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

Introduction
Climate Karanga Marlborough (CKM) is a citizens group of over 85 members, with the mission of bringing the realities of climate breakdown to the people of Marlborough and educate how best to respond. We do this through a number of initiatives:

• by working with the Marlborough District Council on strategies to limit emissions and help adaptation to the effects of climate change
• by publishing articles promoting climate change awareness and preparedness in local newspapers and by sponsoring community and school events
• by providing a social support network for Marlburians and other New Zealanders anxious about, and looking to better understand the implications of the climate change crisis we are now facing.

Preamble
In addition to submitting within the framework of the “15 set questions” of the Ministry for the Environment (MfE), we have extracted our answer to question 15 (other priority issues), embedding it within this explanatory supporting preamble statement.
Central to CKM’s common concern for our environments, local, national and global, is the belief that all of humanity that relies on industrial technology must seek a new way of thinking about and acting in our relationship with our planet. Although most people acknowledge that we can no longer continue to regard our environment as separate from us, as simply a source of goods from which we can extract what we want without return, the fact is that we continue not only to abuse the environment on which our wellbeing relies but to poison it with our waste. CKM takes the warnings of the environmental sciences with regard to global warming and biodiversity loss as both serious and critically urgent.
CKM sees no evidence of new ways of thinking in the document on “pricing agricultural emissions” on which we are submitting. Therefore, we are not willing to relegate our priorities to the last box of what appears to us to be a box-ticking exercise. We have responded to the “set questions”, as requested, worrying that if we don’t answer the questions, our thoughts, and our priorities, will simply be relegated to the box ticked “Other”.

But we have also herewith brought forward our priorities:

• What do we mean by “new ways of thinking”? Simply, by putting the environment, ecosystems, te taiao, whatever our point of reference in the natural world, front and centre of all our thinking and acting. So far, in the face of acknowledged “climate crisis”, all government and ministry thinking, both central and local, including the document on which we are submitting, has remained unchanged, anthropocentric and focussed on profit for individuals and corporates. As long as we continue to think and act in the ways that got us into this “crisis”, we will not escape from it.
  
  
• All members of CKM are sceptical of the ETS scheme, by which the natural, living world has been reduced and monetised into “carbon” to be bought and sold in an imaginary market. “Carbon credits” are traded to achieve imagined “net” reductions in carbon emissions, whilst the world continues to heat up without any reductions in gross carbon emissions, other than wrought on human beings by pandemic and poverty.
  
  
• At the same time, CKM wishes to acknowledge the efforts of the participants in the He Waka Eke Noa (HWEN) process and the willingness of the Government to adopt most of the partnership’s recommendations. Reducing agricultural emissions is a contentious issue, affecting the independent living of most if not all the HWEN partners in the current “economic environment”. CKM members are convinced that there needs to be a rapid transition of animal agriculture away from the centre of modern farming, but we recognise that about half the voting public surveyed oppose even a simple levy system on animal farming. We understand that taking too hard an approach will divide people and entrench opposition and, with that, resistance to necessary change.

 

• CKM acknowledges that a “softly, softly” approach may help frightened, angry and vulnerable people dealing with threatening change, but we feel it incumbent upon us to warn of the pressing dangers of a moderate and incremental approach to the climate crisis.
  In that regard, CKM urges that governments, central and local, put resource, effort and skilled personnel into supporting farmers both facing change and dealing with the oppressive (and depressing) mountain of mounting digital data entry or paperwork entailed by the HWEN agreement.

Consultation Document Questions

Question 1: Do you think modifications are required to the proposed farm-level levy system to ensure it delivers sufficient reductions in gross emissions from the agriculture sector? Please explain.
We are in general support of the farm-level levy system that He Waka Eke Noa (HWEN) has come up with and on which the government system is based. The system may not achieve the 2030 10% methane reduction target, however, because no cap on emissions is set. Emissions reductions will be via trial and error and dependent upon other policies, such as the value of forestry conversions. It will be a challenge to manage so that it brings about the necessary emissions reductions. It is necessary that the setting of levy prices be flexible enough to insure course corrections can be implemented quickly. Annual price setting seems a good balance between this flexibility and certainty for farmers.
There is a risk of the levy system deviating too far from the Partnership’s recommendations, through a submission process such as this. This could cause the farming community to disavow the program (which some groups already appear to be doing). In that HWEN was a major and broad consultation, it behoves the government to honour the results of the consultation as best they can.

Question 2: Are tradeable methane quotas an option the Government should consider further in the future? Why?

Tradeable methane quotes would probably be a better system. We are surprised that the HWEN partnership did not decide on this system and opted for a levy system instead, since a tradeable quota system would have likely have cost farmers less. A drawback of the quota system is that it would not generate government revenue, which should have been attractive to the farming industry, but a drawback from the government’s perspective.
We understand that the major issue with a tradeable quote system was disagreement on the level of initial allocation. We can appreciate that dairy and meat farmers might not be able to agree on an equitable allocation formula, since a per-head-of-stock formula would benefit dairy farmers over beef & sheep farmers.
Perhaps a tradeable quota system can be brought in at some time in the future. It has the advantage of accommodating an emissions cap and can bring emissions down at a predictable rate, which the levy system cannot.

Question 3: Which option do you prefer for pricing agricultural emissions by 2025 and why?
(a) A farm-level levy system including fertiliser?
(b) A farm-level levy system and fertiliser in the New Zealand Emissions Trading Scheme (NZ ETS)
(c) A processor-level NZ ETS?
We support option (b) A farm-level levy system and fertiliser in the New Zealand Emissions Trading Scheme (NZ ETS). This is the system recommended by the Climate Change Commission and would simplify farm emissions reporting by putting fertiliser emissions into the ETS at the manufacturer – importer level. The farm-level levy for methane will be enough of a challenge to introduce and manage, without adding the complexity of nitrous oxide and carbon dioxide emissions from fertiliser.
There is also an equity issue here. The rest of NZ pays for long-lived GHGs through the ETS. It would be unfair to let the farming sector treat these gases differently. Fertiliser is also the main source of GHG in the arable and horticulture sectors, which would likely escape a levy unless brought into the ETS at the processor level.

Question 4: Do you support the proposed approach for reporting of emissions? Why, and what improvements should be considered?
We support the annual reporting of basic farm information for the estimation of emissions. It is best to start out simple, since the system to include over 20,000 farms will be challenging to initiate and manage. Complexity needed to better estimate emissions can be added later, once the reporting system is up and running.

Question 5: Do you support the proposed approach to setting levy prices? Why, and what improvements should be considered?
We support the proposed system for pricing emissions. The Climate Commission is best suited to advise on the price of levy necessary to achieve the mandated emissions reductions. In order to maintain flexibility to respond to trends in emissions reduction, the price should be set annually.

Question 6: Do you support the proposed approach to revenue recycling? Why, and what improvements should be considered?
We support the proposed approach to revenue recycling, with administration costs recovered, research funded and farming assistance provided where needed, with Maori & industry input. We feel it is important to “ring-fence” the revenue from the levy scheme so that it supports farmers in reducing emissions and does not go into general government revenue.
We do not support revenue being used to pay for on-farm sequestration. This should be handled by forestry credits in the ETS. Sequestration should be uniform across all sectors of NZ society and industry, without special treatment for farmers.
The forestry credits might be extended to smaller land parcels, to benefit farmers with claiming riparian planting, but we acknowledge this would create a greater workload for MPI.

