Submission to the Ministry of Transport ‘Green Paper’ on Transport EmissionsRead Now
Climate Karanga Marlborough (CKM) is a climate action group of citizens of the Marlborough Region, with the purpose “to assist elected representatives and their officials to pursue policies designed to limit the extent of rapid climate change and help New Zealanders to adapt to its consequences”. We are concerned about the rapid advance of global warming and work to assist our community and government at all levels in mitigating greenhouse gas emissions and preparing the country for the challenges that global warming will bring.
On the whole, we support the great majority of the ideas presented in the MoT green paper and feel that the transition of our society to low emissions transport is an urgent necessity. CKM believes that, if we are to achieve our aim of reducing harmful emissions, then not only do we need to make our consumption of energy in NZ more efficient and effective, we all need to expect to consume, and demand, less energy, particularly energy derived from fossil fuels.
The changes needed to our cities, outlined in Theme 1, are important and necessary, particularly when considering the possibility of limited future transport options in the absence of fossil fuels. Transitioning the nation’s light vehicle fleet to battery electric, proposed in Theme 2, seems to be the most straightforward and low risk option for continued automobile travel. The transition of heavy freight, discussed in Theme 3, will be more challenging and will present more difficult choices.
There are four issues which we wish to submit on, however, where we disagree with or suggest greater emphasis on, strategy elements presented of the green paper. These are outlined below.
CKM submits that the MoT should look to the Climate Commission for its recommendation on biofuels. In recommending a moratorium on new fossil gas hook-ups to industry and residences, the Commission suggested that the fossil gas industry first demonstrate that blending of low-emissions gases, such as bio-methane or hydrogen, with fossil gas (the industry’s proposed method to reduce fossil gas emissions) is feasible and will not result in higher costs to consumers (Section 15.1.5 of the final advice). This would prevent the construction of expensive new fossil gas infrastructure, for which locked-in gas customers would be required to pay.
Similarly, the petrol industry is proposing blending of low-emissions biofuels with fossil petrol as a way of maintaining their market share in transport. This might cause consumers to purchase new internal combustion engine vehicles able to accept the blended fuel, or pay to modify their existing vehicles. If these promises of low-emissions fuels do not eventuate at reasonable cost, consumers would then be saddled with the stranded investment. The MoT should first require that the petrol and biofuel industries demonstrate the viability of blended or pure biofuels before committing the nation’s transportation strategy to them.
In conclusion, we urge the MoT to adopt the “precautionary principle” in planning for New Zealand’s future transport. That means sticking to the low emissions transport solutions that are tried and effective, and require the least amount of energy. That means battery electric vehicles, electrified trains and decarbonised coastal shipping.
The country should not be led down the road of biofuels and hydrogen only to find that these fuels don’t work as planned or create a new set of problems. Let others work the bugs out of these systems first. If they work out, they can be added to the transport energy mix at a later date.
Whatever strategy the MoT ultimately adopts for decarbonising New Zealand transport, it goes without saying that this strategy needs to be in alignment with the strategies of other government ministries and commissions. We appreciate that this will be a difficult and time consuming task. The MoT has its work cut out for it, and it has our support.
Thomas Powell, Co-chair, Climate Karanga Marlborough
Climate Karanga Marlborough submission to the Infrastructure Commission re the Consultation Document,
He Tūāpapa ki te Ora. 18 June 2021
Climate Karanga Marlborough (CKM) is a local climate action group purposing “to persuade elected representatives and their officials to pursue policies designed to limit the extent of rapid climate change and help New Zealanders to adapt to its consequences”. We have constructive relationships with the Marlborough District Council and Council staff. Recently, we submitted and presented to the Council re their Long-term Plan for the next 10 years.
We welcome the opportunity to support and submit to Te Waihanga re the Infrastructure Strategy Consultation Document, particularly in the wake of the Climate Change Commission (CCC) report and recent government policy documents, such as The Three Waters Reform Programme.
1: We have read the Infrastructure Commission’s response to the Climate Change Commission’s 2021 Draft Advice. Regarding the scale of transition required to meet the recommendations of the CCC, we welcome your statement in response: “Te Waihanga see that infrastructure has an important role to play in facilitating the transition, particularly transport, energy, waste and social infrastructure.” In fact, in principle, with few reservations, we also welcome the tenor of your response. It accords with our request, when presenting to our local council that their entire work programme be viewed through a climate change lens, always using a precautionary approach and taking a long-term view. – Not just to the next turbulent 30 years, but to the impacts well beyond!
