All That Summer

All that summer we sailed the drowned isthmus,
Miramar Island bulking east. Diving
was an anxious wait for murk-filled water

to yield its occasional treasures, relics of better days
left behind as the frantic dikes were overwhelmed.
Out by the drowned airport runway,

the never-finished extension lost beneath us, we faced
long rollers carrying Antarctic meltwater northward,
braved the sudden southern chop and squall

to plumb abandoned warehouses, corroding cars.
So many days we returned empty-handed
to the boatshed on the Wadestown shore,

worked the elaborate locks with reddened fingers,
climbed the hill to short commons and mixed
parental signals of frustration and concern.

It was a life lived in increments of bad news, a
Government of bluster and paralysis, its authority
manifested in chain-link fences and pronouncements

no longer listened to on matters that concerned
only those sited most securely inland. At the water’s edge
the social contract washed away, replaced

by alliances more fickle than the weather.
And the sea still rose, icecaps converted to ocean
by generations of accumulated arrogance.

That was all before our time. What we knew
was the rising wind, swoop of storm,
slack and snap of sails, one of us waiting aboard,

the other diving the ruins of lives lived
in those final glittering years of denial
before the ocean washed all doubts away.

– Tim Jones



He waka eke noa – We are all in this together.

The New Zealand Government has declared a Climate Emergency. The seriousness and ambition of the Climate Change Commission’s advice to the Government should reflect that – now is not the time for half-measures. Yet the draft targets and timelines are patently inadequate in the face of the ever-growing climate catastrophe.

To meet the challenge of climate change, it is essential that Aotearoa plays its part, both domestically and internationally, and serves as an example to other nations. Our team of five million responded well, acting communally, on scientific advice, to keep ourselves safe from COVID-19. Now we need to do it again, to help save the world from an even greater threat.

The majority of people in Aotearoa realise the urgency of climate action and want the Government to act now, in strength and justice. The Government must publicise and follow the science, so that all parts of society can make a planned and just transition.

It is essential to our survival as a civilisation, that we do everything we can to reduce greenhouse gas emissions, particularly carbon dioxide, methane, and nitrous oxide.

We need to focus on redefining economic growth and reducing consumerism. An energy descent is still possible.

As with COVID-19, people will respond to clearly expressed policies required to meet climate targets. We need to step up, as we have made too little effort to date. As a developed nation, Aotearoa has the capacity and the means to do this, compared to other countries, many of which look to us for an example.

If we do not act decisively now, it will be much harder in the future. We are already seeing the disastrous consequences of inaction for the global poor, who have contributed minimally to global warming. Ecosystem collapse is already occurring, as temperatures increase and the forests and oceans edge towards becoming carbon sources, rather than sinks.

Above all, we have a responsibility to future generations; not only to humans, but to every other living species which cannot speak for itself. This is a moral and ethical commitment.

About Coal Action Network Aotearoa

Coal Action Network Aotearoa (CANA) is a group of climate justice campaigners committed to ending coal mining and use in Aotearoa New Zealand. Formed in 2007, we recognise the mining and burning of coal as the primary threat to Earth’s climate system. CANA promotes climate justice by advocating and acting for a just transition to an Aotearoa free of coal mining and use. We work with local communities threatened by new coal mines and coal projects, and with allies across the climate justice and environmental movements. We are a member of the New Zealand Climate Action Network. Our target date for coal mining and use in Aotearoa to end is 2027.

Successful campaigns we’ve been involved in include:

  • Helping to end Solid Energy’s plans to mine and burn massive quantities of Southland lignite
  • Getting Fonterra to commit to, and then bring forward, an end date for installing new coal boilers
  • Bringing Fonterra’s use of coal to the attention of the country
  • Encouraging the New Zealand Government to set up a Just Transition Unit to help resource communities depend on fossil fuel extraction to transition to low-carbon jobs
  • Opposing the expansion of Bathurst Resources’ Coalgate mine in Canterbury – this mine is now being closed down
  • As part of the Fossil Fuel State Sector coalition, getting the Government to commit to replacing coal boilers in schools with renewable alternatives.


We have been involved in legal action, direct action, and lobbying to achieve these goals. Our members and supporters are members of local communities with experience of the negative effects of coal mining and use, climate activists, and scientists. We work with communities around the motu, other activist groups, and central and local Government to achieve our aims.

