Introduction.

This is a submission of Climate Karanga Marlborough to the MfE consultation document regarding the government’s Second Emissions Reduction Plan (ERP2).

Climate Karanga Marlborough (CKM) constitutes a growing group of over 140 citizens in Marlborough, who are concerned with bringing the realities of climate breakdown to the people of Marlborough in particular, and to the wider society in Aotearoa New Zealand in general. Our goals include assisting elected representatives and their officials to pursue policies designed to limit the deleterious effects of rapid climate change, and to help New Zealanders adapt to its consequences, while providing a social support network for the increasing numbers of people who share our concerns.

CKM asked one of its suitably qualified members to prepare a response to the consultation document with the support of an editorial team. We are hopeful that the Government and the Minister concerned will pay due notice to this response and will add more emissions reductions programs in preparation for ERP3 and net zero 2050. Yet, we are also fearful, in view of how the ERP2 document appears to ignore the advice of the Climate Commission itself, that the Government may simply be going through the motions of consultation.

The following CKM submission foregoes the questionnaire, and the limitations it imposes on our response, and focuses specifically on the credibility of the emissions reduction proposals. We have then added some more general comments.

Submission.

    1. In summary, we do not find the emissions reduction plan presented in the consultation document and technical appendix to be accurate,
credible and in the best interests of New Zealand’s long term emissions reduction targets.

    2. This submission is presented in three sections, addressing different deficiencies in the plan (here referred to as ERP2).  These sections
address the following:
              a) Inaccuracies and errors in text, calculations and methodology
              b) The inadequacy of proposed new emissions reduction proposals to reduce emissions to the extent estimated in the plan
              c) The long term consequences of these inadequacies on our country’s ability to meet the emissions reduction targets legislated in the
                  CCRA.

Inaccuracies and Errors.

    3. Firstly, we bring to your attention an important mis-match between statements in the consultation document and the technical annex (page 8):

The consultation document (page 32):

“We expect measures proposed for ERP2 to reduce net emissions over the second budget period. Modelling of key ERP2 complementary policies, such as Electrify NZ, enabling a network of 10,000 electric vehicle (EV) charge points and introducing agricultural pricing, suggests they could provide reductions of about 4.11 Mt CO2-e during the second budget period and about 13.5 Mt CO2-e during the third budget.”  

The technical annex (page 8):

“The Government has made proposals for new policies, including the roll-out of 10,000 electric vehicle (EV) chargers, reductions in barriers to consenting renewable electricity generation (as part of the Electrify NZ strategy), limits on land-use change to forestry from more productive land-use classes and the introduction of agriculture emissions pricing by 2030. However, these proposed policies have not been fully designed or implemented as at the date of the development of the interim emissions baseline (and therefore, in accordance with the definition of the baseline, are not included). The impacts are still to be fully estimated but some initial estimates of the effects of these policies are included in this annex.”

The emphasis in bold in both statements is ours, included to highlight the contradiction between these two statements.  

To add to the confusion, footnote 8 under Table 0.1 of the consultation document states: “CCUS estimates were modelled separately from other key ERP2 policies, which used the Emissions in New Zealand model”.
So, which is it?  Were the emissions reductions from new policy proposals modelled or weren’t they?  If the results were modelled, where are the model parameters?  Or, does the consultation document mislead the reader as to the certainty of the 4.1 Mt CO2-e emissions reduction in ERP2 due to the new policy proposals by saying that they were modelled when they actually were simply estimated?  This needs to be clarified in the consultation document.

    4. The 4.1 Mt CO2-e value for expected emissions reductions due to new policy proposals (calculated in Table 10 of the technical annex) does not include the +0.2 Mt CO2-e emissions due to the planned revision to the clean car standard in technical annex Table 11.  The actual value in Table 10 and in the consultation document, page 32, should be 3.9 Mt CO2-e.  

We note that a correction made to the technical annex in July 2024 actually removed the added emissions from the revision of clean car standard from Table 10 and put it into a separate table (Table 11).  Why was this done?
 
    5. The final tally of emissions in ERP2 in Table 13 of the Technical Annex (and repeated in Figure 2.2 of the consultation document) shows that the ERP2 emissions “with new measures” is 3.8 Mt CO2-e below the ERP2 interim baseline.  Where did this emissions reduction number come from?

If it is a more precise calculation of the 3.9 Mt CO2-e calculated from Technical Annex Tables 10 & 11, then it should be stated as such.  If it is an error, it should be corrected.
 
    6. Regardless of this minor discrepancy, the ERP2 emissions reduction expected from new policy proposals is an optimistic estimate rather than a realistic one.  The 4.1 Mt CO2-e value is the sum of the higher end of “up to -1.3” and “up to -1.1” in the two Waste categories in Technical Appendix Table 10 and consultation document Table 0.1.  

This perhaps justifies the use of the phrase “could provide reductions” in the paragraph copied above from page 32 of the consultation document, but using this value for ERP2 emissions reductions is in conflict with the treatment of uncertainty in the interim baseline in the technical annex.   The projection of uncertainty for the interim baseline relies on both a statistical treatment of historical deviations and on sensitivity analyses.  The results show high, mid-point and low estimates of interim baseline values.  

Why were not similar, high-mid-low values estimated for the emissions reductions from the new policy proposals? It is clear from the calculations that these emissions reductions are at the high end of what is expected.  For consistency with baseline methodology, as well as for straightforward intellectual honesty, these ranges should be estimated (or preferably modelled) and reported in the final ERP2.

    7. In conclusion, there is every indication from the consultation and technical annex documents that the Ministry has attempted to present a more certain and optimistic case for the emissions reductions expected from the government’s new policy proposals than is actually warranted.  The errors discussed above all point in this same direction – towards higher emissions reductions due to the new policy proposals.

We would expect the Ministry to at least get the technical language and mathematics right in such an important document, and to present the results in an honest and unbiased way.  There is an issue of public trust here that should be paramount in the Ministry’s mind.

New Emissions Proposals.

    8. Table 0.1 in the consultation document and Table 10 technical annex show estimates of the impact of new policy proposals on ERP2 and ERP3, summing (optimistically, as discussed above) to 4.1 Mt CO2-e (or more correctly 3.9 Mt CO2-e, when changes to the clean car standard are added).  Three proposals account for the great majority of the ERP2 emissions reductions: carbon capture, utilisation and storage (-1.4 Mt CO2-e), waste minimisation fund (up to -1.3 Mt CO2-e) and organic waste and landfill (up to -1.1 Mt CO2-e).  These provide up to -3.8 Mt CO2-e of the overall 4.1 Mt CO2-e emissions reduction optimistically estimated for ERP2.  Let’s discuss how realistic each these three emissions reduction proposals are, one at a time.

Carbon Capture, Utilisation and Storage.

    9 Carbon capture, utilisation and storage is not a technology.  It has been around for a long time.  It is apparent, however, that plans for CCUS in New Zealand are still in their infancy.  Note the following paragraph from consultation document page 84 under non-forestry removals:

“The Government recognises carbon sequestration can occur through biological, geological, oceanic, chemical and technological processes. Alongside forestry, the Government sees other forms of removing emissions, such as wetland restoration, on-farm vegetation, coastal vegetation management, marine ecosystems, carbon mineralisation, carbon capture, utilisation and storage, ocean fertilisation, direct air capture and bioenergy with carbon capture and storage as opportunities to reduce net emissions that may become viable in the future”.

Indeed, the government’s plans for CCUS appear to be in very early stages of implementation.  Consultation document Appendix 2: Proposals for the second emissions reduction plan lists the following in the description of the proposal for CCUS:  “Consult separately on options to remove barriers to using CCUS”.

Considering that the proposal is still in the consultation stage, it is quite premature to assign it 1.4 mt CO2-e removals between 2026 and 2030.  

    10. Another obvious problem with CCUS is cost.  A 2023 Wood Beca report, referenced in the consultation document, evaluates the suitability of CCS at two Taranaki fields; the onshore Kapuni field and the offshore East Maui field.  These are two projects mentioned in the consultation document as likely candidates for the installation of CCS.  The report concludes that the Class 5 (-50%/+100%) cost estimate for CCS for the onshore Kapuni field is $30-110 per tonne CO2.  They do not state a cost estimate for the offshore Maui East field, saying only, “… that the cost of executing an offshore CCS project is expected to be much higher than onshore.”

The NZU price trend assumed in the ERP2 consultation interim baseline has a peak of $75 in 2028 declining to $50 by 2035, starting at roughly $50 today. It is unlikely that industries will invest in CCS with these low expected NZU prices.  They would be wiser to just pay for the emissions credits.

    11. A third and perhaps more pressing problem for CCS at the Kapuni and Maui fields is declining gas production and the risk that the Methanex methanol plant, which takes nearly half (45%) of the nation’s natural gas production, might close due to lack of gas supply.  Already, one of Methanex’s three methanol plants (Waitara Valley) has been shut down due to insufficient gas supply.  If the other two Methanex plants close, there would be little incentive for field operators for investment in long term gas supply upgrades.  The market risk would be too high.

In a gas supply and demand study to the Gas Industry Company dated December 2023 (and referenced in the consultation document) Ernst & Young state:  “In all the scenarios considered, the best estimate of commercially viable future natural gas production (known as 2P reserves) is estimated to be insufficient to meet demand at some stage between 2025 and 2027. Even if production from 2C resources, which are not currently commercially viable, comes online the results still show natural gas production from all sources as being insufficient to meet demand at some stage between 2028 and 2034.”

Field operators will be hesitant to install expensive new kit, such as CCS facilities, that will soon be under-utilised.

Note the definition of “2C” resources from Ernst & Young: “Contingent Resources are those quantities of petroleum estimated, as of a given date, to be potentially recoverable from known accumulations, by the application of development project(s) not currently considered to be commercial owing to one or more contingencies.” (p150). In other words, 2C resources require favourable economics, additional investment and an appetite for risk.  Will the gas field operators invest more in today’s uncertain gas market environment?

We’ve heard just this month that Methanex has suspended methanol production at its remaining two Taranaki plants until the end of October in order to sell its gas supply to Contact Energy and Genesis Energy.  The gas is needed for electricity generation, to make up for low hydro storage and limited gas supplies for electricity generation this year.  Methanex expects to earn more from selling the gas than it would from methanol production.  As gas supplies continue to decline, Methanex will have more incentive to sell its contracted gas supply and cease methanol production.

    12. In conclusion, it appears highly unlikely, based solely upon economics, that CCS (or CCUS) will be installed at a gas field in the ERB2 (or ERB3) time frame.  The emissions reduction from CCS (or CCUS) is very uncertain.

Waste minimisation fund.

    13. This policy proposal is listed as reducing emissions by up to 1.3 Mt CO2e during ERP2.  Yet it is nothing more than idea at this stage.

    14. There appears to be no new funding to support the suggested infrastructure upgrades.  New funding is mentioned as being from an increase in the Waste Disposal Levy, although a recent report by MfE on the new levy (Supplementary Analysis Report: Waste Minimisation (Waste Disposal Levy) Amendment Bill 2024, dated 15 May 2024) only recommends new central government funding for contaminated sites and emergency waste disposal.  Some new funding will be available to councils, per the 50% funding split between central and local government but it is up to councils to decide where the local council portion will be spent.  

    15. We acknowledge that the increase to the Waste Disposal Levy and intention to use some of the Waste Minimisation Fund to support programs to capture and destroy landfill methane and divert organic waste to other uses, will reduce emissions.  Without a better description of funding level, industry participation and modelling, however, it is difficult to verify what that reduction will be.  The ministry needs to present evidence in support of the emissions reduction claims for this policy proposal.

Organic waste & landfill gas capture.

    16. This proposal also seems to be in the very early stages of development.  The purpose of the proposal, from page 91 of the consultation document is as follows:

“The government proposes engaging with industry on how we dispose of and manage organic waste streams in landfills.  Further analysis and research would be needed to determine which policy and/or regulation changes would be most effective and efficient to reduce our landfill waste emissions”

The consultation document shows up to 1.1 Mt CO2e emissions reduction in ERP2, although the government hasn’t even started to consult on this proposal yet.  

    17. The 1.1 Mt CO2e emissions reduction stated for improved landfill gas efficiency appears to come from some very preliminary calculations.  Page 92 of the consultation document states:

“For example, initial modelling suggests that a scenario of a 7 per cent increase in LFG capture efficiency across New Zealand’s disposal facilities with LFG capture systems in place, combined with LFG capture expansion to all class 1 facilities, may have an abatement potential of up to 309 kt CO2-e per year up to the end of the second emissions budget period (2030) and further abatement during subsequent periods.”

This is followed by the footnote:

“Provisional modelling estimates that in the remaining NDC period (2024–30) this could achieve up to 1.1 Mt CO2-e and from 2024–50 up to 6.1 Mt CO2-e per year.”

There is no analysis that suggests that a 7% increase in landfill gas efficiency is even possible within reasonable budgetary limits.  Passing regulations to “make it so”, as suggested in the consultation document, could put a heavy burden on councils to spend significantly more on landfill gas capture infrastructure.

Also note that the footnote states that the emissions reduction of up to 1.1 Mt CO2e would be for the remaining NDC 2024-30 period, which is 7 years, and not 2026-2030 for ERP2, which is 5 years. Is the 1.1 Mt CO2e reduction for 7 years or for the 5 year ERP2 period?