2: As with Te Waihanga’s response to He Pou a Rangi, CKM finds itself in accord with many of the options for action put forward by Te Waihanga in developing the 30 year Infrastructure Strategy: -
In particular, preparations for climate change/global warming; reducing demand for energy consumption, eg enabling both active and renewable energy-based public modes of integrated transport; resourcing ongoing cross-national data collection and information analysis for transparent modelling and planning for evidence-based development; avoiding siloed thinking, which entails enabling cross-boundary communications and actions; ensuring equitable (fair, inclusive and affordable) funding and financing; making better use of existing infrastructure and considering non-built options, particularly towards behaviour change.
CKM acknowledges your 5 proposed priorities, particularly in the light of what you say you have heard through the Asset Owners’ Survey.
We do not argue with your stated outcomes and principles, as such.
3: In response to your asking for our views on the proposed 2050 infrastructure vision for New Zealand, it seems to us that the vision, as described, is constricted and defined more by what is not in the vision than what is in it. In our opinion, you have missed some opportunities to lay out an expanded vision of building infrastructure in alliance with the natural world and with te Ao Māori.
4: “All decision-making about infrastructure must be guided by Te Tiriti o Waitangi (the Treaty of Waitangi) and its principles, but specifically by the obligation to partner with Māori. As well as this, we propose a fundamental principle that infrastructure should support oranga tangata or the wellbeing of people.” (p08)
In response, we say that Te Tiriti and the Treaty are not the same documents, and the Commission needs to address the differences.
Also, the “obligation” lies specifically, both in legal and moral terms, with the articles of the Treaty, rather than with the so-called principles. Partnering with Māori should not be seen as an obligation but, at the very least, an opportunity! The added statement, starting “as well as this”, reads like an escape clause: escape from the clauses in the previous statement.
5: “There appears to be a lack of meaningful relationships between iwi/Māori and many key infrastructure players (Crown and private.) …
The current resource management approach is not working for Māori due to a lack of meaningful involvement, as well as consultation fatigue on both sides.”– Probably not surprising, given that the Pākehā desire for ‘infrastructure’ has led to Māori land dispossession over 180 years. Both ‘sides’ are moving from a position of lack or loss of trust.
In answer to the 3 associated questions, we respond thus: Q15 – maybe not for us to say, but we suggest continuing to ask Māori without pre-empting the answers: keep listening, talking and building trust. Q16 – explore the meanings of land and infrastructure, whenua and taonga. Q17 – not for us to answer, but we can ask you whether and how Māori are actually being allowed to lead?
6: In regard to how CKM understands the relationships of land, water and air to infrastructure, we believe in the principle of respecting the natural world, in all its manifestations, as our ally, not simply regarding nature as a resource, as we believe that unconsidered exploitation of natural resources has led to the disruption of the climate that we now face. The simplest way of doing this from our viewpoint is to recognise that people are not separate from nature and that we are just one part of nature’s biodiversity. Thus, any infrastructure in which we may wish to invest must be in agreement with nature and nature’s biodiversity. Ways of doing this have been thoroughly explored in The Dasgupta Review: The Economics of Biodiversity, a report commissioned by the UK government and released in February. 2021. We recommend this report to you.
We also believe that our viewpoint corresponds to Māori concepts of whakapapa and of rangatiratanga as used in Article 2 of Te Tiriti. We have come across reference to the ‘environment’ often enough in Infracom’s Consultation Document but neither to nature nor to biodiversity.
We ask that Te Waihanga reconsiders and redefines its statement about how it thinks about infrastructure (in ‘Infrastructure under one roof’) in terms that both Māori and most people who respect the natural world and its creatures can relate to personally.
7: Developing this idea of relating human settlement to the natural world, we recommend that Te Waihanga places much more emphasis on bringing the natural world into cities. Although recent research on this in Aotearoa specifically is limited, there is plenty of international evidence that this both benefits the wellbeing of city dwellers and their relationship to and understanding of nature:
The following links are references in support.
It’s official: City parks make us happy - Outside our doors -
and also benefits the natural world and biodiversity.
Biological corridors throughout the length of New Zealand -
What are wildlife corridors? (Australian government)
Neither Te Tūāpapa ki te Ora nor the Infrastructure Commission’s submission on the Urban Development Bill takes the opportunity to put the relationship between human beings and the natural world at the centre of how we develop our infrastructure. An almost exclusively anthropocentric approach historically has got us to where we are now, in terms both of our environment and the climate. (cf The Dasgupta Review.)
Discussion Q21 as to whether a “10-year lapse period for infrastructure corridor designations is long enough” is pertinent here. CKM’s advice is that a 30-year plus period for such “spatial planning” is minimal from the point of view of the natural world and probably also of te Ao Māori. The discussion that precedes this question in the Consultation Document is set in terms of “lead infrastructures” and “corridors”. It is CKM’s view that if nature and wildlife were to head these terms, then Infracom’s planning would become much more inclusive, considered and relevant to the climate changes we are all facing.
