Submission to CCC: A Systems Critique

The New Zealand Climate Change Commission’s (“CCC”) Q1 2021 draft report falls well short of the mark: it expects incrementalism to create transformation, is incomplete, and is inaccurate with some science.  Worst of all though, it assumes that climate change is a standalone problem to solve.

Climate change is a symptom of overshoot which is a systems issue.[1]  To try to solve climate change therefore requires systems thinking.  This submission does that by way of comprehensively critiquing the CCC’s draft report using a multi-disciplinary sustainability lens. This leads to a number of discoveries.

The first ten discoveries each have an appendix that includes an introduction, a summary of CCC points, and a discussion on the science, conclusions, recommendations, and full footnote references.

The appendices are colour coded as primary ways to reduce emissions, omissions to fix, ‘elephants’ in the room to acknowledge, and one way to set the elephants free.  The discoveries are:

  1. Economic modelling says CO2 emissions will go down and GDP will go up, but historic sustained global material absolute decoupling of emissions and GDP has never happened.
  2. A perfectly circular economy is impossible because of the second law of thermodynamics, so a key solution must be about efficiency.
  3. The lack of a consumer-centric approach conflicts with modern political science, and excludes emissions and consumption reduction opportunities.
  4. The ETS should be coupled with other policies, but bespoke associated or unrelated policies are required that do not undermine the primary tool.
  5. We need to do heaps more to sustain net zero carbon and de-risk the economy post-2050, and future technology steps must start now.
  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.
  7. The impact on planetary boundaries is absent, yet that is a key tenet of doughnut economics and sustainability science.
  8. Cost appears to be conflated with value, and key finance considerations are ignored including detailed capex costs, balance sheets and adaptations for councils.
  9. A hybrid carbon accounting framework is required, and that must be able to be holistic and honour scientific and global developments.
  10. Forestry is flawed because of harvested wood products, and that must be overhauled using first principles science about forestry emissions and removals.
  11. Setting the elephants free: One idea to solve New Zealand’s net zero carbon goal.

Incorporating the learnings from the primary ways to reduce emissions will take a bit of rework.  Fixing the omissions shouldn’t be too hard.  However, the elephants are big and will require deep thinking, honesty, transparency, bravery, leadership, and kaitiakitanga by the CCC and politicians.

Most will submit without a science bent, or on one issue, or to further their own interests.  But my submission is to help the CCC fix its final report.  I do not want the CCC, or politicians, to fail.  People might not realise until years to come but the root cause of failed emissions reductions or surprise at GDP and wellbeing destruction or an accounting nightmare for future holders to fix may be traced back to the CCC if it does not make material changes to its report before the report is finalised.

To explain the thought process…

  • I start with an elephant that few see (GDP vs. emissions correlation) which finds two primary ways to reduce emissions (efficiency and consumption reduction).
  • That forces a think about a more common elephant (ETS coupling with other policies), which discovers the third way to reduce emissions (future technology) yet also highlights a major omission (missing science plus domestic abatement opportunities).
  • By now trade-offs are evident and that realisation raises two more omissions (planetary boundaries and finance considerations).
  • Stepping back finds the fourth way to reduce emissions (hybrid carbon accounting), yet it also forces a deep think which discovers a hidden third elephant (forestry).
  • Synthesising this and reframing the issue discovers a creative idea to solve net zero carbon.

[1] https://www.postcarbon.org/why-climate-change-isnt-our-biggest-environmental-problem-and-why-technology-wont-save-us/

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