Auckland Diocesan Synod 2019

Synod 2019 starts next week and St Andrews Pukekohe is represented in four of the eight Motions to be presented.

Jan Wallace is seconding two Motions, one on getting the Seasons program operating in more parishes, the other on pushing the Diocese to do more around Climate Change Actions.

Vicky Mee is also seconding two motions, one on the Diocese taking a stance on improving housing for the elderly, the other on the preparation of a Diocesan Zero Carbon Plan.
For me, I am moving the Motion for Council to prepare a Diocesan Zero Carbon Plan and had a hand in writing the Climate Change Action Motion.  These are subjects that are important to me.

So why would we want the Diocese to prepare plans around climate change?

To me, there are two prime reasons.  

One is about resilience in the wider Anglican community.  Even though we do not yet have a firm idea of their form, significant climate-induced changes are coming and if no one is planning to meet the challenges of those changes, then we will have failed our Church community.  

The other is about social justice, the justice of the burden of climate change being carried by those who have contributed the least to the drivers of global warming that have led to climate change.

Is there a role for our Church to play in these two aspects?  What do you think?

—-
Image from aucklandanglican.org.nz

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ANGLICAN SOCIAL JUSTICE GROUP Submission on the Zero Carbon Amendment Bill

_________________________________________________________

15 July 2019

Submission on the Climate Change Response (Zero Carbon) Amendment Bill

To: the Committee Secretariat, 
Environment Select Committee
Parliament Buildings 
Wellington 6160

From: The Anglican Diocese of Auckland Social Justice Group of the Anglican Church in Aotearoa, New Zealand  and Polynesia.

We DO wish to speak to this Bill if the Select Committee comes to Auckland.
Contact Person: David Hall

Our interest in this Bill is because we, as the Social Justice Group of the Tikanga-Pakeha Diocese of Auckland, are committed to the five-fold Mission Statement of the Anglican Communion and in particular “seek to transform unjust structures of society “and “to strive to safeguard the integrity of creation and sustain and renew the life of the earth”. 

 (I) To proclaim the good news of the Kingdom;
(ii) To teach, baptise and nurture new believers;
(iii) To respond to human needs by loving service;
(iv) To seek to transform unjust structures of society; 
(v) To strive to safeguard the integrity of creation & sustain & renew the life of the earth 

In addition, the Global Anglican Communion at a meeting of its highest governance body, the Anglican Consultative Council  (ACC) in Hong Kong in April 2019 passed the following motion on Climate Change:

1. recognises that there is a global climate emergency
2. affirms that the Fifth Mark of Mission is clear, ‘To strive to safeguard the integrity of creation, and sustain and renew the life of the earth’, but that it only becomes a living testament to our faith when it is pursued in an integrated way across all five Marks of Mission
3. calls the Member Churches of the Anglican Communion to use a day during the Season of Creation, for a day of public repentance
4. requests every Member Church to develop an action plan, and resources, for sustainable living at individual, parish, diocesan and provincial level; including, but not limited to, policies and procedures to minimise waste, increase use of renewable energies, and incorporate creation care into liturgical practice
5. requests each Member Church to prepare a Lenten Fast for Creation
6. encourages the Lambeth Conference 2020 to set aside a time of repentance for the climate and environmental crisis
7. encourages Lambeth Conference 2020 participants to utilise carbon offset arrangements in their travel plans 
8. encourages each Member Church to hold a strategic planning conference on the Sustainable Development Goals and Climate Change, ensuring the involvement of Indigenous, young, and women’s voices, and to report back to ACC18
9. asks Member Churches to identify environmental and climate-related threats in their context and to develop or adapt existing tools on disaster preparedness and mitigation.

1. General Comments in support of the Bill:

We support this Bill as a first step to addressing the potential disaster that awaits us as a nation, and as the world, if we do nothing and continue to pour more and more greenhouse gases into our atmosphere. We are pleased that the Government has decided to use the 1.5 degrees C as the target rather than 2 degrees. But we are aware that even a 1.5-degree rise will have an adverse impact on our country and the world by 2050 and an even more adverse impact by the end of the century. The long-term aim of New Zealand and the world must be to reduce the total amount of greenhouse gases in the atmosphere, not just stop the increase.

2. Functions of the Climate Change Commission

We overall support the functions of the Climate Change Commission as detailed in the Bill. It would be inappropriate and potentially harmful for the Commission to have an executive power. Its roll is advisory. We strongly support the requirement in clause 5K 4 that any advised the Commission gives to the Minister must be publicly available although we would ask that the word “immediately” be added between “available” and “after”. This should also apply to subsequent clauses requiring the publication of information by the Commission or the Minister,

We also suggest that the likely effects of all types of recommendation include the impact of not acting.

