March 29, 2021

350 Aotearoa submission to the Climate Change Commission

The Climate Change Commission is responsible for advising the Government on how Aotearoa can tackle climate change. Here's what we had to say about its draft advice to the Government on the pathways we can take to meet our emissions reductions targets.

The Climate Change Commission’s draft advice to Government can be accessed here.

Your one big thing:

350 Aotearoa welcomes the opportunity to engage with the Climate Change Commission on its draft advice to Government on the pathways to meet our obligations to reduce emissions and contribute to global efforts to tackle climate change. This is an historic moment for Aotearoa as we seek to chart a course to align our actions with our targets and commitments to reduce emissions as it also presents us with an unprecedented opportunity to transform Aotearoa to be more equitable, accessible and inclusive for all.

We are in the midst of a climate crisis, the impacts of which are already affecting us in Aotearoa and around the world. This is particularly so for frontline and structurally oppressed communities who, despite contributing the least to cause climate change, are bearing the brunt of its worst impacts. New Zealand, as a developed country that has benefitted from decades of growth built on high polluting industries, must take into account its historical emissions and accept a fair share of responsibility for tackling climate change. It is imperative that we act ambitiously, and that we act now.

While the situation we are faced with is serious and urgent, and should be treated as such, the widespread transformation that is necessitated in our approach to tackle climate change also presents us with an unprecedented opportunity to create a better future for everyone in Aotearoa. By centring the principles of justice and equity, we can ensure that our climate solutions not only contribute our fair share of emissions reductions but that they also actively create a fairer society in which all members of our community are supported to thrive.

The Climate Change Commission is in a unique position to shape the path we take from here and we acknowledge the weight of responsibility that sits with the Commission to consider a wide range of perspectives and priorities. The climate crisis, however, requires urgent attention. We must act rapidly and ambitiously, and seize this opportunity to reduce emissions in ways that have benefits for all parts of our community. We urge the Commission to set the bar high in its advice to the Government and not shy away from making recommendations that will transform Aotearoa for the better.

1. Do you agree that the emissions budgets we have proposed would put Aotearoa on course to meet the 2050 emissions targets?

Disagree

350 Aotearoa disagrees with the level of ambition and pace set by the proposed emissions budgets. The cautious and incremental approach taken by the Commission to reduce emissions ignores the importance of rapid and deep cuts to emissions starting immediately. Putting off more ambitious emissions reductions to future budgets is inconsistent with our IPCC 2030 targets and risks pushing our climate past many tipping points.

The emissions budgets must reflect New Zealand’s commitment to global equity and fulfil our obligations as a high income nation. The legislation describes the purpose of emissions budgets to be for meeting the 2050 target and New Zealand contributing to global efforts for 1.5 degrees (section 5W). There are various policy areas where greater action can be taken in the next decade to enhance the first two budgets for greater consistency with IPCC’s 2030 pathways for 1.5 degrees (outlined under our response to question 5), while also meeting the 2050 target.

2. Do you agree we have struck a fair balance between requiring the current generation to take action, and leaving future generations to do more work to meet the 2050 target and beyond?

Disagree

No. Our approach to transitioning equitably must take into account our role as a developed nation that has historically contributed more than our fair share of emissions, and account for the high-polluting industries that have profited from decades of pollution with little consequence. The legislation describes the purpose of emissions budgets to be for meeting the 2050 target AND New Zealand contributing to global efforts for 1.5 (section 5W). The draft emissions budgets are inconsistent with a 1.5 degree pathway for 2030 which is essential to limiting impacts of frontline communities.

Situating the bulk of reductions in the 2030s also puts an unfair burden on future generations compared to greater cuts this decade. Bringing more government direct investment in emissions reductions forward will share the burden of reductions more equitably, while also contributing to greater consistency with 1.5 degree pathways. It is essential that our actions account for our fair share to reduce the burden on future generations and communities on the frontlines of climate impacts.

Our approach to accelerating climate action must consider the impacts of our economy beyond our borders. This must include going beyond climate financial risk reporting and move to regulating our financial sector. New Zealand companies and crown financial institutions currently enable high-emissions industries such as mining, fertiliser and fossil fuels to continue to operate and expand production offshore through investments, loans, and insurance. Our approach to decarbonising the economy must consider the impacts of our financial sector.

