28 February 2011

2050 Emissions Reduction Target submission

Here's my submission on Nick Smith's "50% by 2050" emissions reduction target.

2050 Emissions Reduction Target Consultation
Ministry for the Environment
PO Box 10362
Wellington 6143

By email to 2050target@mfe.govt.nz

28 February 2011

Submission in opposition to 2050 Emissions Reduction Target

Dear Sir/Madam,

I oppose the proposed target of a 50 per cent reduction of net greenhouse gases in CO2-e from gross 1990 levels by 2050.


Gross-net inconsistency

1. The proposed target is misleadingly framed to give the impression of reducing emissions while actually allowing increases in gross emissions. This is because the measurement of the 2050 target is inconsistent with the measurement of the 1990 baseline. The 2050 target is to be ‘net’ (after deducting carbon sink removals) and the 1990 baseline is ‘gross’ (without deducting carbon sink removals).

2. This framing allows actual gross emissions excluding LULUCF to increase by the amount of the actual carbon sink removals identified for 1990. These carbon removals amount to 31 million tonnes (MfE April 2010: “New Zealand’s Greenhouse Gas Inventory 1990–2008”, Report No ME 1009). A net target that represents such a quantum of increased production of GHGs hardly represents a meaningful transition to a low carbon economy. Nor is it particularly credible.

3. I recommend that the 2050 target be expressed consistently with the baseline, either as ‘net to net’ or ‘gross to gross’.

Target is irrelevant to climate policy

4. The proposed target lacks any credible integration with other sections of the Climate Change Response Act 2002, the provisions of the New Zealand Emissions Trading Scheme (NZETS) or any other NZ Government policy on climate change.

5. The emissions reduction target is not defined in the interpretation section of the Climate Change Response Act 2002. Within that act the emissions reduction target does not influence the setting of NZETS emissions caps, or the setting of allocations of emission units, or the setting of prices for emissions units. The proposed target appears irrelevant to the key design features of the NZ ETS.

6. If the proposed target has no meaningful impact on the operations of the NZETS, then the gazetting of the proposed target is merely window-dressing for ineffective policies on climate change mitigation.

Target lacks scientific support

7. The proposed target is not consistent with the science. It is predicated on stabilizing carbon dioxide concentrations at about 450 parts per million (ppm) and keeping temperature increase since the 18th century to two degrees C.

8. In the paper Hansen et al 2008 “Target Atmospheric CO2: Where Should Humanity Aim?” (PDF), Hansen and his co-authors conclude that a temperature increase of two degrees C will constitute dangerous interference in the climate system and that the target of 450 ppm, if long maintained, would push Earth toward an ice-free state and that the present global mean carbon dioxide concentration of 391 ppm, already exceeds a safe level. Hansen et al conclude that a safer concentration of atmospheric carbon dioxide.

9. In the paper by Kevin Anderson and Alice Bows 2011: Beyond 'dangerous' climate change: emission scenarios for a new world, Phil. Trans. R. Soc. 369, 20-44 doi: 10.1098/rsta.2010.0290, the authors make the following three points:

  • There is now little to no chance of maintaining the rise in global mean surface temperature at below 2 degrees C.
  • A temperature increase of 2 degrees C now represents a threshold, not between acceptable and dangerous climate change, but between dangerous and ‘extremely dangerous’ climate change; in which case the probability of exceeding 2 degrees C increases substantially.
  • Annex 1 countries should be aiming to reduce GHG emissions by 100% by 2050 in order to allow Non-Annex 1 countries the space for carbon intensification of their economies to similar levels to Annex 1 countries.
I welcome the release of this submission or any information contained in this submission under the Official Information Act 1982.

Yours sincerely

NB. This process is a farce. There is no independent decision maker, and the Minister is clearly already committed to '50% by 2050'. Its just consultation for less than consultations sake.

15 February 2011

Nick Smith mistakes gross and net GHG emissions

Still on the topic of Nick Smith not being able to tell the difference between gross greenhouse gas emissions and net greenhouse gas emissions (after subtracting forest carbon removals).

It needed its own chart. Here it is. Nick Smith's press release of 10 February 2011 says net GHG emissions in 1990 are 61 million tonnes - the large blue dot. That is actually the gross GHG emissions. Russel Norman's press release of February 2011 gives the correct 1990 net GHG emissions 29 million tonnes according to the Ministry for the Environment.