In writing this submission, we acknowledge the work done by the Climate Change Commission to produce its draft advice in difficult conditions and under time pressure, and likewise, the work of many individuals, groups, and journalists in analysing the report and producing submission guides. CANA contributed to this cross-groups submission guide, and we want to acknowledge the work put in by all the groups that contributed to that document.

We also endorse the submission of OraTaiao, with its focus on the health and wellbeing co-benefits of climate action and the centrality of Te Tiriti.


 1.  Urgent and Effective Action to Reduce GHG Emissions is Required

 Whilst the Commission’s draft advice is a welcome change from decades of Government obfuscation and reluctance to address the existential threat of climate change, the Commission’s clear systemic bias towards Business as Usual (BAU) has blinded it to actions that need to be taken. The advice reads like “happy talk”, in that the Commission:

  • supports the political and economic status quo, e.g. in the treatment of methane and electricity generation;
  • irrationally assumes there will be enough time for incremental policies to solve super-wicked problems, and,
  • despite decades of egregious failure, does not question whether our post-WW2 economic and political structures are up to the task. As per the previous link,

“…the responsibility for global warming is not the common property of humanity but lies overwhelmingly with the few wealthy countries, the United States above all others, that profited most from early industrialization.

 The corollary truism is that the poor countries that disproportionately suffer the impacts of climate change contributed next to nothing to the problem. We have since learned that what is true in global macrocosm applies at the societal level as well. The wealthy consume far more resources and emit far more carbon than the rest of us.

 According to a recent Oxfam report, the richest one percent produce twice as many emissions than the poorest half of the planet’s population, and the richest 5 percent were responsible for more than a third of all emissions growth between 1990 and 2015. Leveling this gross inequity is a question of survival.”

Furthermore, we are, frankly, astounded that the draft never mentions rapidly approaching biophysical hard deadlines such as the multiple “tipping points” (aka planetary boundaries) that our civilisation is transgressing.

These include the melting ice of West Antarctica and Greenland, forests becoming net carbon sources instead of sinks, and the warming Arctic permafrost and shallow seas that are emitting ever-increasing amounts of methane.

These trends, coupled with the latest CMIP6 climate modeling that show a higher climate sensitivity than previously thought, suggest that we do not have more than one or two decades before our emission budgets are overwhelmed by feedbacks in the Earth system and atmospheric and ocean temperatures spike uncontrollably. We know this has caused mass extinction events in the past, e.g. the PETM.

As stated in a recent scientific review, “Underestimating the Challenges of Avoiding a Ghastly Future” (emphasis added):

We report three major and confronting environmental issues that have received little attention and require urgent action.

 First, we review the evidence that future environmental conditions will be far more dangerous than currently believed. The scale of the threats to the biosphere and all its lifeforms—including humanity—is in fact so great that it is difficult to grasp for even well-informed experts.

 Second, we ask what political or economic system, or leadership, is prepared to handle the predicted disasters, or even capable of such action.

 Third, this dire situation places an extraordinary responsibility on scientists to speak out candidly and accurately when engaging with government, business, and the public. We especially draw attention to the lack of appreciation of the enormous challenges to creating a sustainable future. The added stresses to human health, wealth, and well-being will perversely diminish our political capacity to mitigate the erosion of ecosystem services on which society depends.

 The science underlying these issues is strong, but awareness is weak. Without fully appreciating and broadcasting the scale of the problems and the enormity of the solutions required, society will fail to achieve even modest sustainability goals.

 …most of the world’s economies are predicated on the political idea that meaningful counteraction now is too costly to be politically palatable. 

 The gravity of the situation requires fundamental changes to global capitalism, education, and equality, which include inter alia the abolition of perpetual economic growth, properly pricing externalities, a rapid exit from fossil-fuel use, strict regulation of markets and property acquisition, reigning in corporate lobbying, and the empowerment of women. These choices will necessarily entail difficult conversations about population growth and the necessity of dwindling but more equitable standards of living.

We repeat, this is not climate “alarmism”, but cold, hard fact. To have some hope of maintaining a reasonably habitable planet for ourselves and other living species, we need to take actual and urgent action, to bend the emissions curve. The CCC’s draft recommendations to the NZ Government, if implemented, would be a step forward from our very feeble response to climate change so far, but we do not consider them to be nearly strong enough. We have proposed a number of changes to the Commission’s advice to strengthen its policy recommendations. As the draft report says, to the extent that is possible, we need to address this problem in a way that is fair to people and protects their living conditions and livelihoods.