Our policy approaches to equity must ensure that the cost of transitioning to a low-carbon future falls on industries most-responsible and companies rather than individual consumers so that policies do not regressively impact low-income communities.

3. Do you agree with the changes we have suggested to make the NDC compatible with the 1.5°C goal?

Disagree – our changes are not ambitious enough

350 Aotearoa supports the recognition that the NDC is not compatible with Aotearoa making a contribution to limit warming to 1.5C, and that it is more likely to be compatible if much more than 35% below 2005 gross levels by 2030. However, the range used to find emissions reductions consistent with IPCC pathways for 1.5 degrees does not represent differentiated obligations between countries and our responsibility as a developed nation.

When selecting an appropriate mitigation contribution for Aotearoa that reflects our historical pollution and outsized carbon footprint, it is more than likely that our ‘fair share’ would be beyond the interquartile range. 350 Aotearoa calls on the Commission to publish and recommend to the government a ‘fair share’ NDC using appropriate historical responsibility / capability / need calculators, that applies New Zealand’s differentiated obligations under the UN Framework Convention on Climate Change and the Paris Agreement to safe 1.5 degree pathways.

Any NDC update needs to incorporate sufficient domestic reductions through enhanced emissions budgets, a non-mitigation contribution through greatly enhanced climate finance to support those on the frontlines of climate change to adapt to impacts, and not overly rely on offshore mitigation. The opportunity costs of relying on offshore mitigation vs domestic reductions need to be communicated clearly to the public. The Commission should consider annual reporting on a wider range of data to help us to better identify and manage risks – fluctuations in GDP are too crude a measure to evaluate New Zealand’s well-being, future resilience, and how best to allocate NDC components including recommended domestic mitigation policies.

4. Do you agree with our approach to meet the 2050 target that prioritises growing new native forests to provide a long-term store of carbon?

Agree

350 Aotearoa supports the approach of the commission to focus on large reductions on carbon dioxide with as little reliance on emission removals by forestry as possible. Our approach to forestry must consider honouring Te Tiriti o Waitangi and how sovereignty will be returned to mana whenua to manage land and forests.

We support the significant increase in new native forests and the assumption that no further native deforestation occurs from 2025. All native habitats must be incorporated into approach – for example wetlands and tussock should be recognised for their role in storing carbon and protected from destruction.

Our approach to forestry must address climate change while recognising the intersecting biodiversity crisis. We support the recommendation by the commission to reduce reliance on exotic forestry due to the damage it causes to native habitats, and suggest a stronger approach to restore and manage existing native habitats to allow for a reduction in the proposed exotic afforestation.

The Commission could also expand its focus to consider the opportunity of the marine environment as a carbon source and sink.

5. What are the most urgent policy interventions needed to help meet our emissions budgets?

Policy interventions are needed across the board to meet the emissions budgets, alongside policies that mitigate the effects on communities in vulnerable situations.

Action to address barriers in our energy sector such as household-level subsidies to install solar panels to grow our electricity generation capacity, and regulation and subsidies to make homes more energy efficient, can happen alongside investments in research and development to transform and decarbonise industrial heating processes. Much larger direct investment in energy efficiency is needed, especially as we work to make all of the housing stock accessible for disabled communities, and to enable secure life long housing options. Energy efficient homes must be financially affordable and physically accessible.

350 Aotearoa recommends that more ambitious targets and bans on fossil fuels, particularly coal, are implemented, including replacing coal use in process heat for food production, specifically for the dairy industry, with renewable energy sources (not gas) by 2027; banning new and expanded coal mines in Aotearoa and setting an end date for all coal mining in Aotearoa – including coal mining for export; and an immediate ban on any new coal mining on conservation land. The phase out date for fossil heating in new buildings could be brought forward to 2022 and existing ‘pipes in the ground’ for new developments could be compensated financially. This mix of policy approaches will enable a fast transition away from fossil fuel energy sources.

It is critical that the Commission apply an equity lens to policy interventions. Indigenous peoples’ management of resources is crucial to equitable emissions reduction and approaches to climate action must reflect this importance. The Commission can support Māori governance of taonga by:

  • Advising the Government to create binding best practices that require at least co-governance of land, water and air with whānau, hapū, iwi.
  • Give full effect to Te Tiriti o Waitangi by initiating a process to implement the recommendations outlined by the Matike Mai report, in coordination with whānau, hapū and iwi.

