Response 884911013

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General consultation questions

0.1. What do you think is working well in New Zealand to reduce our emissions and achieve the 2050 net zero target?

Please explain your answer here.
Afforestation is working well, but it is left to do the heavy lifting, with agriculture (particularly sheep, cattle, and dairy cattle) claiming "protected sector" status.
Methane is a much more potent greenhouse gas, and special pleading by the agricultural sector shifts the burden of responsibility to the rest of the economy. Responsibility for emissions reductions should be proportional to sector contribution of greenhouse gases.

0.2. The Government is taking a ‘net-based approach’ that uses both emissions reductions and removals to reduce overall emissions in the atmosphere (rather than an approach that focuses only on reducing emissions at the source). A net-based approach is helpful for managing emissions in a cost-effective way that helps grow the economy and increase productivity in New Zealand.

What do you see as the key advantages of taking a net-based approach?
The key advantages are nil. A net-based approach fails to address the root cause of greenhouse gas emissions leading to climate change.
What do you see as the key challenges to taking a net-based approach?
A net-based approach signals to major emitters that they do not have to take any action. They can continue to emit greenhouse gases to secure benefits today, neglecting externalities that will cause future problems.
This problem is compounded with the ETS carbon credits continuing to be below the cost to drive behaviour improvements.

0.3. What, if any, other sectors or areas do you think have significant opportunities for cost-effective emissions reduction?

Please write your answer here
1. Tourism is a major sector within the economy, and a major emitter of greenhouse gases, yet it is not required to make any changes to reduce emissions.

2. Manufacturing faces no restrictions on emissions. It should be required to measure and reduce its greenhouse gas emissions.

0.4. What Māori- and iwi-led action to reduce emissions could benefit from government support?

Please write your answer here
Any government support should not be race based.
If the current science is correct, we all came out of Africa. Government support may be applicable for certain demographics, but should be independent of race.

Chapter 1: Our approach to New Zealand’s climate change response | Tā mātou e whai nei e pā ana ki tā Aotearoa urupare ki te panoni āhuarangi

1.1. What opportunities do the proposed initiatives and policies across the sectors offer for Māori- and iwi-led action to reduce emissions?

Please write your answer here
Given their large land holdings, afforestation of under-utilised land offer a significant opportunity to capture and store carbon in permanent indigenous forests.

1.2. What additional opportunities do you think the Government should consider?

Please write your answer here
Consistent with the government's stated role to not "direct where emission reductions occur in the economy." (page 28), government should ensure that the largest greenhouse gas emitting sector (agriculture) is required to participate in the ETS and to pay for its emissions (like other sectors).
Acceptance of special pleading by a pampered sector should not be the reason for other sectors to shoulder a disproportion share of the responsibility for emissions abatement.

Chapter 2: Tracking our progress towards meeting emissions budgets | Te aroturuki i tō tātou koke i te ara whakatutuki i ngā tahua tukunga

2.1. Current modelling suggests that with a changed approach, the first emissions reduction plan is still sufficient to meet the first emissions budget. What, if any, other impacts or consequences of the Government’s approach to meeting the first emissions budget should the Government be aware of?

Please write your answer here
1. This Paper shows that long-lived greenhouse gases approach net zero by 2050.
Short-lived greenhouse gases such as methane produced by the agricultural section have a greater impact on climate change. The approach proposed is wholly inadequate to climate change.
The focus of the government should be on climate change, not simply the abatement of long-lived greenhouse gases such as carbon dioxide.

2. The agricultural sectors, especially sheep, beef cattle and dairy cattle growers, must be held responsible for the negative impact the sector is having on the environment. The sector must be part of the emissions trading scheme so that the costs of emissions are no longer an externality.

2.2. What, if any, are the long-term impacts from the changes to the first emissions reduction plan on meeting future emissions budgets that should be considered through the development of the second emissions reduction plan?

