The answer, my friend…

Some encouraging facts and figures are provided in an interview with the CEO of the European Wind Energy Association, Christian Kjaer, by Yale Environment 360. For the past two years 40 per cent of all new electricity generating capacity in Europe came from wind turbines. (Add solar and other renewables and that rises to 63 per cent.) From Spain to Sweden so many new turbines are being erected that Europe is on target to produce 15 per cent of its electricity from wind by 2020 and 50 per cent by 2050.

Kjaer puts the emergence of wind as Europe’s leading form of green energy down to a combination of government policies, entrepreneurial vision, and public support. Carrots and sticks are involved. The European Union provides tax credits, financial incentives, and priority access for renewable energy to the electricity grid to encourage the growth of wind, solar and other forms or renewables. The stick is the requirement that member states set renewable energy targets or face the possibility of being sued.

The result is that increasingly as plants fired by coal and natural gas reach the end of their lives they are being replaced by wind and solar power. The economic benefits of the transition are clear, with nearly 200,000 people currently employed in European wind power, rising to an estimated 450,000 by 2020. Kjaer has no doubt that green energy is an engine of job creation.

He thinks the early start that Europe gained in wind power, particularly in Spain and Germany and Denmark, gives them an advantage in the new industry and means they are reaping commercial benefits in terms of wind turbine manufacturing and activity further down the supply line. The high quality manufacturing sector, strongly supported by governments, should see Europe retaining an edge over the intensifying competition from Asian countries.  “The winners of tomorrow’s energy wars,” he says, “are going to be those who understand how to develop new technology, deploy new technology and get the benefits of exporting that technology to the rest of the world.

He speaks of the need for Europe to make a serious effort in terms of changing the way they operate their grids, and to move more quickly to develop an offshore grid for utilizing the offshore wind energy. Politicians need to give attention to optimizing and expanding the grid infrastructure to accommodate a larger amount of variable wind power in the system, and also other renewables.

“One of the main reasons for the strong political support for a supergrid is also that we want to create an internal [European] market for electricity, which of course, in the end, should give consumers the most affordable electricity. That’s the whole idea about the internal market, is that it would create the free movement over borders of goods, services, and in this case electricity at the lowest cost. And in order to create an internal market for electricity you need the infrastructure, just as you need roads to move goods around the European Union.”

Concerning policies required for a robust industry Kjaer speaks first of stable long-term frameworks for investing in renewables. Stable frameworks help the European industry by contrast with the US where the framework is unable to be predicted more than one or two years ahead. This means the US is not reaping the job creation benefits of wind energy; a lot of manufacturing has to be imported since no one’s going to invest in a factory in the United States if they don’t know how the market looks beyond the next two years.

As an aside, a news item today reported US steelworkers complaining that in the manufacture of wind turbines and solar panels China is breaking WTO rules by an array of subsidies, tax credits, cut-rate loans, and other policies that give Chinese companies a strong competitive advantage over foreign firms. If Kjaer is right they might do better to complain of their own government’s failure to support green energy development ahead of the fossil fuel industry which is still favoured by extensive subsidies.

To return to Europe. Kjaer identifies three elements in the stable framework Europe is providing for renewable energy. Financial support such as tax credit is one. Access to the grid is another:

“And what European legislation does, it mandated all 27 member states to give priority access to wind energy, which means that if you have a wind farm and a gas plant, and they’re planned projects, the wind energy should be connected first. And also, if you have plants operating on the system, electricity from the renewables plant gets fed into the grid first.”

The third element is more straightforward administrative procedures. Kjaer spoke of hopes of streamlining what in some European countries are extremely tortuous permission processes.

Asked about public opposition to the expansion of wind turbines, he acknowledged it was an issue, more so in some countries than others. Onshore turbines in the UK are particularly difficult.

“But it’s my feeling that the concern from locals is biggest in the beginning of a new market taking off. So the first thousand megawatts are much more difficult to install than the next thousand megawatts. Because people get used to them, they understand that they don’t make noise anymore — the turbines twenty years ago made quite a lot of noise, today you can’t hear them, almost, if you’re more than two hundred meters away.”

