Opening up the data or webscrape the 2015 free allocation of emission units from MfE

Let's look at the latest data on the very generous free give-aways of emissions units to emitters made by the Ministry for the Environment
(N.B. Update on 10 December 2016. The allocation decisions have moved to the web page of the Environmental Protection Authority. And the "importHTML" function in Google sheets does not work on the EPA pages.)

The Ministry for the Environment has up dated its webpage 2015 Industrial Allocation Decisions to show the final 2015 free allocation of emission units to emitters under the New Zealand Emissions Trading Scheme.

I looked at the 2010 to 2014 data in my post Opening up the data on emissions units in the NZ emissions trading scheme. So in this post I am will repeat my steps in web-scraping the freebie emissions unit data into a sensible open format.

The url of the webpage is http://www.mfe.govt.nz/climate-change/reducing-greenhouse-gas-emissions/new-zealand-emissions-trading-scheme/participatin-4

Go to Google and open a new Google sheet.

Enter this text in cell A1 of the Google sheet.

=importHTML("http://www.mfe.govt.nz/climate-change/reducing-greenhouse-gas-emissions/new-zealand-emissions-trading-scheme/participatin-4","table",1)

That worked perfectly! We have a Google sheet of the 2015 free unit allocation to NZ emissions trading scheme emitters.

I have saved it as NZETS-2015-final-allocations-for-eligible-activities.

However, the first column includes both industry names and types of industries classified by the type of emissions the industry produces. And lots of asterisks. Any sensible format would have these attributes as separate columns so that each company/emitter would have a row each.

So I used a programme called Open Refine to data-wrangle the data into that format and to save it as a comma-separated values file which is this Google sheet NZETS-2015-final-allocations-for-eligible-activities. Its a bit fiddly using Open Refine, so I won't describe how I did it.

This is the updated free emission unit allocation data from 2010 to 2015.

As usual, the big emitters get the most emission units! Of 4.417 million units allocated to industries, 90% went to 11 large companies. New Zealand Steel Development Limited, of arbitrage profits fame, gets 1,067,501 free units. New Zealand Aluminium Smelters Limited gets 772,706 free units.

I did a bit of data visualising and created this pie-chart in R programming language.

The R script for that is

	# read in data downloaded from Google Sheets as a dataframe
	nzu2015 <- read.csv("nzu-allocation-2015.csv",skip=0,header=TRUE, sep = ",",dec=".",na.strings ='na')
	# examine the dataframe
	str(nzu2015)
	'data.frame': 108 obs. of 4 variables:
	$ Year : int 2015 2015 2015 2015 2015 2015 2015 2015 2015 2015 ...
	$ Applicants.Name : Factor w/ 97 levels "ACI Operations NZ Limited",..: 53 31 94 9 59 96 58 23 36 15 ...
	$ Activity : Factor w/ 26 levels "Aluminium Smelting",..: 1 2 2 3 4 5 6 7 7 8 ...
	$ Final.Unit.Entitlement: int 772706 152951 3089 173906 13271 79585 9927 325532 184794 1563 ...
	# How many emission units were given to emitter industries in 2015?
	sum(nzu2015[["Final.Unit.Entitlement"]] )
	[1] 4329248
	# How many units given to the top 12 emitters?
	sum(nzu2015[["Final.Unit.Entitlement"]][1:12])
	[1] 3960716
	# call that number 'therest'
	therest<-sum(nzu2015[["Final.Unit.Entitlement"]][1:12])
	therest
	[1] 3960716
	total <-sum(nzu2015[["Final.Unit.Entitlement"]])
	# look at the top 12 allocations
	nzu2015[["Final.Unit.Entitlement"]][1:12]
	[1] 1067501 772706 655851 325532 184794 173906 152951 148311 143262
	[10] 122825 121292 91785
	# who received the biggest 12 free allocations?
	nzu2015[["Applicants.Name"]][1:12]
	[1] New Zealand Steel Development Limited
	[2] New Zealand Aluminium Smelters Limited
	[3] Methanex New Zealand Limited
	[4] Fletcher Concrete and Infrastructure Limited
	[5] Holcim (New Zealand) Limited
	[6] Ballance Agri-Nutrients (Kapuni) Limited
	[7] Graymont (NZ) Limited (formerly McDonalds Lime Limited)
	[8] Oji Fibre Solutions (NZ) Limited (formerly Carter Holt Harvey Pulp & Paper Limited)
	[9] Oji Fibre Solutions (NZ) Limited (formerly Carter Holt Harvey Pulp & Paper Limited)
	[10] Norske Skog Tasman Limited
	[11] Pan Pac Forest Products Limited
	[12] Winstone Pulp International Limited
	97 Levels: ACI Operations NZ Limited ... Winstone Pulp International Limited
	# we have 2 allocations to Oji Fibre formerly known as Carter Holt Harvey Pulp and Paper Ltd
	[8] [9]
	148311 + 143262
	[1] 291573
	# How many units were given to all the other emitters?
	total - therest
	[1] 368532
	# set up the vector of the top 12 and the names
	units<-c(1067501, 772706, 655851, 325532, 291573, 184794, 173906, 152951, 122825, 121292, 91785,368532)
	names<-c("New Zealand Steel Development Ltd","NZ Aluminium Smelters Ltd","Methanex New Zealand Ltd", "Fletcher Concrete Ltd","Oji Fibre Solutions (ex CHH)","Holcim (NZ) Ltd","Ballance Agri-Nutrients","Graymont (ex McDonalds Lime)", "Norske Skog Tasman Ltd","Pan Pac Forest Products Ltd", "Winstone Pulp International Ltd","All others")
	png("nzu-allocations-pie-2015-680.png", width=680, height=510, pointsize = 14)
	pie(units,labels=c(names),radius = 0.95,clockwise = FALSE,init.angle=90, col = rainbow(13),cex.lab=1.1,cex.main=1.5,main="NZETS free allocation of emission units to industry 2015")
	mtext(side=1,cex=0.9,line=1.5, "Source: http://www.mfe.govt.nz/climate-change/reducing-greenhouse-gas-emissions/\nnew-zealand-emissions-trading-scheme/participatin-4")
	mtext(side=3,cex=0.9,line=-0.1,"Of 4.417 million units allocated to industry 90% went to 11 companies")
	dev.off()

view raw NZETS free allocation of emission units.r hosted with ❤ by GitHub

Did I not get the End the Rainbow memo? So I picked a better colour scale from Colour Brewer.

