Contribution to Marlborough Airport focus group interview from Budyong Hill representing local activist group Climate Karanga Marlborough (CKM). 20/10/2023
To quote from your information document - “In the context of this interview, we’ll refer to business/corporate sustainability that considers Environmental, Social and Cultural, and Economic drivers. One way of looking at it is as a three-legged stool with each leg representing a driver held together by governance, which is the seat. The interview is set up as an open conversation to address these drivers and explore what is going well, what requires improvement and what the future might hold.”
I believe that exercises like this can often be of little use if there is not a realistic and honest view of “what the future may hold”, so that is the area that I wish to focus on. I am a firm believer that without a viable, healthy and sustainable environment there is no future for the other two drivers. In fact I would go so far as to say the three legs of the stool have to be Environment, Environment and Environment.
Simply put without a healthy environment there is no economy. I also see little point in limiting our view to Marlborough or even to NZ, when it comes to discussing what the future may hold. In the modern world we are inextricably connected to the global environment and must make our assessments and decisions with this fact foremost in our minds.
Taking this into account I therefore wish to share some basic facts and information.
1) The dominant economic system in the developed world has, as a primary goal, the growth of GDP. Our economic system relies on this perpetual growth to continue functioning. To maintain a growth rate of 2 – 3% the throughput of materials and energy needs to double approximately every 25 years. (If your country's GDP grows at 3% a year, the economy doubles in 72/3 or 24 years. If your growth slips
to 2%, it will double in 36 years.) This is an exponential increase. It means doubling and then doubling the new amount every 25 years. Basic maths tells us this will end badly.
2) There are a range of ways of assessing what humanity’s impact on the biosphere is but there is general agreement that we are currently using about 1.8 times more than the planet can regenerate. This is known as overshoot which we have been in since the 1970’s. (More info) Again this can only end badly if we continue with our heads in the sand thinking we are so smart that our technology will solve these existential problems.
3) Scientists have identified 9 critical boundaries that our human civilisation needs to stay within if we wish to retain a liveable planet. At this point in time we have exceeded 6 of the 9 boundaries. Three of them cover what we take from the ecological system. They are loss of biodiversity (extinction of species), loss of fresh water (pumping too much water from rivers and aquifers) and land use (deforestation).
The remaining six boundaries concern the waste our activity adds, to what would have occurred naturally. They are: greenhouse gases which cause climate change; ocean acidification (carbon absorbed by the sea); emission of chemicals that deplete the Earth’s ozone layer; ‘‘novel entities’’ (synthetic chemicals such as plastics, DDT and concrete); aerosols; and nutrient overload (nitrogen and phosphorus from fertilisers that wash into rivers and the sea, causing algae blooms, killing fish and coral).
Crossing any of these boundaries doesn’t trigger immediate disaster. But it does mean we’ve moved from the safe zone into dangerous territory. And the nine boundaries are interrelated and interacting, in ways we don’t yet fully understand.
In 2009, the scientists found we’d already crossed three boundaries: biodiversity, climate change and nutrient overload.
By the 2015 update, a fourth boundary had been crossed: land use.
And by this year’s update, only three boundaries hadn’t been crossed: ocean acidification (but only just), aerosol pollution, and stratospheric ozone depletion – where an international agreement banning CFCs is slowly reducing the ozone hole we created.
4) If NZer’s want to reduce their consumption of resources and energy to a sustainable level we need to reduce our use to at least 50% of current levels. This is of course what we should do if we believe in fairly sharing the resources provided by Papatuanuku that we take for granted every day. Think energy, minerals, fresh water, food, a life supporting atmosphere, living oceans, topsoil, forests, etc etc. We are using far more than our fair share per capita. There are billions of people whose consumption needs to rise simply to meet their basic food, shelter, health etc requirements. We need to consume much less so their living standards can rise to a basic level.
5) Taking into account this basic information we would suggest it is wise to reassess our future direction and confront the realities of a post carbon society now. In the context of this exchange that means all airport companies and airlines will have to do everything they can to discourage people from flying. Tourism should not be encouraged because it has a high carbon impact. We need to reassess our priorities and only fly when absolutely necessary.
6) None of the required changes essential to our collective survival are likely to happen if our decisions continue to be driven by the profit motive.
7) We would like to highlight the current increase in litigation in your industry globally. “A wave of anti-“greenwashing” litigation is seeking to hold major players in the aviation industry to account for sensational claims of being sustainable, low-carbon or contributing to net zero. While the industry has faced legal backlash in the past, the dramatic proliferation of these cases may spell disaster for major airlines.”
Airlines are being hit by anti-greenwashing litigation – here’s what makes them perfect targets.
8) There are also a range of concerns we would like to add regarding the risks of future global warming and climate mitigation action to the air travel industry:
• Increasingly inclement and unpredictable weather will make air travel trickier. People will increasingly look for more reliable modes of travel.
• Air travel is destined to become more expensive due to the increased cost of SAF (sustainable aviation fuel – probably mostly from biofuel) relative to fossil fuels. International travel has gotten a “pass” so far, but this can’t last. A recent analysis suggested that SAF is about twice the
price of fossil kerosene.
• There will be growing political pressure not to devote farmland to growing crops for SAF. With much of the world already suffering from hunger, crop failures due to accelerating global warming will make this worse. Where there is a trade-off between feeding people and bringing in tourists, the tourist industry will lose.
• Even with SAF, nearly half the warming due to long to medium distance air travel is due to changes to the stratosphere, where these planes fly, and not from exhaust CO2. Water is rare in the stratosphere and aircraft contrails add a lot. And, water is an intense greenhouse gas. At the same time, stratospheric clouds tend to bottle more heat into the atmosphere than reflect incoming solar radiation back to space. Burning anything to keep airplanes flying in the stratosphere is essentially unsustainable in a warming world.
9) Bill McEwan is a CKM member who wrote to the Marlborough Airport company on more than one occasion in an attempt to highlight the issues we are again raising in our contribution to this focus group. Other than one brief acknowledgement to his first letter dated July 14th , 2021 he received no response to his correspondence. It may well be that MAL management deemed his correspondence represented an extreme view and that they therefore had no need to take it seriously? We think it would have been quite reasonable for MAL to show basic etiquette towards the concerns of a local ratepayer (and a representative of our local climate action group), by responding to his very pertinent questions.
We realise that it is unlikely MAL will seriously address the matters Bill raised and that are included in this document. The economic imperative drives us all onwards towards disaster. It appears that facing the true reality of our predicament requires more than we can collectively give. To be honest with ourselves is just too daunting. How much worse will things get before this mindset changes? Therefore
we don’t make this contribution wanting to denigrate MAL but rather to highlight the very difficult challenges facing all of humanity. The issues that MAL must confront are the same issues we all must confront. Together we have kicked the can down the road for too long now.