Asked whether 100 per cent renewable electricity by 2050 was possible Kjaer explained why he thinks it is:

“Almost two-thirds of our new capacity is from renewables. That figure was about 20 per cent in the year 2000. So in nine years we’ve gone from 20 per cent to 62 — by 2020 of course we can get to 100 per cent of new capacity. And if we can get in 2020 to a situation where all new capacity is renewables, then we will, by definition almost, have 100 per cent renewable electricity by 2050 because all the other power plants will be taken off [line].”

Infrastructure is the absolute key:

“ – we need to build an infrastructure that is different. But, again, our infrastructure in Europe is aging – we haven’t been building power lines since the ‘60s or ‘70s. It needs to be replaced anyway. So we need to make sure that the infrastructure is changed in a way that it accommodates 100 per cent renewable electricity by 2050.”

While I was preparing this post a newsletter coincidentally arrived from the New Zealand Wind Energy Association, welcoming the Government’s continued commitment to its target of 90 per cent renewable electricity by 2025 in the draft New Zealand Energy Strategy and affirming the part that wind generation is able to play.

“In New Zealand, wind generation has increased 10-fold since 2003, helping lift total renewable generation to recent highs of over 70%. With four wind farms currently under construction, together with other new and planned renewable projects, New Zealand is making progress towards the 90% target and the rewards that it brings to the economy and the environment.”

It points to the economic advantage of globally competitive electricity prices that will accrue to New Zealand in the development of its ample renewable energy resources.

“Electricity prices have increased significantly in recent years on the back of rising natural gas prices. Increasing use of renewables such as wind energy, which has no fuel or carbon emissions costs, is helping to check these rising prices.”

There’s a note of understandable exasperation in a section of the newsletter addressing the misinformation barrier which it says is bizarrely making it easier to obtain resource consent for new thermal generation than for renewable generation.

Such misinformation as this:

“In the last few months we’ve seen claims that a proposed wind farm won’t generate the amount of electricity that the developer estimates because wind generation varies with the wind. Such claims overlook that developers’ calculations already take the variable nature of wind generation into account. Developers usually identify both the installed generating capacity of the project in megawatts (or MW) and the total amount of electricity that they expect the project to generate in a year in gigawatt-hours (GWh). This estimate of generation takes into account the wind conditions at the site and that varying wind conditions affect generation.”

The newsletter points out that wind is proving itself in New Zealand on its own merits. (I would add, in spite of the unfair advantages enjoyed by fossil fuels which are only just beginning to have a modest price put on them.) Unlike other countries, New Zealand wind farms are not subsidised. A wind farm will be built here only when it can generate electricity at a cost that is competitive with other forms of generation.

The NZ wind resource is very strong by comparison with other parts of the world where wind farms are being installed. Our wind farms generate almost twice as much electricity per installed megawatt of capacity as the international average.

In response to the claim that new thermal generation is required as back up for new wind farms the newsletter responds that our existing hydro base is sufficient to balance about 2000MW of wind capacity without adding significantly to the price of electricity. Current wind energy capacity sits just under 500MW, so there’s obviously some distance to go before back up becomes a serious concern.

It’s the view of the newsletter that the considerable range of research and practical experience available regarding wind energy after more than 10 years operation in NZ and more than 20 years overseas reveals that many of the claims commonly heard in denigration of wind energy do not stand up to scrutiny.

So, this evidence from Europe and New Zealand, along with that from the US and from China among others, demonstrates that in spite of all its detractors wind generation is advancing rapidly. It’s heartening to see that there are governments prepared to offer the financial and policy support that it needs. Some point sneeringly to that and utter the dirty word ‘subsidies’. In a market place which doesn’t price the environmental costs of fossil fuels there is currently no other way of putting renewables on an equal footing. In any case the imperative to phase out emissions means that we must pay what it costs to do so, just as, for example, we are preparing to pay the costs of repairing the earthquake damage in Canterbury. There are some expenditures which can’t be avoided. Would that our Draft Energy Strategy would recognise that.

The Environmental Politics of Sacrifice

The Environmental Politics of Sacrifice

Addressing climate change will require citizens of wealthy consumer societies to sacrifice. But that’s never going to happen. We’ve all heard statements like that, indeed we’ve probably muttered them to ourselves. Michael Maniates and John Meyer place the words at the beginning of their book The Environmental Politics of Sacrifice. They and their ten fellow-contributors examine exhaustively what they describe as “the political stickiness of sacrifice-talk” to see if there are more hopeful options than the stark contradiction of that opening statement.