Please write your answer here
1. "Longer-term projections are highly uncertain and are contingent on many factors, including assumptions about the rate of technological development,..." (page 30), and yet the government is banking on just such assumptions to achieve future emissions budgets.
Relying on undeveloped technologies for agricultural sector mitigation, and the expensive carbon capture and storage pipe dreams suggests that government is not serious about reducing greenhouse gases. A number of countries have investigated carbon capture and storage. It has always been far more expensive that expected, and far less successful. The ERP2 budget should be based on current and successful tools (such as the emissions trading scheme for agriculture) and technologies, not hope.

2. Restore the following discontinued ERP1 policies.
3.2.1 Develop an equitable transition strategy.
The transition strategy is now inequitable, with the agriculture sector (particularly sheep, beef cattle and dairy cattle) not required to bear the responsibility or costs associated with its greenhouse gas emissions. The responsibility and costs are being inequitably transferred to other sectors, which will bear a higher cost to achieve required ERP2 results.

5.2.3 Assess how the NZ ETS can support indigenous biodiversity.
Government has not discontinued a program, it has stopped any investigation into a potential program that may have a positive impact on achieving ERP2 results. This is unwilling to even consider the benefits to the environment (which are more than just greenhouse gas emissions reduction) of the unique flora and fauna of NZ.

10.2.1 ... incentivise the uptake of low- and zero-emission vehicles...
In a country with abundant renewal energy resources, that imports fossil fuels used for the vast majority of transport, it is extraordinary that government should not be supporting the transition away from fossil fuels. This has a negative impact on both the environment and the voting members of society.

11.2.2 Ban new fossil-fuel baseload generation
There is no place in society for new fossil-fuel baseload generation. Solar and wind, together with storage are the low cost solutions. Instead of subsidies being directed towards agriculture, the money would be better spent on programs that benefit all voters.

11.3.1 Manage the phase-out of fossil gas
Gas is used elsewhere as a transition energy source while build-out continues with non-emitting sources of energy, together with storage. Discontinuing the phase-out of gas is a policy that is out of step with the broader society's expectation (although it does benefit gas explorers).

13.1.1 ... agriculture emissions are priced from 1 January 2025
Exempting agriculture (particularly sheep, beef cattle and dairy cattle) from the costs of its emissions shifts the burden to all other sectors. The agriculture sector will not be quarantined from the effects of climate change, and will likely put its hand out for further compensation to mitigate the effects on pasture and production, caused in part by not internalising the cost. This is inequitable and increases the societal costs, to the benefit of a privileged few.

Chapter 3: Strengthening the New Zealand Emissions Trading Scheme | Te whakakaha i te Kaupapa Hokohoko Tukunga o Aotearoa

3.1. What else can the Government do to support NZ ETS market credibility and ensure the NZ ETS continues to help us to meet our targets and stay within budgets?

Please write your answer here
Cease issuing free NZUs to emitters. Only issue NZUs removers, requiring emitters to abate emissions or purchase NZUs in the market.

3.2. What are the potential risks of using the NZ ETS as a key tool to reduce emissions?

Please write your answer here
The current practice of free-issue NZUs masks information that a free market price would otherwise send.

3.3. How can the Government manage these risks of using the NZ ETS as the key lever to reduce emissions?

Please write your answer here
If the government steps away from signalling the NZU price, but maintains a requirement for abatement or the surrender of NZUs equivalent to emitters' greenhouse gas production, then the market price will more accurately signal the need for emitters to abate or surrender NZUs.

3.4. Do you support or not support the Government’s approach of looking at other ways to create incentives for carbon dioxide removals from forestry, in addition to using the NZ ETS?

Please select one item
Radio button: Unticked Yes I support
Radio button: Ticked No I don't support
Radio button: Unticked Unsure

3.5. Apart from the NZ ETS, what three other main incentives could the Government use to encourage removals through forestry?

Please write your answer here
1. Do not restrict the free choice of private property owners to transform agricultural land (that produces emissions) to forestry (the sequests emissions).

2. Provide additional NZUs to permanent indigenous forests.

3.6. Please provide any additional feedback on the Government’s thinking about how to use the NZ ETS to reduce emissions.