While disability is mentioned in the report, this does not go far enough. The Commission needs to expand on this with a disability-responsive position statement and work group recommendations, to ensure a just transition. Gender is not mentioned in the report once; yet climate change disproportionately impacts women and people of diverse genders. It’s vital that the Commission takes into account research on the gender impacts of climate change and climate action, and include this into their analysis.

350 Aotearoa also echoes calls from public health advocates for a greater focus on health and health equity co-benefits, including appointing public health representation to the Commission’s board.

6. Do you think our proposed emissions budgets and path to 2035 are both ambitious and achievable considering the potential for future behaviour and technology changes in the next 15 years?

Disagree

350 Aotearoa agrees with the Commission’s approach to meet the proposed emissions budgets with existing technologies makes it achievable. However, with existing technology we can achieve far more ambitious emissions budgets, stronger policy recommendations, and more stringent targets for heavy polluters, than the Commission’s draft proposals. The proposed emissions budgets could be made more ambitious by strengthening the policy recommendations, direct regulation and government investment in the next 15 years, independent of technology and behaviour changes.

Future technologies should be utilised to strengthen the emissions budgets and steepen our emissions reductions pathway.

The Commission’s report focuses on quantifying the cost of meeting the proposed emissions budgets, but misses the opportunity to highlight the cost of inaction, and therefore the potential savings of taking bold, ambitious action to reduce emissions early.

The third part of our consultation is more detailed. You will be given the opportunity to answer specific questions.

1. Do you support the principles we have used to guide our analysis?

Partially support

Under Principle 2 ‘Focus on decarbonising the economy’, the report states that “Aotearoa should focus on decarbonising its industries rather than reducing production in a way that could increase emissions offshore.” It is essential that our approach to accelerating climate action considers the impacts of our economy beyond our borders. This must include going beyond climate financial risk reporting to regulating our financial sector. New Zealand companies and crown financial institutions currently enable high-emissions industries such as mining, fertiliser and fossil fuels to continue to operate and expand production offshore through investments, loans, and insurance. Our approach to decarbonising the economy must consider the impacts of our financial sector.

When considering Principle 5: ‘Transition in an equitable and inclusive way’, it is important that our approach to transitioning equitably takes into account the high-polluting industries that have profited from decades of pollution with little consequence. Our policy approaches to ‘equity’ must ensure that the cost falls on industries most-responsible and companies rather than individual consumers so that policies do not regressively impact low-income communities.

4. Do you support budget recommendation 4? Is there anything we should change, and why?

Fully support

350 Aotearoa supports limiting offshore mitigation to zero, and for this mechanism to be used only in exceptional circumstances. It is crucial that we focus on rapid and deep cuts to domestic emissions. Delaying substantial cuts to domestic emissions in the short term by relying on mitigation does not set Aotearoa on course to sustainably and meaningfully contribute our fair share to tackle the climate crisis.

7. Do you support enabling recommendation 3 on creating a genuine, active and enduring partnership with iwi/Māori? Is there anything we should change and why?

Partially support

As outlined in our response to question 5 of Part 2, genuine partnership with iwi and Māori must form the basis of the Commission’s work to fulfil its mandate and provide strategic guidance to government on emissions reduction. We cannot meaningfully or appropriately transition Aotearoa to a low carbon, just and sustainable future without ensuring that our commitment to a partnership approach is steadfast and that space and resources are dedicated to ensuring that Māori are can participate in governance and decision-making process, that their custodianship over land, water and air is respected, and that we fulfil our obligations as treaty partners.

To reiterate our recommendations made in our response to question 5 of Part 2, the Commission can support Māori governance of taonga by:

  • Advising the Government to create binding best practices that require at least co-governance of land, water and air with whānau, hapū, iwi.
  • Give full effect to Te Tiriti o Waitangi by initiating a process to implement the recommendations outlined by the Matike Mai report, in coordination with whānau, hapū and iwi.

9. Do you support enabling recommendation 5 on establishing processes for incorporating the views of all New Zealanders? Is there anything we should change and why?