    18. Another way that emissions from landfill will appear to be reduced by the new ERP2 proposals is by changing the assumptions to the interim baseline.  Appendix 1 of the technical annex shows that the ERP2 baseline assumptions for landfill gas were changed between the earlier 2023 baseline and the new interim baseline used in the ERP2 calculations.  

In the earlier baseline, municipal facilities without existing landfill gas capture facilities were modelled to have 20% gas capture efficiency starting in 2027, rising to 39% by 2028 and 59% by 2050.  In other words, it was assumed that small municipal landfills without existing gas capture facilities would gradually add them.  This is consistent with municipalities progressively looking to reduce their ETS liabilities due to fugitive landfill methane emissions.  It is also consistent with a recognition of steadily improving waste management, stated on page 89 of the consultation document:

“Since 2022, the WMF has supported infrastructure projects that divert organic materials from landfill, process organic waste or otherwise improve resource recovery, particularly for organics.
New Zealand’s domestic resource recovery systems are improving – in terms of infrastructure for our cities, districts and regions…”  

However, the interim baseline used for ERP2 assumes no additional landfill gas facilities will be added between now and 2050 and no additional emissions reductions will occur without the new proposals.  

The upshot of this is that all new landfill gas capture systems installed between now and 2050 will be assumed to be due to the government’s new policy proposal, rather than by municipalities naturally tightening down on their landfill gas emissions.  Again, no modelling results or parameters are presented to illustrate the effect of the changing baseline.

Alignment with future emissions reductions.

    19. It is disheartening to see that the long term projections of emissions presented in this plan show that we will exceed the ERP3 target, the 2050 methane target and 2050 net zero long-lived gases target.  It is clear that the government needs additional emissions reduction programs in order to fulfil its obligations to the CCRA.  The list of emissions reduction programs discontinued by the government fills more than a page in Appendix 3 of the consultation document.  The government needs to urgently develop and implement replacement initiatives if it is to meet the legislated requirements of the CCRA.

    20. We note in the technical annex document, Figure 19, that native afforestation is predicted to fall to nearly zero from 2025 onward.  This is an area where a little bit of government incentive could make a big impact on Maori communities owning marginal land, to the nation’s biodiversity and to the nation’s carbon removals needed for net zero emissions in 2050 and beyond.  We urge the government to put the nation’s long term biodiversity and emissions reduction targets in front of mind and incentivise native afforestation in some form.

Conclusions.

    21. CKM is convinced that in declaring climate change to be an economic issue the Minister is burying his head in the sand in order not to see the disastrous effects of climate change already upon us and not to hear any advice contrary to what his mind has already made up. This does not constitute an approach to climate change. Rather it constitutes wilful avoidance.

    22. As a community group concerned especially about what measures must be taken locally to mitigate and adapt to climate change, CKM regrets the total lack of clear leadership from central government. In 2015 and again in 2017, Local Government Mayors and Chairs, as part of LGNZ, called for central government leadership in climate change. In laying out 3 case studies of the process of local climate adaptation in August 2020, LGNZ highlighted the lack of clarity in leadership from the incumbent government in the matter of climate change. On 10 July this year the Public Health Communication Centre published a briefing by 4 leading academics on the “incoherence” of the present government’s climate change policy.
 
    23. In withdrawing funds and resources from governmental policies and departments protecting the environment and from non-governmental organisations and community groups working for the environment, this government is actively working against Nature and for the forces that are poisoning the planet and furthering climate change.

    24. In working primarily on a net admissions approach based on commodifying climate concerns in terms of money, without clearly reducing real-time carbon emissions, central governments have been, so-to-speak, bargaining with the Devil. Now, in the face of evident ongoing and, in several cases, irreversible effects of climate change, the present government is bargaining with extinction itself, a losing battle. Like it or not, we will not live forever! Let us just not take everything else with us!

    25. Whilst there is always room in every sector for emissions reductions, it is foolish to rely on technological fixes that generally require further injections of fossil-fuelled energy. Overall, the government must consider how to apply energy descent measures.

    26. Until the government (kawanatanga) actually support Māori and iwi (tino rangatiratanga) as per Te Tiriti o Waitangi, seeking "Māori and iwi-led action to reduce emissions" is a pretence. The majority of so-called Māori land, particularly in the form of compensation for loss, is the legacy of colonisation, leaving iwi and hapū with the least productive land, where pine planting has been seen as the most "economic use" of the land. Yet, even within such limits, funding for comprehensive pest control and the application of biodiversity credits could provide "an option for Māori economic survival in their homelands and for active kaitiakitanga." The lack of coherence in the present government’s policies perpetuates the worst outcomes of colonisation.

    27. Finally, we note that "Waste removal", in its widest sense, is not a sub-paragraph of carbon emissions limitation, it is the fundamental underlying problem of our general approach to climate change. Nature wastes nothing. "Waste not, want not" should underlie our approach to climate change. As yet, we are still throwing our slops out the window, regardless of where and on whom they land. – “Gardyloo!"

CKM - Submission to MDC Long Term Plan 2024 – 34.

In our submission we wish to focus on the “Long Term” aspect of the Plan.

INFRASTRUCTURE STRATEGY –

We know the Plan is for the next ten year period but we note that in the Infrastructure Strategy you project expenditure for the next 30 years (page 54). Rather than attempting to project expenditure for 3 decades, which we believe is an impossible and pointless task, we propose the following –

    • Focus resources into anticipating what we might expect in terms of environmental and climatic impacts and disruptions over the next three decades.

We believe this would be of much more value to our community that attempting to project infrastructure spending. We don’t need to remind you that there have been, and will no doubt continue to be, multiple warnings issued by bodies such as the UN, International Energy Agency, international and national environmental NGO’s, climate and environmental scientists etc regarding the major challenges and disruptions we will all have to face together in the decades ahead.

We note the following statement from the Stantec report done as a part of the Sounds Access Study.

4.2.3 Cause: Storm Frequency and Intensity Change

Scientists globally agree that climate change is increasing the frequency and intensity of extreme weather events, and that those impacts will continue to worsen in the future. The Ministry for the Environment’s summary of resent research into the impacts of climate change on severe weather in Aotearoa found45:

    • Floods will continue to become more frequent between now and 2050

    • Severe thunderstorms will carry more rain in a warming world

    • More intense regional cyclonic storms are projected by 2100, as is an increase in the frequency and extent of atmospheric rivers affecting Aotearoa New Zealand, which could bring more rain.

The effects of climate change are already being experienced in Marlborough. The Ministry for the Environment’s climate change projections for Marlborough are that infrastructure may face increased risk from increased storminess. Anecdotally the duration and frequency of storms affecting the region has been increasing. Data demonstrating that such events are increasing in intensity is more readily available. Figure 4-4 shows a comparison of the August rainfall at Tunakino and Rai Falls. It shows that the August 2022 rainfall was:

Tunakino (data from 1979 to 2022):

    • Two and a half times larger than the previous August maximum recorded in 2017

    • 36% greater than the previous monthly maximum recorded in October 1998

    • Five times larger than the historic August average


Rai at Rai Falls (data from 2000 to 2022):

    • Two times larger than the previous August maximum recorded in 2010

    • 53% greater than the previous monthly maximum recorded in December 2010

    • Four times larger than the historic August average

 “The science linking extreme weather and climate change,” Ministry for the Environment, last updated: 3 February 2023.

We believe the overwhelming factors impacting the future of Marlborough and our planet as a whole will be environmental and climatic and it appears that the weighting of these factors in the graphs in the LTP document (pg 54) have been excluded or at the least minimalised. Why would we project infrastructure expenditure for 3 decades with the apparent assumption that life will continue as usual and that disasters such as the 2021 and 2022 extreme rainfall events were somehow unusual. It seems to us heroic or maybe wishful thinking to be projecting spending in the 2030’s to be trending downwards from the relative highs of the next five years. Likewise projecting five yearly expenditures from 2029 – 2054 as being less than the next 5 year period fascinates us. Is no one listening to the warnings of what we are to expect in the decades ahead? All those warnings tell us to expect more extreme events and that the time of living in a relatively benign climate has now passed. We do not comprehend how anyone can make financial projections about the next 10 years, let alone 30 years, without at least acknowledging the impacts of further disruptive events. Presumably Council is expected or required to produce such financial projections as a part of the LTP exercise? From our perspective they are effectively meaningless. There are far too many unknowns in our future and we believe it is important to be honest with ourselves about the predicament we all face.

On a positive note we are encouraged to see recognition of the importance of maintaining flexibility wherever possible regarding management of our collective assets and we strongly support this approach. (pg 51)

“Our overall approach to asset management is to maintain flexibility wherever possible, enabling us to take action when circumstances change, as our knowledge improves and as technology develops.”

We believe this flexibility and an ability to adapt and change our priorities will be a critical factor in determining how well, we as a community, respond to the challenges ahead.

We also support the review of the Wairau Floodway Management Scheme and look forward to seeing the outcome of this review. (pg 52)

“Council will soon begin a review of the core Wairau River Floodway Management Scheme. The review will examine the current level of service, customer expectations and land use changes. It will also model flood flows under different conditions so that the range of effects that may result from climate change and sea level rise can be more accurately predicted and mitigated.”  

Over the last few years we have had various communications with Council and its staff regarding the ongoing decline in the Wairau aquifer. We encourage you to look seriously at any opportunities for giving more room to the river, as this will have the duel benefits of improving aquifer recharge and flood management.
 
CLIMATE ACTION PLAN –
 
We recognise the work being done by Council with it’s Climate Action Plan and note the Climate Change sub-committee formed after the last local body election finally met this January. There is one clause in that Plan which we wish to again focus your attention on, as we have done in the past.

Clause 4(c)(i) of the Climate Action Plan 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).”

    • We ask that all adequate funding required to continue implementing the Action Plan be allocated in the LTP, as stated in clause 4(c)(ii) of the Plan.

SUSTAINABILITY OFFICER –

    • We propose that Council allocate the necessary resources and appoint a Sustainability Officer.

Their remit should include reducing Council’s energy and water use, emissions and waste, plus investigating its supply chains to ensure the goods and services it uses are sourced in a sustainable way. Having a dedicated staff member with the responsibility of having an overview of all of Council activities, with a sustainability focus, could help avoid siloed thinking and foster cooperation between different people and departments.

THE PRECAUTIONARY APPROACH –

    • We urge councillors to always take the “precautionary approach” when making decisions. We believe it is very important that all planning and decision making associated with the current LTP process be done with a knowledge and an awareness of the likely impacts on our climate and environment in general.

We note the recent presentation given by NIWA scientists Paul White and Martin Crundwell at the Marlborough Research Centre and also separately to some people at MDC. Their research shows the existing coastline between Blenheim and Tuamarina about 7,000 years ago was roughly where SH1 now runs. Sea levels were about one metre higher than today at that time. With the certainty of continuing sea level rise over the coming decades we believe it would be prudent to at least start thinking about and planning for the impacts throughout Marlborough that will eventuate.

    • For example, do we need to put some resources into researching the timing and nature of impacts on the Blenheim sewerage plant and start thinking about what possible alternatives there might be for an alternative sewerage treatment system?

We strongly encourage Councillors and staff to keep themselves informed, as more research and evidence of the impacts of environmental degradation, global heating and biodiversity loss become available.

SUPPLEMENTARY INFORMATION.

We wish to include here the following information, hopefully to help raise awareness of the predicament we all face.

The increase in extreme climatic events and unprecedented atmospheric and ocean temperature increases over the last 12 months have been shocking, and even experts who have been working for years on the climate crisis did not expect the magnitude of changes. This trend is deeply concerning.
The diagram below is an attempt by an international team of scientists from the Stockholm Resilience Centre to provide a detailed outline of planetary resilience by mapping out all nine boundary processes that define a safe operating space for humanity. The green circle shows the safe operating space and the red shows that six of the nine planetary boundaries have now been crossed.

    • We are exceeding 6 out of the 9 planetary boundaries as defined by the Stockholm Resilience Centre. To quote from two of the authors of their 2023 update assessing planetary resilience.

“We don’t know how long we can keep transgressing these key boundaries before combined pressures lead to irreversible change and harm.”  Johan Rockström."

“Earth is a living planet, so the consequences are impossible to predict.”  Sarah Cornell.

See HERE AND HERE   for further info.

    • Global Heating is only a symptom of a much bigger dilemma facing humanity: that is our diseased relationship with Planet Earth. We wish to point out there is a big difference between a problem and a dilemma. Calling global heating a problem suggests there are solutions that can fix it. What are the consequences if we can’t fix it?

    • We must find ways to reduce our energy use. The concept of energy descent needs to be better understood. It is our excessive energy use that is the main reason we are exceeding planetary boundaries.

    • We can't simply replace fossil fuels with renewable energy and expect to carry on our current high energy lifestyles. Papatuanuku/Mother Nature cannot continue to provide us with all the resources we require to do that and cannot continue to absorb the levels of waste that arise from our activities.

    • Issues such as ocean heating and ocean acidification are not something that have just appeared in the last couple of decades. It has taken us many, many decades to reach this point and the inertia of this process is so large that it will take many, many decades to stop the heating and acidification and to help Nature to turn it around. With the oceans absorbing 93% of the excess heat caused by GHG emissions and 30% of the CO2 we have to plan and prepare for things to get worse before they get better. The marine heatwaves highlighted in the November report to Council last year were not rare, unexpected events but rather inevitable consequences of our way of living on planet Earth.