The R script for this non-rainbow pie chart is:

	mypalette<-brewer.pal(12, "Paired")
	png("nzu-allocations-pie2-2015-680.png", width=680, height=510, pointsize = 14)
	pie(units,labels=c(names),radius = 0.95,clockwise = FALSE,init.angle=90,col = mypalette, cex.lab=1.1,cex.main=1.5,main="NZETS free allocation of emission units to industry 2015")
	mtext(side=1,cex=0.9,line=1.5,"Source: http://www.mfe.govt.nz/climate-change/reducing-greenhouse-gas-emissions/\nnew-zealand-emissions-trading-scheme/participatin-4")
	mtext(side=3,cex=0.9,line=-0.1,"Of 4.417 million units allocated to industry 90% went to 11 companies")
	dev.off()

view raw NZETS-free-allocation-emission-units-industry-2015.r hosted with ❤ by GitHub

What are we waiting for?

In this guest post, the non - flying Wellington barrister and solicitor Tom Bennion writes about the International Civil Aviation Organization (ICAO) proposals for 'carbon-neutral' growth of greenhouse gas emissions from the fast-growing aviation industry.

New Zealand parents often tell their children not to eat too many sweets. Our primary schools spend a lot of time talking about suitable diets. We do this because we have the long term interests of our children at heart.

I find the contrast between that and how we currently approach climate change disheartening and distressing and especially when I consider all the families I know who are now taking flying holidays with their children.

This is a really uncomfortable topic. But we have to talk about it, and do so urgently.

We should, by now, all know the math. There isnt any personal activity we or our children can engage in that is even remotely close to air travel in terms of the sheer volume of greenhouse gas emissions it produces.

Google tells me that a Boeing 747 burns roughly 12 litres of aviation gas per kilometer. That is pretty good economy for carrying 500 people a short distance. But not if you are flying 18,819 km, the distance from Wellington to London and back. In that case, every person on the flight is responsible for consuming 450 litres of fuel. To put that in perspective, imagine if, instead of taking that trip, you revved up an average family car in your driveway to 100km/hr and at 6 litres per 100km you would need to leave it running for 75 hours or 3 days. Then repeat that for each family member that took the trip.

If you did that in your neighbourhood, you would be called a crass and thoughtless person, and people might wonder what sort of children you were raising.

In addition, these figures dont address the fact that the warming effect of aviation gas burned at altitude is around 2-3 times the impact when burned at sea level. So make that 6-9 days of car revving for each family member.

We also know that the emissions from our plane trips this year and this decade will continue to heat the planet for hundreds of years.

It isnt necessary to bang on about how bad things will get if we keep doing this. We already have an inkling from worldwide weather trends in the last 12 months. The thing to bear in mind is that the emissions we are contributing so hugely to through air travel are a severe threat to the future lives of our children, a much greater threat than a bad diet.

In the face of all of this, we have to accept, I think, that at the moment we are responding essentially with the instincts of small children: 
* We can see that we should stop this behaviour but wont because it would inconvenience us, be 'too hard' and 'everyone else is doing it'.
* We dont like to talk about it. We mumble an excuse and move away if it comes up.
* If we have to confront it, conversations quickly get tense as we get defensive about our reasons for keeping on with this clearly inappropriate behaviour.
* We avoid mentioning the issue with our own children because we know they would instantly spot our hypocrisy. In addition, and maybe this is the worst of it, by taking them on a flying holiday with us, we implicate them in our bad behaviour.

In uncomfortable situations like this we are anxious for good news. Here it is. All the members of the International Civil Aviation Organisation (ICAO), that is, essentially all UN member states, five years ago adopted a goal of carbon neutral growth after 2020.

You may wonder how or why the ICAO picked on 2020 as a benchmark in the first place. I dont know. No one does. It has no bearing on reality, no bearing on trying to avoid dangerous climate change by keeping within the global average temperature rise within 1.5 of 2 degrees, and isnt intended to.

It's the best that can be politically extracted from 190 odd nation states who know that their home populations are acting like children and wont forgive them if they try to have a serious conversation about reducing airline emissions.

Here are some of the problems with the ICAO goal:
* the ICAO has been promising action for ages. It got the mandate to work on reducing aviation greenhouse gases in the 1997 Kyoto Protocol.
* The ICAO plan doesnt cover domestic aviation - thats about 30% of aviation emissions.
* By 2020 annual emissions will be around 1000 megatonnes. And there is no plan to reduce them at all, just to hold the annual level to about 1000 megatonnes.
* Even after making heroic assumptions about how much new airplane developments can cut back on some emissions, the ICAO has calculated that it can only meet its target with offsets.

That's right, the emissions from our holiday flights in 2020 will be fine because someone else somewhere else (the details dont need to concern us) is going to promise to grow some trees and keep them growing until around 2400 or so. I dont think hubris really captures it. Its the sort of fantasy that only children could indulge in.

And lastly, and here is the real kicker, the ICAO isn't going to do pretty much any of this. Its just announced that its about to reset the start date of its proposal so it wont be compulsory for any nations until 2027, and will allow for whole sectors of aviation to aggregate their emissions. So there will be lots of delay and massaging of numbers. We all know what happened with the fraudulent carbon credits under New Zealand's emissions trading scheme, and, with the fantasy thinking of offsets thrown in, I expect you can see where all of this is heading.

No surprises that the New Zealand Government has announced that its happy with the scheme, provided everyone else signs on with them of course.

This also means, obviously, that when your local airline tells you it supports the ICAO approach, has purchased some electric cars or is putting solar panels on the roof of the airport, or planting some trees for you to fly over in their planes, but hasnt yet switched its entire air fleet to biofuels or done something as blindingly obvious as stopping its airpoints programme, you can just politely ignore them.

There is a technical term for this refusal to face reality. Its called cognitive dissonance. That is, juxtaposing two contradictory ideas and finding ways to manage the mental chasm between them. In this case its not just the contradiction between our personal carbon emissions from air travel and stated concern about climate change, its the fact that as parents we care for our kids while managing the secret knowledge that we risk literally shortening their lives and most certainly the lives of their own children.

I am selfish. My worry is that future children will look at our thousands of travel photos alongside the news headlines about record-setting heat, storms, floods etc, and wont just label us childish. Sociopaths is the terms we use for people with a sense of entitlement so strong that they would prefer mass death over personal discomfort and unease. But maybe they will just call us cowards. Then again, they might get inventive and call us child abusers.

I think we need to be uncomfortable for a little bit. We are adults. Adults can examine the situation rationally, and tell our kids that the hypermobile life of flying holidays we have been creating for ourselves and them is going to put us all in danger and has to go on hold. We all have a habitable planet to save right now.

So get out your airpoints statement. Explain to the kids you are donating all of them to forest planting. Tell them that holidays from now on will be a bit closer to home, and that overseas flights are special, rare things, that we will reserve for them when they are older, when they are adults and we have made sure the world is safe again.

Is it in the spirit of the Paris Agreement to ratify it with more emissions and more creative accounting?

Is the New Zealand Government's plan to ratify the Paris Agreement in 2016 consistent with a two degrees Celsius (2C) carbon budget?

Since the December 2015 Paris Agreement, the British climate scientist Kevin Anderson has given a couple of talks with the title Beyond Dangerous Climate Change: Does Paris Lock-out 2 Degrees?