Question 7: Do you support the proposed approach for incentive payments to encourage additional emissions reductions? Why, and what improvements should be considered?
We support incentive payments to encourage additional emissions reduction, although we acknowledge that there are few options for this available to farmers at this time. The only options available, it appears, are through low-protein & low-methane forage crops and effluent handling. The Climate Commission has “high confidence” that feed additives and vaccines to reduce emissions will not be widely available by 2025. We note that inhibitors such as 3NOP and bromoform are not yet approved and the market for asparagopsis seaweed as a feed additive is in its infancy.
We recommend the government consider “no-till” farming, regenerative and organic farming practices be eligible for incentive payments, since they are known to increase soil carbon, even though soil carbon is not yet counted as sequestration. They also promote lower density farming, which, in the absence of emissions mitigation technologies, is the likely end point of farms using traditional farming methods. Stock reduction is the principal way that farmers will achieve emissions reductions in the levy system, at least until additives, vaccines and genetics are available. Regenerative and organic farms already have lower stock densities.

Question 8: Do you support the proposed approach for recognising carbon sequestration from riparian plantings and management of indigenous vegetation, both in the short and long term? Why, and what improvements should be considered?
Carbon sequestration from planting is already available for compensation through the ETS. Farming should not receive special treatment for sequestration versus other sectors of society. We support research which might allow the inclusion of new types of sequestration, such as pre-1990 forest management and riparian planting, along with other types of sequestration, such as in wetlands and soils.
Farmer interest in being paid for on-farm environmental improvements might also be addressed by a “biodiversity credit” for their work managing on-farm indigenous forests and/or riparian planting.
We acknowledge, though, that riparian planting is mainly done to prevent fertiliser and effluent runoff into waterways – a different environmental problem. It also generally involves vegetation that is low in carbon sequestration potential and is too narrow to host much biodiversity. A credit for riparian planting needs to be carefully considered to make sure it is fair to other sectors of society working to improve biodiversity and sequester carbon.
One further point: The split –gas approach to agricultural emissions acknowledges an inequality between biologic methane and CO2. From a fairness point of view, that inequality should not then be breached to allow on-farm sequestration to offset a levy on methane. Sequestration credits should be through the forestry ETS.

Question 9: Do you support the introduction of an interim processor-level levy in 2025 if the farm-level system is not ready? If not, what alternative would you propose to ensure agricultural emissions pricing starts in 2025?
Yes. By 2025 there will be only 5 years remaining to achieve the 10% reduction in methane specified in the Zero Carbon Act. We need to get started on methane emissions reductions right away.

Question 10: Do you think the proposed systems for pricing agricultural emissions is equitable, both within the agriculture sector, and across other sectors, and across New Zealand generally? Why and what changes to the system would be required to make it equitable?
Yes. It appears equitable as described. The system may not be perfect, however, but we shouldn’t let “perfect” be the enemy of “good”. Equitability issues will arise with time and these can be addressed by revisions and targeted support, as needed.

Question 11: In principle, do you think the agricultural sector should pay for any shortfall in its emissions reductions? If so, do you think using levy revenue would be an appropriate mechanism for this?
Yes, through levy revenue.

Question 12: What impacts or implications do you foresee as a result of each of the Government’s proposals in the short and long term?
Short term impacts will likely include higher domestic prices for milk, meat (beef/lamb/venison) and wool, as the levy cost gets passed on to consumers. Even without the levy, however, animal products are expected to lose market share to cultured and plant based protein in the near term, as the price of these products decline with increasing production scale. Likewise for wool, which is being replaced by more environmentally friendly plant-based products. The levy will act to accelerate this otherwise natural transition. New Zealand farmers will need to take note of these trends and adapt.
There will be more farm conversions to forestry, depending on the price of ETS credits for permanent forestry and the emergence of biodiversity credits for indigenous forestry. We hope that this transition can be managed so the nation doesn’t end up a sea of carbon-farmed pine. The multiple environmental and social benefits of native forest need to be prioritised in this transition.
Long term impacts will likely include a move away from animal farming to horticulture and arable farming. These will be needed both for market domestic supply and as industrial feedstocks for lab cultured foods and other plant-based products. Our exports will shift from animal-based products to specialty foods and fibres to which New Zealand is particularly well suited to grow.

Question 13: What steps should the Crown be taking to protect relevant iwi and Māori interests, in line with Te Tiriti o Waitangi? How should the Crown support Māori land owners, farmers and growers in a pricing system?
Support will be needed for Maori farms. Maori need to be an active part of consultation on these issues. What steps should the Crown be taking...? The Crown needs to acknowledge openly that monetary pricing systems do not fit well within Te Tiriti o Waitangi. The idea of buying and selling land and the living beings living in and on it, particularly when reduced to the notion of "carbon", remains a point of contention between 2 very different world views. It also lies at the centre of how we have got to the present state of the climate: the whenua has been seen in terms of saleable resource rather than as treasure to be cared for and as 'being' to be respected. Historically. the  result of this difference in world views led to confiscations by the Crown of good land and the marginalisation of Māori onto marginal farmland. The persistence of pricing land in the agricultural emissions plan simply perpetuates disadvantage for Māori. The Crown needs to take concrete and bold steps to reverse this ongoing process.
How should the Crown support Māori ... ? There appears to be little reward for Māori or concrete incentive for change in the present pricing arrangements. Much of the land "owned" by Māori remains of marginal value under present pricing systems. Support for Māori farmers and growers needs to be in the terms of the Second Article of Te Tiriti (Māori version), recognising in law the notion of collective land "ownership" The Crown must accept the guidance of Māori in this and resist the lobbying of private landowners and those ignorant about the nature of tino rangatiratanga. Support for Māori is in terms of respect, learning and promotional reward for initiative, past and present, rather than only monetary compensation, simply carrying on in the same old way. 

Question 14: Do you support the proposed approach for verification, compliance and enforcement? Why, and what improvements should be considered?
Yes. The plan seems reasonable and comprehensive.

Question 15: Do you have any other priority issues that you would like to share on the Government’s proposals for addressing agricultural emissions?
We applaud the government for the He Waka Eke Noa process and willingness to adopt most of the partnership’s recommendations. Reducing agricultural emissions is a contentious issue, which required thoughtfulness and engagement. We only hope that the farm-level levy system will survive a change of government and go on to help the country achieve its emissions reduction targets.

2022 Budget Policy Statement – Submission.

1. Introduction:
   

Climate Karanga Marlborough (CKM) is a climate action group of citizens of the Marlborough Region, with the purpose “to assist elected representatives and their officials to pursue policies designed to limit the extent of rapid climate change and help New Zealanders to adapt to its consequences”. We are concerned about the rapid advance of global warming and work to assist our community and government at all levels in mitigating greenhouse gas emissions and preparing the country for the challenges that global warming will bring.
We have become aware of the critical urgency to step back from our privileged status and self-entitlement and for our generation and our children’s generation to curb our greed for comfort, control and power in favour of respecting and responding to the urgent need for wellbeing of our planet and its biodiversity, of which we are a part, but just a part.
We humans can be smart, inventive and adaptive, but that counts for little if we simply take for granted that we can exploit the abundance provided for us by the natural world without making any return. The world has its limits and we are there.
From now on, we expect the current government to work within those limits, acknowledging them in detail and, with clear explanation, dedicating adequate finance to enabling us to stop and, if possible, reverse our human contributions in Aotearoa to climate disruption and environmental pollution.
Although I would like to see this coming out of due reverence for our planet and its biodiversity, it certainly would be in our own self-interest, as our wellbeing depends entirely on the Earth’s wellbeing, whatever may be our technological smarts!
A good starting-place would be for the government to deliver with urgency on its commitments in line with the 2015 Paris Agreement and the 2021 COP26.
     2. Budget Frameworks.