We believe the time for incremental changes to our existing economic system and trying to incentivise businesses to change their business models are well past. Is there some way we can greatly reduce our consumption so we can retain a viable biosphere and at the same time maintain a functioning economic and social structure? We don’t know the answer to this question. There are theories and ideas for alternative ways of organising our world that if executed may indeed help by prioritising our collective and planetary wellbeing over profit.
For instance a steady-state economy follows two key principles in order to stay in balance with the living world:
1) Never extract more than ecosystems can regenerate.
2) Never waste or pollute more than ecosystems can safely absorb.
What we are convinced of is the certainty that continuing business as usual will result in the ever increasing frequency and magnitude of disruptions to our lives and to the lives of every other species on our amazing planet.
We wish to finish with some quotes that we hope will stress the seriousness of what we all face.
Antonio Guterres -
“The era of global warming has ended. The era of global boiling has arrived.” This statement was made after July 2023 had become the hottest month in the past 120,000 years. He also said that “humanity has opened the gates of hell” by unleashing worsening heatwaves, floods
and wildfires seen around the world and that a “dangerous and unstable” future of 2.8C global heating, compared with the pre-industrial era, was awaiting without radical action. At the COP27 climate change summit in Sharm el-Sheikh, Egypt, he said “We are in the fight of our
lives, and we are losing. Greenhouse gas emissions keep growing, global temperatures keep rising, and our planet is fast approaching tipping points that will make climate chaos irreversible. We are on a highway to climate hell with our foot still on the accelerator.”
Pope Francis -
“The idea of infinite or unlimited growth, which proves so attractive to economists, financiers and experts in technology ... is based on the lie that there is an infinite supply of the earth’s goods, and this leads to the planet being squeezed dry at every limit.” AND
“Yet all is not lost. Human beings, while capable of the worst, are also capable of rising above themselves, choosing again what is good, and making a new start.”
You can read our submission below. The questions in bold are from the MDC consultation document. If you wish to see this document, which has good background information and a summary of the values and visions that came out of the first round of consultation then you can do so on their website.
NPS-FM 2020 COMMUNITY ENGAGEMENT - ROUND TWO.
Thank you for the opportunity to respond to the proposed values, visions and environmental outcomes as defined after the first round of consultation. As you can see in our earlier submission our focus is on the Wairau FMU, specifically on the health of the Wairau aquifer and how we best manage our efforts to maintain the health of the aquifer, particularly considering the observed ongoing, declining trend in the aquifer. Our original submission lays out our belief that "ecosystem health" must always be given the highest priority above the other three compulsory values in all freshwater management decisions throughout all the FMU's. We have a concern that the incoming government may wish to diminish the "Hierarchy of Obligations" laid out in the National Objectives Framework (NOF) and would be dismayed if this should happen. We ask the MDC to be alert to and to resist any such diminishment.
Do you agree with the proposed values?
Climate Karanga Marlborough (CKM) agree with the proposed values that have resulted from the first round of consultation. We give our support to these values on the understanding that “ecosystem health” always be given highest priority. We believe that any pressure exerted by
people who wish to interfere with values related to ecosystem health should be resisted.
We do wonder if something essential has been missed in defining the values. We absolutely support the importance of giving consideration to Wai Tapu. Yet beyond that we see an overarching value, which may be defined as the Mauri, the Life force, of the Wairau River and all its associated tributaries and aquifers. Vibrant ecosystem health is the means of knowing if that Mauri is healthy and intact. In our first submission we stated that “the goal of human freshwater management practice must be to respect te Mana o te Wai, to recognise water as having needs beyond just being a resource for human beings, and for us to work with Nature and processes natural to Aotearoa rather than against them.” Naturally we believe this value should apply equally to all FMU’s. Water is Life – it’s as simple as that.
Do you agree with the proposed visions?
Overall, CKM support and agree with them and we would go further. The statement in your
document, “The health of the waterbodies and freshwater ecosystems are maintained, protected,
and enhanced for current and future generations” implies current and future generations of
humankind. From our perspective the maintenance, protection and enhancement must be done
primarily for the ecosystem itself, for Papatūānuku. Human beings are just one of the multitude of
current and future generations of living species that rely on “the waterbodies and freshwater
ecosystems” for their survival. We are inextricably connected with all the other species. We would
encourage removing any expression of a dominating human supremacist view that can tend to take
precedence in vision statements such as this. A recognition of our role as stewards would not go
Do you think we are meeting these visions now?
In regard to the Wairau Aquifer we would have to say no. Our concerns are well laid out in our
In the proposed vision you state - “The Wairau River and its tributaries, the Wairau Aquifer and
Wairau Plain Springs are protected and enhanced, continuing to be highly valued throughout
Marlborough for the wide range of benefits they bring to the region.” We fully support this vision,
but we note once more that there is no recognition of the specific issue of the declining trend in the
aquifer. The significant impact on the Mauri and health of the springs in particular, and aquifer ingeneral, should this trend continue, let alone the potential impact on users of the aquifer water
seems relevant to us. Thanks to the wisdom of the MDC in commissioning scientific research work
on the Wairau aquifer, we now have a good knowledge of what the main contributors to the
declining trend are, but still don’t know if the recharge of the aquifer can be improved enough to
reverse this trend. It seems possible to us after studying the Gravel Beds River research that the
historic confining of the river between its stop banks may be a factor that cannot be overcome just
with changed management methods and that the decline may continue despite all our best efforts.
This begs the question - to what degree can we allow nature and the river itself to take their course
in restoring the health of the aquifer? We are not clear how this knowledge can be best expressed
within the values, visions and environmental outcomes categories?
Do you agree with the proposed environmental outcomes?
We note in your document’s statement, “Healthy functioning ecological processes occur in
waterbodies and their margins, including primary production, nutrient cycling, trophic connectivity
as well as life cycle functions such as feeding, migration, reproduction”, that primary production
takes precedence. We accept that this list of “healthy functioning ecological processes” may not be
in any particular order of priority, but we find it telling that primary production comes first. From
our perspective “life cycle functions such as feeding, migration, reproduction” are of the highest
priority. Primary production must be subservient to these functions. In other words, if compromises
are required, then they should be made first by those wanting to engage in primary production not
the other way around. The statement of environmental outcomes should reflect this.
There is a human tendency for making grand statements of intent, yet when the pressure builds for
utilisation of nature and its resources, too often human needs are prioritised above those of
Papatūānuku. So, CKM is encouraging vigilance at all times to ensure that ecosystem health always
comes top priority, even if that means we have to forgo previously assumed rights over freshwater
and access to freshwater. If we can do this, then all species reliant on these lifegiving waters, not
only humankind, will reap the rewards.