In fact, as several of the writers point out, there is a normalcy to sacrifice which is part of many people’s lives. It may be mingled with self-interest, but the sacrifices we make for children, for causes we care about, perhaps for our careers, are essential to making our lives meaningful and pleasurable, and for the most part are recognised and welcomed as such. That kind of sacrifice becomes ingrained in who we are and doesn’t feel like sacrifice. It is not heroic, but sacrifice needn’t be restricted to the exceptional undertaking that cannot be expected of ordinary people. The book doesn’t argue for sacrifice on a superhuman scale for the sake of the environment. Its discussions of the word are nuanced and show a preference for the normalisation of environmental sacrifice whereby it becomes part of the price we willingly pay for the welfare of future generations and the Earth they will inhabit.

Paul Wapner examines the upbeat notion that tackling climate change is a call to embrace new green opportunities rather than be concerned about sacrifice.  “Promethean” environmentalism he calls it. But he prefers to keep the sacrifice word in environmental discourse and points to writers like McKibben who see environmental sacrifice not as a matter of reduction but rather enlargement.  Environmentalism takes Others into consideration by realising that we are not the centre of the universe, and in doing so it is not a politics of less but one of inestimable more. Sacrifice is not a deprivation, but a provision – it involves feeding our moral selves. Karen Liftin in her chapter on the sacred and profane, as she argues for an affirmative politics of sacrifice in an ecologically full world quotes the Indian nationalist and mystic Sri Aurobindo:

“The acceptance of the law of sacrifice is a practical recognition by the ego that it is neither alone in the world nor chief in the world…The true essence of sacrifice is not self-immolation, it is self-giving; its object is not self-effacement, not self-fulfilment; its method not self-mortification, but a greater life.”

There are strong currents in modern affluent society which make this kind of perception difficult. Thomas Princen looks closely at the beguiling concept of consumer sovereignty. There’s a grand entitlement to consumption. The good life centres on goods, not on relations, not on service, not on citizenship.  It leads to a society supremely organised to absolve individuals of responsibility, whether as consumers, producers, investors, or rule makers.  Sacrifice is depreciated and rejected. But in fact much is sacrificed to maintain such a society, in costs and trade-offs, social and environmental problems which are rendered covert and hidden.

“… the hedonistic, growth-manic, cost-displacing consumer economy must give way to a purposeful economy, an economy premised on principles of positive sacrifice, of giving (along with receiving), of sufficiency and good work and participatory citizenship. The sovereign consumer must be dethroned; sacrifice must be elevated, restored to its proper, ‘make sacred’ pedestal.”

Sometimes the built environment makes sacrifice for the environment difficult. Peter Cannavό looks at the development of suburbia in America and the way in which its original pastoral civic republicanism has been lost, especially in the closed, often gated, communities of the post World War II outer suburban expansion. The very form of sprawling suburbia mandates unrestrained consumption, privatism, and exclusivity. The automobile becomes what Lewis Mumford called “a compulsory and inescapable condition of suburban existence”. Zoning laws decree low-density development. Shopping is removed from neighbourhood and town. People are increasingly isolated in their cars and homes. Cannavό looks at ways in which suburbia could be reconstructed to become greener, more moderate and civic and sustainable, and expresses the hope that suburbanites will be willing to sacrifice what they have now in favour of what he sees as a return to suburbia’s republican roots.

Justin Williams provides an interesting essay on the difficulties placed in the way of bicycling as a contribution to environmental sustainability. He observes that there is little meaningful freedom, in America at least, to make choices about transport modes and hence it is difficult for sacrifice to enter the rhetorical field. Structural decisions, particularly those associated with suburban development, have placed cars at the centre and turned streets from social gathering places into means of transport between two distant places, home and work. The obstacles these developments place in the way of cyclists are formidable, paramount among them the distances that need to be travelled, the dearth of facilities such as adequate routes and parking, and the threats posed to personal safety by cycling among cars. Nevertheless a combination of carrots and sticks in cities such as Portland and Chicago in the US and in a  country such as the Netherlands has made cycling a more genuine option. He argues that the promotion of cycling at automobility’s expense is democratic because automobility is not an expression of freedom but merely the structurally “obvious” choice, given the constraints placed on alternatives, and because the freedom to cycle is limited by current automobile infrastructure.  I warmed to his advocacy. I have taken to cycling myself in my later years and often observe myself reduced to pathetic gratitude for very minor provisions for cyclists in my own city.