Please write your answer here
1. The government does not need to control the surrender timing of NZUs to achieve time-sensitive targets if the price of NZUs was sufficient to provide the incentive.

2. Cease the free-issue of NZUs to emitters. Require emitters to purchase NZUs in the secondary market.

3. Make the agriculture sector a part of the NZ ETS to address the expected shortfall from removers shown in Fig. 3.2.

4. Ensure that any constraints imposed on the transformation of productive farmland to forestry does not apply to indigenous forestry. Indigenous forestry is part of NZ's historical heritage and should not be so constrained.

Chapter 4: Scaling private investment in climate mitigation | Te whakakorahi tā te rāngai

4.1. Do current measures work well to unlock private investment in climate mitigation?

Please select one item
Radio button: Unticked Yes
Radio button: Unticked Partially
Radio button: Ticked No
Radio button: Unticked Unsure

4.2. What are the three main barriers to enabling more private investment in climate mitigation?

Write your first barrier here
Low value of EST NZUs due to the issue of no-cost NZUs to emitters. If emitters were required to buy NZUs in the secondary market at a price not distorted by gifts of NZUs from the taxpayers of NZ to large emitters, then there would be a greater focus on mitigation.
Write your second barrier here
Government is not serious in its commitment to prevent climate change.
It is was serious, then the major emitters of methane and NOX (particularly sheep, beef cattle and dairy cattle) would not be exempt from the ETS.
Government should reject the special pleadings from a declining economic sector, and focus on emerging sectors. We need government to be forward-looking, not perpetually focused on what some consider the success of a bygone era.

4.3. What are the three main actions the Government can do to enable more private investment in climate mitigation for the next 18 months?

Write your first action here
Government should signal a reduction in the use of taxpayer monies to perpetually support people and regions that increasingly suffer from the effects of climate change (eg increased intensity of weather events, coastal erosion, etc).
Those affected by climate change need to internalise the costs of climate change and they choices they make to live, work and operate businesses in areas significantly affected by climate change.
The reduction in the use of public money to compensate people and businesses for recurring losses will increase the incentive for private investment to invest in climate mitigation.

4.4. What are the three main things the Government can do to enable more private investment in climate mitigation in the longer term (beyond the next 18 months)?

Write the first here
Promote the use of indigenous over exotic flora, to transform marginal land, productive pasture, former wetlands, and coastal areas into carbon sinks.

Chapter 5: Energy | Te pūngao

5.2. How much will the Government’s approach to driving investment in renewable energy support businesses to switch their energy use during 2026–30 (the second emissions budget period)?

Please select one item
Radio button: Unticked A lot – it will make a large difference  
Radio button: Ticked A moderate amount - there will still be other barriers  
Radio button: Unticked Little to none – it will make no meaningful difference
Radio button: Unticked  Unsure 

5.3. What three main barriers/challenges do businesses and households face related to electrifying or improving energy efficiency, in addition to those already covered in the discussion document?

Write your first barrier here
The Warmer Kiwi Homes program should be accompanied by a mandatory increase in the energy efficiency of new dwelling construction, together with an increased focus on improving residential dwelling thermal insulation (including double- and triple-glazing). Improving the thermal insulation will deliver a perpetual improvement to the housing stock, with lower costs to voters.

The Warmer Kiwi Homes program should be renamed to the Cooler Kiwi Homes program. Global warming will make staying cool more important than getting warm. Excessive heat kills more people around the world than cold.
Write your second barrier here
The cost of EVs is too high relative to fossil fuel transport.
Government should provide an incentive to transition to EV through the introduction of a tax on the use of fossil-fuel powered vehicles. The tax rate should increase annually.
Write your third action here
Government should change its belief that "Gas and coal are substitutes." (page 52).
With regard to electricity generation, gas can be used to rapidly bring on-line additional electricity supply to meet fluctuating demand, but coal takes days to add to the national grid.
Government ignorance is a barrier to putting into place a suitable regulatory framework that incentivise businesses and households to transition to an electric future.