We support the government’s wellbeing priorities, including taking an intergenerational approach and looking beyond simple economic measures of success and so-called ‘progress’.

We support the use of the Living Standards Framework, including improving on it.

We support the development of He Ara Waiora.
We support consideration given to distributional impacts of policies on different populations and the environment.
We support the explanation of moral values, not just economic values, underlying such considerations.
This government has not shied off moral considerations in furthering its policies, for instance with regard to terrorism and response to the Coronavirus pandemic. By ‘moral’ we allude to values or principles that matter most to people, not just to their pocket or their comfort.
       3. A Just Transition.

Here is where moral values, not just economic, must be explicated. Doing justice requires the practice of equality, not just the pursuit of equity.
Climate change, the pandemic and the housing crisis are 3 of our most pressing immediate and long-term challenges and all of them have impacted unequally racially, intergenerationally, on women, on indigenous peoples and on non-industrialised countries, with increasing impoverishment amongst those most affected.
We submit that the Budget Policy Statement requires an additional priority: Reducing economic inequality.
This would align with the other priorities but would highlight a theme common to them all. It would also align with the Living Standards Framework, He Ara Waiora and Fonofale.
Further, Equality and Justice would align with moral values, such as Kindness and Teamwork, already espoused by the current government in dealing with our challenges.
In that regard, We submit that the Budget Policy Statement should allocate ongoing funding specifically to Equality for Women: this would have direct impact on Physical and Mental Wellbeing, Child (and Family) Wellbeing and the Wellbeing of Māori and Pacific peoples.
        4. Implementation Funding:

A Just Transition requires that implementation funding be specified, otherwise processes will be set up unjustly to fail. Funding needs to be allocated to support a genuine and ongoing process of engagement with workers in their unions, with volunteer groups in their communities, and with Māori iwi and hapū and Pacifika communities in the time needed to fulfil such processes. For a Just Transition to occur, these engagements must happen first.
In allocating funding and resources, particularly in vulnerable communities, it is important that the government does not simply take a deficit – ‘we’re helping you/lifting you up’ - approach, but adopts an approach that is prepared to listen and respond appropriately – ‘help us understand what it is you need from us to promote your strengths and skills/lift us up’.
We expect funding will honour Te Tiriti o Waitangi through equal and equitable partnership with Māori in all decision-making, be grounded in Kaupapa Māori and uphold indigenous rights, as stated through He Ara Waiora.
      5. Other Submissions:

We are in full support of the submissions, each made from their own areas of focus, by 350 Aotearoa; Greenpeace; Fossil Free State Sector Coalition; Coal Action Network Aotearoa; NZEI Te Riu Roa – Teachers’ Union.
       6. State Sector Decarbonisation:

We feel strongly that the government should increase funding for the Clean Powered State Sector Fund, to help decarbonise schools, hospitals and other state facilities. This is an easy way for the government to reduce emissions and show leadership in decarbonising infrastructure.
Within this same theme, we strongly encourage the new budget to increase funding for the GIDI scheme to help decarbonise industry and to increase funding to community and household energy generation and conservation projects.
     7. Regenerative Farming:

Similarly, we strongly endorse the suggestion by other submitters that the government fund a scheme to facilitate the transition to regenerative farming practices. Regenerative farming has the potential to reduce herd sizes, to accommodate the government’s methane emissions reduction goals, as well as reduce nitrogen pollution to our rivers, all without reducing farmer income. The government should support farmers who decide to switch to regenerative and organic farming practices.
     8. Environmental Education:

In particular, we would like to add to the submission from NZEI Te Riu Roa about the importance of holistic education about the environmental crisis.
It is important that the government explicitly recognises and funds its own responsibility and leadership role in informing and educating both the public generally and specific population groups, not just about the thinking behind its policies but about how these policies may play out in terms of such issues as justice and equality.
For instance, one issue that is not addressed, except indirectly, in any of the submissions named above is the central importance for us all to consume less energy overall, not just in order to reduce carbon emissions and other pollutants but also because alternative energy sources are not adequate to make up the difference arising from reduced fossil fuel extraction and because it will demand energy to build the infrastructure for alternative energy sources.
So, if we are all to consume less, how just can that be for groups, both within NZ and in those parts of the Pacific where NZ has influence, who have had little or no access to sources of energy to help reduce the effects of poverty and to bring equality with those who have?
Another issue concerns the Wellbeing priority of the Future of Work, “enabling all New Zealanders and NZ businesses to benefit from new technologies and lift productivity and wages through innovation”. The allure of “new technologies” may encourage people to carry on denying the immediacy of the problem of climate change with the illusion that we will fix all such problems with ingenuity, e.g. alternative fuels such as hydrogen and biofuels. Without diminishing the value of innovation in either mitigating or adapting to climate change and whilst encouraging innovative initiatives, the government needs to encourage wide debate at all ages and in all situations about the pros and cons of different proposed solutions or contributions. This is not just for the public’s understanding, but for its own understanding.
      9. Conclusion:

One of the clear messages of scientific research, of increasingly violent weather vagaries and of our continuing failure to adequately reduce global warming, biodiversity loss and environmental degradation is that we can’t afford to keep on going as we have done without drastic consequences for the planet and planetary life, including ourselves. We do need to think or do things differently.
We have to say that we have seen little evidence of new thinking in any government initiatives so far, including in what we have read in the Budget Policy Statement.
Come on! Buck up! We’re in a Climate Emergency – you’ve said it yourselves. You’ve done a good job overall in response to Covid. But Covid is really only a symptom of the underlying disorder: planetary life under stress.
You’ve done plenty homework – it’s time for decisive action. The consequences will not be worse than those of continuing inaction.

                        Climate Karanga Marlborough submission to the Infrastructure Commission re the Consultation Document,
                                                                      He Tūāpapa ki te Ora.  18 June 2021  

Climate Karanga Marlborough (CKM) is a local climate action group purposing “to persuade elected representatives and their officials to pursue policies designed to limit the extent of rapid climate change and help New Zealanders to adapt to its consequences”. We have constructive relationships with the Marlborough District Council and Council staff. Recently, we submitted and presented to the Council re their Long-term Plan for the next 10 years.
We welcome the opportunity to support and submit to Te Waihanga re the Infrastructure Strategy Consultation Document, particularly in the wake of the Climate Change Commission (CCC) report and recent government policy documents, such as The Three Waters Reform Programme.

1: We have read the Infrastructure Commission’s response to the Climate Change Commission’s 2021 Draft Advice. Regarding the scale of transition required to meet the recommendations of the CCC, we welcome your statement in response: “Te Waihanga see that infrastructure has an important role to play in facilitating the transition, particularly transport, energy, waste and social infrastructure.” In fact, in principle, with few reservations, we also welcome the tenor of your response. It accords with our request, when presenting to our local council that their entire work programme be viewed through a climate change lens, always using a precautionary approach and taking a long-term view. – Not just to the next turbulent 30 years, but to the impacts well beyond!

2: As with Te Waihanga’s response to He Pou a Rangi, CKM finds itself in accord with many of the options for action put forward by Te Waihanga in developing the 30 year Infrastructure Strategy: -
In particular, preparations for climate change/global warming; reducing demand for energy consumption, eg enabling both active and renewable energy-based public modes of integrated transport; resourcing ongoing cross-national data collection and information analysis for transparent modelling and planning for evidence-based development; avoiding siloed thinking, which entails enabling cross-boundary communications and actions; ensuring equitable (fair, inclusive and affordable) funding and financing; making better use of existing infrastructure and considering non-built options, particularly towards behaviour change.
CKM acknowledges your 5 proposed priorities, particularly in the light of what you say you have heard through the Asset Owners’ Survey.
We do not argue with your stated outcomes and principles, as such.

