CKM CLIMATE COMMISSION DRAFT SUBMISSION

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Nitrous Oxide

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

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

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

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

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

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

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

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

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

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

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

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

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