Anderson's message is that although the Paris Agreement was a diplomatic triumph, it relies on speculative utopian technological fixes (bio-energy carbon capture and storage) in the future in order to reconcile the now extremely limited carbon budgets consistent with the desired 2C (and 1.5C) temperature limits with business-as-usual economics and politics. In other words, the Paris Agreement locks out the 2C target.

Why do I mention that? Because I want to run a 'Kevin Anderson' ruler over the New Zealand Government's recently announced ratification of the Paris Agreement. To conduct a bare assessment of New Zealand's emissions taking account that it is the cumulative emissions that determine warming. I want to ask the question 'does the New Zealand ratification also lock out any policies for emissions reductions consistent with a fair share of a 2 degrees Celsius carbon budget?'

To set the context, I'll set out some of the mechanics of what ratification of the Paris Agreement will require in New Zealand. Then in true Kevin Anderson style there will be a look at projected emissions and some graphs.

As we know, last month, on 17 August 2016, Minister for Climate Change Issues Paula Bennett announced that New Zealand would ratify the Paris Agreement this year.

Bennett's announcement represented a change in position as in April she had told Fairfax's Tracy Watkins that she was not rushing to ratify the agreement in the next couple of months

A cabinet paper from Paula Bennett "Paris Climate Change Agreement - Report back to Cabinet and Approval for Signature" has been on the Ministry for the Environment website since April 2016.

We also know from the Ministry of Foreign Affairs and Trade (MFAT) that ratification of the Paris Agreement will involve:

"..presenting the agreement and a national interest analysis to Parliament for examination by a select committee, after which the select committee tables a report in the House. After this, legislation may be passed and then New Zealand may ratify the Agreement".

The "Paris Agreement National Interest Analysis" was very briefly open for submissions on the New Zealand Parliament website until 2 September 2016.

The Ministry of the Environment has a Paris Agreement webpage. This confirms that once Parliament agrees to ratification (and enacts legislation), the Government will deposit the ‘instrument of ratification’ with the UN Secretary General before the next international UNFCCC climate change meeting in Morocco (COP22) in November 2016.

Therefore, some stepping stones are apparent. There will be a Parliamentary Select Committee considering the National Interest Analysis and submissions. That Parliamentary process has its shadow process, the Ministry for the Environment driven, and therefore more Government-controlled, review of the New Zealand Emissions Trading Scheme. Some amending legislation will probably be presented as the outcome of both processes.

A crucial point will of course be the detail of this amending legislation.

Paula Bennett has stated that the Government has "absolutely no intention of changing our target" (the New Zealand 2030 climate change target), and that the required 'Paris' legislation will be nothing major. Therefore, as she stated to Radio New Zealand, the New Zealand Emissions Trading Scheme will only need to be tweaked to meet the commitments under the Paris Agreement.

So the amendments will be to the Climate Change Response Act 2002 which is the statute that incorporates the United Nations Framework Convention on Climate Change (UNFCCC) and the Kyoto Protocol into New Zealand law. The UNFCCC is included as the first schedule to the act and the Kyoto Protocol is included as the second schedule.

The amendments will probably affect the provisions describing the operation of the New Zealand Emissions Trading Scheme (which has been under review all of 2016). Perhaps the Paris Agreement will be incorporated as a further schedule.

The current highly conditional New Zealand INDC (Intended National Determined Contribution), otherwise known as the 2030 climate change target, will become a NDC National Determined Contribution. Professor Ralph Sims notes that the NDCs "will need to be based largely on domestic mitigation actions" but "they are not legally binding".

Ralph Sims, who was writing back in February, was hopeful that the New Zealand NDC would be strengthened to be more ambitious, given that the sum of the 2015 INDCs "collectively would lead to an untenable 2.7 – 3 degrees Celsius future, rather than restrict global warming below the internationally agreed 2 degrees Celsius above pre-industrial levels" He seemed to have some hope that the then yet-to-be published Royal Society climate mitigation report would contribute to that.

So does that mean the Government will actually do something to reduce domestic emissions? Perhaps toughen up the emissions trading scheme, so that it uses only New Zealand units and has a fixed cap (as in 'cap and trade'), and auctioning units instead of free generous allocation of units to industry? No, of course not!

The National Interest Analysis continues on paragraph 104 on page 30:

"We have assumed that New Zealand will be able to purchase sufficient international emissions reductions in the 2020s".

So instead of domestic emissions reductions, we are betting the farm on the magic of the market, more speculative emissions trading, open access to and availability of international emission units from international carbon markets. However, this is no sure thing. Table 5 on page 15 states (my emphasis):

"The (Paris) Agreement provides for a centralised market mechanism and also allows other approaches to be developed by Parties. When and how the centralised market mechanism will be operationalised is unclear, and it may not provide a timely and sufficient supply of emission reductions to be economically practical for New Zealand’s use.".

So no pressure, New Zealand! The analysis then lists the many steps/obstacles on and in the way of New Zealand having access to functioning international carbon markets.

"This means that New Zealand will likely need to build future international markets from the bottom up in cooperation with other willing participants. New Zealand must: find willing trading partners, develop standards (including working with others) to ensure international carbon markets can function effectively (eg, on environmental integrity and unit registries), ensure that its trading activities are consistent with any future accounting requirements".

Paragraph 64 on page 19 of the Paris Agreement National Interest Analysis then states:

"New Zealand’s first nationally determined contribution (i.e. the 2030 target) was developed on the basis that New Zealand will achieve the 2030 target through a combination of domestic emission reductions, forestry growth and participation in international carbon markets."

Where have we heard that before? Back when I looked at the creative accounting for the 2020 emissions reduction target.

Surely, if the Government says it intends to adopt a mix of policies, one of which is domestic emission reductions, then some domestic emission reductions will actually happen?

Well perhaps we could look for the reductions in domestic emissions in the Ministry for the Environment's projections of future emissions "with measures" and "without measures" out to 2030. These are in the report New Zealand’s Second Biennial Report under the United Nations Framework Convention on Climate Change released in December 2015. This is the report where the only substantive differences between the with and without energy sector projections were the closure of the Huntly Thermal Power Station which then got reversed. Thus cancelling the projected decline.

At the time of their release in late December 2015, Radio New Zealand reported the complete inconsistency with the freshly-signed Paris Agreement; Emissions set to far outstrip Paris target. And they quoted an expert.

"Suzi Kerr, a senior fellow at economic research institute Motu, said the projections were completely incompatible with the target New Zealand took to the Paris climate change talks"

Here is a chart of these incompatible projected emissions from 2013 to 2030 by sector. The emissions for all sectors are all expected to increase. For the land-use, land-use change and forests (LULUCF) sector, the net carbon absorbed (or sequestered) is displayed as negative emissions and is projected to decline.

