Director of Climate Change and Water Division

30 September 2009MDS/HB/MLM

Claire Bennett

Director of Climate Change and Water Division

Welsh Assembly Government

CathaysPark

Cardiff

CF10 3NQ

Dear Claire

Climate Change Strategy – Programme of Action consultation

The National Public Health Service for Wales welcomes the opportunity to respond to the Welsh Assembly Government’s Climate Change Strategy – Programme of Action consultation documentand I have sought the views of Huw Brunt, Consultant in Environmental Health Protection and Carolyn Lester, Lead for Health Inequality and Equity.

We recognise that, whilst climate change is a global phenomenon, many of its associated effects have the potential to impact on the population of Wales. It is therefore of paramount importance that we work collaboratively to develop co-ordinated plans that set out sustainable, achievable and tangible mitigation and adaptation-related actions to tackle these effects.

In public health terms, the anticipated impacts of climate change could be significant. Some of these impacts may be a direct result of climate change effects, such as temperature and extreme weather-related morbidity and mortality. Other impacts, however, may be indirect (e.g. water, food, vector and rodent-borne diseases, air pollution-related health effects, effects of food and water shortages, allergic diseases and ancillary health benefits). In addition, there are likely to be wider public health impacts that are influenced by impacts on planning and the built environment, vulnerable population groups, environmental and health inequalities, energy and transport, food and agriculture and insurance.

With these potential public health impacts in mind, provided below are some comments that I hope will support the Welsh Assembly Government’s consultation process around the document and inform the development of the final Climate Change Strategy for Wales. Since many of the questions posed in the consultation document were not public health specific, I have attempted to pull together comments under general headings.

GENERAL

• Although acknowledging that a brief description of the work of the Climate Change and Health Working Group is contained in section 5.6 of the consultation document, I am concerned that, considering the potential for the effects of climate change to impact significantly on public health, there is no ‘health-specific’ chapter as there are for other sectors e.g. waste, agriculture/land and business. I hope that the comments provided in this consultation response highlight the importance of health considerations in terms of climate change impacts and demonstrate that NHS agencies, and public health professionals in particular, have a key role to play in facilitating collective action to mitigate against, and adapt to, such impacts;
• Page 7 of the strategy sets out a vision for 2050. Long term targets can diminish the perceived urgency for action, with the risk that sectors may fail to act now in the hope that they can ‘catch up’ later. Targets should avoid being too modest at the outset and emphasise the need for immediate action.

MITIGATION

• Making the links with public health

Climate change is an important public health issue and all carbon reduction strategies and action plans should, therefore, have health protection and improvement as core values. For example:

-Physical activity: Physical activity can improve physical and mental health and active travel can reduce car use. After cycling or walking home, further carbon reduction could be achieved as it is feasible that a lower domestic temperature would be required for maybe the first 30 minutes after return.

-Healthy eating: Home-cooked low fat meals with plenty of fruit and vegetables are healthier than ready meals. A family meal is socially beneficial and can potentially use less power than several individuals cooking separately. When the family is sharing a meal in one room, heating can be reduced in other parts of the home.

-Mortality: Warmer winters are likely to result in lower excess winter mortality in the elderly and it is unlikely that this will be matched by the possibility of increased mortality during heat waves. There is, therefore, likely to be a net increase in the elderly population.

-Morbidity: The predicted increase in the elderly population will result in greater demands on health and social services and there is also a possibility that new diseases will occur in the UK due to global warming. This could be exacerbated by ‘climate change migration’ if people from hotter countries attempt to move to more temperate zones.

• Behaviour change issues

The document rightly identifies behaviour change as an essential component in reaching carbon reduction goals. There will, therefore, be a significant and continuing requirement for public education and it is clear that, for maximum impact, this will need to take place at both a national and local level. Programmes which target school children would have the twin benefits of educating future consumers and applying pressure on parents to live more sustainably.

Experience from health promotion, however, demonstrates that providing information can raise awareness but does not necessarily change behaviour. Changing entrenched behaviour is a complex matter and seldom achieved by appeals to altruism, so information regarding the undesirable impacts of climate change on future generations or on African or Asian populations may not be effective.

Theories and models of behaviour change can provide a useful framework upon which to base a carbon reduction campaign. These include the Theory of Planned Behaviour, Social Cognitive Learning Theory, Diffusion of Innovations, and the Stages of Change Model.

Weinreich (1999) provides a useful synthesis of the main behaviour change theories in which he lists conditions that need to exist in the target group:

-Belief in the risk and severity of the problem

-Belief that the proposed behaviour will lower or prevent the risk

-Belief that benefits of the behaviour outweigh costs

-Intention to perform the behaviour

-Skills to perform the behaviour

-Self efficacy

-Belief in consistency of behaviour performance with self image

-Perception of consistency with social norms

-Experience fewer barriers to perform than not to perform.

