA's Submission to NSW Environment Protection Authority

 

 

Dear Chair and Committee

NSW Environmental Protection Agency’s draft Climate Change Policy & Action
Plan

Climate change is increasingly an animal health and welfare issue. Animals hold no
responsibility for the causes of climate change, yet they feel the consequences most
strongly. Approximately 3 billion animals were killed or displaced by the 2019-20
bushfires, hundreds of thousands more killed by floods, and domestic pets suffer from
heat stress each summer. Veterinary professionals and animal carers are on the
frontline experiencing the impacts first hand.
Vets for Climate Action (VfCA) is a not-for-profit, registered charity which represents
over 2000 members of the veterinary profession and animal care community around
Australia, including over 300 in NSW. Our role is educating, collaborating, and
advocating for climate action within the veterinary community, broader animal care

Vets for Climate Action: Submission to NSW EPA’s draft Climate Change Policy & Action Plan 1

network, and government. Thirty three former Chief Veterinary Officers and Senior
Government Veterinarians (the former CVO Group) work alongside us and our Patron
is Professor Peter Doherty; a veterinary surgeon, Nobel Laureate and former Australian
of the Year. Our Board consists of six Directors, including Professor Mark Howden,
Nobel Laureate and a current Vice Chair of the Intergovernmental Panel on Climate
Change (IPCC).
VfCA supports the NSW Environmental Protection Agency’s Climate Change Policy
(Policy) and Climate Change Action Plan 2022-25 (Action Plan) and applauds these
steps to protect our people and animals. However, we provide additional comments
below that the EPA could consider adopting so the Policy and Action Plan are both
ambitious and impactful, and ensure a world where animals and people thrive in a
healthy environment.
VfCA and the former CVO group would be pleased to provide the EPA with independent
advice at any time on specific elements of the Policy and Action Plan, particularly where
it relates to animal health and welfare.

Key Issues for considerations
VfCA is pleased the NSW Environmental Protection Agency (EPA) recognises its
statutory obligation to protect the community and environment from harm, including that
caused by climate change. We recognise the release of the draft EPA Climate Change
Policy and Climate Change Action Plan 2022-25 as an important and timely step in this
critical decade for action on climate change, and a significant shift within the EPA
confirming its duty in relation to climate change.
Targets
One of the Policy’s key objectives is:
● to reduce greenhouse gas emissions in line with NSW Government’s net zero
targets which are
- a 50% reduction in emissions by 2030, compared to 2005 levels
- net zero emissions by 20501

VfCA celebrates the NSW Government’s commitment and that its net zero targets are
stronger even than those legislated by the Federal Government in the recent Climate
Change Act 2022 (Cth) and the Climate Change (Consequential Amendments) Act
2022 (Cth).

The importance of reducing carbon emissions to zero cannot be overstated. In
scenarios assessed by the IPCC in its Sixth Assessment Report of the
Intergovernmental Panel on Climate Change (6th Assessment Report) limiting
warming to around 1.5°C requires global greenhouse gas emissions to peak before
2025 at the latest, and be reduced by 43% by 2030; at the same time, methane would
also need to be reduced by about a third.2
Even if we are to limit global greenhouse gas emissions, it is almost inevitable that we
will temporarily exceed 1.5°C and the consequences will be stark: heatwaves, droughts,
bushfires and intense rain events will become even more severe. Sea levels will rise,
species will become extinct and crop yields and livestock production will fall. This will
cause further food and water insecurity, economic disruption, conflict, and terrorism3
.
VfCA asks that the NSW Government, and the EPA, approach these targets as “a floor,
not a ceiling” on emission reductions as the Federal Government4 has stated it will. In
fact, there are cogent arguments that Australia should aim to reduce emissions by 75%
below 2005 levels by 2030 and reach net zero emissions by 2035.5 This would protect
Australia from the worsening effects of climate change including irreversible changes.6
There is no safe level of global warming.
Urgency and the timeframe for action
The Action Plan intends actions to be staged over 3 years: 2022 - 2025, with a review of
the Policy and Action Plan due for review in 2025 or earlier “if required”.7
Additionally, with a heavy emphasis throughout the Action Plan on consultation,
information, guidance, support, encouragement, assistance, and listening, VfCA fears
there is not enough focus on direct regulation or enforcement through existing powers

Vets for Climate Action: Submission to NSW EPA’s draft Climate Change Policy & Action Plan 3

and tools to regulate climate pollution and support the NSW Government’s net zero
targets.8 These tools include, but are not limited to, issuing environment protection
licences (EPLs) or developing economic measures such as putting a price on
greenhouse gas emissions. We note the Action Plan foreshadows stronger regulatory
responses and market-based approaches (such as charging a fee for greenhouse gas
emissions) may only be applied in the “medium to longer term if it is required”9.

