Climate Karanga Marlborough (CKM) is a citizens group of over 85 members, with the mission of bringing the realities of climate breakdown to the people of Marlborough and educate how best to respond. We do this through a number of initiatives:
In addition to submitting within the framework of the “15 set questions” of the Ministry for the Environment (MfE), we have extracted our answer to question 15 (other priority issues), embedding it within this explanatory supporting preamble statement.
Central to CKM’s common concern for our environments, local, national and global, is the belief that all of humanity that relies on industrial technology must seek a new way of thinking about and acting in our relationship with our planet. Although most people acknowledge that we can no longer continue to regard our environment as separate from us, as simply a source of goods from which we can extract what we want without return, the fact is that we continue not only to abuse the environment on which our wellbeing relies but to poison it with our waste. CKM takes the warnings of the environmental sciences with regard to global warming and biodiversity loss as both serious and critically urgent.
CKM sees no evidence of new ways of thinking in the document on “pricing agricultural emissions” on which we are submitting. Therefore, we are not willing to relegate our priorities to the last box of what appears to us to be a box-ticking exercise. We have responded to the “set questions”, as requested, worrying that if we don’t answer the questions, our thoughts, and our priorities, will simply be relegated to the box ticked “Other”.
But we have also herewith brought forward our priorities:
Consultation Document Questions
Question 1: Do you think modifications are required to the proposed farm-level levy system to ensure it delivers sufficient reductions in gross emissions from the agriculture sector? Please explain.
We are in general support of the farm-level levy system that He Waka Eke Noa (HWEN) has come up with and on which the government system is based. The system may not achieve the 2030 10% methane reduction target, however, because no cap on emissions is set. Emissions reductions will be via trial and error and dependent upon other policies, such as the value of forestry conversions. It will be a challenge to manage so that it brings about the necessary emissions reductions. It is necessary that the setting of levy prices be flexible enough to insure course corrections can be implemented quickly. Annual price setting seems a good balance between this flexibility and certainty for farmers.
There is a risk of the levy system deviating too far from the Partnership’s recommendations, through a submission process such as this. This could cause the farming community to disavow the program (which some groups already appear to be doing). In that HWEN was a major and broad consultation, it behoves the government to honour the results of the consultation as best they can.
Question 2: Are tradeable methane quotas an option the Government should consider further in the future? Why?
Tradeable methane quotes would probably be a better system. We are surprised that the HWEN partnership did not decide on this system and opted for a levy system instead, since a tradeable quota system would have likely have cost farmers less. A drawback of the quota system is that it would not generate government revenue, which should have been attractive to the farming industry, but a drawback from the government’s perspective.
We understand that the major issue with a tradeable quote system was disagreement on the level of initial allocation. We can appreciate that dairy and meat farmers might not be able to agree on an equitable allocation formula, since a per-head-of-stock formula would benefit dairy farmers over beef & sheep farmers.
Perhaps a tradeable quota system can be brought in at some time in the future. It has the advantage of accommodating an emissions cap and can bring emissions down at a predictable rate, which the levy system cannot.
Question 3: Which option do you prefer for pricing agricultural emissions by 2025 and why?
(a) A farm-level levy system including fertiliser?
(b) A farm-level levy system and fertiliser in the New Zealand Emissions Trading Scheme (NZ ETS)
(c) A processor-level NZ ETS?
We support option (b) A farm-level levy system and fertiliser in the New Zealand Emissions Trading Scheme (NZ ETS). This is the system recommended by the Climate Change Commission and would simplify farm emissions reporting by putting fertiliser emissions into the ETS at the manufacturer – importer level. The farm-level levy for methane will be enough of a challenge to introduce and manage, without adding the complexity of nitrous oxide and carbon dioxide emissions from fertiliser.
There is also an equity issue here. The rest of NZ pays for long-lived GHGs through the ETS. It would be unfair to let the farming sector treat these gases differently. Fertiliser is also the main source of GHG in the arable and horticulture sectors, which would likely escape a levy unless brought into the ETS at the processor level.
Question 4: Do you support the proposed approach for reporting of emissions? Why, and what improvements should be considered?
We support the annual reporting of basic farm information for the estimation of emissions. It is best to start out simple, since the system to include over 20,000 farms will be challenging to initiate and manage. Complexity needed to better estimate emissions can be added later, once the reporting system is up and running.
Question 5: Do you support the proposed approach to setting levy prices? Why, and what improvements should be considered?
We support the proposed system for pricing emissions. The Climate Commission is best suited to advise on the price of levy necessary to achieve the mandated emissions reductions. In order to maintain flexibility to respond to trends in emissions reduction, the price should be set annually.
Question 6: Do you support the proposed approach to revenue recycling? Why, and what improvements should be considered?
We support the proposed approach to revenue recycling, with administration costs recovered, research funded and farming assistance provided where needed, with Maori & industry input. We feel it is important to “ring-fence” the revenue from the levy scheme so that it supports farmers in reducing emissions and does not go into general government revenue.
We do not support revenue being used to pay for on-farm sequestration. This should be handled by forestry credits in the ETS. Sequestration should be uniform across all sectors of NZ society and industry, without special treatment for farmers.
The forestry credits might be extended to smaller land parcels, to benefit farmers with claiming riparian planting, but we acknowledge this would create a greater workload for MPI.
Question 7: Do you support the proposed approach for incentive payments to encourage additional emissions reductions? Why, and what improvements should be considered?
We support incentive payments to encourage additional emissions reduction, although we acknowledge that there are few options for this available to farmers at this time. The only options available, it appears, are through low-protein & low-methane forage crops and effluent handling. The Climate Commission has “high confidence” that feed additives and vaccines to reduce emissions will not be widely available by 2025. We note that inhibitors such as 3NOP and bromoform are not yet approved and the market for asparagopsis seaweed as a feed additive is in its infancy.
We recommend the government consider “no-till” farming, regenerative and organic farming practices be eligible for incentive payments, since they are known to increase soil carbon, even though soil carbon is not yet counted as sequestration. They also promote lower density farming, which, in the absence of emissions mitigation technologies, is the likely end point of farms using traditional farming methods. Stock reduction is the principal way that farmers will achieve emissions reductions in the levy system, at least until additives, vaccines and genetics are available. Regenerative and organic farms already have lower stock densities.
Question 8: Do you support the proposed approach for recognising carbon sequestration from riparian plantings and management of indigenous vegetation, both in the short and long term? Why, and what improvements should be considered?
Carbon sequestration from planting is already available for compensation through the ETS. Farming should not receive special treatment for sequestration versus other sectors of society. We support research which might allow the inclusion of new types of sequestration, such as pre-1990 forest management and riparian planting, along with other types of sequestration, such as in wetlands and soils.
Farmer interest in being paid for on-farm environmental improvements might also be addressed by a “biodiversity credit” for their work managing on-farm indigenous forests and/or riparian planting.
We acknowledge, though, that riparian planting is mainly done to prevent fertiliser and effluent runoff into waterways – a different environmental problem. It also generally involves vegetation that is low in carbon sequestration potential and is too narrow to host much biodiversity. A credit for riparian planting needs to be carefully considered to make sure it is fair to other sectors of society working to improve biodiversity and sequester carbon.
One further point: The split –gas approach to agricultural emissions acknowledges an inequality between biologic methane and CO2. From a fairness point of view, that inequality should not then be breached to allow on-farm sequestration to offset a levy on methane. Sequestration credits should be through the forestry ETS.
Question 9: Do you support the introduction of an interim processor-level levy in 2025 if the farm-level system is not ready? If not, what alternative would you propose to ensure agricultural emissions pricing starts in 2025?
Yes. By 2025 there will be only 5 years remaining to achieve the 10% reduction in methane specified in the Zero Carbon Act. We need to get started on methane emissions reductions right away.
Question 10: Do you think the proposed systems for pricing agricultural emissions is equitable, both within the agriculture sector, and across other sectors, and across New Zealand generally? Why and what changes to the system would be required to make it equitable?
Yes. It appears equitable as described. The system may not be perfect, however, but we shouldn’t let “perfect” be the enemy of “good”. Equitability issues will arise with time and these can be addressed by revisions and targeted support, as needed.
Question 11: In principle, do you think the agricultural sector should pay for any shortfall in its emissions reductions? If so, do you think using levy revenue would be an appropriate mechanism for this?
Yes, through levy revenue.
Question 12: What impacts or implications do you foresee as a result of each of the Government’s proposals in the short and long term?
Short term impacts will likely include higher domestic prices for milk, meat (beef/lamb/venison) and wool, as the levy cost gets passed on to consumers. Even without the levy, however, animal products are expected to lose market share to cultured and plant based protein in the near term, as the price of these products decline with increasing production scale. Likewise for wool, which is being replaced by more environmentally friendly plant-based products. The levy will act to accelerate this otherwise natural transition. New Zealand farmers will need to take note of these trends and adapt.
There will be more farm conversions to forestry, depending on the price of ETS credits for permanent forestry and the emergence of biodiversity credits for indigenous forestry. We hope that this transition can be managed so the nation doesn’t end up a sea of carbon-farmed pine. The multiple environmental and social benefits of native forest need to be prioritised in this transition.
Long term impacts will likely include a move away from animal farming to horticulture and arable farming. These will be needed both for market domestic supply and as industrial feedstocks for lab cultured foods and other plant-based products. Our exports will shift from animal-based products to specialty foods and fibres to which New Zealand is particularly well suited to grow.
Question 13: What steps should the Crown be taking to protect relevant iwi and Māori interests, in line with Te Tiriti o Waitangi? How should the Crown support Māori land owners, farmers and growers in a pricing system?
Support will be needed for Maori farms. Maori need to be an active part of consultation on these issues. What steps should the Crown be taking...? The Crown needs to acknowledge openly that monetary pricing systems do not fit well within Te Tiriti o Waitangi. The idea of buying and selling land and the living beings living in and on it, particularly when reduced to the notion of "carbon", remains a point of contention between 2 very different world views. It also lies at the centre of how we have got to the present state of the climate: the whenua has been seen in terms of saleable resource rather than as treasure to be cared for and as 'being' to be respected. Historically. the result of this difference in world views led to confiscations by the Crown of good land and the marginalisation of Māori onto marginal farmland. The persistence of pricing land in the agricultural emissions plan simply perpetuates disadvantage for Māori. The Crown needs to take concrete and bold steps to reverse this ongoing process.