Here is the R code.

png(file="Smith.png",pointsize = 16,width=600,height=500)
plot(Year,gross,axes="FALSE",type="n",xlim=c(1990,2007),ylim=c(0,82),xlab="Year",ylab="Emissions (Megatonnes)",main="New Zealand's Gross & Net GHG Emissions 1990 to 2007")
points(Year[1],net[1],pch=19, col=3,lwd=8)
text(1990,23,"Norman's \nNet GHG \nemissions",adj=0, col=1)
points(Year[1],61.7,pch=19, col=4,lwd=8)
text(1990,54,"Smith's \nNet GHG \nemissions",adj=0, col=1)
points(Year,net, type="l",col=3,lwd=2)
points(Year,gross,type="l", col=4,lwd=2)
legend(1996, 25,bty = "n", c("MfE Gross GHG emissions","MfE Net GHG emissions"),lty = c(1,1), pch=c(NA,NA),lwd=c(2,2), col = c(4,3))
mtext(side=1,line=-1.5,cex=0.8,"Source: MfE 2010 New Zealand’s Greenhouse Gas Inventory 1990–2008")

11 February 2011

Smith's Gross Error on Net 1990 GHG emissions

Speaking of gross Kyoto confusion, Nick Smith has leapt in to the media fray to defend his view of the Kyoto Protocol and to say that the Greens Russell Norman has got his numbers wrong in his press release.

Smith says Norman is wrong and "tricky, misleading and mischievous" to say that net 1990 emissions are 31 million tonnes less than gross 1990 emissions. Smith says the difference is 1 million tonnes.

Unfortunately it is Smith that has made the Gross error.

In the forth paragraph, Smith states:
New Zealand’s emissions in 1990 were 60.9 million tonnes gross and 61.7 million tonnes net under the agreed Kyoto Protocol rules.
Umm no, according to MfE (April 2010) New Zealand’s Greenhouse Gas Inventory 1990–2008, Report No ME 1009, by the Ministry for the Environment, ISSN 1179-223X.

Page iv states "In 1990, New Zealand’s total (or gross) greenhouse gas emissions were 60,773.6 Gg carbon dioxide equivalent (CO2-e)". (60.7 million tonnes)

Page v states "In 1990, New Zealand’s net greenhouse gas emissions were 29,707.3 Gg CO2-e." (29.7 million tonnes, and certainly not 61.7 million tonnes as Smith's release states)

(NB Gg = gigagrams and 1000 Gg = 1 million tonnes)

Here's the chart again! Nick Smith, have a good look at where the green and blue lines leave the lefthand vertical axis!

Does the Minister's office even understand GHG inventory reports from the Ministry for the Environment?

Kyoto Protocol decoded

The Kyoto Protocol has been mentioned in the NZ blogosphere over the last day or so. No Right Turn describes New Zealand's actions to comply with our obligations under the treaty as Scam Writ Large. He is largely commenting on a Green Party press release from Russell Norman, where Russell critiques Nick Smith's 50% reduction in GHGs by 2050 target.

Russell Norman's point is that the Government target for 2050 is an "accounting trick", as the 1990 baseline is total or gross GHG emissions from industrial and domestic energy use and pastoral farming excluding carbon sequestration from the forestry sector (carbon sinks). The 2050 target will be net, after deducting carbon sink removals. Therefore the "trick" is comparing a net target with a gross baseline. That allows gross emissions to have grown by any amount up to the additional 'credit' from the carbon removals from growing forestry.

No Right Turn agrees and adds that the same Gross-base-net-target fudge also fully applies to the Kyoto Protocol commitment period of 2008 to 2012.

This gross-net distinction is a bit hard to understand. So I have done some charts that will hopefully explain this in the context of the Kyoto 2008 to 2012 period. The first is just total emissions of greenhouse gases in NZ for 1990 to 2008.

Remember, NZ's Kyoto obligation is "no increase on 1990 levels of GHGs" so there is a horizontal line at 61 million tonnes (61 megatonnes), the annual GHG emissions calculated for 1990. Well, its obvious the trend line is not returning to the 1990 level. Okay, lets add the net GHG emissions, the gross GHGs less the forestry carbon sink removals.
Heck, those net emissions have grown faster up to 2008 even more than the gross emissions! So, how on earth is New Zealand going to get the GHG emissions back to 1990 levels to comply with the Kyoto Protocol? Nick Smith has told us that NZ will not just meet the Kyoto target but will be in a surplus.
The red line in this third chart shows the "Kyoto accounting" of NZ emissions. The forestry sink carbon removals, from 1990 to 2007, are ignored and have no status; the base in 1990 is gross GHGs only. Then, magically, from 2008 to 2012, the forestry sink carbon removals suddenly are counted and may be awarded as carbon credits to "post 1990" forest owners. Thus every carbon credit issued to a forester balances out the increase in gross emissions of GHGs above the 1990 base.

Hence, from these charts, I agree with both No Right Turn and the Greens that the Kyoto Protocol is very flawed from the point of view of driving reductions in GHG emissions.

05 February 2011