Here is another chart of the projected gross emissions (without LULUCF) and the LULUCF carbon sequestration (shown as negative emissions). The LULUCF 'credits' are subtracted from the gross emissions to get net emissions (the red line and dots) which is the real measure of what gets into the atmosphere. Note that the forestry sequestration is declining towards zero through the 2020s, but is still a net 'sink' of emissions.

However, wasn't there meant to be a 'wall of wood' in the 2020s? Of wholescale harvesting or land-use change of the 1990s pine forests that would tip the net carbon sequestration from the forests into being a net source of deforestation emissions in the 2020s.

Paul Young of the Morgan Foundation has looked at the issue and has concluded that the Government is pushing to change the rules used for accounting for forest carbon.

"They intend to switch to an 'averaging' approach, which will completely remove the planting and harvest cycle once a plantation forest reaches maturity. This change actually seems sensible; the problem is that we are changing the rules halfway through the game, in a way that directly favours us. If we had used the proposed rules from the beginning, New Zealand would receive far fewer forestry credits up to 2020"

We can look at this issue by comparing the current (December 2015) projections for the forests/LULUCF sector with the previous projections that were in the 2013 Sixth National Communication.

It seems very obvious that the Ministry for the Environment have used a very different definition of sequestered forest carbon in 2015 from the definition used in 2013. By my calculation they have found an extra 248 million tonnes of carbon in the decade from 2020 to 2030. That change in accounting treatment has changed the 'sign' of the signal. A decade of net deforestation has changed into a decade of net storage. That is inspite of the fact that the wall of wood of harvesting is still expected in the 2020s.

Paul Young is also still concerned the the Government has not ruled out using the surplus emissions units to comply with the 2030 target. Its not mentioned in either the Cabinet paper or the National Interest Analysis, so I asked Minister Bennett's office that question and I am waiting for a response.

Time for a conclusion. Is the New Zealand ratification of the Paris Agreement going to help or hinder the agreement's ambitious goals?

The ratification reveals that New Zealand will be doing what it's always done under the UNFCCC. New Zealand's greenhouse gas emissions are expected to rise and our policy response is more creative accounting and forest fudging. Our speculative utopian techno-fix is emissions trading. The New Zealand Government simply has no policies for reducing domestic emissions, let alone have policies that are consistent with a fair share of a 2 degrees Celsius carbon budget.

The Ministry for the Environment's disavowed orphan carbon budget

Did you know that the Ministry for the Environment prepared a 'two degrees' carbon budget in 2014?

The relevant report "Potential long-term pathways to a low carbon economy for New Zealand", Wellington, Ministry for the Environment, August 2014, is not available from the Ministry's web page. However, I requested it from the Ministry via the 'For Your Information' website.

Incredibly, Idiot Savant had a blog post about it up at No Right Turn on Friday titled Climate change: No path to lower emissions under National before I had even updated the status of my Official Information Act request on FYI.

The paper explicitly sets out to explore a New Zealand carbon dioxide budget consistent with limiting eventual global warming to two degrees Celsius, using the contraction and convergence method.

Presumably because of that aim, the paper appears to have been completely disavowed by the Ministry for the Environment. The cover letter replying to my request at FYI states that the report is neither formal advice to the Government nor is it Ministry policy. The report has a header stating that it is 'sensitive' and 'Not Government or Ministry policy'. There is an italicised inserted 'Note' saying that Treasury does not agree that contraction and convergence is an appropriate measure of a 'fair share'.

The guts of the report are three carbon budgets (a 10th percentile, a median and a 90th percentile) based on applying contraction and convergence to one of the IPCC two degrees-consistent carbon budgets. Oddly, the working calculations and the actual budget amounts are omitted. I guess I can just make another request for them. The budgets are only presented in this graph.

Geoff Simmons fact checks Paula Bennett's claim that the surplus units are clean

Geoff Simmons fact-checks Paula Bennett on the integrity of the surplus emission units. But has Geoff had a reverse make-over? Contact lenses instead of glasses? Whats happened to the wild shirts?

The Morgan Foundation's Geoff Simmons has done a whiteboard Friday video on Minister for Climate Change Issues Paula Bennett's claim that the surplus emission units are not tainted by the 97 million fake Russian and Ukrainian emission reduction units that the Climate Cheats report of April 2016 showed had been handed to the Government under the NZ emissions trading scheme.

Geoff explains the issue very well and has the numbers right. You can verify for yourself that the Government intends to use the surplus units to allow greenhouse gas emissions to increase out to 2020 while claiming that New Zealand is 'meeting' it's "minus 5%" emission reduction target. Just go to Latest update on New Zealand's 2020 net position on the Ministry for the Environment's website.

That webpage states explicitly that New Zealand will have 85.7 million emission units surplus after using some to meet the 2020 target. Here is a screenshot.

Further down the page is this barchart that shows that New Zealand's gross emissions from 2013 to 2020 are expected to be 655.9 million tonnes and that the baseline is 509.8 million tonnes.

Morgan Foundation's Climate Cheats II: Who’s the Real Cheat Here? The Dozen Dirty Now thats a title!

Geoff Simmons and the Morgan Foundation have done it again! They have just released a sequel to 'Climate Cheats', the fantastically-named 'Who’s the Real Cheat Here? Climate Cheats II: The Dozen Dirty Businesses'. Simon Johnson breathlessly reviews Climate Cheats II and concludes that while it's about time we had some transparency over Government and corporate shenanigans with emissions trading, we mustn't forget that these are symptoms of the root problem - the uncapped design of the New Zealand emissions trading scheme.

Shock Newsflash Horror! The Morgan Foundation and Geoff "Wild-Shirt" Simmons have done it again! They have just released another tell-all critique of corporate emissions trading shenanigans! A sequel in the franchise they started in April 2016 with the report Climate Cheats. As we know, 'Cheats I' outlined this sad course of events:

• the 'flood' of low-cost and low-integrity Russian and Ukrainian emissions reduction units into the NZ emission unit market
• which then crashed the domestic emission unit price
• which allowed NZ emitters to meet emissions trading obligations for next to nothing
• which allowed the Government to own surplus (but dodgy) units
• which meant Paula Bennett could claim 'form over substance' compliance with climate charge targets out to 2020
• not withstanding the real increases in both gross and net NZ emissions of greenhouse gases.

Weighing in at a thankfully concise 16 pages, the wonderfully named 'Who’s the Real Cheat Here? Climate Cheats II: The Dozen Dirty Businesses' starts with a simple question. Which companies had the most dodgy Russian and Ukrainian emission units? Well, here they are.

Simmons and co then note that Minister Bennett has refused requests to cancel the surplus dodgy units the Government holds, giving the excuse she is 'seeking advice' (That would seem to be a perpetually applicable excuse!). So they ask 'who owned and used dodgy emission reduction units?' The dirty dozen corporates, of course.