How should the Crown support Māori ... ? There appears to be little reward for Māori or concrete incentive for change in the present pricing arrangements. Much of the land "owned" by Māori remains of marginal value under present pricing systems. Support for Māori farmers and growers needs to be in the terms of the Second Article of Te Tiriti (Māori version), recognising in law the notion of collective land "ownership" The Crown must accept the guidance of Māori in this and resist the lobbying of private landowners and those ignorant about the nature of tino rangatiratanga. Support for Māori is in terms of respect, learning and promotional reward for initiative, past and present, rather than only monetary compensation, simply carrying on in the same old way.
Question 14: Do you support the proposed approach for verification, compliance and enforcement? Why, and what improvements should be considered?
Yes. The plan seems reasonable and comprehensive.
Question 15: Do you have any other priority issues that you would like to share on the Government’s proposals for addressing agricultural emissions?
We applaud the government for the He Waka Eke Noa process and willingness to adopt most of the partnership’s recommendations. Reducing agricultural emissions is a contentious issue, which required thoughtfulness and engagement. We only hope that the farm-level levy system will survive a change of government and go on to help the country achieve its emissions reduction targets.
Dear Mayor, Councillors, CEO, Minister David Parker, Minister Nanaia Mahuta and MP Stuart Smith,
Climate Karanga Marlborough (CKM) is a local climate action group purposing “to persuade elected representatives and their officials to pursue policies designed to limit the extent of rapid climate change and help New Zealanders to adapt to its consequences”. We are particularly concerned about the impacts of climate change on the natural environment and biodiversity of which we human beings are just a part, albeit a governing part.
Our members recently had a meeting to discuss the 3 Waters proposals and the position taken by Marlborough District Council (MDC). We know submissions have closed but wanted to send this letter to express our general support for the Council’s position.
The health of all New Zealand waters is inextricably entangled with climate change and its impacts. If human beings do not contribute to the good health of water by mitigating pollution and thus climate change, the environment will suffer and so will all the species both in it and on it, including ourselves.
In the matter of the Government’s proposed Three Waters Bill, we support 5 principles:
Although the urgency to manage ‘our waters’ becomes evidently ever more acute with every weather disaster that occurs, we urge the government to pause and acknowledge the weight of response to their proposals. It is critical they listen and openly adapt to those responses. The failure to bring on board a large proportion of local Councils does not bode well for success. Having read some of C4LD, the collective local councils submission, to which the MDC subscribed, we think that the Government could give a clearer and more detailed explanation of its thinking to the general public as well as to local bodies, including clarity around the engineering, financial and cultural accountabilities of the new entities. It is important that separate issues of water reform, local governance and Treaty obligations are not conflated.
We believe some centralisation of engineering services to ensure that all councils have access to good advice and that no projects proceed without independent assessment and engineering audit will significantly improve outcomes.
In summary, Climate Karanga Marlborough proposes the 5 principles above in supporting nation-wide reforms of water care in Aotearoa New Zealand.
This is a critical time for rebuilding the partnership between central and local government. While central government provides standards and support, we believe it needs to avoid dictating how local and regional communities and institutions apply their different solutions to their own care of New Zealand waters. Cooperation, forbearance and flexibility will be key.
In particular, from a local viewpoint, we support the position of the Marlborough District Council as laid out in its submission dated the 20 July, 2022 to the Finance and Expenditure Committee on Water Services Entities Bill.
We expect clarity and transparency in public of all governmental decision-making.
Finally, we comment that nobody can own water any more than we own the air we breathe; rather, we owe water, air and the land we stand on due care and responsibility.
Otherwise, climate, land, sea and the planet altogether will make their own decisions for us and despite us, as we have all been experiencing at home and abroad.
Yours, Don Quick, Budyong Hill and Bill McEwan for CKM.
2022 Budget Policy Statement – Submission.
We have become aware of the critical urgency to step back from our privileged status and self-entitlement and for our generation and our children’s generation to curb our greed for comfort, control and power in favour of respecting and responding to the urgent need for wellbeing of our planet and its biodiversity, of which we are a part, but just a part.
We humans can be smart, inventive and adaptive, but that counts for little if we simply take for granted that we can exploit the abundance provided for us by the natural world without making any return. The world has its limits and we are there.
From now on, we expect the current government to work within those limits, acknowledging them in detail and, with clear explanation, dedicating adequate finance to enabling us to stop and, if possible, reverse our human contributions in Aotearoa to climate disruption and environmental pollution.
Although I would like to see this coming out of due reverence for our planet and its biodiversity, it certainly would be in our own self-interest, as our wellbeing depends entirely on the Earth’s wellbeing, whatever may be our technological smarts!
A good starting-place would be for the government to deliver with urgency on its commitments in line with the 2015 Paris Agreement and the 2021 COP26.
2. Budget Frameworks.
We support the government’s wellbeing priorities, including taking an intergenerational approach and looking beyond simple economic measures of success and so-called ‘progress’.
We support the use of the Living Standards Framework, including improving on it.
We support the development of He Ara Waiora.
We support consideration given to distributional impacts of policies on different populations and the environment.
We support the explanation of moral values, not just economic values, underlying such considerations.
This government has not shied off moral considerations in furthering its policies, for instance with regard to terrorism and response to the Coronavirus pandemic. By ‘moral’ we allude to values or principles that matter most to people, not just to their pocket or their comfort.
3. A Just Transition.
Here is where moral values, not just economic, must be explicated. Doing justice requires the practice of equality, not just the pursuit of equity.
Climate change, the pandemic and the housing crisis are 3 of our most pressing immediate and long-term challenges and all of them have impacted unequally racially, intergenerationally, on women, on indigenous peoples and on non-industrialised countries, with increasing impoverishment amongst those most affected.
We submit that the Budget Policy Statement requires an additional priority: Reducing economic inequality.
This would align with the other priorities but would highlight a theme common to them all. It would also align with the Living Standards Framework, He Ara Waiora and Fonofale.
Further, Equality and Justice would align with moral values, such as Kindness and Teamwork, already espoused by the current government in dealing with our challenges.
In that regard, We submit that the Budget Policy Statement should allocate ongoing funding specifically to Equality for Women: this would have direct impact on Physical and Mental Wellbeing, Child (and Family) Wellbeing and the Wellbeing of Māori and Pacific peoples.
4. Implementation Funding:
A Just Transition requires that implementation funding be specified, otherwise processes will be set up unjustly to fail. Funding needs to be allocated to support a genuine and ongoing process of engagement with workers in their unions, with volunteer groups in their communities, and with Māori iwi and hapū and Pacifika communities in the time needed to fulfil such processes. For a Just Transition to occur, these engagements must happen first.
In allocating funding and resources, particularly in vulnerable communities, it is important that the government does not simply take a deficit – ‘we’re helping you/lifting you up’ - approach, but adopts an approach that is prepared to listen and respond appropriately – ‘help us understand what it is you need from us to promote your strengths and skills/lift us up’.
We expect funding will honour Te Tiriti o Waitangi through equal and equitable partnership with Māori in all decision-making, be grounded in Kaupapa Māori and uphold indigenous rights, as stated through He Ara Waiora.
5. Other Submissions:
We are in full support of the submissions, each made from their own areas of focus, by 350 Aotearoa; Greenpeace; Fossil Free State Sector Coalition; Coal Action Network Aotearoa; NZEI Te Riu Roa – Teachers’ Union.
6. State Sector Decarbonisation:
We feel strongly that the government should increase funding for the Clean Powered State Sector Fund, to help decarbonise schools, hospitals and other state facilities. This is an easy way for the government to reduce emissions and show leadership in decarbonising infrastructure.
Within this same theme, we strongly encourage the new budget to increase funding for the GIDI scheme to help decarbonise industry and to increase funding to community and household energy generation and conservation projects.
7. Regenerative Farming:
Similarly, we strongly endorse the suggestion by other submitters that the government fund a scheme to facilitate the transition to regenerative farming practices. Regenerative farming has the potential to reduce herd sizes, to accommodate the government’s methane emissions reduction goals, as well as reduce nitrogen pollution to our rivers, all without reducing farmer income. The government should support farmers who decide to switch to regenerative and organic farming practices.
8. Environmental Education:
In particular, we would like to add to the submission from NZEI Te Riu Roa about the importance of holistic education about the environmental crisis.
It is important that the government explicitly recognises and funds its own responsibility and leadership role in informing and educating both the public generally and specific population groups, not just about the thinking behind its policies but about how these policies may play out in terms of such issues as justice and equality.
For instance, one issue that is not addressed, except indirectly, in any of the submissions named above is the central importance for us all to consume less energy overall, not just in order to reduce carbon emissions and other pollutants but also because alternative energy sources are not adequate to make up the difference arising from reduced fossil fuel extraction and because it will demand energy to build the infrastructure for alternative energy sources.
So, if we are all to consume less, how just can that be for groups, both within NZ and in those parts of the Pacific where NZ has influence, who have had little or no access to sources of energy to help reduce the effects of poverty and to bring equality with those who have?
Another issue concerns the Wellbeing priority of the Future of Work, “enabling all New Zealanders and NZ businesses to benefit from new technologies and lift productivity and wages through innovation”. The allure of “new technologies” may encourage people to carry on denying the immediacy of the problem of climate change with the illusion that we will fix all such problems with ingenuity, e.g. alternative fuels such as hydrogen and biofuels. Without diminishing the value of innovation in either mitigating or adapting to climate change and whilst encouraging innovative initiatives, the government needs to encourage wide debate at all ages and in all situations about the pros and cons of different proposed solutions or contributions. This is not just for the public’s understanding, but for its own understanding.
One of the clear messages of scientific research, of increasingly violent weather vagaries and of our continuing failure to adequately reduce global warming, biodiversity loss and environmental degradation is that we can’t afford to keep on going as we have done without drastic consequences for the planet and planetary life, including ourselves. We do need to think or do things differently.
We have to say that we have seen little evidence of new thinking in any government initiatives so far, including in what we have read in the Budget Policy Statement.
Come on! Buck up! We’re in a Climate Emergency – you’ve said it yourselves. You’ve done a good job overall in response to Covid. But Covid is really only a symptom of the underlying disorder: planetary life under stress.
You’ve done plenty homework – it’s time for decisive action. The consequences will not be worse than those of continuing inaction.
Climate Karanga Marlborough (CKM) is a climate action group of citizens of the Marlborough Region, with the purpose “to assist elected representatives and their officials to pursue policies designed to limit the extent of rapid climate change and help New Zealanders to adapt to its consequences”. We are concerned about the rapid advance of global warming and work to assist our community and government at all levels in mitigating greenhouse gas emissions and preparing the country for the challenges that global warming will bring.
On the whole, we support the great majority of the ideas presented in the MoT green paper and feel that the transition of our society to low emissions transport is an urgent necessity. CKM believes that, if we are to achieve our aim of reducing harmful emissions, then not only do we need to make our consumption of energy in NZ more efficient and effective, we all need to expect to consume, and demand, less energy, particularly energy derived from fossil fuels.
