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Submissions Overwhelming Oppose Early Ratification

Climate Change Pan Industry Group

February 14, 2002

Kyoto Submissions Overwhelming Oppose Early Ratification

The Climate Change Pan Industry Group has today released the results of its independent analysis of submissions received by Government in response to the Climate Change Consultation Paper.

“A significant number of submitters accept there is a need to respond to climate change but 70% either opposed early ratification or did not support signing the protocol at all,” said Chris Baker, spokesperson for the Pan Industry Group.

Nearly 40% of submitters believed that New Zealand should not ratify until a thorough cost/benefit analysis is completed, our major trading partners also sign or there is a global response.

“We have yet to see the Government’s detailed analysis of submissions but our analysis continues to support industries view that the Government should not ratify the protocol in advance of our major trading competitors.”


Attached: Independent Analysis of the Submissions on “Kyoto Protocol: Ensuring Our Future” - Climate Change Consultation Paper

Chris Baker

Tel: 04 471 6551

O27 240 6754

Analysis of the submissions on “Kyoto Protocol: Ensuring Our Future’-Climate Change Consultation Paper

Margot Fry

1 The Brief:

1. To briefly analyse the submissions.

2. To assess how many submissions agree that the Kyoto Protocol should be ratified, and how many disagree.

3. To provide information on the substantial issues that are raised by those who do not think the Protocol should be ratified.

4. To provide information on the answer to Question 6 of the Climate Change Consultation Paper.

5. To provide information on whether submissions believed that economic changes should be introduced before 2008.

This report does not:

1. Provide detailed comment from the submissions.

2. Provide information on the questions asked in the Climate Change Consultation Paper, other than the two noted above.

3. Provide detail as to why submissions thought the Protocol should be ratified.

2. The number of submissions analysed 569

The numbering of the submissions is not consecutive. Although the final

submission is labeled as no. 591, there are in fact only 569 submissions.

3. Analysis of the Submissions

The responses in the submissions can be divided into three groups: those who state the Protocol should be signed, those who state it should not, and those who give a qualified response. Submissions in this category either state that the Protocol should not be signed unless a specific set of factors occurs, or they state that the Protocol should be signed, but not until certain conditions occur. Submissions state, for example, either “The Protocol should not be ratified before our trading partners sign’, or “I agree in principle that New Zealand should sign the Protocol, but there needs to be full consultation on the policies beforehand’.

i) The Protocol should not be signed: 185

The farming community made the most submissions in this. They express concern that their industry will be targeted through a carbon tax, that their costs will increase and that their ability to be competitive will be affected as a result.

Farmers 146

Business 4

Organisation 9

Local Government 2

Individual 24

ii) The Protocol should be signed 122

The most dominant category in this group, are those from individuals. Typically the reasons for supporting the ratification of the Protocol are: the respondents believe it is important for the world as a whole, that New Zealand should take a leadership role in this, and that it will make New Zealanders more innovative. A few submissions state that while they support New Zealand ratifying the Protocol, the reduction in emissions is not enough, and that a tougher stance should be taken. Submissions are from the following categories:

Farmers 13

Business 15

Organisation 30

Local Government 9

Individual 55

iii) A Qualified Response 218

Many of these submissions state that they approve of the Kyoto Protocol in

principle. Some say that they have already started reducing greenhouse emissions

voluntarily. The common thread is that New Zealand should not ratify the Kyoto Protocol unless or until all or some of the following happens:

- A thorough cost/benefit analysis is done.

- New Zealand’s trading partners also sign.

- There is a global response.

The submissions in this group are more evenly spread over the different


Farmers 48

Business 39

Organisation 69

Local Government 21

Individual 41

iv) The Number of submissions which did not answer the above question 44

A number of submissions do not address the question of whether or not New Zealand should ratify the Protocol. They either comment on the policy issues, or provide specific information they believe will be of value. The submissions in this category are spread across all categories fairly evenly.

4. Reasons for not wanting the government to sign the Protocol, either at all or not immediately.

The reasons are ordered numerically, from the most commonly stated reason to the least. The figure is further broken down to show how many of those submissions disagree with the decision to ratify, and how many are from the qualified group.

- Other countries will not sign 122

(64 of those state the government should not sign at all, 58 give a qualified response.)

Most commonly this is simply stated as the reason for not ratifying the Protocol, but a number of submission indicate that the fact that America, in particular, is not

signing, is an indication that the Protocol is flawed, and New Zealand should take notice of this.

- The impact it would have on agriculture 107

(47 of those state the government should not sign at all, 60 give a qualified response.)

- There is either not sufficient evidence that emissions will affect climate change, or the evidence is too conflicting. 99

(48 of those state the government should not sign at all, 51 give a qualified


Submissions in this category comment on the belief that global warming is part of a natural phenomena, rather than being manmade. Some comment on the need for more research.

- The decision has been made with too much haste 89

(11 of those state the government should not sign at all, 78 give a qualified response.)