As a result, VfCA believes the Policy and Action Plan do not reflect the urgency of the
situation. This timeline means the regulatory power of the EPA may not be put to use
until at least half way through this decade, which is already considered at least a
decade too late.10
In a 2011 report, the then Climate Commission identified 2010 - 202011 as the critical
decade for action to minimise climate change risks. However, the decade to 2020 was
marked in Australia by inaction and climate wars. This was symptomatic of a global
malaise. As a result, this decade has begun with accelerating emissions and record
temperatures. In May 2022 the highest atmospheric carbon dioxide (CO2)
concentrations in the history of humankind were recorded: 421 parts per million. This is
50% higher than pre-industrial levels.12 And, the last eight years have been the hottest
on record with decadal global temperatures at 1.1°C above the average from the start of
the industrial revolution.13

In fact, the CSIRO states that Australia’s climate has warmed

on average by 1.44°C since national records began in 191014
.

The painful truth is that the latest data indicates that the world is on track for a
temperature rise of between 2.4°C and 2.6°C or more by the end of this century and
there is “no credible pathway to 1.5°C in place” today.
15

Vets for Climate Action: Submission to NSW EPA’s draft Climate Change Policy & Action Plan 4

VfCA asks that the EPA strengthen the timeframes for action and encourage the use of
the EPA’s full range of powers prior to 2025 to ensure the NSW Government’s net zero
targets are achieved as planned.
Climate change is not a future problem. It is with us and there is no time to delay.
Three Key Pillar Framework
The EPA is relying on three key pillars to deliver on their Policy and Action Plan:
1. Inform and Plan
2. Mitigate
3. Adapt
We consider each of these framework approaches below.
1. Inform and Plan
In large, VfCA supports this approach and particularly recognises the importance of the
following actions proposed by the EPA:
- Continuing Action 2: Engage and collaborate with climate change experts
across the NSW Government and with other jurisdictions.
VfCA also recommends that the EPA look to consulting with external, independent
climate experts to ensure the full wealth of information and expertise is utilised.
- New Action 2(c): Partnering with the Department of Planning and Environment
(DPE) to ensure climate change is adequately addressed by proponents of
activities it will regulate.
VfCA believes that it is imperative that the Environmental Planning & Assessment
Act 1979 (NSW) is amended to include explicit reference to climate change
16
, and
that climate is a mandatory consideration in all planning assessments, approvals and
decisions. We also consider that Climate Impact Statements must be required for
major projects to assist decision-makers assess whether the project will have
unacceptable impacts on the climate and our wildlife, and that are contrary to the
NSW Government's Net Zero goals.

16 It is disappointing that the Environmental Planning and Assessment Amendment (Climate Change
Response) Bill 2022 lapsed on 21 October 2022 and we hope that another bill will be considered as a
matter of urgency.
Vets for Climate Action: Submission to NSW EPA’s draft Climate Change Policy & Action Plan 5

- New Action 3: Listen and learn from Aboriginal people; create opportunities to
meaningfully engage and receive feedback on its climate change response
- New Action 4: Regularly discuss our climate change approach with the EPA’s
Youth Advisory Council, to ensure the EPA is putting intergenerational equity
into practice

2. Mitigate
VfCA supports taking action to reduce the rate of climate change and is pleased that the
EPA recognises this requires ‘taking action to limit or prevent greenhouse gas
emissions and activities that remove these gases from the atmosphere.’17
It is
imperative greenhouse gas emissions are urgently reduced to keep temperature
increase at 1.5°C and prevent the catastrophic impacts on climate change to animals,
humans and the environment, discussed further below. Thus, this is the most important
pillar in the Action Plan.
Again, VfCA supports the continuing and proposed actions by the EPA. However we
request that a number of these are strengthened to ensure that the EPA is able to
effectively regulate greenhouse gas emissions. As the EPA recognises in its Action
Plan, its environment protection licensees are the largest source of greenhouse gas
emissions within its regulatory remit.18
- Continuing Action 5: Support the whole of government approach to
streamlining project approvals in renewable energy zones.
VfCA strongly supports the investment and development of renewable energy zones
(REZs), using renewable energies including wind and solar, and providing economic
opportunities for the regional communities in which they will be located. This transition
to renewables ought to occur with the utmost urgency.
Additionally these projects must follow ecologically sustainable standards to ensure
REZs are located, designed and operated to ensure there are no adverse impacts on
our native wildlife (and flora), and preferably enhance outcomes for them.
- Continuing Action 7: Ensure methane emissions from EPA-licenced
onshore-gas operators are minimised; review existing leak detection and repair
programs