The changes needed to our cities, outlined in Theme 1, are important and necessary, particularly when considering the possibility of limited future transport options in the absence of fossil fuels. Transitioning the nation’s light vehicle fleet to battery electric, proposed in Theme 2, seems to be the most straightforward and low risk option for continued automobile travel. The transition of heavy freight, discussed in Theme 3, will be more challenging and will present more difficult choices.
There are four issues which we wish to submit on, however, where we disagree with or suggest greater emphasis on, strategy elements presented of the green paper. These are outlined below.
CKM submits that the MoT should look to the Climate Commission for its recommendation on biofuels. In recommending a moratorium on new fossil gas hook-ups to industry and residences, the Commission suggested that the fossil gas industry first demonstrate that blending of low-emissions gases, such as bio-methane or hydrogen, with fossil gas (the industry’s proposed method to reduce fossil gas emissions) is feasible and will not result in higher costs to consumers (Section 15.1.5 of the final advice). This would prevent the construction of expensive new fossil gas infrastructure, for which locked-in gas customers would be required to pay.
Similarly, the petrol industry is proposing blending of low-emissions biofuels with fossil petrol as a way of maintaining their market share in transport. This might cause consumers to purchase new internal combustion engine vehicles able to accept the blended fuel, or pay to modify their existing vehicles. If these promises of low-emissions fuels do not eventuate at reasonable cost, consumers would then be saddled with the stranded investment. The MoT should first require that the petrol and biofuel industries demonstrate the viability of blended or pure biofuels before committing the nation’s transportation strategy to them.
In conclusion, we urge the MoT to adopt the “precautionary principle” in planning for New Zealand’s future transport. That means sticking to the low emissions transport solutions that are tried and effective, and require the least amount of energy. That means battery electric vehicles, electrified trains and decarbonised coastal shipping.
The country should not be led down the road of biofuels and hydrogen only to find that these fuels don’t work as planned or create a new set of problems. Let others work the bugs out of these systems first. If they work out, they can be added to the transport energy mix at a later date.
Whatever strategy the MoT ultimately adopts for decarbonising New Zealand transport, it goes without saying that this strategy needs to be in alignment with the strategies of other government ministries and commissions. We appreciate that this will be a difficult and time consuming task. The MoT has its work cut out for it, and it has our support.
Thomas Powell, Co-chair, Climate Karanga Marlborough
Climate Karanga Marlborough submission to the Infrastructure Commission re the Consultation Document,
He Tūāpapa ki te Ora. 18 June 2021
Climate Karanga Marlborough (CKM) is a local climate action group purposing “to persuade elected representatives and their officials to pursue policies designed to limit the extent of rapid climate change and help New Zealanders to adapt to its consequences”. We have constructive relationships with the Marlborough District Council and Council staff. Recently, we submitted and presented to the Council re their Long-term Plan for the next 10 years.
We welcome the opportunity to support and submit to Te Waihanga re the Infrastructure Strategy Consultation Document, particularly in the wake of the Climate Change Commission (CCC) report and recent government policy documents, such as The Three Waters Reform Programme.
1: We have read the Infrastructure Commission’s response to the Climate Change Commission’s 2021 Draft Advice. Regarding the scale of transition required to meet the recommendations of the CCC, we welcome your statement in response: “Te Waihanga see that infrastructure has an important role to play in facilitating the transition, particularly transport, energy, waste and social infrastructure.” In fact, in principle, with few reservations, we also welcome the tenor of your response. It accords with our request, when presenting to our local council that their entire work programme be viewed through a climate change lens, always using a precautionary approach and taking a long-term view. – Not just to the next turbulent 30 years, but to the impacts well beyond!
2: As with Te Waihanga’s response to He Pou a Rangi, CKM finds itself in accord with many of the options for action put forward by Te Waihanga in developing the 30 year Infrastructure Strategy: -
In particular, preparations for climate change/global warming; reducing demand for energy consumption, eg enabling both active and renewable energy-based public modes of integrated transport; resourcing ongoing cross-national data collection and information analysis for transparent modelling and planning for evidence-based development; avoiding siloed thinking, which entails enabling cross-boundary communications and actions; ensuring equitable (fair, inclusive and affordable) funding and financing; making better use of existing infrastructure and considering non-built options, particularly towards behaviour change.
CKM acknowledges your 5 proposed priorities, particularly in the light of what you say you have heard through the Asset Owners’ Survey.
We do not argue with your stated outcomes and principles, as such.
3: In response to your asking for our views on the proposed 2050 infrastructure vision for New Zealand, it seems to us that the vision, as described, is constricted and defined more by what is not in the vision than what is in it. In our opinion, you have missed some opportunities to lay out an expanded vision of building infrastructure in alliance with the natural world and with te Ao Māori.
4: “All decision-making about infrastructure must be guided by Te Tiriti o Waitangi (the Treaty of Waitangi) and its principles, but specifically by the obligation to partner with Māori. As well as this, we propose a fundamental principle that infrastructure should support oranga tangata or the wellbeing of people.” (p08)
In response, we say that Te Tiriti and the Treaty are not the same documents, and the Commission needs to address the differences.
Also, the “obligation” lies specifically, both in legal and moral terms, with the articles of the Treaty, rather than with the so-called principles. Partnering with Māori should not be seen as an obligation but, at the very least, an opportunity! The added statement, starting “as well as this”, reads like an escape clause: escape from the clauses in the previous statement.
5: “There appears to be a lack of meaningful relationships between iwi/Māori and many key infrastructure players (Crown and private.) …
The current resource management approach is not working for Māori due to a lack of meaningful involvement, as well as consultation fatigue on both sides.”– Probably not surprising, given that the Pākehā desire for ‘infrastructure’ has led to Māori land dispossession over 180 years. Both ‘sides’ are moving from a position of lack or loss of trust.
In answer to the 3 associated questions, we respond thus: Q15 – maybe not for us to say, but we suggest continuing to ask Māori without pre-empting the answers: keep listening, talking and building trust. Q16 – explore the meanings of land and infrastructure, whenua and taonga. Q17 – not for us to answer, but we can ask you whether and how Māori are actually being allowed to lead?
6: In regard to how CKM understands the relationships of land, water and air to infrastructure, we believe in the principle of respecting the natural world, in all its manifestations, as our ally, not simply regarding nature as a resource, as we believe that unconsidered exploitation of natural resources has led to the disruption of the climate that we now face. The simplest way of doing this from our viewpoint is to recognise that people are not separate from nature and that we are just one part of nature’s biodiversity. Thus, any infrastructure in which we may wish to invest must be in agreement with nature and nature’s biodiversity. Ways of doing this have been thoroughly explored in The Dasgupta Review: The Economics of Biodiversity, a report commissioned by the UK government and released in February. 2021. We recommend this report to you.
We also believe that our viewpoint corresponds to Māori concepts of whakapapa and of rangatiratanga as used in Article 2 of Te Tiriti. We have come across reference to the ‘environment’ often enough in Infracom’s Consultation Document but neither to nature nor to biodiversity.
We ask that Te Waihanga reconsiders and redefines its statement about how it thinks about infrastructure (in ‘Infrastructure under one roof’) in terms that both Māori and most people who respect the natural world and its creatures can relate to personally.
7: Developing this idea of relating human settlement to the natural world, we recommend that Te Waihanga places much more emphasis on bringing the natural world into cities. Although recent research on this in Aotearoa specifically is limited, there is plenty of international evidence that this both benefits the wellbeing of city dwellers and their relationship to and understanding of nature:
The following links are references in support.
It’s official: City parks make us happy - Outside our doors -
and also benefits the natural world and biodiversity.
Biological corridors throughout the length of New Zealand -
What are wildlife corridors? (Australian government)
Neither Te Tūāpapa ki te Ora nor the Infrastructure Commission’s submission on the Urban Development Bill takes the opportunity to put the relationship between human beings and the natural world at the centre of how we develop our infrastructure. An almost exclusively anthropocentric approach historically has got us to where we are now, in terms both of our environment and the climate. (cf The Dasgupta Review.)
Discussion Q21 as to whether a “10-year lapse period for infrastructure corridor designations is long enough” is pertinent here. CKM’s advice is that a 30-year plus period for such “spatial planning” is minimal from the point of view of the natural world and probably also of te Ao Māori. The discussion that precedes this question in the Consultation Document is set in terms of “lead infrastructures” and “corridors”. It is CKM’s view that if nature and wildlife were to head these terms, then Infracom’s planning would become much more inclusive, considered and relevant to the climate changes we are all facing.
8: In further consideration of the relationship between human settlement and the natural world, CKM is very concerned that Te Waihanga is overly focused on the nuts and bolts of urban development at the cost of a whole-of-New Zealand approach. We understand totally that Te Waihanga is facing the legacy of decades-long neglect of urban planning and maintenance of infrastructure, particularly evident in our major cities. Yet it is vitally important, in scrambling to guard the future of our cities, that we do not neglect to resource rural and provincial infrastructure in terms of climate and environmental change. In a hundred years’ time, our coastline, including city borders, will have changed and populations will have changed in terms of scale, placement and movement that are hard to anticipate in the face of climatic, environmental and political uncertainty. In reactively “mitigating … and adapting to the effects of climate change”, we must remember that we can also proactively bring about change, not only in mitigating our own impacts on climate and the natural world but also by adapting how we settle in and with the world.
In that regard, we appreciate discussion questions Q13 and Q14. Our response to these is that in New Zealand we might seek to counter population decline in non-urban communities (through transport, housing, work and amenity options) and develop a Population Strategy focusing as much on a preferred population distribution as on a growth path. How New Zealand plans its infrastructure is central to that.
9: In terms of action, CKM recognises that Te Waihanga does not have a decision- or investment-making function. We wholeheartedly support the proposed priority in the consultation document for “better integration and coordination between local and central government infrastructure functions”. We would add to that the importance of collaboration with the community and volunteer sectors, which would require active support, resourcing and funding at both local and central government levels. Such a collaboration would be essential to understanding “the growing gap between the demand for infrastructure and the funding available or the willingness to pay for it”. In particular, it could enable a reduction in demand for infrastructure that requires growing investment of energy, specifically fossil-fuel energy, which is not only primarily responsible for environmental damage but is also rapidly rising in cost.