2.  End Coal Mining and Use in Aotearoa

In light of the above, Coal Action Network Aotearoa is calling for an end to coal mining and use in Aotearoa by 2027, including a ban on both coal imports and exports.

NB: In this, we can cite the support of the Secretary-General of the United Nations, who recently said:

“Phasing out coal from the electricity sector is the single most important step to get in line with the 1.5 degree goal.”

Mr. Guterres underlined action in three areas to end what he called “the deadly addiction to coal.” 

He called for countries to cancel all coal projects in the pipeline, particularly the 37 members of the Organisation for Economic Co-operation and Development (OECD) who are urged to do so by 2030. 

The UN chief also appealed for ending international financing for coal and providing greater support to developing countries transitioning to renewable energy. 

 “I also ask all multilateral and public banks — as well as investors in commercial banks or pension funds — to shift their investments now in the new economy of renewable energy”, he added.

Specifically, CANA Requests that the Commission:

  • Advise the Government to immediately ban new and expanded coal mines, including but not limited to a ban on mining coal on conservation land
  • Set an end date of 2025 for all coal mining in Aotearoa – including coal for export
  • Set an end date of no later than 2027 for the import of coal into Aotearoa
  • End the free allocation of ETS credits to coal and other fossil fuel users, starting with an immediate end to free allocation of credits to large industrial users of coal


It is vital that the transition from the use of coal is to renewables, not other fossil fuels, and in particular, that it is not to natural gas, given that fugitive emissions mean the extraction and use of natural gas are almost as bad for the climate as burning coal.

The transition must be urgent, but it must also be just. We discuss this later in our response.

In 2019, about 2.68 million tonnes of coal was mined in Aotearoa, leading to well over 5 million tonnes of carbon dioxide being released into the atmosphere. Additionally, in 2020, 1.1 million tonnes of coal were imported into Aotearoa.

In 2021 it is, frankly, a disgrace that a country with the wealth of renewable energy resources New Zealand possesses is still so dependent on coal. The good news is that alternatives are either available now, or rapidly becoming available. The rise of large-scale electricity storage means we don’t need to keep relying on coal or gas to back up renewable energy generation.

Coal boilers are being phased out at all levels: in 2019, Fonterra made a commitment to build no new coal boilers, while the Government has committed to a carbon-neutral public sector by 2025 and is rapidly moving to get coal out of school and hospitals.

But public-sector coal use represents a small fraction of New Zealand’s emissions from burning coal. It’s time to go much wider, and the climate emergency demands that we act much more urgently to phase out coal than the Commission projects. Many overseas jurisdictions have either ended the use of coal or announced target dates to do so within the next few years. New Zealand should not be dragging the chain.

The Commission has said that the use of coal needs to end (Advice report, p.15) – yet also projected coal use continuing at above 10 PJ/yr right up to 2050 (Advice report, Figure 5.4, p. 91). It’s time for the Commission to end the ambiguity and recommend to Government a firm phase-out date for coal.

3.  Low Hanging Fruit – Process Heat in the Dairy Industry

We will focus our submission here on Fonterra, as the country’s biggest user of coal for process heat.

Fonterra has stated that it will not build any new coal boilers, bringing that date forward from 2030. This may seem like progress, but our understanding is that political and other constraints mean that NZ has reached “peak cow” and Fonterra has, in fact, no need to build any more boilers.

Fonterra recently stated that it will reduce emissions by 30% by 2030, and the Climate Commission draft states that Fonterra should be allowed to continue to use coal for process heat until 2037. As noted above, CANA’s target date for coal mining and use in Aotearoa to end is 2027. Continued use of coal for process heat until 2037, by Fonterra or any other company or industry, is unacceptable.

The Commission’s Process Heat evidence (Chapter 4a: Reducing emissions – opportunities and challenges across sectors Heat, Industry and Power) states:

At current carbon prices, the operating costs of low emissions fuels are generally considered more expensive than fossil fuels.

The Commission should recommend a carbon price high enough to reverse this absurd – and unhealthy – price gap.