Clause 5R 1 gives the Minister 12 months to respond to any recommendation of the Commission. In view of the urgency for action this is far too long a period for governments to prevaricate. We suggest the period be reduced to 3 months maximum.

Clause 5ZA requires publication of emissions budgets after consultation with all political parties in the House of Representatives but puts no time limit on the response from political parties. We recommend that a time limit of 2 months be added and also a requirement that if a political party fails to agree to a particular budget the nature and reasons for their disagreement be made public.

Clause 5XL allow Ministers to issue guidance to departments but fails to require a department to follow the guidance. We suggest that the issue is so important that if the Minister issues guidance to a department then the department should be required to follow that guidance.

3. Separate targets for Carbon Dioxide and Methane.

Whilst we understand the reasons for having separate targets for Carbon Dioxide and Methane, this does raise some concerns:

  • The target of zero net emissions of Carbon Dioxide by 2050 is in line with recommendations from the IPCC reports and the Paris Agreement however we strongly recommend that an addition target be added for 2030  that 50% of the reductions needed to reach the zero emissions target be achieved.  This will be a very valuable monitor of progress towards the Zero emissions target. If all the emission reduction happens in the last few years of the period, it is very likely that the 1.5degree rise will be exceeded.
  • We note the inclusion of a target for methane reduction by 2030 of 10% but are concerned about the wide range of the target for 2050 of 24% to 47% by 2050. The very wide range of this target is of concern as we would have thought a more specific target should be set. 
  • We are also concerned that the base for methane is 2017 emissions. New Zealand has seen a very fast rise in methane emissions over the last 30 years which needs to be reversed. Methane in the atmosphere has an impact on Climate Change for a shorter time than other Greenhouse Gases, maybe as short as 25 years, but it still contributes very significantly to global warming and needs to be addresses quickly.

4. Contrasts between the Explanatory Note and the wording of the Bill.

There are a number of statements in the Introduction to the Bill that are either not mentioned in the Bill itself or are different including

  • The first paragraph of the Note states that the aim is to limit temperature rise to 1.5 degrees above pre-industrial levels yet for all gases except Methane the reference point is 1990 and for methane 2017. This implies that there was not temperature rise caused by these gases from the late 1700s until 1990.  
  • Paragraph 2 of the Note says the “overarching purpose represents………just mentioned as factors that the Commission must take into account when making recommendations to the Minister. Climate Change will have much greater impact on the poor both worldwide as well as in New Zealand, the impact of not acting will be very much to the disadvantaged of the poor. Furthermore, the rich 1% have contributed significantly more to Climate Change and will continue to do so. They also gain, at least in the short term, from not acting on Climate Change.
  • In the first paragraph of the Introduction it is indicated that “The overarching purpose represents a balance of the guiding principles agreed by Cabinet to frame the development of climate change policy: leadership at home and abroad; a productive, sustainable, and climate-resilient economy; and a just and inclusive society”, however there is no mention of a just and inclusive society anywhere in the Bill. We believe that it is vital that this be included as an overarching purpose of the Commission. Furthermore, we recognize that Climate Change is an intergenerational justice issue and provision needs to be made for the voice of young people. who will be most affected by Climate Change, to be heard and listened too.  

5. Beyond 2050

Even if, as a world community, we are successful in limiting global warming to 1.5 degrees by 2050 that will not be the end of the crisis. The science indicates that there will be significant negative impacts on life on our planet after a 1.5 degree rise. 

We suggest that there be provisions in the Bill to continue the work of emissions reduction particularly as it is possible that even if a “zero carbon” situation is achieved by 2050 there is the possibility of further global warming beyond 1.5 degrees.

Thank you for considering our submission and we look forward ot the opportunity of sharing our concerns in person on this issue that is vital to life on our planet.

David Hall

Auckland Anglican Diocese Social Justice Group

Anglicans CAN submission on the Zero Carbon Amendment Bill

Submission to the Environment Select Committee on the Climate Change Response (Zero Carbon) Amendment Bill 2019