The report then discusses three types of liability (physical, liability and transition) that may fall on companies who used the emission reduction units. To paraphrase, Simmons is thinking 'did they really think this would never come back and bit them?' And he is making the point that if Government is failing to act ethically, then why don't we shine a spotlight on our corporate citizens and ask them to shoulder some of the responsibility for the dodgy unit fiasco?

Simmons assigns highest culpability to New Zealand Steel and Fonterra. Because they are emitters who received generous free allocations of NZ units but who also owned dodgy emission reduction units. Referencing a blogger (meaning me!), the report notes New Zealand Steel booked $4.4 million Australian dollars of profit from emissions trading that is probably from arbitrage trading of their free NZ units while also owning dodgy units.

Five forestry companies are on the dozen list. Some sympathy is due to some of them as the unit price crash devalued their allocations of units. But none is due to any foresters who carried out 'forest re-registration arbitrage' in the ETS. This was exiting and re-entering the same forest in and out of the ETS several times. For each ETS 'exit', the forester would 'square-up' the refund of carbon liabilities with emission reduction units costing several cents each. For each 're-entry' to the ETS, the forester would be given an allocation of free NZ emissions units worth a few dollars each. The result being instant no-effort windfall profits. The Government took far to long to clamp down on this practice.

Finally, energy companies get their turn in the spotlight. BP, Chevron, Z Energy, Contact Energy and Genesis Energy all owned and used some dodgy international units. Did these companies price their products to NZ customers on the basis of the higher NZ unit prices or the lower dodgy unit price? The Morgan Foundation approached the energy companies for comment which is in an appendix. All give worthy statements saying they followed the rules and of course they put customers first. However, Mobil shows up the fine words of the others. Mobil never owned any dodgy international units and managed to supply fuel just as competitively as the others.

Climate Cheats II concludes by suggesting that the companies who owned dodgy international units and lowered their costs (as well as those who made windfall profits) have two options to put things right.

1. They could voluntarily cancel NZ units to match the dodgy units used
2. They could alternatively pressure Paula Bennett to cancel the surplus units the Government holds.

With NZ emission unit prices now hovering between $17 and $18 per tonne, the latter option will hurt much less than the former.

In summary, it's hard not to like a Morgan Foundation report that references me! But leaving that bias/good taste aside, Climate Cheats II is a concise readable summary of the abject state of New Zealand's emissions targets and trading policies and practices. As Kevin Anderson would say, we need to see clearly where our rose-tinted spectacles have brought us. Climate Cheats II mostly does that.

However, if anything, the report, by focusing on the top dozen owners of the dodgy international units, underplays the persuasiveness of the ownership and use of those international units. Most entities with emissions trading accounts owned some dodgy units. In 2013, more than 400 entities (out of 496 account holders) owned some share of the almost 35 million emission reduction units in private hands. You can check this with this Google sheet of Kyoto Units obtained from the Emission Unit Register at the EPA.

Finally, I have one concern which is perhaps more about how 'Climate Cheats II' will be received rather than what message it has. It seemed to me that the media response to initial splash of 'Climate Cheats I' (they loved the emotive framing - 'fraud!' - 'cheating!') really missed the fundamental point that I think both reports support, and that other assessments of the ETS support, that an emissions trading scheme that has no cap on emissions, that earns no revenue and that isn't economy-wide, is an excuse and rationalisation for doing nothing and not an effective mitigation policy at all.

Where is the Two Degrees Celsius Carbon Budget for New Zealand?

I have been reading up about carbon budgets on and off since the Paris Agreement at COP21 last December.

By 'carbon budget' I mean "a finite amount of carbon that can be burnt before it becomes unlikely we can avoid more than two degrees of global warming". And I have been asking myself "where is New Zealand's carbon budget that is consistent with no more than two degrees Celsius of average global warming"?

I see that Canadians Simon Donner and Kirsten Zickfield asked themselves similar questions about Canadas contribution to meeting the Paris temperature targets and Can Canada live up to the promise of the Paris Agreement? The chart on the left shows three Canadian 'temperature' budgets/emission pathways under a share of emissions approach.

In short, Donner and Zickfield have calculated several "2C"-consistent carbon budgets, based on a range of temperature goals, a range of probabilities of success, and a range of sharing principles used for allocating part of the global carbon budget to Canada. They wrapped that up in a short 3-page paper "Canada’s Contribution to meeting the temperature limits in the Paris Climate Agreement".

Simon Donner also wrote a more policy-oriented summary What do the temperature targets mean for Canada?

This is their summary table of budgets by temperature targets and probabilities.

Simon Donner's conclusion from Can Canada live up to the promise of the Paris Agreement is:

The analysis in our report suggests that the current Canadian target of a 30% reduction below 2005 levels by 2030 could be consistent with maintaining a likely chance (66%) of limiting warming to less than 2°C globally, but only if Canada is given a generous allocation of the world’s “remaining” future carbon budget (based on the present fraction of the world’s emissions). A target consistent with a likely (66%) chance of avoiding 1.5°C of warming globally is extremely limited regardless of the method of allocation. Even under a generous allocation to Canada, national net CO2 emissions would need to decline 90-99% below 2005 levels by 2030.

Simon Donner also notes that "The 1.5°C limit is “at best unrealistic, at worst politically impossible.”

Simon Donner is also highly aware that 'sharing-on-current-emissions' unfairly favours developed highly carbon-intensive OECD countries like Canada (or New Zealand) over the developing countries with much lower greenhouse gas emissions per capita.

Allocating the remaining carbon budget based on present-day emissions places an unfair burden on developing and rapidly industrializing countries that historically have had low per-capita emissions. Despite being far less responsible for climate change to date, and currently having low per-capita emissions, countries like India would essentially be asked to bear an equal part of future mitigation efforts.

Good work Canada! But where the bloody hell is New Zealand's 2C consistent carbon budget?

Kevin Anderson Beyond Dangerous Climate Change Does Paris Lock-out 2 Degrees?

There is another new talk by Kevin Anderson. The image is his title page and the title is Beyond Dangerous Climate Change: Does Paris Lock-out 2 Degrees?.

Kevin Anderson gave the talk on 9th of March 2016 to the Institute of International and European Affairs which is Ireland’s leading think tank on European and International affairs. They describe his message in this way.

In his presentation, Kevin Anderson revisited the scale of the climate challenge, arguing that whilst the science of climate change has progressed, there has been no corresponding acknowledgement of the rate at which our emissions from energy need to be reduced. He suggested that the Paris Agreement exemplifies this duality. Similarly, he argued that the focus on green growth continues to eclipse analysis which demonstrates the need for radical social as well as technical change. Prof. Anderson developed a quantitative framing of mitigation, based on IPCC carbon budgets, before finishing with more qualitative examples of what a genuine low-carbon future may contain.

Anderson's key message is that due to the constant privileging of economic analysis over physics, the finite carbon budget consistent with no more than two degrees Celsius of average global warming will only be achievable with an "outside" probability of 33% if the developed countries suppress energy demand and reduce carbon dioxide emissions by 10% each year and fully de-carbonise their energy sectors by 2035.