Diffusion of Innovations theory as discussed in Malcolm Gladwell’s The Tipping Point (2000), describes how a behaviour gains momentum via dissemination by opinion leaders and peer to peer networks until it reaches a point where it is perceived as desirable and adopted by a high proportion of the target population. Similarly, ‘buzz marketing’ has been used to promote ideas, services and products in a wide range of social and commercial settings (Holdford 2004).

Incorporating the methods described above, social marketing is the systematic application of marketing concepts and techniques to achieve ‘social good’ via tangible and measurable behavioural goals. Whilst one of the primary focuses of social marketing is improving health and reducing health inequalities, it is also used to bring about positive change in areas such as recycling, modes of transport and compliance with legislation.

Social marketing is just one of a number of intervention options which can be used to promote a desired behaviour. One of its major contributions is to provide ‘customer insight’ to inform policy and strategy and improve the development of interventions aimed at different groups. As such it can be used in conjunction with, for example, legislation, fiscal measures and community development.

Achieving behavioural goals can be extremely complex so, to justify its cost, social marketing must demonstrate evidence of sustained positive change in difficult to reach groups. Social marketing aims to achieve this by understanding and working with three facilitators of change:

-Insight - the lived reality of the target audience, avoiding professional assumptions about what they might want or think;

-Exchange – what may be lost during behaviour change and balance this with what will be gained (loss of pleasure and convenience versus avoiding extreme climate change);

-Competition – what is competing for allegiance to different ways of living, balancing this against what can be gained.

This requires the development of a shared understanding by seeing the individual in his/her social context and understanding that patterns of behaviour may be ingrained over several generations but also subject to variation according to time and context. Patterns of behaviour are framed by attitudes, values, beliefs, wishes and other motivators, sometimes resulting from habit rather than conscious decision. Behaviour does not always result from cognitive decision making and social marketers advise that the following should be considered:

-Product – what’s on offer?

-Price – what will it cost the consumer?

-Place – where does the relevant behaviour happen?

-Promotion – what incentives can be used that will be valued by the target audience?

These are applied by segmenting the audience by their potential to respond to differing approaches. Segmentation could be by social class, age, gender, ethnic origin, area of residence or any other grouping relevant to the behaviour in question.

• Health and social inequalities

-Vulnerability: As stated in the document (6.1), people who are already disadvantaged will be more vulnerable to the impacts of climate change. Carbon reduction plans should be subjected to impact assessment, with a strong emphasis on human health and reducing inequalities (Health Inequalities Impact Assessment). Whilst WAG must be primarily concerned with impacts within Wales, consideration should also be given to the severe effects that are likely to occur in areas such Sub-Saharan Africa.

-Social Justice: The overall aim should be for the social, economic and environmental impacts of climate change to be more evenly distributed both within Wales and internationally. Polluting or undesirable processes, such as those associated with recycling, have often been sited in less prosperous areas and, though such industries may provide employment, this can be at the expense of the local environment. Skilled, more highly paid workers are often brought in from other areas, whilst low paid jobs go to local people. It is recognised that being in work is generally better for health than being unemployed, but there are exceptions and wider effects on community health and wellbeing should be considered.

-Community energy schemes (p 43) Due to lack of expertise and/or awareness, disadvantaged communities may be less able than the more affluent to initiate community energy schemes and there is a risk that areas with more middle class residents may benefit disproportionately.

• Public sector organisations

Public sector administration produces vast quantities of waste, often through lack of thought: for example, large quantities of food waste are sometimes produced when catering for meetings. Those responsible for procurement should be made aware of the waste implications of, for example, renewing useable equipment just because it is the end of the financial year. This could be addressed to some extent by revising public sector financial rules which encourage this behaviour. It would also be helpful if the Assembly could develop over-arching policies and guidance for public sector organisations, for example regarding use of recycled paper, printing, catering for meetings, procurement and travel.

WAG must ensure that all public sector organisations are fully engaged in maximising carbon reduction opportunities. It is unlikely that comprehensive carbon reduction schemes exist in all NHS facilities across Wales, and the formation of the new Health Boards and of Public Health Wales provides the opportunity for a new level of commitment.

Meetings should be held at public transport friendly venues or replaced by tele/audio conferencing. Page 86 states that the Assembly Government has linked with the UK Government campaign to reduce transport emissions. It should, therefore, lead by example by organising meetings at public transport friendly venues and by reducing the use of private cars and air travel for internal UK flights.

The tendency to over-cater for meetings, producing large amounts of waste should be better controlled and the use of bottled water and disposable cups/beakers should be discontinued.