Anglican Climate Action Network
Contact person: Dr. Richard Milne

Summary of recommendations
  • That the purpose of the Zero Carbon Act be clearly stated in the Act.
  • That the proposed Climate Change Commission be expanded to include at least one Māori person and two persons under 30 years of age, one male and one female. 
  • That the Climate Change Commission sets targets based on cumulative greenhouse gas emissions rather than annual or 5-yearly emissions.
  • That the Bill strengthens its targets for biogenic methane emissions, considering the need for a fair and just transition from present agricultural methods to low emissions agriculture.
  • That the Climate Change Commission be tasked to set a limit on the carbon emissions that can be compensated through the emissions trading scheme.
  • That the Bill includes a provision which requires the Climate Change Commission to provide advice to the Government on how emissions-reduction and adaptation policies can best ensure that the burden of adjustment is shared fairly and that the extractive industries, agriculture and forestry and least advantaged citizens are assisted in practical ways to adjust. 
  • That the Minister be given 3 months rather than 12 months to respond to any recommendation of the Climate Change Commission (clause 5R1). 
  • That emissions budgets be published within 3 months of consultation with all political parties, and that any reasons for disagreement be published (clause 5ZA).
  • That government departments be required to follow the recommendations of the Minister (clause 5XL).

Who we are

The Auckland Anglican Climate Action Network is formally acknowledged and resourced by the Anglican diocese of Auckland to work towards a carbon neutral New Zealand. To this end, since 2006 we have worked towards divestment of church resources from the fossil fuel industry; provided education on climate change and sustainable living at parish level; conducted audits of church buildings (energy/water/waste/food production and consumption); advocated for more efficient use of clergy vehicles including electric cars; developed community gardens; and made connections with other Christian churches with similar intentions. 

In addition, the Global Anglican Communion at a meeting of its highest governance body, the Anglican Consultative Council, in Hong Kong in April 2019 passed the following motion on Climate Change (abbreviated):

recognises that there is a global climate emergency

requests every Member Church to develop an action plan, and resources, for sustainable living at individual, parish, diocesan and provincial level; including, but not limited to, policies and procedures to minimise waste, increase use of renewable energies, and incorporate creation care into liturgical practice

encourages each Member Church to hold a strategic planning conference on the Sustainable Development Goals and Climate Change, ensuring the involvement of Indigenous, young, and women’s voices, and to report back to ACC18

asks Member Churches to identify environmental and climate-related threats in their context and to develop or adapt existing tools on disaster preparedness and mitigation

We accept the very strong scientific evidence that progressive increases in mean surface temperatures (‘global warming’), resulting in major changes to the Earth’s climate and ecosystem, are caused largely by burning of fossil fuels (coal, oil and natural gas) and progressive deforestation in Nigeria, Indonesia, Brazil, China, New Zealand and elsewhere. Therefore, we believe that the emphasis of the Bill should be on transitioning to a low or zero carbon economy as rapidly as possible, and sequestration of carbon through reforestation and other means.

Endorsement

The Anglican Climate Action Network endorses the proposed Zero Carbon Bill with an architecture for emissions reductions in New Zealand, with strengthening (see below). We support the global goal to limit warming to 1.5°C above preindustrial levels and the signal of solidarity with Pacific Island Nations that are already suffering from rising sea levels, thought to be a consequence of melting of the glaciers and polar ice caps and expansion of warming oceans. We also endorse the formation of an independent advisory Climate Change Commission, operating under the principles of social justice, intergenerational justice and Te Tiriti o Waitangi.

Matters for the Select Committee to consider. 

Recommendation: that the purpose of the Zero Carbon Act be clearly stated in the Act.

“The purpose of the Climate Change (Zero Carbon) Amendment 2019 Act is to enable Aotearoa New Zealand to contribute to limiting global warming to 1.5°C in accordance with the IPCC 1.5 degrees report (2018).”

  • We acknowledge that, without similar actions in other countries, reductions in carbon emissions in New Zealand will make little or no measurable difference to the global mean atmospheric temperature or the local climate. However, for moral reasons and because of New Zealand’s commitment to the Paris Accord, this fact does not provide an excuse to have weak ambitions around reducing our carbon emissions.
  • New Zealand is in a unique position geographically and strategically, being a relatively wealthy country located on the Pacific rim, which can take a moral lead over other developed countries in reducing carbon emissions for the common good of the Earth and all its inhabitants.
  • it is very clear that the future cost of weak emissions policies will be born largely by those individuals who were born after about 1970. Reducing carbon emissions therefore is a matter of intergenerational justice.
  • It is also clear that the future cost of weak emissions policies will selectively disadvantage the poorest sectors of our community, who cannot afford to buy themselves out of trouble (e.g. by relocating away from the coast or adjusting to increases in food prices brought about by flood- or drought-induced food insecurity). This is a matter of social justice.

Composition of the Climate Change Commission

Recommendation: that the proposed Climate Change Commission be expanded to include at least one Māori person and two persons under 30 years of age, one male and one female. 

In order to honour Te Tiriti o Waitangi and Māori cultural values, and the potential impact of carbon reduction policies on Māori, it is important that at least one Māori person be represented on the Commission.

