Tag: sustainability

Climate and the Government’s transport plan

by Robert McLachlan

[This is my personal submission to the Draft Government Policy Statement on land transport. Submissions close at noon on Tuesday 2 April, 2024.]

In the Emissions Reduction Plan (ERP1), transport emissions fall 41% by 2035. As the Ministry of Transport says, “Achieving this will reduce our dependence on fossil fuels and give us a more sustainable, inclusive, safe and accessible transport system that better supports economic activity and community life.” There is plenty of detail in the plan:

The plan is supported by four specific transport targets:

Target 1 – Reduce total kilometres travelled by the light fleet by 20 per cent by 2035 through improved urban form and providing better travel options, particularly in our largest cities. 

Target 2 – Increase zero-emissions vehicles to 30 per cent of the light fleet by 2035. 

Target 3 – Reduce emissions from freight transport by 35 per cent by 2035. 

Target 4 – Reduce the emissions intensity of transport fuel by 10 per cent by 2035. 

Targets 1 and 3 are wrecked by the Draft GPS, while Target 4 is already suspended. Target 2 is also threatened by related government actions to slow the uptake of EVs and other low-emission vehicles: cancelling the CCD, imposing high RUCs on EVs (a world first), proposing to weaken the CCS, and proposing to replace fuel tax by RUCs based on distance and weight.[1] The Ministry advise that the first two of these alone may limit EV share of the light vehicle fleet to  7% by 2030 (and 23% market share)[2], vs. 12.5% in the Climate Change Commission’s Demonstration Path (and 64% market share), putting the 2035 target at risk. However, the Ministry’s model involves 22,000 EV sales in 2024. In fact there were only about 1,700 sales in the first quarter.

The ERP1 for transport is not rocket science and should not be at all controversial. Internationally, all transport climate plans include the basic elements of fuel standards, mode shift, public transport planning. The IPCC in their summary of evidence say the same thing. The debate is over the mixture of fees, incentives, regulations, and bans, not over the direction of travel. The Draft GPS would wreck this plan. Spending on walking, cycling, and public transport would reduce and become highly constrained. Spending on rail infrastructure would reduce drastically, which could render the national rail network non-viable. That in turn wrecks the New Zealand Rail Plan, intended to increase the proportion of heavy freight carried by rail by building high-tech truck/rail freight hubs and new rail ferries.

Dropping climate from the GPS drops it from NZTA, currently the lead agency charged with delivering emissions reductions from transport. What could replace it? The government is committed to meeting the emissions budgets, but have not yet released much detail about how they plan to do that, other than that the ETS will be the main tool.

But it is well known that carbon charges are not an effective way to reduce transport emissions. At current prices the ETS adds 15 cents per litre to the price of petrol, or $15/1000 km. The RUC rate for light vehicles is $76/1000 km. The carbon price would have to increase by a factor of five just to match that, which is unthinkable – it would destroy all other exposed sectors.

This issue has been covered extremely thoroughly in the international literature. In 2022, I co-authored a review with David Hall on “Why emissions pricing can’t do it alone”[3]. The Climate Change Commission identified ten types of barriers to a low-emission transition; tellingly, transport is the only sector for which they proposed specific fixes for all ten barriers. Nearly all of them are under attack.

So it is really flying in the face of evidence think that the ETS can be our main climate tool, particularly for transport. Details are lacking – Minister of Climate Change Simon Watts will only say that work on the second Emissions Reduction Plan (2026-2030) is under way. Analyst Christina Hood has repeatedly detailed how the ETS will struggle to deliver even under present conditions[4].

Emissions reductions first entered the GPS in 2015, under John Key. It was raised to a strategic priority in 2018 and 2021, but now it is proposed to be dropped. Presumably, all work streams in NZTA related to emissions reduction will be stopped and all work teams dissolved. So, despite all the other alarming and potentially disastrous parts of the Draft GPS, this one is the worst.

Section 5ZI(3) of the Climate Change Response Act 2002 states that

The Minister may, at any time, amend the plan and supporting policies and strategies to maintain their currency, (a) using the same process as required for preparing the plan; or (b)in the case of a minor or technical change, without repeating the process used for preparing the plan.

But the Draft GPS states, in contrast, that

Following the general election and a change of government in late 2023, the intended emissions reduction policies foreshadowed by the previous Government are being reassessed. For this reason, GPS 2024 has not undertaken the alignment exercise as anticipated in ERP1. The Emissions Trading Scheme (ETS) is the Government’s key tool to reduce emissions. In addition to the ETS, matters relating to climate change/emissions reduction issues are being worked through and will be addressed during development of the second Emissions Reduction Plan (ERP2). 

Thus both the Draft GPS and the decision to not perform the alignment exercise are in violation of the Climate Change Response Act 2002. Note that the relevant “plan” referred to in section 5ZI(3) in this case is ERP1, not ERP2. In addition, many of the activities needed to support the 2nd and 3rd carbon budgets need to be undertaken in the first budget period.

