Submission on the Zero Carbon Bill

Anglicans CAN logoThis submission represents the collective views of the Anglican’s Climate Action Network (Anglicans CAN), Auckland, and does not purport to be the position of the Anglican Church of Aotearoa New Zealand. Anglicans CAN is a group of Anglicans who have been raising awareness, providing education and supporting political action on climate change issues since 2006 under the initiative.

Cherished Earth is a climate justice initiative of the Anglican Diocese of Auckland. e initiative is about taking actions that connect Christian faith with caring for creation, and is the practical outworking of a commitment made in 2006 by the Anglican Bishops of Aotearoa New Zealand, including Māori, Pacifika and Pākehā.


Anglicans CAN supports the need to create certainty around New Zealand’s response to the challenges of our changing climate. We offer these considerations around the intentions of the proposed Zero Carbon Bill.

The overarching principle to apply in developing the Zero Carbon Bill, must be one of social justice, not just for New Zealanders, but for all peoples of the world and for future generations.  This implies equality in terms of the distribution of wealth, opportunities, privileges and obligations.

For example, our climate actions must recognise the rights of people in developing countries to achieve the same standard of living and privileges that we take for granted. As the Earth cannot sustain our level of consumption of resources, it follows that our obligation is to reduce our consumption of the things we want but do not need.

Another example is that if incentives and subsidies are to be made available, they must be able to be taken up by anyone, regardless of income, assets or standing in the community.

The numbered paragraphs within this submission correspond to the questions posed in the Zero Carbon Bill Discussion Document.

1. The Government must set an ambitious 2050 target in legislation now.
A goal around “net zero emissions” is not adequate because it assumes an unspecified level of gross carbon emissions with offsetting to achieve a net position. Offsetting unconstrained gross emissions is not sustainable because the supply of land suitable for tree planting is limited, and the Government cannot guarantee that it will be able to purchase international carbon credits indefinitely.

That 2050 reduction target must focus predominantly on the release of new carbon to the atmosphere, and less on the recycling of existing carbon gases. New carbon is defined as carbon that is locked into the earth as coal, oil and natural gas, and is therefore, not already within the existing carbon cycle.

Carbon Dioxide generated by the burning and mining of previously sequestered fossil fuels is an example of new carbon. Methane emissions from the exploration and mining of fossil fuels is another example. The emissions from these sources must go to zero.

Biological sources of methane generated by the agricultural sector, is an example of a gas already within the existing carbon cycle. The emissions from this source have already stabilised (since 2011) and have grown by only 5.6% since 1990 (calculated from the 2016 Greenhouse Gas Inventory published by the Ministry for the Environment).

2. Anglicans CAN support none of the three options presented as the “best” target:

  1. net zero carbon dioxide excludes nitrous oxide and so this option cannot be supported.
  2. net zero long-lived gases and stabilised short-lived gases does not explicitly provide for zero new carbon gases and so this option cannot be supported.
  3. 3. net zero all gases (CO2, CH4, N2O) ignores the fundamental differences between short and long- lived gases and so this option cannot be supported.

In place of these “best” target options we propose ones that:

  1. target gross zero emissions of CO2 from fossil fuel sources (2016: 84% of total CO2)
  2. target methane being stabilised at 1990 levels (2016: a 4% reduction to 1990 levels)
  3. for N2O, targets:
    – gross zero emissions from manure management (2016: 1% of total N2O)
    – 50% reduction of N2O from agricultural soils (2016: 94% of total N2O)
    – gross zero emissions from the application of nitrogenous fertilisers to land

3. How should New Zealand meet it’s targets?
Use of the term “net emissions” in each of the three options within the discussion document, make the explicit assumption that tree planting will offset gross emissions and that any shortfall on the target, will be offset with international carbon credits. Anglicans CAN do not see this as an acceptable response to the very serious challenges that global warming represents.

Our submission distinguishes between the emissions of new carbon from the mining and burning of fossil fuels, and the recycling of existing atmospheric and oceanic carbon already within the carbon cycle. Emissions of new carbon must go to zero in gross terms; they must not be off-settable through tree planting nor the purchase of international credits.

Having a target for zero new carbon means that tree planting can be focused on the removal (sequestering) of CO2 from the atmosphere. We recommended a separate target be set for the tonnage of CO2 removal by tree plantings.

4. Revisions to the 2050 targets.
We agree that the 2050 target could be revised but with the proviso that any revised target be no lesser a reduction target than exists already.  That is, once the initial target is set, any revised target may be increased but not reduced. We believe that it is very important that the Zero Carbon Act be protected from dilution by political interference.

It is acknowledged that the Act could need to be repealed. We envisage this only in exceptional circumstances, and then only following a public referendum that approves such a repeal.

5. Yes, we agree with the proposal for three successive budgets, each of ve years’ duration.

6. Yes, the Government should be able to alter the last emissions budget (years 10 – 15) but only during the term of the first budget period.

7. No, the Government should not have the ability to review and adjust the second emissions budget.  Any government having this ability, would work to negate the certainty the Act would provide, especially in the build up to government elections.

8. Anglicans CAN believe the Climate Change Commission ought have a role greater than just advising the government on policy decisions. In particular, we believe the Commission must have a regulatory role as noted in point 11 below. We have no view on the considerations the proposed Climate Change Commission may take in to account.

9. Yes, the Zero Carbon Bill must require Governments to set out plans within a certain timeframe to achieve the emissions budgets.

10. The single most important issue for the Government to consider in setting plans to meet budgets is that our economic system does not support economics based on planetary/national resource boundaries. For example, the work of the Global Footprint Network suggests that our present use of global resources, requires 1.7 earths to meet our demand. If every person lived like New Zealanders, we would require 3 Earths to meet the demand for resources. Such levels of resource use are clearly not sustainable, pointing up the need for an economic system that works within planetary boundaries.

11. The Climate Change Commission ought have a regulatory role (perhaps along the lines of the Reserve Bank and Commerce Commission) to ensure that actions are taken, and not just talked about. Such a role should be protected against political appointments and interference.

12. The NZETS needs to be replaced with a Carbon Tax.  The current pragmatism around there not being enough differentiation between an ETS and a Carbon Tax to justify the costs of changing over, ignores the ineffectiveness and abuses of the ETS that have occurred to date.

13. The proposed expertise that the Climate Commission must have is agreed to with the following additions:

  • Systems thinking expertise should be specifically included. Without this level of expertise, there is a danger that a reductionist approach to the issues will be adopted, leading to incomplete analyses and ineffective actions that work to sustain business as usual.
  • Likewise, a problem solving ability should be listed within the expertise requirements.

14. The Carbon Zero Bill ought not cover climate change adaptation.
To do so, runs the risk of taking the focus away from the urgent need to mitigate the drivers of global warming.

Adaptation strategies do need to be developed, but within their own enabling legislation.

15. The new functions around adaptation to climate change are NOT agreed with:
We believe that adaptation measures (including the new functions proposed) are necessary, but not desirable within climate mitigation legislation.

16. An adaptation reporting power should be established, but done so within a separate Climate Adaptation Bill and outside of the powers of the Zero Carbon Bill.

2 thoughts on “Submission on the Zero Carbon Bill

  1. I like this well reasoned alternative to the proposed Zero Carbon Bill Its interesting that the questions asked and not asked in these public submission processes often constrain the debate so bravo for redefining the targets and the desired outcomes

    Liked by 1 person

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