Responses to questions
Section 1: Hydrogen is emerging as an important part of the future global energy system
1. Are there other issues we should be considering in our assessment of the strategic landscape for hydrogen in New Zealand?
1. Safety: There is no mention of program support for the safe transport of hydrogen. It is presumed that the network of hydrogen fuelling stations around the country will be serviced by tanker trucks carrying compressed hydrogen. As with any form of road transport, there will be accidents and local fire & emergency personnel will be needed to respond to these accidents. Compressed hydrogen presents serious safety risks to these personnel. For example:
- Hydrogen has no smell and when prepared for fuel cells, cannot be oderised. Local firefighters will need special sensors to detect leaking hydrogen at an accident site.
- Hydrogen burns with a flame that is invisible in daylight. Firefighters will need special equipment to detect burning hydrogen at an accident site.
- Hydrogen has very low ignition energy and can spontaneously explode when decompressed. Compressed hydrogen presents a serious explosion hazard to rescue personnel.
If hydrogen is to be transported around the country in tanker trucks, the skills and equipment of local emergency personnel nationwide will need to be upgraded. This should also be part of the hydrogen roadmap.
2. Leakage: One of the unavoidable realities of hydrogen is that it leaks through most materials, including the carbon composite fuel tanks of fuel cell vehicles. . The International Energy Agency estimates that with increasing hydrogen demand could lead to as much as 5.6% leakage by 2050. Leakage from transportation applications (trucking & storage) is considerably larger than that from fixed industrial applications. while that for industrial processes is assumed to be around 0.5%.
3. Global Warming: While the main focus on leakage has been to prevent hydrogen from reaching explosive concentrations in air (above 3-4%), there has been little attention given, until recently, to low level leakage which will have a climate impact. Recent studies have shown that hydrogen has a global warming potential of 11.6 times that of CO2 over 100 years (GWP100), but an estimated GWP of (~2.4 years). It is not itself a greenhouse gas; its warming effect is due to its rapid reaction with atmospheric hydroxyl ions, which results in prolonging the life of the intense greenhouse gas methane and contributing to the production of the other greenhouse gases, such as tropospheric ozone and stratospheric water vapour.
4. Water Demand: Simple chemistry suggests that it takes 9 kilograms of water to make 1 kilogram of hydrogen by electrolysis. This will put additional pressure on freshwater resources. Seawater can be used, but traditional methods of electrolysis produce toxic and corrosive chlorine ions (i.e., Cl- and ClO-) which should not be released to the environment. Many electrolysis processes use water treated with alkali or acid, which would similarly need to be disposed of safely and kept out of the environment. There is no mention in the assessment of the environmental risks presented by water demand and waste water disposal related to green hydrogen production.
Section 2: The role for hydrogen in New Zealand’s energy transition
2. Do you agree with our assessment of the most viable use cases of hydrogen in New Zealand’s energy transition?
The assessment given in the consultation document is highly favourable toward green hydrogen while missing or only briefly mentioning some of the many downsides to hydrogen as an energy fuel. A more balanced assessment would include:
1. Efficiency: Green hydrogen used for combustion or fuel cell energy in transport is very inefficient compared to the direct use of electricity through batteries or overhead electrification, as with electric trains. Battery electric vehicles are approximately 3 times more efficient in the use of electricity than fuel cells or internal combustion engines fuelled by hydrogen.
New Zealand is depending upon an ample supply of renewable electricity to replace fossil fuels, yet renewable energy supply will only grow at a pace that the wholesale price of electricity allows. In our current electricity market, increasing electricity prices are needed to promote growth in renewable generation. With an expectation of a long-term increase in electricity prices, it makes no sense to invest in low efficiency uses of electrical energy.
2. Impact on Electricity Prices: Electrical energy used to make green hydrogen will be energy not available to other consumers. Although hydrogen consumers are expected to help with generation, they can also simply purchase electricity from third party generators. It is wishful thinking that an over-build of intermittent renewable electricity will be sufficient to supply the power needed for the high capacity factor (80-90%) that electrolysers will require to be economic.
Growth in hydrogen users, then, will create further demand for electricity. The laws of supply and demand dictate that greater demand will result in increasing price, as more “marginally economic” renewable energy projects will be needed to fulfil added demand due to green hydrogen production. In New Zealand’s deregulated electricity generation market, we would expect to see average electricity prices rise due to the added demand from hydrogen producers.
This does not meet with the expectation of a “just transition”. Residents and businesses in New Zealand should not have to pay more for their electricity due to the electricity demand created by a hydrogen fuel production industry.
3. Practicality: There are a number of hydrogen fuel uses proposed in the consultation document which show very marginal practicality. Examples include:
a. Aircraft: compressed hydrogen, at the 350 bar pressure NZ standard, has the density of expanded polystyrene. The space requirement for hydrogen fuel tanks on even medium range aircraft is impractical. Liquefied hydrogen fuel is even more impractical because it takes roughly 40% of the energy embedded in the hydrogen fuel just to liquefy it. In addition, even in the most well-insulated storage vessels, liquefied hydrogen loses about 1% of its mass each day due to boil-off. In NASA space rockets, typically 45% of liquefied hydrogen fuel is lost before launch.
b. Energy Storage: Storage of hydrogen for peak or back-up generating capacity is one of the least efficient forms of energy storage. Battery storage returns more than 80% of stored energy. Pumped hydro returns about 75% of stored energy. Green hydrogen storage, in compressed gas tanks or underground, will return, at most, 30% of stored energy. when commenting on the early NZ Battery project option to store hydrogen for “dry year” back-up power. The option for green hydrogen storage has since been dropped from the NZ Battery project list of options.
3. Do you support some of these uses more than others?
We support green hydrogen used in industrial processes and as feedstock for aviation and ship fuel, as there are few alternative technologies at this time and it is important, for strategic purposes, that New Zealand has its own source of aviation and ship fuel. We do not support the use of green hydrogen as a direct fuel for heavy transport. It is highly inefficient, hazardous to transport and store, and new research is showing that it is an intense indirect greenhouse gas. Existing battery electric heavy transport vehicles are nearly equivalent in performance and are much more efficient, safer and will require much less support infrastructure (i.e., refuelling stations, electrolysers, storage tanks, etc.). The greater infrastructure and equipment requirements of hydrogen transport fuel compared to that needed for battery electric vehicles will necessarily have greater embedded fossil fuel emissions and environmental impact. The less kit we have to buy, the less impact on our environment and biodiversity.
4. What other factors should we be considering when assessing the right roles for hydrogen in New Zealand’s energy transition?
