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.

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