Slower transport emissions reductions from existing policies mean that other policies will need to be developed to replace them. I am skeptical that the two that have been announced – higher carbon prices and faster EV charger rollout – can make up the difference. But at the very least the modelling and policy advice to support this approach should be published. To put it another way, the climate plan and the transport plan should be prepared together. But they have not been prepared together in what appears to be a deliberate strategy.

Another possibility is transport emissions will be allowed to decrease more slowly that previously intended and that other sectors will make up the difference. But transport is so large a share of emissions that it is hard to know where the other savings could come from. Three other large sectors are agriculture, industry, and trees. The first two may struggle to deliver greater cuts, while trees are already performing a far greater share of net emissions reductions than in any other developed country and are also facing policy challenges and risk transferring climate obligations to future budget periods. 

To sum up, the Draft GPS constitutes climate denial.

Recommendations

R1.          Perform the alignment exercise required of the GPS by ERP1.

R2.          As the proposed changes to ERP1 are neither minor nor technical in nature, but strike directly at its heart, revise ERP1 using the process required by the Climate Change Response Act.

R3.          Publish the legal advice received regarding R1 and R2 above.

R4.          Reinstate emissions reduction as a strategic priority of the GPS.

[1] https://www.thepost.co.nz/nz-news/350179050/casualties-governments-declaration-war-evs

[2] Departmental Report to the Transport and Infrastructure Committee, RUC Amendment Bill, https://www.parliament.nz/resource/en-NZ/54SCTIN_ADV_60f18385-f31e-4c3e-1dba-08dc38a90c66_TIN1082/e69f6e2b63ae81e98f300a8d3cc146de8b21ae76

[3] https://ojs.victoria.ac.nz/pq/article/view/7496

[4] https://www.linkedin.com/pulse/nz-ets-review-zero-carbon-act-theory-vs-reality-christina-hood/?trackingId=DtF8IukNSzW5egD9Mc2POg%3D%3D

Aotearoa’s fossil fuel emissions, 2023

Three years ago I asked, “Why did New Zealand’s CO2 emissions blow out so spectacularly in 2019?“. At that point, emissions had risen 10% in three years. My conclusion was that

the forces for increasing fossil fuel burning were vastly more powerful than the puny forces opposing them. All the talk about climate change in 2017–2019 had little effect on the behaviour of companies or individuals.

Have we turned the corner? Possibly. The pro-fossil fuel forces are still there, but the opposing forces are gathering strength, especially through the Zero Carbon Act which for the first time includes a falling cap on emissions. In the most sensitive sector, electricity, the changes can be seen already. My takeaway from the new 2019 data is that the big four, road transport, aviation, electricity, and food processing, that are so large, that have performed so poorly, and that have so much scope for transformation, are where we need to look for change.

We don’t have full emissions data yet for 2023, but MBIE have just released a partial snapshot covering emissions from the burning of fossil fuels, which contribute 85% of gross CO2 emissions. 2023 was the first full post-lockdown year – travel restrictions were only eased in early and mid-2022.

Although emissions are up slightly, they are still well below the blow-out year of 2019, and stand at 23-year lows. 2022 and 2023 comprise the first half of the first 2022-2025 carbon budget, so low emissions in these two years will definitely help us meet the budget.

But digging into things in more detail, progress is not so great. Here’s the breakdown by fuel.

This shows that the fall in emissions in 2022-23 was due to falling electricity emissions, caused by full hydro lakes (hydro generation up 4200 GWh on the previous two years, or 5% of total generation) and new wind farms (up 1100 GWh). Solar (up 290 GWh) also started to make an appearance. That doesn’t mean that electricity emissions will bounce back, though: another 2800 GWh of new renewable generation is planned for the next three years, so even in an ‘average’ rain year we should be alright.

Clearly a major culprit is oil. It’s a big chunk of these emissions (70%) and it’s hard to move. Oil consumption is down on record highs, but not by much – closing the Marsden Point oil refinery in mid-2022 shifted 0.8 MtCO2 of emissions offshore, accounting for the whole decline.

The Clean Car Discount was introduced in mid-2021, and staying in place for 2 1/2 years, but has now ended. Road User Charges will be introduced on EVs in two weeks’ time, at a proposed rate of $76/1000 km – New Zealand will be the first country in the world to do this. (In Australia, the state of Victoria did impose RUCs on EVs, at A$25/1000 km, but this was annulled by the High Court last year.) There are also threats to weaken future fuel efficiency standards and to remove fuel excise duty entirely. Together these amount to a war on EVs which may lead to significant upward pressure on emissions. The fact that all the EVs in New Zealand are only saving 0.14 MtCO2 a year at present – too small to even see on the above graph – doesn’t mean they’re a failure, it just shows the scale of the problem and the persistence that is required.

Of course EVs are not the only or even the most important solution to transport emissions. In 2021 I wrote that “big battles over mode shift lie ahead” and these have now come to pass with the release of the Government’s draft policy statement on transport, which drastically de-emphasises cycling, passenger rail, and public transport. Climate Liberation Aotearoa have a handy mantra:

The first three are part of the first Emissions Reduction Plan, but the Government appears to think it is free to ignore the plan. As I read it, they are in violation of the Zero Carbon Act, which says that

The Minister may, at any time, amend the plan and supporting policies and strategies to maintain their currency (a) using the same process as required for preparing the plan; or (b) in the case of a minor or technical change, without repeating the process used for preparing the plan.

