25 Mar 2021

Toitū Envirocare’s submission: Climate Change Commission Report 2021

Posted in: News

Toitū Envirocare’s submission: Climate Change Commission Report 2021

On 31 January, the Climate Change Commissions released its much-anticipated draft advice to government. The advice aims to guide policy development and covers the first of 3 five-year budget periods, through to 2035.

To get a summary of the draft report, check out:

The advice is open to consultation until 28 March 2021. We are making our submission publicly available to clarify our position on various topics while offering our technical insight to organisations looking to formulate their own submissions.


Approach and Principles

Consultation Question 1: Do you support the principles we have used to guide our analysis?

Our response:

☒ Fully Support

☐ Partially Support

☐ Neutral

☐ Do not know

Reason/Comments:

Toitū Envirocare fully agreed with the approach and recommendations of the Commission


Emissions Budget numbers

Consultation question 2: Do you support budget recommendation 1? Is there anything we should change and why?

Emissions Budget 1 from the Climate Commission draft advice

Our response:

  Too ambitious About right Not ambitious enough Don't know
Emissions budget 1 (2022-25)  X 
Emissions budget 2 (2026-30)  X 
Emissions budget 3 (2031-35)  X 

Reason/Comments:

The proposed emissions budgets lead towards achievement of New Zealand's Nationally Determined Contribution (NDC) targets but do not allow New Zealand to meet emissions levels required for 1.5 degrees warming above pre-industrial levels.


Breakdown of emissions budgets

Consultation question 3: Do you support our proposed break down of emissions budgets between gross long-lived gases, biogenic methane and carbon removals from forestry? Is there anything we should change, and why?

Our response:

  Too ambitious About right Not ambitious enough Don't know
Gross long-lived gases  X 
Biogenic methane X  
Forestry  X

Reason/Comments:

Discussions that we have been involved in indicate that it is technically feasible to reduce emissions beyond those outlined in the Advice if barriers can be broken down through suitable funding, provision of information and advice, and implementation of suitable policies by government.


Limit on offshore mitigation for emissions budgets and circumstances justifying its use

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

Our response:

☒ Fully Support

☐ Partially Support

☐ Neutral

☐ Do not support

☐ Do not know

Reason/Comments:

We support the Commission’s recommendation that New Zealand’s domestic emissions budgets should be met solely through domestic action, except in the case of force majeure events, such as those currently prescribed in the Climate Change Response Act 2002.

However, we encourage the implementation of processes that enable the voluntary sector to undertake offshore mitigation in order to enable Aotearoa to further support global efforts to mitigate climate change. This would include the ability to purchase high quality offshore carbon credits


Enabling an enduring climate transition - intro

Cross-party support for emissions budget

Consultation question 5: Do you support enabling recommendation 1 on cross-party support for emissions budgets? Is there anything we should change and why?

Our response:

☒ Fully Support

☐ Partially Support

☐ Neutral

☐ Do not support

☐ Do not know

Reason/Comments:

Toitū Envirocare fully agreed with the approach and recommendations of the Commission


Coordinate efforts to address climate change across Government

Consultation question 6: Do you support enabling recommendation 2 on coordinating efforts to address climate change across Government? Is there anything we should change and why?

Our response:

☒ Fully Support

☐ Partially Support

☐ Neutral

☐ Do not support

☐ Do not know

Reason/Comments:

We recommend that the Commission specifically recommends the establishment of a clear and efficient structure for interagency coordination, which should allow for policy to be developed in close partnership with the private sector.

Toitū Envirocare also recommends that the CCC advises Government to consider the opportunity to develop an all of government agency to become the country’s public ‘home’ of all GHG information. Currently information and support on carbon for citizens and businesses is widely distributed between MfE, EECA, MBIE, MPI and elsewhere. This is unhelpful for those seeking support or information and therefore quick progress on reductions.


Genuine, active and enduring partnership with iwi/Māori

Consultation question 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?

Our response:

☒ Fully Support

☐ Partially Support

☐ Neutral

☐ Do not support

☐ Do not know

Reason/Comments:

Toitū Envirocare fully agreed with the approach and recommendations of the Commission.


Central and local government working in partnership

Consultation question 8: Do you support enabling recommendation 4 on central and local government working in partnership? Is there anything we should change and why?

Our response:

☒ Fully Support

☐ Partially Support

☐ Neutral

☐ Do not support

☐ Do not know

Reason/Comments:

Toitū Envirocare fully agreed with the approach and recommendations of the Commission.


Ensuring inclusive and effective consultation, engagement and public participation

Consultation question 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?

Our response:

☒ Fully Support

☐ Partially Support

☐ Neutral

☐ Do not support

☐ Do not know

Reason/Comments:

Toitū Envirocare fully agreed with the approach and recommendations of the Commission.


Locking in net zero

Consultation question 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?