Policy on lighting public buildings when not in use should be reviewed, considering possibility of using a partial or movement sensitive system. Public buildings should not be over heated or over cooled, and this includes hospitals, which are often uncomfortably hot for patients and visitors.

Innovative thinking is necessary in the provision of services, for example, less carbon is produced if a consultant travels to hold a satellite clinic, rather than requiring many people to travel long distances to a central location.

All printers should be set to double-sided as the default position.

• Agriculture

-Biomass crops: Agricultural land should primarily be considered for food production and proponents of biomass should be aware of potential risks to food supply and pricing.

-Meat production: It is now widely accepted that meat consumption should be reduced considerably, both for health reasons and to free up land for arable use. WAG can lead by example by in-house catering and by advice to school meals and hospital food providers and to all public sector organisations. It would be possible to move closer to consuming a fairer share of the world’s resources in Wales by making meat free days the norm. Page 101 mentions intensive poultry and pig farming. and there appears to be an opportunity here to encourage more environmentally and animal friendly production methods.

-Fish farming: Support for the expansion of eco-friendly fish farming should be considered.

• Transport

Public transport use should be encouraged throughout all strata of society: a service for the poor is often a poor service. Carbon reduction can only be achieved if public transport is universally perceived as affordable, reliable and safe. If the aim is to reduce emissions, rather than just to alleviate congestion, then weekend and evening public transport services must improve. For example, one bus an hour to fairly densely populated residential areas is not sufficient to deter people from using a private car or taxi. Urging greater use of public transport is likely to encounter capacity problems at peak times and it may be necessary to consider restricting concessionary travel for the over 60s to weekends and on weekdays from 9.30 am – 4.30 pm and after 6.30 pm. This would have the added benefited of ceasing to subsidise commuting for those over 60 who are still working, many in highly paid jobs.

Improved rail services need to be accompanied by improvements to linking bus services. For example the increase in train services to and from Merthyr Tydfil is quoted in the document but there has been little or no corresponding improvement in bus connections from the town centre to outlying communities. (Personal communication: NPHS staff).

Larger firms and public sector organisations should be encouraged to promote the use of public transport for official business and to provide car and cycle pools if necessary. This would overcome the excuse for daily commuting by car as necessary to facilitate travel during the working day.

Though the growth in air travel has slowed, the aim should be trend reversal, especially for internal flights. The public sector can contribute by using the train when travel in unavoidable and by increased used of tele/audio conferencing. There is a tendency to advocate low carbon transport for others and a risk that internal air travel has become a status symbol in some public sector organisations.

Park and ride facilities should include provision for safe storage of bicycles.

Increased use of waterways and coastal transport should be considered for the movement of passengers and freight.

• Planning

New developments such as retail, business, public service and leisure, should be avoided where access is difficult except by private car. (The exceptions would be high risk industrial developments or those with the potential to pollute by emissions, noise, etc.) Energy efficiency design requirements for buildings are becoming more rigorous but this must be linked with requirements regarding location and public transport links.

The power for schools to change their hours to make transport more sustainable should be used with caution and only after consultation to ensure that it does not have a detrimental effect on working families.

• Waste

It may be useful to develop incentives for participation in carbon reduction strategies to reduce all forms of waste both at home and at work, together with awards for achievement.

Incinerators: The HPA has stated that modern incinerators do not constitute a significant risk to public health, as they produce only 1% of UK particulate emissions, compared with 50% produced by transport. Due to EU regulations on landfill, the use of incineration, and therefore its proportional contribution to total pollution is likely to increase. The comparison with emissions from transport does not seem valid, as pollution from waste incineration is concentrated over a much smaller area when compared with total UK transport emissions. Such facilities should, therefore be sited at an acceptable distance from residential areas.

Anaerobic digestion: Care will be needed in selecting sites for these facilities, with consideration given to transport implications, risk of explosion and exposure to digestate. Digestate is reduced in the open air and there is a risk of pollution by odours, spores and particulates. The facility is also likely to be unattractive and may affect the sense of wellbeing locally. Decisions on waste disposal facilities should be subject to health (inequality) impact assessment.

ADAPTATION

• Prioritising adaptation action

It will be essential for the Welsh Assembly Government to continue to interpret the findings and predicted impacts from the work of UK Climate Projections (UKCP09). This information will be required to prioritise adaptation action and inform multi-agency action planning and resource allocation.

It will be equally important for the Welsh Assembly Government, when developing adaptation action plans and allocating resources, to ensure that achievable and tangible outcomes are considered. In order to assess impacts and determine the effectiveness of adaptation activity undertaken, continuous progress monitoring will be required. Involving all stakeholders in outcome generation and agreement will support the process and ensure it is inclusive.