Submissions state either that the government is rushing into ratifying this (some state for political rather than environmental reasons). Others say that there is no need for haste and that it is better not to be a leader in this instance- 31 submissions state this.

- It will disadvantage New Zealand’s ability to compete 79

(21 of those state the government should not sign at all, 58 give a qualified response.)

These respondents are concerned that if we ratify the Protocol ahead of our competitors, New Zealand’s ability to trade will be affected.

- The amount of New Zealand’s emissions are so small that reducing them 44

will not make a difference

(24 of those state the government should not sign at all, 20 give a qualified response.)

Some of the submissions note that as New Zealand makes such a small contribution, we should not be ratifying the Protocol. Others say that New Zealand’s rate of emissions is so small (the rate of 0.2% is often quoted), the reductions made will be comparatively insignificant. This is often related to the trade issue. It is said that New Zealand will make little impact in terms of the greenhouse emission problem, yet will be disproportionately affected.

A number of submissions (26) state that New Zealand has already signed the Protocol, which shows its intent to address the issues. These respondents say that is sufficient

- There is not sufficient information 43

(9 of those state the government should not sign at all, 34 give a qualified response.)

Some submissions state that there is not enough information available for the government to make a decision.

- Need to see the policy first 39

(9 of those state the government should not sign at all, 34 give a qualified


A number of submissions state that there must be consultation on the policies before the Protocol is ratified. To ratify first, then make the policies, is said to be unwise.

- Industries will locate offshore (leakage) 30

(all from those who give a qualified response.)

- It is just another means of increasing the government’s revenue 8

Other concerns raised include:

- The base line should change

- People wanting to change land use will be penalized.

5. Reasons for giving a qualified response.

These submissions state that the government should not sign until:

- A cost/benefit analysis should be done first 118

- New Zealand’s trading partners sign 82

- There is a global response 65

6. Additional comments made by both those who qualify their response, and those who reject the proposal to ratify the Kyoto Protocol.

The number of respondent making the following statements is numerically small- ranging from three to nine respondents. The statements are, however, included, ranging from the most often stated to the least. The submissions state that:

- The process is politically driven.

- New Zealand is more like a developing rather than a developed nation.

- Agriculture should be exempt from the carbon tax.

- The role of the RMA needs to be clarified.

- The role of local government needs to be clarified.

- New Zealand can do as much as is necessary voluntarily.

- There should be no discrimination between Kyoto forests and non Kyoto forests.

- The position will be complicated where the landowner and the tree owner is not the same person

7. Answers to Question 6-Who should take responsibility for managing greenhouse emissions?

Most submissions that answered this question, prefer the government to take responsibility. The reasons given range from “it needs to be managed on behalf of all New Zealanders’ to “The government is signing it, the government can manage it’. Those who advocate farmers managing the emissions say it is because farmers have the knowledge to do so.

- The government 77

- Farmers 50

- A Mix of government/private sector/farming 25

- Levy Based Organisation 13

- Industry 8

- Private sector/government 6

8. Answer to Question 8- Should economic changes be implemented prior to 2008?

This question has only been answered by 59 submissions. This reflects the fact that many submissions simply state either the respondent’s support of ratification, or their rejection of it.

The responses are fairly even.

- Yes 36

- No 23

9. Comments on the Consultation process

A significant number of submissions state that they welcomed the opportunity to consult with the government on the climate change document. Others made the following comments.

- There was insufficient consultation 23

- The government has already decided. 22

- There was not enough information 18

- There was not enough time 13

- The Document assumes there is only one answer 8

- Maori were not adequately consulted, despite the fact

that they are a treaty partner. 5

- The consultation process was excellent. 4


The brief for this report was to analyse the public submissions from the Consultation Document and evaluate the extent to which they agreed/disagreed with the decision to ratify the Kyoto Protocol. The report was also to indicate the reasons given by those who disagreed with the decision to ratify the Protocol. The report does not therefore not fully reflect the comments of all the submissions, but only those in the targeted group.

The submissions fall into three distinct categories:

- those who agree with the consultation document,

- those who disagree with the premise behind the consultation document, and

- those who believe that a number of concerns need to be addressed before any decision is made to ratify the Kyoto Protocol.

Over three quarters of the submissions fall into the last two categories.

Submissions in the first category believe the Protocol should be ratified because reducing greenhouse gas emissions is beneficial, that it will encourage New Zealanders to be innovative and that New Zealand should take a lead on this issue.

Submissions in the second category believe the Protocol should not be ratified because it will have an adverse affect on industry and agriculture, because other countries (in particular Australia and America) are not signing, and because the evidence is conflicting.

Submissions in the last category, which is the largest of the three, state that three things in particular should occur before the Protocol is ratified: a cost/benefit analysis needs to be completed, New Zealand’s trading partners should sign, and there needs to be a global response. Many of these support ratification in principle, but state that New Zealand should not be rushing into something that may affect our competitiveness before the cost of that decision is fully understood, or before the policies are in place.

The submissions from the public consultation process therefore reflect a high level of concern about the government’s intention to ratify the Kyoto Protocol in September 2002.


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