    • We are dealing with a long-term and ongoing predicament, not a series of problems for which all we have to do is find a series of more or less technological fixes.
We understand that Councils throughout the country are faced with the awkward situation of having to deal with the impacts of climate crises while still waiting for guidelines from central government regarding roles and responsibilities and resource allocations.
We note that LGNZ openly regrets the lack of leadership from central government and calls on them to take up the reins of leadership regarding climate change and adaptation to change. We think such calls are in vain. Internationally and nationally governments have shown themselves too much beholden financially and otherwise to industry lobbies and large companies, who depend on fossil fuel consumption (successive IPCC COP conferences have demonstrated that.) We believe leadership is going to come from grass roots, and that is what the Council and its committees should be fostering.

Our hope is that our Council adopts the requisite leadership with bravery. We believe it is important for Councillors and staff to keep abreast of the implications of the planetary limits, referred to earlier, being exceeded. In that regard we encourage MDC to take a long-term view of its activity, knowing that we all have to put our long-term hats on and work towards not only adaptation but still also mitigation.
We believe there is value in our collective view being well beyond the designated 10 years of this Plan because of the big challenges we have referred to in this submission. We don’t know how best to meet these challenges but we do consider it our responsibility to raise them with you at this time.
We would like to remind you of something Gregor Macara from NIWA stated in his presentation to Council in 2021. He said - “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 and plan ahead, for our grandchildren’s sake please!  

TIWAIWAKA.

Finally we would like to bring your attention to a very useful small publication called Tiwaiwaka, written by Rob McGowan. We believe this view of our world needs to be given much more priority if Papatuanuku is to be able to thrive and continue to support the myriad lifeforms that make up life on Planet Earth. The next LTP needs to reflect this thinking.

The critical matter we need to address especially in these challenging times is defined very well by Rob with the following statement and principles -

We have to begin by changing the order of priorities we work to. New Zealand’s greatest priority is not economic development but caring for the Earth.

By following the Principles of Tiwaiwaka set out below we have a way forwards that gives us hope for the future. Keeping the whenua well is always the first priority. That is what will ensure our long-term future, especially for the generations that follow us.

    1. Te Whenua, Papatūānuku, is the source of all life. She is the Mother. Ka ora te Whenua, ka ora te tangata.
Caring for the whenua is the first priority. Everything else must be measured against this.

    2. We are not the centre of the Universe but we are part of it.
All living creatures are our brothers and sisters, and we are the potiki, the last born. Papatūānuku is our mother. We must care for them.

    3. The mauri is the web of connections that sustains life.
If any of those connections is weakened or broken the mauri is less able to sustain life. The integrity of the mauri and its web of connections has greater priority than the rights and needs of any individual or species.

    4. Te tangata, people, are not the masters of the mauri; we are part of the mauri and embraced by it.
Our role is to care for the mauri. In doing so we are cared for by it. We find peace. We are at home.

    5. No individual person is more important than any other.
Each must contribute what they have to offer, and receive what they need to be well. We are most well when we are sustained by the mauri, the web of connections that makes us who we are.   

    6. We give special care to the tiniest living creatures.
Even though they are too small to be seen they are the foundation that keeps and sustains all life. Caring for them is caring for the mauri. This is the source of wellness, of sustainability.

Climate Karanga Marlborough

CKM presentation to LTP Hearings.

CKM chose to focus on the "Long Term" in our submission. This is because we believe it is critical for our community to come to terms with the consequences of climate breakdown and environmental degradation in the decades ahead, both at a local level and as they impact our global support systems.
We are a Marlborough activist environmental group of some 150 members, and we consider it one of our responsibilities consistently to remind Marlborough leaders and residents of the dangerous road ahead and the need for us to do whatever we can to prepare ourselves.
In this submission I will speak to the difficulties in fronting up to the reality of the major changes happening to our planet. Then, in the light of that, I will talk briefly to the main points of our written submission.
Adverse global and even national weather and environmental events can seem remote to those of us not directly affected. But they are insidious in the way they slowly but surely impact our lives and the multitudes of species that play their roles in maintaining and sustaining viable ecosystems. Day to day things can appear as if they are manageable as we deal with major disruptive events, such as the 2021 and 2022 floods. Those of us who can may often return to our day-to-day lives without necessarily facing up to the implications of what these events foreshadow. Those who have been directly impacted and those who accept that we are faced with a major crisis cannot ignore these implications.

We are encouraging our community to heed these warnings, to prepare to adapt to a new and less benign climate and world, and so to build resilience. These measures must go to the very top of our priority list. This Council has a critical role to play in the process. Major disruptions happening all over our planet are becoming so ubiquitous that we tend to become inured to them, but the mounting pressure on our life support systems is undeniable and inexorable. It is hard to anticipate the consequences of such pressure.

The heating and the acidification of our oceans are two of the best examples of the slow but steady collapse of our planetary ecosystems. Over the past half a century the oceans have absorbed more than 90% of the excess heat due to the green house gases (GHG) released into the atmosphere by human activities. This amount of heat is incredibly hard to visualise. It has been calculated to be equivalent currently to the heat of 5 atom bombs, each the size of the one that devastated Hiroshima, released every second of every minute of every day. This is not a linear process; it is compounding, as interest compounds. The rate of ocean heating has doubled since the 1960's and will continue to double for decades to come. There is nothing we can do to change this fact. We might be able to come up with ways of removing GHG from the atmosphere, though in our view this is wishful thinking, but there is no way we can remove the heat from the oceans, other than by cooling the planet. We maintain that that is an impossibility as long as we cling to our current ways of life and energy consumption. As long as we keep heating up the atmosphere, the oceans will keep absorbing most of that heat. The oceans may so far have been saving our lives from fast cooking, but if we carry on as we are, we are still cooking ourselves slowly.

In addition to the oceans heating up, the surface layer of the ocean absorbs between one third and one half of human-released carbon dioxide (CO2). CO2 dissolves in water as carbonic acid. Ocean acidity has increased about 25-30% from pre-industrial times up to the early 21st century, a pace faster than any known in Earth's geologic past. The acidity of the ocean is now greater than at any point in the past two million years. Ocean acidification affects the calcification of corals, shellfish and plankton, shortens the survival of fish and impacts the marine food chain. It also interacts with plastic pollution. What does this mean for aquaculture in Marlborough? Do we let future generations deal with the consequences, or do we face up to the reality of the predicament in front of us and start adapting now?
CKM regards these long-term changes as having amounted for some time to a crisis, both locally and globally, that we ignore not only at our own peril but at the peril of much of planetary life as we know it.

To quote Australian climate scientist Joelle Gergis - "How could we not understand that life as we know it is unravelling before our eyes? That we have unleashed intergenerational warming that will be with us for millenia?"

That said I will focus briefly on the recommendations of our written submission. All our recommendations are made with the long term in view.

1. In the first paragraph, we wrote: "We know the Plan is for the next ten year period but we note that in the Infrastructure Strategy you project expenditure for the next 30 years (page 54). Rather than attempting to project expenditure for 3 decades, which we believe is an impossible and pointless task, we propose the following – Focus resources into anticipating what we might expect in terms of environmental and climatic impacts and disruptions over the next three decades. We believe this would be of much more value to our community than attempting to project infrastructure spending."

In the face of a disrupted future, projecting expenditure seems to have little meaning. We challenge the thinking behind the graphs on page 54 of the Plan. We cannot comprehend the projections showing significant extra expenditure over the rest of this decade to address the infrastructure damage in the Sounds and elsewhere and then returning to relatively low expenditure by the mid 2030's. Also, in allocating little to no finance for renewing assets, the 5 yearly infrastructure projections from 2029 appear to assume no more existing assets are going to be damaged by extreme weather events like the ones we've had recently. Maybe it is not proper with such projections to show "hypotheticals", but we think the likelihood of similar events is inevitable over the coming decades. As we said in our submission, "There are far too many unknowns in our future and we believe it is important to be honest with ourselves about the predicament we all face." It would be honest to say to Marlborough ratepayers that the future has become a lot more unpredictable due to climate breakdown and environmental degradation, making it extremely difficult to make infrastructure expenditure projections with any accuracy. Rather, we must expect the unexpected and do all we can to prepare for more disruptions.

2. We applaud your approach to asset management (p 51) maintaining “flexibility wherever possible, enabling us to take action when circumstances change …”

3. We support the review of the Wairau Floodway Management Scheme and encourage you to look seriously at any opportunities for giving more room to the river.

4. We ask that all adequate funding required to continue implementing the Climate Action Plan be allocated in the Long Term Plan.

5. We recommend the appointment of a Sustainability Officer from Council staff to help avoid siloed thinking and foster interdepartmental cooperation.

6. We urge councillors always to take “the precautionary approach” in all planning and decision-making e.g. in considering the impacts of certain sea level rise in the coming decades.

7. We must find ways to reduce our energy use. Consider the concept of ‘Energy Descent’. It is our excessive energy use that is the main reason that we are exceeding planetary boundaries. (See ‘Supplementary Information’ in our written submission.)

8. Know that we are dealing with a long-term and ongoing predicament, not a series of problems for which all we need is a series of technological fixes.

9. We have to be smarter with our planning and decision making and be prepared, for our grandchildrens’ sake.

In conclusion: over the years that we have been making submissions, attending council meetings and dealing with council staff, we have built up a respect for the people with whom we have interacted. We recognise the challenges of attending to all the different demands from our communities and the exigencies of central government in coming to the best decisions for our region. We acknowledge, along with LGNZ, the lack at times of leadership and the frequently conflicting nature of leadership from central government.
CKM firmly believes that, if we have any useful answers to our global predicament, they will come out of local and community effort and imagination across the globe. Our plea is that, whilst you take care of the dollars and cents. you do your best to keep the big picture issues well in focus. We ask that you keep clear in your minds that without a healthy, vibrant and well functioning environment, all our projections for the future are meaningless.

CKM member Don Quick wrote a group submission to the Fast Track legislation which was sent to Minister Chris Bishop in February this year. There were 27,000 submissions with 2,900 requests to speak to the committee. The committee chose to hear from 1100 organisations and individuals who made unique submissions, of which one was CKM. Below is the text of the original letter and the subsequent presentation to the Select Committee.

LETTER TO MINISTER CHRIS BISHOP.

Sir,
We reply to your letter of 31/01/2024, addressed “Tena koe”. In particular, we address the process of your letter, which appears to us to lack  good faith. It appears to betray the intentions expressed in what you write. Your process amounts as much to an assault on our democracy,  that your Government claims in its coalition agreements to uphold, as the content of your letter amounts to an assault on our environment, to  which, as Minister Responsible for RMA Reform you are responsible. Using a Māori form of address is odd for a Minister in a Government whose policy is to use English as its primary form of communication. The use of this form in your letter thus suggests cultural  misappropriation, disrespect and a colonialist attitude.
“Tena koe” does not specify who you are addressing except as being an individual. If you were addressing ‘Dear Voter’, as would be appropriate in a democracy like ours, that would be fine and good. However, the form of address you use invalidates any response by a collective, such as ourselves, who would be addressed as ‘tēnā koutou’. You have not given notice of this letter in any truly public way; you have required feedback within a tight fortnight; and you have released the letter over a period of public distraction with Waitangi Day. With such limitations on participation, it is very hard to know how to make any contribution; hard to know in what way and to what extent any contribution will be “valued”.
With some difficulty, I sought your letter online and initially found not the letter itself but an apparently frank summation of its intent by Anderson Lloyd, environmentalconsultants, who suggest that the letter is addressed to “stakeholders”. In a general sense of course, everyone in
New Zealand’s democracy is a stakeholder in “New Zealand’s prosperity”, to quote your letter. In contrast, the content of your letter clearly indicates that your concern for our prosperity is in a business sense, prioritising “locally, regionally and nationally significant infrastructure and development projects”. The stakeholders in this context would be well defined as anyone with a ‘legitimate interest’ in the business at hand, i.e. with a primarily pecuniary interest recognised at law. As you say, this will be a “one- stop shop process”; a process by which vested interests principally will prosper.
The whole process of your letter indicates that your own interest in writing, rather than hoping for “our valuable contribution to policy development”, is to seek our endorsement of the fully-formed intentions that you openly express in the letter. You reveal little of how those intentions will affect either the voting public or the “environment” that supplies those resources which you intend to manage. This is a continuance of the kind of ‘trust-us-we-know-best’ process that has led many Māori people to distrust the intentions of successive colonialist governments, that have failed to live up to their promises.
We, Climate Karanga Marlborough, consider that what you, in your letter, say you are planning will constitute an assault on our natural world; that is, the environment which you mistakenly consider as an ongoing provider of resources with which business can continue to progress as usual. The fast-track regime, of which you do not specify particulars, will be under a standalone Act, by which ministers will be able pre-emptively to determine project referrals, priorities and decision-making. This is day-to-dayrule by dictate not by any form of participatory or contributory democracy. There are no apparent ‘checks and balances’ to fast-track authority other than an “Expert Panel” with limited powers and of uncertain make-up. If made up of political appointees, it will provide little to no check on the consenting power you propose, potentially leading to litigation and even a slowing of the consenting process.
You do not specify what you mean by the “adverse effects” of a project. The adverse effects with which we are concerned are the effects of industrial activity on the natural environment: pollution, climate warming, ocean heating and acidification, biodiversity loss and a neglect of caring for Papatūānuku and the wellbeing of all her children. - There is not even a mention of concern for the natural environment in your letter. - These all constitute an assault on our environment, which the content of your letter continues to promote.

