SUBMISSION Climate Change Policy Proposals This submission by Oxfam New Zealand has been prepared in response to the five government position papers on climate change: • Measures to Reduce Greenhouse Gas Emissions in New Zealand Post-2012 (Ministry for the Environment) • Transitional Measures to Reduce New Zealand Greenhouse Gas Emissions Prior to 2012 (Ministry of Economic Development) • Draft New Zealand Energy Strategy to 2050 (Ministry of Economic Development) • Draft New Zealand Energy Efficiency and Conservation Strategy (Energy Efficiency and Conservation Authority) • Sustainable Land Management and Climate Change (Ministry of Agriculture & Forestry) Contact Oxfam New Zealand Attn: Barry Coates, Executive Director 62 Aitken Terrace, Kingsland Auckland 1145 Tel: (9) 355-6500 www.oxfam.org.nz Oxfam New Zealand Submission: Climate Change (30 March 2007) 1 I. Recommendations Oxfam New Zealand is a non-profit development organisation with programme activities concentrated in the Pacific and East Asia. We are principally concerned with assisting poor and vulnerable people in developing countries to mitigate and adapt to climate change (see Conclusion). We welcome this opportunity to comment on the set of five climate change policy proposals released for public consultation in December 2006. This submission is our first in-depth policy statement on climate change. Oxfam New Zealand is working closely with the other affiliates of Oxfam International, who have collectively identified climate change as one of the strategic priorities for the forthcoming five years. In New Zealand, Oxfam joined the Climate Defence Network (www.climatedefence.org.nz) in August 2006 and is seeking to build links with other organizations and scientific institutes. Oxfam New Zealand welcomes this initiative to develop coherent climate change policy, but is concerned that the five policy documents do not establish an overarching framework for how to address the significant and pressing challenges posed by climate change. The policies lack bold, achievable and measurable targets for action with staged milestones. There are also major omissions with respect to our international obligations under Kyoto and our ethical commitment to assist developing countries to adapt and mitigate against climate change. Oxfam New Zealand believes the government should: • Establish an overarching framework for climate change policy with bold, achievable and measurable targets for action including staged milestones; • Institute a carbon pricing system without delay. • Preserve and expand existing sinks, both land and sea, and engage in off-setting; • Initiate a range of measures to reduce emissions and to reduce demand for private road transport and non-renewable energy; • Address aviation emissions and demonstrate that goods produced domestically for export meet the highest environmental standards possible; • Push for strong, universal emissions reduction targets in international negotiations; • Commit funding, additional to the existing aid budget, and political support to a far larger global Adaptation Fund; • Mainstream climate change assessments into New Zealand’s development assistance programmes and advocate for international financial institutions and others to also undertake climate change mainstreaming; • Ensure that ethical dimensions of climate change, including both international and inter-generational equity, underlie New Zealand’s climate change policy framework. Oxfam New Zealand Submission: Climate Change (30 March 2007) 2 II. Policy Comments 1. Oxfam New Zealand is concerned that New Zealand still does not have a set of policies to address climate change despite being a member of the 1997 Kyoto Protocol with a firm target to reduce our carbon emissions to what they were in 1990. Disappointingly little of the government’s 2002 policy package on climate change has been implemented. In 1999, New Zealand’s carbon emissions were caused primarily by the agriculture (49%) and energy (42%) sectors. The transport sector is however the fastest growing source of emissions. 2. Strong political leadership on climate change is needed if we are to achieve a truly sustainable economy. We welcome Prime Minister Helen Clark’s recent calls for New Zealand to aspire to be carbon neutral and the initiative to move the public service towards carbon neutrality. Such statements should not, however, obscure the fundamental need to set and meet emissions reductions targets. 3. New Zealand’s climate change policy requires bold, achievable and measurable objectives and targets. We need absolute and measurable targets to reduce greenhouse gas emissions, to increase energy efficiency, to shift transport modes, and for conversion to renewable energy. For instance, the overall transport goal proposes a resilient, low carbon transport system yet neither ‘resilient’ nor ‘low carbon’ is defined and the measures proposed are inadequate to meet this goal. 4. New Zealand urgently needs a robust cap on its greenhouse gas emissions including a comprehensive pricing system that ultimately covers all sectors. We must put a price on carbon. 5. The allocation of emissions permits must be carefully considered. Mechanisms for permit distribution are key considerations in developing an equitable system. We are concerned that “grand-parenting” could provide substantial windfall gains to polluters. Permits should not be issued in perpetuity. Much could be learned from New Zealand’s experience implementing the fisheries quota system. 6. Other options not covered by the policy proposals include auctions and a tradable permits scheme based upon individually allocated emissions entitlements. Both have their merits and should be considered. Permit auctioning gives the revenue to government, which can then be smartly recycled to achieve further emissions reductions and ensure equitable outcomes. 7. Priority should be given to preserving and expanding existing carbon sinks. The retention of existing sinks in marine areas, fisheries, wetlands, and soil are absent from the policy proposals. Greater emphasis should be placed on improving carbon storage in existing indigenous forests. 8. Measures to offset our carbon emissions are important and necessary, but second in priority to establishing a cap. Offsetting alters the short-term carbon cycle and could be used as a justification for continuing to add long-term carbon into this cycle. In planting new forests, for example, the policy proposals must consider the biodiversity implications and ecological impacts of offsetting with radiata pine or other non-natives. Oxfam New Zealand Submission: Climate Change (30 March 2007) 3 9. Throughout the policy proposals too much focus is placed on the kind of power generation or transport needed (supply side) as opposed to reducing emissions and significantly reducing demand for motorized transport and for new energy generation. For example, by emphasizing fuel efficiencies and biofuels, the proposed transportation policy does little to encourage alternatives to private road transport and doesn't address the imperative to reduce the need for individualised motorised travel. A broader overview of the importance of sound urban planning is missing. There is a need for greater public education campaigns to create informed consumers. 10. The rapidly emerging demand for biofuels represents a significant opportunity for many developing countries, yet there are many drawbacks. Indonesia and Malaysia are experiencing severe deforestation brought about in part by the creation of massive oil palm plantations that has resulted in massive loss of biodiversity and numerous cases of abuse of customary land rights, displacement and violent conflict. In Brazil, soy production has displaced smallholder farmers and indigenous peoples and is currently held to be responsible for more destruction of the Amazon than either logging or ranching. New Zealand should carefully consider these and other issues in the importation and use of biofuels. A holistic understanding of the biodiversity and other impacts is essential in the development of a domestic biofuel industry. 11. The transportation section of the policy proposals includes some useful principles, but carbon emissions from aviation are conspicuously absent. While these are not included in the Kyoto Protocol, aviation emissions are significant and should be considered not least because their growth has the potential to swamp carbon reductions in other areas. 12. New Zealand cannot afford to sidetrack aviation issues. Our economy is heavily dependent upon sending produce long distance as well as revenue from international tourism. Internationally, major buyers of NZ products are beginning to initiate full carbon accounting on both distance travel and the production system. The calculation of these food miles could potentially discriminate unfairly against long distance trade. As a leader in global trade talks our actions will be closely watched. Our actions and stance on aviation emissions could assist developing countries facing similar constraints on their exports. As a proponent of free trade, we have a responsibility to develop climate- friendly trade for a world of carbon conscious consumers. 13. We must consider our own carbon footprint as well as our greenhouse gas footprint from aviation and other emissions. For example, New Zealand dairy products may have a low carbon footprint if shipped by sea and not air, but our greenhouse gas emissions could be high if methane is factored