Introduction.

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

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

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

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

Submission.

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

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

Inaccuracies and Errors.

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

The consultation document (page 32):

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

The technical annex (page 8):

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

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

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

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

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

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

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

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

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

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

New Emissions Proposals.

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

Carbon Capture, Utilisation and Storage.

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

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

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

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

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

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

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

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

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

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

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

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

Waste minimisation fund.

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

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

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

Organic waste & landfill gas capture.

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

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

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

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

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

This is followed by the footnote:

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

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

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

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

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

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

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

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

Alignment with future emissions reductions.

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

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

Conclusions.

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

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

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

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

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

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

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

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

INFRASTRUCTURE STRATEGY –

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

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

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

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

4.2.3 Cause: Storm Frequency and Intensity Change

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

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

    • Severe thunderstorms will carry more rain in a warming world

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

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

Tunakino (data from 1979 to 2022):

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

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

    • Five times larger than the historic August average


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

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

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

    • Four times larger than the historic August average

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

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

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

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

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

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

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

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

Clause 4(c)(i) of the Climate Action Plan states - “Include assumptions for climate change in the Long Term Plan, including provision for uncertainty, based on latest scientific evidence from the Intergovernmental Panel on Climate Change (IPCC).”

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

SUSTAINABILITY OFFICER –

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

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

THE PRECAUTIONARY APPROACH –

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

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

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

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

SUPPLEMENTARY INFORMATION.

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

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

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

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

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

See HERE AND HERE   for further info.

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

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

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

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

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

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

    • We have to be smarter with our decision making and think and plan ahead, for our grandchildren’s sake please!  

TIWAIWAKA.

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

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

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

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

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

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

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

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

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

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

Climate Karanga Marlborough

CKM presentation to LTP Hearings.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

LETTER TO MINISTER CHRIS BISHOP.

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

Yours, Climate Karanga Marlborough.

TEXT OF VERBAL PRESENTATION TO SELECT COMMITTEE.

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

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

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

Ko Don Quick taku ingoa.

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

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