Can academics refining the concept of environmental sacrifice dent the prevailing perception, often vehemently expressed in the hurly burly of every day politics, that it’s almost an affront to expect wealthy consumer societies to make sacrifices? Sometimes it can seem an insuperable task. But I liked the idea of doggedness to which the editors give voice in their conclusion. They quote Frances Moore Lappé: “keep asking ‘why?’”. They urge students, activists, scholars and citizens to ask, and keep asking, why sacrifice should be pushed to the margins, why narrow assumptions about the capacity and willingness of humans to sacrifice should prevail, why leaders remain reluctant to call on our ability to sacrifice on behalf of public aims. That’s the first challenge. Four others follow: developing awareness of the many rich ways in which sacrifice infuses daily life; shaping environmental politics to cultivate the capacity for sacrifice or at least to make it part of the discussion; identifying and studying illustrative examples where sacrifice is made for distant benefits; engaging in a nuanced way with the rhetorical power of sacrifice, a word perilous in public debate but not therefore to be shunned.

The book is a thoughtful and lively contribution to an issue which gathers importance and urgency as the years of climate inaction continue to accumulate. There is still hope we will choose the democratic sacrifice which the book advances. If we spurn it we are likely to have sacrifice forced on us by the passage of events.

[More at Fishpond (NZ), Amazon.com, Book Depository (UK, free shipping worldwide).]

Bjorn again: Lomborg’s convenient change of heart

Climate protestors at AberdeenBjorn Lomborg is in the news again. He’s changed his tune, says a Guardian headline, announcing the forthcoming publication of a new book edited by him, Smart Solutions to Climate Change: Comparing Costs and Benefits. That was a pretty quick change, I thought, recalling what I heard him say on a panel at the PEN World Voices Festival, back in May. He followed the famed Norwegian novelist Jostein Gaarder and the leading climatologist James Hansen. I wrote about it on Hot Topic at the time. Neither the passion of Gaarder nor the scientific logic of Hansen was for him. He admittedly presented himself as an advocate for tackling global warming, but without a shred of scientific reference he spoke of the need for “balanced information” and a move from the end-of-world kind of story.  “Apocalyptic information” turns people off, he said, and is part of the reason why there has been a decline in public concern about global warming over the past year. That, plus problems in the IPCC report such as those relating to the Himalayan glaciers. In other words, it’s the scientists who point to the great danger we are in who are to blame for the lack of public concern. The relentless denialist campaign seemingly has nothing to do with it. As I listened I simply thought you obviously haven’t bothered to follow the science. You’ve sniffed out a strategic political position, safely positioned between science and denial. Perhaps that was unfair of me. But I’d reviewed Howard Friel’s painstaking book The Lomborg Deceptiona few weeks previously, and what Lomborg was saying fitted Friel’s analysis.

 

Then just last month he produced an article (accessible from here) claiming that we have the capacity to readily adapt to even a 6 metre sea level rise. Only 400 million people would be affected, about 6% of the world’s population, and most of them live in cities where they could be protected relatively easily.

“94% of the population would not be inundated. And most of those who do live in the flood areas would never even get their feet wet. […] The point isn’t that we can or should ignore global warming. The point is that we should be wary of hyperbolic predictions. More often than not, what sound like horrific changes in climate and geography actually turn out to be manageable – and in some cases even benign.”

This hardly presaged a change of tune. I haven’t seen a copy of the new book, nor will I be seeking to. But books take time to publish and the things that an author is saying and writing in the months preceding release are unlikely to be at variance with what the forthcoming book will have to say.

Joe Romm, who is deeply unimpressed by the news of the book, quotes from its penultimate paragraph:

“It is unfortunate that so many policy makers and campaigners have become fixated on cutting carbon in the near term as the chief response to global warming.”

“Seriously” is Romm’s one-word response.

It’s not that Lomborg thinks we can avoid responding to global warming. It’s rather that he has a better way than cutting emissions. His final paragraph:

“If we care about the environment and about leaving this planet and its inhabitants with the best possible future, we actually have only one option: we all need to start seriously focusing, right now, on the most effective ways to fix global warming.”

That involves using money raised by a carbon tax (a small one of $7 a ton, in case that alarms anyone).

“Investing $100bn annually would mean that we could essentially resolve the climate change problem by the end of this century.”