We recommend that the proposed Climate Change Commission be expanded to include two persons under 30 years of age, preferably one male and one female, to be nominated by one or other of the organisations of young people that are making submissions on the ZCB (such as Generation Zero and 350.org).

Speaking as parents and grandparents, we are aware that many thoughtful young people are deeply concerned about their future and need to be reassured that their Government is taking strong steps to mitigate climate change and to demonstrate moral leadership to the rest of the world. Their concern has been evident in protests and school strikes, and in formation of strong NGOs dedicated to action on climate change. Collectively, these young people hold a lot of wisdom as well as passion, and this needs to be explicitly recognised by direct participation in the Climate Change Commission. 

Emissions targets

Recommendation: that the Climate Change Commission sets targets based on cumulative greenhouse gas emissions rather than annual or 5-yearly emissions.

While the Bill declares support for a 1.5°C warming cap (above pre-industrial levels), the targets are not consistent with this goal. 

The key issue is what our cumulative emissions will be over the next 30+ years. A fast reduction path over the next 10-15 years followed by a slower reduction path over the subsequent 15-20 years will deliver much lower cumulative emissions than a slow reduction path in the near term followed by a rapid, probably panic-driven steep reduction path later. 

The IPCC 1.5°C report suggests that to have a 50% chance of staying within the 1.5°C warming limit (with little or no overshoot) will require global CO2 emissions to fall by about 45% compared to 2010 levels by 2030. The Bill therefore must commit to a reduction of this magnitude by 2030.

Given NZ’s large cumulative emissions to date and our current high per capita emissions (both of long-lived gases and GHG emissions overall), together with our relatively high GDP per capita, there is a very strong case, based on well-established principles of distributive justice, for NZ to commit to a faster reduction in long-lived GHG gases than the global average (i.e. of 45%). Aside from this, a 50% chance of avoiding more than 1.5°C warming entails a very high risk of failing and heading towards global climate catastrophe.

Biogenic methane emissions

Recommendation: that the Bill strengthens its targets for biogenic methane emissions, considering the need for a fair and just transition from present agricultural methods to low emissions agriculture.

The Bill in its present form has very weak targets for reduction of biogenic methane emissions. We acknowledge the impact on the farming community of having stronger targets for methane emissions and we acknowledge the scientific argument that biomethane is short lived and is in a stable equilibrium and therefore does not contribute directly to growth in annual carbon emissions or further global warming. 

However, any methane in the atmosphere contributes to global warming, regardless of its origin. Warming of the Arctic Circle is thawing the permafrost and thereby releasing methane, leading to positive feedback (i.e. increased warming leads to more methane which leads to increased warming). Ultimately, this could lead to dangerous tipping points and atmospheric temperatures that increase beyond the level that humanity can survive. Therefore, we believe that it is imperative that all nations reduce methane from all sources. In New Zealand, this requires much stronger targets than the Bill allows for currently. We submit that the Climate Change Commission should research this issue immediately and recommend a much stronger methane emissions pathway, finding ways to compensate the agricultural sector, especially dairy farming. 

The emissions trading scheme

Recommendation: that the Climate Change Commission be tasked to set a limit on the carbon emissions that can be compensated through the emissions trading scheme.

We are concerned that the emissions trading scheme can provide an excuse for failing to reduce carbon emissions directly. In this respect, it is like the mediaeval system of buying indulgences to compensate for bad behavior. Therefore, we believe that there should be a limit to the quantity of carbon emissions that can be traded.

On a just and inclusive society

Recommendation: that the Bill includes a provision which requires the Climate Change Commission to provide advice to the Government on how emissions-reduction and adaptation policies can best ensure that the burden of adjustment is shared fairly and that the extractive industries, agriculture and forestry and least advantaged citizens are assisted in practical ways to adjust. 

The Paris Agreement acknowledges that climate change is a common concern of humankind and that negotiating parties should, when taking action to address climate change, respect, promote and consider their respective obligations on human rights. These include the right to health, the rights of indigenous peoples, local communities, migrants, children, persons with disabilities and people in vulnerable situations; also, the right to development, gender equality, empowerment of women and intergenerational equity.

The Explanatory notes of the Bill begin with an overarching purpose which includes ‘a just and inclusive society.’ However, this provision, which is also used extensively in the Regulatory Impact Statement, is not used in the Bill. Instead there is a requirement to consult affected communities, and 

  • (a) take account of economic, social, health, environmental, ecological, and cultural effects of climate change, including effects on iwi and Māori
  • (b) take account of the distribution of the effects of climate change across society, taking particular account of vulnerable groups or sectors(5ZQ4) 

Therefore, equity considerations need to be strengthened in the New Zealand bill. In particular, New Zealand needs to find ways to share the burden of reducing the size of ruminant herds; also providing employment and income support policies for changes in work and for retraining, with particular forecasting of training needs for renewable-energy industries and low-emission agriculture. 

