11.3. 21-57 Gisborne District Council Submission to Climate Change Commission

21-57

Title: 21-57 Gisborne District Council Submission to Climate Change Commission

Section: Strategy

Prepared by: Charlotte Knight – Principal Advisor

Meeting Date: Thursday 18 March 2021

Legal: No Financial: No Significance: Low

Report to COUNCIL for decision

PURPOSE

The purpose of this report is for Council to approve a submission to the Climate Change Commission on their draft advice about the actions the Government should take to reach net-zero by 2050, and ensure a transition to a low-emissions, climate resilient and thriving Aotearoa.

SUMMARY

He Pou a Rangi – the Climate Change Commission published their draft advice for consultation. The draft advice recommends the course for reducing emissions in Aotearoa, how we can reach net zero emissions for long-lived gases by 2050, and the direction of policy that Aotearoa takes to get there.

The Commission’s draft advice includes:  The proposed first three emissions budgets and guidance on the first emissions reduction plan, advising the Government on how the emissions budgets could be met.  Advice on whether Aotearoa’s first Nationally Determined Contribution is compatible with contributing to the global efforts to limit warming above 1.5°C above pre-industrial levels.  Advice on what potential reductions in biogenic methane might be needed in the future (this is not a review of current targets).

The draft Council submission focuses on an organisational point-of-view. Several other councils and local government sector groups are intending to submit on the draft advice. Council’s submission includes some points that are covered in other local government sector groups’ submissions. The broad sentiment is that there is agreement with the direction of the draft advice, but some additions and tweaks could be made to ensure it is successful.

The decisions or matters in this report are considered to be of Low significance in accordance with the Council’s Significance and Engagement Policy.

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RECOMMENDATIONS

That the Council: 1. Endorses the submission to the Climate Change Commission, subject to minor edits.

Authorised by:

Joanna Noble - Chief of Strategy & Science

Keywords: climate change, Climate Change Commission, submission, emissions reduction

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BACKGROUND

1. The Commission was formed alongside work to set the country’s climate targets in November 2019. These targets were legislated under the Climate Change Response (Zero Carbon) Amendment Act which passed with multi-party support.

2. The draft advice recommends the course for reducing emissions in Aotearoa, how we can reach net zero emissions for long-lived gases by 2050, and the direction of policy that Aotearoa takes to get there. The advice is required to be produced under the Climate Change Response (Zero Carbon) Amendment Act; however, the advice is not binding for Government.

3. The Commission’s advice includes recommendations on the level of the first three emissions budgets, and strategic policy direction for meeting the emissions budgets (including sector specific advice). An executive summary of the draft advice is attached for ease of reference (Attachment 1).

4. The draft advice includes recommendations on actions the Government must take to reach its climate goals. The recommendations (Attachment 2) are for: emissions budgets, enabling actions, time-critical necessary actions, necessary actions, NDC and enabling actions, and biogenic methane emission reduction.

5. Public consultation on their first package of advice opened on 1 February 2021 and runs until 28 March 2021. Since publication of their draft advice the Commission have also held several different stakeholder engagement events, Council staff have had a number of opportunities across several forums to engage.

6. The consultation questions are structured around the content of the 2021 Draft Advice for Consultation report. Accompanying this report is an evidence report. It sets out the detailed evidence that the Commission have drawn upon to support the development of their recommendations and advice. In addition to this the Commission have also made available on their website further information about the data and modelling used in their advice, a study on the science of mitigation pathways, their approach to developing advice, and information about five big decisions Aotearoa will have to make when taking action against climate change1.

DISCUSSION and OPTIONS

Council’s key messages

7. The draft submission (Attachment 3) focuses on specific questions from the consultation rather than attempting to answer all of them. The key messages and recommendations mainly address Council’s responsibilities as a local authority (organisational perspective) rather than responding to all the issues addressed in the draft advice on behalf of the region.

1 For further information: https://www.climatecommission.govt.nz/get-involved/sharing-our-thinking/

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8. Trust Tairāwhiti is drafting a submission that will focus more on key regional issues, Council staff have been included in the process. This submission is being drafted with the input of several regional stakeholders and it is intended that Council will endorse this submission by adding our name and logo to the Trust’s submission. We have also noted at the beginning of our submission that we support their submission.

9. A summary of the key messages is at the beginning of the draft submission. Council’s key messages are predominately about our role as a local authority, the importance of a just transition for our region, and the role of forestry and transport in the draft advice. Several of our key messages are reflective of other draft submissions in the local government sector.

Council’s recommendations

10. An overview of all the recommendations throughout the submissions is at the beginning of the draft submission. They include recommending some additions to the draft advice, amending some points or recommendations in the draft advice, and several points about road pricing. Like our key messages the recommendations are broadly in line with those that are in other submissions in the local government sector.

ASSESSMENT of SIGNIFICANCE

11. The decisions or matters in this report are considered to be of Low significance in accordance with Council’s Significance and Engagement Policy.

TANGATA WHENUA/MĀORI ENGAGEMENT

12. There has been no engagement on the draft submission.

COMMUNITY ENGAGEMENT

13. There has been no engagement on the draft submission.

CLIMATE CHANGE – Impacts / Implications

14. There are no climate change impacts of submitting on the draft advice.

15. The Climate Change Commission’s final advice and the Government’s response to it will influence Council’s role and responsibilities in responding to climate change (adaptation and mitigation). After the final advice has been submitted to Government and their intended response is made public Council will be in a better position to understand how our role and responsibilities will change and the approximate timeframes for statutory obligations.

CONSIDERATIONS

Financial/Budget

16. There are no financial implications of submitting on the draft advice.

Legal

17. There are no legal considerations that need to be taken into account when submitting on the draft advice.

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POLICY and PLANNING IMPLICATIONS

18. There are no policy and planning considerations that need to be taken into account when submitting on the draft advice.

RISKS

19. There are no major risks associated with submitting on the draft advice.

NEXT STEPS Date Action/Milestone Comments

Final advice to be delivered to May 2021 Advice will be made public. Government.

ATTACHMENTS

1. Attachment 1 - Executive Summary of the Commission's advice [21-57.1 - 11 pages] 2. Attachment 2 - Climate Change Commission Draft Advice Recommendations [21-57.2 - 18 pages] 3. Attachment 3 - Draft Council Submission to the Climate Change Commission [21-57.3 - 38 pages]

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Executive Summary: work must start now

In Aotearoa, the Government has committed to reaching net zero emissions of long-lived gases by 2050, and to reducing biogenic methane emissions by between 24-47% by 2050.

The work that He Pou a Rangi, the Climate Change Commission, has carried out over the last year shows that meeting these targets is possible – and can lead to a thriving, climate-resilient and low emissions Aotearoa.

Transformational and lasting change across society and the economy will be needed, but the Commission’s analysis shows the tools to start the work to reach our targets and address climate change in Aotearoa already exist.

To meet the Commission's proposed emissions budgets, Aotearoa does not need to rely on future technologies. As new technologies develop, this will allow the country to reduce emissions even faster.

However, the Government must pick up the pace. Aotearoa will not meet its targets without strong and decisive action now to drive low emissions technologies and behaviour change across all sectors. 2050 is not far away – particularly if you consider the life span of infrastructure, vehicles, buildings – and people.

Aotearoa must focus on decarbonising and reducing emissions at the source. As a country we can no longer rely on forests to meet our climate change targets.

Current government policies do not put Aotearoa on track to meet our recommended emissions budgets and the 2050 targets.

In 2018, gross greenhouse gas emissions in Aotearoa were about 45.5 Mt CO2-e of long-lived gases, and 1.34 Mt CH4 (biogenic methane). Our analysis shows if policy stayed as it is now, Aotearoa would fall short of achieving the 2050 net zero long-lived gas target by 6.3 Mt CO2-e. Biogenic methane would reduce 12% below 2017 levels and fall short of the current target of 24-47%.

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Figure ES1: Current government policies do not put Aotearoa on track to meet the Commission’s emissions budgets and the 2050 targets. This figure shows how our path to 2035 would reduce emissions of long-lived gases (top figure) and biogenic methane (bottom figure)

The Emissions Trading Scheme (NZ ETS) alone won’t get us to where we need to be. Action is needed across all sectors of the economy.

Priority areas for action include increasing the number of electric vehicles on our roads, increasing our total renewable energy, improving farm practices and planting more native trees to provide a long-term carbon sink.

Care should be taken to make sure climate related policies do not further compound historic grievances for Māori. To give effect to the Treaty Partnership, central and local government need to acknowledge iwi/Māori rights to exercise rangatiratanga and kaitiakitanga in a joint plan to reduce emissions.

The speed of this transition needs to be steady – fast enough to make a difference and build momentum but considered, with room to support people through the change. An equitable transition means making sure the benefits of climate action are shared across society, and that the costs of the climate transition do not fall unfairly on certain groups or people.

To achieve this, we need to understand that all things are connected: the people, the land, the atmosphere, the oceans. This connectivity – material and non-material – is central to Te Ao Māori. It is also essential to understanding how to guide a transition that is fair and equitable for people and the environment.

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The transition must reduce emissions at pace while allowing the country to continue to grow, so that future generations inherit a thriving, climate-resilient and low emissions Aotearoa.

Our first package of advice

This advice provides Aotearoa with a comprehensive strategy for tackling climate change. It is also the starting point. It outlines the first in a series of steps that chart the course for reducing emissions.

We asked ourselves a series of questions when developing this advice. They are: Is this ambitious enough? Is it fair and equitable? Is it technically and economically feasible? And, can it be achieved through policy?

We have used a range of quantitative and qualitative tools, including economic models and analytical frameworks. Our analytical approach used the He Ara Waiora framework to understanding wellbeing from a mātauranga Māori perspective and form an anchor for our analysis.

Our advice includes recommendations on the level of the first three emissions budgets. It also provides advice on strategic policy direction for meeting the emissions budgets, looking at what’s needed across different sectors. We recommend 17 critical actions the Government must take to reach its climate goals.

Many recommendations include indicators the Commission will use to monitor the Government’s progress.

In developing our advice, we focused on key sectors across the economy, identifying where the greatest opportunities to reduce emissions are, and working with experts and stakeholders to understand the barriers for change. Some key findings from these sectors include:

Land • Agriculture has a large role to play in reducing emissions, and farming needs to become even more efficient. There have been improvements in the last few decades, but more can happen. • Aotearoa has been an agricultural world leader over recent decades. We must adapt and improve our use of our land to keep this status. This means developing, adopting and using practices and technologies that lower emissions and address climate change. • Forests have a role to play, but we can’t plant our way out of climate change. What are we recommending? • The Government needs a cohesive strategy that includes water, biodiversity and climate. There are multiple benefits to taking a holistic view of how we use and protect our land. • There are changes farmers can make now to reduce emissions on their farms while maintaining, or even improving, productivity. This includes reducing animal numbers and better animal, pasture and feed management. Policy support is needed to make this happen. • Our advice advocates for a long-term plan for targeted research and development of new technologies to reduce emissions from agriculture. • Pine trees will still play an important role in getting to 2050 and could support a future bioeconomy, as bioenergy to replace fossil fuels and as timber for building. • Existing forests, small blocks of trees, soils and wetlands can all store more carbon. Work is needed to better understand this potential and how to include this in accounting systems.

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• Native forests can create a long-term carbon sink while providing a range of other benefits, like improving biodiversity and erosion control. Incentives are needed to get more native trees planted.

Agriculture

What is the sector’s current emissions profile?

In 2018, agriculture emissions made up about 90% of biogenic methane and 18% of long-lived gas emissions. This is 1.2 Mt CH4 and 8.3 Mt CO2-e, respectively.