Yours, Climate Karanga Marlborough.

TEXT OF VERBAL PRESENTATION TO SELECT COMMITTEE.

Whakataka te hau ki te uru,
Whakataka te hau ki te tonga.
Kia mākinakina ki uta,
Kia mātaratara ki tai.
E hī ake ana te atakura,
He tio, he huka, he hauhū.
Tīhei mauriora!

E mihi ana ki te Runga Rawa Nāna nei ngā mea katoa,
E mihi ana ki ngā mana whenua.
E te hunga mate, haere, haere, haere.
E te hunga ora kua hui mai nei tēnā koutou, x3.

Nō tauiwi ahau, nō Ngāti Pākehā, nō te tangata Tiriti.

Ko Don Quick taku ingoa.

I have been resident in Aotearoa New Zealand since 1979. I still consider myself to be  a manuhiri in this land, but I have 2 Kiwi children and I use greetings and a karakia in Māori not out of appropriation but out of love and respect for te reo Māori and tikanga Māori.
The karakia promises the dawning of a clear day after the storms have died down.
I submit today  on my own behalf and on behalf of Climate Karanga Marlborough, whose written submission you will hopefully have read. I won’t repeat it save to say that we recommend that you do not pass the Fast Track Bill through its first hearing, because we strenuously object to the hurried process and poor consultation in introducing the bill and to the process of the bill itself, as we consider both processes to be anti-democratic. We consider that the bill is not only out of touch with the desperate reality of the climate, environmental and planetary crisis that humanity is facing but also that it will, if passed, subsequently contribute significantly toward the ongoing crisis.
When I first came to New Zealand, I believed it to be a nation characterised by what I saw as values of democracy, fairness, egalitarianism, hospitality, pragmatism and trustworthiness set in a clean and green environment. It has taken me 45 years to realise how colonialist my first notions were and how much the realities of our nationhood lag well behind our aspirations.
As a nation, New Zealand has made 3 great promises: the first as a contract  between 2 peoples in Te Tiriti o Waitangi; second, in the course of two world wars as a consequence of that treaty; third, in the Paris Agreement on climate change in 2015. The second promise, as a commitment to colonial ‘sovereignty’, was kept in full, disproportionately by the Māori people, for whom the wars did not, as Tūhoe and other tribes justifiably maintained, constitute ‘their’ fight. The treaty promise remains to be properly  honoured on the Pākehā side. The third promise is currently being dishonoured: the Fast Track Bill, introduced by the present government is evidence of this. Such promises are part of our national integrity.
In the face of climate breakdown, even the threat of extinction, the integrity of our nation as a people is primarily at issue. In declaring the primary issue for voters in last year’s election as the “broken economy”, the National Party threw a dead cat on the table, distracting us all from the real issues of  climate breakdown and broken promises. The financial economy in NZ is no more broken than in any other capitalist-based and so-called  democratic economy in the world, but our political economy is marked by growing inequalities and inequities as a consequence of prioritising the dollar over the welfare of people and the land.
It is in the name of the ‘economy’ and “the delivery of infrastructure and development projects with significant regional or mational benefits” (undefined) that the Fast Track Bill is being rushed through by the government over a matter of weeks. In so doing, the government is turning its back on those long-standing values of fairness, equality, equity, integrity and a clean, green environment.
In contrast, the RMA, which the Fast-Track Bill seeks to circumvent, was the end-point of 6 years’ democratic debate and the work of 2 governments of different political leanings. It established uniquely an integrated and principled legislative framework with the express purpose of promoting the “sustainable management of natural and physical resources”. The Fast Track Bill barely mentions the natural environment.
I maintain that this government does not have the mandate it claims to turn its back so summarily on such legislation in favour of the dictates of 3 power-hungry ministers under the influence of money-hungry private industries and their lobbyists. This government’s actions constitute a continuing failure to adhere to the values and keep to the promises of TeTiriti o Waitangi.
I have just turned 78, have a terminal diagnosis and this will probably be my last chance to declare my allegiance to the values that can still make Aotearoa special. We will surely have to reevaluate the nature of our democracy, but I still believe in the dawning that my introductory karakia promises, despite the current government having turned its back to it.

E ai i ki te whakataukī, ka ora te whenua, ka ora te tangata.  
E ngā rangatira, tēnā koutou.

 Contribution to Marlborough Airport focus group interview from Budyong Hill representing local activist group Climate Karanga Marlborough (CKM).   20/10/2023

To quote from your information document - “In the context of this interview, we’ll refer to business/corporate sustainability that considers Environmental, Social and Cultural, and Economic drivers. One way of looking at it is as a three-legged stool with each leg representing a driver held together by governance, which is the seat. The interview is set up as an open conversation to address these drivers and explore what is going well, what requires improvement and what the future might hold.”

I believe that exercises like this can often be of little use if there is not a realistic and honest view of “what the future may hold”, so that is the area that I wish to focus on. I am a firm believer that without a viable, healthy and sustainable environment there is no future for the other two drivers. In fact I would go so far as to say the three legs of the stool have to be Environment, Environment and Environment.
Simply put without a healthy environment there is no economy. I also see little point in limiting our view to Marlborough or even to NZ, when it comes to discussing what the future may hold. In the modern world we are inextricably connected to the global environment and must make our assessments and decisions with this fact foremost in our minds.

Taking this into account I therefore wish to share some basic facts and information.

1) The dominant economic system in the developed world has, as a primary goal, the growth of GDP. Our economic system relies on this perpetual growth to continue functioning. To maintain a growth rate of 2 – 3% the throughput of materials and energy needs to double approximately every 25 years. (If your country's GDP grows at 3% a year, the economy doubles in 72/3 or 24 years. If your growth slips
to 2%, it will double in 36 years.) This is an exponential increase. It means doubling and then doubling the new amount every 25 years. Basic maths tells us this will end badly.

2) There are a range of ways of assessing what humanity’s impact on the biosphere is but there is general agreement that we are currently using about 1.8 times more than the planet can regenerate. This is known as overshoot which we have been in since the 1970’s. (More info) Again this can only end badly if we continue with our heads in the sand thinking we are so smart that our technology will solve these existential problems.

3) Scientists have identified 9 critical boundaries that our human civilisation needs to stay within if we wish to retain a liveable planet. At this point in time we have exceeded 6 of the 9 boundaries. Three of them cover what we take from the ecological system. They are loss of biodiversity (extinction of species), loss of fresh water (pumping too much water from rivers and aquifers) and land use (deforestation).
The remaining six boundaries concern the waste our activity adds, to what would have occurred naturally. They are: greenhouse gases which cause climate change; ocean acidification (carbon absorbed by the sea); emission of chemicals that deplete the Earth’s ozone layer; ‘‘novel entities’’ (synthetic chemicals such as plastics, DDT and concrete); aerosols; and nutrient overload (nitrogen and phosphorus from fertilisers that wash into rivers and the sea, causing algae blooms, killing fish and coral).
Crossing any of these boundaries doesn’t trigger immediate disaster. But it does mean we’ve moved from the safe zone into dangerous territory. And the nine boundaries are interrelated and interacting, in ways we don’t yet fully understand.
In 2009, the scientists found we’d already crossed three boundaries: biodiversity, climate change and nutrient overload.
By the 2015 update, a fourth boundary had been crossed: land use.
And by this year’s update, only three boundaries hadn’t been crossed: ocean acidification (but only just), aerosol pollution, and stratospheric ozone depletion – where an international agreement banning CFCs is slowly reducing the ozone hole we created.

4) If NZer’s want to reduce their consumption of resources and energy to a sustainable level we need to reduce our use to at least 50% of current levels. This is of course what we should do if we believe in fairly sharing the resources provided by Papatuanuku that we take for granted every day. Think energy, minerals, fresh water, food, a life supporting atmosphere, living oceans, topsoil, forests, etc etc. We are using far more than our fair share per capita. There are billions of people whose consumption needs to rise simply to meet their basic food, shelter, health etc requirements. We need to consume much less so their living standards can rise to a basic level.

5) Taking into account this basic information we would suggest it is wise to reassess our future direction and confront the realities of a post carbon society now. In the context of this exchange that means all airport companies and airlines will have to do everything they can to discourage people from flying. Tourism should not be encouraged because it has a high carbon impact. We need to reassess our priorities and only fly when absolutely necessary.

6) None of the required changes essential to our collective survival are likely to happen if our decisions continue to be driven by the profit motive.

7) We would like to highlight the current increase in litigation in your industry globally. “A wave of anti-“greenwashing” litigation is seeking to hold major players in the aviation industry to account for sensational claims of being sustainable, low-carbon or contributing to net zero. While the industry has faced legal backlash in the past, the dramatic proliferation of these cases may spell disaster for major airlines.”
Airlines are being hit by anti-greenwashing litigation – here’s what makes them perfect targets.

8) There are also a range of concerns we would like to add regarding the risks of future global warming and climate mitigation action to the air travel industry:

• Increasingly inclement and unpredictable weather will make air travel trickier. People will increasingly look for more reliable modes of travel.
• Air travel is destined to become more expensive due to the increased cost of SAF (sustainable aviation fuel – probably mostly from biofuel) relative to fossil fuels. International travel has gotten a “pass” so far, but this can’t last. A recent analysis suggested that SAF is about twice the
price of fossil kerosene.
• There will be growing political pressure not to devote farmland to growing crops for SAF. With much of the world already suffering from hunger, crop failures due to accelerating global warming will make this worse. Where there is a trade-off between feeding people and bringing in tourists, the tourist industry will lose.
• Even with SAF, nearly half the warming due to long to medium distance air travel is due to changes to the stratosphere, where these planes fly, and not from exhaust CO2. Water is rare in the stratosphere and aircraft contrails add a lot. And, water is an intense greenhouse gas. At the same time, stratospheric clouds tend to bottle more heat into the atmosphere than reflect incoming solar radiation back to space. Burning anything to keep airplanes flying in the stratosphere is essentially unsustainable in a warming world.

9) Bill McEwan is a CKM member who wrote to the Marlborough Airport company on more than one occasion in an attempt to highlight the issues we are again raising in our contribution to this focus group. Other than one brief acknowledgement to his first letter dated July 14th , 2021 he received no response to his correspondence. It may well be that MAL management deemed his correspondence represented an extreme view and that they therefore had no need to take it seriously? We think it would have been quite reasonable for MAL to show basic etiquette towards the concerns of a local ratepayer (and a representative of our local climate action group), by responding to his very pertinent questions.

Conclusion -

We realise that it is unlikely MAL will seriously address the matters Bill raised and that are included in this document. The economic imperative drives us all onwards towards disaster. It appears that facing the true reality of our predicament requires more than we can  collectively give. To be honest with ourselves is just too daunting. How much worse will things get before this mindset changes? Therefore
we don’t make this contribution wanting to denigrate MAL but rather to highlight the very difficult challenges facing all of humanity. The issues that MAL must confront are the same issues we all must confront. Together we have kicked the can down the road for too long now.
We believe the time for incremental changes to our existing economic system and trying to incentivise businesses to change their business models are well past. Is there some way we can greatly reduce our consumption so we can retain a viable biosphere and at the same time maintain a functioning economic and social structure? We don’t know the answer to this question. There are theories and ideas for alternative ways of organising our world that if executed may indeed help by prioritising our collective and planetary wellbeing over profit.

For instance a steady-state economy follows two key principles in order to stay in balance with the living world:
1) Never extract more than ecosystems can regenerate.
2) Never waste or pollute more than ecosystems can safely absorb.

What we are convinced of is the certainty that continuing business as usual will result in the ever increasing frequency and magnitude of disruptions to our lives and to the lives of every other species on our amazing planet.

We wish to finish with some quotes that we hope will stress the seriousness of what we all face.

Antonio Guterres -
“The era of global warming has ended. The era of global boiling has arrived.” This statement was made after July 2023 had become the hottest month in the past 120,000 years. He also said that “humanity has opened the gates of hell” by unleashing worsening heatwaves, floods
and wildfires seen around the world and that a “dangerous and unstable” future of 2.8C global heating, compared with the pre-industrial era, was awaiting without radical action. At the COP27 climate change summit in Sharm el-Sheikh, Egypt, he said “We are in the fight of our
lives, and we are losing. Greenhouse gas emissions keep growing, global temperatures keep rising, and our planet is fast approaching tipping points that will make climate chaos irreversible. We are on a highway to climate hell with our foot still on the accelerator.”

Pope Francis -
“The idea of infinite or unlimited growth, which proves so attractive to economists, financiers and experts in technology ... is based on the lie that there is an infinite supply of the earth’s goods, and this leads to the planet being squeezed dry at every limit.” AND
“Yet all is not lost. Human beings, while capable of the worst, are also capable of rising above themselves, choosing again what is good, and making a new start.”

You can read our submission below. The questions in bold are from the MDC consultation document. If you wish to see this document, which has good background information and a summary of the values and visions that came out of the first round of consultation then you can do so on their website.

NPS-FM 2020 COMMUNITY ENGAGEMENT - ROUND TWO.