8: In further consideration of the relationship between human settlement and the natural world, CKM is very concerned that Te Waihanga is overly focused on the nuts and bolts of urban development at the cost of a whole-of-New Zealand approach. We understand totally that Te Waihanga is facing the legacy of decades-long neglect of urban planning and maintenance of infrastructure, particularly evident in our major cities. Yet it is vitally important, in scrambling to guard the future of our cities, that we do not neglect to resource rural and provincial infrastructure in terms of climate and environmental change. In a hundred years’ time, our coastline, including city borders, will have changed and populations will have changed in terms of scale, placement and movement that are hard to anticipate in the face of climatic, environmental and political uncertainty. In reactively “mitigating … and adapting to the effects of climate change”, we must remember that we can also proactively bring about change, not only in mitigating our own impacts on climate and the natural world but also by adapting how we settle in and with the world.
In that regard, we appreciate discussion questions Q13 and Q14. Our response to these is that in New Zealand we might seek to counter population decline in non-urban communities (through transport, housing, work and amenity options) and develop a Population Strategy focusing as much on a preferred population distribution as on a growth path. How New Zealand plans its infrastructure is central to that.
9: In terms of action, CKM recognises that Te Waihanga does not have a decision- or investment-making function. We wholeheartedly support the proposed priority in the consultation document for “better integration and coordination between local and central government infrastructure functions”. We would add to that the importance of collaboration with the community and volunteer sectors, which would require active support, resourcing and funding at both local and central government levels. Such a collaboration would be essential to understanding “the growing gap between the demand for infrastructure and the funding available or the willingness to pay for it”. In particular, it could enable a reduction in demand for infrastructure that requires growing investment of energy, specifically fossil-fuel energy, which is not only primarily responsible for environmental damage but is also rapidly rising in cost.
10: CKM’s final recommendation to Te Waihanga regards energy descent, product stewardship and the circular economy. CKM takes the view that reducing consumption, especially of energy, and avoiding waste are the critical changes that we all need to make in limiting global warming, mitigating the excesses of climate change and beginning to care for our planet. This is what we mean by energy descent. But changing our demands for energy requires not only reduced consumption but also changes in how we supply energy. As long as energy supply is based simply on profit out of production geared to growing demand, there will be no energy descent. Responsibility for change rests on all involved. Responsibility for reducing the impact on climate and the environment of any product rests as much with producers and marketers as with consumers, entailing a process of product stewardship.
Whilst we acknowledge that there are a growing number of product stewardship schemes in Aotearoa, CKM urges Te Waihanga to lay much greater emphasis on energy descent, product stewardship and the circular economy in its recommendations to government. CKM recognises that these must surely be central to how Te Waihanga thinks about infrastructure, but this is really not apparent in the principles and priorities laid out in the Consultation Document. The government, and therefore Infracom and the taxpayer, tend to be seen as responsible for end-of-the line waste management, but the taxpayer needs better informed about what a circular economy means, about waste management options and responsibilities. It is up to the government to make clear nationally and internationally what national policies we have in Aotearoa with regard to product management, so that not only consumers and manufacturers but also importers understand the responsibilities, the costs and the benefits.
As a lead player over the next 30 years, Te Waihanga, on behalf of all New Zealanders, has the opportunity to lay out an expanded vision of building infrastructure together with nature and the responsibility to karanga,
to summon the government boldly and publicly to describe clearly its own vision in response, to pick up the wero, to accept the challenges presented to it in planning and designing in partnership an infrastructure for Aotearoa fit for the next 30 to 100 years.
A: We have introduced ourselves as Climate Karanga Marlborough (CKM) and identified a constructive relationship with our local Council.
B: We appreciate the opportunity to submit. In doing so, we have expressed both our support for what Te Waihanga has proposed and also our opinion that it has missed the opportunity to present a bigger vision.
C: We have responded to your questions about relationships with the Tangata Whenua.
D: We have outlined how we understand people to be part of nature, not separate from it, and we have recommended that any infrastructure in which New Zealanders may wish to invest must be in favour of nature and nature’s biodiversity, in line with recommendations from the 2021 Dasgupta Review, which was commissioned by the UK government and which we have recommended to Te Waihanga.
E: Accordingly, we have asked that Te Waihanga explain further how it thinks about infrastructure.
F: We have explored the importance of relationships between human settlement and the natural world and made recommendations accordingly.
G: We have recommended that Te Waihanga articulate how it might engage with the community and volunteer sectors.
H: We have urged Te Waihanga to lay more emphasis on practices of energy descent, product stewardship and the circular economy.
I: We believe Te Waihanga has a key role in supporting the government in dealing with climate change challenges over the next 30 to 100 years.
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