The talk is available as a podcast in mp3 format. Also available is Kevin Anderson's slide presentation.

The talk is also available on Youtube in two parts. Part One has had 1,975 views. Part Two has had 664 views.

I usually browse with Firefox and I have installed an add-on called Down load helper. That enables me to download talks as mp4 files I can listen to later.

There are two differences from the talk given to the University of Sheffield. The sound is a bit boomy and not as clear as the University of Sheffield recording. And when Kevin Anderson says "people with grey hair or no hair have failed the generation born since the IPCC was established", the grey-hairs seems to be the audience from the two in the foreground.

New Kevin Anderson talk Delivering 2 Degrees Triumph and Tragedy in Paris

The other day I noticed that Kevin Anderson has tweeted a new talk.

Anderson spoke at the University of Sheffield on 28 April 2016. Anderson's host was the Carbon Neutral University Network Sheffield and they provide a fulsome description of Anderson's 47 minute talk. However, you should watch it for yourself or better still download the talk from Youtube. The sound quality is very good.

Minister for Climate Change Issues Paula Bennett and the surplus emission units

A wee while ago, back on 23 May to be precise, I wrote an open letter to Minister for Climate Change Issues Paula Bennett calling on her to cancel the surplus Kyoto emission units held by the Crown.

I received an undated reply from Bennett on Monday 4 July 2016.

To crudely sum it up, Bennett's reply is "No we won't cancel any units. Those bad bad Ukrainian units! It was bad. But we stopped being bad, we won't bad again, at any rate no more bad than any one else!"

Here is the text of Bennett's letter. For reference, I have put the text of my open letter at the bottom of this post.

Thank you for your letter of 23 May 2016 about surplus Kyoto Protocol assigned amount units.

As you say, the Government has a surplus of 123.7 million Kyoto Protocol emission units which were left over after we retired units to meet our target for the first Kyoto commitment period.

I accept that there were up to 97 million Emission Reduction Units (ERUs) bought and surrendered in the New Zealand Emissions Trading Scheme (NZ ETS) before the Government stopped accepting them. That was within the rules, but we now know many of the ERUs are likely to have had poor environmental integrity. We are not accepting international units now, and we are working hard to make sure any international units traded in the NZ ETS in the future are of high environmental integrity. We are reviewing the NZ ETS to make sure it will be fit for purpose in the future.

As we have said in the past, we will meet our target of -5 per cent by 2020 using a combination of domestic abatement, forestry removals, and some international purchasing. There is information about the target on the Ministry for the Environment website at www.mfe.govt.nz.

We have not made a decision about what to do with any Kyoto units that are left over after we have met the 2020 target.

Nearly all other Kyoto developed countries also have surpluses. Some of them have said they will cancel units, but haven't actually cancelled them yet. There is no urgency to do anything with these units, and the fact that we are not cancelling them at this stage doesn't put us out of step with other countries.

---

Let's look a little harder at three statements in Bennett's letter.

1. "We are not accepting international units now"
   Bennett is implying that the New Zealand Government made an express decision to stop the importing of some low-integrity international emission units. In fact, New Zealand ended up with no access to international carbon markets when Tim Groser told the UNFCCC that New Zealand was not going to have a formal emissions reduction commitment under the Kyoto Protocol for 2013 to 2020. Ms Bennett and the Ministry for the Environment should stop implying that some positive decision was made. Its just not true.
2. "we will meet our target of -5 per cent by 2020 using a combination of domestic abatement, forestry removals, and some international purchasing."
   The translation of this spin back into plain language is 'we will still be using creative carbon accounting' to pretend we are reducing emissions when we know we are not. Bennett should really stop saying such a disingenuous statement. The Ministry for the Environment's 2020 Net Position Statement still explicitly shows the 123.7 million surplus units plugging the gap.
3. "not cancelling them... doesn't put us out of step with other countries"
   Heaven forbid that New Zealand should be out of step with the many other countries who are also doing nothing about climate change!

My open letter to Paula Bennett - Your ethical duty to cancel 124 million surplus assigned amount units

Dear Minister,

I see that last Friday (20 May 2016) the Ministry for the Environment released New Zealand's Greenhouse Gas Inventory 1990–2014 and the summary 'Snapshot'.

I see that in the Snapshot summary on Figure 5, page 5, that New Zealand is still intending to use 123.7 million emission units (Assigned Amount Units or 'AAUs') that were 'surplus' from the Kyoto Protocol first Commitment Period to meet the 2020 emissions reduction target and still have a surplus of 92.6 million units.

You are aware that the Morgan Foundation's report 'Climate Cheats' and the Stockholm Environment Institute report (Kollmuss, Schneider and Zhezherin 2015) set out a persuasive case that the 97 million Emission Reduction Units ('ERUs') that were imported to New Zealand were “questionable or of low environmental integrity”. Those ERUs were surrendered by NZETS participants into Crown holding accounts.

According to the Kyoto Protocol 'True-Up' Report, in December 2015, the Ministry for the Environment cancelled (transferred Crown-owned units to cancellation accounts) 373 million emission units to comply with the Kyoto Protocol. The numbers and types of units cancelled were: the 97 million imported ERUs, 16 million imported Certified Emission Reduction units ('CERs'), 81 million removal units ('RMUs'), and 179 million AAUs . The 'surplus' units remaining in Crown holding accounts were 124 million AAUs.

In a nutshell, the only reason New Zealand (the Crown) has so many 'surplus' AAUs is because of the inflow and use of the dubious ERUs in the NZETS. Each dubious imported ERU has allowed one additional AAU to be carried forward in a Crown holding account as a 'surplus' unit. Because the ERUs have no credibility, the AAUs no longer represent carbon safely stored out of the atmosphere. No emissions were reduced. Therefore to use these surplus AAUs to comply with the national 2020 emission reduction target is simply an exercise in creative carbon accounting. It is simply unethical.

I put it to you that as Minister for Climate Change Issues, you are morally obliged to cancel these surplus units owned by the Crown. Will you cancel the units? It may hopefully to some small extent restore New Zealand’s very tarnished reputation with respect to mitigating climate change policy.

Yours sincerely

Turn off Meridian open letter to Mark Binns on why I am divesting from coal-pushing Meridian Energy

When is a renewable electricity generator not a renewable electricity generator? Or what do you do when the electricity generator who are claiming to supply your home with 100% renewable electricity enters into a commercial contract that keeps a coal-thermal power station emitting carbon dioxide for an additional four years?

Meridian Energy has recently signed a contract with Genesis Energy to keep the Huntly coal thermal power station open for four more years instead of closing in 2018.

New Zealand has made some predictions of future reductions in emissions that we have confidently sent off to the United Nations Framework Convention on Climate Change (UNFCCC). Unfortunately Meridian's action has had the effect of sending the emissions savings up in a puff of coal smoke.