Where does this come from?

Long-lived gases from agriculture are largely nitrous oxide, coming from animal urine and synthetic fertiliser use. Smaller amounts of carbon dioxide are emitted through other types of fertiliser.

Biogenic methane emissions from agriculture are primarily from deer, sheep, beef and dairy cow burps.

What does our path show for this sector?

By 2035, our path shows that biogenic methane emissions from agriculture reduce to 0.97 Mt CH4, and long-lived gases reach 6.9 Mt CO2-e. This puts us on track to meeting our 2050 target.

Forestry

What is the sector’s current emissions profile?

In 2018, forests removed 9.5 Mt CO2 from the atmosphere. Our emissions would be 14% higher without this.

Where does this come from?

Forests remove carbon dioxide from the atmosphere as they grow and emit it when they burn or decompose after harvest or clearance.

What does our path show for this sector?

By 2035, our path shows that net forestry removals reach 14.5 Mt CO2. This puts us on track to meeting our 2050 target.

Waste • Aotearoa needs to fundamentally change the way it deals with and thinks about waste. A transformation to this sector will not only reduce emissions but move us from a throw away culture to one that values our resources.

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What are we recommending? • Creating a circular, self-sustaining economy will reduce Aotearoa’s waste emissions and cut biogenic methane emissions. Strengthened product stewardship and a commitment to resource recovery and reuse must be part of this approach. • Capturing methane from any remaining waste that makes it to landfill will further emissions reduction.

Waste and F-Gases

What is the sector’s current emissions profile?

In 2018, waste emissions made up 10% of total biogenic methane. This is 0.14 Mt CH4. The sector also emitted 0.22 Mt CO2-e of long-lived gases. Emissions of hydrofluorocarbons (HFCs) were 1.8 Mt CO2-e.

Where does this come from?

Most waste emissions are from solid waste decomposing at landfill (90%), with smaller portions from wastewater treatment (9%) and burning and composting emissions (1%). F-gas emissions are largely from the leakage of HFCs used in refrigeration and air conditioning systems.

What does our path show for this sector?

By 2035, our path shows waste emissions reduce to 0.12 Mt of biogenic methane. HFC emissions reduce to 1.2 Mt CO2-e.

Transport • Reducing transport emissions is crucial to meeting our climate targets. Action here will have an immediate and lasting impact. Aotearoa can cut almost all transport emissions by 2050. The technology already exists and is improving fast. • In Aotearoa we need to change the way we build and plan our towns and cities and the way people and products move around. This includes making walking and cycling easier with good cycleways and footpaths. It means moving freight off the road and onto rail and shipping. It means reliable and affordable public and shared transport systems. And it means an electric or low emissions transport fleet. What are we recommending? • An integrated national transport network should be developed to reduce travel by private car. There needs to be much more walking, cycling and use of public and shared transport.

Transport

What is the sector’s current emissions profile?

In 2018, transport emissions made up 36.3% of total long-lived gases. This is 16.6 Mt CO2-e.

Where does this come from?

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Most transport emissions are from fossil fuels used to power vehicles. For example, petrol and diesel used by cars, SUVs and trucks (91%), domestic flights (7%) and rail and coastal shipping (2%).

What does our path show for this sector?

By 2035, our path shows transport emissions reduce to 8.8 Mt CO2-e. This puts us on track to meet our 2050 target. • Electric vehicles are key and need to be widely adopted. We want to see the majority of the vehicles coming into New Zealand for everyday use electric by 2035. The government will need to provide support and incentives to make this happen. • Use of low carbon fuels, such as biofuels and hydrogen, needs to increase, particularly in heavy trucks, trains, planes, and ships.

Heat, industry and power • Aotearoa needs to decarbonise how we produce and use energy. We need to move towards a set of diverse and low emission energy sources by 2050. • Aotearoa will need to maximise the use of electricity. This means generating and using more low emissions electricity for vehicles and for process heat. Building more renewable generation such as wind, solar and geothermal will be required. • Reducing emissions from process heat is key. Other low emission energy sources, such as bioenergy, will be needed. • Emissions must be reduced at pace while allowing the country to continue to grow. Planning ahead so that technologies, assets and infrastructure can be replaced with low emissions choices on as natural a cycle as possible will help business and industry keep pace with the transition. What are we recommending? • We need to almost eliminate fossil fuels. This means ending the use of coal. • The homes, buildings and infrastructure we build now will still be here in 2050. We need to think about our choices with climate change in mind. That means using low emissions technologies and prioritising energy efficiency. • In the long-term, we will need to reduce how much natural gas we use in homes and businesses.

Heat, Industry and Power

What is the sector’s current emissions profile?

In 2018, heat, industry and power emissions made up 41% of total long-lived gases. This is 18.8 Mt CO2-e.

Where does this come from?

Heat, industry and power emissions come from using fossil fuels, such as coal and gas, to generate electricity (22%); producing heat and chemical reactions to manufacture products (47%); fossil fuels used in our buildings and homes (7%); oil refining, oil and natural gas

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production and the operation of coal mines (12%); and the use of off-road vehicles and machinery (11%).

What does our path show for this sector?

By 2035, our path shows emissions from heat, industry and power reduce to 10.4 Mt CO2-e. This puts us on track to meet our 2050 target.

Emissions budgets

We have proposed the first three emissions budgets for Aotearoa. These budgets set the maximum amount of greenhouse gases Aotearoa can emit over a five-year period and chart the course for stepping down emissions.

We have looked at opportunities and barriers for reducing emissions across the whole economy. The budgets are based on how far and how fast our analysis tells us Aotearoa can go towards the 2050 targets.

Our recommended budgets are consistent with putting Aotearoa on track to meeting the 2050 target under a wide range of future circumstances.

The budgets are ambitious, but achievable. They represent a significant reduction on current levels of emissions, and step down considerably over time.

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Figure ES1: Our proposed emissions budgets. The figure shows all gases combined as CO2 equivalent – grey is emissions of long-lived gases, orange is biogenic methane emissions.

Figure ES2: How our path would reduce emissions across all sectors by 2035. Note that long-lived gases from agriculture are mainly nitrous oxide and some carbon dioxide.

Table ES1: Our proposed emissions budgets. All gases are combined as CO2 equivalent Emissions Emissions Emissions 2018 budget 1 budget 2 budget 3 (2022 – 2025) (2026 – 2030) (2031 – 2035) All gases, net (AR4) (Mt 271 286 223 CO2e) Annual average (Mt 69.2 67.7 57.3 44.6 CO2e/year) Average reductions on 2018 2% 17% 36% levels

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Each budget must be met, as far as possible, through reducing and removing emissions here in Aotearoa. Gross emissions must be reduced to meet and sustain the country’s emissions targets, and to avoid pushing the burden to future generations.

Relying heavily on forestry before 2050 is likely to make maintaining net zero long-lived greenhouse gas emissions after 2050 difficult. It would delay action, lead to higher cumulative emissions and make the job ahead of us more difficult.

How to meet the emissions budgets – direction of the emissions reduction plan

Meeting our proposed emissions budgets and 2050 targets requires transformational change across all sectors of the economy.

Our analysis shows that reducing transport emissions is crucial to meeting our emissions budgets and reaching net zero by 2050 – this will have an immediate and lasting impact.

This means changing the way we travel and move goods. New Zealanders should be able to walk and cycle more. Freight will need to come off the road and onto rail and shipping.

To lower emissions we will need to change the way we plan and build our cities to make it faster and easier to get around. Having an integrated public and shared transport system both locally and across Aotearoa will encourage a shift in the way we live and travel.

Our draft advice recommends action to drive change in all sectors, as described above. It also recommends changes that cut across sectors, to support behaviour change and make sure that climate change is factored into government decisions. Changes to the ETS are needed to make sure it drives low emissions choices. We also recommend measures to ensure policy decisions and investments made now do not lock Aotearoa into a high emissions path.

What will this mean for New Zealanders?

Aotearoa must have an equitable and fair transition to a low emissions economy and society with benefits widely shared.

We have looked at the impacts which our budgets could have on the economy and society over the next 15 years. The overall costs of meeting the country’s targets and our proposed emissions budgets are likely to be less than 1% of projected GDP. This is significantly lower than what was estimated when the 2050 targets were set. While the overall costs are small relative to the size of the whole economy, they will not be evenly felt.

The transition to a low emissions society will bring opportunities, benefits, challenges and costs. Any change needs to be well-signalled, equitable and inclusive to make sure that it maximises opportunities while minimising disruption and inequities.

Different groups of society, regions and sectors will be affected in different ways, and impacts won’t always be evenly distributed. The Government will need to address this through careful policy design and targeted support. At the same time, government will need to recognise and encourage the co- benefits that come from climate action. This includes health improvements, quieter streets, cleaner water and increased biodiversity through more native forests.

There will inevitably be changes to employment as Aotearoa moves to low emissions. The coal mining and oil and gas sectors, and the services that support them, will be impacted by the transition away from fossil fuels. This will particularly affect regions with lots of workers in these

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industries. While these industries are already declining, our proposed emissions budgets could speed this up and possibly result in 600-1,100 fewer jobs across both sectors by 2035.

It is worth noting that many of these workers have important skills that will be valuable in other sectors and new industries. We expect employment will rise in in the circular economy, development of biofuels and hydrogen, and in deploying and supporting new technologies. A well- signalled transition will allow time to plan and support workers to retrain and redeploy into new areas of work. We recommend that the Government develop an Equitable Transitions Strategy to support an equitable, inclusive and well-planned climate transition. Government will need to work alongside people, and ensure they are including young people, regional Aotearoa, low-income communities, some Māori and Pasifika and people with disabilities to make sure they benefit from the opportunities and are not disproportionately impacted. Central and local government should support Māori communities to ensure they are appropriately resourced for the transition to a low emissions Aotearoa. Government will need to co-develop plans to make this happen and recognise people are the experts – our communities know what actions need to be taken to benefit or empower them.

While some businesses will need to close there will be many opportunities for new industries, businesses and jobs. Our analysis suggests that our emissions budgets could result in job losses in the coal mining and oil and gas sectors. At the same time, taking action to meet the budgets is also likely to result in new jobs in other sectors and new industries, such as supporting and deploying new technologies.

The make-up of the economy will change, and some workers will need to be supported to retrain or move to similar jobs in new industries.

Reductions in biogenic methane

Current Aotearoa targets require biogenic methane emissions to reduce by 10% below 2017 levels by 2030 and between 24-47% by 2050.

The Commission has been asked to provide advice on how much biogenic methane emissions may need to be reduced by in the future for Aotearoa to meet its international obligations.

Our analysis shows that by 2100, Aotearoa could need to reduce methane emissions by 49-60% below 2017 levels.

Our country’s world-leading agricultural sector has made big advances over the last 60 years, and improvements can and should continue.

Our analysis for our emissions budgets shows Aotearoa can achieve methane reductions of 24% by 2050 without any technology developments, such as vaccines or inhibitors. It is likely these technologies will become available, and this would increase the speed and efficiency of reducing methane emissions.

Our Nationally Determined Contribution (NDC)

The Commission was asked to determine if the first NDC for Aotearoa is compatible with contributing to global efforts to limit global warming to 1.5°C above pre-industrial levels.

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Our analysis has found that the Government’s commitment to reduce net emissions by an average of 30% from 2005 emissions levels over the 2021-2030 period is not compatible with global efforts.

If Aotearoa is to play its part as a developed nation, the NDC would need to be strengthened to reflect emission reductions of much more than 35% below 2005 levels by 2030.

The Commission’s proposed emissions budgets are already ambitious – but the NDC goes further.

