Someone took the words away

NZETS.jpgDone and dusted. My submission to the Emissions Trading Scheme Review has been safely committed to the tender mercies of NZ Post. It’s a bit long to be posted in full — it’s over 3,500 words (there’s a PDF of the full document here), but I will run through the main recommendations I make. Because the terms of reference were very widely drawn they gave me scope for a submission that tries to put the ETS into a wider climate policy context, and so I’ve taken the opportunity to make some fairly wide ranging suggestions.

[Update: No Right Turn notes that the deadline for submissions has been extended to Feb 27th. Good. But I wish I’d known earlier…]

Here’s my summing up:

Climate policy must not become a political football. It is too important, and too long term to allow for incessant tinkering on a three year political cycle.

It is therefore important that NZ build a political and social consensus on the need for action, and develop shared goals on where NZ should be heading. The last government’s goal of “carbon neutrality” was a worthy one, and in the light of the sorts of emissions targets discussed earlier, effectively essential, but very little effort was made to get the NZ community to “buy in” to that goal.

The new government has a one-off strategic opportunity to begin a process to build a long term consensus on action to deal with climate change. It should take that opportunity.

Much has been made of the costs of introducing climate policies in NZ, but there has been very little work on our vulnerability to the direct impacts of climate change, and the policy actions taken by our trading partners. It is important that growth targets for the economy be “green growth” and sustainable in the broadest sense.

We need to consider “lifeboat New Zealand” as more than a pleasant place to ride out climate change. NZ will be vulnerable to stresses caused by population movements on a global scale – both returning expatriates and increased refugee numbers.


1. Build a multi-party, multi-sector, strong consensus on the need for action on climate change and the steps to be taken.

  • Create a Parliamentary Commissioner for Climate (or equivalent), to be responsible for preparing regularly updated reviews of climate science and global climate policy development to enable parliament to have a “single source” of best advice to inform policy development.
  • Appoint a Chief Scientist to advise Cabinet on science and technology issues related to climate change (and other areas where science impacts policy).
  • Develop scientifically and internationally credible emissions reduction targets and ensure buy-in to those targets by business and consumers.
  • Build public and business awareness of need for action.
  • Develop NZ’s “clean green” brand values to include “low carbon” as a highly visible brand asset.
  • Support international marketing by tourism industry and exporters
  • Provide certainty for business and consumers by framing policy on a long time scale.

2. Establish NZ equivalent of UK’s Carbon Trust

  • To support businesses and consumers to move to low carbon operation
  • To develop an NZ carbon labelling scheme to international standards
  • To develop strategic understanding of areas where NZ has “carbon advantage” (ie where “food miles” are not an issue), and encourage exporters to exploit that advantage
  • To set standards for NZ-based carbon offset schemes that harmonise with emerging global standards
  • To encourage the establishment of high quality national carbon offset schemes to allow carbon vulnerable exporters and tourism operators to achieve credible zero carbon status.

3. Implement current ETS design without further delay

  • Encourage early adoption by agriculture of emissions reduction strategies to ease participation in the ETS when it arrives.
  • Begin urgent work to assess potential for large scale use of biochar for both carbon offsets in agriculture, and as a long term potential approach to fixing carbon.
  • Support biofuel initiatives, especially second generation cellulosic ethanol and algal fuel developments, and the use of biomass for fuel.
  • Create carbon innovations fund to support NZ companies working on innovative low-carbon technologies/crops/processes.
  • Reintroduce funding for housing improvements to increase energy efficiency.
  • Provide “feed-in’ tariffs and similar incentives to encourage local small-scale generation initiatives.
  • Discourage the building of new thermal power generation, and support renewable generation investment.
  • Create renewable energy innovation funding to encourage investment in energy R&D, and the construction of innovative new plant (tidal generation, for example)

4. Develop national strategy for adaptation to expected near term (20/30 yr) climate changes

  • Support improved local modelling of climate change impacts
  • Create national soil/climate/crop database (topoclimate mapping) to allow agriculture to plan land use change
  • Increase new crop research, esp on developing warm climate alternatives to present crops/cultivars
  • Develop coastal hazard plan to prepare for sea level rise
  • Support low-impact irrigation schemes for east coast NZ agriculture, preferring water harvesting and on-farm storage to large storage lake development

5. Place climate policy at the centre of government decision making

  • All policy should be examined for its potential effects on both adaptation and mitigation policy, to avoid unintended consequences.
  • Consider inevitable climate change and its global impacts when developing long term policy and strategies (including defence and immigration policy).

In conclusion

An Emissions Trading Scheme, in whatever its final form, is only one part of the process of achieving cost-efficient emissions reductions in the NZ economy, and a small part of the national response to climate change in its broadest sense. The ETS has to be seen as a key part of an overall strategy. I hope this submission has suggested some ways in which such a strategy can be developed and implemented, and what it might contain.


Wishful thinking? Pie in the sky? Probably all of those things and more — but that’s the beauty of democracy; they asked for my opinion, now they’re going to have to listen to it!

Meanwhile I’m happy to expand on any of the above points or defend my analysis in comments.

[Elvis Costello]

2 thoughts on “Someone took the words away”

  1. “Wishful thinking? Pie in the sky? ”

    Only if MPs decide to make it so. Your recommendations look like practical common sense to me. It struck me that together they highlight the necessity of building climate change issues into the structure of government so that it’s there wherever you turn. They’re also politically neutral – I couldn’t see anything which would be unpalatable for party ideological reasons.

    The reality of your strategy for adaptation suggestions, without being in any way alarmist, makes pretty clear the seriousness of what lies ahead.

    Readers of the full submission will see how you got from the committee’s terms of reference to your wider statement. A major effort. Here’s hoping it receives the attention it warrants.

  2. Thanks Bryan. Of course, having sent it off, I immediately find some typos and things I might have clarified, but…

    You’re right, I did try to avoid party political points, though you could interpret my overall thrust as a suggestion that the government needs to get itself a strategy because it doesn’t seem to currently have one. I couldn’t possibly comment further… 😉

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