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3 Additional Comments in Submissions

Several submitters made comments that were not covered by questions in the Post-2012 Measures discussion document, but which are relevant to climate change policy development. These comments have been recorded here, and relate to the following topics:

  • comments specific to Māori submissions

  • comments from the Greenpeace Aotearoa New Zealand form submissions

  • union/worker initiatives

  • research and development initiatives

  • impacts on public health

  • local government initiatives

  • incentives for small-scale renewable energy

  • additional general rates levy

  • Kyoto Protocol methodologies

  • targets for reducing emissions

  • New Zealand’s emissions profile.

Comments specific to Māori submissions

Submissions from Māori organisations emphasised a number of concerns, including:

  • the status of Māori as Treaty partner

  • the need for an integrated Sustainable Development Strategy as a starting point for climate change policy development

  • the importance of considerations of equity across economic sectors in terms of the policy impact

  • the incorporation of tikanga/value-based and evidence-informed analysis of climate change impacts

  • the need to consider the specific issues and realities facing Māori communities

  • the need for greater collaboration between government agencies on climate change

  • the need for inter-departmental resourcing of an active Māori reference group on climate change, with Māori determining the representation.

Comments from the Greenpeace form submissions

In summary, the Greenpeace form submission supported the following measures (relevant to the Post-2012 Measures discussion document):

  • the setting of bold greenhouse gas emissions reduction targets: a 30% reduction by 2020 and a 90% reduction by 2050 (from 1990 levels)

  • the introduction of a broad-based carbon charge by 2008, with emissions trading possibly phased in later

  • complementary measures such as: increased funding for energy efficiency projects; generating funds for energy savings through an Electricity Demand Fund; boosting solar water heating programmes; strengthening the Building Code to increase energy efficiency standards and encourage the use of smart meters; good urban planning; dramatically boosting funding for public transport; increasing the use of biofuels derived from sustainable sources; encouraging hybrid vehicles; increasing fuel efficiency standards; and providing assistance for the least well-off people in society during the economic transformation caused by climate change policies

  • an RMA requirement for local and central government to consider the effects of activities on climate change.

Suggestions relating to the other discussion documents were also made.

Union/worker initiatives

A submission from a union stated that climate change mitigation policies will have an impact on workers in New Zealand. Accordingly, the submission requested that the Labour Department be required to analyse and monitor the employment effects of climate change mitigation policies.

The submitter considered that there is great potential to increase union involvement in energy conservation and efficiency through a social partnership approach. They suggested developing a ‘Sustainable Workplace Plan’ (similar to the existing Health and Safety Workplans). This plan could be a requirement for public service organisations and a voluntary ‘goal’ for private sector organisations. Such measures may have co-benefits for quality standards at work, health and safety, and workplace productivity.

The submitter also suggested that shortages in labour and skill supply could become a major issue for emerging sustainable and environmentally friendly industries. Accordingly, the union urged the government to begin focused work with industry training organisations to ensure the necessary labour and skills are available to carry out future climate change policies. They suggested energy efficiency should be included in all trades training and engineering qualifications. They also argued that labour and skill supply could be particularly important for initiatives to increase the use of solar water heating, smart electricity networks, biofuels and retrofitting initiatives, along with wind, wave, tidal, hydro or geothermal initiatives.

Research and development initiatives

A submission from a research institute suggested that for Commitment Period One of the Kyoto Protocol (2008–2012), as well as investing substantially in measures to reduce emissions, the government must also invest in research on institutional and behavioural change. This could include monitoring emissions to demonstrate the return on investments, and accelerating research and development and implementation pathways for agricultural emissions reduction.

For any later international climate change agreement (beyond Commitment Period 1 of the Kyoto Protocol) the submitter recommended more rigorous consideration of sources of greenhouse gases and mitigation options. These studies should include climate feedback responses. For example, studies should include enhanced loss of carbon dioxide from soils with increasing temperature, and carbon losses from erosion and indirect greenhouse gas emissions (such as nitrous oxide emissions from waterways). They also recommended further research into the impact of climate change on business and infrastructure.

The submission suggested that the government needs to focus on working out what carbon neutrality means in practice for key export sectors, including:

  • assessing the risks and opportunities for the sector

  • undertaking a feasibility study to map out a methodology

  • developing the required calculators, including metrics for future key performance indicators

  • piloting the methodology with a representative sample of organisations for each sector, including highly respected (iconic) early adopters

  • establishing minimum standards and best practice for emissions reductions

  • rolling out the programme to each sector, with options for a verified emissions inventory (needed for reporting and disclosure), certified emissions reduction (an option for large emitters) and carbon-neutral certification.

Some submitters from the business and industry and business NGO sectors suggested a number of research and development initiatives, including:

  • New Zealand co-operation on research and technology development with other nations that have a high potential for, or dependence on, energy recovery from fluid flows (wind, tidal flows, geothermal)

  • operational research to identify the level of intervention needed to influence decisions in different circumstances - consideration should be given to all levels of intervention, ranging from public education to compulsory information provision at decision points, clear and stable market rules, minimum standards and (possibly) incentives

  • membership in the Asia-Pacific Partnership (AP6) once government and industry have identified the climate change working groups where they can make useful contributions

  • investment in, or incentives for, research that determines how overseas technology can be adapted to achieve maximum benefit in New Zealand’s local conditions.