To achieve our NDC, Aotearoa will need some offshore mitigation. We are not using this to do less domestically – but to increase our contribution beyond what is possible at home.

Conclusion

This document contains the Commission’s first draft advice to government, for input and consideration by the people of Aotearoa.

The advice and recommendations contained in this report draw on robust evidence and expert analysis. It incorporates knowledge and wisdom from a wide range of people and organisations to ensure it is sound and reflects our diverse experiences.

But this is draft advice. We are committed to true consultation and want to hear your feedback. We will consider all evidence we receive during consultation and are prepared to review and change any part of our work in light of this. We need to achieve a plan to address climate change that is effective, considered and ambitious – and Aotearoa won’t get there unless we work together.

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Climate Change Commission Recommendations

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Ko te Hurihanga Āhuarangi me te Kaunihera o Te Tairāwhiti Climate Change and the Gisborne District Council Gisborne District Council’s submission to the Climate Change Commission

Contact person: 18 March 2020

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Mihi E ōku nui, e ōku rahi, e ōku whakatairanga o Aotearoa whānui tonu, tēnā koutou katoa. Tēnā koutou me ngā tini whakaarotanga nui o te wa, rokohanga ngā pāheketanga i waenganui tonu i a tātau. Hāunga tērā, ko te tūmanako e pakake haere ana āu mahi, ā, kei te whakapapa pounamu tonu ngā huarahi i mua i a koutou i tēnei wā. Tēnā anō koutou, ā, tihe mauri ora!

Our esteemed leaders of the country who care for and guide us all the citizens of NZ, greetings to you all. Greetings to you in the continued spirit of glad tidings, albeit the challenges that still continue to impact us. That aside, I hope your work continues to excite you and that the opportunities before you are filled with reward. Greetings again. Alas the breath of life!

Summary of our key messages for you Climate change has or will have impacts on literally every aspect of life now or in the future. There are a wide range of portfolio Ministers and sectors with climate change interests. We cannot continue to ‘kick the can down the road’ if we want the best intergenerational outcomes for our communities and the environment. Broadly speaking Council supports the draft advice but has recommended some amendments and additions to ensure that we set ourselves up for success.

Council is concerned about the increasing costs faced by local government to respond to climate change. The transition to a low carbon economy will be expensive for councils in the first instance. For example, affordability is already the main constraint for funding public transport networks and walking and cycling infrastructure. Furthermore, councils must adapt their significant network of assets to the changing climate on top of supporting communities in managed retreat of their private property. Together, this means councils will face prohibitive costs in both the short-term and the long-term.

For Council, the exact implications of the draft advice will depend on Government’s policy responses. There needs to be a clearer definition of the accountability of local government for climate change policies, instruments, and actions, relative to those of central government. We are already confronted by competing directions and requirements, concerted effort will be needed to assure alignment across all relevant national policy and legislation.

It is important that Government and local government work closely together given the potential for regional disparities of policy implications. Investment in ensuring local government is able to work together alongside Government will be needed.

For Tairāwhiti, Principle 5 “Transition in an equitable and inclusive way” is crucial. Our region could experience disproportionate adverse effects due to our demographics, unless Government applies measures to mitigate these impacts (particularly for Māori and low income households). Additional support should be made available for regions likely to experience disproportionate adverse outcomes than the rest of New Zealand. Resourcing the change process itself needs to be an integral part of any thinking about a ‘just transition’.

Policy responses must ensure Iwi/Māori are able to exercise their rangatiratanga and enable Māori to fully participate in climate action.

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The elevation of native trees in the sequestration narrative supports regional aspirations and environmental outcomes in our spatial plan Tairāwhiti 2050. Our current national policy settings do not incentivise planting the right tree in the right place. Tairāwhiti already has a significant amount of land converted to forestry (about 17%)1. As of 1 April 2020 the net stocked area in the region is 155, 359ha, and the average age is 19.6years2. The capping of land conversion to forestry regionally would go some way to helping manage forestry and its impacts locally.

Nationally and locally, we have large and diverse coastal and marine environments that should be a key part of our mitigation and adaptation actions. The ‘blue economy’ could be another source of employment for those that are transitioning out of other high-emission sectors. This would complement the direction on shipping in the advice. Our recommendations Additional recommendations Council recommends that the Commission include recommendations to:

 Establish an interdepartmental executive board with responsibility for climate change as a time-critical action.

 Provide national and local support and advice to landowners and investors in a variety of professional disciplines for native forestry projects.

o As part of the support and advice offered, assessments be undertaken to help determine areas that would regenerate with less active intervention.

 Simplify access to funding and prioritise funding for areas where regeneration could occur with less active intervention.

 Provide additional funding and support for Regional Pest Management Plans to help facilitate native regeneration.

 Build up local supply chain of plants for native forestry (which has local employment opportunities).

 Direct that afforestation funding schemes also support conversion from plantation to native where specifc criteria are met.

 Increase the level of funding available to Councils through the Envirolink programme and increase the flexibility of the fund to give councils improved capacity to address the science supporting Council decision-making.

 Explicitly state the role and responsibilities of local government in the Zero Carbon Act.

 Resource the monitoring of non-monetary benefits of transport mode shift (e.g. environmental, social, cultural benefits.

 Investigate an increased FAR to promote mode shift to public and active transport.

1 https://www.gdc.govt.nz/assets/Files/State-of-our-Environment/SOE-Report-2020-LAND-SOIL.pdf 2 https://www.mpi.govt.nz/forestry/new-zealand-forests-forest-industry/forestry/new-zealands-forests- statistics/

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 Review the land transport funding model with a view to creating a model that incentivises low emissions transport.

 Accelerate the uptake of e-bikes and other e-micro mobility options alongside new active transport network infrastructure.

 Remove regulatory barriers, such as cumbersome traffic resolution processes, which significantly slow or hinder delivery of walking, cycling and public transport infrastructure.

 Better integrate urban planning and transport in the development of the proposed Strategic Planning Act.

 Accounting for long-lived GHG emissions generated upstream from extraction, production, transport, and consumption of packaging

 Further invesitgate:

o Greater clarity of well-functioning urban environment outcomes for Tier 3 councils under the NPS-UD

o Incentivising the use of low emissions building materials.

o Funding to urban design projects that promote low emissions communities such as street and reserve tree programmes (also reduces urban ‘heat island’ effects), cycleways and adaptive reuse of town centres.

o Financial support for rural land use optimisation such as landscape restoration and alternative high value land uses.

o Moving towards improved integrated urban planning which acknowledges and facilitates the multi-use of zoned land. For example, ‘passive open space’ can also serve as other purposes of drainage, ecological corridors, walking/cycling transport corridors.

o Urban development approaches that enable a critical mass around transport nodes to promote sustainable and economically viable active and public transport.

o Public transport and active transport being planning objectives rather than retrofitting (including timely rollout/delivery), for example assessing the ’walkability’.

o Other low carbon options other than ‘working from home’ which does not suit everyone, can be socially isolating and runs the risk of unintended consequences (e.g. more heating/cooling and lighting being used in more homes during the day). There is opportunity here for local authorities to create or encourage networks of community hubs and hyper-local micro hubs for shared and communal working. This would support changing away from current high emissions patterns of commuting from suburbs to city centres, build social connections and strengthen communities.

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Amendments to current recommendations and advice Council recommends that the Commission include the Land Transport Management Act on the list of legislation that needs to be aligned.

Council recommends that the Commission broaden the land emissions brief to include biological carbon removal, instead of just forestry.

Council recommends that the Commission amends Necessary Action 1, recommendation b to focus also on life and personal skills necessary to support transition to a low emissions economy or the impact of such a transition.

Council recommend that the Commission include a broader recommendation around reducing travel demand and encouraging more efficient travel – capturing more flexible working times and other arrangements (not just work from home) to allow for more off-peak travel and to encourage increased vehicle occupancies and mode shift. Road pricing Council strongly recommends that the Commission be more direct in its recommendations in support of road pricing.

Council recommends that the Commission expand their recommendation to include the use of any funds acquired through road pricing be reinvested into development, operation and maintenance of walking, cycling and low emissions public and shared transport infrastructure.

Council recommends that the Commission expand their road pricing recommendation to include introducing national transitional measures.

Council recommend that the Commission include a recommendation to direct the Ministry of Transport and Waka Kotahi (in conjunction with local authorities) to:

 Make final decisions on the technological approach for road pricing

 Develop enabling legislation to support road pricing

 Update (in a very timely manner) the research on the environmental and social costs of road use

 Identify of the next regulatory and practical steps to support road pricing in practice and that these steps be incorporated into the development of the integrated transport strategy and the Government Policy Statement on Land Transport Funding; and,

 Amend section 46 of the Land Transport Management Act to permit tolling of existing road use subject to consultation with the public.

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Contents Mihi ...... 2 Summary of our key messages for you...... 2 Our recommendations...... 3 Additional recommendations...... 3 Amendments to current recommendations and advice...... 5 Road pricing...... 5 The Big Issues for Te Kaunihera o Te Tairāwhiti...... 8 Future generations ...... 8 Consultation question: ...... 8 Just transition...... 8 Role and type of forests ...... 9 Consultation questions:...... 9 Why we support growing new native forests ...... 9 Current challenges facing native forestry ...... 10 Our recommendations to the Climate Change Commission...... 13 Managing the impacts of forestry - local interventions ...... 13 The science ...... 15 The consultation questions ...... 16 The approach and emissions budgets ...... 16 Enabling recommendations ...... 16 Cross-party support for emissions budget...... 16 Coordinate climate change efforts across Government...... 16 Genuine, active and enduring partnership with iwi/Māori ...... 16 Central and local government working in partnership...... 17 Incorporating the views of all New Zealanders ...... 19 The path to 2035...... 19 Overall path ...... 19 The direction of policy in the Government’s emissions reduction plan...... 21 Transport ...... 21 Waste ...... 26 Multisector strategy ...... 28 Rules for measuring progress ...... 29 Appendix One – Our Context ...... 30 Our Community...... 30 Our Council...... 31 Our assets ...... 32 Our finances...... 33

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Our major environmental restoration project ...... 34 Climate change and local government...... 34 Our climate change journey...... 37

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The Big Issues for Te Kaunihera o Te Tairāwhiti

The Climate Change commission has identified six big issues. The most important to us are:

 Future generations  Role and type of forests Future generations Consultation question: Do you agree we have struck a fair balance between requiring the current generation to take action, and leaving future generations to do more work to meet the 2050 target and beyond?

13. Do you support the package of recommendations and actions we have proposed to increase the likelihood of an equitable, inclusive and well-planned climate transition? Is there anything we should change, and why?

Council agree that a fair balance has been struck between the current generation and future generations. We cannot continue to ‘kick the can down the road’ if we want the best intergenerational outcomes for our communities and the environment. The work on developing and implementing a ‘just transition’ will be crucial in ensuring that the our current communities are not dispropriportionately impacted Just transition Council fully supports the recommendations and actions to increase the likelihood of an equitable, inclusive and well-planned climate transition.

Council already intends to develop a Tairāwhiti Just Transition Plan alongside Trust Tairāwhiti3A ‘just transition’ will focus on actions that reduce perverse outcomes from the transition. This plan collaboration is in line with the Commission's call for regional transition planning.

Support should be made available for regions likely to experience disproportionate adverse outcomes than the rest of NZ.

The work on a just transition will be crucial in ensuring that the our current communities are not dispropriportionately impacted. The infromation provided in Appendix 1 demonstrates the existing challenges faced by many in Tairāwhiti. The sheep, beef, cattle and grain farming sector is the largest employer in Tairāwhiti4. The modelling undertaken by the commisison suggests between 3,300 and 4,000 job losses in this sector by 2035. This would have a signficaint imapct on Tairāwhiti, where unployment is already the highest in the country (5.4% in the year to June 2020 compared to 4.1% for Aotearoa as a whole).