The Commission also refers to “current business models” that limit a company’s ability to convert to other forms of energy such as biomass.

The Commission rightfully states that New Zealand doesn’t have a huge amount of expertise in large biomass plants, and availability.  This is indeed true.  The downside of this is that a few so-called “experts” who have little international experience, nor willingness to understand, for example, the experience in Europe, are advising companies like Fonterra that there is no availability of biomass for new boilers.

We need to draw on overseas expertise. Europe is far ahead of New Zealand in this issue and biomass plants, using all kinds of sources, are common there.

4.  Carbon Border Adjustment Mechanisms 

Another issue the Climate Change Commission omits to mention are Carbon Border Adjustment Mechanisms, and how that sits with our current Eligible Industrial Activities (EIA) allocations of NZU to big emitters, who argue they need a level playing field internationally, so shouldn’t have to pay a carbon price for their use of coal.

Over the nine years 2010-2019, for example, Fonterra was allocated 333,489 free units. It wasn’t our biggest recipient, by any means, but is an example of how this country does not provide any disincentives for coal users, and is therefore propping up a dirty industry.

While the recipients of these free allocations have previously relied on the argument that they would be at a competitive disadvantage internationally if they had to pay for their emissions, the situation is rapidly changing. The European Union is actively considering imposing Carbon Border Adjustment Mechanisms (e.g carbon taxes or tariffs) on any goods entering the region that haven’t had to pay for their emissions at source.  China is also putting Emissions Trading Schemes in place in some regions, and is likely to take these nationwide in the near future.  The US, UK and the G7 are likely to follow suit.

Thus, while the Zero Carbon Act does reduce EIA allocations gradually through to 2050, exporters such as Fonterra are likely find themselves facing growing border costs.

This is another reason to remove these allocations sooner rather than later, so that exporters such as Fonterra are forced to switch from coal.

In our view, free allocations of credits to large industrial users of coal and other fossil fuels should cease immediately.

5.  Fossil Free State Sector

The Government’s announcement, as part of its Climate Emergency declaration, that it was committed to becoming a carbon-neutral Government by 2025 was welcome. However, while some sectors (such as education) are now making progress in actual emissions reductions by removing coal boilers from schools, there are still many Government departments and agencies that have not yet focused on what they will need to do to reduce their emissions.

As a result, there is a considerable risk that offsetting, rather than actual emissions reductions will be the main method used to meet this target.

Therefore, CANA wants the Commission to advise the Government that it should place a high priority on reducing actual emissions to zero from the state and public sector by 2025.

6. The Cost of Climate Change

The CCC’s estimates of the costs of action (GDP) vs BAU show that acting on climate change will cost little more than BAU GDP projections. Due to the fact that there are no complete studies of the costs of climate change impacts to the country, the CCC simply left out the whole subject.

This is, in our view, raises a major communications issue. For years, consecutive governments have successfully argued that acting on climate change would cost too much, especially the Key government. In 2015, then Climate Change Minister, Tim Groser, argued the cost of meeting our target would cost New Zealanders $30 billion. He claimed that a stronger target would cost the country too much, but the opposite is true, as the following articles attest:

Treasury 2018 estimate of the rising cost of climate change is also sobering:

..we estimate that flood and drought costs attributable to anthropogenic influence on climate are currently somewhere in the vicinity of $120M per decade for insured damages from floods, and $720M for economic losses associated with droughts.

Because no NZ-based peer-reviewed papers yet exist investigating the FAR associated with storm damage, hailstorms, wildfire, frosts or tornadoes, we have left these out from the analysis. Our neglect of such events means we ignore at least NZ$279M in weather-related losses between July 2007 and June 2017. As an indicative comparison, if the FARs associated with these events were similar to those in the table – around 0.3 – then the extra attributable losses would add another $84M.

Our first estimate is that climate change attributable extreme rainfall-related floods have cost New Zealand around $120M in climate change attributable privately insured damages over that ten year period. Our second estimate is that climate change-attributable economic losses associated with droughts have cost New Zealand around $720M over that ten year period. These estimates are necessarily approximate and incomplete. Nevertheless, they provide ball-park estimates of current climate change-attributable costs, and the methodology could be extended to examine a wider range of hydrometeorological and other impacts, potentially forming one important element of a future more comprehensive understanding of climate risks in New Zealand.