So I decided to divest from Meridian Energy and move my account to electricity supplier to Ecotricity who own only 100% renewable generation capacity and who are certified as carbon neutral. I used the Consumer Power Switch website. There is also Whats my number web site.

I thought I should let Meridian Energy know I was voting with my account so I sent this open letter to Meridian Energy two weeks ago on 16 June 2016. I have not yet received a reply.

Mark Binns
Chief Executive
Meridian Energy Limited
PO Box 2128
Christchurch 8140

16 June 2016

Re: Meridian Energy’s support for four more years of thermal coal electricity carbon dioxide emissions from Huntly Power Station

Dear Mr Binns,

I am a Meridian retail customer. My customer number is TrJ5I19vcteK2 My account number is 1.h@"]41Y6x#5-r.

I consider climate change to be a serious risk that we are all morally obliged to respond to. In 2012 I deliberately chose Meridian as my electricity retailer because of it's 100% renewable generation.

I am aware that to some extent the electricity I consume inevitably draws on some fossil-fueled capacity due to the networked nature of the grid. However, I was satisfied that choosing Meridian as my retailer was the best I could do in terms of reducing carbon dioxide emissions as I would not be contributing my money to any fossil-fueled thermal generation. In the past four years I have been very happy with that choice and with the service I have received from Meridian. Unfortunately, I did not know that Meridian had a contract with Genesis to keep the Huntly coal thermal power station operating to 2018.

On 28th April 2016, Meridian Energy announced that it had signed a new contract with Genesis Energy that would keep the Huntly coal thermal power station operating for an extra four years. This contract therefore postpones the expected closure from the planned 2018 date to 2022. I have read the statement on the Meridian website explaining the contract as a means of reducing the risk of low levels in the hydro lakes. The explanation fails to take climate change seriously.

The Fifth Assessment Report of the IPCC sets out very simply the carbon budget consistent with limiting global warming to less than two degrees Celsius. The global warming we will experience will be linearly proportional to the cumulative volume of carbon dioxide emissions emitted by humanity. To prevent further dangerous levels of warming with a reasonable probability, cumulative emissions cannot exceed the carbon budget. At that point, emissions must not exceed net zero.

As a matter of physics, the additional emissions that will come from Huntly for the extra four years will result in higher and more dangerous eventual global warming. Meridian Energy's actions have facilitated these additional emissions.

I find Meridian’s actions to be completely contrary to the IPCC's finite carbon budget conception of mitigation and with Meridian’s previous statements on renewable electricity. Those statements now appear very shallow and insincerely held to say the least.

Therefore, it gives me some satisfaction to inform you I am moving my electricity account to a 100% renewable electricity generator who has carbon neutral certification and who is not a party of the Huntly contract. It is my sincere wish that as many customers as possible who are concerned about climate change also leave Meridian.

Yours sincerely

Emissions Trading Scheme unit allocations are open data but units surrendered and actual emissions are state secrets

It would be good if we could compare actual company emissions under the NZETS to the generous free allocations of unit some entities receive. But we can't. It's half secret. So how will we ever know if allocations are excessive?

Someone recently asked me if there was enough publicly available information to be able to tell how the free allocation of NZ emission units to some privileged ETS participants under the NZ Emissions Trading Scheme related to the emitters actual emissions of greenhouse gases.

This information would be the number of emission units allocated to some emitters on the one hand, and on the other hand, the actual emissions of the emitters as reported to the Environmental Protection Authority and the actual numbers of corresponding emission units they surrender to the Environmental Protection Authority.

I replied "No, the data is not available". A response which, although it contains a grain of truth, still doesn't reflect the whole story. So this post is an attempt at that story.

In the past few years, I have written several posts about the significance of the free allocation of emission units to New Zealand Aluminium Smelters Ltd, Norske Skog Tasman and New Zealand Steel. In each case I concluded that the free allocation of units (including units for energy costs) were excessive. That these were cases of 'over-allocation'.

In those posts I had to make estimates of the actual emissions and actual units surrendered. Although the Ministry for the Environment completely discloses the annual free allocation of units, neither the Ministry or the Environmental Protection Authority report the emissions and units surrendered by entity.

As I noted recently I have compiled a Google sheet of all units allocated to emitters from 2010 to 2014.

So good on the Ministry for the Environment. A while ago I made this pie chart of the 2011 allocations from the Ministry. Yes, awful rainbow colours I know! But it still makes it clear that the vast bulk of free units get allocated to the top ten or so emitters - who happen to also be some of New Zealand's largest and most influential companies.

I was running out of emitters like NZ Steel and NZ Aluminium Smelters Ltd who both have unique operations. Both are the only example of their industry in New Zealand. So I could look at 'category' emissions for 'aluminium smelting' and 'steel making from iron sands' in the Ministry for the Environment's greenhouse gas inventory reports and be confident the category emissions were the same as the company emissions.

So, back on 28 March 2013, I made a request under the Official Information Act (OIA) to the Environmental Protection Authority, who administer the reporting of emissions and surrendering of units in the ETS.

I asked for number of units surrendered by the top eleven ETS participants (New Zealand Steel Limited, New Zealand Aluminium Smelters Limited, Methanex New Zealand Limited, Fletcher Concrete and Infrastructure Limited, Ballance Agri-Nutrients Limited, Holcim (New Zealand) Limited, Carter Holt Harvey Pulp & Paper Limited, Pan Pac Forest Products Limited, McDonalds Lime Limited, Winstone Pulp International Limited, Whakatane Mill Limited) for 2010 and 2011.

On 18 April 2013, the Environmental Protection Authority declined my request.

On 19 April 2013 I made a complaint about the EPA decision to the Office of the Ombudsman.

Almost a year later, on 8 April 2014, the Ombudsman concluded his investigation and said that the EPA were correct in refusing to give me the information as the Climate Change Response Act 2002 explicitly applies to the surrender of units in priority to the Official Information Act 1982.

The Deputy Ombudsman Leo Donnelly advised that he agreed with the EPA view that they did not have to provide the information on units surrendered. This is the key passage from his letter dated 8 April 2014.

"I am not persuaded that the Official Information Act is an Act that provides for the disclosure of information in s 99(2)(a) of the Climate Change Response Act.
The Official Information Act confers a right to request official information and requires that such requests be processed in accordance with its provisions, but those provisions do not provide for the disclosure of information under the Climate Change Response Act (or any other Act that imposes restrictions on the availability of official information).
Instead, section 52(3)(b)(i) of the Official Information Act provides that nothing in that Act derogates from any provision which is contained in any other Act which imposes a prohibition or restriction in relation to the availability of official information. Section 99 is such a section.
Accordingly, the Official Information Act does not override the restrictions imposed by section 99 of the Climate Change Response Act and it would be contrary to that section for the requested information to be made available to you. Consequently, section 18(c)(1) of the Official Information Act provides a reason to refuse your request on that basis."