Rural regions in Tairāwhiti already have significant issues with water poverty and are reliant on tank water supplemented by purchasing water during dry periods. The quality of both rainwater tank and purchased water is an issue. This water poverty issue will be exacerbated in already stressed lower decile rural communities that will be faced with increased drought and an overall drier climate.

3 https://trusttairawhiti.nz/assets/Uploads/17-Jan-TEAP-Report-Full-Version-v24-single-pages2.pdf 4 Market Economics. Tairawhiti Spatial Plan Profile and Analysis report https://www.shapetairawhiti.nz/assets/docs/ME-Economic-Report.pdf

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Resourcing the change process itself needs to be an integral part of any thinking about a ‘just transition’.

The work of making transitions needs funding and resourcing – both creating the new systems and structures needed, and the actual processes of change.

A just transition will involve personal and professional learning for everyone.

The recommendation under Necessary action 1 is focused on vocational skills. While very important, New Zealanders will require a much wider set of life (personal) skills. For example, more frequent adverse weather events are likely to create additional needs for first aid skills. The focus should be broadened to learning a variety of skills not only on vocational skills.

Council recommends that the Commission amends Necessary Action 1, recommendation b to focus also on life and personal skills necessary to support transition to a low emissions economy or the impact of such a transition. Role and type of forests Consultation questions: Do you agree with our approach to meet the 2050 target that prioritises growing new native forests to provide a long-term store of carbon?

11. Do you support our approach to focus on growing new native forests to create a long-lived source of carbon removals? Is there anything we should change, and why?

17. Do you support the package of recommendations and actions for the forestry sector? Is there anything we should change, and why?

Council strongly agrees with prioritising growing new native forests to provide a long-term store of carbon. We fully support the approach to focus on growing new native forests to create a long-lived source of carbon removals. Furthermore, we support all the actions for the forestry sector and have recommended some additional actions. Why we support growing new native forests Some regions and districts already have a significant amount of land converted to forestry

The Commission recommends 300,000 additional hectares of natives and 380,000 additional hectares of exotic forestry to reach the 2050 target. This is intended to be managed and capped at a national level, rather than locally. However, some regions and districts already have a significant amount of land converted to forestry – predominately exotic. In Tairāwhiti, plantation forestry accounts for about 17% of land use compared to 8% nationally5.

Exotic forests and the activities surrounding their harvest are a source of conflict in local communities, for example the impact on the quality of local roads due to heavy and continued use throughout a harvest. In addition, the region has experienced several adverse environmental outcomes as a result of harvest practices. The regional climate report undertaken by NIWA indicates that there will be more extreme weather events in the future and therefore an increase in environmental risk. There is a place for both types of planting in the country’s emissions reduction plan; however, the local impacts need to be better managed through both national instruments, and tools and resources for councils.

5 https://www.mfe.govt.nz/sites/default/files/media/RMA/Our-land-201-final.pdf

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Our system does not incentivise planting the right tree in the right place.

National instruments need further work to ensure that native afforestation is elevated as equally or more desirable than exotic planting. We are currently experiencing the implications of market distortions created by national policy settings, and the environmental impacts of clearfell plantation forestry that are not adequately managed by the National Environmental Standard – Plantation Forestry (NES-PF)6.

Anecdotally, foreign investment appears to be driving forestry conversion. Our independent valuers report strong demand from overseas investors, particularly with the rising carbon price and attractive government policy7. For the first time in several years, pastoral land has been purchased for conversion to forestry. Over 75% of forestry in New Zealand is under foreign ownership.

The elevation of natives in the sequestration narrative supports regional aspirations and environmental outcomes in our spatial plan Tairāwhiti 20508.

Only 7% of the Tairāwhiti district is classified as native bush but about 15% of our region has highly erodible soils potentially unsuitable for traditional plantation forestry (pinus radiata and clear-fell). For New Zealand plantations, there is a window of vulnerability of about six years from the time of clearfelling until the replanted plantation crop establishes a full canopy, where plantation sites are more susceptible to erosion9.

Retiring land which is unsuitable for either farming or forestry will result in positive environmental and cultural outcomes for Tairāwhiti. However, further land conversion to exotic forests in our region could have negative impacts on our communities, especially if planting is not in the right location. Current challenges facing native forestry Our native forestry project, the Waingake Transformation Project (for background information refer Our major environmental restoration project in Appendix One), highlights some of the challenges for native forestry currently:

New Zealand Emissions Trading Scheme (NZETS)  In its current format, the NZETS is complex with several classifications and is a barrier to native forestry. As a participant in the NZETS, Council has had to commission external advice regarding its liabilities at harvest time, particularly when considering a move from exotic to native forest cover. Despite this external advice, there remains confusion about when and how to earn through the NZETS with native forestry. The current accounting system also enhances this preference toward exotic forests (refer to Accounting for forestry). For private landowners looking to pursue a similar transition from exotic to native forestry, the associated costs and uncertainty around liability and future income could be a substantial barrier.

6 https://www.mpi.govt.nz/forestry/national-environmental-standards-plantation-forestry/ 7 https://www.gdc.govt.nz/2020-property-revaluations/ 8 https://www.gdc.govt.nz/tairawhiti-2050/ 9 Ministry for Primary Industries 2017. Proposed National Environmental Standard for Plantation forestry: Section 32 Evaluation Proposed National Environmental Standard for Plantation Forestry: Section 32 Evaluation (mpi.govt.nz)

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Resources  Seed sourcing requires specialist knowledge and skills - building up a selection of sites within or as close as possible to the project site, identifying suitable mature trees for seed sourcing, understanding the phenology of each species, monitoring the development of seed set, collecting, cleaning and processing seed to ensure viability, propagation technique and so on. These skill sets need to be developed alongside improving nursery capacity.

 While there are forestry planting crews available to contract for planting services, the way in which native plants need to be planted is very different to forestry planting techniques. The skills are not necessarily transferable and crews need upskilling/training for planting natives, unless they are planting forestry grade manuka. Locally there are gaps in the workforce for post plant maintenance and weed control also – it is a real challenge for us to find contractors to complete weed control at Waingake.

 Council is fortunate that is employs a variety of experts in different professional areas that can provide timely advice throughout the project. There are very few potential investors or landowners that have access to this advice and support without substantial personal expense and no guarantee that the project will progress or be a success.

Funding

 Funding is challenging for native conversion. Council’s own funds for investment come predominately from rates, this limits the amount and pace at which the project can proceed without external funding.

 One Billion Trees provides only a minor portion of the actual costs of native conversion costs, significant investment will still needed by Council to pursue the project if it attains funding under this programme. Applying for this funding is also resource intensive, and long timeframes for sign-off and approval leave projects with a high level of uncertainty. Despite the co-benefits and community and iwi/hapū support, as this project is a conversion project from plantation to native it was difficult to meet the requirements of the One Billion Trees fund.

 Current funding cycles do not align with timeframes for sourcing seed and propagating plants ready for revegetation planting. Projects need to be planning for planting a year ahead, and funding cycles should be developed which support planning to secure eco-sourced plant material.

 Replanting is only part of the costs for ensuring successful native regeneration. Ongoing pest animal and weed control is important and this is required for a number of years as native forests are slower to grow than exotic forests.

 Pest control is essential to ensure survival of naturally regenerating or planted native forests. We require capacity building in the region to help address this issue. Working with mana whenua to achieve a balance between effective pest control and enabling hunting for kai (pigs/deer) needs to be considered. This is not necessarily a big consideration for private land owners.

We have included our Waingake project in our draft 2021-2031 Infrastructure Strategy. The projected captial expenditure in Figure 1 and Figure 2 highlights our affordability challenge we face in funding this project given that $8 million in new expenditure is equivalent to a 1% rates increase.

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This expenditure also impacts on the Council’s debt threshold if it is funded through loans rather than external funding. Council has a limited ability to increase debt under our draft 2021-2031 Financial Strategy10, which has a debt limit of 130% to net revenue.

Figure 1 Ten year capital expenditure forecast for Waingake project

The red colour-coding for the bars is the impact on the level of service. This project is considered an increased level of service under our draft 2021-2031 Long Term Plan.

10 https://www.gdc.govt.nz/assets/Uploads/21-0-Draft-2021-2031-Financial-Strategy.pdf

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Figure 2 Thirty year capital expenditure forecast for Waingake project

Our recommendations to the Climate Change Commission Based on our own experience, Council recommends that the Commission include recommendations to:

 Provide national and local support and advice to landowners and investors in a variety of professional disciplines for native forestry projects

o As part of the support and advice offered, assessments be undertaken to help determine areas that would regenerate with less active intervention

 Simplify access to funding and prioritise funding for areas where regeneration could occur with less active intervention

 Provide additional funding and support for Regional Pest Management Plans to help facilitate native regeneration

 Build up local supply chain of plants for native forestry (which has local employment opportunities)

 Direct that afforestation funding schemes also support conversion from plantation to native where specifc criteria are met Managing the impacts of forestry - local interventions At local government stakeholder events, the Commission posed the question: “Are tools also needed at a local level – for example, to manage local impacts of forestry?”

Controlling afforestation is not a simple issue to address locally, as ultimately intervention by Council could be viewed as telling landowners how to farm and use their land.

There are also national policy drivers that influence forestry investment choices. For example, the controls put in place under the Overseas Investment Act and the funding and financial support available under the One Billion trees programme.

Treaty obligations

Council also needs to ensure any intervention it takes provides for Māori landowners, many of whom invest in forestry and are already making informed choices about afforestation. Past Treaty settlements have been made based on land being able to be used for plantation forestry, whereas potentially only some whenua Māori may be appropriate for this land-use.

Local intervention options

Research has identified that landowners are unlikely to change their activities to achieve a greater external benefit (such as mitigating climate change) unless the measures taken are worthwhile to them, or at least leave them no worse off11.

11 Haydon Jones, Peter Clough, Barbara Höck, and Chris Phillips 2008. Economic costs of hill country erosion and benefits of mitigation in New Zealand: Review and recommendation of approach https://www.researchgate.net/publication/253418045_Economic_costs_of_hill_country_erosion_and_be nefits_of_mitigation_in_New_Zealand_Review_and_recommendation_of_approach

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Councils could use rating policies locally to incentivise forestry, exotic or native, or both. Currently land is valued based on ‘highest and best-use’. If pastoral land is planted in forestry it will be valued and rated as ‘forestry land’. If the forestry is native and subject to some sort of enduring protection (QE II covenant or Ngā whenua rahui) then it may be eligible for a rates remission.

Council’s rates setting and remission policies do not currently specifically address carbon forests; however, it is a tool that could be used. It is likely that most councils would want to incentivise native carbon forests rather than exotic carbon forests as remissions for exotic forests would not accurately reflect the investment required from Council to ensure roads are maintained and repaired due to heavy logging traffic. Rating remissions are not a very effective tool to encourage specific land uses, other national and local tools would still be required.

Another tool councils can use is their resource management plans, although the time and cost taken to develop these results in very slow change. Currently forestry land use in the rural zone under the Tairāwhiti Resource Management Plan is a permitted activity12. Resource consent is only required if afforestation is on steep land or in an area of identified significant landscape and/or biodiversity values under the NES-PF13.