Impacts on public health

The submission from the Ministry of Health focused on strategies to deal with the potential effects of climate change on public health. The primary recommendation was that the Ministry of Health’s Health Impact Assessment Support Unit work with the Ministry for the Environment to develop climate change human health impact assessment guidelines. These guidelines would be used to help identify the sensitivity and vulnerability of populations for a range of health issues, and would feed in to climate change policy development.

Local government initiatives

A submission from the local government sector pointed out that in New Zealand, councils are not able to set standards (eg, through local laws) that go beyond the Building Code. In contrast, councils in other countries have the ability to set building regulations to demand minimum energy performance standards and to mandate sustainable technologies. They recommend that similar measures be adopted in New Zealand to allow councils to promote a range of measures that reduce energy, water and waste to their ratepayers.

The submission noted that councils are largely unable to commit significant resources to measures to reduce emissions. Councils wishing to carry out large-scale initiatives often build on existing national initiatives. For example, councils in Queensland, Australia, have offered rebates on solar and heat pump hot water systems to further boost subsidies and rebates from the state and federal government. To this end, the submission suggests that national measures to reduce emissions should take into account potential partnership roles with local government and/or the potential for local government to utilise national initiatives.

The submission noted that the Communities for Climate Protection (CCP) Programme currently only assists councils to reduce operational emissions and community emissions arising from stationary and transport energy and from organic waste to landfill. Councils have been seeking assistance on climate change adaptation and measures to reduce community emissions from the agriculture sector. Consequently, the submission suggested, the CCP Programme should be enhanced to include adaptation and agriculture.

Incentives for small-scale renewable energy

Two submissions from the business sector discussed the implications of climate change policy on waste management and landfill development and operations. They contended that there are significant barriers for small-scale renewable energy generators (eg, landfall gas generators), including:

  • reliance on existing network operators to provide grid access

  • a limited ability to influence connection fees and charges to embedded/distributed generation

  • a limited ability to negotiate over the price paid for electricity.

The submissions suggested that these barriers should be overcome by providing incentives and subsidies, such as capital grants or feed-in tariffs, to small-scale renewable energy producers. They also suggested that a price-based measure should not be applied to the waste management sector, as this would constitute ‘double dipping’ in the waste management sector because the waste levy already aims to reduce greenhouse gas (methane) emissions from landfills. The levy is part of the Waste Minimisation (Solids) Bill, and applies to each unit of waste deposited in landfills.

Additional general rates levy

One submitter proposed that an additional levy, related to the energy efficiency of the person’s residential location, be included in the general rates. This system would penalise those who choose to live in sprawled-out subdivisions, and so would discourage sprawl and the resulting carbon emissions resulting from sprawl-related transport.

Kyoto Protocol methodologies

A business and industry sector submitter urged the government to negotiate with appropriate international bodies to change the current ‘instant oxidation’ assumption for harvested wood covered by the Kyoto Protocol. They suggested that officials promote a system that recognises the ‘locked in’ value of carbon in harvested wood products. The submitter also noted the government’s aspiration to become carbon neutral, and suggested that it work towards this goal by increasing the use of wood and wood-based products in government-funded buildings.

Targets for reducing emissions

Many submissions expressed a desire to see specific targets for emission reductions to be set. Some considered that these targets should be formalised through legislation. The need for formalised targets was a particularly common view of environmental and community NGOs, who considered that the targets should form the basis of New Zealand’s international and domestic response to climate change mitigation.

Some submitters suggested a long-term economy-wide emissions reduction target of 80 to 90% reduction in New Zealand’s greenhouse gas emissions by 2050, compared to 1990 levels. These submitters considered it necessary that targets be subject to both revision and an increase in precision as understanding of the risks of both abrupt and gradual climate change increases. Other submitters, including business NGOs, suggested that emissions management agreements, with agreed targets, could be a precursor to a price-based measure if, in the future, this were found to be the least-cost method of emissions reductions.

New Zealand’s emissions profile

Some submissions were concerned that the policies in the discussion document were not framed within the context of New Zealand’s emissions profile. Some of these submissions noted that the proposed measures tend to focus too heavily on the electricity generation and stationary energy sectors. They commented that for future New Zealand policies to be effective, they must address the transport and agricultural sectors, which make up some 68.9% of New Zealand’s emissions and are still growing.

Criticism of the consultation documents

During public consultation meetings and in some submissions across the discussion documents, some stakeholders noted that the discussion documents presented high-level policy options and did not include detailed information on policy design or cost-benefit analysis of policy impacts. A number of submitters also criticised a perceived lack of coherence and consistency between the various climate change consultation documents.

Further consultation and communication

Many stakeholders, particularly Māori and industry groups, expressed an expectation or desire for further consultation on detailed preferred options, and/or further quantitative analysis of impacts, prior to final Cabinet policy decisions. Industry groups recommended that further consultation be undertaken so that policies can be developed in a thorough and open way, in order to achieve widespread ‘buy-in’.

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