Lawyers for Climate Action NZ’s initial comments on the 2035 NDC, released last night, are as follows.

Last night, the Government announced its next Nationally Determined Contribution (NDC) under the Paris Agreement, aiming for our net emissions to be 51-55 per cent below 2005 gross emissions by 2035.

The 2035 NDC represents minimal progression since our previous NDC, which was for a 50 per cent reduction below 2005 gross emissions by 2030. The Government has opted for what appears to be the smallest and least ambitious target possible within the Paris Agreement framework.

Does the new NDC meet the Paris Agreement?

It is highly questionable whether this 2035 NDC meets the requirements of the Paris Agreement:

Under the Paris Agreement, the NDC must represent a country’s “highest possible ambition”. The Climate Change Commission has provided analysis that indicates that New Zealand can do more than the Government’s 2035 target, finding that reductions of up to 69% by 2035 were feasible domestically across its scenarios. And international 1.5°C-consistent pathways (such as the IEA’s net-zero energy scenario) reduce fossil fuel emissions even more rapidly than the Commission’s scenarios. All in all, the 2035 NDC does not reflect what is actually possible.

The level of ambition contained in the NDC must represent each country’s fair share towards achieving the global temperature goal - limiting temperature increases to 1.5°C and well below 2°C. The Climate Action Tracker already called our existing NDC “critically insufficient” compared to New Zealand’s fair share contribution to climate action. By reducing our climate commitments to the minimum progression available under the Paris Agreement, it is hard to see how the Government can claim that “New Zealand remains committed to playing its part to achieve the long-term temperature goal”.

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In addition, for New Zealand to play its fair share, this requires an assessment of fairness and equity. For New Zealand, this ought to reflect the fact we are a developed country with GDP per capita similar to that of the European Union, and with some of the highest per capita gross emissions in the world. The government’s own analysis on equity is unconvincing; a high methane share is not an excuse to set a weak NDC given it’s set on a ‘net’ basis including forestry.

New Zealand must approach its international legal obligations in good faith. There are real questions around whether a 1-4% increase on a previous target is a good faith interpretation of the requirement of progression.

Gross: Net Approach Survives

In addition, like our previous NDC, this NDC is expressed in gross:net terms. That is, the NDC sets a target for net emissions in 2035, but the target number is calculated by applying the percentage reduction to gross emissions in 2005.

The problem is that this compares apples with oranges, making the 2035 NDC even less ambitious than it first appears.

Our “net emissions” are the greenhouse gas emissions that the atmosphere sees from New Zealand, once offsets such as forestry are taken into account. However, our “gross” emissions are the actual emissions that New Zealand releases into the atmosphere.

In 2005, our gross emissions were 86.62 Mt CO2-e, and our net emissions were 62.4 Mt CO2-e. The Government states that the new 2035 target “provisionally equates to reducing emissions to between 38.98 and 42.44 Mt CO2-e”. This means that on an apples-for-apples basis, the true ambition is only to reduce net emissions by roughly 32% to 37.5%.(1)

The approach also allows us to continue planting pine forests instead of truly decarbonising the economy and reducing emissions at source, even though forestry removals are much less permanent than continued emissions.

We are one of the few countries to use this gross:net approach, and it means that New Zealand’s actual NDC falls far short of the level of ambition of our international peers.

The climate does not care about our clever accounting choices, it cares about actual emissions reductions. And our failure to walk the talk will be apparent to our trading partners, some of whom are already adopting much more ambitious targets.

Note:

(1) These numbers are approximations only, the real figures may be slightly lower if approached on an inventory basis.

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