Additional rules and land-use controls shouldn't be the first or only option for Council, we already have considerable pressure on our consent processing resources and have little capacity to cope with more resource consents. Changes to resource management plans could consider socio-economic impacts on the community, but we lack capacity and capability to undertake the required analysis and defend the outcomes. The plantation forestry sector is well-organised and resourced and tends to take an aggressive approach if it feels its business is being constrained or additional consenting requirements imposed. The preferable option would be that the government better manage the driver of carbon forestry in the carbon price.

Effects currently not addressed by the NES-PF should be reconsidered and included at a national level to ensure consistency across the country

The NES-PF does not address the wider land use issues associated with changing land use, such as impacts on infrastructure and rural communities (except for effects on amenity landscapes and shading of roads).

Council does have the option to pursue this and implement planning provisions through the review of the TRMP; however, the current process for reviewing plans is lengthy and is unable to address issues that are occurring now. Furthermore, there is often immense push-back if addressing this matter in local plans, like the TRMP, and it is misconstrued as councils trying to tell people how to use their land, especially whenua Māori. A stronger emphasis on the impacts of land use types and how they are to be managed will hopefully come through in the development of the anticipated Natural and Built Environments Act.

A useful local tool would be the capping of land conversion to forestry. This is currently proposed to occur nationally but implementing a regional ratio would go some way to helping manage forestry and its impacts locally.

12 https://www.gdc.govt.nz/the-tairawhiti-plan/ 13 https://www.mpi.govt.nz/forestry/national-environmental-standards-plantation-forestry/

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Tairāwhiti is a region that could become ‘overrun’ by exotic forests and provide more than its fair share of the national quota of exotic forests. Plantation forestry accounts for about 17% of land use compared to 8% nationally14. It is also not anticipated that many of these exotic forests would be carbon sinks15. The science There is emerging science that suggests that increasing temperatures and increasing CO2 in the atmosphere may significantly change the dynamics of both indigenous and exotic forests. For indigenous forests the likely impact will be changes in range of particular species, for example Kauri expanding further south. For pine forests, both New Zealand and US studies have suggested that these changing environmental factors may result in faster growth, taller trees but this may at the expense of a lower wood density and tree diameter at maturity. This may have a significant impact on the long-term economic sustainability of pine grown for harvest and increase vulnerability to loss due to windthrow and new pest species.

14 https://www.mfe.govt.nz/sites/default/files/media/RMA/Our-land-201-final.pdf 15 Review of regional log availability. Forme Consulting Group, 2019.

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The consultation questions The approach and emissions budgets 1. Do you support the principles we have used to guide our analysis? Is there anything we should change, and why?

Council fully supports the principles that have been used to guide the Commission’s analysis.

For Tairāwhiti, Principle 5 “Transition in an equitable and inclusive way” is crucial.

As outlined under Our Community, Tairāwhiti has a number of factors to contend with that may mean our people and region will be ‘left behind’ if the transition is not well managed. Enabling recommendations Cross-party support for emissions budget 5. Do you support enabling recommendation 1? Is there anything we should change, and why?

Council fully supports this recommendation.

We respect the importance of a variety of political views; however, responding to climate change and reducing our emissions needs to remain as apolitical as possible

Consistency in the strategic direction for long-term issues will reduce the rework required for councils and reduce pressure on resourcing requirements. This will enable a consistent, effective and efficient transition to a low emissions future and adaptation to the impacts of climate change. Coordinate climate change efforts across Government 6. Do you support enabling recommendation 2? Is there anything we should change, and why?

Council fully supports this recommendation.

We have provided further comment about coordinating efforts in Multisector strategy. Genuine, active and enduring partnership with iwi/Māori 7. Do you support enabling recommendation 3? Is there anything we should change, and why?

Council fully supports this recommendation.

Policy responses must ensure Iwi/Māori are able to exercise their rangatiratanga and enable Māori to fully participate in climate action.

There is a risk that emissions budgets could place disproportionate restrictions on iwi/Māori Any additional costs arising from climate policy could result in additional barriers for the continued development of iwi/Māori landholdings and businesses.

Some Māori-collectives have received forested land through Treaty settlements, if the land has pre-1990 exotic forests they are burdened with a deforestation liability which creates barriers for alternative aspirations such as papakainga development. Once agriculture enters the NZETS, free emissions allocation needs to carefully consider how to avoid disadvantaging Māori-collectives operating in this sector.

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Central and local government working in partnership 8. Do you support enabling recommendation 4? Is there anything we should change, and why?

Council fully supports this recommendation, but suggest some additions to enhance consistency and integration.

It is important that we work closely together given the potential for regional disparities of policy implications.

True partnership between central and local government in the areas highlighted in enabling recommendation 4 would assist to achieve the ambitious goals recommended by the Commission. This partnership needs to start early on, by jointly agreeing how to work as partners and developing the work plan mentioned under the heading “progress indicators”.

There needs to be a clearer definition of the accountability of local government for climate change policies, instruments, and actions, relative to those of central government.

An explicit statutory role and requirements would go some way to providing consistency in the framework and approach across the country. Under the Zero Carbon Act there are few explicit references to local government climate change obligations. Despite this, any requirements recorded in any of the instruments to be prepared under this Act are more than likely to impact on the roles and responsibilities of local government.

Council recommends that the Commission include a recommendation to explicitly state the role and responsibilities of local government in the Zero Carbon Act.

Including an explicit reference and requirement of local government removes the debate around what the role/s and responsibilities are or should be, leaving the sector to get on with ensuring that it meets them in accordance with their specific community’s preferences. Currently some of the perceived climate change responsibilities of local government are more discretionary than obligatory.

Council recommends that the Commission include the Land Transport Management Act on the list of legislation that needs to be aligned.

The draft advice includes a list of legislation and instruments that will need to be aligned. The Land Transport Management Act is absent from this list and transport is key policy area for councils and climate change.

Potential barriers In working together, the following may become barriers for participation for local government if not addressed:

 Funding constraints and insufficient revenue to address anything but priority water, road, community service and place making responsibilities.

 Uncertainty and lack of pan-council support for giving priority to climate change initiatives, compared to other pressing issues such as investment in the upgrade of water infrastructure.

 Lack of capability and capacity across each council to:

o Assess the carbon footprint of Council activities.

o Prepare carbon reduction plans.

o Assess climate change risks.

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o Prepare climate change adaptation and resilience plans.

 Unwillingness of communities to make necessary decarbonisation behavioural changes.

 Council operational models that create a propensity to address complex issues in a siloed function-specific way rather than by applying an organisation-wide strategic approach.

 Councils working in isolation from each other and an absence of collaboration.

 Insufficient information about the local risks and impacts of climate change on floods, biodiversity and health and the priority that should be accorded to mitigation and adaptation interventions.

 Clarity on the interface between central government responsibilities and local government responsibilities

Collaboration and consistency across local government There is a need to develop common and preferred climate change mitigation and adaptation methods covering matters such as:

 Adaptation:

o Methods for defining and developing a risk assessment framework for local government16.

o Methods to better apply the Task Force on Climate-related Financial Disclosures framework to the local government context.

o Methods for defining / confirming community views about how to motivate and optimise behavioural change.

o Methods for defining preferred approaches to adaptation and resilience building.

o Methods for defining flood return intervals / sea level rise.

o Better resourcing and enhanced capacity-building to address managed retreat.

 Mitigation:

o Methods for achieving consistent approaches to carbon reporting e.g., choice of Scope 3 categories, choice of emission factors, reporting boundaries etc.

o Methods for defining what ‘zero carbon’ actions may most effectively be applied (what works best) within local government entities and communities.

o Business case for insetting carbon emissions.

o Methods for establishing consistency between the defining and measuring progress of mitigation actions applied by local government.

16 This work has started recently with delivery expected mid-2021.

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o Methods for providing easy access to a shared library of reduction assessment

tools such as: marginal cost abatement curves, $ investment per kg CO2e emission reduction achieved etc.

Investment in ensuring local government is able to work together alongside Government will be needed.

Some potential solutions for enabling effective collaboration:

 Funding and support of a collaborative climate change website/portal for the public sector, including a local government focus area.

 Funding and support for the local government officers’ climate change network to support information exchange between local government climate change leaders.

 Development of templates, methods, models, and policy positions across potential local government actions. For example, how to conduct a regional risk assessment using a ‘model’ approach.

 Deliver an annual public sector climate change forum – where progress and initiatives/actions can be shared, and climate change progress can be accelerated. Incorporating the views of all New Zealanders 9. Do you support enabling recommendation 5? Is there anything we should change, and why?

Council partially supports this recommendation. Although we support new and effective mechanisms to incorporate public opinion, there is an assumption with this recommendation to start new rather than leverage off existing platforms and stakeholder engagement opportunities. Our communities are often beset by multiple consultations from multiple government departments using different engagement methods.

Never before has Council consulted on issues as it does now, having multiple conversations at the same time in order to progress important work and statutory requirements. Adding another mechanism and voice such as a public forum into the mix will add to consultation fatigue and confusion. Our community love to give their opinion but are often frustrated by the blinkered approach to each conversation and the change in engagement methods. The path to 2035 Overall path 12. Do you support the overall path that we have proposed to meet the first three budgets? Is there anything we should change, and why?

Council supports the overall path to 2035; however, we could further investigate and advance ‘blue carbon’ and use of wetlands as carbon sinks.

We have large and diverse coastal and marine environments that should be a key part of our mitigation and adaptation actions.

Supporting the ‘blue economy’ initially through the development of centres of research and development will enable the required innovation to develop the next generation of carbon removals and energy generation for later emissions budgets. Marine energy and coastal ‘blue carbon’ capture will likely require public-private partnerships and may take some time in becoming economically viable. The ‘blue economy’ would also provide potential alternative employment opportunities in coastal settlements, including small and isolated areas, around New Zealand.

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There is an opportunity to explore ‘blue carbon’ credits for places like salt marsh and estuarine wetlands. Many of these areas have been drained or are now in farming paddocks, but still flood on big tides or storms. If there was a carbon price attached to this land like there is for forestry, landowners and farmers would have an economic incentive to retire the land (often low productivity). This would be an additional incentive to assist farmers transitioning to a low carbon economy and lead to improved ecosystems, ‘blue carbon’, and managed retreat.

Council recommends that the Commission broaden the land emissions brief to include biological carbon removal, instead of just forestry.

Including wetlands in the “land emissions” definition broadens the options for carbon sinks. This would introduce a wider range of carbon sinks, such as:

 Long term management of estuaries and mangrove forests allowing for their inland movement because of sea level rise.

 Restoration of drained wetlands.

 Use of aquaculture as regenerative carbon sinks for example, mussel farming and seaweed farming.

 Expanding the marine protected area network (kelp forests) and their role in storing carbon.

 Restorative aquaculture, areas within the coastal marine environment that are established for the sole purpose of capturing and storing carbon.

Perspectives on the past An area that should be further investigated in policy development is understanding why the measures we have taken in the past have not worked to change behaviour significantly. We need to better understand how we can incentivise behaviour change, particularly where good alternatives are already available.

Urban form At local government stakeholder events on their draft advice the Commission posed the question: “How can government support a strong relationship between urban planning, design and transport, to ensure Aotearoa has well-designed low-emissions communities?”

We are already required to manage complex and competing tensions in the resource management space. Where national directions are being prepared, we encourage that such directions provide clarity on identifying, prioritising and weighting such tensions to enable timely and cost-effective implementation. Examples include the allocation of freshwater water, highly productive land, indigenous biodiversity and achieving well- functioning urban environment outcomes sought through the NPS-Urban Development.

There needs to be explicit responsibility included in national direction and legislation for local authorities to take emission consequences into account in urban development and land use decisions. This direction and legislation must be coordinated and consistent to ensure that councils are not forced into implementing counter-productive measures due to siloed policy- making. Urban planning, transport, and infrastructure design and investment is a critical part of ensuring we have well-designed low-emissions communities.

