More of the endless cycle of incremental reform of the emissions trading scheme

There is a new Cabinet paper to read; "A Review of the Emissions Trading Scheme", 28 pages, by the Office of the Minister of Climate Change

What use is a Cabinet paper when the key policy options are redacted?

Last Wednesday 22 March 2023, the Ministry for the Environment announced yet another review of the My-Eyes-Glaze-Over New Zealand Emissions Trading Scheme.

For some reason, I downloaded the Cabinet paper.

For some even more masochistic reason, I actually read all 28 pages.

It was largely a waste of time.

I can't even use the metaphor that the Cabinet paper was "rearranging the deckchairs on the Titanic" as I have already used that title on a blog post on a past consultation on industrial allocation.

The first paragraph of the Cabinet paper tells us what the paper is about. So far so good.

"This paper seeks agreement to the scope and process of a review of the New Zealand Emissions Trading Scheme (NZ ETS). This review is in response to Cabinet’s decision to prioritise gross emissions reductions in New Zealand’s first emissions reduction plan (ERP), and Cabinet’s in-principle decision to at agree to the Climate Change Commission’s recommendations to strengthen the incentives for gross emissions reductions in the NZ ETS."

The fourth paragraph states;

"Enabling a just transition to a low-emissions, climate resilient future is a Government priority..."

Okay. I am all for a just transition. I'd like the transition to help those with low incomes instead of being corporate welfare for emissions intensive industry as in the case of the dreaded industrial allocation.

Back to the Cabinet paper. Who is being mean to the emissions trading scheme saying it needs more reform? It's the naughty He Pou a Rangi/Climate Change Commission. The Cabinet paper says in paragraph 50 that:

"In their 2021 advice, the Commission highlighted the risk that the NZ ETS would drive relatively low-cost net emission reductions through exotic forests, rather than gross emissions reductions needed to put us on track to net zero by 2050".

For emissions nerds who have tracked the emissions trading scheme since it's inception in 2007, this isn't just a future risk. It is exactly what has already happened in the 2008 to 2012 period of the Kyoto Protocol. Gross emissions rose in proportion to economic growth but "Net Kyoto" emissions (that included "afforestation and reforestation" sequestration credits that were not in the 1990 baseline) were less than the baseline.

This was before the fraudulent hot air emission units from Russia and Ukraine flooded into New Zealand. Here is Geoff Simmons in the Spinoff.

The Cabinet paper continues with a lot of background to the emissions trading scheme that is probably unnecessary. For example its not like Chris Hipkins would read that. He couldn't remember any details of other Cabinet papers where policies had consequences measurable in emissions.

Finally, I got to paragraph 79 on page 11. Maybe the officials who wrote the paper would finally mention where they see this reform proposal going. That would be new information. For example, what do the officials think are the possible high level options for amending the emissions trading scheme? Great, they are going to say what they think. Here is paragraph 79.

"However, in my view there is value in identifying some of the potential, high-level options Ministers may be presented as an output of the review. This will help give a sense of the kinds of options that could support balancing gross and net emissions reductions in the NZ ETS."

I turned the page expecting to be mildly enlightened. Okay that is sarcasm. It would have been nice to learn something new though.

This is paragraph 80. And 81 and 82.

Yes the potential, high-level options have been redacted! The whole point of downloading and reading the Cabinet paper was really to find out the possible options or new directions for dealing with known problems.

I kept plowing my way through the paper. Several pages are dedicated to the peculiarities of the inter-departmental 'process' to be followed. Remember the emissions trading scheme involves several government departments: principally Ministry for the Environment on policy, but also the Environmental Protection Authority for operating the emissions trading scheme, the Ministry for Primary Industries for foresty, MBIE for energy sector emissions and Ministry of Foreign Affairs and Trade for international climate agreements.

These departments interact in accordance with the their own perceptions of relevant interests. I add the observation that such interactions may not be in the direction of 'no more than 1.5C warming' or 'net zero carbon by 2050. The Cabinet paper leaves that unsaid.

However, such interactions are implicit as on page 14 paragraph 100, as the paper proposes some 'governance terms of reference' to presumably make the public servants play nicely.