Thank you for the opportunity to respond to the proposed values, visions and environmental outcomes as defined after the first round of consultation. As you can see in our earlier submission our focus is on the Wairau FMU, specifically on the health of the Wairau aquifer and how we best manage our efforts to maintain the health of the aquifer, particularly considering the observed ongoing, declining trend in the aquifer. Our original submission lays out our belief that "ecosystem health" must always be given the highest priority above the other three compulsory values in all freshwater management decisions throughout all the FMU's. We have a concern that the incoming government may wish to diminish the "Hierarchy of Obligations" laid out in the National Objectives Framework (NOF) and would be dismayed if this should happen. We ask the MDC to be alert to and to resist any such diminishment.

Do you agree with the proposed values?

Climate Karanga Marlborough (CKM) agree with the proposed values that have resulted from the first round of consultation. We give our support to these values on the understanding that “ecosystem health” always be given highest priority. We believe that any pressure exerted by
people who wish to interfere with values related to ecosystem health should be resisted.
We do wonder if something essential has been missed in defining the values. We absolutely support the importance of giving consideration to Wai Tapu. Yet beyond that we see an overarching value, which may be defined as the Mauri, the Life force, of the Wairau River and all its associated tributaries and aquifers. Vibrant ecosystem health is the means of knowing if that Mauri is healthy and intact. In our first submission we stated that “the goal of human freshwater management practice must be to respect te Mana o te Wai, to recognise water as having needs beyond just being a resource for human beings, and for us to work with Nature and processes natural to Aotearoa rather than against them.” Naturally we believe this value should apply equally to all FMU’s.  Water is Life – it’s as simple as that.

Do you agree with the proposed visions?

Overall, CKM support and agree with them and we would go further. The statement in your
document, “The health of the waterbodies and freshwater ecosystems are maintained, protected,
and enhanced for current and future generations” implies current and future generations of
humankind. From our perspective the maintenance, protection and enhancement must be done
primarily for the ecosystem itself, for Papatūānuku. Human beings are just one of the multitude of
current and future generations of living species that rely on “the waterbodies and freshwater
ecosystems” for their survival. We are inextricably connected with all the other species. We would
encourage removing any expression of a dominating human supremacist view that can tend to take
precedence in vision statements such as this. A recognition of our role as stewards would not go
amiss.

Do you think we are meeting these visions now?

In regard to the Wairau Aquifer we would have to say no. Our concerns are well laid out in our
earlier submission.
In the proposed vision you state - “The Wairau River and its tributaries, the Wairau Aquifer and
Wairau Plain Springs are protected and enhanced, continuing to be highly valued throughout
Marlborough for the wide range of benefits they bring to the region.” We fully support this vision,
but we note once more that there is no recognition of the specific issue of the declining trend in the
aquifer. The significant impact on the Mauri and health of the springs in particular, and aquifer ingeneral, should this trend continue, let alone the potential impact on users of the aquifer water
seems relevant to us. Thanks to the wisdom of the MDC in commissioning scientific research work
on the Wairau aquifer, we now have a good knowledge of what the main contributors to the
declining trend are, but still don’t know if the recharge of the aquifer can be improved enough to
reverse this trend. It seems possible to us after studying the Gravel Beds River research that the
historic confining of the river between its stop banks may be a factor that cannot be overcome just
with changed management methods and that the decline may continue despite all our best efforts.
This begs the question - to what degree can we allow nature and the river itself to take their course
in restoring the health of the aquifer? We are not clear how this knowledge can be best expressed
within the values, visions and environmental outcomes categories?

Do you agree with the proposed environmental outcomes?

We note in your document’s statement, “Healthy functioning ecological processes occur in
waterbodies and their margins, including primary production, nutrient cycling, trophic connectivity
as well as life cycle functions such as feeding, migration, reproduction”, that primary production
takes precedence. We accept that this list of “healthy functioning ecological processes” may not be
in any particular order of priority, but we find it telling that primary production comes first. From
our perspective “life cycle functions such as feeding, migration, reproduction” are of the highest
priority. Primary production must be subservient to these functions. In other words, if compromises
are required, then they should be made first by those wanting to engage in primary production not
the other way around. The statement of environmental outcomes should reflect this.

Conclusion.

There is a human tendency for making grand statements of intent, yet when the pressure builds for
utilisation of nature and its resources, too often human needs are prioritised above those of
Papatūānuku. So, CKM is encouraging vigilance at all times to ensure that ecosystem health always
comes top priority, even if that means we have to forgo previously assumed rights over freshwater
and access to freshwater. If we can do this, then all species reliant on these lifegiving waters, not
only humankind, will reap the rewards.

Responses to questions 
Section 1: Hydrogen is emerging as an important part of the future global energy system
1.  Are there other issues we should be considering in our assessment of the strategic landscape for hydrogen in New Zealand?

1. Safety: There is no mention of program support for the safe transport of hydrogen.  It is presumed that the network of hydrogen fuelling stations around the country will be serviced by tanker trucks carrying compressed hydrogen.  As with any form of road transport, there will be accidents and local fire & emergency personnel will be needed to respond to these accidents.  Compressed hydrogen presents serious safety risks to these personnel.  For example:

-  Hydrogen has no smell and when prepared for fuel cells, cannot be oderised.  Local firefighters will need special sensors to detect leaking hydrogen at an accident site. 
-  Hydrogen burns with a flame that is invisible in daylight.  Firefighters will need special equipment to detect burning hydrogen at an accident site.
-  Hydrogen has very low ignition energy and can spontaneously explode when decompressed.  Compressed hydrogen presents a serious explosion hazard to rescue personnel.

If hydrogen is to be transported around the country in tanker trucks, the skills and equipment of local emergency personnel nationwide will need to be upgraded.  This should also be part of the hydrogen roadmap.

2. Leakage: One of the unavoidable realities of hydrogen is that it leaks through most materials, including the carbon composite fuel tanks of fuel cell vehicles. .  The International Energy Agency estimates that with increasing hydrogen demand could lead to as much as 5.6% leakage by 2050.  Leakage from transportation applications (trucking & storage) is considerably larger than that from fixed industrial applications. while that for industrial processes is assumed to be around 0.5%.

3. Global Warming: While the main focus on leakage has been to prevent hydrogen from reaching explosive concentrations in air (above 3-4%), there has been little attention given, until recently, to low level leakage which will have a climate impact.  Recent studies have shown that hydrogen has a global warming potential of 11.6 times that of CO2 over 100 years (GWP100), but an estimated GWP of (~2.4 years).  It is not itself a greenhouse gas; its warming effect is due to its rapid reaction with atmospheric hydroxyl ions, which results in prolonging the life of the intense greenhouse gas methane and contributing to the production of the other greenhouse gases, such as tropospheric ozone and stratospheric water vapour. 

4. Water Demand: Simple chemistry suggests that it takes 9 kilograms of water to make 1 kilogram of hydrogen by electrolysis.  This will put additional pressure on freshwater resources.  Seawater can be used, but traditional methods of electrolysis produce toxic and corrosive chlorine ions (i.e., Cl- and ClO-) which should not be released to the environment.  Many electrolysis processes use water treated with alkali or acid, which would similarly need to be disposed of safely and kept out of the environment.  There is no mention in the assessment of the environmental risks presented by water demand and waste water disposal related to green hydrogen production.

Section 2: The role for hydrogen in New Zealand’s energy transition
2. Do you agree with our assessment of the most viable use cases of hydrogen in New Zealand’s energy transition?

The assessment given in the consultation document is highly favourable toward green hydrogen while missing or only briefly mentioning some of the many downsides to hydrogen as an energy fuel.  A more balanced assessment would include:

1. Efficiency: Green hydrogen used for combustion or fuel cell energy in transport is very inefficient compared to the direct use of electricity through batteries or overhead electrification, as with electric trains.  Battery electric vehicles are approximately 3 times more efficient in the use of electricity than fuel cells or internal combustion engines fuelled by hydrogen. 

New Zealand is depending upon an ample supply of renewable electricity to replace fossil fuels, yet renewable energy supply will only grow at a pace that the wholesale price of electricity allows.  In our current electricity market, increasing electricity prices are needed to promote growth in renewable generation.  With an expectation of a long-term increase in electricity prices, it makes no sense to invest in low efficiency uses of electrical energy. 

2. Impact on Electricity Prices: Electrical energy used to make green hydrogen will be energy not available to other consumers.  Although hydrogen consumers are expected to help with generation, they can also simply purchase electricity from third party generators.  It is wishful thinking that an over-build of intermittent renewable electricity will be sufficient to supply the power needed for the high capacity factor (80-90%) that electrolysers will require to be economic. 

Growth in hydrogen users, then, will create further demand for electricity.  The laws of supply and demand dictate that greater demand will result in increasing price, as more “marginally economic” renewable energy projects will be needed to fulfil added demand due to green hydrogen production.   In New Zealand’s deregulated electricity generation market, we would expect to see average electricity prices rise due to the added demand from hydrogen producers.  

This does not meet with the expectation of a “just transition”.  Residents and businesses in New Zealand should not have to pay more for their electricity due to the electricity demand created by a hydrogen fuel production industry.

3. Practicality: There are a number of hydrogen fuel uses proposed in the consultation document which show very marginal practicality.  Examples include:

a. Aircraft: compressed hydrogen, at the 350 bar pressure NZ standard, has the density of expanded polystyrene.  The space requirement for hydrogen fuel tanks on even medium range aircraft is impractical.  Liquefied hydrogen fuel is even more impractical because it takes roughly 40% of the energy embedded in the hydrogen fuel just to liquefy it.  In addition, even in the most well-insulated storage vessels, liquefied hydrogen loses about 1% of its mass each day due to boil-off. In NASA space rockets, typically 45% of liquefied hydrogen fuel is lost before launch.

b. Energy Storage: Storage of hydrogen for peak or back-up generating capacity is one of the least efficient forms of energy storage.  Battery storage returns more than 80% of stored energy.  Pumped hydro returns about 75% of stored energy.  Green hydrogen storage, in compressed gas tanks or underground, will return, at most, 30% of stored energy. when commenting on the early NZ Battery project option to store hydrogen for “dry year” back-up power.  The option for green hydrogen storage has since been dropped from the NZ Battery project list of options.
 
3. Do you support some of these uses more than others?

We support green hydrogen used in industrial processes and as feedstock for aviation and ship fuel, as there are few alternative technologies at this time and it is important, for strategic purposes, that New Zealand has its own source of aviation and ship fuel.  We do not support the use of green hydrogen as a direct fuel for heavy transport.  It is highly inefficient, hazardous to transport and store, and new research is showing that it is an intense indirect greenhouse gas.  Existing battery electric heavy transport vehicles are nearly equivalent in performance and are much more efficient, safer and will require much less support infrastructure (i.e., refuelling stations, electrolysers, storage tanks, etc.).  The greater infrastructure and equipment requirements of hydrogen transport fuel compared to that needed for battery electric vehicles will necessarily have greater embedded fossil fuel emissions and environmental impact.  The less kit we have to buy, the less impact on our environment and biodiversity.

4. What other factors should we be considering when assessing the right roles for hydrogen in New Zealand’s energy transition?

 Hydrogen, as a gas or liquefied, should not be used as a transportation fuel.  Due to its ability to leak through nearly all storage materials, its explosivity and its global warming potential, hydrogen is most appropriately used as feedstock for other fuels or chemicals, or used in industrial processes, such as steel making.  In these instances, it can be created and used at the same site, reducing leakage and allowing for tight safety controls.

As a transportation fuel it will need to be transported, stored and transferred between storage tanks, allowing for significant leakage and global warming effects, as well as exposing the general public and emergency personnel to its inherent risk of ignition and explosion.

5. Do you agree with this assessment of the potential for hydrogen supply and demand in New Zealand?

The assessments are far too optimistic for the following reasons:

1. Electricity prices have been steadily increasing since the inception of the electricity generation market and are unlikely to fall as demand increases and new generation is added.  The easy and cheap renewable generation projects have all been built and as demand increases the next generation projects will be the ones that are more expensive and more difficult to build, such as offshore wind.  In addition, new generation from wind and solar are intermittent and will need some type of energy storage in order to be reliable, which will add to their cost.  The assumption that electricity prices will fall due to an influx of cheap renewable power is highly unrealistic.

2. The assumption that electrolyser capital costs will drop to a fifth of their present level (from $1000/KW capacity to $200/KW) by 2050 is highly optimistic.  The price of most electrical equipment has been rising in recent years.

3. Considering the high capital cost of electrolysers, they will need to run at high capacity factor, as mentioned in the consultation document.  The need for high capacity factor is key to the economic success of industrial projects and is unlikely to fall as suggested in the consultation document.  It is unrealistic to think that electrolyser operators will readily agree to demand response services (i.e., shutting down when electricity demand on the national grid it high) without compensation.
 
4. Operations tied to new renewable (and therefore intermittent) generation will require a contract for back-up power, which will likely come from the national grid.   This would be expected to add to electricity demand and further increase electricity prices.

6. Do you agree with the key factors we have set out that are likely to determine how hydrogen deployment could play out?
 
The key factors put forward in the consultation document neglect to mention environmental and social factors. 
1. Due to the hazardous nature of compressed hydrogen, many communities will not want hydrogen production and storage in their neighbourhoods.
2. Due to the fresh water and waste water demands of electrolyser plants, many communities will not want the potential pollution and fresh water allocation.
3. Hydrogen being an indirect greenhouse gas, it is likely that leaked hydrogen will be added to the NZ Emissions Trading Scheme at some point.  This will add cost to hydrogen vendors which will be passed on to consumers.