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Council recommends that the Commission include recommendations to further investigate:

 Greater clarity of well-functioning urban environment outcomes for Tier 3 councils under the NPS-UD.

 Incentivising the use of low emissions building materials.

 Funding to urban design projects that promote low emissions communities such as street and reserve tree programmes (also reduces urban ‘heat island’ effects), cycleways and adaptive reuse of town centres.

 Financial support for rural land use optimisation such as landscape restoration and alternative high value land uses.

 Moving towards improved integrated urban planning which acknowledges and facilitates the multi-use of zoned land. For example, ‘passive open space’ can also serve as other purposes of drainage, ecological corridors, walking/cycling transport corridors.

 Urban development approaches that enable a critical mass around transport nodes to promote sustainable and economically viable active and public transport.

 Public transport and active transport being planning objectives rather than retrofitting (including timely rollout/delivery), for example assessing the ’walkability’.

 Other low carbon options other than ‘working from home’ which does not suit everyone, can be socially isolating and runs the risk of unintended consequences (e.g. more heating/cooling and lighting being used in more homes during the day). There is opportunity here for local authorities to create or encourage networks of community hubs and hyper-local micro hubs for shared and communal working. This would support changing away from current high emissions patterns of commuting from suburbs to city centres, build social connections and strengthen communities.

The direction of policy in the Government’s emissions reduction plan Transport 14. Do you support the package of recommendations and actions for the transport sector? Is there anything we should change, and why?

Council supports the actions and associated recommendations for the transport sector. The direction in the 2021 Government Policy Statement on land transport is already strong in relation to supporting low emissions public transport, walking, and cycling, but a key issue is the availability of funding, including affordability of local share, and the sometime onerous processes required to unlock that funding17.

At local government stakeholder events on their draft advice the Commission posed the question: “Development of an integrated national transport network to increase walking, cycling and low emissions public and shared transport – what are the biggest constraints on councils and what do they need to support this?”

17https://www.nzta.govt.nz/planning-and-investment/national-land-transport-programme/government- policy-statement-on-land-transport/

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Funding Funding is both a constraint and a support tool for local government regarding the development of an integrated national transport network. Affordability is already the main constraint for funding public transport networks and walking and cycling infrastructure. Our draft Te Tairāwhiti Regional Land Transport Plan 2021-2031 includes three large walking and cycling projects that have been rated by the Regional Transport Committee as the highest priority for our region. However, they will all require funding from external grants for the local share if they are to proceed.

Even if national spending on this infrastructure increases, the ability of local authorities to pay their local share will still be constrained by rates revenue or the ability to get external funding. Government’s support would be needed for Council to achieve these outcomes due to affordability concerns as outlined in Our finances.

Waka Kotahi has used an increased Funding Assistance Rate (FAR) for projects in past to incentivise different types of infrastructure and enable local investment to be affordable. Council recommends that the Commission include a recommendation to investigate an increased FAR to promote mode shift to public and active transport. For example, a 90% FAR rate instead of the usual local FAR rate for projects meeting the criteria. These projects would also provide multiple benefits (emission reduction, health and safety and accessibility).

Like councils, Waka Kotahi has a set budget it works with to achieve the outcomes required by Government. Doing more with the same is unrealistic if we expect to make real change and develop an integrated national transport network. Private vehicle use has been the country’s primary mode of transport for a long time and it is also ingrained into the way our built environments are designed and developed. This is an issue that will take time to resolve and intervention will need to be supported by Government – financially and with clear national direction and standards.

The current land transport funding model has been developed around the preference of private vehicle as the main mode in NZ. The model needs to be reviewed to determine the best way to fund the transition to, and management of, the future network needed to achieve the envisaged emission reduction targets. The transport funding model will need to be changed to accommodate the decrease in petrol vehicles (ie. revenue generated through Fuel Excise Duty). Council recommends that the Commission include a recommendation to review the land transport funding model with a view to creating a model that incentivises low emissions transport.

There is the potential to increase fuel taxes as disincentive for the ownership and use of fossil fuel vehicles and to provide additional funding to implement the desired transport network. In the interests of a just transition this needs to be balanced with subsidies/loan schemes for EV. There needs to be a financial incentive for transitioning earlier to EV as well as support for those that may be disadvantaged, for example social leasing.

Centralised tools The following tools would be beneficial for all public infrastructure, not just land transport.

Waka Kotahi have a lot of power to direct local transport funding through their Investment Assessment prioritisation tools. They acknowledge that environmental benefits are often overlooked as they are not ‘measurable’. Some work has been done to develop indicators and the evidence for these, but this work needs to be strengthened and integrated into other government investment frameworks to ensure consistency. A consistent approach to measuring the environmental benefits of infrastructure decisions will be key to a new way of showing the value and benefits of infrastructure investment into the future.

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Waka Kotahi require a good evidence base for their funding decisions and prioritisation of projects under the National Land Transport Fund. Evidence of mode shift and environmental outcomes is often lacking from Council planning and funding bids as it is currently difficult or expensive to measure. Council recommends that the Commission include a recommendation to resource the monitoring of non-monetary benefits of transport mode shift (e.g. environmental, social, cultural benefits).

Procurement is an important tool used by councils to achieve its objectives for a specified set of work. To ensure consistency in approach to low emissions and other procurement criteria that are needed to transition to a low emissions future, centralised procurement support for the public sector should be developed and be made available to local government as well. This would ensure that expectations of contractors are consistent and procurement is supported with research/tools for monitoring emissions.

Research and development of new technologies and methodology will be key to gaining further emissions reductions. Centralised research and development for alternative building materials and construction methods would be beneficial for all public infrastructure, as well as privately built infrastructure. Centralising this research and development would enable councils to focus their spending in other areas that they need to address, for example adaptation of coastal infrastructure. Additionally, to incentivise more expensive low carbon alternatives (e.g. new emulsions) subsidies could be provided, or taxes imposed on less desired materials and methods to try to ‘even the playing field’ from a consumer’s price perspective.

Road pricing More can be done now to incorporate stronger pricing signals into the land transport system. Road pricing could be used to better reflect the true costs of the transport network (e.g. development, maintenance, environmental and health costs) and encourage a mode shift towards public and active transport shift. Road pricing could also help reduce affordability issues around the maintenance of our roads – particularly low volume/access roads that are vital for forestry and our economy but are expensive to maintain.

Legislative changes to enable the use of road pricing tools like congestion charge/cordon charge/parking pricing is an important action that has significant potential to support the proposed emissions budgets. Council strongly recommends that the Commission be more direct in its recommendations in support of road pricing. This is one of the biggest practical steps that can be taken to reduce the emissions that come from transport.

A key outcome in the success of implementing road pricing would be the reduction in total emissions regardless of the time of day, not just in peak traffic times, due to mode shift. Road pricing is a policy tool that will achieve other policy objectives in terms of health and safety, asset management and the other environmental impacts of road use (e.g reducing road run off). It would encourage a more sustainable urban form by encouraging intensification along transport routes, particularly around the key transport nodes (such as railway stations). A reduction in traffic volumes also serves to make active modes more attractive due to reduced concerns around mode conflict and the real and perceived safety risks associated with this.

To ensure that road pricing is successful in incentivising mode shift other factors need to be considered and progressed. The availability of convenient alternative modes of transport to private vehicles from ‘day one’ are a must-have to be successful in achieving transitions to other modes.

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The administration and expenditure of road pricing revenues will become a key issue (centrally or locally). User acceptance of a scheme is critical, and the key to this is having a credible and publicly accepted plan for the use of the funds. Council recommends that the Commission expand their recommendation to include the use of any funds acquired through road pricing be reinvested into development, operation and maintenance of walking, cycling and low emissions public and shared transport infrastructure.

Tolling of new and existing roads could be a useful intermediate step to full road pricing as both a revenue raising tool and a demand management tool. Moving to toll a network of strategic roads – for example, major urban arterials with few practicable alternatives or low volume/access roads that are required only for forestry harvest might be appropriate places to start. This would acclimatise people to the notion that they are paying to use the roads not just to build the physical infrastructure. The time involved in implementing road pricing of whatever form and ensuring credible alternatives are available may necessitate that a transitional measure such as increasing the level of fuel excise and road user charges may also need to be pursued. Council recommends that the Commission expand their road pricing recommendation to include introducing national transitional measures.

For road pricing to be a successful tool to reduce emissions there will need to be a coordinated national approach and leadership to avoid duplication of efforts and resourcing to implement any road pricing directed. This will also reduce inconsistencies in application that may detract from achieving an integrated national transport network. To progress road pricing around the country Council recommend that the Commission include a recommendation to direct the Ministry of Transport and Waka Kotahi (in conjunction with local authorities) to:

 Make final decisions on the technological approach for road pricing

 Develop enabling legislation to support road pricing

 Update (in a very timely manner) the research on the environmental and social costs of road use

 Identify of the next regulatory and practical steps to support road pricing in practice and that these steps be incorporated into the development of the integrated transport strategy and the Government Policy Statement on Land Transport Funding; and,

 Amend section 46 of the Land Transport Management Act to permit tolling of existing road use subject to consultation with the public.

Public and active transport While shifting to EVs is important, we also need to be investing in high quality public transport and safe, connected, and attractive active mode networks. Providing safe environments for active transport when our built environment is designed for private vehicle use often causes conflict between user groups. We strongly support recommendation 2b (p.106) to “significantly increase the share of central government funding available for these types of transport investment, and link funding with achieving our emissions budgets” as current funding levels will not support the changes needed to develop the transport network envisaged by the Commission.

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As a society we will have to change our perspectives and the values that are attached to private vehicles – both their use and ownership. For example, vehicle ownership is a factor that is often assessed when looking at deprivation in a community or accessibility inequalities. This is appropriate while we have few alternatives available, but we need to change this perception moving forward to where public and active transport are more desirable modes. We need better ways of assessing the accessibility of a community beyond measuring household access to a car. This links to the comments made earlier under Centralised tools around the need to develop a centralised approach and provide resource to monitor mode shift across all networks.

There should be greater focus in the overall transport advice on reducing the need to travel. In the hierarchy of interventions, reducing the need to travel should come before dealing with it in a more sustainable/lower emission way. Short term measures like changing the way/when/where/how we work need to be promoted and supported with technology. Council recommend that the Commission include a broader recommendation around reducing travel demand and encouraging more efficient travel – capturing more flexible working times and other arrangements (not just work from home) to allow for more off-peak travel and to encourage increased vehicle occupancies and mode shift.

Incentivising active transport supports other co-benefits, for example individual health through increased exercise. Council recommend that the Commission include a recommendation to accelerate the uptake of e-bikes and other e-micro mobility options alongside new active transport network infrastructure. This could be achieved by subsidising the up-front cost purchase cost, partnering with local suppliers to smooth freight supply issues, and funding the quicker roll-out of associated charging and secure parking facilities.

Councils are often criticised for the time it takes them to implement change. In part this is due to the myriad of regulatory and statutory requirements we must adhere to that are unique to our sector. Council recommend that the Commission include a recommendation to remove regulatory barriers, such as cumbersome traffic resolution processes, which significantly slow or hinder delivery of walking, cycling and public transport infrastructure.

Freight With historic and current policies encouraging exotic forestry, the ‘wall of wood’ that will be harvested and transported on our roads will be a significant challenge for the transport industry. The effects on the network due to this increased use will vary across regions and interventions will likely be increased maintenance, road reversion to prioritise spending in other high priority areas, and significant changes needed to current road and intersection designs. There are no avenues for councils to manage the projected increase in forestry trucks, councils like Gisborne District Council are already facing intense network pressure with the increase in forestry trucks and this will only worsen.

