Letter to the Minister for Climate Change on the NDC

Last week, LCANZI wrote to the Minister for Climate Change, Hon James Shaw, regarding a significant error in the Climate Change Commission’s analysis on the updated NDC.

The IPCC’s 2018 Special Report determined the percentage reductions required to give us a 50-66% chance of limiting global warming to 1.5°C. In particular, net CO2 emissions must fall -40% to -58% from 2010 levels by 2030. The Commission has erred by applying these percentage reductions to Aotearoa NZ’s 2010 level of gross CO2 emissions, rather than the 2010 net CO2 level (net figures take into account carbon removals from forestry).

LCANZI correspondence with Stats NZ and the Ministry for the Environment confirmed that the IPCC’s percentage reductions must be applied to net 2010 figures, not gross 2010 figures in order to determine where we must be by 2030.

The result of the Commission’s calculation error is that they recommended an NDC which would allow between 14.713 and 21.019 Mt net CO2 in 2030, when (if calculated correctly) it should be 2.120 to 3.029 Mt. When you look at overall net emissions (all gases) for the period 2021-2030, the Commission’s error means that they allow 568Mt of emissions, when it should be only 484Mt.

We have urged the Minister to take into account this calculation error in his independent assessment of the Commission’s advice. He has the power to adopt different targets than those recommended by the Commission, if there are good reasons for doing so. We think this is a pretty good reason.

LCANZI co-founder, James Every-Palmer QC, noted that: “We accept that the implications for Aotearoa New Zealand could be onerous and that this is in part because of the high level of forestry removals in 2010 relative to our gross carbon dioxide emissions. However, it is imperative that each country does its share and that we are robust and transparent about where we sit relative to the required global average reductions.”