Submission to the Zero Carbon Act

​Introduction
1.Climate Karanga Marlborough (CKM) is a citizens group of over 100 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:
a.by working with the Marlborough District Council on strategies to limit emissions and help adaptation to the effects of climate change
b.by publishing articles promoting climate change awareness and preparedness in local newspapers and by sponsoring community and school events
c.by providing a social support network for Marlburians and other New Zealanders anxious about, and looking to better understand the implications of the climate change crisis we are now facing.
2.CKM broadly supports the objectives and overall structure of the Bill.  We are happy that Parliament is finally taking action on the climate emergency.  We agree with aligning the Bill with the warming limited to 1.5°C rather than other, less ambitious targets.
3.We do wish to be heard at the Select Committee hearings. 


Climate Commission
4.We support the establishment of the Climate Commission as an independent panel of experts (rather than stakeholders) to advise Parliament and government departments.  Although the selection mechanism proposed in the Bill appears sufficiently robust to prevent politicisation of the Commission and the reporting mechanisms will prevent suppression of the Commission’s reports, we strongly feel that the Commission should be a separate statutory body reporting to Parliament rather than to the minister.  This is the structure of the Committee on Climate Change in the UK and it seems to be working well.  The NZ Commission needs to be shielded from the political whims of the government of the day.  The best way to achieve this is with a separate public body.  In addition, funding of the Commission as proposed appears vulnerable to the annual budget cycle of Parliament. We recommend that funding of the Commission be provided for separately, as is the case with the nation’s courts.
5.We support the measures taken in the Bill to include Maori and honour the Treaty of Waitangi. These appear to be sufficient to provide the needed Maori input into the Commission’s work.
6.We support the inclusion of adaptation and risk assessments as reporting responsibilities of the Commission and not handled or shared by separate agencies.  It will be important that emissions targets and progress toward meeting those targets be integrated with reporting on the impacts of climate change on New Zealanders and adaptation to it.  The nation needs a coherent strategy, which would not be the case if these functions are handled by or shared with other agencies.


Emissions Targets
7.We support the goal of net zero emissions of greenhouse gases (other than methane) by 2050.  This is in line with the IPCC recommendations to achieve no more than 1.5°C warming with limited overshoot.  Given the fact that New Zealand is lagging behind in achieving the emissions reductions and renewables uptake it has committed to, we feel it would be important to aim to achieve net zero emissions before 2050.  That way there is room to take account of unforeseen circumstances that may set us back from this goal. 
8.With respect to the “net zero emissions by 2050” goal, we feel that an interim goal for 2030 should also be stated, as is the case with methane.  The IPCC recommends a decrease of 45% by 2030 relative to 2010.  We support this as an interim 2030 goal.  It would ensure New Zealand stays aligned with IPCC recommendations and prevent the necessity of having to introduce urgent, disruptive and costly emissions reductions measures as the 2050 deadline approaches.
9.We support the “split gas” approach to emissions targets.  Methane has a limited lifetime in the atmosphere, but also cannot be mitigated through sequestration.  Carbon dioxide has a long lifetime in the atmosphere and accumulates in our environment, but it can be sequestered by forestry, soils and industrial processes.  The two gases produce vastly different warming, with methane having a much more severe near-term impact than carbon dioxide.  Methane’s more severe near-term impact is not properly accounted for in the GWP100 method for equating their impacts, which would likely be the basis for a common emissions accounting scheme.  Lumping methane with carbon dioxide in the emissions trading scheme could also have a perverse consequence, whereby methane emissions are allowed to increase through forestry offsets.  This could conceivably prevent us from reaching the 1.5°C global warming limit the Bill is aiming for.  That does not mean methane reduction should be given less priority; just the opposite.
10.We support the 2050 reduction target for methane of at least 24-47%.  This is in line with the IPCC recommendation of “35% or more” decrease by 2050 in order to remain below the 1.5°C global warming target.  Flexibility in this target is prudent because it is not clear that technological advancements, de-stocking and land-use changes in our agriculture sector will, on their own, be able to achieve the more ambitious reduction target in time.  Neither is it clear that our atmosphere will always have the same capacity to remove methane. A 29 April 2019 article in EOS () published by the American Geophysical Union, suggests that methane emissions are growing faster than can be accounted for and new, poorly understood factors with respect to methane sources and breakdown in the atmosphere could make it harder to reach the 1.5°C goal.
11.We feel that the interim 10% reduction target for methane by 2030 is well below that which will be required to limit warming to 1.5°C.  MPI has recently stated that a 10% reduction could be achieved simply by following farming best practice.  We note that methane emissions pathways used in IPCC modelling to achieve a limit of 1.5°C heating show a decrease well below 10% by 2030.  The IPCC Special Report: Global Warming of 1.5°C Figure 2.7 shows an average decline of approximately 30-40% by 2030 for models achieving 1.5C warming with low overshoot.   New Zealand could achieve the target of net zero carbon dioxide emissions, only to exceed the 1.5°C warming limit because methane was not decreased quickly enough.  We argue for a more aggressive 2030 target for methane, in order to stay in line with what is necessary to achieve the 1.5°C warming limit.


Other Matters
12.We do not support the provision in Section 5ZJ of the Bill which prevents any court remedies in the event the government fails to achieve emissions targets, other than a declaration of such.  The Bill should carry the weight of a treaty, a treaty between the people of New Zealand and its government.  In the event that emissions targets are not met, the government should be compelled to act to remedy the situation. 
13.We do not support the provision in Section 5ZK which states that government decision makers “may take the 2050 emissions target and emissions budget into account”.  This wording needs to be changed to “must take the 2050 emissions target and emissions budget into account”.  Simply stating that they must take this target into account doesn’t mean that they have to blindly follow it – they still may not.  But it makes little sense to set a cross-party national policy that does not need to be taken into account in government decision making. 
14.New Zealand’s share of international aviation and shipping needs to be included in national emissions accounting and in emissions reduction schemes.  The fact that these sources of emissions are presently exempt from the Paris Agreement is no excuse.  New Zealand should follow the UK’s lead in including these emissions sources in our emissions reduction targets.
15.We support the establishment of a youth council to work in parallel with and advise the Climate Commission.  Youth today will be the hardest hit by the climate changes of tomorrow and they need to have informed representation on the Climate Commission.