10: CKM’s final recommendation to Te Waihanga regards energy descent, product stewardship and the circular economy. CKM takes the view that reducing consumption, especially of energy, and avoiding waste are the critical changes that we all need to make in limiting global warming, mitigating the excesses of climate change and beginning to care for our planet. This is what we mean by energy descent. But changing our demands for energy requires not only reduced consumption but also changes in how we supply energy. As long as energy supply is based simply on profit out of production geared to growing demand, there will be no energy descent. Responsibility for change rests on all involved. Responsibility for reducing the impact on climate and the environment of any product rests as much with producers and marketers as with consumers, entailing a process of product stewardship.
Whilst we acknowledge that there are a growing number of product stewardship schemes in Aotearoa, CKM urges Te Waihanga to lay much greater emphasis on energy descent, product stewardship and the circular economy in its recommendations to government. CKM recognises that these must surely be central to how Te Waihanga thinks about infrastructure, but this is really not apparent in the principles and priorities laid out in the Consultation Document. The government, and therefore Infracom and the taxpayer, tend to be seen as responsible for end-of-the line waste management, but the taxpayer needs better informed about what a circular economy means, about waste management options and responsibilities. It is up to the government to make clear nationally and internationally what national policies we have in Aotearoa with regard to product management, so that not only consumers and manufacturers but also importers understand the responsibilities, the costs and the benefits.
As a lead player over the next 30 years, Te Waihanga, on behalf of all New Zealanders, has the opportunity to lay out an expanded vision of building infrastructure together with nature and the responsibility to karanga,
to summon the government boldly and publicly to describe clearly its own vision in response, to pick up the wero, to accept the challenges presented to it in planning and designing in partnership an infrastructure for Aotearoa fit for the next 30 to 100 years.
A: We have introduced ourselves as Climate Karanga Marlborough (CKM) and identified a constructive relationship with our local Council.
B: We appreciate the opportunity to submit. In doing so, we have expressed both our support for what Te Waihanga has proposed and also our opinion that it has missed the opportunity to present a bigger vision.
C: We have responded to your questions about relationships with the Tangata Whenua.
D: We have outlined how we understand people to be part of nature, not separate from it, and we have recommended that any infrastructure in which New Zealanders may wish to invest must be in favour of nature and nature’s biodiversity, in line with recommendations from the 2021 Dasgupta Review, which was commissioned by the UK government and which we have recommended to Te Waihanga.
E: Accordingly, we have asked that Te Waihanga explain further how it thinks about infrastructure.
F: We have explored the importance of relationships between human settlement and the natural world and made recommendations accordingly.
G: We have recommended that Te Waihanga articulate how it might engage with the community and volunteer sectors.
H: We have urged Te Waihanga to lay more emphasis on practices of energy descent, product stewardship and the circular economy.
I: We believe Te Waihanga has a key role in supporting the government in dealing with climate change challenges over the next 30 to 100 years.
Climate Karanga Marlborough Submission to MDC 2021 – 2031 LTP.
A couple of our members sat in on the the recent presentation to the Environment Committee by Gregor Macara from NIWA, on Climate Change Projections and Impacts. We were encouraged to see Councillors and Staff are keeping up to date with the latest information in this area.
We wish to refer you to the Executive Summary of the Report on pages 9, 10 & 11. Please note the large range of possibilities for temperature and sea level rises dependent on the different greenhouse gas concentration pathways (RCP’s). We wish to stress the importance of not assuming the lowest pathway will happen. All indications up to the present indicate that we are more on track for the medium or even the high pathways and the difference in consequences is large and significant. For example a decrease in mean annual low flow (MALF) could exceed 50% for most of the river systems in the region with increased greenhouse gas concentration and time. With the declining trend in the Wairau Aquifer already clearly evident this added information is cause for concern. Longer periods of low flow will result in further reduced aquifer recharge. We don’t need to explain to you how serious the impacts of such an outcome would be for the river and spring fed ecosystems and the Marlborough economy.
We request councillors to always take the “precautionary approach” when making decisions that have the potential to impact the Wairau River and aquifer.
We wish to take this opportunity to remind Council that your entire work program needs to be viewed through a climate - change lens. The NIWA report was a timely reminder of how important this is and will be, as Climate Change impacts, such as extreme weather events and sea level rise, increase. We are encouraged to see in the LTP document the recognition of the importance of building resilience in our local infrastructure to such impacts. We strongly encourage the aim of being proactive when doing infrastructure planning and support the statement – “Building infrastructure to the latest standards and with the most suitable materials increases resilience to floods, earthquakes and changes in the climate.”
We support the resourcing for planning and modelling work to assess the likely effects of these impacts and to be better prepared to mitigate them.
CLIMATE ACTION PLAN.
In our submission we wish to highlight the question of whether funding allocations within the LTP are adequate to meet commitments previously made by this council when they adopted the Climate Action Plan in March 2020.
We request that you systematically review the LTP, taking a perspective of urgent climate action in the current decade and recognising the need to reduce net GHG emissions by half by 2030.
Richard Coningham has recently supplied us with a progress report on the Climate Change Action Plan. We are encouraged to see steady progress being made on various Actions laid out in the Plan.
We ask you to keep this “provision for uncertainty” foremost in your minds when finalising the LTP.
We ask you to reassess funding commitments in the Climate Action Plan and ensure adequate resourcing is allocated, if you have not already done so.
THE LONG VIEW
We believe it is critical to keep a long view with all planning decisions. The NIWA report gives you critical information to consider in your decision making. As an example we wish to highlight the recent agenda topic looking at the upgrade of the Town Branch drain, which was discussed at the Assets and Services Committee meeting on January 28th this year. We note in the associated article printed in the Marlborough Express on February 7th that the question of establishing further housing east of the existing town boundary on the E2 land arose during this discussion. This is a very good example of where the long view is essential.
We note the MDC CEO Mark Wheeler is quoted as saying, "It's not an easy process and there's a lot of questions to answer, because there's a whole raft of issues with that land.” One of those issues that appears to have not been mentioned in the councillors’ discussion is that of sea level rise. Maybe the belief is that the sea is several kilometres from this area and that therefore there is nothing to be concerned about? The excellent public resource you have now made available online with the new LIDAR maps shows clearly, most of the E2 land is less than 2 metres above sea level. One of our members used to drive a liquid waste truck and has seen what the ground water levels are like in Hardings Rd in the middle of winter where the land is currently only about one metre above sea level. Ground water levels reach the surface during wet periods. With sea levels projected to rise by around one metre by 2100 all the E2 land will be in the same boat, so to speak – one metre above sea level. Council will have to provide more pumping stations to keep the area liveable. If worst case scenarios occur we may well have nearly 2 metres of sea level rise by about 2150 according to the NIWA report. We would like to remind you of something Gregor Macara mentioned in his presentation. The possibility of passing currently unknown tipping points in the climate system (that may be irreversible) can not be included in their projections. We have to be smarter with our decision making and think ahead a bit more for our grandchildren’s sake please!
We request Councillors to take the long view when considering development of any further housing east of the existing town boundary.
Thankyou. Budyong Hill for Climate Karanga Marlborough.
MDC - LTP HEARINGS – CLIMATE KARANGA MARLBOROUGH SUBMISSION. 02/06/2021
Kia ora. Thankyou for this opportunity to have input to the 2021 – 2031 LTP process. We recognise the value that this chance to interact with Council gives you and us and hopefully the experience helps to keep you in touch with the aspirations and concerns within our community. We are aware there are many varied demands on Councillors attention and we understand the challenge you all face making the necessary decisions to meet the many and varied needs of our community. We know our request to view your entire work program through a “climate change lens”, to always use the “precautionary approach” and to take the “long view” only adds to the complexity of your decision making processes. But we strongly believe these things must be done if we are to have the best chance of reducing the biodiversity and climate impacts that are resulting from global warming, ocean acidification and ecosystem degradation. This LTP process is designed to look out over the next 10 years. The really big challenges are going to be with us for not one decade, but many decades and in fact centuries. The recent NIWA report to Council helped to focus our attention on this reality. As we noted in our submission, Gregor Makara emphasised that the possibility of passing currently unknown and irreversible tipping points in the climate system could not be included in their projections.
Somehow having gained this knowledge we all have to retain some optimism and hope. As the dominant species on our planet we have to work together, find the solutions and make the necessary changes to the way we live to hopefully give our descendants a fighting chance of survival. Members of CKM have a strong belief that this requires big changes in the ways we think about the world, in the ways we relate to our planet and to all the myriad other species we share the planet with.
I recently read an article titled “Humans are in collision with nature”. This was not David Attenborough reminding us but Rob Campbell, the current chair of the boards of SkyCity Entertainment Group, Summerset Group, Tourism Holdings, Wel Networks, New Zealand Rural Land Co, and also a director of Precinct Properties, the largest owner and developer of premium inner-city real estate in Auckland and Wellington.
In the article Rob was quoted as saying “The way I perceive the world at the moment is that there is a real clash or collision going on between the way human beings have conducted ourselves and nature. Wherever you look, you can see all these things, which are very important in themselves, but effectively symptoms of this wider collision. There is a dawning recognition that the old things we do and the way in which we do them are under challenge. If you think everything in the world is basically okay and that all we need to do is to return to previous behaviours and increase our GDP as much as we can and increase the individual profitability of our business as much as we can and increase your personal income as much as you can, then I think you’re quite at odds with the way I see the world.”
He went on to talk about the importance of Boards needing to view their businesses through a wider lens and that businesses that will succeed in a sustainable way in the new post Covid environment are those that are responsible to all their stakeholders, constantly scan the horizon for change rather than just reacting when it smacks them in the face, and that genuinely excite their people to work for a common cause rather than just a short-term incentive.
“Those key things will distinguish the businesses of the future,” he says.
Of course what he is talking about does not just apply to the business world, it applies to each and every one of us and in particular it applies to those in positions of influence and leadership in a community such as yourselves. We have to find ways to live our lives using less energy and consuming less. We have to make less demands on the many life giving resources our planet provides for us because currently we are living beyond our means. We are using more resources per person than the planet can sustainably provide and Kiwis are amongst the world leaders in this area.
We would like to finish by reminding you of the main issues we raised in our submission and getting some feedback from you if that is appropriate.
1) We recognise the positive steps being taken putting the Climate Change Action Plan into effect and look forward to further progress with these actions. We hope to be reassured that all adequate funding required to implement the Action Plan has been allocated in the LTP, as stated in clause 4(c)(ii) of the Plan.
2) Similarly we hope you can reassure us you will have clause 4(c)(i) of the Action Plan foremost in your minds when finalising the LTP. This clause states – “Include assumptions for climate change in the Long Term Plan, including provision for uncertainty, based on latest scientific evidence from the Intergovernmental Panel on Climate Change (IPCC).”