5.4. How much will existing policies support private investment in low-emissions fuels and carbon-capture technologies?

Please select one item
Radio button: Unticked A lot – it will make a large difference  
Radio button: Unticked A moderate amount – there will still be some barriers  
Radio button: Ticked Little to no difference – it will make no meaningful difference  
Radio button: Unticked Unsure  

5.5. What three main additional actions could the Government do to enable businesses to take up low-emissions fuels and carbon-capture technology?

Write your first action here
Low-emission fuels investment will become a stranded asset if businesses were to invest, when a zero-emission alternative exists.
Rather than focusing on alternatives to zero-emission renewable energy, it would be better for government to take actions that would stimulate zero-emission renewable energy.
Write your second action here
Carbon-capture technology is decades away from being scalable and affordable. Government should drop its promotion of a non-existent technology, and be technology-independent.

Chapter 6: Transport | Te tūnuku

6.1. Do you support the proposed actions to enable EV charging infrastructure?

Please select one item
Radio button: Ticked Yes I support
Radio button: Unticked No I don't support
Radio button: Unticked Unsure

6.3. Do you support the Government’s proposals to reduce emissions from heavy vehicles?

Please select one item
Radio button: Ticked Yes I support
Radio button: Unticked No I don't support
Radio button: Unticked Unsure

6.5. Do you support the Government proposals to reduce emissions from aviation and shipping?

Please select all that apply
Checkbox: Ticked Yes I support
Checkbox: Unticked No I don't support
Checkbox: Unticked Unsure

6.6. What opportunities might there be from rolling out new technologies to reduce emissions from aviation and shipping?

Please write your answer here
1. Local production of biofuels through the transition of farmland (currently used for methane-emitting activities such as sheep, beef cattle and dairy cattle farming) to growing crops suitable for biofuels.

6.7. What are the three main actions the Government can do to make it easier to reduce emissions from aviation and maritime fuels (without adding too much cost for households and businesses)?

Write your first action here
Create a green corridor for coastal shipping, including the fishing fleet.
Write your second action here
Introduce constraints on the operation of fossil-fuelled pleasure craft.

Chapter 7: Agriculture | Te ahuwhenua

7.1. What are the three main barriers or challenges to farmer uptake of emissions-reduction technology?

Write your first barrier here
Uncertain date when technology will be available (if ever).

Methane inhibitors and vaccines are years and years away from ever being used in production (page 71), yet government is assuming this mitigation is adopted in the emissions budget periods (page 72). How can the expected emissions reductions have any validity when the estimate is based on a solution that does not exist and has no timeframe for existence (let alone deployment)?
Write your second barrier here
Durability of technology under development.
Writer your third barrier here
Business disruption.

7.2. How can the Government better support farm- and/or industry-led action to reduce emissions?

Please write your answer here
1. Include farm emissions in ETS, fully pricing CO2-e, including short-lived emission, such as methane (it's the largest and most damaging source of emissions).

2. Mandate the use of nitrous oxide inhibitors used in fertilisers. A voluntary uptake scheme is inequitable. It means environmentally conscious farmers are carrying a greater burden of responsibility than farmers who care less about the environment and the future of a habitable and productive planet.

7.3. How should Government prioritise support for the development of different mitigation tools and technologies across different parts of the agriculture sector?

Please write your answer here
1. Pricing emissions within the ETS will be a more reliable solution than pie-in-the-sky technologies.

2. Use satellite monitoring for on-farm emissions measurements, including methane (the largest source of farm-based emissions) and other short-lived greenhouse gases. Land owners should not have to be responsible for emissions measurement.

3. There are no contingencies in place in the likely event that the technologies under development are not delivered or delivering the expected carbon emissions mitigation. This is a serious flaw in the government's decision to try to pick and price "winners". The records of government are extremely poor in picking winners.

7.4. What are three possible ways of encouraging farmer uptake of emissions-reduction tools?

Write your first here
Price emissions within the ETS.
Write your second here
Use satellite monitoring for on-farm emissions measurements (including methane and other short-lived greenhouse gases). Land owners should not have to be responsible for emissions measurement.
Write your third here
Require greenhouse gas labelling for food and other agriculture sector products.