 In the Evidence chapter 12.2.1, the Commission’s draft states:

Under current policy settings, GDP is projected to grow to $512 billion by 2050. This is likely to be an overestimate as this does not factor in the negative climate and trade impacts of not acting on climate change.

It further states:

Any analysis of the impact on GDP only provides a narrow picture of the impacts of reducing emissions. It does not reveal the indirect costs and benefits, nor who the costs and benefits fall on. The cost of not acting on climate change and the co-benefits of actions to reduce emissions, such as to health, the environment and productivity from increased innovation, are significant and provide even more reason for a country to act on climate change.

The rising costs of climate impacts

While we accept there is no New Zealand-wide study on the subject, some preliminary work has already been undertaken. However, the two statements above are buried in Chapter 12 of the Evidence report, and not well communicated to the wider population.

Frame et al, 2018, did address this issue. They looked at the costs of floods and droughts over the course of a ten-year period, finding:

…we estimate that flood and drought costs attributable to anthropogenic influence on climate are currently somewhere in the vicinity of $120M per decade for insured damages from floods, and $720M for economic losses associated with droughts.

Because no NZ-based peer-reviewed papers yet exist investigating the FAR associated with storm damage, hailstorms, wildfire, frosts or tornadoes, we have left these out from the analysis. 

Our neglect of such events means we ignore at least NZ$279M in weather-related losses between July 2007 and June 2017. As an indicative comparison, if the FARs associated with these events were similar to those in the table – around 0.3 – then the extra attributable losses would add another $84M.

Nevertheless, they provide ball-park estimates of current climate change-attributable costs, and the methodology could be extended to examine a wider range of hydrometeorological and other impacts, potentially forming one important element of a future more comprehensive understanding of climate risks in New Zealand.

Moreover, New Zealand has more than $20 billion worth of assets vulnerable to sea-level rise, another factor ignored by the Climate Change Commission in this draft.

While we accept there is no currently agree method of modeling these costs, that should not be a reason for the CCC to just go with a projected BAU GDP, and thus conveying the same kind of misleading communications to the New Zealand public in this report that we have seen over the past 30 years.

In summary: This flawed strategy has focussed attention on the cost of action, conveniently leaving out the very important issue of the costs of inaction, thus skewing the debate.

While Chapter 12 of the expert evidence does include two small paragraphs, this is wholly inadequate to the importance of the issue. It should have been front and centre in the Advice Report.  There is no mention at all of such costs, even generally, in the Executive Summary of the CCC’s advice to the government, therefore the country and our media will all be focussing on the costs of transition to a low-carbon economy.  What are the benefits of avoiding dangerous climate change?  What are the costs of continuing the way we’re going, and the impacts of a >3C world? These are indeed big issues, but to avoid discussing this aspect altogether is both disingenuous and dangerous.

The NZ Insurance Council’s data on the costs of extreme weather events bring this into focus. Last year the Napier floods alone cost $73m. The Ohau fire cost $35m.  How many coastal properties or properties on floodplains are going to lose their ability to get insurance?

By omitting this discussion altogether from its advice and the public conversation, the Climate Change Commission is not providing the New Zealand public with reasons to take actionInstead, we are left with conversations about the Government preparing to take away someone’s gas barbecue, never mind the fact that the home containing that barbecue may well be destroyed by the warming of 3-4C that currently awaits us!7.  Emission Budgets

Re the CCC draft advice Big Issues Question 1, Do you agree that the emissions budgets we have proposed would put Aotearoa on course to meet the 2050 emissions targets?

Coal Action Network Aotearoa strongly disagrees. The emissions budgets are not ambitious nor set to be achieved quickly enough. The Intergovernmental Panel on Climate Change’s 1.5-degree report outlines that for a 66% chance of averting climate catastrophe, we must begin emissions reductions with deep cuts, starting immediately. The Commission’s proposed approach is clearly not ambitious enough and risks passing many tipping points, which would put us on a hothouse earth trajectory.

The proposed emissions budgets must take into account the commitment to global equity and New Zealand’s obligations as a developed nation that are noted in the NDC section of the report. The legislation describes the purpose of emissions budgets to be for meeting the 2050 target AND New Zealand contributing to global efforts for 1.5 degrees (section 5W).

There are various policy areas where greater action can be taken in the next decade to enhance the first two budgets for greater consistency with IPCC’s 2030 pathways for 1.5 degrees while also meeting the 2050 target.