 7. What do you think needs to happen to address these factors?

 While a reasonable case can be made for green hydrogen in the production of low emissions fuels and industrial process such as steel making, the use of green hydrogen as a transportation fuel will be expensive and problematic.  People will not want hydrogen production or storage facilities in their communities.  The odd accidental explosion of hydrogen fuel will further sour public perception of its safety, as we’ve seen overseas. 

Continued revelations as to the climate impact of leaked hydrogen can be expected to further damage its reputation and desirability among consumers.  Add to this the poor efficiency, expected high cost and impact of electricity prices that will accompany large scale green hydrogen production and distribution and we see no future for hydrogen as a transport fuel.

8.  Do you have any evidence to help us build a clearer picture?
 
Recent research has shown that hydrogen is an intense indirect greenhouse gas.  A peer reviewed journal article, by scientists Ilissa Ocko and Steven Hamburg (Climate Consequences of Hydrogen Emissions, Atmospheric Chemistry & Physics Vol 22, issue 14, 2022) lays out the science behind hydrogen’s climate impact.  A copy of this article is included with this submission.
To quote the article:
“Scientists have long known and cautioned that hydrogen has indirect warming impacts (Ehhalt et al., 2001; Derwent et al., 2001, 2006, 2020; Prather, 2003; Schultz et al., 2003; Warwick et al., 2004, 2022; Colella et al., 2005; Wuebbles et al., 2010; Derwent, 2018; Paulot et al., 2021; Field and Derwent, 2021). When it escapes into the atmosphere, hydrogen has two main fates: around 70 %–80 % is estimated to be removed by soils via diffusion and bacterial uptake, and the remaining 20 %–30 % is oxidized by reacting with the naturally occurring hydroxyl radical (OH), yielding an atmospheric lifetime of around a few years (Rahn et al., 2003; Derwent, 2018; Paulot et al., 2021; Warwick et al., 2022). The oxidation of hydrogen in the atmosphere leads to increasing concentrations of greenhouse gases in both the troposphere and stratosphere, as described in Fig. 1 (Derwent, 2018; Derwent et al., 2020; Paulot et al., 2021; Field and Derwent, 2021; Warwick et al., 2022).
In the troposphere, less OH is available to react with methane; given that methane’s reaction with OH is its primary sink, this leads to a longer atmospheric lifetime for methane which accounts for around half of hydrogen’s total indirect warming effect (Paulot et al., 2021). Moreover, the production of atomic hydrogen from hydrogen oxidation in the troposphere leads to a series of reactions that ultimately form tropospheric ozone, a greenhouse gas that accounts for about 20% of hydrogen’s radiative impacts (Paulot et al., 2021). In the stratosphere, the oxidation of hydrogen increases water vapor, which, in turn, increases the infrared radiative capacity of the stratosphere, leading to stratospheric cooling and an overall warming effect on the climate because energy emitted out to space is now from a cooler temperature; this stratospheric effect accounts for about 30% of hydrogen’s climate impacts (Paulot et al., 2021).
The key to preventing global warming due to hydrogen is preventing leaks and discharges.  Unfortunately, it is not presently possible to quantify the amount of hydrogen leaking through production, storage and transport systems due to the very low detection limits monitoring equipment will require.  Leakage from present systems is estimated in the above reference to be as high as 10%.  If liquid hydrogen becomes widely used, this rate of leakage could be higher due to venting of boil-off. 
The abstract to the article presents the conclusion that:
“green hydrogen applications with higher-end emission rates (10 %) may only cut climate impacts from fossil fuel technologies in half over the first 2 decades, which is far from the common perception that green hydrogen energy systems are climate neutral.”
The last three of five recommendations of the article are:
“3. improve quantification of hydrogen leakage rates by developing technologies that can be taken into the field to accurately measure hydrogen emissions at low detection thresholds (i.e., ppb level);
4. include the likelihood of hydrogen leakage and its impacts in decision-making about where and how to effectively deploy hydrogen – such as co-located production and end-use applications; and
5. identify leakage mitigation measures and best practices before building out infrastructure.”
Given the scientific findings on hydrogen’s global warming impact and the lack of information about hydrogen leakage rates from production, transportation and storage, the precautionary principle dictates that we should wait to deploy hydrogen as an energy fuel until the leakage is better understood.  We do not want to be in the position of simply trading one greenhouse gas emissions problem for another.

​9. Do you agree with our findings on the potential for hydrogen to contribute to New Zealand’s emissions reduction, energy security and resilience and economic outcomes?
 
No.  There is no mention of the likely impact of hydrogen production on electricity prices.  In New Zealand’s electricity market, the added electricity demand for hydrogen production will increase electricity prices, since it will require the construction of what would otherwise be marginally economic electrical power projects.  The cheaper projects will have already been built.  These new projects will demand an increase in price in order to be economic.  The law of supply and demand will dictate higher electricity prices for the added generation capacity.
An earlier statement in the consultation document that new renewable energy will be cheaper to install because cost for kit has been falling has not been borne out by experience.  Wholesale electricity prices have only been going up for the last two decades even as lots of new renewable generation has been installed.
Flexibility in demand response, touted as a benefit of green hydrogen production, will undoubtedly come at a price.  Operators will not agree to shut down electrolysers without getting something back for it – which is likely to be cheaper electricity.   This can be expected to further raise electricity prices for the rest of the economy.

10. Do you have any insights we should consider on what is needed to make hydrogen commercially viable?

At the moment, green hydrogen is not a commercially viable energy fuel.  We see little evidence that this situation will change in the near future. 

11.  Is there any further evidence you think we should be considering?
 
There is the very real possibility that the global warming impact due to the unavoidable leakage of hydrogen will make hydrogen unsuitable as a transportation fuel and will result in the failure of the hydrogen fuel industry.   New Zealand should wait to develop widespread hydrogen use until hydrogen leakage and its global warming impact are better understood.

Section 3: Government position and actions
12.  Do you agree with our policy objectives?

While the policy objectives mention a just transition, it is only for affected communities.  There needs to be consideration as to the impact that green hydrogen production will have on electricity prices around the country.  As explained in responses to questions above, the greater demand for electricity accompanying green hydrogen production will undoubtedly result in higher electricity prices. 

13. Do you agree with our positioning on hydrogen’s renewable electricity impacts and export sector?

We think it is wishful thinking that hydrogen production can be powered by intermittent renewable power.  With the needed capacity factor of 80-90% (stated in the consultation document), electrolysers will need baseload power, from hydro or geothermal.  The suggestion that there might be an over-build of renewable generation accompanying hydrogen production, appears to be a “red herring” to mask the impact hydrogen production will have on electricity demand and electricity prices.

Considering the environmental compromises that will need to be made in order to build the energy sources needed for hydrogen production, we do not support developing an export market for green hydrogen.  We should not compromise our environment for the benefit of another export industry.
14. Do you agree with the proposed actions and considerations we have made under each focus area?

Support for price and long-term certainty to allow hydrogen to scale for key use cases: We do not support the $100m price subsidy for green hydrogen.  This subsidy seems tailored to the use of hydrogen as transport fuel, which we do not support. 

Support for capital investment for hydrogen projects: We do not support Clean Heavy Vehicle Grant money used to buy hydrogen fuel cell vehicles.  There is too much uncertainty as to the amount of hydrogen that might be leaked in its application as transport fuel and the global warming impact this would have.  We urge the government to wait until leakage can be quantified and the resulting global warming understood before supporting hydrogen as transport fuel.

Planning System: We do not support the use of an industry body (the New Zealand Hydrogen Council) producing training material on hydrogen aimed at consenting authorities.  Industry bodies should not be telling consenting authorities what to think about hydrogen. This is a clear case of “the fox guarding the hen house”!  Advice to consenting authorities needs to be free of conflict of interest and industry messaging.  An academic panel would be more appropriate for this task.

15. Is there any evidence we should be considering to better target actions in the final Hydrogen Roadmap?

There needs to be consideration of the global warming impact of leaked hydrogen. This has gone un-mentioned in the Interim Hydrogen Roadmap consultation document.  Information about the global warming impact of hydrogen gas in our atmosphere has been available for nearly a decade now, so it is surprising that this was overlooked in this consultation. 
Of critical importance here is the quantification of hydrogen gas leakage from production, storage and use facilities, since this is largely unknown and could have a significant global warming impact. 

General comments

We have been disappointed in the one-sided, industry-friendly tone of the consultation document.  While we recognise that the government is keen to decarbonise New Zealand industry and transport, it is important that we make informed and balanced judgements about how we do this.  The consultation document has consistently downplayed or omitted many negative aspects of green hydrogen production and use, and repeatedly stressed impractical benefits, such as an over-build of renewable power.  Another example of this bias is the suggestion that an industry council provide guidance to consenting authorities.  This sort of unbalanced, industry-focussed viewpoint could lead us into supporting a set of “white elephant” projects, wasting valuable time and resources as we attempt to stem off the climate crisis we are in.
 
 
 
 

Introduction
Climate Karanga Marlborough is a citizen’s organisation of about 130 members with the purpose of educating the public and our decision-makers as to the dangers of climate breakdown, and to support local and national decision-makers to take action.

Concerns
We have serious concerns with this program and request a change in direction.  We support a subsidy for green hydrogen used in industrial processes and aviation & ship fuel but we do not support the use of green hydrogen for heavy transport.  Our reasons are below:

1. The program appears to be tailored just to the use of hydrogen in heavy transport.  Companies with stationary uses for hydrogen, such as in steel and chemical manufacturing, would likely prefer to produce their own green hydrogen on-site rather than purchase it from a supplier, the condition whereby the subsidy would apply.  On-site generation of hydrogen would have the benefit of being closely coordinated with other industrial processes and would require only limited storage.  On the other hand, purchases of hydrogen from a supplier would like require road transport and significant on-site storage, with commensurate insecurity of supply. 
   
   For these companies, a cost-shared subsidy for the purchase of electrolysers and associated equipment, such as through the GIDI fund, would make more sense.  Still, we do not oppose a subsidy for green hydrogen for industrial application.
   
   
2. Electrical energy used to make green hydrogen will be energy not available to other consumers.  Although hydrogen consumers are expected to help with generation, they can also just contract electricity from 3rd party generators.  A subsidy for hydrogen users, then, will help hydrogen producers pay for their electricity, in essence subsidising what they pay for electricity.  In the open market for electricity, we would expect average electricity prices to rise due to the added demand from hydrogen producers.  
   
   This does not meet with the expectation of a “just transition”.  Residents and businesses in New Zealand should not have to pay more for their electricity due to the added electricity demand created by subsidised hydrogen fuel.
   
   
3. A green hydrogen rebate unfairly disadvantages other green energy technologies in transport.  For example, battery powered trucks are an alternative to hydrogen-powered but will receive no similar price support. This will distort the market for the uptake of low emissions trucks.  Similarly, the market for sustainable aviation fuel (SAF) and sustainable shipping fuel will be similarly distorted to favour fuels made with green hydrogen as opposed to other, potentially cheaper and more efficient fuels.  We appreciate, however, that there are few options for producing SAF and ship fuel at this time and hydrogen will likely be an important component in the manufacture of both, so we are not opposed to a subsidy for SAF and ship fuel containing green hydrogen.
   
   
4. Heavy transport is not a “hard to decarbonise” enterprise.  Battery EV trucks with similar performance to hydrogen fuel cell trucks are already available.  A comparison of the recently imported Hyundai XCIENT fuel cell trucks to the Volvo Electric VNR series trucks shows similar gross vehicle weight and range.  The major difference is in refuelling time; the Hyundai can be refilled in 8 to 20 minutes, the Volvo takes 60 minutes to recharge to 80% state of charge.  This is hardly enough difference to require a subsidy for hydrogen fuel.  And besides, truck drivers would likely benefit from an hour’s rest after driving 400 km.
   
   It is also important to consider the charging infrastructure needed for both types of vehicles.  The battery electric vehicle needs only a power line and transformer.  The hydrogen vehicle will require hydrogen storage tanks and either regular visits by hydrogen fuel trucks or an on-site electrolyser. 
   
   Considering the fact that hydrogen storage tanks have been known to explode, hydrogen filling stations will likely need to be sited well away from homes and communities, in areas where there are few other services.
   
   
5. Green hydrogen used for combustion or fuel cell energy in transport is very inefficient compared to the direct use of electricity through batteries or overhead electrification, as with electric trains.  Battery electric vehicles are approximately 3 times more efficient in the use of electricity than fuel cells or internal combustion engines fuelled by green hydrogen. 
   
   New Zealand is depending upon an ample supply of renewable electricity to replace fossil fuels, yet renewable energy supply will only grow at a pace that the wholesale price of electricity allows.  In our current electricity market, increasing electricity prices will be needed to promote growth in renewable generation.  With an expectation of a long-term increase in electricity prices, it makes no sense to invest in low efficiency uses of that energy.  A ten-year subsidy for green hydrogen as a transport fuel will lock in this inefficient use of our renewable electricity.
   