7.5. What are the key factors to consider when developing a fair and equitable pricing system?

Please write your answer here
Fair and equitable pricing of emissions are already available in the ETS. There is no reason to develop a parallel system to satisfy the special pleading of minority cohort.

The producers of the greenhouse gases (farmers) should be solely and fully responsible for the costs of abatement.

7.6. Please provide any additional feedback on the Government’s thinking about how to reduce emissions in the agriculture sector.

Please write your answer here
If on-farm non-forestry abatement activities are to be recognised, then the converse should also apply: activities that reduce carbon sequestration should be penalised.

Chapter 8: Forestry and wood processing | Te ahumahi ngāherehere me te tukatuka rākau

8.1. How could partnerships be structured between the Government and the private sector to plant trees on Crown land (land owned and managed by the Government)?

Please write your answer here
1. Partnerships with the private sector to plant trees on Crown land (owned by the people of NZ, NOT the government!) should be limited to indigenous flora only.
Higher value indigenous forest are far more preferrable than the exotic forestry that is less well adapted to NZ conditions.
Ownership should remain vested with the citizens of NZ, with leases not exceeding 50 years, being auctioned to the private sector.

2. The statement "The current costs of native afforestation make it uneconomic compared with exotic planting..." (page 80) is incorrect. The actual situation is the indigenous forests take longer to mature, but the value of the harvest is substantially higher.

8.2. What are the three main actions the Government could do to streamline consents for wood processing?

Write your first action here
Black market timber (like livestock rustling) becomes a significant problem to the/both primary production sectors if there is inadequate regulation.
It is important that any streamlining of consents does not open the door to rogue operators.
This is particularly important for indigenous timber, which is considerably more valuable than exotic timbers.
Write your second action here
Do not weaken controls over the harvesting and processing of indigenous tree varieties. Once the tree has been felled, then it cannot be replanted. For some rogue operators, the penalties imposed for the illegal harvesting of indigenous trees is simply incorporated into the costs of doing business.
Some streamlining of consents may be an opportunity to lower the costs of doing business, but penalties for breaches should be increased at least ten fold.
Write your third action here
Do not weaken controls over the export of indigenous forest products (logs, or sawn timber).

8.3. How large should the role of wood in the built environment play in New Zealand’s climate response?

Please select one item
Radio button: Unticked Less than currently  
Radio button: Unticked About the same as currently  
Radio button: Ticked More than currently  
Radio button: Unticked Unsure  

8.4. What other opportunities are there to reduce net emissions from the forestry and wood-processing sector?

Please write your answer here
1. Require the use of chainsaws that do not rely on fossil fuels (electric chainsaws). This will both reduce emissions and yield a positive outcome to the environment through less fuel spillage onto the forest floor.

2. Prohibit slash from being left on the forest floor. Like sawmill waste, forest floor waste should be required to processed into products. This will ensure that carbon trapped in the waste is not released back into the atmosphere.
Importantly for slash, it ensure that it does not cause pollution to waterways and damage to properties downstream during the increased intensity of weather events (both rainfall, and pollution due to increased forest fires during hot weather).

8.5. Please provide any additional feedback on the Government’s thinking about how to reduce emissions in the forestry and wood-processing sector.

Please write your answer here
1. Despite the government's claim that afforestation has "...undesirable impacts on rural communities and economies..." (page 79), it should not be the role of government to decree to private land owners how they should husband their properties. Land owners should be entitled to make their own "best" decisions for their land, not be dictated by government fiat, which is not dissimiliar to a command economy established in communist dictatorships. Those "planned" economies have a long history of failure.