3) We urge councillors to always take the “precautionary approach” when making decisions. In particular we would focus on decisions that have the potential to impact the Wairau River and aquifer, especially with the knowledge we have gained and are gaining from the NIWA report projections and the ongoing Gravel River Beds and associated aquifer research. It is clear users of water from the aquifer can no longer take it for granted that their ongoing supply will always continue uninterrupted.
4) Finally we wish to focus on the final paragraph of our submission headed “The Long View”. As we have already said we believe that view needs to be well beyond the designated 10 years of this Plan because of the big challenges I referred to earlier. We have used the proposed residential development of the E2 land as an example of where this longer view is required. Do we understand the implications for this area when sea level rises one metre or more? Will we not already have big challenges to face with managing rising ground water levels around the sewerage ponds and the Riverlands Industrial Estate? Do we want to add to these challenges by extending the residential zone further to the east? We don’t have the answers to these questions but we do consider it our responsibility to raise them with you at this time.
I’m very aware of the difficulty of raising such issues without sounding like a pessimist and alarmist. I am inherently an optimist, otherwise I wouldn’t be standing here in front of you right now. Members of our group are involved in a variety of positive and constructive activities in the wider community and try our best to strike a balance when applying our kaupapa, which in part is, “To increase NZ society’s awareness of, and its preparedness to meet the impending challenges that rapid climate change will entail.”
So thankyou again for the opportunity to submit to the LTP and to come here today and “prod” you all, as we have done before. We see this as an important part of our task as a lobby group. We value the interaction and the relationships we have established with councillors and staff and will continue to contribute as positively as we can to the community building process in Marlborough.
Nga mihi nui, Budyong Hill – for Climate Karanga Marlborough.
We received a response from MDC after the LTP hearings where they informed us of their decision -
"There is $483,000 budgeted for Climate Change investigations. The group’s concerns are valid and are being taken account of in Council's planning, whether that be our resource management plan, infrastructure design or the broader planning issues involved in new development area considerations. There will be further work done on the benefits and costs of electric and hybrid vehicles to inform our next fleet renewal. The CE’s Council vehicle is a hybrid."
Climate Karanga Marlborough Submission on the Climate Commission Draft Advice for Consultation.
1. Climate Karanga Marlborough is a grass-roots incorporated society with 112 members. Our mission is to bring to the people of Marlborough the realities of climate breakdown and educate how best to respond.
2. We wish to acknowledge the importance and urgency of this Report, the detailed and varied work that has gone into it and the openness of its presentation. We submit that we are generally in support of the Commission’s many recommendations.
3. We submit that the report, as it stands, is too long and at times technologically and politically too daunting to engage the submissions of a significantly large and representative proportion of New Zealanders. The Executive Summary, whilst making vital points about the need to increase the speed of change, the importance of an “equitable transition” and the need for a “cohesive strategy”, is an uneasy combination of sketchy explanation and technical information.
The Climate and Biodiversity Crises
4. We sadly acknowledge the inability of the human race to see its place in the web of life. There is no doubt that, because we have lost sight of our place within the greater web of life, humans are destroying our only home. Too often self-centredness and a sense of entitlement to nature’s resources dominate our decisions. Global warming is but one manifestation of these human traits. Biodiversity loss and widespread pollution and desecration of the natural world are evident for all to see. We accept there is no easy way forward to deal with this dilemma, but are also in no doubt that if we do not succeed, the future for our descendants will indeed be grim. Humanity has dug this deep hole we are now in and finding our way out is not going to be simple.
5. There are some members of our race largely from various indigenous groupings, including Maori, who have managed to retain an understanding of our place in the web of life. This knowledge has been developed over millennia. Unfortunately, those who hold the political and economic power largely do not listen to their advice and wisdom. It is encouraging to see a recognition in the Report of the need to incorporate the values Maori espouse. Quoting the Report:
“We have considered how policies could support kotahitanga, manaakitanga, tikanga and whanaungatanga. As the Government develops its plan to reduce emissions, it also needs to consider how actions will align with these values. Partnership with iwi/Māori at every stage of the policy development process will be critical to support this.”
6. We are faced with an existential crisis because the prevailing economic system requires continuous growth on a finite planet, encourages huge amounts of waste and treats many of the amazing resources that nature provides for sustaining life as expendable and of little value. We have our priorities completely wrong! So, incorporating the above mentioned values in a way that is meaningful requires a major overhaul of our societal operating system. We cannot pretend we are listening to the wisdom of those who still have this understanding and carry on with the “Growth” imperative at the same time.
7. We wish to encourage the Commission to be honest and open about the nature of the challenges we face. The recent Dasgupta Review: the Economics of Biodiversity, commissioned by the UK government and released around the same time as the Commission’s Report in NZ, highlights many alarming facts including:
“in little more than two decades, between 1992 and 2014, there was a 40% fall in the stock of natural capital per person. That is the water we drink, the air we breathe, the soil we grow food in, and all living things shared among the global population.”
8. We have politicians in NZ who are happy to state publicly that:
“It is imperative that the Government does not meddle with the freedoms of New Zealanders and finds solutions to achieving net zero carbon emissions using effective and rational policy.”
This statement encapsulates the issue we are faced with. Turn this around and it is in effect saying solutions to achieving net zero carbon that impinge on our present so-called “freedoms” are not acceptable.
9. The Commission must appeal to all New Zealanders and encourage them to give up or drastically change many aspects of their current ways of living to help create the possibility of leaving a liveable planet for our grandchildren. We need to stop putting our own needs first and think not only of those still to come but more importantly of maintaining a viable web of life. Without it we are finished.
10. We would wish to strengthen the arm of the Commission in encouraging politicians and our Government, in particular, to recognise and acknowledge the damage we have continued to do to our environment, to our Motu, and to take immediate action to begin to reverse it. We hope that this will be part of a world-wide effort and that New Zealanders can seize the opportunity to take a lead in that effort, as we have done in combatting the effects of the Corona virus. – In fact, we recognise the advent of the Corona virus as a consequence of human depradations on our planet.
Nature as an Economic Asset
11. We recommend that the Commission refer to findings of The Dasgupta Review: the Economics of Biodiversity as potentially providing a way to put biodiversity and the environment into our economic thinking. Centring on the dynamic power, interconnectedness and intrinsic worth of biodiversity, local and global, the Review considers climate disruption as one of the consequences of the failure of modern economics, global business and individuals to account for natural capital, that is to say the air we breathe, the waters we drink and take food from, and the earth that sustains us and all the species on which the health of natural ecosystems depends. Biodiversity is essential to all ecosystems as an enabling asset, just as our own skills and aptitudes enable the value of our labour. In the last 400 years we have taken our environment for granted, given it no accounting value, subject to whatever we demand of it, whenever.
12. The Review has developed a unified framework for the economics of diversity. “The grammar we have developed enables economics to serve our values, not direct them.” (p 487) “Correct economic reasoning is entangled with our values. Biodiversity does not only have instrumental value, it also has existence and intrinsic worth. ... To detach Nature from economic reasoning is to imply that we consider ourselves to be external to Nature. The fault is not in economics; it lies in the way we have chosen to practise it.” (p 498)
13. There is a paradox that modern humans seems unable to save themselves simply by having the knowledge that we are destroying ourselves by destroying the web of life. We still seem to need some monetary or market incentive to change. Unfortunately, a market economy, historically based upon natural resource exploitation, remains the devil we know and trust.
14. Public awareness of the Climate Emergency appears minimal, at this stage, yet it has the potential to help decrease emissions from personal actions and cement political will to endure the changes ahead. The Commission has suggested awareness campaigns, such as the TV road safety ad campaign by NZ Police. We submit that, given that the government has declared a climate emergency, it needs to follow through with a public awareness campaign appropriate for an emergency, along the lines of the ongoing Covid-19 awareness campaign. This campaign might include regular updates of important climate parameters, such as global average air and ocean temperature, CO2 & methane concentrations, trends in sea ice, ocean pH and scientific research findings on climate related biodiversity and environmental changes.
15. We submit that the Commission recommend to government that it develop and promote an awareness campaign to help New Zealanders adapt climate-friendly habits in their daily lives, as one would expect in a national emergency. In particular, we submit that the campaign should be presented in a way for schools and other educational institutions to put before young people of all ages. – As the Report points out, these are the people who will deal with the changes their elders do or do not make now.
16. One critical issue we believe the Commission needs to face is that of continued energy availability. We need to accept the reality that, as we phase out fossil fuels, we are highly likely to have less overall energy available to us. It is not realistic to continue our planning as if we’re going to be able to continue meeting our extravagant energy needs unheeded, by just changing to renewable sources for that energy.
17. To date the ETS has demonstrably failed in reducing our emissions. We understand the cap that has now been introduced is expected to improve outcomes but there still appear to be shortcomings. We note in the Report on page 132 -
“The Government has recognised that the regulatory framework governing conduct in the NZ ETS market is patchy and incomplete. It has established a work programme to address the lack of good governance and associated risks, which include insider trading, market manipulation, false or misleading advice to participants, potential lack of transparency and oversight of trades in the secondary market, money laundering, credit and counter-party risks and conflicts of interest.”
The Commission appears to be saying the ETS, as it stands is not fit for purpose and, on page 133, that under the present governance arrangements “some [market] risks are potentially catastrophic for the scheme’s effectiveness..”
18. To highlight our concern about continued energy availability we wish to quote from a recent paper titled “The Political Economy of Deep Decarbonization: Tradable Energy Quotas (TEQs) for Energy Descent Futures”. A full copy is available here -
“Much mainstream energy and sustainability discourse is based on a series of highly optimistic assumptions about future energy supply in a carbon-constrained world. The improbability of conditions aligning such that all necessary assumptions are borne out implies that the energy futures ahead will likely diverge significantly from those envisaged within this established discourse. This has potentially profound implications. The availability of energy in the right forms at sufficient rates is the lifeblood of any particular form of social organisation. Energy-related factors are fundamental to how we shape our societies and pursue our goals, yet it seems most individuals and societies are making plans based on precarious expectations.”
And - “...we appreciate the psychological drivers for denying the prospect of energy descent and trusting instead in a cornucopian or techno-optimistic worldview. It is less confronting to human identities and ways of life to believe that technology and markets can solve social and environmental problems without needing to rethink the underpinning structures that give rise to those problems.”
And - “All human societies exist interdependently with natural systems that are ultimately beyond human control. It is far preferable, we contend, that societies retain the greatest degree of agency possible in getting to grips with the dilemma of fossil fuel dependence. The alternative is to have our futures dictated to us by breakdown in natural systems that are beyond our capacity to control.”
