- We support the proposed level of the fourth emissions budget and agree with the Commission's assessment of the considerations that have informed the budget level as well as the inclusion of international shipping and aviation in future emissions assessments.
- We agree with the Commission's view on offshore mitigation as also described in The Climate Change Response Act 2002.
We must focus on meeting our greenhouse gas emissions reductions targets through radical improvements in the way we work and live. It is a dangerous distraction to continue to pay others to do that instead of us.
The processes that brought wealth to industrialised nations like ours are the primary drivers of climate change. This places a greater responsibility on countries like ours to change them. Using that wealth to sidestep those changes will also rob us of the benefits of these developments.
We’ve already seen convoluted and/or perverse international markets for emissions trading. We remain in the wake of the 2008 Global Financial Crisis. We're living in a time of fiat currencies no longer closely tethered to underlying value. Market mitigation mechanisms falsely equate these currencies with the health of the priceless global biosphere and atmosphere on which all our lives depend. This severely limits their usefulness. This is especially true in the face of ongoing economic difficulties.
In line with that caution about this approach, we note and agree with the Commission’s assessment that: “the New Zealand Emissions Trading Scheme (NZ ETS) as currently structured is highly unlikely to drive the gross emissions reductions in line with our demonstration pathway…particularly in a way that can be sustained.”
We cannot shy away from the courageous innovation our times require. Doing so is choosing to miss out on the spectacular benefits of being a leader in the emerging global circular economy to come.
Continuing to invest inappropriately in such things as fossil fuel and road expansion, weds us more tightly to a sinking system. Instead, we must turn our energies and investments to creating and enjoying the flourishing of a better way to be.
- We share the Commission's concerns regarding Government plans to allow emissions and removals from pre-1990 forest management activities to be included in emissions calculations.
These, like offshore emissions, could make it possible to achieve set emissions budgets without meaningfully reducing gross emissions in the here and now.
More than 80% of land in Aotearoa New Zealand was covered with native bush before human arrival. This was reduced to 27% by 2018. New Zealand’s gross greenhouse gas emissions increased by 24% between 1990-2018. Forest management activities during that latter period cannot seriously be deemed as assisting in the radical reduction of greenhouse gas emissions now required to avert imminent catastrophic climate change. This is an unfair shifting of the goal posts way too late in the game.
The activities suggested were not, and were not intended to be, additional to ‘business as usual’. They occurred prior to any serious attempt to address climate change.
Attempting to redefine them now in this way would undermine:
- the core logic of additionality in climate mitigation
- the credibility of this nation’s commitment to real change
- the entire global endeavour to tackle greenhouse gas emissions.
It invites other nations to trawl their history for mitigations, rather than looking to the present and future changes required.
- We agree with and applaud the emphasis on the regeneration of native bush rather than exotic plantations. “While exotic afforestation offers quicker reductions in net emissions, planting natives offers a longer-term carbon sink as well as improving biodiversity and reducing erosion risk of marginal land classes.”
The logic of additionality and permanence makes native bush a far more robust solution to the challenges we face.
The long-term growth of a myriad of inter-connected species represents much greater potential for greenhouse gas emissions mitigation. It also comes with a host of co-benefits.
The rapid build-up of greenhouse gases in the Earth’s atmosphere is not happening in isolation on an otherwise pristine planet. It is a symptom (albeit a very serious one) of a wider and deeper breakdown in the planet’s ecological health. This is all being driven by unsustainable human activity.
Aotearoa New Zealand has the highest proportion of threatened indigenous species on Earth. More than 4,000 species are at risk. More than 80% of land in Aotearoa New Zealand was covered with native bush before human arrival. This was reduced to 27% by 2018. As the Commission’s Chair has emphasised elsewhere, “nature based” solutions and the restoration of native bush must play a key role in addressing climate change. This work will also secure our cultural heritage. It will support our physical, psychological and spiritual well-being long into the future.
We would also like to see the Commission explicitly explore and promote more innovative approaches to integrated land management. This should include community and iwi-led nature regeneration, regenerative agriculture and regenerative agro-forestry.
The root cause of the challenges we are facing are the disconnection and dis-integration of people from their place in the world. We need to re-establish ways of living and working harmoniously in and with the landscape and oceans. This will be vital in tackling climate change. It is what will build the low carbon, circular, low waste economy.
- SBN also supports more ambitious assumptions around the role of public transport, walking, cycling along with increased use of private sector car-sharing schemes.
Feedback on the 2024 review of the 2050 emissions target
- We support the Sustainable Business Council and Climate Leaders Coalition call that any changes to the target should serve to strengthen New Zealand's ambition and contribution to addressing climate change.
We also note how global standards and regulations will continue to drive change in Aotearoa New Zealand. In particular, there is increasing evidence of growing customer expectations for businesses to be able to demonstrate and report on efforts to cut waste and pollution. Our businesses will need support with tools, skills building and verification to ensure we remain globally relevant.
Additional comments
- 2024 surveys of SME attitudes to climate action suggest increasing business understanding, but key obstacles remain. These include lack of time, knowledge and high perceived cost of taking action. What had changed from previous surveys, however, was a greater recognition of the potential benefits of taking action. The lag, however, between awareness and action needs addressing.
Various NGOs and government agencies are currently working on tackling these barriers. But more investment is needed to enable SMEs to follow concern and awareness with action.
We also recently completed research with Aurecon and thinkstep-anz for the Ministry of Business, Innovation and Employment. This includes initial quantification of carbon cutting potential of circular economy approaches in New Zealand’s built environment, agriculture and critical materials. These could represent a 2.7%-3.4% reduction on 2021’s net emissions. In addition, potential long-term emissions savings realisable in coming decades of 14,241ktCO2e (14 MtCO2e) to 20,836ktCO2e (21 MtCO2e). But funding for the Circular Economy and Bioeconomy Strategy this research was set to inform was removed in the 2024 Budget. We recommend the Commission be more explicit and direct in support of such initiatives. A rapid transition to a low emissions economy will not be possible without such work.
- $939.3m has been allocated in the 2024 Budget over four years to repair roads damaged during Cyclone Gabrielle, the Auckland floods and other North Island weather events. We support the efforts of the McGuinness Institute to have costs like these, and the projected cost of other forms of mitigation included in the Government’s accounts.
As former Climate Change Minister James Shaw, who also supports this, said in a recent interview: “If you acknowledge the reality that it is a liability, then you look for ways to avoid the liability.”
This would incentivise early investment in all areas of addressing climate change. Dollars spent today will save more than their worth later on, when measures to tackle climate change will only become more expensive. For similar reasons, early investment today is likely to yield greater returns and benefits in the long term. Again, this is about actually addressing the realities of climate change. It is not about appearing to do so to the minimum extent deemed politically advantageous in our short election cycles.
This, in our view, is what the Commission was created for.