Adaptation

Recommendation: that the Climate Change Commission be tasked to provide advice to the government on adaptation of society and of the economy to the predicted increase in extremes of temperature, drought, fires, flooding, fires, sea level rise and other outcomes of global warming.

The need for adaptation will become more evident as global atmospheric and oceanic temperatures keep rising. We submit that the most urgent task for the proposed Climate Change Commission is to advise on mitigation will in order to meet our international commitments; and a less urgent but equally important task is to advise on adaptation.

Specific recommendations

  1. Clause 5R1 of the Bill gives the Minister 12 months to respond to any recommendation of the Climate Change Commission. In view of the urgency for action this is far too long a period for governments to prevaricate. We recommend that the period be reduced to 3 months maximum.
  2. Clause 5ZA requires publication of emissions budgets after consultation with all political parties in the House of Representatives but puts no time limit on the response from political parties. We recommend that a time limit of 3 months be added and also a requirement that if a political party fails to agree a particular budget, the nature and reasons for their disagreement be made public.
  3. Clause 5XL allow Ministers to issue guidance to departments but fails to require a department to follow the guidance. We recommend that the issue is so important that if the Minister issues guidance to a department then the department should be required to follow that guidance.

Signed:

 Dr. Richard Milne (Co-Convenor)
Dr. Nicola Hoggard-Creegan (Co-Convenor)

On behalf of:

Dr. Bobbi Laing
Mr. Lane Hannah
Rev’d Jim Hunt
Mr. Rod Oram

Personal submission on the Zero Carbon Amendment Bill

This is my personal submission on the Zero Carbon Amendment (ZCA) Bill. Social Justice figures large in it, as does the shortfall between ambition and what is required to meet the Paris 1.5° C goal. But the main thrust of my submission is around the improper and incorrect framing as agricultural emissions being a 48% driver of New Zealand emissions.

Submission on the The Climate Change Response (Zero Carbon) Amendment Bill (ZCA Bill)

Thank you for the opportunity to comment on the ZCA Bill.  This submission is a personal one, in the name of W John Allen.   I want to be heard in person at a hearing considering submissions.

Bill is opposed

Whilst the intentions of the ZCA Bill are applauded, I believe that, as written, it will not achieve its purposes and is therefore opposed on these grounds:-

  • Part 1: it provides no basis for ensuring social justice in the implementation of mitigation and adaptation actions
  • Part 2: it’s goal of contributing to the global effort to limit global warming to 1.5° C1 is not achievable as the Bill is written and is inconsistent with the aims of the IPCC SR15 report
  • Part 3: the framework provided under the Bill is predicated on a falsity and thus mitigation policies, targets and in particular, social justice aspects, will remain neither clear nor stable when those falsities are corrected:-
    1. The Bill does not recognise a fundamental aspect of the science around climate change.  That is, that the single cause of global warming is the unbalancing of nature’s carbon cycle.
    2. CO2 targets are set on a net basis, meaning that forestry offsets accrue to fossil CO2 emissions.  However, the CH4 target is set on a gross basis, meaning that the CO2 sinks that generate that CH4 (pasture grasses and fodder), are excluded.
    3. A further distinction between biogenic and fossil methane is required:
      1. to ensure justice and equity for ruminant farmers
      2. fossil methane must be reduced to zero in the shortest timescale possible.
      3. biogenic methane emissions are declining or stable, and so do not contribute to warming as much as many want it to. 
      4. if forced methane reductions are the means to relieve pressure on the reduction rate of fossil CO2 emissions, then ruminant farmers must be paid a price that reflects their lost revenues
    4. Contrary to the assertion that the Bill seeks to strike a balance between flexibility and prescription in NZ’s long term transition, it is very prescriptive around methane emissions.

The Explanatory Note to the ZCA Bill announces its purpose as providing a “… framework by which New Zealand can develop and implement clear and stable climate change policies that contribute to the global effort under the Paris Agreement to limit the global average temperature increase to 1.5° Celsius above pre-industrial levels”.  And goes on to argue that the overarching purpose “represents a balance of the guiding principles … to frame the development of climate change policy: leadership at home and abroad; a productive, sustainable, and climate-resilient economy; and a just and inclusive society.”

As argued below, the framework will be neither stable nor clear in the long term, because it  maintains business-as-usual, and thus is not balanced, and is counter-productive, unsustainable, unjust and exclusive.