I am reminded of the italian novelist Umberto Eco's explanation of the behaviour of the crusading Knights Templar religious order. The historic reality of knightly behaviour in the Holy lands was best understood by considering the order's offical commandments. For example, "thou shall not be drunk on a horse blaspheming the name of the Lord" was in fact the proof that such behaviour was the rule and not the exception.

So yes I am mildly interested in the 'governance terms of reference'. Here are the relevant paragraphs.

Yes the 'governance terms of reference' have been fucking redacted!

So I logged onto FYI.org.nz, the online transparent and open portal for requesting official information from public agencies. And I requested a complete copy of the Cabinet paper with all 26 redactions restored all their improbable glory. The 26 redactions are probably not earth-shatteringly egregious but the point of principle is - do there need to be any redactions if the Government is pursuing emissions policies consistently with their own professed value statement of a "just transition"?

I was so mad about that point that I started writing an email to Minister for Climate Change James Shaw asking him that exact question. The email turned into a three page letter. Oh well, push the send button, and try not to forget what the issue was when I finally get a reply after waiting a month or two for a reply. Of course, the same proviso applies to my Official Information Act request at FYI.org.nz. The Ministry may well extend the timeframe, or transfer the request to the Minister's office, or just ignore the timeframe - or a combination of all three.

Of course, in terms of climate change policy responses, we don't have time for this shit.

Charting the surplus emission units in New Zealands Emissions Trading Scheme

The New Zealands Emissions Trading Scheme doesn't work to cap emissions. It has just far too many surplus emission units sloshing around because of the big buy-up of low-priced dodgy Russian-sourced international units.

The New Zealand Emissions Trading Scheme Review discussion document includes this statement about surplus emission units on page 10.

"There is a substantial number of banked NZUs owned by market participants, which combine with current ETS settings to weaken the effectiveness of the NZ ETS to assist New Zealand to meet its international obligations...
This stockpile of banked NZUs amounts to around 140 million units. This is several times the total number of units surrendered under current NZ ETS settings each year, which typically amounts to less than 30 million units.
Some of these units are held by foresters, who banked the NZUs they received as their trees grew. Other participants banked units they received via one-off allocations when the NZ ETS was first put in place, or accumulated NZUs by surrendering cheaper international units to meet their obligations and banking NZUs they purchased or received from the Government".

Did you notice the specific use of language? The word 'surplus' is not used. The preferred term is 'banked NZUs owned by market participants'. 'Banked units' implies that it's the fault of the market participants. Surplus units implies faulty design. As I have posted previously.

An effective emissions trading scheme with a real cap would never have surplus units. Units would be scarce and realistically priced. A surplus of units is of itself evidence of a failed implementation of cap and trade frameworks such as Kyoto and the EU ETS.

How many surplus units are there? The discussion document says 140 million units. I have doodled away with the R programme and some data from the Environmental Protection Authority's Emissions Units Register and have made a graph of the cumulative total of units held in the NZ Emissions Unit Register at the end of the calendar year, up to 2014.

The key point being that the cumulative total of all types of units, 588 million, at the end of 2014, exceeds the total 'compliance demand', 110 million, the number surrendered by emitters/ market participants from 2009 to 2014 by a factor of almost six.

We need to note that in the final accounting for the 2008 to 2012 Kyoto Protocol commitment period, New Zealand has to cancel some 373 million units to match our emissions.

Here is the R script.

Here is the data.

Jeanette Fitzsimons also says forget tinkering with emissions trading scheme scrap it

Jeanette Fitzsimons has written a great article in the New Zealand Herald. (Photograph courtesy of the Green Party of Aotearoa via Wikimedia Commons)

Forget tinkering with emissions trading scheme scrap it!

Here are some excerpts.

The ETS should not be amended, but withdrawn entirely. It fails on every count and is in fact counter-productive.

The Government's discussion document admits that in its seven years, the ETS has not reduced NZ's climate pollution; in fact, emissions are expected to rise to 96 per cent above 1990 levels within 15 years.

Many suspect the design of the ETS, with no price floor and no emissions cap, was never intended to make a real difference to our climate-changing emissions. It was intended to provide a trading platform for speculators, which it has done.

Any further public time and expense tweaking a broken system will send good money after bad, and use resources that would be better used on measures that will actually reduce emissions.

