Climate Change Commission 2021 Report - Submission Guide!

Developed by Pacific Climate Warriors, SS4C, 350 Aotearoa, Generation Zero, Forest & Bird Youth, Oxfam, Zero Waste Network Aotearoa, The Rubbish Trip, Para Kore and Coal Action Network. Disability responsive climate change position, contributed by SustainedAbility.

With the Climate Change Commission’s advice comes a real opportunity to move forward. This is our chance. 

With your help, this will be a roadmap for a better Aotearoa for everyone. Together, we can create an equitable and Zero Carbon Future. Climate change affects individuals and communities to different extents and exacerbates existing inequities. We have an opportunity for climate action in Aotearoa to address intersecting issues including poverty and housing, and so much more. In other words, this can be a step towards climate justice, by centering intersectional social issues in the act of mitigating and adapting to the climate crisis. Now is our chance to create the kind of future we wish to have ourselves and pass on to our mokopuna.

The situation is urgent so any real action we can take makes a big difference. As the inaction continues, our generation is becoming more and more scared. We must realise the situation for what it is: a climate crisis, and act now. This starts with setting ambitious targets and taking meaningful action. It starts with comprehensive and meaningful engagement with Tangata Whenua, disabled people and our communities, younger generations and all structurally oppressed groups. We must go further for the sake of our future. This is our chance and we must seize it.

The closing date for submissions is 28th March 2021.


Make your submission here

You can complete an official submission at climatecommission.govt.nz.

After completing the 'Introduction' section, scroll to the bottom of the next page and choose ‘I want to continue with the consultation questions’. You can refer to our submission guide below for basic templates and inspiration to help answer the questions that follow.

  • Submissions are most effective when they are unique and authentic to the person who is writing it. They definitely do not need to be overly technical. You just need to share your story, why this issue matters to you and what specific change or action you want to see. Sharing your feelings and reasons for caring can be just as, if not more, effective as having a deep understanding of the ins-and-outs of the policy. We know it can be really daunting to write your own submission from scratch, and that this often means that young people don’t have their voices heard on important issues that will fundamentally impact them the most. For this reason, we are offering this template to make the submission writing process more accessible. But please remember that this is your chance to have your voice heard, and that the submission will have the most impact if it is not a direct copy-paste from the template below, but unique to you. Your voice matters - share it.
    • The Commission is looking for unique and authentic submissions to make sure you personalise the template below as much as you can.
    • You could add why this issue matters to you and how climate change affects you/ your community.
    • The below recommendations have been contributed to this template by various organisations across Aotearoa. These are the points our organisations believe should be changed or added to strengthen the Climate Change Commission’s advice. Feel free to copy/paste them if needed, but you’ll have the greatest impact if you write a couple out in your own sentences!
    • Please note that we have offered more general recommendations in Part One, and more focused recommendations in Part Two to respond to specific questions from the Commission.
  • *This template was written by many different groups and organisations to support you to make a submission on the Climate Change Commission’s draft advice. We acknowledge that we do not bring experience or expertise from all communities, or all sectors. Some climate action organisations involved in this group submission are still on the journey of understanding how best to support climate justice in Aotearoa. We acknowledge the current and past harms of focusing on a “zero carbon at all costs” approach to address climate change. Our organisations acknowledge the need and commit to progressing our understanding of climate justice, by giving space to climate justice organisations and structurally oppressed communities that are most impacted by climate change, while examining the power we hold in these spaces. This is also critically important mahi for the Climate Change Commission, and any agency or organisation implementing the Climate Change Commission's recommendations. This submission guide is not exhaustive, and we welcome feedback on how it could be improved.

Submission Guide:

Part One: Your 'One Big Thing'

The first part of the consultation gives you the opportunity to tell the Commission the one big thing that you feel is really important that they know.

My name is [insert name here]. I am [insert age here] and am from [insert where you are from here].

I care about climate justice because [insert your own sentences here].