The ZCA Bill will not solve the problem before us even while we give ourselves the illusion that we are in process to solving it.  Hence I cannot support it.

Part 1: Social Justice provisions

The elephant in the room of climate social justice is that people with high discretionary incomes contribute much more to global emissions than those without.  This is true both across international borders and within this country.  

A 2014 report by Motu Economic and Public Policy Research2 quantified this difference in New Zealand as a near four-fold inequality: Decile 1 -> 9.48 T CO2e pp compared with 35.67 T CO2e pp for Decile 10.  So it follows that the costs of both mitigation and adaptation actions must fall more on the rich than on the poor.

The ZCA Bill does not include specific provisions to protect those who have a reduced ability to cope with the costs of mitigation and adaptation actions.

The only reference to ensuring social justice within the ZCA Bill as written, is in the adaptation section (5ZQ(4) which provides for “the distribution of the effects of climate change across society, taking particular account of vulnerable groups or sectors: “.  This is just words and words do not offer protection to those who need it.

Further, the Emissions Trading Scheme (ETS) is seen as the key tool in meeting emissions budgets and achieving the 2050 goal.  It will therefore, add to the cost of living for all New Zealanders.  However, there is no provision in the ZCA Bill to return ETS revenues to the poor or at-risk communities as a social justice measure.  It is therefore, a regressive provision, and will likely result in even greater economic inequalities as the poor will end up paying a disproportionately higher percentage of their income on ETS costs, than the rich will pay.

The experience requirements of the Climate Commissioners will preclude those who do not identify with the rich or influential or politically connected people and so may not select people with practical experience of being vulnerable.  Therefore, the voice of those needing economic protection will not be heard by government.

recommendations
  1. Include Social Justice provisions within the mitigation and adaptation sections of the ZCA Bill.
  2. Include provisions for ETS revenues to be returned to the people as a part of those Social Justice provisions.
  3. Add to the mandate of the Climate Commission, the monitoring of the justness and fairness of climate actions.
  4. Change the selection criteria for Commission members to include those with practical experience of being vulnerable.

NOTE: The ETS was retained as New Zealand’s key tool for meeting emissions budgets on the basis that it was too difficult to develop a new system.  A new carbon tax based system is well justified when considering social justice matters and the regressive nature of the ETS.  I would like to propose a new system, one that combines a consumption-based personal/business carbon budget (T CO2e/year) with a declining carbon cap (T CO2e) and an increasing carbon tax ($/T CO2e) charged on local production and imports, but not exports (to protect export receipts).  Manipulating the carbon tax rate (up) and the carbon budget (down) would be the primary means of controlling consumption emissions.   Products that incur a carbon tax will have the tax added at the point of sale with the collected tax being refunded annually up to the value of the cap.   Such a system would be progressive – those spending within their cap will not incur additional costs but those spending above it will pay that amount of the carbon tax that exceeds the product of their carbon budget (T CO2e/year) multiplied by the carbon tax ($/T CO2e).

Part 2: Consistency with the IPCC SR15 Report

The explanatory notes to the ZCA Bill argue for consistency with the goals of the IPCC SR15 report.   As a principle, this is agreed with but is not consistently applied in the ZCA Bill.  The IPCC SR153 report:

  • warns that limiting warming below or close to 1.5 °C , requires net emissions to decrease by around 45% by 2030 and reach net zero by 2050 (para C.1).  The first aspect of this warning is not included in the ZCA Bill.
  • argues for 
    • “deep reductions in emissions of methane” of at least 35% by 2050, relative to 2010 (para C.1.2).  Note that this is a reference to methane from all sources and that on a global scale, fossil methane emissions are forecast to be around 44%4 of total anthropogenic methane.
    • Figure SPM.3b of the IPCC SR15 report records the interquartile range from all model pathways with no or limited overshoot, for the reduction of “agricultural”methane by between 24% to 47% from 2010 levels at 2050.   
    • The report specifically excludes these data from necessarily being used to set national emissions reduction strategies (Figure SPM.3b: “These pathways illustrate relative global differences in mitigation strategies, but do not represent central estimates, national strategies, and do not indicate requirements.”).  
    • Contrary to this qualification, and an opinion expressed by the NZAGRC5“While this range can serve as a reference point, it does not in itself prescribe a specific target for methane emissions reduction by any individual country. A national target necessarily depends on national value judgements around what is an appropriate contribution by New Zealand and the economic cost of reducing emissions… 
    • the ZCA Bill seeks to enshrine this 24%-47% range in legislation.  This appears to be a politically motivated target, without value judgements and so is also not consistent with the IPCC SR15 report. 
  • argues that “all pathways that limit global warming to 1.5°C with limited or no overshoot project the use of carbon dioxide removal (CDR) on the order of 100–1000 GtCO2 over the 21st century.”   Carbon sequestration actions are not mentioned in the ZCA Bill which is then, not consistent with the PICC SR15 report.

