Omission 1: Science & Full Abatement List

Appendix 6 – There is missing science and a process error in producing sectors, and the legal duty has yet to be discharged vis-à-vis a full list of domestic emissions reductions and a new NDC.

Intro

Thinking ‘inside the square’ can chip away at emission reductions targets, but only if the science and legal requirements are honoured. Errors and omissions must be remedied.

The CCC…

Offers a range of producing sector recommendations.
Picks energy winners such as hydro, wind, solar and geothermal.[1]
Does not offer a complete list of domestic emissions reductions opportunities for the existing (currently inadequate)[2] NDC.[3]

Discussion

“There is a strong [argument] in … technology policy of avoiding … ‘picking winners’.”[4] “The trick for the government is not to pick winners, but to know when it has a loser.”[5] “To avoid accidentally helping to entrench the wrong technology, it is desirable for policy to be technology neutral, encouraging all efforts that achieve specified objectives.”[6] “In situation[s with] … technological uncertainty it is important to have initial variety even within technological fields … [so] policy should stimulate the development of different designs rather than trying to make ex ante identifications of the ‘optimal’ design.”[7]
Counterintuitively, “nuclear [fission] is the safest power source per TWh … even including the Fukushima and Chernobyl [disasters].”[8] The next source ranks nuclear fission fourth (behind wind, hydro and solar but all within 0.05 deaths per year), yet it also ranks nuclear fission as the cleanest power source (cleaner than wind, solar and hydro) with 3 t “of CO_2e[emissions] per gigawatt hour of electricity over the lifecycle of the plant.”[9] Contrary to popular opinion, nuclear power is not banned in New Zealand; rather the country’s nuclear-free moment and legislation was about banning nuclear powered vessels and weapons.[10] A nuclear power plant was even seriously considered in Kaipara in the 1960s and 1970s.[11] The three reasons why New Zealand discontinued those plans have gone.[12] I.e. a plant that contributed to 1/7^th of the size of the grid wouldn’t be too big these days with EV ambitions, the initial cost may not be considered prohibitive in the current regulatory environment, and the level of opposition to nuclear is not what it once was.[13]
The Act requires the CCC to provide expert advice[14] vis-a-vis what is required so Aotearoa can achieve the NDC[15] and the 2050 target and contribute to global goals[16] “in a way that allows those budgets to be met domestically”.[17]
While the Act does require the CCC to consider how emissions reductions “may realistically be met”,[18] the fact is that a failure to do so wholly domestically would not contribute towards “the global effort under the Paris Agreement to limit the global average temperature increase to 1.5⁰C above pre-industrial levels”[19] which is required in the Act. Further, the adverb “realistically” qualifies the word “be”, which means the subject of the sentence must be done and done so “when you want to emphasize that what you are saying is true, even though you would prefer it not to be true.”[20] I.e. the test is whether it will reduce emissions, not whether it will be good for GDP or whether people will like it.
Politicians expressly asked for “recommendations on any changes to the NDC to ensure it is compatible with global efforts…”[21] The CCC does not offer scientific advice about what a more appropriate NDC would be.[22]

Conclusions

Earlier appendices have already considered errors and gaps in things like waste (circularity and consumption), transport (electric bikes) and heat, industry and power (cement). However, there are more errors and gaps elsewhere – the obvious ones are transport (trains) and heat, industry and power (wood, and carbon capture and storage).
It is poor scientific process not to consider nuclear fission when it is one of the cleanest and safest technologies. Proper process should set aside preconceptions and agnostically consider the science before reaching a conclusion; not fail to consider it at all. Nuclear fission should therefore be considered in the report. The CCC should be brave enough to at least discuss the technology and understand it before passing judgement.[23]
The other learning about exploring the nuclear fission omission is the lack of abatement graphs in the draft report. While a different approach has been used, people understand abatement graphs and these should be central to the report.
The government should play a co-ordination role in mapping the innovation systems in the producing sectors and it should incentivise and leverage free-market invention and innovation so many more current (and future) technologies can be part of a portfolio approach to climate change and sustainability.
The CCC is at risk of not discharging its legal duty. It is wrong to exclude a full list of domestic emissions reductions opportunities (by way of including offshore mitigation) as a way of Aotearoa achieving its NDC because the CCC’s role is to table all possible domestic abatement options.[24] The CCC therefore needs to find more domestic policy directions and options, which may well be severe.[25] The Act says we should see what they are![26] It would then be a political decision (not one for the CCC) as to whether some of those policy directions were progressed. The status quo approach deprives Aotearoa of the chance to have a wholly informed debate and to even understand the worst-case scenario.
The CCC was specifically asked by politicians to opine what a more appropriate NDC should be based on the science yet it has shied away from that. This is not a game of hot potato. In turn that deprives New Zealand of learning about what further domestic emissions reductions (i.e. beyond the already incomplete list) are required by 2035. In turn, that risks politicians not adopting ambitious enough emissions reductions plans if international short-term Paris commitments are revised.
Given the current NDC is inadequate and emissions budgets are set with regard to the NDC, then emissions budgets should be reset if the NDC is changed. It is not clear whether the Act would permit that. This dynamic risks undermining the whole purpose of having the CCC.