Re Big Issues Question 5, What are the most urgent policy interventions needed to help meet our emissions budgets? (Select all that apply)

Action to address barriers – Pricing to influence investments and choices – Investment to spur innovation and system transformation – None of them

All of these are urgent, and, to quit coal, all of the first three are required.

Coal and other fossil fuels can be burnt far too cheaply. The low price range in the ETS and, even worse, the massive allocation of free credits to major polluters – which renders the ETS unjust and ineffective, and gives vested interests an unearned financial advantage over renewable energy industries – render it an almost completely ineffective tool for influencing investments and choices.

CANA requests the Commission recommend to Government that:

  • The floor price for ETS credits be sharply increased, and
  • The allocation of free credits be ended immediately


High-temperature processes that use coal are a crucial area where investment to spur innovation and system transformation are needed. The Advice report, Fig 5.4, p. 91, projects that coal use will continue at above 10 PJ/year right up to – and possible beyond – 2050. From discussions with Commission staff, we understand that this demand is for steel and cement production.

If steel and cement production is to continue in Aotearoa, both must transition rapidly away from coal consumption.

NB: Research & development in carbon-free steel is already accelerating overseas, notably in Europe and Australia, and New Zealand Steel should be put on notice that a similar transition is urgently needed here.

Re Big Issues Question 6, Do you think our proposed emissions budgets and path to 2035 are both ambitious and achievable considering the potential for future behaviour and technology changes in the next 15 years?

Strongly disagree

In our view, the Commission’s recommendations lack ambition.

Given that we were all led to understand, by Climate Change Minister James Shaw, that the Climate Change Commission would provide advice on a 1.5C compatible 2030 target, we are puzzled as to why the CCC did not provide such a recommendation, only stating it should be “much more than 35%”.  This is another communications failure.

By only stating “much more than” and not giving any number above 35%, it is logical that the public understanding (and indeed we have already heard this from the media) is that the target should be 35%, not the “much more than” as set out in the recommendations by the CCC.  Moreover, the emissions budgets don’t even meet our weak 2030 target.

This is a failure of monumental proportions, exacerbated by the aforementioned failure to communicate to the public – and to Government – the cost of inaction, the cost to Aotearoa of a >3C world.  

Leaving aside the obfuscatory and unacceptable gross:net accounting of our plantation forest sinks (and its new “averaging” iteration), New Zealand’s emissions in 2030 will be around 67 MtCO2eq/year (excluding LULUCF). To be compatible with the Paris Agreement, those emissions should be at 41 MtCO2eq/year: a 50% reduction by 2030 levels excluding LULUCF.

NB: This is just for our domestic emissions pathway: taking into account our privileged position in the developed world, and “fair share” equity contribution to global emissions reductions, this should be even less.  (Here we agree wholeheartedly with the submission by Lawyers for Climate Action).

The problem is, the emissions budgets provided by the CCC are based on what the industry has said it can do, not on what must be done. The CCC has failed to do its job. Its budgets do not even meet the 2030 target.

To truly meet the scale of the climate emergency, and to play our part in giving the world a chance to stave off the worst effects of climate change, we need to carry out the bulk of the needed emissions reductions by 2030. Although not easy, decarbonising heat, industry, and power is comparatively straightforward compared to the challenges faced in decarbonising sectors such as transport and agriculture.

Therefore, we need to press ahead quickly, end the use of coal in this sector by 2027, and ensure a transition to renewable energy use.

8.  Te Tiriti

Re Detailed Question 7, Do you support enabling recommendation 3 on creating a genuine, active and enduring partnership with iwi/Māori? Is there anything we should change and why?

We agree that this partnership is critical, but the Commission’s focus on “the principles of the Treaty of Waitangi” rather than the wording of Te Tiriti risks weakening this focus and imperilling this partnership.

The Commission should undertake a thorough Te Tiriti analysis of its proposals and include recommendations on how Crown policy can give effect to Te Tiriti in achieving emissions targets.

Without prejudicing the outcome of such an analysis, we envisage this could include a national-level partnership mechanism with Māori as well as measures to enable iwi, hapū, and whānau to exercise their rangatiratanga and kaitiaki role in respect of taonga within their rohe.