3: In response to your asking for our views on the proposed 2050 infrastructure vision for New Zealand, it seems to us that the vision, as described, is constricted and defined more by what is not in the vision than what is in it. In our opinion, you have missed some opportunities to lay out an expanded vision of building infrastructure in alliance with the natural world and with te Ao Māori.

4: “All decision-making about infrastructure must be guided by Te Tiriti o Waitangi (the Treaty of Waitangi) and its principles, but specifically by the obligation to partner with Māori. As well as this, we propose a fundamental principle that infrastructure should support oranga tangata or the wellbeing of people.” (p08)
In response, we say that Te Tiriti and the Treaty are not the same documents, and the Commission needs to address the differences.
Also, the “obligation” lies specifically, both in legal and moral terms, with the articles of the Treaty, rather than with the so-called principles. Partnering with Māori should not be seen as an obligation but, at the very least, an opportunity! The added statement, starting “as well as this”, reads like an escape clause: escape from the clauses in the previous statement.  

5: “There appears to be a lack of meaningful relationships between iwi/Māori and many key infrastructure players (Crown and private.) …
The current resource management approach is not working for Māori due to a lack of meaningful involvement, as well as consultation fatigue on both sides.”– Probably not surprising, given that the Pākehā desire for ‘infrastructure’ has led to Māori land dispossession over 180 years. Both ‘sides’ are moving from a position of lack or loss of trust.  
In answer to the 3 associated questions, we respond thus: Q15 – maybe not for us to say, but we suggest continuing to ask Māori without pre-empting the answers: keep listening, talking and building trust. Q16 – explore the meanings of land and infrastructure, whenua and taonga. Q17 – not for us to answer, but we can ask you whether and how Māori are actually being allowed to lead?

6: In regard to how CKM understands the relationships of land, water and air to infrastructure, we believe in the principle of respecting the natural world, in all its manifestations, as our ally, not simply regarding nature as a resource, as we believe that unconsidered exploitation of natural resources has led to the disruption of the climate that we now face.  The simplest way of doing this from our viewpoint is to recognise that people are not separate from nature and that we are just one part of nature’s biodiversity. Thus, any infrastructure in which we may wish to invest must be in agreement with nature and nature’s biodiversity. Ways of doing this have been thoroughly explored in The Dasgupta Review: The Economics of Biodiversity, a report commissioned by the UK government and released in February. 2021. We recommend this report to you.
We also believe that our viewpoint corresponds to Māori concepts of whakapapa and of rangatiratanga as used in Article 2 of Te Tiriti. We have come across reference to the ‘environment’ often enough in Infracom’s Consultation Document but neither to nature nor to biodiversity.
We ask that Te Waihanga reconsiders and redefines its statement about how it thinks about infrastructure (in ‘Infrastructure under one roof’) in terms that both Māori and most people who respect the natural world and its creatures can relate to personally.

7: Developing this idea of relating human settlement to the natural world, we recommend that Te Waihanga places much more emphasis on bringing the natural world into cities. Although recent research on this in Aotearoa specifically is limited, there is plenty of international evidence that this both benefits the wellbeing of city dwellers and their relationship to and understanding of nature:
    The following links are references in support.
  It’s official: City parks make us happy - Outside our doors -
and also benefits the natural world and biodiversity.
       Biological corridors throughout the length of New Zealand -
        What are wildlife corridors? (Australian government)
 
Neither Te Tūāpapa ki te Ora nor the Infrastructure Commission’s submission on the Urban Development Bill takes the opportunity to put the relationship between human beings and the natural world at the centre of how we develop our infrastructure. An almost exclusively anthropocentric approach historically has got us to where we are now, in terms both of our environment and the climate.  (cf The Dasgupta Review.)
Discussion Q21 as to whether a “10-year lapse period for infrastructure corridor designations is long enough” is pertinent here. CKM’s advice is that a 30-year plus period for such “spatial planning” is minimal from the point of view of the natural world and probably also of te Ao Māori. The discussion that precedes this question in the Consultation Document is set in terms of “lead infrastructures” and “corridors”. It is CKM’s view that if nature and wildlife were to head these terms, then Infracom’s planning would become much more inclusive, considered and relevant to the climate changes we are all facing.

8: In further consideration of the relationship between human settlement and the natural world, CKM is very concerned that Te Waihanga is overly focused on the nuts and bolts of urban development at the cost of a whole-of-New Zealand approach. We understand totally that Te Waihanga is facing the legacy of decades-long neglect of urban planning and maintenance of infrastructure, particularly evident in our major cities. Yet it is vitally important, in scrambling to guard the future of our cities, that we do not neglect to resource rural and provincial infrastructure in terms of climate and environmental change. In a hundred years’ time, our coastline, including city borders, will have changed and populations will have changed in terms of scale, placement and movement that are hard to anticipate in the face of climatic, environmental and political uncertainty. In reactively “mitigating … and adapting to the effects of climate change”, we must remember that we can also proactively bring about change, not only in mitigating our own impacts on climate and the natural world but also by adapting how we settle in and with the world.
In that regard, we appreciate discussion questions Q13 and Q14. Our response to these is that in New Zealand we might seek to counter population decline in non-urban communities (through transport, housing, work and amenity options) and develop a Population Strategy focusing as much on a preferred population distribution as on a growth path. How New Zealand plans its infrastructure is central to that.  

9: In terms of action, CKM recognises that Te Waihanga does not have a decision- or investment-making function. We wholeheartedly support the proposed priority in the consultation document for “better integration and coordination between local and central government infrastructure functions”. We would add to that the importance of collaboration with the community and volunteer sectors, which would require active support, resourcing and funding at both local and central government levels. Such a collaboration would be essential to understanding “the growing gap between the demand for infrastructure and the funding available or the willingness to pay for it”. In particular, it could enable a reduction in demand for infrastructure that requires growing investment of energy, specifically fossil-fuel energy, which is not only primarily responsible for environmental damage but is also rapidly rising in cost.

10: CKM’s final recommendation to Te Waihanga regards energy descent, product stewardship and the circular economy. CKM takes the view that reducing consumption, especially of energy, and avoiding waste are the critical changes that we all need to make in limiting global warming, mitigating the excesses of climate change and beginning to care for our planet. This is what we mean by energy descent. But changing our demands for energy requires not only reduced consumption but also changes in how we supply energy. As long as energy supply is based simply on profit out of production geared to growing demand, there will be no energy descent. Responsibility for change rests on all involved. Responsibility for reducing the impact on climate and the environment of any product rests as much with producers and marketers as with consumers, entailing a process of product stewardship.
Whilst we acknowledge that there are a growing number of product stewardship schemes in Aotearoa, CKM urges Te Waihanga to lay much greater emphasis on energy descent, product stewardship and the circular economy in its recommendations to government. CKM recognises that these must surely be central to how Te Waihanga thinks about infrastructure, but this is really not apparent in the principles and priorities laid out in the Consultation Document. The government, and therefore Infracom and the taxpayer, tend to be seen as responsible for end-of-the line waste management, but the taxpayer needs better informed about what a circular economy means, about waste management options and responsibilities. It is up to the government to make clear nationally and internationally what national policies we have in Aotearoa with regard to product management, so that not only consumers and manufacturers but also importers understand the responsibilities, the costs and the benefits.  
As a lead player over the next 30 years, Te Waihanga, on behalf of all New Zealanders, has the opportunity to lay out an expanded vision of building infrastructure together with nature and the responsibility to karanga,
to summon the government boldly and publicly to describe clearly its own vision in response, to pick up the wero, to accept the challenges presented to it in planning and designing in partnership an infrastructure for Aotearoa fit for the next 30 to 100 years. 
 