Alternatives to road transport for freight need to be investigated and invested in. This is needed to transition from lower efficiency to higher efficiency transport modes ahead of replacement technologies, e.g. use of coastal shipping (including incentives to create a domestic industry) and significant reinvestment in rail, to make it the preferred long-distance freight option (particularly in the multi-modal and freight forwarding business). Rail and short sea shipping will play a much bigger role in the future of freight, and more funding will be required to make these modes competitive.

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These alternatives provide opportunities for transporting people as well as freight. For example, increased coastal shipping would provide transport opportunities for people and goods to small coastal settlements. Many of these settlements are a long way by road from main routes and under disrupted climate it may become unsustainable to repeatedly restore roads that have repeat significant slip or wash-out events. There is the opportunity to shift to a ‘beyond road’ model for these settlements – where they would need to be able to sustain their own energy supplies and water treatment, and transport may be a mix of coastal shipping, drone delivery and autonomous robotic terrain walkers. The key challenge for this suggestion is that the existing port infrastructure, including access roads are low-lying which will be at risk from the effects of climate, sea level rise, increased stormy conditions and frequent inundation. Additional consideration is needed to determine how to build resilience into a shift from road transport to sea and to ensure that expansion of the shipping ports and associated networks are strategic and well thought through and do not result in further degradation of sensitive coastal environments.

Integrated planning The role of urban form in contributing to emissions reduction budgets should be strengthened and given a higher profile in the report actions and recommendations.

In the longer term we need better integration of urban planning and transport to promote efficient cities based around transport and economic hubs – Council recommend that the Commission include a recommendation that better integration of urban planning and transport is incorporated into the development of the proposed Strategic Planning Act. This may also require a rethink about the form and purpose of regional land transport and public transport planning, or if they are destined to instead become an operational action plan for the transport components of a spatial plan under the proposed Strategic Planning Act. Waste 18. Do you support the package of recommendations and actions for the waste sector? Is there anything we should change, and why?

Council supports the actions and associated recommendations for the waste sector. The Commission’s general waste advice takes us in the right direction, but the recommendations could be more specific, holistic, and ambitious to harness the power of reduction, reuse and recovery strategies to reduce our emissions. Council recommends that the Commission include recommendations on accounting for the long-lived GHG emissions generated upstream from extraction, production, transport, and consumption of packaging. The consumption-based approach should play a key role in setting our emissions budgets and measuring progress. Consumption-based emissions data follows emissions through the lifecycle of products and materials, exposing both embodied emissions generated offshore and the upstream emissions cost of short-lived consumer goods.

The Commission’s path sets a waste reduction target for organic waste to landfill of 23% by 2030 - we should aim higher. Government needs to mandate separate collection of organics (first emissions budget) and ban organic waste from landfill (second emissions budget) to halve food waste at source by 2030, and divert more organic waste to local and regional composting. There are opportunities in large-scale composting of organic waste to create local employment for those that may be affected by job-losses in other industries.

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The Government is developing a new waste strategy this year, it is critical that it sets stretch targets and focuses on waste reduction to put New Zealand on the path to a low waste, low carbon circular economy18. This is a key opportunity to implement the Commission’s advice. Government needs to set waste reduction targets in the Waste Strategy and the Waste Minimisation Act for all waste streams, organic and inorganic. This includes single use plastics and packaging, e-waste, textile, and construction and demolition waste.

As a sector in February 2020 Taituarā launched a report to support local government chief executives and managers in their statutory responsibility to promote and maximise the well- being of their communities for the future, as well as the present. The report outlines five future transitions that council's need to make, along with a framework to structure our thinking on how these transitions can be made19. Transitioning to a low waste society is one of the five critical transitions local government is focused on20. A three horizons approach has been developed to provide clarity about what we are changing from, and what we are changing towards by bringing shifts in assumptions and systems to the surface. The three horizons map for waste is:

At local government stakeholder events on their draft advice the Commission posed the question: “What are the barriers to reducing waste at source and where could the best investment be made?”

18 https://zerowaste.co.nz/reduce-waste-to-reduce-emissions/ 19 https://taituara.org.nz/Attachment?Action=Download&Attachment_id=2200 20 https://taituara.org.nz/Article?Action=View&Article_id=230

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The waste hierarchy, which prioritises prevention, reduction and reuse, can be used to help guide decisions and investment. We need to move away from focusing on recyclability and diversion from landfill. We need to support innovation within industry to design more reusable products, have more effective and efficient reprocessing of plastics, and to use safer alternatives to plastic. In 2015 the United Nations Environment Programme estimated that improving waste management practises and recovering more materials could reduce emissions by 15 to 20% (and more) if we are serious and purposeful in our actions to design waste out of the system to begin with and keep products in use for longer21. Developing New Zealand’s resource recovery industry will create good local jobs to replace those lost in other sectors as we make the transition.

Government needs to use effective product stewardship to create reuse and resource recovery systems that keep materials in circulation and make things last as long as possible. Products that cannot be effectively recovered and recycled or composted need to be designed out of the economy, single use disposable products and ‘right to repair’ should be a priority. This includes the products that we import, councils have no control over what products come into the country, but currently have responsibility for dealing with it on disposal. An ideal future state is where ‘Everything that enters the country has to have a sustainable path for its life-cycle as a condition of its entry’.

Product stewardship schemes make it easy for households and businesses to do good quality recycling. Investing in work being done by the waste sector on product stewardship schemes will help reduce our emissions. For example, a beverage container return scheme will increase recycling rates and replace virgin raw materials with recycled content22. Another example is an e-waste scheme that will use ‘urban mining’ to recover precious metals and rare earths which reduces emissions from extraction and refining23.

Reducing methane emissions from organics in landfill is important. More investment in community scale composting to keep organic materials out of landfill is needed. Once we have better local and regional composting systems in place we can ban organic material from landfill to make faster progress24. Austria, Germany, Finland, Norway and Sweden have done this already.

Funding is always a barrier to pursuing more ways to reduce waste at the source. To reduce emissions from production, consumption and waste, invest the Waste Levy revenue in systems and infrastructure that target the top of the waste hierarchy to prevent and reduce waste in the first place and grow the reuse economy. To ensure a just transition Government needs to invest a fair share in local, community scale solutions and SME innovators who are driving change. Currently the small community funds achieve some progress but on their own will not be sufficient to drive the change that is needed. Multisector strategy 19. Do you support the package of recommendations and actions to create a multisector strategy? Is there anything we should change, and why?

Council supports the actions and associated recommendations for the creation of a multi- sector strategy. For context, local government has a single broad legislative mandate and responsibility for implementing around 40 pieces of legislation that are sector-specific (alongside several pieces of non-sector-specific legislation and other legislative instruments).

21 https://www.unep.org/resources/report/global-waste-management-outlook 22 https://zerowaste.co.nz/reduce-waste-to-reduce-emissions/ 23 https://zerowaste.co.nz/reduce-waste-to-reduce-emissions/ 24 https://zerowaste.co.nz/reduce-waste-to-reduce-emissions/

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Climate change has or will have impacts on literally every aspect of life now or in the future. There are a wide range of portfolio Ministers and sectors with climate change interests. Ministry for the Environment is responsible for developing, coordinating and implementing ‘whole of government’ climate change policy and is well-positioned to achieve integrated climate change outcomes given it is leading significant reforms to the existing resource management frameworks. All levels of government and key sectors play supporting policy and implementation roles.

Having a single agency’s Chief Executive as the point of accountability could lead to the kind of ‘crowding out’ that the Commission identifies. The Public Service Act 2020 allows for two new types of public sector entity – interdepartmental executive boards and interdepartmental joint ventures. Each is a means for advancing a cross departmental programme but the accountability for delivery of the programme outcomes rests jointly and severally with a group of Chief Executives rather than a single Chief Executive. Council recommends that the Commission include a recommendation for the Government to establish an interdepartmental executive board with responsibility for climate change as a time-critical action. Rules for measuring progress 20. Do you agree with Budget recommendation 5? Is there anything we should change, any why?

Council supports all the actions but believes further work needs to be undertaken on accounting for exotic and native forestry, and ‘blue carbon’.

Accounting for forestry Indigenous forests are presently treated differently than exotic forests and there is an assumption that indigenous forests stop sequestering at 80 years but NIWA research shows that New Zealand forests are sequesting up to 60% more carbon than has been calculated with much of this occurring in native forests.

Exotic forest harvest has an carbon impact that is broader than just the removal of trees and their eventual replacement. International research indicates that harvest results in significant transfer of soil carbon to the atmosphere but there appears to have been little consideration of soil carbon loss in the New zealand context.

The current emissions offset accounting system is based on the research and growth rates of exotic forests, in particular pine. This does not consider the entire native forest ecosystem and the rates of sequestration. At 50 years native forests are still relatively young, and as a young forest it is will be sequestering more carbon at that age than exotic forests. More research needs to be undertaken to ensure that native forests are fairly represented in our emissions offset accounting system, rather than extrapolating data from exotic species.

Blue carbon Enabling the valuation of coastal blue carbon for carbon offsets through the NZETS or other scheme would help incentivise these types of carbon removals, with the co-benefit of providing financial support for adaptation programs.

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Appendix One – Our Context Our Community Tairāwhiti is undergoing rapid change. New residents and families are buying and building homes, business is bringing new industry and services, communities are engaged and having meaningful conversations about our bicultural heritage, and kaitiakitanga is being practised and making a difference.

Tairāwhiti has an abundance of cultural and natural assets. Our fertile soils and warm climate are the foundation for a strong agricultural and horticultural sector. Our rich bi-cultural and historical heritage and people provide a strong sense of place and foundation for growth. There is also the untapped potential of the 228,000 hectares of whenua Māori, which is 28% of the land area in Tairāwhiti.

Our region is a place where great things start. Growth in Tairāwhiti has become obvious over the past three years, increasing at a higher rate than expected. The population is now over 50,00025 and continuing to grow. This growth has put pressure on our services and infrastructure. We must react faster than expected to maintain, plan, and deliver the development infrastructure needed to support residential growth.

Over half of our population is Māori (53% percent compared to 16.5 percent for New Zealand). To realise our potential, we need to continue and further develop effective and meaningful collaboration with mana whenua to ensure iwi and hapū have a long-term role in the future planning and decision-making for the region.

Tairāwhiti has some challenges around income and rates affordability: a. Employment has grown over the last five years, but the average household income remains amongst the lowest in New Zealand. The Tairāwhiti average household income is $82,800 compared with $104,400 for all New Zealand. b. Fewer people have above average incomes - 23.6% of people in Tairāwhiti have an annual income more than $50,000, compared with 31.6% of people in New Zealand. c. Rates in most of the Gisborne urban area exceed the 5% threshold of affordability26. The eight areas where the 5% threshold is exceeded contain about 40% of all rateable units in Tairāwhiti (see Figure 3 in Our finances). While the average household income has increased in Gisborne District, it still remains below that of the other unitary councils.

25 Stats NZ 2020 estimate. https://www.stats.govt.nz/information-releases/national-population-estimates- at-30-september-2020-infoshare-tables 26 According to the 2007 Funding Report of the Local Government Rates Inquiry (also known as the Shand Report), rates affordability is more likely to be an issue when rates exceed 5% of household income

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95,000

90,000

85,000

80,000 $ per annum 75,000

70,000 2016 2017 2018 2019

Gisborne District Council Unitary Council Average

We also have a younger population than most other regions, and the over 65 age group is growing. These factors influence the ability of our community to pay more for their rates and our ability to match the level of investment more affluent councils can make. Our Council

Tairāwhiti Maranga Ake! E tīmata mai ana i konei

Tairāwhiti Rising. It all starts here.