19. The Report provides no guidance to the government on the reduction of nitrous oxide emissions. It appears to take the position of the IPCC, that nitrous oxide emissions are a necessary part of agriculture and should be left to decrease simply through ongoing farming efficiency gains. This may be the IPCC view, which has a whole-world perspective, but it need not be the view here in New Zealand.
20. Most nitrous oxide emissions in New Zealand primarily originate from high-nitrogen pastoral farming practices – the use of nitrogen fertilisers and nitrogen-rich urine from cattle. The discussion of nitrous oxide in Evidence Chapter 4c points out a number of low-nitrogen alternatives to these practices, including ongoing pastoral farming practices where nitrogen fertiliser is not used at all. While the world may need nitrogen fertilisers to feed itself, it is clear that this isn’t the case here.
21. Nitrous oxide emissions are not an insignificant part of our total emissions. They make up 16% of the nation’s long-lived greenhouse gases in the 2022-2025 proposed emissions budget. And, due to the “light-touch” treatment in later emissions reductions, they rise to 22% of long-lived gases by the 2031-2035 budget.
22. Since nitrous oxide is not part of the NZ Emission Trading Scheme, there is, at present, no market mechanism to limit these emissions. The only control is based upon water quality considerations. We appear to be at the mercy of other pollution control laws and the good faith of the farming sector to take steps to limit these emissions.
23. Further, the lack of guidance on nitrous oxide emissions reductions:
1) Represents an economic injustice in emissions reductions efforts between New Zealand’s business sectors. The lack of a tax on
nitrogen fertiliser, while the rest of New Zealand pays an ETS tax on carbon emissions, represents an unfair “pass” on long-lived
GHG for the farming sector.
2) Ignores guardianship and sustainable principles, given the existing level of nitrate pollution to New Zealand’s rivers and lakes. We
simply cannot expect to keep spreading fertiliser on our lands indefinitely without damaging ecosystems. We must ultimately move
to sustainable, zero pollution farming practices.
3) Being primarily an export industry, New Zealand’s farming sector will likely be exposed to international carbon tariffs at some point.
These tariffs will increasing become a tool for nations to protect their domestic farming industries. New Zealand farming can stay
ahead of these tariffs only by innovating and adopting low emissions practices now.
24. We feel it is imperative that the Climate Commission provide some type of policy or market guidance to the government on ways to limit nitrous oxide emissions. A fee-rebate tax system on nitrogen fertiliser, for example, would use market forces to reduce and refine the use of nitrogen fertiliser, with the proceeds returned to support farmer education and R&D on low-nitrogen farming techniques.
A Stretch Goal to meet the Paris NDC
25. The Climate Commission has done an admirable job of assembling a set of recommendations to government on how to reduce GHG emissions sufficiently to meet the goals of the Zero Carbon Act.
26. It points out, however, that these recommendations will not be sufficient to meet the nation’s NDC made for the 2015 Paris Agreement – a 30% drop from 2005 emissions levels by 2030. The recommendation to address this shortfall is to simply purchase overseas emissions credits, with notes that other countries, such as Switzerland, are already doing this.
27. It is important to recognise, however, that international emissions credits aren’t necessarily a good thing.
1) By their nature, overseas credits are like foreign aid, only with a downstream cost, in that they rob the source country of the
ability to claim those emissions reductions for itself. The government of the time might be happy to sell the credits now because
they won’t be around when their country’s emissions reduction NDC comes due.
2) While some of these credits represent actual sequestration of carbon emissions, through forestry, for example, others are simply
programs to avoid future emissions in continued economic development. These programs might be approved by the UNFCCC, but
experience shows that relatively few foreign aid projects actually achieve what they set out to do. As a consequence, there is the risk
that many of these credits will end up being nothing but hot air, as we have seen with the Ukrainian and Russian credits NZ
companies bought last decade.
3) The rich country – poor country dynamics involved in most international emissions credits transactions creates a new kind of
colonialism. The poor seller needs to meet the requirements of the rich buyer, losing control of that portion of their economy and
perhaps their land. As a rich nation, we should be helping poor nations reduce their emissions without strings attached, not using
them to meet our international commitments.
4) Lastly, the overseas credits will cost us foreign exchange, which is important to our balance of payments and currency stability. For
the same amount of money, it would be better to meet these obligations domestically, paid for in NZ dollars.
28. There is another option – that of a “stretch goal” for the country that would meet this emissions target, in case parliament wishes to try to meet the target with minimal use of overseas credits. What more could the country do to meet this target? Where are opportunities for further emissions reductions by 2030?
29. In that most of the overseas credits that the government might purchase would be of the form of carbon offsets, either through forestry or “green” developments, it is worth noting some of the carbon offset opportunities here in NZ. Motu Economic and Public Policy Research lists a number of these offset opportunities in a 2017 report (Motu Note #25 – New Offset Options for New Zealand). To name a few of these offset opportunities:
1) Terrestrial and marine wetlands are known to be net carbon sinks but are not counted in the national emissions accounting and
could be. Their omission is largely due to a lack of understanding about how much carbon is sequestered and how much of other
GHG emissions (methane and nitrous oxide) they generate. More research is needed here, which the Commissions should
reasonably recommend. In the meantime, however, the other “ecosystem services” and wildlife habitat provided by wetlands are
well appreciated, so a national effort to promote, protect and restore wetlands, even if future research shows carbon sequestration is
insignificant, would be of net national benefit. We note that New Zealand is a signatory to the 1971 Ramsar International
Convention on Wetlands, so we should already be doing our best to protect and restore wetlands.
We submit the Commission should recommend to government that a national program of research, protection and restoration of
wetlands, with an eye toward ultimately adding wetlands carbon sequestration toward the national GHG inventory.
2) Soils are another known carbon sink which are not accounted for in the national GHG inventory and could be. As with wetlands,
NZ research on soils carbon sequestration is limited. We submit that the Commission recommend to government that a program of
expanded soil carbon research combined with programs to promote known methods of soil carbon enhancement and soil
conservation, be undertaken. This might take the form of carbon credits allotted to farmer who plant carbon-sequestering cover
crop during fallow years. This, again would be with an eye toward adding carbon sequestration by soils into the national GHG
3) Biochar, or charcoal made from wood waste, is known to be a valuable soil amendment; acting to retain water and nutrients in soils.
It is also an efficient form of carbon sequestration; taking wood waste that would naturally decay to carbon dioxide & methane and
converting it into carbon dioxide and elemental carbon. Test show that up to 50% of wood waste carbon can be retained as biochar,
which is stable in soils for potentially hundreds to thousands of years. There is already a small but active biochar industry here in NZ.
We submit that the Commission should request that the government provide stimulus to this industry, perhaps in the form of a
biochar price guarantee, which would further sequester carbon from our country’s abundant wood waste.
30. The NZ voluntary offset market has the potential to sequester a significant amount of carbon, provided there are enough offset projects and it is sufficiently subscribed. Many companies looking for reputational benefits, such as Air New Zealand, already purchase carbon offsets, but cannot find enough domestic offsets to meet the demand of their passenger-funded program. We request that the Commission recommend to government that it promote the domestic carbon offset market, perhaps by supplying seed money for projects and assistance with certification costs. At the same time, the Commission should recommend to government that it promote the carbon offset market to NZ industry, as a way for them to claim to be “carbon neutral”. This could reasonably start with SOEs, such as Air NZ, Genesis Energy, Mercury and Kiwi Rail and be expanded to wider industry and businesses.
We acknowledge that promoting the voluntary carbon offset market might compete with the government’s existing strategy of promoting permanent forests, or at least may represent a duplication of effort. The thought here is that government should use as many “levers” as available to promote domestic carbon sequestration.
31. We submit that the points in the submission are in no way a criticism of the Commission or the report. This first report and carbon budgets represent an important step forward in New Zealand’s transition to address the accelerating climate breakdown happening all around us. The report has stressed some important, yet perhaps underappreciated aspects of the transition, such as intergenerational justice, Maori partnership and an equitable distribution of benefits and burden. The Commission is to be applauded for this. The aim of this submission is to make a great, groundbreaking report, even better.
32. We wish the Commission to keep in mind, however, that we cannot go on behaving, thinking and treating the world as we have been, exploiting the earth for all the energy and everything else we can get from it now; the future, our descendants and the planet be damned. This is our only home: it is urgent that we remember to treat it and all life that shares it with us respectfully, valuing it for what it is, how it sustains us, not just for the resources it provides. All our submissions concern the means to that end.
Tēnā koutou rangatira mā.
Climate Karanga Marlborough comprises a group of over 100 different people all of whom have come through their own personal journey to a realisation of the real threat of climate breakdown, that we all now face and that we seek to bring to the attention of our fellow Malburians. We work with the Marlborough District Council, we publish articles, give talks and provide a social support network. Many of our members, through their personal and professional lives, have had experience of how people’s mental health and wellbeing may be drastically affected by changes in our environments.
Our submission is that the establishment of the Mental Health and Wellbeing Commission
1. specifically includes within the Commission’s purview and its functions attention to the significant impact on mental health and wellbeing of climate change, particularly those functions listed in Clause 11;
2. requires the Commission, in its task to promote alignment, collaboration and communication amongst contributors to New Zealanders’ mental health and wellbeing, to work closely with the Climate Change Commission and other contributors to managing climate change;
3. requires specifying that the membership of the Board collectively have knowledge, understanding and experience of the effects of climate on our land and its people.
CKM wish to present our submission in person at the Select Committee hearings.
The Mental Health and Wellbeing (MHWB) Commission (hereinafter The Commission).
We affirm the spirit and the intention in establishing The Commission, and we affirm its stated objectives, functions and powers as an independent body.
We applaud the cross-party involvement in drafting the MHWB Commission Bill (hereinafter The Bill), although we regret that despite 6 National Party members declaring their support for The Bill in its first reading, the National Party appears to have chosen to veto the Bill along party lines on a point of timing that surely the Select Committee might be allowed to have some leeway to adjust depending on their progress.
We acknowledge how those who have drafted The Bill have held to the findings of the He Ara Oranga Report, particularly expanding access, facilitating co-design, taking a whole-of-government approach to wellbeing, prevention and social determinants, and facilitating health promotion and prevention. However, we are disappointed that neither the He Ara Oranga Report nor the first draft of The Bill mentions how climate change has a significant impact on the mental health and wellbeing of New Zealanders. That it does so has been confirmed in the Royal Society’s report in 2017 on Human Health Impacts of Climate Change for New Zealand, in various reports by the Ministry for the Environment, by the Climate Change Commission and in numerous articles in the international health literature.