Summary.

A: We have introduced ourselves as Climate Karanga Marlborough (CKM) and identified a constructive relationship with our local Council.

B: We appreciate the opportunity to submit. In doing so, we have expressed both our support for what Te Waihanga has proposed and also our opinion that it has missed the opportunity to present a bigger vision.

C: We have responded to your questions about relationships with the Tangata Whenua.

D: We have outlined how we understand people to be part of nature, not separate from it, and we have recommended that any infrastructure in which New Zealanders may wish to invest must be in favour of nature and nature’s biodiversity, in line with recommendations from the 2021 Dasgupta Review, which was commissioned by the UK government and which we have recommended to Te Waihanga.

E: Accordingly, we have asked that Te Waihanga explain further how it thinks about infrastructure.

F: We have explored the importance of relationships between human settlement and the natural world and made recommendations accordingly.

G: We have recommended that Te Waihanga articulate how it might engage with the community and volunteer sectors.

H: We have urged Te Waihanga to lay more emphasis on practices of energy descent, product stewardship and the circular economy.

I: We believe Te Waihanga has a key role in supporting the government in dealing with climate change challenges over the next 30 to 100 years.

Climate Karanga Marlborough Submission to MDC 2021 – 2031 LTP.

OVERVIEW

A couple of our members sat in on the the recent presentation to the Environment Committee by Gregor Macara from NIWA, on Climate Change Projections and Impacts. We were encouraged to see Councillors and Staff are keeping up to date with the latest information in this area.
We wish to refer you to the Executive Summary of the Report on pages 9, 10 & 11. Please note the large range of possibilities for temperature and sea level rises dependent on the different greenhouse gas concentration pathways (RCP’s). We wish to stress the importance of not assuming the lowest pathway will happen. All indications up to the present indicate that we are more on track for the medium or even the high pathways and the difference in consequences is large and significant. For example a decrease in mean annual low flow (MALF) could exceed 50% for most of the river systems in the region with increased greenhouse gas concentration and time. With the declining trend in the Wairau Aquifer already clearly evident this added information is cause for concern. Longer periods of low flow will result in further reduced aquifer recharge. We don’t need to explain to you how serious the impacts of such an outcome would be for the river and spring fed ecosystems and the Marlborough economy.

We request councillors to always take the “precautionary approach” when making decisions that have the potential to impact the Wairau River and aquifer.

We wish to take this opportunity to remind Council that your entire work program needs to be viewed through a climate - change lens. The NIWA report was a timely reminder of how important this is and will be, as Climate Change impacts, such as extreme weather events and sea level rise, increase. We are encouraged to see in the LTP document the recognition of the importance of building resilience in our local infrastructure to such impacts. We strongly encourage the aim of being proactive when doing infrastructure planning and support the statement – “Building infrastructure to the latest standards and with the most suitable materials increases resilience to floods, earthquakes and changes in the climate.”

We support the resourcing for planning and modelling work to assess the likely effects of these impacts and to be better prepared to mitigate them.

CLIMATE ACTION PLAN.

In our submission we wish to highlight the question of whether funding allocations within the LTP are adequate to meet commitments previously made by this council when they adopted the Climate Action Plan in March 2020.

We request that you systematically review the LTP, taking a perspective of urgent climate action in the current decade and recognising the need to reduce net GHG emissions by half by 2030.

Richard Coningham has recently supplied us with a progress report on the Climate Change Action Plan. We are encouraged to see steady progress being made on various Actions laid out in the Plan.

• We look forward to seeing a copy of the Report assessing the MDC baseline emissions when it becomes available.

 

• We note that Action 1(a)(iii) regarding investigating charging stations for vehicles and e-bikes and the use of hybrid and electric vehicles in the Council fleet is tagged as “yet to be investigated.”

 

• 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 you to keep this “provision for uncertainty” foremost in your minds when finalising the LTP.

• We also wish to bring to your attention an important “Action” in the Climate Action Plan regarding funding. Clause 4(c)(ii) states - "Incorporate funding provision in the Long Term Plan to implement this Action Plan." We note the statement in the LTP document - "It is not intended to formally consult on the entire programme of infrastructure works, as much of what is included in Council’s capital expenditure budget is regarded as essential to (amongst other things) - Mitigate the potential impacts of climate change;" It is unclear to us which funding is already allocated in the capital expenditure budget for mitigation purposes and what extra resources may need to be allocated in the LTP to ensure the commitments made in the Action Plan can be met.

We ask you to reassess funding commitments in the Climate Action Plan and ensure adequate resourcing is allocated, if you have not already done so.

THE LONG VIEW

We believe it is critical to keep a long view with all planning decisions. The NIWA report gives you critical information to consider in your decision making. As an example we wish to highlight the recent agenda topic looking at the upgrade of the Town Branch drain, which was discussed at the Assets and Services Committee meeting on January 28th this year. We note in the associated article printed in the Marlborough Express on February 7th that the question of establishing further housing east of the existing town boundary on the E2 land arose during this discussion. This is a very good example of where the long view is essential.
We note the MDC CEO Mark Wheeler is quoted as saying, "It's not an easy process and there's a lot of questions to answer, because there's a whole raft of issues with that land.” One of those issues that appears to have not been mentioned in the councillors’ discussion is that of sea level rise. Maybe the belief is that the sea is several kilometres from this area and that therefore there is nothing to be concerned about? The excellent public resource you have now made available online with the new LIDAR maps shows clearly, most of the E2 land is less than 2 metres above sea level. One of our members used to drive a liquid waste truck and has seen what the ground water levels are like in Hardings Rd in the middle of winter where the land is currently only about one metre above sea level. Ground water levels reach the surface during wet periods. With sea levels projected to rise by around one metre by 2100 all the E2 land will be in the same boat, so to speak – one metre above sea level. Council will have to provide more pumping stations to keep the area liveable. If worst case scenarios occur we may well have nearly 2 metres of sea level rise by about 2150 according to the NIWA report. We would like to remind you of something Gregor Macara mentioned in his presentation. The possibility of passing currently unknown tipping points in the climate system (that may be irreversible) can not be included in their projections. We have to be smarter with our decision making and think ahead a bit more for our grandchildren’s sake please!

We request Councillors to take the long view when considering development of any further housing east of the existing town boundary.

Thankyou. Budyong Hill for Climate Karanga Marlborough.

MDC - LTP HEARINGS – CLIMATE KARANGA MARLBOROUGH SUBMISSION. 02/06/2021

Kia ora. Thankyou for this opportunity to have input to the 2021 – 2031 LTP process. We recognise the value that this chance to interact with Council gives you and us and hopefully the experience helps to keep you in touch with the aspirations and concerns within our community. We are aware there are many varied demands on Councillors attention and we understand the challenge you all face making the necessary decisions to meet the many and varied needs of our community. We know our request to view your entire work program through a “climate change lens”, to always use the “precautionary approach” and to take the “long view” only adds to the complexity of your decision making processes. But we strongly believe these things must be done if we are to have the best chance of reducing the biodiversity and climate impacts that are resulting from global warming, ocean acidification and ecosystem degradation. This LTP process is designed to look out over the next 10 years. The really big challenges are going to be with us for not one decade, but many decades and in fact centuries. The recent NIWA report to Council helped to focus our attention on this reality. As we noted in our submission, Gregor Makara emphasised that the possibility of passing currently unknown and irreversible tipping points in the climate system could not be included in their projections.