Vets for Climate Action: Submission to NSW EPA’s draft Climate Change Policy & Action Plan 6

VfCA recommends that this action be extended to include methane from coal mines.
We support all actions that require and enforce improved leak detection and repair. As
recommended by the IPCC’s 6th Assessment, all methane production needs to be
reduced by at least a third by 2030.19
- New Action 7: Develop a series of greenhouse gas emission reduction targets
and related pathways for key industry sectors the EPA licences, to help guide
the EPA’s regulatory effort
While we commend the EPA’s approach to consult with the relevant industry sectors,
we do not support targets that are based on what is “reasonable and feasible for the
sector”.20
VfCA urges the EPA to ensure these emission reduction targets are science-based,
ambitious and legally enforceable. Again, recognising the urgency with which action is
required, we ask that these targets be set within the first year, not “over the next three
years”.21
- New Action 9: Progressively place greenhouse gas emission limits and other
requirements on licences for key industry sectors.
As per New Action 7, VfCA urges the EPA to ensure that greenhouse gas limits are
science-based, ambitious and legally enforceable (rather than “feasible”22
).

Additionally, we recommend this action be extended to all licences and that this action
occur within the first year, recognising that this is a critical decade for action on
climate change. Delay will cost our animals and people much more than it will for
licensees to comply with any requirements and targets.

3. Adapt
The EPA’s Policy and Action Plan recognises that communities, businesses and the
economy can, to some degree, adjust and adapt to the existing and anticipated effects
of climate change. However most animals (companion, livestock and wildlife) cannot or
will not be able to adapt in time, risking further extinctions and biodiversity loss.
Australia has the unenviable record of the worst mammal extinction rate in the world. In
NSW alone 1,043 species and 115 ecological communities are listed as threatened
under the Biodiversity Conservation Act 2016 (NSW) including 78 species declared

Vets for Climate Action: Submission to NSW EPA’s draft Climate Change Policy & Action Plan 7

extinct since European settlement.23 The Bramble Cay melomys, a small rodent in the
Torres Strait Islands, is the first mammal to become extinct due to climate change. It is
thought that rising sea levels and storm surges resulted in the loss of the animal’s
habitat.

The NSW EPA’s own State of the Environment 2021 Report24

recognises the threat
climate change is to a number of our unique species. It identifies the species most at
risk from climate change include those with:
● a narrow range of physiological tolerances
● low genetic variability and long generation times
● specialised relationships with other species or narrow geographic ranges
● limited physical capacity to disperse or move to new habitats25
While some species and ecosystems may adapt through a range of strategies, such as
changing their behaviour, or moving to more suitable climates,26

the increasing rate of
climate change and pre-existing threats (like natural resource exploitation, land clearing
and introduction of invasive species) may limit their success.
This is in large part why VfCA believes the Mitigation framework pillar (as discussed
above) is the most important to ensure success. Despite playing no role in causing
climate change, our animals have already suffered from its effects:
- In November 2018, when temperatures exceeded 42°C for two days in a row in
an extreme Queensland heatwave, 23,000 spectacled flying foxes (nearly one
third of the entire Australian population) were killed.27
- The sex of a sea turtle is determined by the sand temperature in which the eggs
incubate. When temperatures are below 29.1°C the turtle will be born male. But,
with temperatures on the rise due to climate change, 99 out of a hundred turtles
are being born female. This threatens the future of many turtle species including
the Pacific green sea turtle which nests in northern Queensland.28

Vets for Climate Action: Submission to NSW EPA’s draft Climate Change Policy & Action Plan 8