Hydrogen, as a gas or liquefied, should not be used as a transportation fuel. Due to its ability to leak through nearly all storage materials, its explosivity and its global warming potential, hydrogen is most appropriately used as feedstock for other fuels or chemicals, or used in industrial processes, such as steel making. In these instances, it can be created and used at the same site, reducing leakage and allowing for tight safety controls.
As a transportation fuel it will need to be transported, stored and transferred between storage tanks, allowing for significant leakage and global warming effects, as well as exposing the general public and emergency personnel to its inherent risk of ignition and explosion.
5. Do you agree with this assessment of the potential for hydrogen supply and demand in New Zealand?
The assessments are far too optimistic for the following reasons:
1. Electricity prices have been steadily increasing since the inception of the electricity generation market and are unlikely to fall as demand increases and new generation is added. The easy and cheap renewable generation projects have all been built and as demand increases the next generation projects will be the ones that are more expensive and more difficult to build, such as offshore wind. In addition, new generation from wind and solar are intermittent and will need some type of energy storage in order to be reliable, which will add to their cost. The assumption that electricity prices will fall due to an influx of cheap renewable power is highly unrealistic.
2. The assumption that electrolyser capital costs will drop to a fifth of their present level (from $1000/KW capacity to $200/KW) by 2050 is highly optimistic. The price of most electrical equipment has been rising in recent years.
3. Considering the high capital cost of electrolysers, they will need to run at high capacity factor, as mentioned in the consultation document. The need for high capacity factor is key to the economic success of industrial projects and is unlikely to fall as suggested in the consultation document. It is unrealistic to think that electrolyser operators will readily agree to demand response services (i.e., shutting down when electricity demand on the national grid it high) without compensation.
4. Operations tied to new renewable (and therefore intermittent) generation will require a contract for back-up power, which will likely come from the national grid. This would be expected to add to electricity demand and further increase electricity prices.
6. Do you agree with the key factors we have set out that are likely to determine how hydrogen deployment could play out?
The key factors put forward in the consultation document neglect to mention environmental and social factors.
1. Due to the hazardous nature of compressed hydrogen, many communities will not want hydrogen production and storage in their neighbourhoods.
2. Due to the fresh water and waste water demands of electrolyser plants, many communities will not want the potential pollution and fresh water allocation.
3. Hydrogen being an indirect greenhouse gas, it is likely that leaked hydrogen will be added to the NZ Emissions Trading Scheme at some point. This will add cost to hydrogen vendors which will be passed on to consumers.
7. What do you think needs to happen to address these factors?
While a reasonable case can be made for green hydrogen in the production of low emissions fuels and industrial process such as steel making, the use of green hydrogen as a transportation fuel will be expensive and problematic. People will not want hydrogen production or storage facilities in their communities. The odd accidental explosion of hydrogen fuel will further sour public perception of its safety, as we’ve seen overseas.
Continued revelations as to the climate impact of leaked hydrogen can be expected to further damage its reputation and desirability among consumers. Add to this the poor efficiency, expected high cost and impact of electricity prices that will accompany large scale green hydrogen production and distribution and we see no future for hydrogen as a transport fuel.
8. Do you have any evidence to help us build a clearer picture?
Recent research has shown that hydrogen is an intense indirect greenhouse gas. A peer reviewed journal article, by scientists Ilissa Ocko and Steven Hamburg (Climate Consequences of Hydrogen Emissions, Atmospheric Chemistry & Physics Vol 22, issue 14, 2022) lays out the science behind hydrogen’s climate impact. A copy of this article is included with this submission.
To quote the article:
“Scientists have long known and cautioned that hydrogen has indirect warming impacts (Ehhalt et al., 2001; Derwent et al., 2001, 2006, 2020; Prather, 2003; Schultz et al., 2003; Warwick et al., 2004, 2022; Colella et al., 2005; Wuebbles et al., 2010; Derwent, 2018; Paulot et al., 2021; Field and Derwent, 2021). When it escapes into the atmosphere, hydrogen has two main fates: around 70 %–80 % is estimated to be removed by soils via diffusion and bacterial uptake, and the remaining 20 %–30 % is oxidized by reacting with the naturally occurring hydroxyl radical (OH), yielding an atmospheric lifetime of around a few years (Rahn et al., 2003; Derwent, 2018; Paulot et al., 2021; Warwick et al., 2022). The oxidation of hydrogen in the atmosphere leads to increasing concentrations of greenhouse gases in both the troposphere and stratosphere, as described in Fig. 1 (Derwent, 2018; Derwent et al., 2020; Paulot et al., 2021; Field and Derwent, 2021; Warwick et al., 2022).
In the troposphere, less OH is available to react with methane; given that methane’s reaction with OH is its primary sink, this leads to a longer atmospheric lifetime for methane which accounts for around half of hydrogen’s total indirect warming effect (Paulot et al., 2021). Moreover, the production of atomic hydrogen from hydrogen oxidation in the troposphere leads to a series of reactions that ultimately form tropospheric ozone, a greenhouse gas that accounts for about 20% of hydrogen’s radiative impacts (Paulot et al., 2021). In the stratosphere, the oxidation of hydrogen increases water vapor, which, in turn, increases the infrared radiative capacity of the stratosphere, leading to stratospheric cooling and an overall warming effect on the climate because energy emitted out to space is now from a cooler temperature; this stratospheric effect accounts for about 30% of hydrogen’s climate impacts (Paulot et al., 2021).
The key to preventing global warming due to hydrogen is preventing leaks and discharges. Unfortunately, it is not presently possible to quantify the amount of hydrogen leaking through production, storage and transport systems due to the very low detection limits monitoring equipment will require. Leakage from present systems is estimated in the above reference to be as high as 10%. If liquid hydrogen becomes widely used, this rate of leakage could be higher due to venting of boil-off.
The abstract to the article presents the conclusion that:
“green hydrogen applications with higher-end emission rates (10 %) may only cut climate impacts from fossil fuel technologies in half over the first 2 decades, which is far from the common perception that green hydrogen energy systems are climate neutral.”
The last three of five recommendations of the article are:
“3. improve quantification of hydrogen leakage rates by developing technologies that can be taken into the field to accurately measure hydrogen emissions at low detection thresholds (i.e., ppb level);
4. include the likelihood of hydrogen leakage and its impacts in decision-making about where and how to effectively deploy hydrogen – such as co-located production and end-use applications; and
5. identify leakage mitigation measures and best practices before building out infrastructure.”
Given the scientific findings on hydrogen’s global warming impact and the lack of information about hydrogen leakage rates from production, transportation and storage, the precautionary principle dictates that we should wait to deploy hydrogen as an energy fuel until the leakage is better understood. We do not want to be in the position of simply trading one greenhouse gas emissions problem for another.