Recommendations

Recommend building high-speed trains connecting Auckland, Waikato and the Bay of Plenty, the so called ‘Golden Triangle’.[27]
Recommend promoting and maximising the use of wood in building projects.[28] [29]
Recommend participating wholly in permanent carbon capture and storage technologies.
Discuss and consider nuclear fission, including its cost, before ruling it in or out of the mix on safety or other scientific grounds.
Add abatement graphs and curves into the main body of the report and discuss that, to show the carbon price at which each abatement option would occur.
Review, reference and refer to the MfE’s 102 page 2020 work on “Marginal abatement cost curves analysis for New Zealand”[30] and incorporate and correlate that into its work. It is critical that the MfE’s work is not lost and is wholly mined as the CCC process is the best way to influence emissions reductions plans.
Recommend that producing sectors of the economy are pulled together by mapping the country’s high-level possibilities to motivate socio-technical actors[31] to then deep dive into relevant functions of the innovation system to validate or uncover the most important processes and specific next steps.[32]
Recommend further tax breaks where new inventions are pursued and new innovations are brought to market, subject to that knowledge progressing climate change and sustainability outcomes and to it being democratised.
Be more ambitious in terms of what is realistic and perhaps to help with this it could state the level of ambition and difficulty of each policy direction. That would help to guide which technological developments should be prioritised for emissions budgets.
Discharge its duty in full and rework its report to propose many more policy directions and options that would ensure that the current NDC[33] is wholly met domestically in order to meet the legislative requirement and our commitment to 1.5⁰C.
Discharge its duty in full and rework its advice in Part B to advise what the science says would be a better NDC target (or narrow range) in % terms that would achieve 1.5⁰C.
Recommend that the government amends r5ZC of the Act to permit the CCC to provide advice and recommendations on amendments to current emissions budgets at any time and/or add a new r5ZC(1)(c) to the Act to make the section apply at any other time when the CCC considers that an amendment to an existing emissions budget is required.
Recommend that the government add a new r5ZC(2)(b)(xii) to the Act such that for any changes to existing emissions budgets, it has regard for any changes in r5ZC(b)(i) through (xi). This would remove a loophole and clarify that amendments to underlying factors can be considered when amending advice on, or resetting, emissions budgets that had already been set or opined on.

[1] Page 9 of the draft report.

[2] Page 153 of the draft report.

[3] Page 20 of the draft report.

[4] Page 6 of https://www.sciencedirect.com/science/article/abs/pii/S0921800905000303

[5] Page 13 of https://drodrik.scholar.harvard.edu/publications/industrial-policy-twenty-first-century

[6] Page 8 of https://www.sciencedirect.com/science/article/abs/pii/S0921800905000303

[7] Page 10 of https://www.sciencedirect.com/science/article/abs/pii/S0301421500000410

[8] https://www.visualcapitalist.com/worlds-safest-source-energy/

[9] https://ourworldindata.org/safest-sources-of-energy

[10] https://ecotricity.co.nz/why-nuclear-energy-isnt-an-option/

[11] https://www.stuff.co.nz/business/industries/100468448/from-uranium-to-nuclear-plants-new-zealands-secret-nuclear-past

[12] https://ecotricity.co.nz/why-nuclear-energy-isnt-an-option/ -.

[13] https://www.world-nuclear.org/information-library/country-profiles/countries-g-n/new-zealand.aspx

[14] r5B(a) of the Act

[15] r5M(g) of the Act

[16] r5W(a) of the Act

[17] r5W(b) of the Act

[18] r5Z(2)(a) of the Act

[19] r5W(a) of the Act

[20] https://www.collinsdictionary.com/dictionary/english/realistically

[21] Page 146 of the draft report.

[22] Page 154 of the draft report.

[23] I would be nervous about nuclear fission being part of New Zealand’s power mix, especially given earthquake and tsunami risk, but let’s at least see where it sits on the abatement graph.

[24] Refer to previous references, plus r5K(1) of the Act which only refers to “reducing [actual] emissions” in the context of an additional report about further domestic emissions reductions required if the NDC is amended.

[25] If the CCC currently cannot find further emissions reductions without use of future technology, doesn’t that suggest that future technology should be fast-tracked? However, the fact is that there are further emissions reductions opportunities to cull livestock numbers, by way of an extreme example.

[26] And understand the impact on GDP.

[27] Necessary action 4d. on page 110 of the draft report is sub-standard and not ambitious enough.

[28] This is also a circular economy solution, yet the benefits are only apparent when the current technology of wood is thought of as a green alternative to steel.

[29] The CCC seems to agree with this on pages 68, 99 and 142 of the draft report, but then doesn’t recommend any policy direction for it.

[30] https://www.mfe.govt.nz/sites/default/files/media/Climate%20Change/marginal-abatement-cost-curves-analysis_0.pdf

[31] Page 1506 of https://www.sciencedirect.com/science/article/abs/pii/S0048733305001721.

[32] Page 418 of https://www.sciencedirect.com/science/article/abs/pii/S0040162506000564.

[33] Not just the 2050 target in 2050.