Partially support

It is critical that all New Zealanders have the opportunity to engage with those setting the agenda for Aotearoa’s climate policy moving forward. Climate change consistently ranks as one of the most pressing issues in the minds of New Zealanders.

Establishing a transparent process that enables the public to engage with authorities will lead to more inclusive policy outcomes by ensuring that all communities are able to share their views and perspectives on our approach to climate action and building a channel by which the public can demand accountability from decision-makers.

350 Aotearoa urges the Commission to closely consider the nuances involved in establishing a consultative space to ensure that its recommendations to government in this area proactively address the inherent power dynamics of such a process. The Commission must consider which parts of the community have the time, resources and trust to engage in a consultative process, and how the process can ensure that structurally oppressed communities are meaningfully supported to engage. A consultative process in which only the loudest voices are heard, or where not everyone is at the table, is inherently flawed. The Commission must focus on reducing the barriers to participation encountered by parts of the community that experience structural oppression.

Finally, 350 Aotearoa recommends that the Commission reflect on how this consultative space can also meet our treaty obligations and reinforce a partnership approach with Māori. The Commission needs to consider how Maori voices will be amplified and centred in public consultation, and what weight will be given to the outcomes of any such consultation when there are separate processes to consult directly with iwi.

10. Do you support our approach to focus on decarbonising sources of long-lived gas emissions where possible? Is there anything we should change and why?

Partially support

350 Aotearoa supports decarbonising sources of long-lived gas emissions as part of a broader strategy to reduce our use of and reliance on all fossil fuels. However this split gas approach must not miss the opportunity to also rapidly decarbonise short-lived gases. The Commission must ensure that the short-lived gas pathway is more ambitious.

11. Do you support our approach to focus on growing new native forests to create a long-lived source of carbon removals? Is there anything we should change and why?

Partially support

350 Aotearoa broadly supports the Commission’s approach to focus on growing new native forests to create long-lived sources of carbon removals but urges the Commission to ensure that the Commission minimises reliance on emissions removals by forestry, as outlined under question 4 of Part 2. Where possible, we must focus on large reductions to domestic carbon emissions.

We support the significant increase in new native forests and the assumption that no further native deforestation occurs from 2025. Our approach to forestry must also consider honouring Te Tiriti o Waitangi and how sovereignty will be returned to mana whenua to manage land and forests.

13. Do you support the package of recommendations and actions we have proposed above to ensure an equitable, inclusive and well-planned climate transition, and is there anything we should change?

Support some of the actions

The scale and pace of change required to ensure that Aotearoa meets its emissions reduction targets is immense, and will significantly impact communities across the country if not managed with careful planning and consideration of potential harms and opportunities. The Commission must emphasise the importance of this in its recommendation to government to ensure that all New Zealanders and particularly structurally oppressed communities benefit from our transition to a low carbon economy.

350 Aotearoa acknowledges the critical work that groups like unions are doing to ensure that workers and communities impacted by any changes are properly supported through a just transition framework, and recommends that the Commission ensure that their perspectives, experience and insights are appropriately taken into consideration.

350 Aotearoa broadly supports the Commission’s recommendation to government to develop an Equitable Transitions Plan. We recommend, however, that the Commission include the terminology of ‘just transition’ to acknowledge and uplift the important work that has been done, particularly by unions, to ensure that not part of our community is negatively impacted by our shift to a low-carbon future. We have a unique opportunity to ensure that our approach to tackling climate change transforms Aotearoa not only reduces overall emissions, but also sets us on course to be more equitable, just, inclusive and accessible. The Government must play a central role in supporting this transition and ensuring that the voices of all communities in Aotearoa, including but not limited to workers employed, and communities supported by impacted industries, Māori, disabled communities and low income communities, are uplifted and their needs and potential impacts taken into account. Taking an inclusive, consultative approach to developing the plan must guide the Government to ensure proper representation of these needs and impacts, and the Commission must make this clear in its advice.

15. Do you support the package of recommendations and actions for the heat, industry and power sectors? Is there anything we should change and why?