    • We know that we are in the midst of a climate crisis and the Government has recognised it as such. Transformational and lasting change across society and the economy will be needed to address this crisis in a just, equitable and sustainable way.
    • The tools we need to reach our targets and address climate change in Aotearoa already exist, and have been practiced for centuries by Indigenous communities. We must recognise and uplift the knowledge and indigenous wisdom that will help get through the climate crisis and has long been held by Māori in Aotearoa and by Indigenous peoples all over the world. As we sit on the brink of environmental collapse, we must follow the leadership of Indigenous communities who have for so long been fighting for the protection of Papatūānuku, and those communities on the frontlines of pollution and climate impacts.
    • The land, air and water bind us together. Climate justice must create and foster the solidarity and equity needed to stand up for a liveable planet and fairer society. If, through our climate solutions, we ensure everyone will have what they need to thrive and fully participate, we are on the way to centering justice. Through the actions we take to mitigate and adapt to climate change, we must also work to repair historic oppression of frontline and vulnerable communities. As we have outlined, addressing the climate crisis and centering climate justice in this brings with it not only opportunities to rectify the balance between us as a people and the natural environment but also many opportunities to restore justice and balance in our society.
    • Working toward climate justice to ensure that no one gets left behind means acknowledging that climate change and it’s drivers negatively and disproportionately impact disabled people. These systems have actively oppressed disabled people throughout society, and the policies we currently have will not uphold disability rights and justice now and as the climate crisis escalates.
    • Disabled people and disabled communities are not passive victims of climate change; systematic oppression has made them vulnerable. Disabled people are leaders and innovators who have valuable climate solutions that will help everyone through the climate crisis. Disabled communities need to be supported and resourced to create an equitable future. When we create disability responsive solutions, all people benefit.
    • It is key that our narrative and approach must be one of intersectionality across all forms of oppression, including women and diverse genders - only with this narrative can we build the collective response necessary and ensure action we take to address the climate crisis recognises both the experiences and situations; past, present and future of communities, especially those already overburdened and marginalised, and works to restore equity.

    For these reasons I wish to make the following recommendations to He Pou a Rangi, Climate Change Commission [choose from our recommendations below and add your own]:

    • The Commission’s proposed budgets need to be substantially enhanced to create deeper emissions cuts over the next decade and better align with efforts to keep warming to 1.5 degrees.
    • We need better climate education so that each sector can confidently and knowledgeably transition to more sustainable practises, and so younger generations have the knowledge and are empowered to join our movement for climate justice.
    • The Commission’s advice must recognise New Zealand’s context as an island nation in the Pacific; our response and actions to addressing the climate crisis must consider the impacts on the Pacific region, and provide adequate support for Pacific island countries to adapt through greatly enhanced climate finance.
    • The focus on climate change expertise vs. representation may have impacted the perspectives on timeframes highlighted in the draft advice.
    • The commission’s proposed plan fails to approach the interconnectedness of the many crises we face, including the intersection between climate change and the biodiversity crisis. This is despite constant warnings from experts on both climate change and biodiversity.
    • To fully understand the intergenerational impacts of this proposed climate plan, the Commission must undertake meaningful youth engagement programmes. Future generations will have to live with the policies proposed in this report and their consequences - we deserve a seat at the table.
    • The commission must take into account all disabled people, disability rights and justice in its recommendations to the Government. I/we recommend that the commission set up a formal disability working group, in order to create equitable disability responsive recommendations and engagement.
    • We must also understand the wider social impacts of this proposed plan through undertaking meaningful community engagement. Structurally oppressed communities will be hardest hit if the government and Commission do not work alongside them and centre climate justice.
Part Two: The Six Big Issues

The Climate Change Commission has identified 6 issues that framed its thinking as it developed a path for Aotearoa to meet its domestic targets and international obligations.

Here are some of our thoughts to help guide your response to these questions. Choose the points that speak to you for each question and aim to expand on them with some of your own thoughts.