Our response:

☒ Fully Support

☐ Partially Support

☐ Neutral

☐ Do not support

☐ Do not know

Reason/Comments:

It is necessary to decarbonise sources of long lived gases as there are no proven long term technology solutions for removal of these emissions from the atmosphere and there is insufficient land available to remove future CO2 emissions from the atmosphere.

Toitū Envirocare recommends that in addition to decarbonising sources of long-lived gases, the Commission recommends that Government develops a mechanism for establishment of non-biological GHG sequestration credits that are available to the voluntary sector in New Zealand.


Consultation question 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?

Our response:

☒ Fully Support

☐ Partially Support

☐ Neutral

☐ Do not support

☐ Do not know

Reason/Comments:

While exotic afforestation is likely to provide increased rate of sequestration per hectare in the short term, permanent native reforestation/afforestation provides the ability to sequester carbon for longer periods with fewer negative impacts associated with monoculture planting and harvesting such as risk of landslides when the forests are harvested. We would encourage a mechanism that allows transition of land use on blocks of land from exotic to native forest over a period of time and provides additional co-benefits.


Our path to 2035

Consultation question 12: Do you support the overall path that we have proposed to meet the first three budgets? Is there anything we should change and why?

Our response:

☒ Fully Support

☐ Partially Support

☐ Neutral

☐ Do not support

☐ Do not know

Reason/Comments:

Toitū Envirocare agrees with the path but notes that there are significant barriers/risks to implementation.

A key assumption underpinning the first budgets is that Tiwai Aluminium Smelter will close, resulting in availability of electricity for use elsewhere. There are a number of challenges associated with this assumption and the implications of Tiwai not closing are not sufficiently clear. In addition, it is important that early planning and budgeting occurs for the upgrades to the National Electricity Grid that will enable both transmission of electricity in Southland to northern areas on NZ and the increase in electricity use associated with electrification of process/building heating and NZ’s vehicle fleet.


An equitable, inclusive and well-planned climate transition

Consultation question 13: Do you support the package of recommendations and actions we have proposed to increase the likelihood of an equitable, inclusive and well-planned climate transition? Is there anything we should change, and why?

Our response:

☒ Fully Support

☐ Partially Support

☐ Neutral

☐ Do not support

☐ Do not know

Reason/Comments:

Key to an equitable, inclusive and well-planned transition is the provision of suitable information for individuals and small businesses on how they can change behaviour and the support available to them, along with training/education to support individuals and small businesses to gain the skills they need to work in a low-carbon economy.


Transport

Consultation question 14: Do you support the package of recommendations and actions for the transport sector? Is there anything we should change and why?

Our response:

☒ Support all the actions

☐ Support some of the actions

☐ Do not support these actions

☐ Do not know

☐ Neutral

Reason/Comments:

Toitū Envirocare recommends that the Commission increases the focus on risk and/or alternative options should the key assumptions not be correct, along with timelines for implementation.

The solution to reducing transport emissions will be a combination of:

  • Promotion of behaviour change by individuals and businesses through the provision of tools and information
  • Reducing the age, size and fuel mix of New Zealand’s passenger transport fleet
  • Improving cycling and public transport networks to provide feasible alternatives to car travel
  • Enabling timely transition to EVs, including by increasing the availability of second-hand EVs (such as by incentivising new EV purchase by businesses or by mandating EVs use in government fleets) and by improving charging networks. UK and India have chosen a 2030 date for this transition, which may be suitable for New Zealand.
  • That fuel and/or mode switching for the heavy transport fleet be enabled through mechanisms such as improved availability of information and improvement of rail networks

Heat, industry and power

Consultation question 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?

Our response:

☒ Support all the actions

☐ Support some of the actions

☐ Do not support these actions

☐ Do not know

☐ Neutral

Reason/Comments:

Toitū Envirocare recommends:

  • That measuring and reducing embodied emissions are considered within the Commission’s recommendations
  • Incentivising private sector investment in actions that reduce emissions within and beyond their business (e.g. through their supply chain). This may include the implementation of options for businesses to purchase NZ-based carbon credits associated with decarbonisation activities beyond biodiversity options, that they can use in carbon neutral claims.
  • That clarity be improved regarding risks relating to assumptions in the modelling, such as the ability of the NZ electricity grid to enable recommended electrification activities.

Agriculture

Consultation question 16: Do you support the package of recommendations and actions for the agriculture sector? Is there anything we should change and why?

Our response:

☒ Support all the actions

☐ Support some of the actions

☐ Do not support these actions

☐ Do not know

☐ Neutral

Reason/Comments:

Toitū Envirocare recognises that there are some technology limitations and research/commercialisation needs for reduction of biogenic emissions. However, the sector needs to continue its work to reduce emissions reductions and the He Waka Eke Noa process needs to be appropriately resourced and maintain its progress against targets and timeframes.


Forestry

Consultation question 17: Do you support the package of recommendations and actions for the forestry sector? Is there anything we should change and why?