2. Any limitations on the number of NZ ETS registrations should NOT apply to indigenous afforestation.

3. Page 77 states that "Projected afforestation from 2025 will not materially impact net emissions in the second emissions budget. This is because low carbon removals from initial planting (increasing over time) are offset by the emissions from soil and the removal of previous vegetation."
This statement assumes that post-2025 afforestation is just a recycling of existing forested areas, and does not include new forestry planting, where existing land does not require the removal of vegetation (eg pasture planted with trees). In that example, the soil and pasture remain in place, with the trees simply added to the flora mix. The assumptions and modelling need to be revised to estimate the impact.

4. The discussion document rightly points out some key climate change risks (page 82), but fails to offer any actions that may mitigate those risks. It's as if the government does not accept anthropomorphic climate change. What are the proposed actions?

Chapter 9: Non-forestry removals | Ngā tangohanga ngāherehere-kore

9.1. What are the three main opportunities for non-forestry removals to support emissions reduction?

Write your first opportunity
Riparian planting and wetland restoration also provide a benefit to water quality and flood control.

9.2. What are three main barriers to developing more non-forestry removals?

Write your first barrier here
Government will.
Write your second barrier here
Scale
There must be a minimum scale, such that recognised actions taken by people is significant enough to offset the costs of incorporation into schemes like the NZ ETS.
There is little point in recognising 10 m of riparian planting. These small-scale activities should be encouraged as part of normal positive community activity.
Rather than including small-scale activities in the NZ ETS, supplying trees and other plants would be a sufficient alternative.
Write your third barrier here
The costs of including non-forestry removals in national CO2-e accounting may be higher than the benefits.
It is likely that non-forestry removals is better as part of public awareness, environmental awareness and constructive land husbandry education activities.

9.3. It is important to balance landowners ability to use their land flexibly with the recognition of the role of non-forestry removals. How can this balance be achieved?

Please write your answer here
It is hypocritical recognise landowners rights to use their land flexible, and at the same time, prohibit farm landowners from flexibly transition to forestry.
If government is keen on a command economy for the agriculture sector, the same constraints should be applied to all landowners.

9.4. What three main benefits beyond emissions reductions could be created by developing more non-forestry removals?

Write your first benefit here
Environmental awareness.
Write your second benefit here
Improved water quality and flood mitigation
Write your third benefit here
Less on-farm runoff into waterways and the ocean, which will improve species living in those areas.

9.5. What risks and trade-offs from incentivising land-use and management change to reduce net emissions need to be considered?

Please write your answer here
Costs may be high if included in the NZ ETS.

9.6. Please provide any additional feedback on the Government’s thinking about how to reduce emissions through non-forestry removals.

Please write your answer here
This is a marginal matter. Better to park this idea and focus on areas where a much more significant impact can be achieved, especially the reduction in short-lived greenhouse gases such as methane from sheep, beef cattle and dairy cattle farming.

Chapter 11: Helping sectors adapt to climate change impacts | Te āwhina i ngā rāngai ki te

11.1. What are the three main barriers to managing climate risks through emissions reduction policies in this discussion document?

Write your first barrier here
Educating climate change deniers that anthropomorphic activities are the key drivers of climate change (especially sheep, beef cattle and dairy cattle farmers).
Write your second barrier here
Reducing expectations that all tax payers should compensate people affected by climate change (such as coastal erosion, flat land flooding, increased intensity of wildfires and rainstorms) and the decisions they have made to live and work in prone areas.

11.2. What are the three main benefits of managing climate risks that can come from the emissions reductions policies in this discussion document?

Write your first benefit here
Societal stability.
Write your second benefit here
Improved environment for future generations.

Chapter 12: Addressing distributional impacts of climate mitigation policy | Te whakatutuki i ngā pāpānga tohatoha o te kaupapahere whakamauru panoni āhuarangi

12.1. What are the main impacts of reducing emissions on employees, employers, regions, iwi and Māori, and/or wider communities that you believe should be addressed through Government support?

Please write your answer here
Provide a means-tested grant to replace the existing light vehicle fleet with electric vehicles.

12.2. Do you think additional climate-specific services, supports or programmes should be considered by the Government over the coming years?

Please select one item
Radio button: Unticked Yes
Radio button: Ticked No
Radio button: Unticked Unsure