Thus the ZCA Bill is inconsistent with the IPCC SR15 report on at least four counts:

  1. No inclusion of an interim (2030) CO2 reduction target.
  2. Focuses on agricultural methane (page 4).  Elsewhere in the ZCA Bill, the focus is on biogenic methane, so the one use of agricultural methane demonstrates and inherent bias against agriculture in the formulation of the Bill.
  3. the ZCA target for methane reduction of 24%-47% by 2050 is a consequence in modelling work and goes against IPCC expectations of it not being used as an emissions reduction target.
  4. Carbon Dioxide Removal technology is not included at all.
recommendations

Amend the ZCA Bill to be consistent with the IPCC SR15 report by:

  1. including a 2030 emissions reduction target of a 45% reduction below 2010 levels.  This equates to a 34% reduction below 1990 levels and would replace our existing 2030 goal of an 11% reduction below 1990.
  2. amend all references to “agricultural methane” to “biogenic methane”
  3. The biogenic methane reduction target of 10% to 2030 can be exceeded with a focus on agricultural manure management (4.3% of total CH4), waste management (11.7% of total CH4)  and Energy (2.6% of CH4 total) (all data from Table 10s3 of MfE 2017 GHG Inventory)
  4. Delete the biogenic methane reduction target of 24% to 47% (from 2010 levels at 2050) from the ZCA Bill and allow the Climate Commission to develop a 2050 target once impacts of the 10% reduction (to 2030) are better understood and once progress on the IPCC emissions reduction pathways is clear.
  5. Add Carbon Dioxide Removal (CDR) targets to the ZCA Bill.  In support of this, I have used biochar for three years to make our Earth Day events carbon negative.  Whilst Biochar is a valid and effective carbon sequestration technology, it is not getting government support for its development.  Part of the reason for this is the manufacturing cost of biochar makes it uneconomic compared to ETS values.  Biochar production costs will not come down to approach ETS values until its production technologies are studied and developed.
    1. This requires that Biochar as a CDR technology be brought in to the ETS.

Chart 1 below shows that methane from all sources is essentially static and so is not contributing to further warming to any significant extent.  It also shows the accumulated emissions of various gases since 1990.  Methane, on a CO2eq basis, has the lowest accumulated emissions than any of the GHG gases and so contributes the least to global warming in terms of Global Warming Potential.  The decline in forestry sinks however, has made the second largest contribution to New Zealand’s emissions profile.

Part 3: Framing of the drivers of global warming

The present framing of our carbon emissions is counter-productive to actually reducing emissions.  This framing presents agriculture as being responsible for 48% of national emissions (data from 2017 GHG Inventory) with the consequence that mitigation actions are widely viewed as something for the agricultural sector to address.

This framing ignores a number of relevant points.  One is that 100% of the methane emissions are derived from carbon already within the carbon cycle.  Another is that enteric methane is a part of the natural world and thus has a role to play in global environments.

A reframing would recognise that there is but a single driver of global warming and were the issues we face framed in terms of that single driver, the solution to the predicament we now face, would be the focus of this Bill.  Instead, the Bill focuses on maintaining and protecting the economic system, that led to our problems.

That single driver is the unbalancing of nature’s carbon cycle. That balance has been so grossly upset, that it is now beyond nature’s capacity to restore it for perhaps centuries.    Science is clear on two things: that increasing green house gas concentrations in the atmosphere, leads to the greenhouse effect and thus, to global warming; and that it is human activities that caused that increase in gas concentrations.

The two human activities that are are the primary drivers of global warming are: 

  1. increasing greenhouse gas concentrations in the atmosphere through the mining and burning of fossil fuels. (releasing previously sequestered fossil CO2 and fossil CH4). 
  2. the removal of global carbon sinks – forests – that leave more gases in the atmosphere and so are equivalent to new emissions

If global warming was framed as a consequence of these two drivers, then we would deal with fossil fuel use and with deforestation.  Instead, many see agricultural emissions, at 48% of New Zealand’s total emissions, as the primary cause.  The problem with this is that it gives many the reason to not address the two actual primary causes.