Somehow having gained this knowledge we all have to retain some optimism and hope. As the dominant species on our planet we have to work together, find the solutions and make the necessary changes to the way we live to hopefully give our descendants a fighting chance of survival. Members of CKM have a strong belief that this requires big changes in the ways we think about the world, in the ways we relate to our planet and to all the myriad other species we share the planet with.

I recently read an article titled “Humans are in collision with nature”. This was not David Attenborough reminding us but Rob Campbell, the current chair of the boards of SkyCity Entertainment Group, Summerset Group, Tourism Holdings, Wel Networks, New Zealand Rural Land Co, and also a director of Precinct Properties, the largest owner and developer of premium inner-city real estate in Auckland and Wellington.

In the article Rob was quoted as saying “The way I perceive the world at the moment is that there is a real clash or collision going on between the way human beings have conducted ourselves and nature. Wherever you look, you can see all these things, which are very important in themselves, but effectively symptoms of this wider collision. There is a dawning recognition that the old things we do and the way in which we do them are under challenge. If you think everything in the world is basically okay and that all we need to do is to return to previous behaviours and increase our GDP as much as we can and increase the individual profitability of our business as much as we can and increase your personal income as much as you can, then I think you’re quite at odds with the way I see the world.”

He went on to talk about the importance of Boards needing to view their businesses through a wider lens and that businesses that will succeed in a sustainable way in the new post Covid environment are those that are responsible to all their stakeholders, constantly scan the horizon for change rather than just reacting when it smacks them in the face, and that genuinely excite their people to work for a common cause rather than just a short-term incentive.

“Those key things will distinguish the businesses of the future,” he says.

Of course what he is talking about does not just apply to the business world, it applies to each and every one of us and in particular it applies to those in positions of influence and leadership in a community such as yourselves. We have to find ways to live our lives using less energy and consuming less. We have to make less demands on the many life giving resources our planet provides for us because currently we are living beyond our means. We are using more resources per person than the planet can sustainably provide and Kiwis are amongst the world leaders in this area.

We would like to finish by reminding you of the main issues we raised in our submission and getting some feedback from you if that is appropriate.

1) We recognise the positive steps being taken putting the Climate Change Action Plan into effect and look forward to further progress with these actions. We hope to be reassured that all adequate funding required to implement the Action Plan has been allocated in the LTP, as stated in clause 4(c)(ii) of the Plan.

2) Similarly we hope you can reassure us you will have clause 4(c)(i) of the Action Plan foremost in your minds when finalising the LTP. This clause states – “Include assumptions for climate change in the Long Term Plan, including provision for uncertainty, based on latest scientific evidence from the Intergovernmental Panel on Climate Change (IPCC).”

3) We urge councillors to always take the “precautionary approach” when making decisions. In particular we would focus on decisions that have the potential to impact the Wairau River and aquifer, especially with the knowledge we have gained and are gaining from the NIWA report projections and the ongoing Gravel River Beds and associated aquifer research. It is clear users of water from the aquifer can no longer take it for granted that their ongoing supply will always continue uninterrupted.

4) Finally we wish to focus on the final paragraph of our submission headed “The Long View”. As we have already said we believe that view needs to be well beyond the designated 10 years of this Plan because of the big challenges I referred to earlier. We have used the proposed residential development of the E2 land as an example of where this longer view is required. Do we understand the implications for this area when sea level rises one metre or more? Will we not already have big challenges to face with managing rising ground water levels around the sewerage ponds and the Riverlands Industrial Estate? Do we want to add to these challenges by extending the residential zone further to the east? We don’t have the answers to these questions but we do consider it our responsibility to raise them with you at this time.

I’m very aware of the difficulty of raising such issues without sounding like a pessimist and alarmist. I am inherently an optimist, otherwise I wouldn’t be standing here in front of you right now. Members of our group are involved in a variety of positive and constructive activities in the wider community and try our best to strike a balance when applying our kaupapa, which in part is, “To increase NZ society’s awareness of, and its preparedness to meet the impending challenges that rapid climate change will entail.”

So thankyou again for the opportunity to submit to the LTP and to come here today and “prod” you all, as we have done before. We see this as an important part of our task as a lobby group. We value the interaction and the relationships we have established with councillors and staff and will continue to contribute as positively as we can to the community building process in Marlborough.

Nga mihi nui, Budyong Hill – for Climate Karanga Marlborough.

We received a response from MDC after the LTP hearings where they informed us of their decision -

"There is $483,000 budgeted for Climate Change investigations. The group’s concerns are valid and are being taken account of in Council's planning, whether that be our resource management plan, infrastructure design or the broader planning issues involved in new development area considerations. There will be further work done on the benefits and costs of electric and hybrid vehicles to inform our next fleet renewal. The CE’s Council vehicle is a hybrid."

Climate Karanga Marlborough Submission on the Climate Commission Draft Advice for Consultation.

Introduction
    1. Climate Karanga Marlborough is a grass-roots incorporated society with 112 members.  Our mission is to bring to the people of Marlborough the realities of climate breakdown and educate how best to respond.

    2. We wish to acknowledge the importance and urgency of this Report, the detailed and varied work that has gone into it and the openness of its presentation. We submit that we are generally in support of the Commission’s many recommendations.

Report Format
    3. We submit that the report, as it stands, is too long and at times technologically and politically too daunting to engage the submissions of a significantly large and representative proportion of New Zealanders. The Executive Summary, whilst making vital points about the need to increase the speed of change, the importance of an “equitable transition” and the need for a “cohesive strategy”, is an uneasy combination of sketchy explanation and technical information.

The Climate and Biodiversity Crises
    4. We sadly acknowledge the inability of the human race to see its place in the web of life.  There is no doubt that, because we have lost sight of our place within the greater web of life, humans are destroying our only home. Too often self-centredness and a sense of entitlement to nature’s resources dominate our decisions. Global warming is but one manifestation of these human traits. Biodiversity loss and widespread pollution and desecration of the natural world are evident for all to see. We accept there is no easy way forward to deal with this dilemma, but are also in no doubt that if we do not succeed, the future for our descendants will indeed be grim. Humanity has dug this deep hole we are now in and finding our way out is not going to be simple.

    5. There are some members of our race largely from various indigenous groupings, including Maori, who have managed to retain an understanding of our place in the web of life. This knowledge has been developed over millennia. Unfortunately, those who hold the political and economic power largely do not listen to their advice and wisdom. It is encouraging to see a recognition in the Report of the need to incorporate the values Maori espouse. Quoting the Report:
“We have considered how policies could support kotahitanga, manaakitanga, tikanga and whanaungatanga. As the Government develops its plan to reduce emissions, it also needs to consider how actions will align with these values. Partnership with iwi/Māori at every stage of the policy development process will be critical to support this.”

    6. We are faced with an existential crisis because the prevailing economic system requires continuous growth on a finite planet, encourages huge amounts of waste and treats many of the amazing resources that nature provides for sustaining life as expendable and of little value. We have our priorities completely wrong! So, incorporating the above mentioned values in a way that is meaningful requires a major overhaul of our societal operating system. We cannot pretend we are listening to the wisdom of those who still have this understanding and carry on with the “Growth” imperative at the same time.

