Sunday, March 28, 2021

NZCPR: Submission on the Climate Change Commission’s Draft Emissions Budget


Climate Change Commission
PO Box 24448
Wellington 6142

New Zealand Centre for Political Research Submission on the Climate Change Commission’s Draft Emissions Budget

Dear Sir,

Thank you for providing the opportunity to submit on the Climate Change Commission’s draft emissions budget.

This submission is on behalf of the New Zealand Centre for Political Research, a public policy think tank established in 2005 by former Member of Parliament Dr Muriel Newman.

We propose to address three issues of major concern.

1. The emissions budgets are not evidence-based

Many New Zealanders opposed the Climate Change Response (Zero Carbon) Amendment Bill, which gave rise to the Climate Change Commission, on the basis that it is not man-made carbon dioxide that drives the climate, but nature.

We were therefore heartened to hear that the Climate Change Commission was going to examine the science and produce advice that was “evidence-based”.

However, the statement in the draft report claiming that, “The climate science is clear, the direction of climate policy is laid out and the time for accelerated climate action is now” appears to indicate that no attempt has been made to investigate the huge anomalies that exist.

This is especially important given that new evidence has emerged following the 2020 global pandemic, that shows that while most of the world’s economy was forced to shut down, dramatically reducing emissions of man-made carbon dioxide, contrary to climate model expectations, there was no decrease of carbon dioxide in the atmosphere.

This appears to show that since the human contribution to the overall greenhouse effect is only 0.03 percent, with 99.7 percent being natural, the impact of human emissions on the planet is too insignificant to register. This surely shows that contrary to the models and claims of many climate scientists, it is indeed nature, not mankind, that controls the climate.

In light of these new revelations, it is extremely disappointing that the Climate Change Commission did not investigate this new evidence, since it throws all of the emission reduction recommendations into doubt.

Furthermore, the farming community has long argued that methane from livestock, as a short-lived component of a natural cycle that sees greenhouse gases sequestered by farmland forests, grasslands and soil, should be excluded from emissions reduction goals altogether.

It is therefore extremely disturbing to find that the Climate Change Commission has not only failed to properly investigate those claims, but it has decided to increase the penalties on farmers through harsher methane targets.

This brings us to the second point.

2. The Climate Change Commission has failed to uphold the Paris Agreement requirement to safeguard food production

The Paris Agreement is very clear - it requires that governments do not jeopardise food production, when implementing their climate change targets.

In its preamble the Paris Agreement outlines that signatories are expected to recognise “the fundamental priority of safeguarding food security and ending hunger…”

Article 2 states: “This Agreement, in enhancing the implementation of the United Nations Framework Convention on Climate Change, including its objective, aims to strengthen the global response to the threat of climate change, in the context of sustainable development and efforts to eradicate poverty, including by increasing the ability to adapt to the adverse impacts of climate change and foster climate resilience and low greenhouse gas emissions development, in a manner that does not threaten food production”.

In other words, safeguarding food security is a key requirement of the Paris Agreement. The instruction to governments is very clear - the initiatives that they introduce to reduce greenhouse gas emissions must not undermine food production.

Yet the Climate Commission has not only ignored its responsibility to recommend that farming be excluded from the emissions targets, but it has proposed even harsher restrictions on the sector.

The original targets set by the Government were to reduce “gross emissions of biogenic methane within the range of 24% to 47% below 2017 levels by 2050, with an interim requirement to reduce emissions to 10% below 2017 levels by 2030”.

The Government’s NZIER modelling estimated that the impact on dairy farming alone could result in a profit drop of 68 percent beneath baseline levels by 2050. The impact would dramatically cut food production since there is no feasible way to reduce livestock emissions except by cutting livestock numbers. This would cause food production to fall substantially. 

With the Climate Change Commission recommending even harsher targets of “between 49% and 60% below 2017 levels by 2100”, the fall in production will be even more dramatic.

In other words, the Climate Change Commission’s recommendations will decimate the food producing sector.

On that basis alone, New Zealanders can have no confidence at all in the Climate Change Commission’s draft budget, since it advises the Government to adopt targets that are in direct contravention of the Paris Agreement. In doing this they are deliberately in breach of the explicit requirement of the Paris Agreement to protect food suppliers. 

3. The Emissions Trading Scheme should be the primary mechanism to meet Paris targets

The United Nation’s Intergovernmental Panel on Climate Change has stated that once a country has an Emissions Trading Scheme in place, no other policy interventions are necessary to meet emissions targets: “if a cap and trade system has a sufficiently stringent cap to affect emission‐related decisions, then other policies have no further impact on reducing emissions”.

With New Zealand already having a fully functioning ETS in place, no other policy recommendations are needed.

Since the ETS will enable emissions to be reduced at the lowest cost to the economy, if international offsetting is enabled, the ETS can be used as the sole mechanism to bring about the changes needed to meet our international obligations. 

As Dr Oliver Hartwich, the Executive Director of the New Zealand Initiative, pointed out last year, “A recent paper in the American Economic Review reported that a forest conservation project in Uganda managed to sequester carbon for a cost of $US1 per tonne. Previously, we found projects in the Brazilian Amazon rainforest achieving a carbon offset for $US2 a tonne. But even at a conservatively-high $10 a tonne, New Zealand could offset all its net emissions for an annual cost of under $600 million.

“Imagine that: If New Zealand entered a partnership with countries like Brazil and Uganda we would become net carbon neutral tomorrow – not in 2050. Such a deal has a precedent. Switzerland and Peru recently announced a carbon offsets deal. Peru will receive funding for sustainable development, and Switzerland will receive credits for lower emissions. The deal is recognised under the Paris climate agreement, to which New Zealand is a signatory.”

The New Zealand Centre for Political Research urges the Climate Change Commission in their final report to replace their draft emissions budget with recommendations to follow the lead of Switzerland and use the ETS and Paris Agreement rules to meet our international obligations at the lowest possible cost to the New Zealand economy.

In that way the immense economic disruption and suffering to all New Zealanders that the Climate Change Commission has signalled could be avoided.

Yours sincerely,
Dr Muriel Newman

New Zealand Centre
for Political Research

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