Our response:

☒ Support all the actions

☐ Support some of the actions

☐ Do not support these actions

☐ Do not know

☐ Neutral

Reason/Comments:

While exotic afforestation is likely to provide increased rate of sequestration per hectare in the short term, permanent native reforestation/afforestation provides the ability to sequester carbon for longer periods with fewer negative impacts associated with monoculture planting and harvesting such as risk of landslides when the forests are harvested. We would encourage a mechanism that allows transition of land use on blocks of land from exotic to native forest over a period of time.


Waste

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

Our response:

☒ Support all the actions

☐ Support some of the actions

☐ Do not support these actions

☐ Do not know

☐ Neutral

Reason/Comments:

Toitū’s customers have expressed to us that the key challenges in reducing waste emission include:

  • Availability of suitable recycling infrastructure in NZ
  • Costs of recycling that are higher than waste disposal to landfill (increased landfill levies may help this)
  • Lack of available information about options for diverting waste from landfill
  • Lack of waste stewardship schemes, meaning that packaging and other waste materials are not made the responsibility of the parties that initially create the materials.

Toitū recommends improved availability of information regarding options for recycling and reuse, and improved drivers for consistency across NZ about treatment of waste and recycling streams.


Multi-sector strategy

Consultation question 19: Do you support the package of recommendations and actions to create a multisector strategy, and is there anything we should change?

Our response:

☒ Support all the actions

☐ Support some of the actions

☐ Do not support these actions

☐ Do not know

☐ Neutral

Reason/Comments:

Toitū strongly agrees that improved behaviour change initiatives should be implemented across all sectors in NZ, including provision of information and incentives for rapid behaviour change.

  • We recommend the Commission be more assertive about the role of mobilizing capital to support reducing GHG emissions.
  • We recommend that work be undertaken to improve the ability of the voluntary sector to act without affecting the ETS cap
  • The Government plans to make climate-related financial disclosures mandatory for some organisations. We recommend that the Commission acknowledge and support the TCFD recommendations in its advice to government.

Rules for measuring progress

Consultation question 20: Do you agree with Budget recommendation 5 on the rules for measuring progress? Is there anything we should change any why?

Our response:

☒ Support all the actions

☐ Support some of the actions

☐ Do not support these actions

☐ Do not know

☐ Neutral

Reason/Comments:

Toitū strongly recommends that the Commission encourages government to enable a voluntary carbon credit market for NZ businesses. We have had strong feedback from our customers that it is important that they are able to continue to make carbon neutral claims. We agree that action in the voluntary sector should not have the result of reducing the action required from organisations within the ETS, so actions undertaken in the voluntary sector should not result in increases to the NZ ETS cap.


Our Nationally Determined Contribution (NDC)

Consultation question 21: Do you support our assessment of the country’s NDC? Do you support our NDC recommendation?

Our response:

☒ Fully support

☐ Partially support

☐ Neutral

☐ Do not support (too ambitious)

☐ Do not support (not ambitious enough)

☐ Do not know

Reason/Comments:

Toitū agrees that the NDC as currently written is unlikely to ensure that NZ contributes the share of global reductions necessary for us as a developed nation, and that our emissions reduction targets should be more ambitious.


Consultation question 22: Do you support our recommendations on the form of the NDC?

Our response:

☒ Support

☐ Somewhat support

☐ Do not support (too ambitious)

☐ Do not support (not ambitious enough)

☐ Do not know

Reason/Comments:

Toitū recommends the Commission update its recommendations to include additional conclusions it reaches in this section, i.e. that the government should:

  • Continue to actively pursue the development of international emissions reduction markets with strong environmental integrity so that it can access offshore mitigation, if required.
  • Develop a strategy for ensuring that the purchase of international units does not undermine the NZ ETS price signal
  • Develop and communicate a system for holding itself to high standards of environmental integrity in the offshore mitigation it applies to the NDC.

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

Our response:

☒ Support

☐ Somewhat support

☐ Do not support (too ambitious)

☐ Do not support (not ambitious enough)

☐ Do not know

Reason/Comments:

Toitū believes that NZ is more likely to achieve stronger reductions in line with the reductions needed to limit global warming to 1.5 degrees if the voluntary sector is enabled to contribute through the ability to fund reductions beyond their organisation in a way that allows them to make carbon neutral claims. We recommend that the advice to government addresses the need for improved ‘space’ for the voluntary sector to contribute to international reductions targets. This would require the ability to make carbon neutral claims relating to purchases of carbon credits both within and beyond NZ.


Eventual reductions in biogenic methane

Consultation question 24: Do you support our assessment of the possible required reductions in biogenic methane emissions?

Our response:

☒ Fully support our assessment

☐ Somewhat support our assessment

☐ Do not support our assessment

☐ Do not know

☐ Neutral

Reason/Comments:

Toitū Envirocare fully agreed with the approach and recommendations of the Commission