9. Do you agree with our findings on the potential for hydrogen to contribute to New Zealand’s emissions reduction, energy security and resilience and economic outcomes?
No. There is no mention of the likely impact of hydrogen production on electricity prices. In New Zealand’s electricity market, the added electricity demand for hydrogen production will increase electricity prices, since it will require the construction of what would otherwise be marginally economic electrical power projects. The cheaper projects will have already been built. These new projects will demand an increase in price in order to be economic. The law of supply and demand will dictate higher electricity prices for the added generation capacity.
An earlier statement in the consultation document that new renewable energy will be cheaper to install because cost for kit has been falling has not been borne out by experience. Wholesale electricity prices have only been going up for the last two decades even as lots of new renewable generation has been installed.
Flexibility in demand response, touted as a benefit of green hydrogen production, will undoubtedly come at a price. Operators will not agree to shut down electrolysers without getting something back for it – which is likely to be cheaper electricity. This can be expected to further raise electricity prices for the rest of the economy.
10. Do you have any insights we should consider on what is needed to make hydrogen commercially viable?
At the moment, green hydrogen is not a commercially viable energy fuel. We see little evidence that this situation will change in the near future.
11. Is there any further evidence you think we should be considering?
There is the very real possibility that the global warming impact due to the unavoidable leakage of hydrogen will make hydrogen unsuitable as a transportation fuel and will result in the failure of the hydrogen fuel industry. New Zealand should wait to develop widespread hydrogen use until hydrogen leakage and its global warming impact are better understood.
Section 3: Government position and actions
12. Do you agree with our policy objectives?
While the policy objectives mention a just transition, it is only for affected communities. There needs to be consideration as to the impact that green hydrogen production will have on electricity prices around the country. As explained in responses to questions above, the greater demand for electricity accompanying green hydrogen production will undoubtedly result in higher electricity prices.
13. Do you agree with our positioning on hydrogen’s renewable electricity impacts and export sector?
We think it is wishful thinking that hydrogen production can be powered by intermittent renewable power. With the needed capacity factor of 80-90% (stated in the consultation document), electrolysers will need baseload power, from hydro or geothermal. The suggestion that there might be an over-build of renewable generation accompanying hydrogen production, appears to be a “red herring” to mask the impact hydrogen production will have on electricity demand and electricity prices.
Considering the environmental compromises that will need to be made in order to build the energy sources needed for hydrogen production, we do not support developing an export market for green hydrogen. We should not compromise our environment for the benefit of another export industry.
14. Do you agree with the proposed actions and considerations we have made under each focus area?
Support for price and long-term certainty to allow hydrogen to scale for key use cases: We do not support the $100m price subsidy for green hydrogen. This subsidy seems tailored to the use of hydrogen as transport fuel, which we do not support.
Support for capital investment for hydrogen projects: We do not support Clean Heavy Vehicle Grant money used to buy hydrogen fuel cell vehicles. There is too much uncertainty as to the amount of hydrogen that might be leaked in its application as transport fuel and the global warming impact this would have. We urge the government to wait until leakage can be quantified and the resulting global warming understood before supporting hydrogen as transport fuel.
Planning System: We do not support the use of an industry body (the New Zealand Hydrogen Council) producing training material on hydrogen aimed at consenting authorities. Industry bodies should not be telling consenting authorities what to think about hydrogen. This is a clear case of “the fox guarding the hen house”! Advice to consenting authorities needs to be free of conflict of interest and industry messaging. An academic panel would be more appropriate for this task.
15. Is there any evidence we should be considering to better target actions in the final Hydrogen Roadmap?
There needs to be consideration of the global warming impact of leaked hydrogen. This has gone un-mentioned in the Interim Hydrogen Roadmap consultation document. Information about the global warming impact of hydrogen gas in our atmosphere has been available for nearly a decade now, so it is surprising that this was overlooked in this consultation.
Of critical importance here is the quantification of hydrogen gas leakage from production, storage and use facilities, since this is largely unknown and could have a significant global warming impact.
We have been disappointed in the one-sided, industry-friendly tone of the consultation document. While we recognise that the government is keen to decarbonise New Zealand industry and transport, it is important that we make informed and balanced judgements about how we do this. The consultation document has consistently downplayed or omitted many negative aspects of green hydrogen production and use, and repeatedly stressed impractical benefits, such as an over-build of renewable power. Another example of this bias is the suggestion that an industry council provide guidance to consenting authorities. This sort of unbalanced, industry-focussed viewpoint could lead us into supporting a set of “white elephant” projects, wasting valuable time and resources as we attempt to stem off the climate crisis we are in.
Climate Karanga Marlborough is a citizen’s organisation of about 130 members with the purpose of educating the public and our decision-makers as to the dangers of climate breakdown, and to support local and national decision-makers to take action.
We have serious concerns with this program and request a change in direction. We support a subsidy for green hydrogen used in industrial processes and aviation & ship fuel but we do not support the use of green hydrogen for heavy transport. Our reasons are below:
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:
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.
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.
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:
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?
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.
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.
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.
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.
LETTER TO NZ GOVERNMENT on United nations declaration of human rights of indigenous people. (UNDRIP)Read Now
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.
Here is the full list of the initiating groups and the supporting organisations and individuals.
Amnesty International Aotearoa New Zealand
Inclusive Aotearoa Collective Tāhono
Aotearoa New Zealand Association of Social Workers / Te Rōpū Tauwhiro i Aotearoa
Asylum Seekers Support Trust
Auckland Action Against Poverty
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
Human Rights Foundation
Mental Health Foundation of New Zealand
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
Parents for Climate Aotearoa
Peace Movement Aotearoa
People Against Prisons Aotearoa
Physiotherapy NZ / Kōmiri Aotearoa
Protect Our Winters NZ
Public Health Association of New Zealand / Kāhui Hauora Tūmatanui
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 Basket Hauraki
The New Zealand Speech Language Therapists Association
Treaty Action Collective
Volunteering New Zealand
VOYCE Whakarongo Mai
Wesley Community Action
Dr Heather Came
Climate Karanga Marlborough (CKM) is a citizens group of over 85 members, with the mission of bringing the realities of climate breakdown to the people of Marlborough and educate how best to respond. We do this through a number of initiatives:
In addition to submitting within the framework of the “15 set questions” of the Ministry for the Environment (MfE), we have extracted our answer to question 15 (other priority issues), embedding it within this explanatory supporting preamble statement.
Central to CKM’s common concern for our environments, local, national and global, is the belief that all of humanity that relies on industrial technology must seek a new way of thinking about and acting in our relationship with our planet. Although most people acknowledge that we can no longer continue to regard our environment as separate from us, as simply a source of goods from which we can extract what we want without return, the fact is that we continue not only to abuse the environment on which our wellbeing relies but to poison it with our waste. CKM takes the warnings of the environmental sciences with regard to global warming and biodiversity loss as both serious and critically urgent.