    7. We wish to encourage the Commission to be honest and open about the nature of the challenges we face. The recent Dasgupta Review: the Economics of Biodiversity, commissioned by the UK government and released around the same time as the Commission’s Report in NZ, highlights many alarming facts including:
“in little more than two decades, between 1992 and 2014, there was a 40% fall in the stock of natural capital per person. That is the water we drink, the air we breathe, the soil we grow food in, and all living things shared among the global population.”  

    8. We have politicians in NZ who are happy to state publicly that:
“It is imperative that the Government does not meddle with the freedoms of New Zealanders and finds solutions to achieving net zero carbon emissions using effective and rational policy.”
This statement encapsulates the issue we are faced with. Turn this around and it is in effect saying solutions to achieving net zero carbon that impinge on our present so-called “freedoms” are not acceptable.

    9. The Commission must appeal to all New Zealanders and encourage them to give up or drastically change many aspects of their current ways of living to help create the possibility of leaving a liveable planet for our grandchildren. We need to stop putting our own needs first and think not only of those still to come but more importantly of maintaining a viable web of life. Without it we are finished.

    10. We would wish to strengthen the arm of the Commission in encouraging politicians and our Government, in particular, to recognise and acknowledge the damage we have continued to do to our environment, to our Motu, and to take immediate action to begin to reverse it. We hope that this will be part of a world-wide effort and that New Zealanders can seize the opportunity to take a lead in that effort, as we have done in combatting the effects of the Corona virus. – In fact, we recognise the advent of the Corona virus as a consequence of human depradations on our planet.

Nature as an Economic Asset
    11. We recommend that the Commission refer to findings of The Dasgupta Review: the Economics of Biodiversity as potentially providing a way to put biodiversity and the environment into our economic thinking.  Centring on the dynamic power, interconnectedness and intrinsic worth of biodiversity, local and global, the Review considers climate disruption as one of the consequences of the failure of modern economics, global business and individuals to account for natural capital, that is to say the air we breathe, the waters we drink and take food from, and the earth that sustains us and all the species on which the health of natural ecosystems depends. Biodiversity is essential to all ecosystems as an enabling asset, just as our own skills and aptitudes enable the value of our labour. In the last 400 years we have taken our environment for granted, given it no accounting value, subject to whatever we demand of it, whenever.  

    12. The Review has developed a unified framework for the economics of diversity.  “The grammar we have developed enables economics to serve our values, not direct them.” (p 487) “Correct economic reasoning is entangled with our values. Biodiversity does not only have instrumental value, it also has existence and intrinsic worth. ... To detach Nature from economic reasoning is to imply that we consider ourselves to be external to Nature. The fault is not in economics; it lies in the way we have chosen to practise it.” (p 498)

    13. There is a paradox that modern humans seems unable to save themselves simply by having the knowledge that we are destroying ourselves by destroying the web of life. We still seem to need some monetary or market incentive to change. Unfortunately, a market economy, historically based upon natural resource exploitation, remains the devil we know and trust.

Public Awareness
    14. Public awareness of the Climate Emergency appears minimal, at this stage, yet it has the potential to help decrease emissions from personal actions and cement political will to endure the changes ahead.  The Commission has suggested awareness campaigns, such as the TV road safety ad campaign by NZ Police.  We submit that, given that the government has declared a climate emergency, it needs to follow through with a public awareness campaign appropriate for an emergency, along the lines of the ongoing Covid-19 awareness campaign.  This campaign might include regular updates of important climate parameters, such as global average air and ocean temperature, CO2 & methane concentrations, trends in sea ice, ocean pH and scientific research findings on climate related biodiversity and environmental changes.

    15. We submit that the Commission recommend to government that it develop and promote an awareness campaign to help New Zealanders adapt climate-friendly habits in their daily lives, as one would expect in a national emergency.  In particular, we submit that the campaign should be presented in a way for schools and other educational institutions to put before young people of all ages. – As the Report points out, these are the people who will deal with the changes their elders do or do not make now.

Energy Descent.
    16. One critical issue we believe the Commission needs to face is that of continued energy availability. We need to accept the reality that, as we phase out fossil fuels, we are highly likely to have less overall energy available to us. It is not realistic to continue our planning as if we’re going to be able to continue meeting our extravagant energy needs unheeded, by just changing to renewable sources for that energy.

    17. To date the ETS has demonstrably failed in reducing our emissions. We understand the cap that has now been introduced is expected to improve outcomes but there still appear to be shortcomings.  We note in the Report on page 132 -

“The Government has recognised that the regulatory framework governing conduct in the NZ ETS market is patchy and incomplete. It has established a work programme to address the lack of good governance and associated risks, which include insider trading, market manipulation, false or misleading advice to participants, potential lack of transparency and oversight of trades in the secondary market, money laundering, credit and counter-party risks and conflicts of interest.”

The Commission appears to be saying the ETS, as it stands is not fit for purpose and, on page 133, that under the present governance arrangements “some [market] risks are potentially catastrophic for the scheme’s effectiveness..”

    18. To highlight our concern about continued energy availability we wish to quote from a recent paper titled “The Political Economy of Deep Decarbonization: Tradable Energy Quotas (TEQs) for Energy Descent Futures”. A full copy is available here -
“Much mainstream energy and sustainability discourse is based on a series of highly optimistic assumptions about future energy supply in a carbon-constrained world. The improbability of conditions aligning such that all necessary assumptions are borne out implies that the energy futures ahead will likely diverge significantly from those envisaged within this established discourse. This has potentially profound implications. The availability of energy in the right forms at sufficient rates is the lifeblood of any particular form of social organisation. Energy-related factors are fundamental to how we shape our societies and pursue our goals, yet it seems most individuals and societies are making plans based on precarious expectations.”

And - “...we appreciate the psychological drivers for denying the prospect of energy descent and trusting instead in a cornucopian or techno-optimistic worldview. It is less confronting to human identities and ways of life to believe that technology and markets can solve social and environmental problems without needing to rethink the underpinning structures that give rise to those problems.”

And - “All human societies exist interdependently with natural systems that are ultimately beyond human control. It is far preferable, we contend, that societies retain the greatest degree of agency possible in getting to grips with the dilemma of fossil fuel dependence. The alternative is to have our futures dictated to us by breakdown in natural systems that are beyond our capacity to control.”

Nitrous Oxide

    19. The Report provides no guidance to the government on the reduction of nitrous oxide emissions.  It appears to take the position of the IPCC, that nitrous oxide emissions are a necessary part of agriculture and should be left to decrease simply through ongoing farming efficiency gains.  This may be the IPCC view, which has a whole-world perspective, but it need not be the view here in New Zealand.  

    20. Most nitrous oxide emissions in New Zealand primarily originate from high-nitrogen pastoral farming practices – the use of nitrogen fertilisers and nitrogen-rich urine from cattle.  The discussion of nitrous oxide in Evidence Chapter 4c points out a number of low-nitrogen alternatives to these practices, including ongoing pastoral farming practices where nitrogen fertiliser is not used at all.  While the world may need nitrogen fertilisers to feed itself, it is clear that this isn’t the case here.
 
    21. Nitrous oxide emissions are not an insignificant part of our total emissions.  They make up 16% of the nation’s long-lived greenhouse gases in the 2022-2025 proposed emissions budget.  And, due to the “light-touch” treatment in later emissions reductions, they rise to 22% of long-lived gases by the 2031-2035 budget.

    22. Since nitrous oxide is not part of the NZ Emission Trading Scheme, there is, at present, no market mechanism to limit these emissions. The only control is based upon water quality considerations.  We appear to be at the mercy of other pollution control laws and the good faith of the farming sector to take steps to limit these emissions.  