Council is one of six unitary authorities (also referred to as unitary councils). We combine the functions, duties and powers of a territorial authority (service delivery bodies) with those of a regional council (regulatory authorities). The functions of territorial councils and regional councils are split as follows:

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Tairāwhiti 2050, our regional spatial plan from 2020, sets some goals for Tairāwhiti in 30 years’ time that reflect our community’s aspiration to build resilient and prosperous communities that thrive in a more inclusive and regenerative economy. The outcomes of “resilient communities” and “we take sustainability seriously” relate directly to climate change.

The other six outcomes relate indirectly27. We have taken these outcomes into our 2021-2031 Long Term Plan as our community outcomes that our activities are focused around for the next 10 years28.

Tairāwhiti 2050 complements Huarahi Hei Whai Oranga Tairāwhiti Economic Action Plan, which sets out short-term priorities for action29. The actions in this plan align with some of the recommendations presented in the Commission’s draft advice, for example developing a Tairāwhiti Just Transition Plan, and supporting businesses to adopt circular economy principles.

Working with local government is one of the Commission’s recommendations, we achieve more for our communities when we focus our collective energies into a coordinated response on issues our community faces. The Provincial Growth Fund (PGF) provided significant capital investment in our region and job creation. Our delivery record and the outcomes achieved under the PGF demonstrates that the Council can be a trusted and reliable partner. Our assets Council has assets of $2.3 billion. Of this, our infrastructure assets make up around $2 billion. This includes everything from waste, roads and footpaths (network infrastructure) through to libraries, pools and reserves (social infrastructure). The graph below shows how the value of Gisborne’s infrastructure assets compares to the average value of assets owned by three unitary councils, Nelson, Tasman and Marlborough.

2.3

1.8

Billion $ Billion 1.3

0.8 2016 2017 2018 2019 2020

Gisborne District Council Unitary Council Average

We are skilled at working within tight financial constraints – but it isn’t easy and comes with trade-offs. Our forecast rates revenue for the 2021 year is just under $64m. This is supplemented by central government investment (such as the National Land Transport Fund), fees and charges, and development contributions from new builds.

Over 90% of our capital expenditure is on critical infrastructure and community facilities. Based on our current Long Term Plan, this is about $35m per year on average. Over 70% of our operational expenditure (or nearly $70m a year) is needed to deliver these core services.

27 https://www.gdc.govt.nz/tairawhiti-2050/ 28 https://www.gdc.govt.nz/assets/Uploads/20-153-Long-Term-Plan-2021-2031-Strategic-Framework.pdf 29 https://trusttairawhiti.nz/news/tairawhiti-economic-action-plan-teap-refresh/

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There is no scope to drop projects or reprioritise spending in our 2021-2031 Long Term Plan (LTP) without reducing levels of service or failing to meet statutory requirements. Our finances So we can deliver these critical projects, we are planning to set our rating increase limits to 6.5% + growth and we are intending to return to our 5% + growth cap in year 4 of the 2021- 2031 LTP period30. Our actual rates increases will be close to these limits in the initial years of the LTP, and varied in the later years.

Even relatively ‘modest’ changes to forecast expenditure can have a significant impact on rates. Rating to fund $600,000 of new operating expenditure is equivalent to a 1% rates increase. For capital expenditure $8million in new expenditure is equivalent to a 1% rates increase.

According to the 2007 Funding Report of the Local Government Rates Inquiry (also known as the Shand Report), rates affordability is more likely to be an issue when rates exceed 5% of household income. Rates in most of the Gisborne urban area exceed the 5% threshold of affordability. The eight areas where the 5% threshold is exceeded contain about 40% of all rateable units in Tairāwhiti (see Figure 3 below). Rates as a percentage of median household income (by area unit)

GISBORNE AIRPORT 6.6% KAITI SOUTH 6.5% GISBORNE CENTRAL 6.4% OUTER KAITI 6.3% TE HAPARA 6.1% TE KARAKA 5.9% TAMARAU 5.4% MANGAPAPA 5.1% RIVERDALE 4.9% KAITI NORTH 4.5% WHATAUPOKO 4.4% RUATORIA 3.8% MAKARAKA 3.5% TOLAGA BAY 3.3% EAST CAPE 3.0% WAINUI 3.0% MATOKITOKI 2.9% PATUTAHI 2.9% MANUTUKE 2.8% TOKOMARU BAY 2.7% WHAREKAKA 2.5% TINIROTO 2.5% TARNDALE-RAKAUROA 2.1% – 1.0% 2.0% 3.0% 4.0% 5.0% 6.0% 7.0%

Figure 3 2018/19 median rates per area as a percentage of the median household income.

Our LTP planning is based on what we know now and our current statutory obligations so we are expecting that expenditure in later years will change as resource management reform, freshwater planning, three waters reform, and the climate change work are progressed. As affordability is already an issue for our community, we expect this to become more

30 http://gdc.govt.nz/assets/Uploads/21-0-Draft-2021-2031-Financial-Strategy.pdf

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pronounced if additional responsibilities are added to expectations of our Council by Government. Our major environmental restoration project We are delivering nature-based employment projects in partnership with iwi, conservation organisations and local agri-business. Our ‘showcase piece’ is the restoration programme at Waingake, planned to protect critical water supply infrastructure – including the pipeline that delivers drinking water to Gisborne31.

The Waingake block currently consists of around 1,100ha of commercial pine forestry and 500ha of native vegetation in various stages of regeneration and maturity. Over the next 11 years we will work with Maraetaha Inc supported by Ngai Tāmanuhiri to progressively return about 70% of the exotic forestry to native forest. Just 7% of the Tairāwhiti district is classified as native bush. The programme will ultimately result in the addition of a further 1,100 ha of secondary native forest within the region.

There are multiple and significant co-benefits associated with the programme, including nature-based employment (with a focus on training, development and employment of rangatahi from Ngai Tāmanuhiri), a reduction in pest plants and animals, ensuring stability of steep and highly erodible land, and an increase in biodiversity regionally. The regenerating forest will be contiguous with the Waingake Waterworks Bush – the largest and most significant remnant of coastal lowland forest in our region, and home to several rare and threatened flora and fauna species. The programme will create valuable additional habitat and provide a buffer of protection on the southern edges of Waingake Waterworks Bush from natural impacts such as wind damage and desiccation, to allow its long-term survival. Together these areas have the potential to be a major biodiversity asset for Tairāwhiti and a haven for taonga species.

Forecast expenditure is in the region of $1.6m a year over several years. We will receive some income as the pine forest is harvested, but some of this income has been allocated to water supply projects and we need to secure additional funding via rates (which could require rates increases) or other sources. We have applied for funding through Kaimahi for Nature. Climate change and local government Eighteen pieces of local government-related legislation have an impact on the climate change roles and responsibilities of local government. The Resource Management Act (RMA) makes the most explicit mention of local government’s climate change management responsibilities. Figure 4 below outlines the mitigation and adaptation responsibilities that are currently included in local government-related legisaltion. Figure 5 below outlines the anticipated mitigation and adaptation responsibilities that are to come in emerging local government-related legisaltion.

31 http://www.gdc.govt.nz/benefits-flow-from-waingake-revegetation-partnership-project/

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Figure 4 Existing instruments with climate change responsibilities32

32 Local Government Climate Change Collaboration. HenleyHutchings, March 2021.

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Figure 5 Emerging instruments with climate change responsibilities33

Our climate change journey Our official journey began in 2017 when our Mayor Meng Foon signed the Local Government Leaders’ Climate Declaration34.

Our drivers for our climate change journey are:

Tairāwhiti 2050 Outcomes of “resilient communities” and “we take sustainability seriously” relate directly to climate change. The other six outcomes relate indirectly. School Strike 4 Climate/Climate Emergency A student and intergenerational strike35 and petition36 to Council to declare a climate emergency. Office of the Auditor General Matters Arising from 2018-28 LTPs publication outlines expectations for transparent and comprehensive climate change discussions in the 2021-31 LTPs; including acknowledging that the implications of climate change are happening now37. Legislation Changes to Climate Change Response Act included the Zero Carbon Amendment Act (2019) and the Emissions Trading Reform Amendment Act (June 2020). Council also has direct and indirect climate change obligations under other legislation including Local Government Act and the Resource Management Act. Tairāwhiti Climate Summit 2020 Hosted by Tina Ngata and co-funded by Trust Tairāwhiti and GDC. Attendees demanded urgent action; comprehensive community involvement in developing a response and the need for mātauranga Māori to be incorporated in all responses.

In June 2019 Council approved a regional climate leadership approach to responding to climate change38. This includes adaptation, mitigation and community education. In December 2019, Council resolved that climate change is a significant issue for Tairāwhiti and that it will be considered in all council decision making39. It was also noted that the next Long Term Planning process provides an opportunity for prioritisation of climate change and corresponding allocation of resources.

33 Local Government Climate Change Collaboration. HenleyHutchings, March 2021. 34https://www.lgnz.co.nz/our-work/publications/local-government-leaders-climate-change- declaration-2017/ 35 http://www.gisborneherald.co.nz/local-news/20190928/striking-for-our-planet/ 36 https://www.gdc.govt.nz/assets/Uploads/COUNCIL-Agenda-Order-Page-19-December-2019.pdf 37 https://oag.parliament.nz/2019/ltps/docs/ltps.pdf 38 http://gdc.govt.nz/assets/Uploads/Future-Tairawhiti-Minutes-6-June-2019.pdf 39 http://gdc.govt.nz/assets/Uploads/COUNCIL-Minutes-19-December-2019.pdf

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Our Council recently completed two emissions inventories – one for the region and one for Council (including our council controlled organisation Gisborne Holdings Limited)40. This provides us with a baseline measurement to base our improvements and planning on, alongside any direction or requirements from Government.

Climate change has been identified as one of our significant infrastructure issues in our draft 2021-2031 Infrastructure Strategy, and is a key focus area in our draft 2021-2031 LTP41. We have budgeted to undertake mitigation and adaptation planning in the initial years of our LTP.

The next steps in our journey will involve:

Regional climate change mitigation

Regional emissions reduction planning (a joint Council and Trust Tairāwhiti action in the TEAP)

Council climate change mitigation

Including climate change considerations in the procurement framework (to be taken to Council for adoption)

Council emissions reduction planning

Regional climate change adaptation

Natural hazard research programme

Regional climate change risk assessment (links to national assessment)

Regional climate change adaptation planning (links to national plan which is still to be developed)

Tairāwhiti Resource Management Plan review

Council climate change adaptation

Council climate change adaptation planning

Emissions Trading Scheme

Understanding impacts of emissions trading reform on Tairāwhiti and developing options for response in line with Tairāwhiti 2050 outcomes

Building organisational capacity

Building awareness across Council teams of low-carbon decision-making processes and emissions estimation, as well how to frame and assess climate risk across a capital and operational programme.

Mātauranga Māori

Incorporating a mātauranga Māori lens to the climate change kaupapa

40 Regional inventory https://www.gdc.govt.nz/assets/Uploads/20-134-Tairawhiti-Regional-Greenhouse- Gas-Emissions-Inventory.pdf Draft Council inventory (updates being processed and final version to be published) http://www.gdc.govt.nz/assets/Uploads/20-180-Council-Greenhouse-Gas-Emissions-Inventory.pdf 41 NB changes have been made to the draft since this version. Final draft will form part of the LTP consultation in late March http://gdc.govt.nz/assets/Uploads/21-25-Draft-2021-Infrastrcture-Strategy.pdf

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