CKM sees no evidence of new ways of thinking in the document on “pricing agricultural emissions” on which we are submitting. Therefore, we are not willing to relegate our priorities to the last box of what appears to us to be a box-ticking exercise. We have responded to the “set questions”, as requested, worrying that if we don’t answer the questions, our thoughts, and our priorities, will simply be relegated to the box ticked “Other”.
But we have also herewith brought forward our priorities:
Consultation Document Questions
Question 1: Do you think modifications are required to the proposed farm-level levy system to ensure it delivers sufficient reductions in gross emissions from the agriculture sector? Please explain.
We are in general support of the farm-level levy system that He Waka Eke Noa (HWEN) has come up with and on which the government system is based. The system may not achieve the 2030 10% methane reduction target, however, because no cap on emissions is set. Emissions reductions will be via trial and error and dependent upon other policies, such as the value of forestry conversions. It will be a challenge to manage so that it brings about the necessary emissions reductions. It is necessary that the setting of levy prices be flexible enough to insure course corrections can be implemented quickly. Annual price setting seems a good balance between this flexibility and certainty for farmers.
There is a risk of the levy system deviating too far from the Partnership’s recommendations, through a submission process such as this. This could cause the farming community to disavow the program (which some groups already appear to be doing). In that HWEN was a major and broad consultation, it behoves the government to honour the results of the consultation as best they can.
Question 2: Are tradeable methane quotas an option the Government should consider further in the future? Why?
Tradeable methane quotes would probably be a better system. We are surprised that the HWEN partnership did not decide on this system and opted for a levy system instead, since a tradeable quota system would have likely have cost farmers less. A drawback of the quota system is that it would not generate government revenue, which should have been attractive to the farming industry, but a drawback from the government’s perspective.
We understand that the major issue with a tradeable quote system was disagreement on the level of initial allocation. We can appreciate that dairy and meat farmers might not be able to agree on an equitable allocation formula, since a per-head-of-stock formula would benefit dairy farmers over beef & sheep farmers.
Perhaps a tradeable quota system can be brought in at some time in the future. It has the advantage of accommodating an emissions cap and can bring emissions down at a predictable rate, which the levy system cannot.
Question 3: Which option do you prefer for pricing agricultural emissions by 2025 and why?
(a) A farm-level levy system including fertiliser?
(b) A farm-level levy system and fertiliser in the New Zealand Emissions Trading Scheme (NZ ETS)
(c) A processor-level NZ ETS?
We support option (b) A farm-level levy system and fertiliser in the New Zealand Emissions Trading Scheme (NZ ETS). This is the system recommended by the Climate Change Commission and would simplify farm emissions reporting by putting fertiliser emissions into the ETS at the manufacturer – importer level. The farm-level levy for methane will be enough of a challenge to introduce and manage, without adding the complexity of nitrous oxide and carbon dioxide emissions from fertiliser.
There is also an equity issue here. The rest of NZ pays for long-lived GHGs through the ETS. It would be unfair to let the farming sector treat these gases differently. Fertiliser is also the main source of GHG in the arable and horticulture sectors, which would likely escape a levy unless brought into the ETS at the processor level.
Question 4: Do you support the proposed approach for reporting of emissions? Why, and what improvements should be considered?
We support the annual reporting of basic farm information for the estimation of emissions. It is best to start out simple, since the system to include over 20,000 farms will be challenging to initiate and manage. Complexity needed to better estimate emissions can be added later, once the reporting system is up and running.
Question 5: Do you support the proposed approach to setting levy prices? Why, and what improvements should be considered?
We support the proposed system for pricing emissions. The Climate Commission is best suited to advise on the price of levy necessary to achieve the mandated emissions reductions. In order to maintain flexibility to respond to trends in emissions reduction, the price should be set annually.
Question 6: Do you support the proposed approach to revenue recycling? Why, and what improvements should be considered?
We support the proposed approach to revenue recycling, with administration costs recovered, research funded and farming assistance provided where needed, with Maori & industry input. We feel it is important to “ring-fence” the revenue from the levy scheme so that it supports farmers in reducing emissions and does not go into general government revenue.
We do not support revenue being used to pay for on-farm sequestration. This should be handled by forestry credits in the ETS. Sequestration should be uniform across all sectors of NZ society and industry, without special treatment for farmers.
The forestry credits might be extended to smaller land parcels, to benefit farmers with claiming riparian planting, but we acknowledge this would create a greater workload for MPI.
Question 7: Do you support the proposed approach for incentive payments to encourage additional emissions reductions? Why, and what improvements should be considered?
We support incentive payments to encourage additional emissions reduction, although we acknowledge that there are few options for this available to farmers at this time. The only options available, it appears, are through low-protein & low-methane forage crops and effluent handling. The Climate Commission has “high confidence” that feed additives and vaccines to reduce emissions will not be widely available by 2025. We note that inhibitors such as 3NOP and bromoform are not yet approved and the market for asparagopsis seaweed as a feed additive is in its infancy.
We recommend the government consider “no-till” farming, regenerative and organic farming practices be eligible for incentive payments, since they are known to increase soil carbon, even though soil carbon is not yet counted as sequestration. They also promote lower density farming, which, in the absence of emissions mitigation technologies, is the likely end point of farms using traditional farming methods. Stock reduction is the principal way that farmers will achieve emissions reductions in the levy system, at least until additives, vaccines and genetics are available. Regenerative and organic farms already have lower stock densities.
Question 8: Do you support the proposed approach for recognising carbon sequestration from riparian plantings and management of indigenous vegetation, both in the short and long term? Why, and what improvements should be considered?
Carbon sequestration from planting is already available for compensation through the ETS. Farming should not receive special treatment for sequestration versus other sectors of society. We support research which might allow the inclusion of new types of sequestration, such as pre-1990 forest management and riparian planting, along with other types of sequestration, such as in wetlands and soils.
Farmer interest in being paid for on-farm environmental improvements might also be addressed by a “biodiversity credit” for their work managing on-farm indigenous forests and/or riparian planting.
We acknowledge, though, that riparian planting is mainly done to prevent fertiliser and effluent runoff into waterways – a different environmental problem. It also generally involves vegetation that is low in carbon sequestration potential and is too narrow to host much biodiversity. A credit for riparian planting needs to be carefully considered to make sure it is fair to other sectors of society working to improve biodiversity and sequester carbon.
One further point: The split –gas approach to agricultural emissions acknowledges an inequality between biologic methane and CO2. From a fairness point of view, that inequality should not then be breached to allow on-farm sequestration to offset a levy on methane. Sequestration credits should be through the forestry ETS.