We welcome the positive approach that the Climate Change Commission has taken in recognising New Zealanders’ responsibilities in managing climate change and in supporting their endeavours to that end. With that in mind, we urge the Select Committee to highlight in the second reading of The Bill the importance of The (MHWB) Commission collaborating with the Climate Change Commission to promote an understanding of how climate change affects people’s mental health and wellbeing and how these effects may be managed for greater wellbeing, and so to prevent further ill health.
Mental health, including ill-health, and wellbeing services.
We welcome the emphasis in The Bill on providing an overview of services promoting wellbeing, not only services ‘treating and managing’ illness. But we welcome too the recognition of the social determinants of illness, to which we would add environmental determinants, as well as the biological determinants. Also, we recognise how poverty and social and economic disadvantage interplay with mental illness and distress, a fact widely recognised in the mental health and sociological literatures. So, we see that there is a great opportunity for The Commission to take a wider approach to mental health than the so-called social investment approach which targets services to key groups, and thereby discriminates them. Almost inevitably, such an approach tends to stigmatise those groups, such as ‘the mentally ill, the disabled, the elderly, vulnerable children and Māori’. Rather The Bill aims to improve equity for communities ‘that experience poorer mental health and wellbeing outcomes’.
We support the requirement that the members of The Commission collectively have knowledge, understanding and experience of Te Ao Māori. The Māori people know what it is to belong to the land, rather than vice versa, and have long experience of what it is to become dispossessed and displaced, and so to grieve. To us this is key, as these will be the effects on all of us, our health and our wellbeing, inseparably both physical and mental, if we do not anticipate and deal with the threats of climate change.
We therefore ask that The Bill be amended to ensure the work of the MWHB Commission
Letter sent on 10/11/19 to request meeting -
Kia ora John,
Congratulations on returning such a strong Council. We really appreciate that you have taken on the position of chair of the Environment Committee and are encouraged by your statement that there is a "lot of work to do" in this area. Needless to say this is “music” to our ears and we are now keen to organise a time for 3 or 4 members of our CKM team to meet with you to consider how we might best work together in the coming months.
To prepare for this possibility, constructive meetings have been had with the new councillors, as well as several of the returned councillors. This has been a useful time for Councillors to familiarise themselves with our current interests and concerns and vice versa.
At this stage we are particularly keen to discuss:
We are keen to share concerns being expressed by some of the youth. It is difficult to know how best to respond to the distress some of them are feeling. We're guided to some extent by what they tell us. They say it is more distressing when they perceive people in positions of authority and power responding inadequately to the information the scientists are telling us. They say it reduces their worries when those same people recognise there is an emergency and declare this openly. When they feel people are not being open and direct about it they worry that it is not being treated as a priority.
A Declaration of Climate Emergency:
We raised the question of the declaration of a Climate Emergency with the old council, as did the Youth, and you indicated such a decision was best left for the new council to make. We appreciate there are political and practical ramifications from making such a declaration but for us, there is no doubt about the severity of the crisis and we believe that such a Declaration at this time would be a valuable response to our young people and focus point for the wider community. We are aware of the constant new information coming into the public arena confirming the critical nature of the state of the planet's climate. This long slow emergency will be with us for generations.
We have included a couple of items for your interest to support our concerns. The first is a sobering paper published in Australia in May this year titled "Existential Climate Related Security Risk". https://www.breakthroughonline.org.au/papers
The second is a link to a recent article from the Guardian. https://www.theguardian.com/environment/2019/nov/05/climate-crisis-11000-scientists-warn-of-untold-suffering
We look forward to discussing these matters further with you.
Supplementary information sent on December 2nd -
As you will have noted we are interested to discuss the pros and cons of declaring a Climate Emergency in Marlborough. Firstly we wish to state we are optimistic the final Climate Change chapter of the MEP is going to provide the council and the community with a firm foundation to work from. We expect it to give clear guidance on suitable actions to take, as we plan together how best to prepare for the climate emergency scientists have informed us we are all now faced with. As we have stated before we believe MDC has a critical leadership role to play in our community in helping raise awareness of the threats we are likely to face from Global Warming and in leading by example with appropriate actions.
One question that has arisen in discussions with councillors has been: “What actions would council need to take to justify declaring a Climate Emergency?”
We believe there is not a lot extra council needs to do to justify making such a public statement. Effectively you have already done the donkey work. You have already instigated the “Integrated Work Programme” to provide you with baseline information to plan from and recently formed the “Cross Council Staff Working Group”, which we see as having an important role in coordinating activity across the council operations. But most important has been the drafting of the Climate Change chapter in the draft MEP followed by the proposed adoption of a range of important recommendations arising from the draft chapter and the submission process. We wish to commend you on appointing David Jackson to present the Section 42A report, as it was clear he was well qualified to do that job. Just as important was your decision to appoint several very well informed and qualified commissioners to the Hearings Panel. We were also particularly pleased that the very important contribution from one of CKM’s expert witnesses, Dr Judy Lawrence, was well reflected in the recommendations. We are optimistic the final Climate Change chapter in the MEP will incorporate all that good work and provide the foundation we need to work from as a community. If our optimism is well founded then this important document will ensure the council takes some very important actions in the next few years to lead by example and help build resilience in our community.
Another question we were asked was: “If the council is already taking actions that recognise the importance of planning for global warming then why declare a Climate Emergency”.
This is a valid question and we believe gets to the crux of the matter. There is only one really good reason to make this declaration. The answer is this: “Council has a leadership role in the community. This requires it to take every possible action to let the community know our planet is faced with an existential crisis. Declaring a Climate Emergency says to everyone we must always keep the information about this threat in the forefront of our minds. It says we are all in this together and we must do whatever we can in our lives to make a contribution to addressing the issues we face. It is a symbolic action with the potential to have great influence.”
If you accept and agree with the information we have already sent, contained in the paper “Existential Climate Related Security Risk” and the accompanying Guardian article then we believe there is no other real option. It is our future and the future of our descendants that is at stake here. We accept this is a huge responsibility but face it we must if we are to have any chance of doing the necessary work to play our part and prepare ourselves for a changing world. We understand and accept that in the end any decision needs a majority of councillors to support it. We have put some effort into discussing the matter with various councillors and sharing information with them, but believe getting a positive decision will be more difficult without the support of the mayor. We are therefore keen to have this opportunity to meet face to face and hear what you thoughts are on making or not making such a declaration.
If there is support for a declaration we would like to suggest an appropriate time to make such a public declaration would be after the MEP is released when the Climate Change chapter can be referred to in support of the declaration.
Below is an attempt to put together the important highlights from the Section 42A report and Addendum on Chapter 19, the Climate Change chapter of the MEP. We have done this as much for our own use as yours. Extracting the important statements and recommendations from the report and putting them all together in one place helps to emphasise the value of this document. We are hopeful that, as the Climate Emergency becomes more obvious to everyone over the next decade, it will provide a good basis to work from and to guide us in making the necessary decisions and adaptations that benefit our community.
Amended introduction to Climate Change Chapter 19.
Society currently relies on fossil fuels as an energy source. The consumption of these fuels and livestock farming are the two major contributors to the large increase in the release of carbon dioxide and other greenhouse gases into the atmosphere over the last 150 years. The general consensus of scientific opinion is that the world is getting warmer, causing its climate to change. Global temperatures are approximately 0.85 degrees Celsius higher than in 1880 according to the IPCC 5 Assessment Report. To “strengthen the global response to the threat of climate change” the UN Paris Agreement set an aim to hold the increase in global average temperatures to well below 2°C above pre-industrial levels. There is now strong evidence that most of the warming observed is attributable to increased concentrations of greenhouse gases produced by human activities. As more gases accumulate in the atmosphere, the Earth gets warmer, resulting in rising sea temperatures and levels, the melting of glaciers and ice caps and greater extremes in weather patterns, such as more storms of greater intensity and longer droughts.
In Marlborough, NIWA predicts that the mean temperature will increase by approximately 0.7-1.0 degrees by 2040 and 0.7-3.0 degrees by 2090 above 1995 levels. The climate is likely to become drier and the frequency of droughts is expected to increase. There is also a predicted increase in westerly winds, especially in winter and spring.
Section 7 of the Resource Management Act 1991 (RMA) requires the Council to have regard to the effects of these predicted climatic changes in exercising its functions under the RMA. Uncertainty about the nature of these effects at international, national and local level makes this a difficult task.
Most projections are also long term and certainly beyond the ten year life of the Marlborough Environment Plan (MEP). Taking all of this into account, the provisions of this chapter focus on applying the best available information to enable people and communities to respond to the adverse effects created by climate change - and any beneficial effects that may arise.
Climate change may also lead to more stress-related mental health effects from extreme weather events such as droughts, floods or fires as these can cause disruption to individuals and business, including the primary sector.
In the meantime, it is prudent to promote actions that reduce or offset carbon emissions and retain sufficient flexibility in the use, development and protection of natural and physical resources to enable resource use to adapt to climate change.
One of the difficulties is that there is inherent uncertainty regarding the likely local climate changes in Marlborough and therefore the exact nature of those adverse effects is unknown, making it particularly difficult to plan for climate change. Further research will assist in this regard. In the meantime, it is prudent to promote actions that offset carbon emissions and retain sufficient flexibility in the use, development and protection of natural and physical resources to enable resource users to adapt to a changing climate.
Promote actions within Marlborough to reduce or offset carbon emissions.
For example, the Council will assess and then address the carbon footprint of delivering its own services to the community (including its tree planting) and encourage businesses to do likewise.
Improve the community’s understanding of the potential effects of climate change on the Marlborough environment.
Enable primary industries to adapt to the effects of climate change.
Investigate Council operations to establish their carbon footprint; set goals for reducing carbon emissions having regard to New Zealand’s national emissions reduction targets and develop an action plan to reach those goals.
Consider, in the review of the Marlborough Regional Transport Plan, provisions to reduce emissions of greenhouse gases taking into account the climate change provisions of the Marlborough Environment Plan.
Apply the findings of international and national climate change research to Marlborough’s environment to the extent that is possible and support research relating to Marlborough. The findings can then be applied to determine and better understand the implications of climate change.
Share the findings of research on climate change in Marlborough and the implications
of these predictions with the community. This will help to allow people to take action to prepare for
those implications and therefore reduce the adverse effects of climate change .
Rules will establish sustainable levels of freshwater allocation that take into account the effects of climate change on river flows and aquifer levels and the resulting sustainable yield from those freshwater resources. Enable the taking of surface water for storage purposes through the application of a controlled activity rule to the abstraction.
Apply a range of permitted activity rules to farming and forestry activities. Use broad definitions of “farming” and “forestry” so that farmers and foresters are able to modify farming practices and diversify or change crop/stock types in response to changes in climate. Enable the creation of permanent carbon sinks through the application of appropriate rules.