- 127 ringtail possums died after they became so dehydrated they drank sea water
after 4 days of temperatures in the high 30s, in the Mornington Peninsula,
Victoria in early 2019.29
- Floods in Far North Queensland killed over 600,000 cattle in 2019. Those that
didn’t drown died of cold exposure in the summer month of February. The
damage bill was estimated at $2 billion.30
- In all floods, burrowing animals (mammals, insects, reptiles, amphibians and
arachnids) and fish are heavily impacted.
- An estimated 475,000 cattle (or about 2% of the national herd) have been
affected by flooding in NSW and southern Queensland this year (as have food
and feed crops).31
- By April this year, Japanese Encephalitis, a tropical mosquito-borne disease,
endemic to Asia and the Pacific, was confirmed in commercial pig farms in
Queensland, NSW, Victoria and SA causing reproductive losses and neonatal
deaths in pigs. The perfect conditions for the virus to travel well south of where it
is usually found has been caused by climate change: warming temperatures,
record floods and rainfall.32 A zoonotic disease, it threatens not just livestock but
also humans, with 37 human cases also recorded and 3 deaths.33
- Over 3 billion animals died or were displaced during the 2019-2020 bushfires:
○ 143 million mammals;
○ 2.46 billion reptiles;
○ 180 million birds; and
○ 51 million frogs.34
Climate change is an animal health and welfare issue, as well as an economic threat.
Without action on climate change, we can expect further extreme weather events like

Vets for Climate Action: Submission to NSW EPA’s draft Climate Change Policy & Action Plan 9

fire and flood, and diseases to threaten our animals (and people). We risk losing even
more of them, as well as the life-supporting benefits they provide by contributing to
biodiversity.
Earlier this month, the Minister for the Environment, Tanya Plibersek, announced that
the Federal Government has set a goal to prevent any new extinctions of Australian
wildlife. However, statements about environment and wildlife protections are
meaningless unless climate change is effectively addressed through strong policy and
action at every level.
Forests are an integral part of the global carbon cycle, as well as home to many of our
unique species, absorbing twice as much carbon as they emit each year. In this way,
forests are a ‘carbon sink’. However if deforestation continues (through either clearing
or fire), we risk them becoming a carbon source.35
As a result, in relation to:
- Continuing Action 11: Ensuring climate risks are considered in native forestry
via the Forest Monitoring and Improvement Program
VfCA believes that it is important to establish an ambitious timeframe to cease or limit
operations like timber harvesting and thinning, constructing access roads, burning,
and grazing in NSW’s native forests.
In the EPA’s own words, “[t]he native forests of NSW are one of our most valuable
assets, benefiting the community, wildlife, and the economy.”36 Protecting our
remaining forests are critical to supporting Mitigation under pillar 2 and ensuring the
NSW Government reaches its net zero goals.

Conclusion
By regulating greenhouse gas emissions, the NSW EPA’s Climate Change Policy and
Action Plan have the potential to drive real and urgent action on climate change and
achieve the NSW Government's net zero targets. However, it is imperative that the final
versions contain ambitious, science-based targets backed by strong regulatory powers
with urgent timeframes.

VfCA commends the NSW EPA for its commitment and welcomes timely action on
climate change for the safety of our people and communities, and the animals we love
and need.

We appreciate the opportunity to provide feedback. As mentioned, VfCA and the former
CVO group would be pleased to provide the EPA with independent advice at any time
on specific elements of the Policy and Action Plan, particularly where it relates to animal
health and welfare.
Yours sincerely

Tara O’Connell
Chief Executive Officer
Vets for Climate Action
E: [email protected]
M: +61 411 037 534

Dr Jeannet Kessels BVSc (Hons)
Chair
Vets for Climate Action
E: [email protected]
M: +61 402 771 173

 