Question 9: Do you support the introduction of an interim processor-level levy in 2025 if the farm-level system is not ready? If not, what alternative would you propose to ensure agricultural emissions pricing starts in 2025?
Yes. By 2025 there will be only 5 years remaining to achieve the 10% reduction in methane specified in the Zero Carbon Act. We need to get started on methane emissions reductions right away.
Question 10: Do you think the proposed systems for pricing agricultural emissions is equitable, both within the agriculture sector, and across other sectors, and across New Zealand generally? Why and what changes to the system would be required to make it equitable?
Yes. It appears equitable as described. The system may not be perfect, however, but we shouldn’t let “perfect” be the enemy of “good”. Equitability issues will arise with time and these can be addressed by revisions and targeted support, as needed.
Question 11: In principle, do you think the agricultural sector should pay for any shortfall in its emissions reductions? If so, do you think using levy revenue would be an appropriate mechanism for this?
Yes, through levy revenue.
Question 12: What impacts or implications do you foresee as a result of each of the Government’s proposals in the short and long term?
Short term impacts will likely include higher domestic prices for milk, meat (beef/lamb/venison) and wool, as the levy cost gets passed on to consumers. Even without the levy, however, animal products are expected to lose market share to cultured and plant based protein in the near term, as the price of these products decline with increasing production scale. Likewise for wool, which is being replaced by more environmentally friendly plant-based products. The levy will act to accelerate this otherwise natural transition. New Zealand farmers will need to take note of these trends and adapt.
There will be more farm conversions to forestry, depending on the price of ETS credits for permanent forestry and the emergence of biodiversity credits for indigenous forestry. We hope that this transition can be managed so the nation doesn’t end up a sea of carbon-farmed pine. The multiple environmental and social benefits of native forest need to be prioritised in this transition.
Long term impacts will likely include a move away from animal farming to horticulture and arable farming. These will be needed both for market domestic supply and as industrial feedstocks for lab cultured foods and other plant-based products. Our exports will shift from animal-based products to specialty foods and fibres to which New Zealand is particularly well suited to grow.
Question 13: What steps should the Crown be taking to protect relevant iwi and Māori interests, in line with Te Tiriti o Waitangi? How should the Crown support Māori land owners, farmers and growers in a pricing system?
Support will be needed for Maori farms. Maori need to be an active part of consultation on these issues. What steps should the Crown be taking...? The Crown needs to acknowledge openly that monetary pricing systems do not fit well within Te Tiriti o Waitangi. The idea of buying and selling land and the living beings living in and on it, particularly when reduced to the notion of "carbon", remains a point of contention between 2 very different world views. It also lies at the centre of how we have got to the present state of the climate: the whenua has been seen in terms of saleable resource rather than as treasure to be cared for and as 'being' to be respected. Historically. the result of this difference in world views led to confiscations by the Crown of good land and the marginalisation of Māori onto marginal farmland. The persistence of pricing land in the agricultural emissions plan simply perpetuates disadvantage for Māori. The Crown needs to take concrete and bold steps to reverse this ongoing process.
How should the Crown support Māori ... ? There appears to be little reward for Māori or concrete incentive for change in the present pricing arrangements. Much of the land "owned" by Māori remains of marginal value under present pricing systems. Support for Māori farmers and growers needs to be in the terms of the Second Article of Te Tiriti (Māori version), recognising in law the notion of collective land "ownership" The Crown must accept the guidance of Māori in this and resist the lobbying of private landowners and those ignorant about the nature of tino rangatiratanga. Support for Māori is in terms of respect, learning and promotional reward for initiative, past and present, rather than only monetary compensation, simply carrying on in the same old way.
Question 14: Do you support the proposed approach for verification, compliance and enforcement? Why, and what improvements should be considered?
Yes. The plan seems reasonable and comprehensive.
Question 15: Do you have any other priority issues that you would like to share on the Government’s proposals for addressing agricultural emissions?
We applaud the government for the He Waka Eke Noa process and willingness to adopt most of the partnership’s recommendations. Reducing agricultural emissions is a contentious issue, which required thoughtfulness and engagement. We only hope that the farm-level levy system will survive a change of government and go on to help the country achieve its emissions reduction targets.
Dear Mayor, Councillors, CEO, Minister David Parker, Minister Nanaia Mahuta and MP Stuart Smith,
Climate Karanga Marlborough (CKM) is a local climate action group purposing “to persuade elected representatives and their officials to pursue policies designed to limit the extent of rapid climate change and help New Zealanders to adapt to its consequences”. We are particularly concerned about the impacts of climate change on the natural environment and biodiversity of which we human beings are just a part, albeit a governing part.
Our members recently had a meeting to discuss the 3 Waters proposals and the position taken by Marlborough District Council (MDC). We know submissions have closed but wanted to send this letter to express our general support for the Council’s position.
The health of all New Zealand waters is inextricably entangled with climate change and its impacts. If human beings do not contribute to the good health of water by mitigating pollution and thus climate change, the environment will suffer and so will all the species both in it and on it, including ourselves.
In the matter of the Government’s proposed Three Waters Bill, we support 5 principles:
Although the urgency to manage ‘our waters’ becomes evidently ever more acute with every weather disaster that occurs, we urge the government to pause and acknowledge the weight of response to their proposals. It is critical they listen and openly adapt to those responses. The failure to bring on board a large proportion of local Councils does not bode well for success. Having read some of C4LD, the collective local councils submission, to which the MDC subscribed, we think that the Government could give a clearer and more detailed explanation of its thinking to the general public as well as to local bodies, including clarity around the engineering, financial and cultural accountabilities of the new entities. It is important that separate issues of water reform, local governance and Treaty obligations are not conflated.
We believe some centralisation of engineering services to ensure that all councils have access to good advice and that no projects proceed without independent assessment and engineering audit will significantly improve outcomes.
In summary, Climate Karanga Marlborough proposes the 5 principles above in supporting nation-wide reforms of water care in Aotearoa New Zealand.
This is a critical time for rebuilding the partnership between central and local government. While central government provides standards and support, we believe it needs to avoid dictating how local and regional communities and institutions apply their different solutions to their own care of New Zealand waters. Cooperation, forbearance and flexibility will be key.
In particular, from a local viewpoint, we support the position of the Marlborough District Council as laid out in its submission dated the 20 July, 2022 to the Finance and Expenditure Committee on Water Services Entities Bill.
We expect clarity and transparency in public of all governmental decision-making.
Finally, we comment that nobody can own water any more than we own the air we breathe; rather, we owe water, air and the land we stand on due care and responsibility.
Otherwise, climate, land, sea and the planet altogether will make their own decisions for us and despite us, as we have all been experiencing at home and abroad.