    • The Commission's approach is not ambitious enough. The first three carbon budgets take a very cautious and incremental approach to reducing emissions, requiring larger cuts in later years.
    • The emissions budgets should reflect New Zealand’s commitment to global equity and fulfillment of our obligation as a developed nation.
    • Agricultural climate pollution must be reduced further and faster.
    • The advice on waste should consider all waste streams, and consumption-based measurements.
    • The Intergovernmental Panel on Climate Change’s 1.5 degree report outlines that for a 66% chance of averting climate catastrophe, we must approach emissions reductions with deep cuts in emissions starting immediately. The Commission’s proposed approach is not ambitious enough and risks passing many tipping points, which would put us on a hothouse earth trajectory.
    • The Intergovernmental Panel on Climate Change’s 1.5 degree report outlines that for a 66% chance of averting climate catastrophe, we must approach emissions reductions with deep cuts in emissions starting immediately. The Commission’s proposed approach is not ambitious enough and risks passing many tipping points, which would put us on a hothouse earth trajectory.
    • I/we do not agree with the Commission’s plan to reduce as little agricultural methane as possible (the lower end of the target ranges - 13% by 2035 and 24% by 2050). We must aim for the most ambitious climate plan, not the least. I/we want to see more agricultural climate pollution reduced and faster.
    • The Commission's waste advice focuses on reducing methane emissions from organics that end up in landfills. However, long-lived GHG emissions are also generated from the extraction, production, transport and consumption of packaging and goods, which is intrinsic to our current, unsustainable ‘take-make-throw’ linear economy. To meet the 2050 emissions targets, the Commission should expand its advice to consider all waste streams, and build consumption-based measurements into its analysis.
    • No
    • We are a developed nation and must be doing more. For the sake of this planet and future generations, we simply cannot afford just to do the average. The recommendations unfairly burden future generations.
    • The cost of transitioning to a low-carbon future must fall on industries most responsible so that policies do not regressively impact low-income communities.
    • The articles of Te Tiriti should be integrated throughout the policy recommendations instead of using the Treaty Principles.
    • We need to work now to ensure a safe and positive climate future that includes structurally oppressed communities.
    • The report needs a greater focus on unions, a Just Transition, and building an accessible society, including considering the co-benefits of design for and by disabled people in the built environment.
    • The draft emissions budgets are inconsistent with a 1.5 degree pathway for 2030, particularly with the role New Zealand needs to take as a highly developed nation to do more than the average (our fair share).
    • Our approach to transitioning equitably must take into account our role as a developed nation that has historically contributed more than our fair share of emissions, and account for the high-polluting industries that have profited from decades of pollution with little consequence. It is essential that our actions account for our fair share to reduce the burden on future generations and communities on the frontlines of climate impacts, who have contributed the least to the problem but are paying the highest costs.
    • Our policy approaches to equity must ensure that the cost of transitioning to a low-carbon future falls on industries and companies most-responsible rather than individual consumers so that policies do not regressively impact low-income communities.
    • Situating the bulk of reductions in the 2030s puts an unfair burden on future generations compared to greater cuts this decade. Bringing more government direct investment in emissions reductions forward will share the burden of reductions more equitably, while also contributing to greater consistency with 1.5 degree pathways.
    • We must put in the work now to create a climate safe future that includes disabled people in our society and way of commerce.
    • The report must include the positive co-benefits of design, for and by disabled people in the built environment. When design is led by disabled people, for accessibility, in a way that centres our rights, this benefits disabled people as well as non-disabled people.
    • For a Just Transition, greater focus on building a more accessible society is crucial.
    • Unions are not mentioned once in the CCC’s advice; there needs to be a greater focus on unions and a Just Transition. We can deliver good, clean, living wage jobs to everybody that wants one.
    • I/we support the recognition that New Zealand’s current 2030 target under the Paris Agreement is not compatible with Aotearoa making a contribution to limit warming to 1.5C.
    • I/we agree that New Zealand’s fair contribution is “much more than 35% below 2005 gross levels by 2030”.
    • The Commission should publish and recommend to the Government a ‘fair share’ 2030 target in our NDC (nationally determined contribution), that reflects New Zealand’s outsized carbon footprint and historic responsibility for causing climate change.
    • The NDC should be met primarily through domestic emissions reductions, with offshore mitigation only being a last resort.
    • Climate finance to support communities on the frontlines of climate change to adapt should be a key part of supplementing our NDC emissions reduction target.
    • A fair share nationally determined contribution: A 2030 NDC target under the Paris Agreement for New Zealand that reflects our historical pollution and outsized carbon footprint (our fair share) would be far beyond 35% below 2005 levels by 2030. The 2030 target range (25-44%) the Commission uses to find emissions reductions consistent with IPCC pathways for 1.5 degrees represents what Aotearoa’s contribution would be if we did the average, and not our actual fair share.
    • The Commission should publish and recommend to the government a ‘fair share’ NDC using appropriate historical responsibility / capability / need calculators, that applies New Zealand’s differentiated obligations under the UN Framework Convention on Climate Change and the Paris Agreement to safe 1.5 degree pathways.