9.  Overall Path

Re Detailed Question 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?

CANA do not support this pathway, because it is insufficiently ambitious, particularly with respect to methane. We call for the Commission to recommend large cuts to methane and nitrous oxide emissions from agriculture, through destocking and by imposing limits on the import of synthetic nitrogen fertiliser and PKE.

The IPCC report estimates that 30 – 40% of current global warming comes from humanity’s methane emissions, as shown below:


“Controlling methane emissions is an effective way to slow global warming. Because methane is very effective at trapping heat and has a relatively short lifetime of about a decade before it oxidizes to carbon dioxide, controlling its emissions is an effective way of reducing the heat trapped in the atmosphere now. It thus is very influential in determining how rapidly the planet warms.”

To our dismay, the draft submission barely mentions this fact, preferring strained and specious arguments centred on the short lifetime of methane in the atmosphere (10-20 years). Unfortunately for all of us, the Global Warming Potential of methane over 20 years is about 85 times that of carbon dioxide, and that heat remains in the atmosphere and ocean long after the methane molecules have decomposed into carbon dioxide and water.

The full impact, going forward, of this uncomfortable truth is left to the last page of the Commission’s draft advice, where we find the following graph:

To reiterate, whilst a particular molecule of CH4 decomposes relatively quickly to CO2 and H2O, most of the heat it has trapped in the atmosphere is absorbed by the oceans, causing the sea level to rise (SLR).

Ocean warming causes SLR through both ocean thermal expansion and the melting of the underside of floating ice shelves in the polar regions, which then destabilizes adjacent land-based ice sheets.

To our surprise, the Commission’s draft advice seems oblivious of these critical processes, despite much of the research having been carried out by their own colleagues!

The historical impact of methane-induced warming is shown in the graph on p.76 of the Commission’s draft advice, where we can easily see that the cumulative warming caused by methane is more than that of the next two gases combined.

10.  A Just Transition  

Re Consultation Question 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?

We are pleased to see that the Commission acknowledges the need for an equitable transition to a low-carbon economy. CANA has been a leader in this field, specifically in terms of the need for a just transition to low-carbon jobs for New Zealand coal miners and coal mining communities.

Our 2015 report Jobs After Coal: A Just Transition for New Zealand Communities helped contribute to the Labour Party’s Future of Work project and has contributed to the New Zealand Council of Trade Unions’ thinking on just transitions – see for example NZCTU, Just Transition – A Working People’s Response to Climate Change (2017), p. 16.

Jobs After Coal argues that:

  • the role of coal in New Zealand’s economy is small
  • there are many options for jobs in the industries that will replace coal
  • skills of coal miners are transferable to other industries, and
  • communities can reinvent themselves to regain a new prosperity after coal.


These positive outcomes depend on recognising the need for a proper and effective transition path and setting up a planned process within the community itself, including all stakeholders, with support from central and local government. One of the recommendations in Jobs After Coal was that the Government set up a unit within MBIE to help manage the transition to low-carbon jobs. This Just Transitions Unit has now been set up, but has focused on oil and gas so far – CANA wants  the Commission to recommend to Government that MBIE widen its focus to coal-mining communities and regions.

CANA views trade unions as important partners in the just transition process, together with iwi, local authorities and business in affected areas. The words “trade union”, however, do not appear at all in the Commission’s advice. Therefore, we want the Commission to acknowledge the central role that New Zealand trade unions and workers will play in the transition from fossil fuels.

11.  Electricity generation

 Distributed electricity generation is viewed positively in the Evidence section of the draft:

Distributed generation refers to a variety of technologies that generate electricity at or near where it will be used, such as solar panels. About 95% of distributed generation is from renewable sources such as wind, geothermal and hydro, and ‘behind the meter’ generation such as rooftop solar.

 These forms of decentralised generation play a role in reducing the amount of electricity that would otherwise have to be transmitted by the grid. This is particularly valuable when it can offset periods of peak demand, and potentially emissions and high electricity prices, and when the grid is limited in some way (for example if a line fails during a storm). The amount of distributed generation in the system is expected to increase as the cost of solar PV and wind generation decreases and more households and communities look for energy sovereignty.

 Community involvement in distributed generation may have social benefits, such as enhanced cohesion, acceptance of development (when there is control over where the generation is located) and self-sufficiency through self-supply. It can also adapt and affect consumer behaviour and energy use.

