The Climate Change Commission's report needs a response

Over the weekend the Climate Change Commission released its first package of comprehensive advice to the Government on how New Zealand should tackle climate change. The advice is clear – the Government must pick up the pace and changes are needed in all sectors. It is draft advice though; the Commission wants to hear about the impact of its suggestions before presenting it to the Government.

All corners of New Zealand should consider giving feedback – below we identify specific issues you should be considering and provide some tips on how to provide effective feedback.

The Commission has advised on four key matters

The Commission’s draft advice canvasses four key matters:

1. Granular emissions budgets for specific greenhouse gases until 2035 so that New Zealand's long-term greenhouse gas emission targets can be met.
2. How the Government can set policy across sectors to meet the emissions budgets.
3. Ways to reduce biogenic methane emissions to meet international obligations.
4. The incompatibility of New Zealand’s first National Determined Contribution under the Paris Agreement with global efforts to limit warming to 1.5 degrees Celsius above pre-industrial levels. More action is needed to ensure we deliver on our international commitments.

The Commission provides recommendations throughout the report, often accompanied by progress indicators that will be used to monitor the Government's progress. The recommendations are categorised as budget recommendations (the levels to be set in the emissions budgets), enabling recommendations (to ensure that processes are in place so that the actions to address climate change are enduring) and policy recommendations (to inform the direction of policy needed in the Government's emissions reduction plan – being time-critical necessary actions and necessary actions).

Implications of the recommendations for individual organisations can be identified from the sector by sector analysis of opportunities to reduce emissions.

The Government must pick up the pace and changes are needed in all sectors

The advice presents some clear messages:

• Transformational and lasting change across society and the economy is needed.
• The Government must pick up the pace. New Zealand will not meet the Commission’s recommended emissions budgets and its 2050 targets under the CCRA without strong and decisive action now to drive low emissions technologies and behaviour change across all sectors. Current Government policies are not sufficient to put New Zealand on track.
• Technology is developing and will allow the country to reduce emissions fast; we do not need to rely on future technologies.
• Forests have a role to play, but we can’t plant our way out of climate change.
• The Emissions Trading Scheme won’t get us to where we need to be.
• Priority areas for action include increasing the number of electric vehicles, increasing our total renewable energy, improving farm practices and planting more native trees.
• The Commission’s proposed emissions budgets are ambitious but New Zealand’s NDC goes further. To achieve the NDC, we will need some offshore mitigation.
• The overall costs of meeting the country’s targets and our proposed emissions budgets are estimated at less than 1% of projected annual GDP.
• While the overall costs are small relative to the size of the whole economy, they will not be evenly felt. Some sectors of society will experience greater impacts, both positive and negative.
• Climate related policies should not further compound historic grievances for Māori.
• Change should be equitable: the benefits of climate action should be shared across society, and the costs of the climate transition should not fall unfairly on certain groups or people.
• It is important that emissions budgets are non-partisan and set transparently to provide business certainty and ensure enduring progress. Abrupt direction changes as governments change may undermine efforts to reduce emissions.

There is an opportunity now to share your organisation’s perspective with the Commission

The Commission is seeking feedback on its draft advice until 14 March 2021. The Commission will consider this feedback and provide its final advice to the Government and public by 31 May 2021.

The Commission has flagged key components of the advice that it is particularly interested to receive feedback on. These components have been developed into questions throughout the report. However, broader perspectives on the Commission’s advice can be provided.

The Commission will consider all evidence received during consultation and it is prepared to review and change any part of its work in light of that information.

There are specific issues you should consider providing feedback on

In preparing your feedback on the Commission’s advice you should consider:

• What are the practical implications of the Commission’s advice for your organisation?
• How will the Commission’s advice change the regulatory environment in which your sector operates?
• How will the Commission’s advice change the way your business plans and budgets for the future?
• Are the timeframes in which the Commission recommends change achievable?
• Has the Commission identified all relevant challenges and opportunities for your sector?
• Do you agree with the Commission’s sector-specific approach?
• Is the Commission’s approach equitable across different sectors?
• What useful information, data and examples could you share with the Commission to inform its advice?

We’re interested in your thoughts and reactions to the Commission’s advice and would be delighted to engage with you on the above discussion points, and others.

Providing effective feedback is important

The Commission’s advice will influence the way all sectors develop and operate in the future. It is important that your organisation’s perspective is heard and informs the Commission’s advice.

In our experience feedback is most effectively received by panels like the Commission if it:

1. Is presented in a clear and constructive manner;
2. Provides real-world, sector-specific examples, information and other feedback about the challenges and opportunities of a particular proposal; and
3. Is conveyed in writing and reinforced in person through face to face discussions.

Please let us know if we can provide any assistance in preparing a written submission for your organisation, developing an approach to a written a submission or in preparing and undertaking a consultation plan.

Authors: 

Rachel Devine  Partner Environment and Planning, MinterEllisonRuddWatts
Stephanie de Groot  Senior Associate - Environment and Planning, MinterEllisonRuddWatts