    • The form of the NDC should be primarily domestic emissions reductions and removals through strengthened emissions budgets [detailed in Q1-2], greatly enhanced climate finance to support those on the frontlines of climate change to adapt to impacts (as a non-mitigation contribution), and not overly rely on offshore mitigation. The opportunity costs of relying on offshore mitigation vs domestic reductions need to be communicated clearly to the public.
    • I/we support the commission’s focus on large reductions of carbon dioxide with as little reliance on emission removals by forestry as possible.
    • Our approach to forestry must consider how sovereignty will be returned to mana whenua to manage land, to uphold article 2 of Te Tiriti o Waitangi.
    • I/we support the significant increase in new native forests and the assumption that no further native deforestation occurs from 2025. All native habitats must be incorporated into this approach. For example, wetlands and tussock should be recognised for their role in storing carbon, and protected from destruction.
    • Our approach to forestry must address climate change while recognising the intersecting biodiversity crisis. I/we support the commission’s recommendation to reduce reliance on exotic forestry due to the damage it causes to native habitats. I/we suggest a stronger approach to restore and manage existing native habitats to allow for a reduction in the proposed exotic afforestation.
    • Transport
    • An active and public transport mode shift. Currently, the recommendations for active and public transport are not ambitious enough. Walking, cycling and public transport can and must play a much larger part in decarbonising the transport system. Design active transport systems that work for disabled people Greater focus on livable, compact, accessible and equitable cities. I/we support the proposals for converting internal combustion engine vehicles to EVs as a supporting measure for situations where alternatives to private vehicle ownership are not possible. Take into account any unintended consequences of mass EV adoption and co-create policy with those affected. A disability responsive EV policy is essential to ensure that disabled people can participate in all modes of low carbon transportation. Advise the Government that continuing to expand road capacity is incompatible with addressing climate change.
    • Energy
    • Much larger direct investment in energy efficiency is needed, especially as we work to make all of the housing stock accessible for disabled communities, and to enable secure life long housing options. Energy efficient homes must be financially affordable and physically accessible. More ambitious targets and bans on coal: Replace coal use in process heat for food production, specifically for the dairy industry, with renewable energy sources (not gas) by 2027. Ban new and expanded coal mines in Aotearoa, and an end date for all coal mining in Aotearoa - including coal mining for export. An immediate ban on any new coal mining on conservation land. Bring forward the phase out date for fossil fuel heating in new buildings to 2022. Make our biggest polluters pay by immediately ending subsidies via free carbon credits.
    • Agriculture
    • A sinking cap on synthetic nitrogen fertiliser, which eliminates it by 2024 A sinking cap on imported feed which eliminates it by 2024 A prohibition on all new dairy conversions, A maximum stocking rate limit, which is set low enough to drive a significant reduction in the national herd. Advise that agriculture enters the Emissions Trading Scheme in 2021 and with no subsidies
    • Waste
    • Provide more detail on the interventions needed to reduce organic waste to landfill Recommend binding reduction targets for all waste streams. Recommend waste levy revenue is invested in community-scale solutions at the top of the waste hierarchy Advise that measuring and increasing circularity in our economy is urgent Advise the government to strengthen its approach to product stewardship to ensure materials are kept in circulation and product lifespans are extended. Advise that products that cannot be effectively reused, repaired, recycled or composted should be designed out of the economy.
    • Health
    • Having minimal focus on health, and particularly on health savings from co-benefits, is a dangerous communication failure on the part of the Commission.
    • Equity
    • Indigenous peoples management of resources is crucial to equitable emissions reduction and approaches to climate action must reflect this importance. Support Māori governance of taonga by: Government to create binding best practices that require at least co-governance of land, water and air with whānau, hapū, iwi. Give full effect to Te Tiriti o Waitangi by initiating a process to implement the recommendations outlined by the Matike Mai report, in coordination with whānau, hapū and iwi While disability is mentioned in the report, this does not go far enough. The commission needs to expand on this with a disability-responsive position statement and work group recommendations, to ensure a just transition. Gender is not mentioned in the report once; yet climate change disproportionately impacts women and people of diverse genders. It’s vital that the Commission takes into account research on the gender impacts of climate change and climate action, and include this into their analysis.
    • Our View: Disagree
    • With existing technology we can achieve far more ambitious emissions budgets, stronger policy recommendations, and more stringent targets for heavy polluters, than the Commission’s draft proposals.
    • The Commission’s report currently misses the opportunity to highlight the cost of inaction.
    • Agriculture - The current pathway lacks ambition and should include a far greater amount of land-use change away from ruminant livestock farming and into native forest, horticulture and other plant-based and non-ruminant land-use.
    • Waste - The commission’s waste advice takes us in the right direction, but must be more specific, ambitious and holistic to harness the power of reduction and reuse strategies to reduce emissions. Increase organic waste reduction targets. Recommend binding waste reduction targets for all waste streams.