Sounds like good news. And in some ways it is. The areas that Lomborg and his fellow writers propose spending money on include research and development of clean energy options, planting more trees, reducing soot and methane, and investigating geo-engineering projects such as “cloud whitening”. There’s little to argue with there, and presumably that’s how he managed to get a commendation of the book from Rajendra Pachauri, who welcomed Lomborg’s statement that we have ‘long moved on from any mainstream disagreements about the science of climate change’.

So it looks like a change of emphasis from Lomborg, though he maintains he has never denied anthropogenic global warming. He even acknowledged to the Guardian reporter that there could be “something really bad lurking around the corner”. But it’s hardly change enough. Cutting carbon emissions is our only hope of avoiding really serious multiple consequences from global warming. That is the clear message of the science. The notion that we can get by without seriously addressing that need is not founded on science. Lomborg’s message is welcomed by fossil fuel vested interests because it suggests we can carry on doing what we are at the same time as covering any damage we may be laying up for the future. Gerry Brownlee’s draft NZ Energy Strategy fits very nicely into that delusion.

I’ll give Howard Friel, writing in the Guardian, the last word.

“Lomborg still argues in this book, as he did in the others, that cost-benefit economics analysis shows that it is prohibitively expensive for the world to sharply reduce CO2 emissions to the extent required by the scientific evidence.

“…what will happen to the earth and human civilisation when atmospheric CO2 concentrations rise – essentially unchecked, if we followed Lomborg’s recommendations – to 450 parts per million, 550ppm, 700ppm, 800ppm; and when the average global temperature rises by 2C, 3C, and 4C to 7C?

“Climate scientists have set 350ppm and a 2C average temperature rise (from 1750 to 2100) as the upper range targets to prevent a global climate disaster. Since we are already at 390ppm and since a 2C plus rise is a near certainty, how does Lomborg’s appeal to forgo sharp reductions in CO2 emissions reflect climate science? He argues that there are ‘smarter solutions to climate change’ than a focus on reducing CO2. This is hardly smart: it’s insanity.

The secret migration

Acouple of weeks ago, a comment on carbon footprints and immigration kicked off a brief exchange of views on New Zealand’s vulnerability to climate-forced migration. It’s an interesting subject, worth more attention, and so in this post I’m going to set out how I see NZ’s position in the context of the likely future flows of climate-forced migration.

Let’s start by defining the probable sources of migrants. The first and most obvious are refugees forced to move by climate impacts. The horrendous situation in Pakistan gives some idea of the sheer scale of the problems likely to be faced by some of the world’s most populous and least-wealthy countries. Here’s how the New York Times describes the situation in Pakistan:

Initial estimates for the scale of damages and human suffering for Pakistan’s worst flooding in 80 years, is larger than the 2004 Indian Ocean tsunami, 2005 Kashmir earthquake, 2008 Cyclone Nargis disaster in Burma and 2010 Haitian earthquake — combined.

Each of the great Asian megadeltas — in Bangladesh, Myanmar, Thailand, Vietnam and China — could face similar problems if the Asian monsoon intensifies further, or if sea level rise picks up pace. The potential for tens of millions of people to be made homeless, to start a desperate search for dry land and food is obvious — but that’s not where New Zealand’s principal vulnerability lies.

Continue reading “The secret migration”

Ramping up renewables

There may be conflicting reports as to whether renewable energy can replace fossil fuels in time to significantly reduce carbon dioxide emissions, and there are still plenty of people in positions of authority, like our own Energy Minister, who see little reason to hurry the process. The heavy lobbying influence of big oil and coal interests remains powerful. But it’s heartening to be reminded from time to time that transition is nevertheless under way in many parts of the world and that it’s gathering pace. An Earth Policy Institute article has arrived in my inbox offering just such a reminder. It refreshes what Lester Brown had to say about the shift to renewable energy in his book Plan B 4.0.

 

I reviewed the book on Hot Topic last year, but at the risk of repeating myself I’ll report some of the points which he now reiterates and updates. The first is that the transition to energy powered by wind, solar and geothermal sources is moving worldwide at a pace and on a scale we could not have imagined even two years ago. Texas, the oil state, is a prime example. It has 9,700 megawatts of wind generating capacity online, 370 more in construction, and a huge amount in the development stage. When all of these wind farms are completed, Texas will have 53,000 megawatts of wind generating capacity—the equivalent of 53 coal-fired power plants. This will more than satisfy the residential needs of the state’s 25 million people, enabling Texas to export electricity, just as it has long exported oil.