1 p. 14 EPA Climate Changes Policy: Draft for Consultation accessed 24 October 2022 Vets for Climate Action: Submission to NSW EPA’s draft Climate Change Policy & Action Plan 2
2 IPCC, 2022: Summary for Policymakers. In: Climate Change 2022: Mitigation of Climate Change. Contribution of Working Group III to the Sixth Assessment Report of the Intergovernmental Panel on Climate Change [P.R. Shukla, J. Skea, R. Slade, A. Al Khourdajie, R. van Diemen, D. McCollum, M. Pathak, S. Some, P. Vyas, R. Fradera, M. Belkacemi, A. Hasija, G. Lisboa, S. Luz, J. Malley, (eds.)]. Cambridge University Press, Cambridge, UK and New York, NY, USA. Doi: 10.1017/9781009157926.001, accessed 24 October 2022
3 United Nations, The Climate Crisis – A Race We Can Win, 2020, accessed 24 October 2022
4 Ellen Ransley, Chris Bowen: ‘bit to go yet’ on climate bill as government prepares to introduce bill, The Australian, 27 July 2022, accessed 24 October 2022
5 Will Steffen, Lesley Hughes, Simon Bradshaw, Dinah Arndt and Martin Rice, Aim High, Go Fast: Why emissions need to plummet this decade, The Climate Council, 2021, accessed 24 October 2022
6 Steffen, Hughes et al, Ibid
7 p. 7, EPA Climate Change Action Plan: 2022-25, accessed 24 October 2022
8 Environmental Defenders Office, Empowering the NSW EPA to Prevent Climate Pollution, 2020, accessed 25 October 2022
9 p. 50, EPA Climate Change Action Plan: 2022-25, accessed 24 October 2022
10 Steffen, Hughes et al, Ibid
11 W. Steffen & L. Hughes, The Critical Decade: New South Wales climate impacts and opportunities, TheClimate Commission (Department of Climate Change and Energy Efficiency), 2011, accessed 24 October2022
12 US National Oceanic and Atmospheric Administration, Carbon dioxide now more than 50% higher thanpre-industrial levels, 3 June 2022, accessed 24 October 2022
13 Josh Davis, The last eight years have been the hottest on record, Natural History Museum, 14 January2022, accessed 25 October 2022
14 CSIRO & Bureau of Meteorology, State of the Climate, 2020, accessed 24 October 2022
15 Climate Change: No ‘credible pathway’ to 1.5C, UNEP warns, UN News, 27 October 2022, access 28 October 2022
16 It is disappointing that the Environmental Planning and Assessment Amendment (Climate ChangeResponse) Bill 2022 lapsed on 21 October 2022 and we hope that another bill will be considered as amatter of urgency.
17 p. 25, EPA Climate Change Action Plan: 2022-25, accessed 24 October 2022
18 p. 25 Ibid
19 IPCC, 2022 Ibid
20 p. 33, EPA Climate Change Action Plan: 2022-25, accessed 24 October 2022
21 p.32, EPA Climate Change Action Plan: 2022-25, accessed 24 October 2022
22 p. 36, EPA Climate Change Action Plan: 2022-25, accessed 24 October 2022
23 NSW EPA, NSW State of the Environment: Threatened Species, accessed 29 October 2022
24 NSW EPA, NSW State of the Environment, accessed 29 October 2022
25 NSW EPA, NSW State of the Environment: Threatened Species, accessed 29 October 2022
26 NSW EPA, NSW State of the Environment: Threatened Species, accessed 29 October 2022
27 Sharnie Kim & Adam Stephen, Extreme heat wipes out almost one third of Australia’s spectacled flying fox population, ABC News, 19 Dec 2018, accessed 28 October 2022
28 Craig Welch, Rising Temperatures Cause Sea Turtles to turn Female, National Geographic, 9 Jan 2018, access 28 October 2022.
29 Lisa Cox, ‘Falling out of tree’:dozens of dead possums blamed on extreme heat stress, The Guardian, 7 March 2019, accessed 28 October 2022
30 Tom Major, Cattle, infrastructure losses following Queensland floods could near $2b, farm lobby says, ABC News, 16 April 2019, accessed 28 October 2022
31 Natasha May, Floods and livestock losses leave NSW and Queensland farmers reeling from third disaster in three years, The Guardian, 2 March 2022, accessed 28 October 2022
32 Frances Vinall, As Australia’s climate changes, a tropical disease advances, The Washington Post, 14 April 2022, accessed 29 October 2022
33 World Health Organisation, Japanese Encephalitis - Australia, 28 April 2022, accessed 29 October 2022
34 p. 2, Interim Report: Australia’s 2019-2020 Bushfires: The Wildlife Toll, WWF, 28 July 2020, accessed 28 October 2022
35 Nancy Harris & David Gibbs, Forests Absorb Twice As Much Carbon As They Emit Each Year, World Resources Institute, 21 January 2021, accessed 29 October 2022.Vets for Climate Action: Submission to NSW EPA’s draft Climate Change Policy & Action Plan
10
36 NSW EPA, Native forestry: NSW overview, accessed 29 October 2022

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