Extra Method recommended for addition.
The Council will consider establishing a Climate Change Advisory Group comprising representatives from science, industry and the local community to work with Council in a collaborative way to identify regional climate change threats in Marlborough and devise appropriate adaptation and mitigation responses.
Climate change could affect natural hazards and create a coastal inundation hazards associated with sea level rise.
Explanation to Issue 19B
Global warming is expected to result in a rise in sea level due to thermal expansion of ocean water and melting of glacial and polar ice. Sea level is predicted to rise around 0.55 to 1.36 metres by 2120 . This rise potentially increases the risk of inundation at the coast.
Coastal erosion could also become more prevalent, increasing the need for coastal protection measures, both of which can have adverse effects on natural values . Along the coastal margin of the Wairau Plain, the level of the Wairau River bar and river mouth efficiency has far greater influence on the potential for inundation than the projected sea level rise. Further south, the topography and lack of settlement minimises any inundation risk. However, the risks are far greater in the Marlborough Sounds where settlement and associated infrastructure (especially means of access, such as jetties and access tracks) tend to be located in the coastal environment and near the water edge. Where land is subsiding, the adverse effects of sea level rise from climate change can be accelerated.
Avoid and mitigate the adverse effects of natural hazards influenced by climate change.
Monitor flood hazard on an ongoing basis.
For planning and development in the coastal environment the following sea level rise allowances and scenarios should be used (until a dynamic adaptive pathways planning process is completed) to assess and manage potential coastal hazard risk:
(a) Coastal subdivision, greenfield developments and major new infrastructure – Avoid hazard risk by using sea-level rise over more than 100 years and the H+ scenario;
(b) Changes in land use and redevelopment (intensification) – Adapt to hazards by conducting a risk assessment using the range of scenarios and a dynamic adaptive pathways planning approach;
(c) Existing coastal development and assets – use a minimum 1.0m sea level rise ; and
(d) Non-habitable short-lived assets with a functional need to be at the coast, and which either have low consequences or are readily adaptable (including services) - use a minimum 0.65m sea level rise.
Dynamic adaptive pathways planning approach, and the climate change/sea level rise scenarios are as defined in “Coastal Hazards and Climate Change: Guidance for Local Government, Ministry for the Environment, December 2017”
Explanation to Policy 19.2.2
The International Panel on Climate Change has determined that it is very likely that the rate of global mean sea level rise during the twenty-first century will exceed the rate observed during 1971– 2010 due to increases in ocean warming and loss of mass from glaciers and ice sheets.
The Ministry for the Environment advises local government*, to use a ‘dynamic adaptive pathways planning’ approach to considering the effects of climate change, and managing and adapting to it and the hazards risk from plan for a sea level rise and climate change. The approach provides flexibility that allows an agreed course of action to be changed if the need arises. Until the adaptive pathways planning is undertaken, the Ministry for the Environment guidance is to use interim sea level rise allowances and scenarios, depending on the type of activity. This advice, for four categories of activity, is reflected in Policy 19.2.2. In Policy 19.2.2 (a) a fixed figure is not used because a development occurring in the late 2020s, for example, will have a different forecast period (and predicted sea level rise), than one occurring earlier than this, or later. Also, the decadal increments for sea level rise over the next 100 years are not equal, but get larger under the H+ scenario further into the future.
Although the life of the MEP is only ten years, buildings have a minimum design life of 50 years and new subdivisions and property titles have an indefinite life. Equally, new infrastructure can be long-lived, and involve multi-million-dollar community investment. The policy reflects the different timeframes, and increases of sea level – and the different risk involved – associated with various types of development. It also recognises that a different approach is possible with new compared to existing development.
This policy will be applied to the determination of resource consent applications, plan changes and designations. Rules elsewhere in the MEP require buildings to be set back from the coastal marine area. This in itself will act to protect buildings from the adverse effects of sea level rise and/or storm surge. However, when applications are made to establish a building within this setback, then the policy will be able to be applied.
*Coastal Hazards and Climate Change: Guidance for Local Government, Ministry for the Environment, December 2017.
In order to plan for the effect of sea level rise, it is necessary to understand the areas along the Marlborough coast that are likely to be affected by inundation in the long term. The Council will undertake an investigation to establish the extent and nature of the inundation hazard using the Intergovernmental Panel on Climate Change’s most recent projections of sea level rise.
There is a reduction in the carbon footprint of the Marlborough District Council’s operations. Council report establishing existing carbon footprint and subsequent reports on reductions achieved.
1.Climate Karanga Marlborough (CKM) is a citizens group of over 100 members, with the mission of bringing the realities of climate breakdown to the people of Marlborough and educate how best to respond. We do this through a number of initiatives:
a.by working with the Marlborough District Council on strategies to limit emissions and help adaptation to the effects of climate change
b.by publishing articles promoting climate change awareness and preparedness in local newspapers and by sponsoring community and school events
c.by providing a social support network for Marlburians and other New Zealanders anxious about, and looking to better understand the implications of the climate change crisis we are now facing.
2.CKM broadly supports the objectives and overall structure of the Bill. We are happy that Parliament is finally taking action on the climate emergency. We agree with aligning the Bill with the warming limited to 1.5°C rather than other, less ambitious targets.
3.We do wish to be heard at the Select Committee hearings.
4.We support the establishment of the Climate Commission as an independent panel of experts (rather than stakeholders) to advise Parliament and government departments. Although the selection mechanism proposed in the Bill appears sufficiently robust to prevent politicisation of the Commission and the reporting mechanisms will prevent suppression of the Commission’s reports, we strongly feel that the Commission should be a separate statutory body reporting to Parliament rather than to the minister. This is the structure of the Committee on Climate Change in the UK and it seems to be working well. The NZ Commission needs to be shielded from the political whims of the government of the day. The best way to achieve this is with a separate public body. In addition, funding of the Commission as proposed appears vulnerable to the annual budget cycle of Parliament. We recommend that funding of the Commission be provided for separately, as is the case with the nation’s courts.
5.We support the measures taken in the Bill to include Maori and honour the Treaty of Waitangi. These appear to be sufficient to provide the needed Maori input into the Commission’s work.
6.We support the inclusion of adaptation and risk assessments as reporting responsibilities of the Commission and not handled or shared by separate agencies. It will be important that emissions targets and progress toward meeting those targets be integrated with reporting on the impacts of climate change on New Zealanders and adaptation to it. The nation needs a coherent strategy, which would not be the case if these functions are handled by or shared with other agencies.
7.We support the goal of net zero emissions of greenhouse gases (other than methane) by 2050. This is in line with the IPCC recommendations to achieve no more than 1.5°C warming with limited overshoot. Given the fact that New Zealand is lagging behind in achieving the emissions reductions and renewables uptake it has committed to, we feel it would be important to aim to achieve net zero emissions before 2050. That way there is room to take account of unforeseen circumstances that may set us back from this goal.
8.With respect to the “net zero emissions by 2050” goal, we feel that an interim goal for 2030 should also be stated, as is the case with methane. The IPCC recommends a decrease of 45% by 2030 relative to 2010. We support this as an interim 2030 goal. It would ensure New Zealand stays aligned with IPCC recommendations and prevent the necessity of having to introduce urgent, disruptive and costly emissions reductions measures as the 2050 deadline approaches.
9.We support the “split gas” approach to emissions targets. Methane has a limited lifetime in the atmosphere, but also cannot be mitigated through sequestration. Carbon dioxide has a long lifetime in the atmosphere and accumulates in our environment, but it can be sequestered by forestry, soils and industrial processes. The two gases produce vastly different warming, with methane having a much more severe near-term impact than carbon dioxide. Methane’s more severe near-term impact is not properly accounted for in the GWP100 method for equating their impacts, which would likely be the basis for a common emissions accounting scheme. Lumping methane with carbon dioxide in the emissions trading scheme could also have a perverse consequence, whereby methane emissions are allowed to increase through forestry offsets. This could conceivably prevent us from reaching the 1.5°C global warming limit the Bill is aiming for. That does not mean methane reduction should be given less priority; just the opposite.
10.We support the 2050 reduction target for methane of at least 24-47%. This is in line with the IPCC recommendation of “35% or more” decrease by 2050 in order to remain below the 1.5°C global warming target. Flexibility in this target is prudent because it is not clear that technological advancements, de-stocking and land-use changes in our agriculture sector will, on their own, be able to achieve the more ambitious reduction target in time. Neither is it clear that our atmosphere will always have the same capacity to remove methane. A 29 April 2019 article in EOS () published by the American Geophysical Union, suggests that methane emissions are growing faster than can be accounted for and new, poorly understood factors with respect to methane sources and breakdown in the atmosphere could make it harder to reach the 1.5°C goal.
11.We feel that the interim 10% reduction target for methane by 2030 is well below that which will be required to limit warming to 1.5°C. MPI has recently stated that a 10% reduction could be achieved simply by following farming best practice. We note that methane emissions pathways used in IPCC modelling to achieve a limit of 1.5°C heating show a decrease well below 10% by 2030. The IPCC Special Report: Global Warming of 1.5°C Figure 2.7 shows an average decline of approximately 30-40% by 2030 for models achieving 1.5C warming with low overshoot. New Zealand could achieve the target of net zero carbon dioxide emissions, only to exceed the 1.5°C warming limit because methane was not decreased quickly enough. We argue for a more aggressive 2030 target for methane, in order to stay in line with what is necessary to achieve the 1.5°C warming limit.
12.We do not support the provision in Section 5ZJ of the Bill which prevents any court remedies in the event the government fails to achieve emissions targets, other than a declaration of such. The Bill should carry the weight of a treaty, a treaty between the people of New Zealand and its government. In the event that emissions targets are not met, the government should be compelled to act to remedy the situation.
13.We do not support the provision in Section 5ZK which states that government decision makers “may take the 2050 emissions target and emissions budget into account”. This wording needs to be changed to “must take the 2050 emissions target and emissions budget into account”. Simply stating that they must take this target into account doesn’t mean that they have to blindly follow it – they still may not. But it makes little sense to set a cross-party national policy that does not need to be taken into account in government decision making.
14.New Zealand’s share of international aviation and shipping needs to be included in national emissions accounting and in emissions reduction schemes. The fact that these sources of emissions are presently exempt from the Paris Agreement is no excuse. New Zealand should follow the UK’s lead in including these emissions sources in our emissions reduction targets.
15.We support the establishment of a youth council to work in parallel with and advise the Climate Commission. Youth today will be the hardest hit by the climate changes of tomorrow and they need to have informed representation on the Climate Commission.