South Dakota has begun development on a vast 5050-megawatt farm that when completed will produce nearly five times as much electricity as the state needs. It will become an exporter, as some ten American states and several Canadian provinces are planning to be.

Brown then moves across the Atlantic to point to the hopes of the Scottish government for the development of an enormous off-shore wind generating capacity of some 60,000 megawatts. I reported  on Hot Topic a few months ago on a major survey which has identified North Sea potential from wind and wave of even larger potential, capable of producing six times as much electricity as is currently used in the UK. If joined to a northern super-grid it could enable access to a single European electricity market and export opportunity.

Algeria plans to build 6000 megawatts of solar thermal generating power for export to Europe via undersea cable

It’s not only the developed world that is embracing renewable energy on a rapidly growing scale. Brown instances Algeria’s plans to build 6000 megawatts of solar thermal generating power for export to Europe via undersea cable. He points to their awareness that they have enough harnessable solar energy in their vast deserts to power the entire world economy. Solar energy is clearly of enormous potential not only in the Mediterranean region but also in the south-west US and the Indian desert and China, and there is regular news of new developments in all of these areas.

Brown touches on Turkey where construction  permits are being issued for 7,000 megawatts of wind generating capacity, in response to bids to build a staggering 78,000 megawatts. In Indonesia the state oil company Pertamina is responsible for developing most of a planned 6,900 megawatts of geothermal generating capacity.

“These are only a few of the visionary initiatives to tap the earth’s renewable energy. The resources are vast. In the United States, three states—North Dakota, Kansas, and Texas—have enough harnessable wind energy to run the entire economy. In China, wind will likely become the dominant power source. Indonesia could one day get all its power from geothermal energy alone. Europe will be powered largely by wind farms in the North Sea and solar thermal power plants in the North African desert.”

The 20th century saw the globalisation of the world energy economy as countries everywhere turned to oil, much of it from the Middle East. This century, says Brown, will see the localisation of energy production as the world turns to wind, solar and geothermal energy. It will also see the electrification of the economy.

“The transport sector will shift from gasoline-powered automobiles to plug-in gas-electric hybrids, all-electric cars, light rail transit, and high-speed intercity rail. And for long-distance freight, the shift will be from diesel-powered trucks to electrically powered rail freight systems. The movement of people and goods will be powered largely by electricity. In this new energy economy, buildings will rely on renewable electricity almost exclusively for heating, cooling, and lighting.”

Can renewable energy be expanded fast enough? Brown thinks so, encouraged by the phenomenon of the extraordinary growth of the communications and information economies in only the last thirty years. Others don’t. Barry Brook in Australia is one, with his views summed up in this recent article and much more on his Brave New Climate website. Not that he’s arguing for fossil fuels – in his view nuclear power is the only technology that can get us there fast enough and economically enough.

Lester Brown falls back on the analogy of the Second World War when the American economy changed direction with extraordinary speed and prospered in doing so. He’s not alone in sounding this theme, but he was an early proponent of it. The difficulty with this concept is that our societies are hardly yet ready to see climate change in the stark terms which obtained in 1939 and 1941.

Whether renewables will be ratcheted up quickly enough or not they certainly represent one of our best hopes of containing climate change impacts. Don’t forget to tell Gerry Brownlee so before September 2, when submissions on the new draft energy strategy close. I’ve said elsewhere on Hot Topic what I see as wrong with the draft.  Simon Boxer of Greenpeace has put it succinctly:

“It’s a document that lacks vision and goals. It shows that the Energy and Resources Minister Gerry Brownlee is ignoring the climate crisis. It’s a route map to a dead end.

“The Government’s energy strategy prioritises drilling and mining for more oil and coal, while providing virtually no stimulation for the development of renewable energy and clean technology. It fails to acknowledge the seriousness of climate change and makes no attempt to set measurable emissions reduction targets.”

If you’d like some suggestions the Greens offer a thoughtful submission guide.  If you’re lacking time a shortcut is offered by Greenpeace or WWF . Many of the 40,000 submissions received by the government on Brownlee’s proposals to mine conservation land no doubt used form statements provided by organisations. They still count, so use one of the offered quick responses rather than pass the opportunity by.