    23. Further, the lack of guidance on nitrous oxide emissions reductions:
          1) Represents an economic injustice in emissions reductions efforts between New Zealand’s business sectors.  The lack of a tax on    
            nitrogen fertiliser, while the rest of New Zealand pays an ETS tax on carbon emissions, represents an unfair “pass” on long-lived
            GHG for the farming sector.
         2) Ignores guardianship and sustainable principles, given the existing level of nitrate pollution to New Zealand’s rivers and lakes.  We
            simply cannot expect to keep spreading fertiliser on our lands indefinitely without damaging ecosystems.  We must ultimately move
            to sustainable, zero pollution farming practices.
         3) Being primarily an export industry, New Zealand’s farming sector will likely be exposed to international carbon tariffs at some point. 
           These tariffs will increasing become a tool for nations to protect their domestic farming industries.  New Zealand farming can stay
           ahead of these tariffs only by innovating and adopting low emissions practices now.  

    24. We feel it is imperative that the Climate Commission provide some type of policy or market guidance to the government on ways to limit nitrous oxide emissions.  A fee-rebate tax system on nitrogen fertiliser, for example, would use market forces to reduce and refine the use of nitrogen fertiliser, with the proceeds returned to support farmer education and R&D on low-nitrogen farming techniques.

A Stretch Goal to meet the Paris NDC
    25. The Climate Commission has done an admirable job of assembling a set of recommendations to government on how to reduce GHG emissions sufficiently to meet the goals of the Zero Carbon Act.

    26. It points out, however, that these recommendations will not be sufficient to meet the nation’s NDC made for the 2015 Paris Agreement – a 30% drop from 2005 emissions levels by 2030.  The recommendation to address this shortfall is to simply purchase overseas emissions credits, with notes that other countries, such as Switzerland, are already doing this.
 
    27. It is important to recognise, however, that international emissions credits aren’t necessarily a good thing.
 
           1) By their nature, overseas credits are like foreign aid, only with a downstream cost, in that they rob the source country of the
              ability to claim those emissions reductions for itself.  The government of the time might be happy to sell the credits now because
              they won’t be around when their country’s emissions reduction NDC comes due.
           2) While some of these credits represent actual sequestration of carbon emissions, through forestry, for example, others are simply
              programs to avoid future emissions in continued economic development.  These programs might be approved by the UNFCCC, but
             experience shows that relatively few foreign aid projects actually achieve what they set out to do.  As a consequence, there is the risk
             that many of these credits will end up being nothing but hot air, as we have seen with the Ukrainian and Russian credits NZ
             companies bought last decade.
          3) The rich country – poor country dynamics involved in most international emissions credits transactions creates a new kind of
             colonialism.  The poor seller needs to meet the requirements of the rich buyer, losing control of that portion of their economy and
             perhaps their land.  As a rich nation, we should be helping poor nations reduce their emissions without strings attached, not using     
             them to meet our international commitments.
          4) Lastly, the overseas credits will cost us foreign exchange, which is important to our balance of payments and currency stability.  For
              the same amount of money, it would be better to meet these obligations domestically, paid for in NZ dollars.

    28. There is another option – that of a “stretch goal” for the country that would meet this emissions target, in case parliament wishes to try to meet the target with minimal use of overseas credits.  What more could the country do to meet this target?   Where are opportunities for further emissions reductions by 2030?

    29. In that most of the overseas credits that the government might purchase would be of the form of carbon offsets, either through forestry or “green” developments, it is worth noting some of the carbon offset opportunities here in NZ.  Motu Economic and Public Policy Research lists a number of these offset opportunities in a 2017 report (Motu Note #25 – New Offset Options for New Zealand).  To name a few of these offset opportunities:
           1) Terrestrial and marine wetlands are known to be net carbon sinks but are not counted in the national emissions accounting and
               could be.  Their omission is largely due to a lack of understanding about how much carbon is sequestered and how much of other
              GHG emissions (methane and nitrous oxide) they generate.  More research is needed here, which the Commissions should
              reasonably recommend.  In the meantime, however, the other “ecosystem services” and wildlife habitat provided by wetlands are 
              well appreciated, so a national effort to promote, protect and restore wetlands, even if future research shows carbon sequestration is
              insignificant, would be of net national benefit.  We note that New Zealand is a signatory to the 1971 Ramsar International
              Convention on Wetlands, so we should already be doing our best to protect and restore wetlands.
              We submit the Commission should recommend to government that a national program of research, protection and restoration of 
              wetlands, with an eye toward ultimately adding wetlands carbon sequestration toward the national GHG inventory.  
          2) Soils are another known carbon sink which are not accounted for in the national GHG inventory and could be.  As with wetlands,
              NZ research on soils carbon sequestration is limited.  We submit that the Commission recommend to government that a program of
              expanded soil carbon research combined with programs to promote known methods of soil carbon enhancement and soil
              conservation, be undertaken.  This might take the form of carbon credits allotted to farmer who plant carbon-sequestering cover 
              crop during fallow years.  This, again would be with an eye toward adding carbon sequestration by soils into the national GHG
              inventory.
         3) Biochar, or charcoal made from wood waste, is known to be a valuable soil amendment; acting to retain water and nutrients in soils. 
             It is also an efficient form of carbon sequestration; taking wood waste that would naturally decay to carbon dioxide & methane and
             converting it into carbon dioxide and elemental carbon.  Test show that up to 50% of wood waste carbon can be retained as biochar,
            which is stable in soils for potentially hundreds to thousands of years.  There is already a small but active biochar industry here in NZ. 
            We submit that the Commission should request that the government provide stimulus to this industry, perhaps in the form of a
            biochar price guarantee, which would further sequester carbon from our country’s abundant wood waste.

    30. The NZ voluntary offset market has the potential to sequester a significant amount of carbon, provided there are enough offset projects and it is sufficiently subscribed.  Many companies looking for reputational benefits, such as Air New Zealand, already purchase carbon offsets, but cannot find enough domestic offsets to meet the demand of their passenger-funded program.  We request that the Commission recommend to government that it promote the domestic carbon offset market, perhaps by supplying seed money for projects and assistance with certification costs.  At the same time, the Commission should recommend to government that it promote the carbon offset market to NZ industry, as a way for them to claim to be “carbon neutral”.  This could reasonably start with SOEs, such as Air NZ, Genesis Energy, Mercury and Kiwi Rail and be expanded to wider industry and businesses.

We acknowledge that promoting the voluntary carbon offset market might compete with the government’s existing strategy of promoting permanent forests, or at least may represent a duplication of effort.  The thought here is that government should use as many “levers” as available to promote domestic carbon sequestration.

Conclusion
    31. We submit that the points in the submission are in no way a criticism of the Commission or the report.  This first report and carbon budgets represent an important step forward in New Zealand’s transition to address the accelerating climate breakdown happening all around us.  The report has stressed some important, yet perhaps underappreciated aspects of the transition, such as intergenerational justice, Maori partnership and an equitable distribution of benefits and burden.  The Commission is to be applauded for this.  The aim of this submission is to make a great, groundbreaking report, even better.

    32. We wish the Commission to keep in mind, however, that we cannot go on behaving, thinking and treating the world as we have been, exploiting the earth for all the energy and everything else we can get from it now; the future, our descendants and the planet be damned. This is our only home: it is urgent that we remember to treat it and all life that shares it with us respectfully, valuing it for what it is, how it sustains us, not just for the resources it provides. All our submissions concern the means to that end.