 For example, iwi/Māori through local marae schemes and rural communities may actively transition to distributed generation for a variety of reasons, including ownership, cost and resilience (particularly if they are in remote areas) and a desire to reduce their emissions.

 In Aotearoa, it can be challenging for owners or would-be investors in distributed generation to access the electricity market. Owners of distributed generation can either sell any generation not used on site to a retailer through a contract or sell it into the market and ‘take’ the wholesale price. It can be difficult to secure the long-term contracts. A liquid hedge market would be important in facilitating this. 

 Given this, it is surprising that the Advice section makes no mention of household rooftop solar, which is subsidised as a public good in other many countries.

Instead, the draft advice prefers wind power, as seen in the graphs on p. 62, and, in the absence of government support, any growth in solar generation seems likely to come from corporate solar farms, rather than small household and community installations. This is clearly anti-competitive.

Commenting on a recent article on renewable power generation in NZ, respected economics professor Geoff Bertram has the following to say about the institutional impediments to such smaller initiatives (emphasis added):

“Tweaking the market settings” won’t really cut it. Clearing the way for distributed solar to get quickly underway requires breaking the united opposition of the big generators and their wholly-owned subsidiary the Electricity Authority, who are still pressing ahead to get increased fixed charges imposed on household consumers as a means of making rooftop solar uneconomic (the very low buy-back rates in the absence of a regulated feed-in tariff were just a first step towards squeezing out small distributed competition to the big guys)…

Basically, we have an industry structure designed and built to entrench and perpetuate monopolistic behaviour, and that broken market is the biggest roadblock to electrifying the economy . A climate change emergency is a recipe for the generator cartel to hold us all to ransom.

 Energy analyst Molly Melhuish expresses a similar view:

MBIE’s scenarios support Government’s fast-track plan for removing the Low Fixed Charge regime… The corporates want every residential consumer to pay around $2/day on their power bill. This is like an electricity tax to fund their growing electricity empire. Their intent is to reduce the per-kilowatt-hour charge from 33c/kWh to 23c/kWh, which will clearly make consumer investment in rooftop solar panels much less economic.

Yet rooftop panels add resilience to our energy supply – a benefit that is ignored in MBIE’s supply-side analyses. Small-scale energy projects, household retrofits and community energy projects all employ people at all levels of skill and experience.

Utility-scale solar competes with rooftop solar, so removing the low fixed charge regime, driving unit prices down from 33c/kWh to 23c/kWh, will be a nail in the coffin of the independent solar installers.

CANA calls for strong Government support for small-scale distributed generation, including photovoltaic (PV) panels & batteries for rooftop solar, if necessary by restructuring the electricity generation industry to reduce the power of the cartel of major players.

Furthermore, we believe the building codes should be revised, to make all new buildings zero-emission, with mandatory solar panels and water tanks.

12.  Green Hydrogen

Whilst CANA supports the Commission’s advice to research the potential role of hydrogen fuel produced from the electrolysis of water by renewable electricity, we oppose the use of hydrogen anywhere that electricity could be used directly.

This is because the process of electrolysing water to hydrogen gas, then compressing, cooling, storing, transporting, and using it is grossly inefficient when compared to simply using the electricity directly.

For example, in passenger vehicles, electricity is more than three times as efficient as hydrogen, and almost six times as efficient as such “electrofuels” as methanol.

NB: New Zealand has been down this wasteful road already, with the “Think Big” projects of the ’80s, particularly the gas -> methanol -> synthetic petrol boondoggle that was apparently designed to use and/or waste as much gas as possible within the thirty-year “Take or Pay” contract for the Maui gas field.

Indeed, the same multinational oil and gas companies that benefitted from that scheme, would also be in line for huge contracts to build the infrastructure for a hydrogen economy, which may provide some explanation as to why the idea of exporting hydrogen to other countries is gaining traction.

CANA wants to see our renewable energy resources used to add value within New Zealand, rather than exported as yet more “frozen goods” in the form of liquid hydrogen or, indeed, as aluminium ingots.

In conclusion, we welcome Rio Tinto’s promised departure, and look forward to their replacement by exciting new sustainable industries in Southland.


Nau te rourou, naku te rourou, ka ora te iwi – From my food basket and your food basket, there is sufficient for everyone.