   
6. There is no mention of program support for the safe transport of hydrogen.  It is presumed that the network of hydrogen fuelling stations around the country will be serviced by local electrolysers or by tanker trucks carrying compressed hydrogen.  As with any form of road transport, there will be accidents and local fire & emergency personnel will be needed to respond to these accidents.  Compressed hydrogen presents serious safety risks to these personnel.  For example:
   
   -  Hydrogen has no smell and when prepared for fuel cells, cannot be perfumed.  Local firefighters will need special sensors to detect leaking hydrogen at an accident site. 
   -  Hydrogen burns with a flame that is invisible in daylight.  Firefighters will need special equipment to detect burning hydrogen at an accident site.
   -  Hydrogen has very low ignition energy and can spontaneously explode when decompressed.  Compressed hydrogen presents a serious explosion hazard to rescue personnel.
   
   If hydrogen is to be transported around the country in tanker trucks, the skills and equipment of local emergency personnel nationwide will need to be upgraded.  This should also be part of this transition program.
   
   
7. When considered alongside national support for other low emissions technologies, hydrogen for heavy transport appears to be getting “corporate welfare” through this subsidy program.  In industries which are truly hard to decarbonise, such as steel & fertiliser production and aviation and ship fuels, it makes sense to subsidise green hydrogen in order to reduce the nation’s greenhouse gas emissions.  It is also important, from a strategic viewpoint, that New Zealand have a domestic source of aviation and ship fuel. 
   
   The inclusion of heavy transport in the subsidy program appears to benefit only a few companies, which are easily named.
   
   
8. Finally, one of the unavoidable realities of hydrogen is that it leaks through most materials, including the carbon composite fuel tanks of fuel cell vehicles.  It is estimated that 2.7% of hydrogen produced leaked to the atmosphere in 2020.  The International Energy Agency estimates that with increasing hydrogen demand could lead to as much as 5.6% leakage by 2050.  Leakage from transportation applications (trucking & storage) is considerably larger than that from fixed industrial applications.  Transportation leakage has been calculated to be 2.3% while that for industrial processes is assumed to be around 0.5%.
   
   While the main focus on leakage has been to prevent hydrogen from reaching explosive concentrations in air (above 4%), there has been little attention given, until recently, to its climate impact.  Recent studies have shown that hydrogen has a global warming potential of 11.6 times that of CO2 over 100 years (GWP100), but an estimated GWP of over 100 times that of CO2 over ten years due to its short lifetime (~2.4 years).  It is not itself a greenhouse gas; its warming effect is due to its rapid reaction with atmospheric hydroxyl ions, which results in prolonging the life of other greenhouse gases, such as methane, tropospheric ozone and stratospheric water vapour. 
   
   Do we solve the global warming crisis by subsidising the production and widespread use of another gas which is leaky and causes intense warming?
   
   

Considering its low efficiency, ready alternatives, lack of infrastructure, explosivity, limited commercial benefit and climate impact of leakage, green hydrogen for transport should not be given preferential price support.  

Introduction
Climate Karanga Marlborough is a citizen’s organisation of about 120 members with the purpose of educating the public and our decision-makers as to the dangers of climate breakdown, and to support local and national decision-makers to take action.
We submitted on the earlier permanent forestry consultation and were disappointed that now MfE is asking for a second submission.  We appreciate the complexities, but also recognise that the Climate Change Commission has put forward recommendations similar to what we've presented here. 

We urge the government and MfE to work with the Commission and endeavour to follow their recommendations.  They are the experts charged to advise the government on these matters.  The government should use them.

Question 1: How do you think the Inquiry’s recommendations could be reflected in proposals to redesign the permanent forest category?
The inquiry examines a quite pertinent and recent failure in forestry management, so its recommendations are relevant.  We agree with many of the Inquiry’s recommendations, in particular Recommendation 36 (which refers to Paragraph 54 and second bullet point): “incentivising indigenous and slower-growing exotics (such as through front-loading the earning of credits – effectively a loan, and not a fake credit).”

Question 2: Do you agree with our assessment criteria for the redesigned permanent forest category? If not, what would you change and why?
There is no mention of wildfire risk, which is a major problem in forests overseas.  Many exotic tree species have adapted to wildfire and depend upon wildfire for regeneration.  As such, many of these species will burn more readily than tree species not adapted to fire. 
Wildfire not only risks returning sequestered carbon to the atmosphere, potentially negating whole carbon farming enterprises, it also risks local ecological devastation and damage to nearby infrastructure and communities and the lives of firefighting personnel.
An additional criteria should be: Permanent forests should be designed to minimise risks of wildfire, disease, climate disruption and wilding. 
On an additional note, the assessment criteria in Item 2 is not clear.  How do permanent forests improve climate adaptation and resilience other than by stabilising erosion prone land (mentioned page 19), which is an environmental outcome and mentioned already in Item 3?  Why is Item 2 criteria included?

Question 3: Do you think any of these criteria are more important than the others? If so, which criteria and why?
Of primary concern should be the risks from climate change, disease and wilding.  Forest inability to withstand drought, disease and wildfire have resulted in the devastation of large tracts of forest overseas.  As the climate warms, we can expect the same situation here.  There is also the risk of disease, which is particularly high in monoculture exotic forests.  Disease pathogens are projected to spread more readily as the planet warms.  Finally, there is the risk of wilding, which can upset and degrade nearby pasture, grasslands and regenerating forests.  It does little for carbon sequestration, environmental co-benefits, Maori aspirations and local communities if forest die, succumb to wildfire or spread unwanted weed species.  The long term risks to forests should be the primary concern and permanent forest design criteria.  Remember, right tree, right place.

Of secondary concern are the environmental benefits in terms of water quality, erosion control, habitat for indigenous biodiversity, etc.  We need forests that both survive long term and provide ecosystem services to wildlife and communities.  The lack of erosion control afforded by recently harvested production forests in Tairawhiti was a major factor in the damage due to Cyclone Gabrielle (Item 3).
The tertiary concern with respect to the nation’s net zero emissions target for 2050 and beyond, is the ability of permanent forests to sequester emissions long-term (Item 1).  Contrary to what is stated in the consultation document (page 15), and as the Climate Change Commission has pointed out, some permanent exotic forests (particularly pine forests) will provide carbon offsets in the short term, through 2050, but will reach senescence and stop sequestering more carbon after about 60 years, therefore providing few offsets in the decades after 2050, when New Zealand is expected to remain “net zero”.  This is the reason the Climate Commission recommends significant indigenous afforestation.  This criteria is listed as tertiary because many different combinations of exotic and indigenous forests will sequester carbon long term, but not all will survive to do so.  In addition, the country’s international commitments are simply words on paper; real life concerns for a healthy environment are more important than these words.
Support for Maori aspirations and rural communities can be designed by economic levers put into whatever policy is decided. 

Question 4: Of these options, what is your preferred approach? Why? Are there other options you prefer, that we haven’t considered? (Note, options 1.2a and 1.2b are not mutually exclusive)
This is a difficult “either/or”.  We support either Option 1.1 or Option 1.2 depending upon assurances that the end goal is stable mature forests which sequester carbon and provide a habitat for wildlife and other ecosystem services. 
While we feel that indigenous forests are preferable in most circumstances, there may be forest types and locations where exotic forests or mixed forests provide better long-term stability, wildfire and disease resistance and ecosystem services.  The New Zealand climate is changing and our indigenous forests may not cope well with a changing climate in all areas.  In these cases, exotic forests may be better adapted to the conditions.

At the same time, we remain sceptical that transition forests will be successful in establishing permanent indigenous forests in all settings, particularly when first established with radiata pine.  Pine is prone to wildfire and wilding.  Its only advantage is quick sequestration rate.  Transition forestry models based upon pine need to be carefully managed and should come with added precautionary measures against wildfire and wilding to nearby properties.

We support both Options 1.2a and 1.2b.  We believe that, since Maori are to retain title to their land for perpetuity, they will be less prone to make short sighted forestry choices.

We do not agree with Option 1.2c, an exception for small scale exotic forests planted on farms.  This, we feel, will be driven mostly by short-term economic incentives and thus be prone to short-sighted forestry choices and mismanagement.  Who is to stop a farm business from claiming bankruptcy and leaving a mismanaged or unmanaged, decaying and fire-prone pine forest for the rest of us to deal with?
 
Question 5: If you support allowing exotic species under limited circumstances, how do you think your preferred ‘limited circumstance’ should be defined? (for example, if you support allowing long-lived exotics to register, how do you think we should define ‘long-lived’?)
We feel that exotic permanent forests should meet the following criteria:

1. Deemed as fire and disease-resistant as the average of local indigenous species.  In other words, exotic forest should not add to the fire risk of local forests and should not be known to be vulnerable to diseases which might be present or introduced.
2. Should not be a source of wilding, especially where those wildings modify important natural habitats or result in economic costs for adjacent landholders.
3. Deemed as long lived as the average of local indigenous forest, or longer. 
4. If to be select cut harvested at some point, only in areas with suitable soil stability so as not to increase erosion and stream sediment problems.
5. Should provide a habitat for local wildlife that is no less acceptable than indigenous forest.
   
   

Question 6: Do you think there is an opportunity to use permanent forests to stabilise erosion-prone land?
Yes, very definitely so.  The Inquiry has concluded that the effects of Cyclone Gabrielle would not have been so severe had much of the inland forest been permanent and not recently cleared for production forestry.  

Question 7: Do you think the Government should consider restricting the permanent forest category to exotic species with a low wilding risk?
Yes, wilding risk needs to be taken into account in allowing exotic permanent forestry.  We already spend large amounts in areas like the Marlborough Sounds to eliminate wilding pines.  We should not be making the problem worse by allowing wilding tree species in permanent forests.

Question 8: Do you agree with the proposal for a specific carbon accounting method for transition forests? If you disagree could you please provide the reasons why? If there are other options you think we should consider please list them.
We agree with the proposed new carbon accounting approach for transition forests.  We see potential for abuse of the status quo stock accounting method when significant surrender obligations come due.  Without a bond put down to cover that obligation, some forestry owners will attempt to skip out on the transition phase by declaring bankruptcy or avoiding liability through shell corporations.   And no forestry owner will be in the position to guarantee a bond that would cover this obligation beforehand.  The proposed “averaging” method avoids this problem.

Question 9: If you agree with the proposal for a specific carbon accounting method for transition forests, what do you think it needs to achieve?
We agree with the need for some type of “averaging” credit accounting for transition forests.
We feel that it is also important that allocated credits should be spread out over the life of the forests, up to the climax carbon storage of the resulting indigenous forest, so as to provide transition foresters a steady stream of income needed for continued forest management.  It is critical that foresters have the cash on hand to remove old growth exotic trees during the transition phase 30 to 50 years down the track.
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Question 10: What do you think should occur if a forest does not transition from a predominately exotic to indigenous forest within 50 years?
Although there are a number of options available to deal with transition failure, we provisionally would agree with an imposed management plan, at the forester’s expense, to try to address the lack of transition.  This would include the option to allow conversion to production forestry, if local soil and erosion characteristics allow.  This would, hopefully, create the conditions that would induce the forester to carefully monitor and insure progress toward the indigenous forest goal.

Introduction:

Climate Karanga Marlborough is a citizen’s organisation of about 120 members with the purpose of educating the public and our decision-makers as to the dangers of climate breakdown, and to support local and national decision-makers to take action.
We are alarmed at the current state of the NZ ETS market with respect to forestry credits.  This is clearly the result of the Minister and Cabinet not following the Climate Change Commission’s years old advice.  We are somewhat gratified to see this consultation, but it is long overdue. 

The Climate Change Commission was formed to provide expert advice to government.  We support the Commission's independence and its recommendations.  The government needs to urgently follow the Commission's advice.

2.1      Do you agree with the assessment of reductions and removals that the NZ ETS is expected to drive in the short, medium and long term?
Yes, it is also clear from the Climate Commission’s analysis that forestry is on track to exceed NZU demand in the long term, likely depressing NZU prices and slowing decarbonisation in the rest of the society.

2.2      Do you have any evidence you can share about gross emitter behaviour (sector specific, if possible) in response to NZU prices?
The evidence is clear.  With the falling of the NZU price this year, the portion of petrol costs due to the ETS has fallen.  By the laws of supply and demand, this has created an incentive to use more fuel – contrary to the intention of the ETS.

2.3      Do you have any evidence you can share about land owner and forest investment behaviour in response to NZU prices?
My family has applied for carbon credits for our regenerating pasture land.  These haven’t been awarded yet and may not ever be due to the backlog at MBI.  We have decided, however, to reforest the land anyway.  Regardless of possible earnings from the ETS, this is the right thing to do.

2.4      Do you agree with the summary of the impacts of exotic afforestation? Why/why not?
We find the following exceptions to this summary:

1. Well managed exotic forestry will not necessarily stabilise erosion prone land.  The wide spread practice of clear cutting of production pine generally leads to de-stabilisation of erosion-prone land until the forest is regrown. 
2. Even permanent exotic forests, planted in pine, will undergo senescence and the dead and dying forest will, with time, lose the erosion resistance gained from the living trees. Permanent exotic forests need to be transitioned to indigenous forests, wherever possible, and this will require additional investment and active management.  It isn’t even clear that this can be successfully on a large scale.
   
   

3.1      Do you agree with the case for driving gross emissions reductions through the NZ ETS? Why/why not? In your answer, please provide information on the costs of emissions reductions.
The ETS does have a role to play in driving down gross emissions, especially where fossil fuel cost, rather than the cost of investment in a low emissions alternative, is the major behaviour driver.  It needs to be complemented by other policies and incentives, as stated in the discussion document.