The chart below gives the lie to this framing.  This shows New Zealand’s cumulative emissions growth (by gas) since 1990.  CO2 has contributed more than five times that of CH4 (CH4 as CO2equivalent).  It also shows the extent that forestry removals have declined since 1990.  On the basis that removing forestry sinks is equivalent to increasing CO2 emissions, then the LULUCF sector is the second largest contributor to the increase in NZ’s emissions since 1990 (3.6 times more than the contribution from CH4).

Chart 1: Where has the increase in emissions has come from?
Not methane to a significant amount compared to fossil carbon and forestry harvesting.

In using the term net-zero emissions, the ZCA Bill implicitly promotes offsetting the CO2 emissions from fossil fuel use and ignores the impact of forestry on our emissions profile.   It also excludes the offsetting of CH4 emissions and more importantly, ignores the carbon consumed by ruminants as it cycles through pasture forages and the atmosphere via ruminant’s guts.

It is clear that rapidly reducing CH4 concentrations has a big impact on global warming and will enable a more orderly transition away from fossil fuels.  There are two aspects to this observation.  One is that ruminant farmers ought be paid for reducing CH4 emissions below the steady state (and by corollary, pay for increasing emissions above the steady state.  Second is a consideration of whether biogenic or fossil methane has caused global warming, or whether rising carbon dioxide levels is leading to the release of previously sequestered methane that would not have otherwise been released.

Changing this framing would mean a number of things:
  1. We would focus on what the world needs – a gross-zero carbon future in which new-to-the-atmosphere carbon emissions are eliminated.   A low-carbon, reduced-carbon or net-zero carbon future still releases new-to-the-atmosphere fossil carbon and so is not solving the underlying problem. 
  2. We would not look to ruminant farmers to solve our problem in the short term, by giving us breathing space to address fossil fuel emissions.
  3. I notice that no-one is suggesting that foresters must cut back on their forest harvesting work as a climate mitigation effort.  If foresters delayed harvesting by some number of years, then income from those forests would be delayed but not sacrificed (unlike the permanent loss of income to ruminant farmers who de-stock).   This would go a long way to helping the world to avoid increasing emissions thru to 2050.  The attached Cumulative Growth in CO2eq chart shows a major reduction in forest harvesting in the 2008 GFC, so do it foresters can.
  4. Carbon offsetting would be stopped and forestry plantings would then be a Carbon Dioxide Removal tech.
Pay ruminant farmers to reduce methane emissions

It has been suggested6 that there is a “main opportunity” to reduce livestock numbers as a means to reducing emissions significantly.  This implies an expectation that ruminant farmers will reduce stocking rates.  There is some merit in such an imposition.  However, if implemented, this must be fair and equitable to farmers. but there are no such provision for fairness nor equity written in to the ZCA Bill.  Further, the emissions reduction opportunity available from foresters is even more significant than that from ruminant farmers but with revenue impacts.

As a matter of interest, the average New Zealand dairy farmer grosses around $2,400 per milking cow per year (372 Kg MS data from Dairy NZ x Fonterra price of $6.40/Kg MS May 2019).  The ETS value of a cow’s enteric fermentation emissions (83.16 kg CH4/head/yr) plus emissions from  manure management (7.70 kg CH4/head/yr) is valued at around $56 (at an ETS price of $25/T CO2eq).  Paying farmers only the annual ETS value of their saved emissions is not at all fair and equitable compared to the earning forgone through de-stocking.

As another matter of interest, (the calculations have not been attempted) requiring foresters to delay harvesting forests will have a similar impact (of giving a quick reduction in warming impacts) as requiring farmers to de-stock.  Except that foresters will suffer only a delay in their earnings whereas ruminant farmers will suffer a permanent loss of earnings.

REMEDY
  1. That the ZCA Bill establish a fair and just calculation for the lost opportunity cost for ruminant farmers to de-stock as a global warming mitigation action.
  2. That the ZCA Bill establish a fair and just calculation for the lost opportunity cost for foresters to delay harvesting forests as a global warming mitigation action.
  3. That the ZCA Bill recognise and account for the atmospheric carbon embodied in the pasture grasses that ruminants consume.

——

References:

1 Part 1, clause 4(aa)
2 p17, Greenhouse Gas Emissions in NZ: A Preliminary Consumption-Based Analysis. April 2014, Motu Working Paper 14-05
3 https://report.ipcc.ch/sr15/pdf/sr15_spm_final.pdf
4 https://www.globalmethane.org/documents/gmi-mitigation-factsheet.pdf
5 https://www.nzagrc.org.nz/knowledge,listing,593,scientific-aspects-of-new-zealands-2050-emission-targets.html
6 Mitigating agricultural greenhouse gas emissions: Strategies for meeting NZ’s goals, July 2018. Chief Science Advisor