Support some of the actions

350 Aotearoa supports the proposed recommendations and actions for the heat, industry and power sectors. Shifting our energy mix away from fossil fuels and towards renewable sources is vital to meaningful and sustainable reductions in our overall emissions. We acknowledge that the Commission is recommending the need to “almost eliminate fossil fuels”, and encourage the Commission to assess areas where targets can be made more ambitious to ensure we are cutting emissions as quickly and deeply as possible.

In particular, 350 Aotearoa recommends the following:

  • Much larger direct investment in energy efficiency is needed, especially as we work to make all of the housing stock accessible for disabled communities, and to enable secure life long housing options.
  • Energy efficient homes must be financially affordable and physically accessible.
  • More ambitious targets and bans on coal:
    • Replace coal use in process heat for food production, specifically for the dairy industry, with renewable energy sources (not gas) by 2027.
    • Ban new and expanded coal mines in Aotearoa, and an end date for all coal mining in Aotearoa – including coal mining for export.
    • An immediate ban on any new coal mining on conservation land.
    • Bring forward the phase out date for fossil fuel heating in new buildings to 2022.
  • Make our biggest polluters pay by immediately ending subsidies via free carbon credits.
  • Phase out all state sector fossil fuel boilers in schools, hospitals, prisons and other state-sector infrastructure by 2025

Our government’s approach to meeting 100% renewable energy target and addressing our ‘dry-year’ problem with a comprehensive scoping study that considers all viable options for meeting our target, including a combination of approaches and a focus on decentralising our energy system, rather than setting Lake Onslow as the primary option that is used as a tool for comparison.

16. Do you support the package of recommendations and actions for the agriculture sector, and is there anything we should change?

Do not support these actions

350 Aotearoa supports the submission of Greenpeace Aotearoa, in addition to the following:

There is a real benefit to using a “go hard, go early” approach to reducing methane emissions. The recommendations and actions rely too heavily on future technologies to reduce methane from 2035, rather than using the opportunity to make transformative changes in the agriculture sector in the first 15 years. We do not agree with the Commission’s plan to reduce as little agricultural methane as possible (the lower end of the target ranges – 13% by 2035 and 24% by 2050). We must aim for the most ambitious climate plan, not the least. We want to see more agricultural climate pollution reduced and faster.This must be supported by policies to ban synthetic fertilisers, reduce animal numbers, and support farmers to transition to regenerative farming practices.

This must be supported by direct regulations on the sources of climate pollution. These should be:

  • A sinking cap on synthetic nitrogen fertiliser, which eliminates it by 2024.
  • A sinking cap on imported feed which eliminates it by 2024.
  • A prohibition on all new dairy conversions.
  • A maximum stocking rate limit, which is set low enough to drive a significant reduction in the national herd.

The Commission has also failed to recommend that agri-business pay reparations for the vast historic and ongoing climate pollution that this industry has created. To address this inequity the Commission should advise that agriculture enters the Emissions Trading Scheme in 2021 with no subsidies, ie. that they enter at 100% with no free allocation.

18. Do you support the package of recommendations and actions for the waste sector? Is there anything we should change and why?

Support some of the actions

The Commission’s advice on waste takes us in the right direction but the recommendations need to be more specific, holistic, and ambitious, recognising that our current system is broken. Waste is a product of a system that does not recognise our interconnectedness with other species nor the natural systems of Papatūānuku. The Commission’s advice must harness the power of reduction and reuse strategies to reduce our emissions. The Commission’s organic waste reduction targets can aim much higher than 23% by 2030. The Commission should also recommend that the Waste Strategy and the Waste Minimisation Act set binding reduction targets for all waste streams, whether organic or inorganic.

21. Do you support our assessment of the country’s NDC? Do you support our NDC recommendation?

Partially support

350 Aotearoa supports the submission of Oxfam New Zealand and the recommendations in their report ‘A Fair 2030 Target for Aotearoa’ (September 2020).

22. Do you support our recommendations on the form of the NDC?

Somewhat support

350 Aotearoa supports the submission of Oxfam New Zealand and the recommendations in their report ‘A Fair 2030 Target for Aotearoa’ (September 2020).

23. Do you support our recommendations on reporting on and meeting the NDC? Is there anything we should change, and why?

Somewhat support

350 Aotearoa supports the submission of Oxfam New Zealand and the recommendations in their report ‘A Fair 2030 Target for Aotearoa’ (September 2020).