I was bloody disappointed with that response. Here is the Ombudsman's letter. I also didn't know that the Official Information Act only applies if another statute allows it too. I will look at the relevant sections in detail.

Section 52(3)(b)(i) of the Official Information Act states;

(3) Except as provided in sections 50 and 51, nothing in this Act derogates from—
(a) ....
(b) any provision which is contained in any other Act of Parliament or in any regulations within the meaning of the Regulations (Disallowance) Act 1989 (made by Order in Council and in force immediately before 1 July 1983) and which—
(i) imposes a prohibition or restriction in relation to the availability of official information;...

So if another statute (or regulation) prohibits or restricts the availability of official information, then that statute or regulation applies irrespective of the Official Information Act.

Section 99 of the Climate Change Response Act certainly appears to prohibit the availability of information. It states;

This section applies—
(a) to the chief executive, the EPA, an enforcement officer, and any other person who performs functions or exercises powers of the chief executive, the EPA, or an enforcement officer under this Part and Part 5; and
(b) at the time during which, and any time after which, those functions are performed or those powers are exercised.
(2) A person to whom this section applies—
(a) must keep confidential all information that comes into the person’s knowledge when performing any function or exercising any power under this Part and Part 5; and
(b) may not disclose any information specified in paragraph (a), except—
(i) with the consent of the person to whom the information relates or of the person to whom the information is confidential; or
(ii) to the extent that the information is already in the public domain; or
(iii) for the purposes of, or in connection with, the exercise of powers conferred by this Part or for the administration of this Act; or
(iiia) for the purposes of, or in connection with, reporting requirements of the Public Finance Act 1989; or (iv) as provided under this Act or any other Act; or
(v) in connection with any investigation or inquiry (whether or not preliminary to any proceedings) in respect of, or any proceedings for, an offence against this Act or any other Act; or
(vi) for the purpose of complying with any obligation under the Convention or the Protocol.
(3) A person to whom this section applies commits an offence under section 130 if the person knowingly contravenes this section.....

So why does the Ministry for the Environment publish the annual allocations of units on its website? Why is the policy for unit allocation effectively open data (with complete public disclosure) when the policy for emissions and units surrendered in the ETS, the policy is 'Official Secrets Act?

The answer is the perfect bureaucrat's answer, because the Act says so. Section 86B Decisions on applications for allocations of New Zealand units to industry and agriculture of the Climate Change Response Act states:

(5) The EPA must, as soon as practicable, after deciding an eligible person’s final allocation for an eligible activity in respect of a year,—
(a) publish the decision in the Gazette; and
(b) ensure it is accessible via the Internet site of the EPA.

Where does this leave us? It's the old story of the three-handed forestry consultant. 'On the one hand, on the second hand, but on the third hand..' Its great that the data on free allocation of units to emitters is fully disclosed. I am sure many of them wouldn't want that. However, without data on units surrendered and actual annual emissions under the ETS, no one can make much of an assessment of whether the units allocated are reasonable or over-allocated in terms of exceeding actual emissions. Transparency (and legitimacy) would be very much improved if the actual emissions and unit surrenders were just as open as the unit allocations

Saturday night listening White Valiant The Muttonbirds live in 1994

The Muttonbirds are a terrific band led by the indefatigable Don McGlashan in the 1990s.

Although Nature and The Heater are arguably better-known songs, this is the subtly disturbing 'White Valiant' played live in 1994.

Ah, that's great! I can't get enough! So here is another! It is the official video of 'Dominion Road', which was a single from their first album 'The Muttonbirds'.

An open letter to Minister for Climate Change Issues Paula Bennett cancel the dubious surplus units

In which I write to Paula Bennett and ask her to cancel the 124 million surplus emission units.

Paula Bennett's first act as the new Minister for Climate Change Issues was to announce that yes indeed New Zealand would be using creative carbon accounting and shuffling of dubious 'surplus' emissions units to meet the 2020 climate change target without actually reducing any emissions of greenhouse gases.

That approach became unstuck for Paula Bennett with the release of the Morgan Foundation's 'Climate Cheats' report.

Report author Geoff Simmons pretty convincingly put the case that if New Zealand has unethically benefited from buying dubious Ukrainian emission units, then Paula Bennett is ethically bound to cancel the remaining surplus units. I have heard no response, so I thought I would ask her myself. Hence this letter.

Hey why don't you write or email her too? Her email address is paula.bennett@parliament.govt.nz

The Hon Paula Bennett
Minister for Climate Change Issues
Parliament Office
Private Bag 18888
Parliament Buildings, Wellington 6160

23 May 2016

Your ethical duty to cancel 124 million surplus assigned amount units

Dear Minister,

I see that last Friday (20 May 2016) the Ministry for the Environment released New Zealand's Greenhouse Gas Inventory 1990–2014 and the summary 'Snapshot'.

I see that in the Snapshot summary on Figure 5, page 5, that New Zealand is still intending to use 123.7 million emission units (Assigned Amount Units or 'AAUs') that were 'surplus' from the Kyoto Protocol first Commitment Period to meet the 2020 emissions reduction target and still have a surplus of 92.6 million units.

You are aware that the Morgan Foundation's report 'Climate Cheats' and the Stockholm Environment Institute report (Kollmuss, Schneider and Zhezherin 2015) set out a persuasive case that the 97 million Emission Reduction Units ('ERUs') that were imported to New Zealand were “questionable or of low environmental integrity”. Those ERUs were surrendered by NZETS participants into Crown holding accounts.

According to the Kyoto Protocol 'True-Up' Report, in December 2015, the Ministry for the Environment cancelled (transferred Crown-owned units to cancellation accounts) 373 million emission units to comply with the Kyoto Protocol. The numbers and types of units cancelled were: the 97 million imported ERUs, 16 million imported Certified Emission Reduction units ('CERs'), 81 million removal units ('RMUs'), and 179 million AAUs . The 'surplus' units remaining in Crown holding accounts were 124 million AAUs.

In a nutshell, the only reason New Zealand (the Crown) has so many 'surplus' AAUs is because of the inflow and use of the dubious ERUs in the NZETS. Each dubious imported ERU has allowed one additional AAU to be carried forward in a Crown holding account as a 'surplus' unit. Because the ERUs have no credibility, the AAUs no longer represent carbon safely stored out of the atmosphere. No emissions were reduced. Therefore to use these surplus AAUs to comply with the national 2020 emission reduction target is simply an exercise in creative carbon accounting. It is simply unethical.

I put it to you that as Minister for Climate Change Issues, you are morally obliged to cancel these surplus units owned by the Crown. Will you cancel the units? It may hopefully to some small extent restore New Zealand’s very tarnished reputation with respect to mitigating climate change policy.

Yours sincerely

Helter smelter deja vu Tiwai Point smelter uncertainty stalls renewables for more Huntly coal