Yours, Don Quick, Budyong Hill and Bill McEwan for CKM.
2022 Budget Policy Statement – Submission.
We have become aware of the critical urgency to step back from our privileged status and self-entitlement and for our generation and our children’s generation to curb our greed for comfort, control and power in favour of respecting and responding to the urgent need for wellbeing of our planet and its biodiversity, of which we are a part, but just a part.
We humans can be smart, inventive and adaptive, but that counts for little if we simply take for granted that we can exploit the abundance provided for us by the natural world without making any return. The world has its limits and we are there.
From now on, we expect the current government to work within those limits, acknowledging them in detail and, with clear explanation, dedicating adequate finance to enabling us to stop and, if possible, reverse our human contributions in Aotearoa to climate disruption and environmental pollution.
Although I would like to see this coming out of due reverence for our planet and its biodiversity, it certainly would be in our own self-interest, as our wellbeing depends entirely on the Earth’s wellbeing, whatever may be our technological smarts!
A good starting-place would be for the government to deliver with urgency on its commitments in line with the 2015 Paris Agreement and the 2021 COP26.
2. Budget Frameworks.
We support the government’s wellbeing priorities, including taking an intergenerational approach and looking beyond simple economic measures of success and so-called ‘progress’.
We support the use of the Living Standards Framework, including improving on it.
We support the development of He Ara Waiora.
We support consideration given to distributional impacts of policies on different populations and the environment.
We support the explanation of moral values, not just economic values, underlying such considerations.
This government has not shied off moral considerations in furthering its policies, for instance with regard to terrorism and response to the Coronavirus pandemic. By ‘moral’ we allude to values or principles that matter most to people, not just to their pocket or their comfort.
3. A Just Transition.
Here is where moral values, not just economic, must be explicated. Doing justice requires the practice of equality, not just the pursuit of equity.
Climate change, the pandemic and the housing crisis are 3 of our most pressing immediate and long-term challenges and all of them have impacted unequally racially, intergenerationally, on women, on indigenous peoples and on non-industrialised countries, with increasing impoverishment amongst those most affected.
We submit that the Budget Policy Statement requires an additional priority: Reducing economic inequality.
This would align with the other priorities but would highlight a theme common to them all. It would also align with the Living Standards Framework, He Ara Waiora and Fonofale.
Further, Equality and Justice would align with moral values, such as Kindness and Teamwork, already espoused by the current government in dealing with our challenges.
In that regard, We submit that the Budget Policy Statement should allocate ongoing funding specifically to Equality for Women: this would have direct impact on Physical and Mental Wellbeing, Child (and Family) Wellbeing and the Wellbeing of Māori and Pacific peoples.
4. Implementation Funding:
A Just Transition requires that implementation funding be specified, otherwise processes will be set up unjustly to fail. Funding needs to be allocated to support a genuine and ongoing process of engagement with workers in their unions, with volunteer groups in their communities, and with Māori iwi and hapū and Pacifika communities in the time needed to fulfil such processes. For a Just Transition to occur, these engagements must happen first.
In allocating funding and resources, particularly in vulnerable communities, it is important that the government does not simply take a deficit – ‘we’re helping you/lifting you up’ - approach, but adopts an approach that is prepared to listen and respond appropriately – ‘help us understand what it is you need from us to promote your strengths and skills/lift us up’.
We expect funding will honour Te Tiriti o Waitangi through equal and equitable partnership with Māori in all decision-making, be grounded in Kaupapa Māori and uphold indigenous rights, as stated through He Ara Waiora.
5. Other Submissions:
We are in full support of the submissions, each made from their own areas of focus, by 350 Aotearoa; Greenpeace; Fossil Free State Sector Coalition; Coal Action Network Aotearoa; NZEI Te Riu Roa – Teachers’ Union.
6. State Sector Decarbonisation:
We feel strongly that the government should increase funding for the Clean Powered State Sector Fund, to help decarbonise schools, hospitals and other state facilities. This is an easy way for the government to reduce emissions and show leadership in decarbonising infrastructure.
Within this same theme, we strongly encourage the new budget to increase funding for the GIDI scheme to help decarbonise industry and to increase funding to community and household energy generation and conservation projects.
7. Regenerative Farming:
Similarly, we strongly endorse the suggestion by other submitters that the government fund a scheme to facilitate the transition to regenerative farming practices. Regenerative farming has the potential to reduce herd sizes, to accommodate the government’s methane emissions reduction goals, as well as reduce nitrogen pollution to our rivers, all without reducing farmer income. The government should support farmers who decide to switch to regenerative and organic farming practices.
8. Environmental Education:
In particular, we would like to add to the submission from NZEI Te Riu Roa about the importance of holistic education about the environmental crisis.
It is important that the government explicitly recognises and funds its own responsibility and leadership role in informing and educating both the public generally and specific population groups, not just about the thinking behind its policies but about how these policies may play out in terms of such issues as justice and equality.
For instance, one issue that is not addressed, except indirectly, in any of the submissions named above is the central importance for us all to consume less energy overall, not just in order to reduce carbon emissions and other pollutants but also because alternative energy sources are not adequate to make up the difference arising from reduced fossil fuel extraction and because it will demand energy to build the infrastructure for alternative energy sources.
So, if we are all to consume less, how just can that be for groups, both within NZ and in those parts of the Pacific where NZ has influence, who have had little or no access to sources of energy to help reduce the effects of poverty and to bring equality with those who have?
Another issue concerns the Wellbeing priority of the Future of Work, “enabling all New Zealanders and NZ businesses to benefit from new technologies and lift productivity and wages through innovation”. The allure of “new technologies” may encourage people to carry on denying the immediacy of the problem of climate change with the illusion that we will fix all such problems with ingenuity, e.g. alternative fuels such as hydrogen and biofuels. Without diminishing the value of innovation in either mitigating or adapting to climate change and whilst encouraging innovative initiatives, the government needs to encourage wide debate at all ages and in all situations about the pros and cons of different proposed solutions or contributions. This is not just for the public’s understanding, but for its own understanding.
One of the clear messages of scientific research, of increasingly violent weather vagaries and of our continuing failure to adequately reduce global warming, biodiversity loss and environmental degradation is that we can’t afford to keep on going as we have done without drastic consequences for the planet and planetary life, including ourselves. We do need to think or do things differently.
We have to say that we have seen little evidence of new thinking in any government initiatives so far, including in what we have read in the Budget Policy Statement.
Come on! Buck up! We’re in a Climate Emergency – you’ve said it yourselves. You’ve done a good job overall in response to Covid. But Covid is really only a symptom of the underlying disorder: planetary life under stress.
You’ve done plenty homework – it’s time for decisive action. The consequences will not be worse than those of continuing inaction.