I guess that’s why we have lawyers.

Which climate scenario should we plan for?

By Robert McLachlan

In the Manawatū region of New Zealand where I live, the Horizons Regional Council plans for climate change impacts under the high-emission “RCP8.5” scenario. This is a scenario in which no attempts are made to reduce emissions – the track we were on for decades. In this scenario, emissions triple by 2100 and coal burning expands by a factor of six.

This is now considered highly unlikely. So why is it still used for planning?

The Ministry for the Environment recommends

using the middle-of-the-road scenario (RCP4.5) and the fossil-fuel intensive development scenario (RCP8.5), and screening hazard and risk assessments for longer-term coastal impacts up to 2130 (RCP8.5).

RCP4.5 reflects moderate emissions and implementation of current global emissions reduction policy settings. It represents limiting the rise in global air temperature to 2.7°C by 2100.

RCP8.5 broadly aligns with emissions-reduction practice over the past few decades. It reflects high emissions, limited mitigation measures and no global emissions reduction policy settings. This scenario represents a rise in global air temperature to 4.4°C by 2100. RCP8.5 enables local government to understand the full extent of possible climate risk. It is particularly important for developments with a long timeframe (more than 100 years), especially for climate-sensitive projects and coastal planning activities, due to the very long time-lag (from decades to centuries) between sea level rising and seeing the effects on developments.

Ministry for the Environment. 2022. National adaptation plan and emissions reduction plan. https://environment.govt.nz/assets/publications/national-adaptation-plan-and-emissions-reduction-plan-guidance-note.pdf

RCP8.5 is relevant not just as a worst-case scenario of emissions. The key point is that it gives an idea of a bad-case outcome for the climate response even under moderate emissions. For that reason, only RCP8.5 should be used for planning; RCP4.5 still allows a completely unacceptable level of risk.

Climate change predictions are highly uncertain. One measure is the “Equilibrium Climate Sensitivity”, the increase in temperature in response to a doubling of CO2, after short- and medium-term feedbacks have entered equilibrium. (“Medium-term” means decades to a few centuries). This has long been estimated at 2–4.5 ºC, with an average of 3 ºC. We are currently at just over half a doubling, resulting in 1.3 ºC of warming, although not all those feedbacks have yet run to equilibrium.

2–4.5 ºC is a wide range, and that’s only the “most likely” values – a 66% probability. If the sensitivity is actually on the high side, then even moderate emissions will lead to much greater impacts.

There are two fundamental reasons why the uncertainty is so large and has proven difficult to reduce.

First, there are many climate feedbacks. Some lead to more warming and some to cooling. Each is hard to predict accurately because of the long time scales and complicated interactions of the atmosphere and ocean.

Combining effects of the same sign needn’t increase uncertainty:

A = 10 ± 1 (10% uncertainty)

B = 10 ± 1 (10% uncertainty)

A + B = 20 ± 2 (10% uncertainty)

But combining effects of opposite sign always increases uncertainty:

A = 10 ± 1 (10% uncertainty)

B = –5 ± 0.5 (10% uncertainty)

A + B = 5 ± 1.5 (30% uncertainty)

Secondly, the uncertainty is worse on the high side:

Roe, G. H., & Baker, M. B. (2007). Why is climate sensitivity so unpredictable?. Science 318(5850) 629–632.

Here the most likely response is 3 ºC, but very large values (6 ºC or even higher) are possible. In the most recent IPCC report (AR6) the most likely range was reduced somewhat, to 2.5 ºC–4 ºC. However, this was due in part to discarding a number of “hot models” that showed higher sensitivity. (In those models, forecasts of less clouds meant less sunlight reflected directly back to space, and hence more warming.) And that was done for a good reason, namely that the mid-range models fit the observed warming extremely well:

The takeaway message is that even under moderate emissions, there is still a pretty decent chance of catastrophe.

Allen Fawcett et al., Can Paris pledges avert severe climate change? Science, 2015.

Here the “no policy” scenario (RCP8.5) gives a 90% chance of more than 3 ºC of warming by 2100. But even “Paris–continued ambition” (which assumes that all countries in the world achieve their 2030 targets and continue decarbonising at the same rate) has a 42% chance of exceeding 3 ºC. Only “Increased ambition”, in which decarbonisation accelerates greatly after 2030, gives a decent 14% chance of avoiding 3 ºC. That’s an “extreme climate change” scenario, with up to 60% of the global population at risk of starvation.

Risk is a funny thing. For aircraft, we think a 1-in-10 million chance of a crash is an acceptable level of risk. If a crash is linked to a design flaw, the entire global fleet of that model is grounded indefinitely. For flooding, we’ve settled on a 1-in-500 annual risk of catastrophic urban flooding in any given location. (In Palmerston North, stop banks were upgraded to that level just in time to survive the 2004 floods.) For climate change, a 50-50 risk of complete annihilation is met with “that’s the best we can do”.