3.2      Do you agree with our assessment of the cost impacts of a higher emissions price? Why/why not?
Yes.  Higher emissions prices will drive inflation, but this is what it is meant to do – to make emitting activities more expensive.  Any tax system on emissions would do this.  Policies to shield people of lower income from price increases need to be implemented to facilitate a ‘just transition’.

3.3      How important do you think it is that we maintain incentives for removals? Why?
It is important to maintain incentives for removals, but these removals should be controlled to meet the long term and short term emissions targets.  As of now, there is no control other than the ETS market. It is also important that the country increase forestry, particularly indigenous forestry, for the benefit of long term carbon sequestration, as well as biodiversity, erosion control and water quality.

4.1      Do you agree with the description of the different interests Māori have in the NZ ETS review? Why/why not?
Yes

4.2      What other interests do you think are important? What has been missed?

4.3      How should these interests be balanced against one another or prioritised, or both?

4.4      What opportunities for Māori do you see in the NZ ETS review? If any, how could these be realised?
Prioritising and possibly subsidising indigenous forests for carbon removal will provide the best outcome for Maori land owners interested in carbon forestry.  The only attraction of exotic permanent forest is the enhanced income.  This incentive should be shifted to prioritise indigenous forest.

5.1      Do you agree with the Government’s primary objective for the NZ ETS review to consider whether to prioritise gross emissions reductions in the NZ ETS, while maintaining support for removals? Why/why not?
Yes.  The current ETS structure does not prioritise reduction in gross emissions.  As the Climate Change Commission has pointed out, this needs to change.  There is still need for forestry removals, however, in making national and NDC targets.

5.2      Do you agree that the NZ ETS should support more gross emissions reductions by incentivising the uptake of low-emissions technology, energy efficiency measures, and other abatement opportunities as quickly as real-world supply constraints allow? Why/why not?
Yes.  Gross emissions reductions are permanent.  Removals by forestry are not permanent.  Forests can burn down or die from disease or drought. In either case, the carbon stored in the forest will be returned to the atmosphere.  Emissions reductions due to a shift away from burning fossil fuel and other GHG emitting practices are permanent.

5.3      Do you agree that the NZ ETS should drive levels of emissions removals that are sufficient to help meet Aotearoa New Zealand’s climate change goals in the short to medium term and provide a sink for hard-to-abate emissions in the longer term? Why/why not?
No, we feel that emissions removals need to be managed and not left up to a market mechanism like the ETS.  They need to be decoupled from the ETS and managed in a way that balances the effects of afforestation with net zero and NDC goals.

5.4      Do you agree with the primary assessment criteria and key considerations used to assess options in this consultation? Are there any you consider more important and why? Please provide any evidence you have.
Yes.

5.5      Are there any additional criteria or considerations that should be taken into account?

6.1      Which option do you believe aligns the best with the primary objectives to prioritise gross emissions reductions while maintaining support for removals outlined in chapter 5?
Option 4: Separate incentives for gross emissions reductions and emissions removals. 
Option 1 could possibly incentivise gross emissions reductions in the short term, but not in the medium term.  No matter how the present system is tweaked, it will result in an oversupply of forestry NZUs in the medium term, as the Climate Change Commission has pointed out.  This option also goes against the established ERP system of emissions budgets that has been established by the Zero Carbon Act.  The Climate Change Commission already carefully considers the balance between emissions reductions, economic impacts and emissions targets in proposing emissions budgets.  Since they are the experts in this topic, the job should be left to them and not tweaked by government ministries, as suggested by this option.  We, therefore, do not support Option 1.
Option 2 would allow purchase of NZUs in the voluntary market here and abroad, which could have perverse consequences.  If the demand for NZUs unexpectedly increases or decreases, it could promote uncontrolled carbon forestry, beyond the stated purpose of “right tree, right place”, or a collapse in NZU price, neither of which is desirable.  Markets are unpredictable, making this option risky.  We, therefore, DO NOT support Option 2.
Option 3 still relies on market mechanisms to control gross emissions and removals.  Markets are unpredictable, however and, as we have seen in the NZ ETS market, prone to unexpected swings in price.  We should not plan “right tree, right place” on an unpredictable process.  We, therefore, DO NOT support Option 3.

6.2      Do you agree with how the options have been assessed with respect to the key considerations outlined in chapter 5? Why/why not? Please provide any evidence you have.
Yes.

6.3      Of the four options proposed, which one do you prefer? Why?
Option 4.  The inclusion of forestry removals in the ETS has been a problem since the beginning because the incentives and timing of emissions reductions and forestry removals are not aligned.  In addition, forestry removals aren’t equivalent to gross emissions reductions.  Forestry removals aren’t permanent because forests can burn down and die of disease or drought, returning their stored carbon to the atmosphere. The two processes – the ETS and forestry removals – need to be managed as separate processes.

6.4      Are there any additional options that you believe the review should consider? Why?

6.5      Based on your preferred option(s), what other policies do you believe are required to manage any impacts of the proposal?
As mentioned, it will be important to prioritise indigenous forests due to their relative fire resistance (compared to exotic forests), biodiversity and water quality benefits, long term carbon sequestration and soil stabilisation.
The problem will be the high cost of initiating and managing indigenous forests in their early years when they are sequestering little carbon and, thus, earning little income.  Some type of start-up grant or loan against future credits or multiyear credit averaging scheme would help incentivise the planting and management of indigenous forests.  The long-term benefits to the nation of indigenous forest are too great to leave their start-up to purely economic forces.

6.6      Do you agree with the assessment of how the different options might impact Māori? Have any impacts have been missed, and which are most important?

7.1      Should the incentives in the NZ ETS be changed to prioritise removals with environmental co-benefits such as indigenous afforestation? Why/Why not?
As stated above, we first believe that forestry should be taken out of the ETS (i.e., Option 4).  If it is to be kept in the ETS, then, yes, indigenous forestry should be prioritised.  The key feature of indigenous forestry will be its ability to sequester carbon long term, beyond 2050.  Once New Zealand reaches “net zero”, it is important that the nation stay there or progress to “negative” emissions.  As the Climate Change Commission has pointed out, this is best facilitated by significant permanent indigenous forestry.
On the general question of environmental co-benefits prioritised by the ETS, we believe that environmental benefits should be managed separately from the ETS, so as not to combine potentially misaligned intentions which can lead to perverse economic incentives.  We are already dealing with the perverse incentives created by including forestry removals in the ETS.

7.2      If the NZ ETS is used to support wider co-benefits, which of the options outlined in chapter 6 do you think would provide the greatest opportunity to achieve this?
We believe that Option 4 allows the greatest flexibility in supporting co-benefits.  Separate categories and premiums could be applied to different forest types and different settings.  For example, where slope stability and erosion control are at a premium (such as in Tairawhiti) a premium could be added for forest types that are better at stabilising soils in that environment.

7.3      Should a wider range of removals be included in the NZ ETS? Why/Why not?
Under our preferred option, Option 4, removals would be separated from the ETS.  We feel that there is then room for additional removal activities (i.e. pest management in pre-1990 forests, restoring wetlands and carbon sequestered in soil).  These need to be supported by robust science and monitoring, although there is good evidence for the efficacy of pest management in existing forests now.  These removals should be priced separately, as in Option 4, so as to prevent perverse economic incentives. 
Our overriding recommendation, however, is to remove carbon sequestration from the ETS and focus the ETS solely on gross emissions reductions.  If, at some future date, technology for permanent carbon sequestration becomes available (i.e., air capture or mineral sequestration), then this might be included in the ETS. 
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7.4      What other mechanisms do you consider could be effective in rewarding co-benefits or recognising other sources of removals? Why?
We believe that some existing programs, such as grants for pest control or the promotion of QEII covenanted forests could be expanded and more generously funded to promote co-benefits. 
Other sources of removals will need to be vetted by the IPCC before they officially count toward the nation’s NDCs and be credible in ‘net zero carbon’ claims.  Research needs to be progressed to support IPCC approval. 

Amnesty International NZ, ActionStation, Tauiwi Tautoko, and Inclusive Aotearoa Collective Tāhono have written an open letter to the Government expressing;

·        solidarity and support with Māori who are leading the UN Declaration for the Rights of Indigenous People (UNDRIP) process.

·        commitment to working with our own communities to honour Te Tiriti o Waitangi and;

·        support for the Government to keep working toward the plan in the coming year.

They are concerned that there are a large layer of people and communities who want to see more action to honour Te Tiriti, who haven’t been included in the public conversation about the UNDRIP process.

A wide range of NZ activist, community and educational groups have given support to the letter.

Here is the text of the letter -

To the New Zealand Government,

No matter our background, family, or where we grew up, most of us want to live in a country where all of us can be valued for who we are. Where we celebrate the unique strengths and knowledge that we bring, and all people, families and communities can set their own path to thrive.

But the laws, policies and rules of Aotearoa do not value all of us equitably. Established in the image of British colonial power, people in our successive governments have ignored our social need for honourable and just relationships with tangata whenua. We acknowledge the severe and ongoing injustices of colonisation through actions by the Crown and its governors — suppression of language, culture, institutions, and laws, and alienation of land — have created intergenerational harms in need of restoration.

As a result of that injustice, unfair divisions have been created that hurt all of us, especially whānau Māori. They harm our relationships and our ability to solve problems together so that our families, communities and wider society can flourish.

Our foundational documents, He Whakaputanga and Te Tiriti o Waitangi, gave us clear direction on how we can value all of us, and live in respectful relationship with each other. The United Nations Declaration on the Rights of Indigenous Peoples (UNDRIP) reflects the intentions of those documents, and connects us into a global network of people prepared to honour the strengths, knowledge and authority of Indigenous communities. Together, these documents promise relationships that benefit us all, and enable us to contribute to the wellbeing and future of Aotearoa. They strengthen our unity and relationships by honouring our differences.

As members of civil society, we are concerned about the recent indication that progress toward meeting our Declaration (UNDRIP) obligations may be put on hold at the Cabinet meeting on 19 December 2022. We’re writing to express our support for the work to continue. It offers a way forward for all of our communities, so that our mokopuna might live in a just Te Tiriti future, where restoration and healing from the harms of our shared past have taken place.

We stand in solidarity and support with Māori who are leading the UNDRIP process. We commit to working with our own communities to honour Te Tiriti o Waitangi. And we ask that you keep working toward the plan in the coming year.

Lately, we’ve seen some great progress towards honouring Te Tiriti o Waitangi.

More than one million of us have taken part in Te Wiki o Te Reo Māori. We celebrated Matariki — many of us for the first time — on its first public holiday. 32 new Māori Wards enable our councils to make great decisions for our communities and environment, with stronger representation. Te Aka Whai Ora — the Māori Health Authority — has given detail to the blueprint for how we can better organise resources and decision-making to look after everyone’s health. Unsung actions are being taken across Aotearoa by people of all backgrounds. People in businesses, schools, community and faith groups are working hard to better honour Te Tiriti.

But we’ve also seen backlash to that progress, just as other great moves toward equity from our past were met with attempts to drive us apart by stirring up fear over change.

We ask that leaders do not lose heart, or commitment to this work, which uplifts all of us and will strengthen our communities and relationships in the years to come.

Ngā mihi,

Here is the full list of the initiating groups and the supporting organisations and individuals.

ActionStation Aotearoa
Amnesty International Aotearoa New Zealand
Inclusive Aotearoa Collective Tāhono
Tauiwi Tautoko
350 Aotearoa
Aotearoa New Zealand Association of Social Workers / Te Rōpū Tauwhiro i Aotearoa
Asylum Seekers Support Trust
Auckland Action Against Poverty
Barbarian Productions
Center for Culture-Centered Approach to Research & Evaluation (CARE)
Child Poverty Action Group
Citizen Advice Bureau
Climate Karanga Marlborough
Coal Action Network Aotearoa
Community Networks Aotearoa / Te Hapori Tuhononga o Aotearoa
Free Store Wellington
Generation Zero
Greenpeace Aotearoa
Groundwork
Howard League
Human Rights Foundation
Mental Health Foundation of New Zealand
Multicultural Nelson
Network Waitangi Ōtautahi
New Zealand Psychological Society / Rōpū Mātai Hinengaro o Aotearoa
New Zealand Speech-language Therapists’ Association / Te Kāhui Kaiwhakatikatika Reo Kōrero o Aotearoa
Ora Taiao: NZ Climate and Health Council
Oxfam Aotearoa
Parents for Climate Aotearoa
Peace Movement Aotearoa
PEN International
People Against Prisons Aotearoa
Physiotherapy NZ / Kōmiri Aotearoa
Podiatry NZ
Protect Our Winters NZ
Public Health Association of New Zealand / Kāhui Hauora Tūmatanui
STIR
Tangata Tiriti — Treaty People
Te Kuaka — New Zealand Alternative
Te Muka Rau
Te Rau Ora
Te Reo o Ngā Tāngata
Te Waka Hourua
Tertiary Education Union / Te Hautū Kahurangi
The Aunties
The Basket Hauraki
The New Zealand Speech Language Therapists Association
Treaty Action Collective
Unite Union
Volunteering New Zealand
VOYCE Whakarongo Mai
Wesley Community Action
Jane Kelsey
Dr Heather Came
Sue Bradford
David Williams
Catherine Delahunty
Tim Howard
Seán Manning
Lynne Holdem
Catriona Cairns
Ros Noonan