Jeanette's conclusion.

The ETS should be abandoned and replaced with a simple and gradually rising price on carbon through a carbon charge, the proceeds distributed equally to all New Zealanders.

But you really need to read the whole article

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Fixing the NZ Emissions Trading Scheme is just flogging the dead horse

I look at 'fix the ETS' metaphors and argue that trying to incrementally 'save' or 'fix' the NZ Emissions Trading Scheme will ensure it remains ineffective in reducing domestic emissions for decades. Politically, its just flogging the dead horse. We don't have time for a unending institutionalised cultural conflict over 'fixing the NZETS' like the one we have had for 'fixing' the Resource Management Act.

So, in my last post I used the metaphor or framing of 'arguing over the gears while accelerating towards a cliff' for the latest review of the New Zealand Emissions Trading Scheme.

Other commentators are using a very different framing for the review; that of 'fixing the NZETS'. For me that raises some fundamental questions. What are the political advantages and disadvantages of the two framings? Where will each framing lead us? Which framing is more 'science-informed'?

Brian Fallow, Generation Zero and Geoff Simmons are all accepting the 'fix the NZETS' framing in their comments on the review. Geoff Simmons heads up his second post in two days on the NZETS review How do we save the Emissions Trading Scheme?.

Brian Fallow starts his Herald column "Possible adjustments to the Emissions Trading Scheme aren't much, but at least they'd be a start".

Geoff Simmons and Brian Fallow do a double act of analysis on the NZETS review. I totally respect both Geoff and Brian in their intentions and views and understanding of the NZETS. However they both accept this inherently incremental 'fix the NZETS' framing of the politics. Here's their discussion.

I think this framing, 'fixing the NZETS' is fundamentally wrong in it's politics.

One key point from my last post was that this NZETS review has reversed the burden of proof. The allegedly temporary and allegedly transitional 'moderating features' are now the status quo or the default settings in the NZETS.

Policy analysis and assessment now has to be prepared and presented to show that each flawed 'moderating feature' of the NZETS won’t harm business interests. Queue the technical report Economic impacts of removing NZ ETS transitional measures by New Zealand Institute of Economic Research.

We need to remember there are a lots of 'cost moderating' features (flaws) still in the NZETS: unlimited international linkage and importing of overseas units (access to which officials are trying to restore), overly generous free allocation of units, the hang-over of surplus units in the market, the lack of auctioning (well there is no point having an auction if there is a huge surplus of units).

And the ultimate flaw in the NZETS is that half of New Zealand's greenhouse gas emissions, those from pastoral agriculture, seem to have a permanent get-out-of jail card.

So we have an emissions trading scheme with multiple flaws. The politically selected burden of proof provides a high hurdle for change each time the hapless officials attempt to remove the flaws. All the lobbyists join in as they already have the dates in their calendars.

Also, what is the messaging you need to do if you are promoting long-term incremental reform of the NZETS?

Well, first of all and before explaining your 'fix', you have to try to explain the NZETS from square one for each increment (again and again!). Geoff Simmons gets this as one of his other recent NZETS posts is white board Friday emissions trading for dummies.

The trouble with this is that explaining the NZETS is 95% impossible! I suggest from my own experience that most people find the NZETS the ultimate "My Eyes Glaze Over" topic. Poor old Geoff Simmons better to be ready to do another decade's worth of 'emissions trading for dummies! To borrow a metaphor from the centenary of the First World War, incrementally fixing the NZETS is like winning the trench warfare one shell hole at a time.

Compare that with the explicit message from the fast-car-to-cliff NZETS metaphor. The NZETS is not effective. It is not worth saving. It's got to go. Three four or five word sentences. Message transmitted loud and clear, over.

You need more convincing?. Let's look at one of Tim Groser's last statements as Minister for Climate Change.

First Groser praises Labour for their shared consensus on having an emissions trading scheme.

We have an understanding that there are certain policy frameworks in New Zealand which take decades to put in place, and where you need a very high degree of consensus - particularly amongst the two major parties of Labour and National - on at least a structure of a policy response.

Labour have supped the kool-aid and have bought into this framing. As shown by this statement to Forest and Bird during the 2014 election campaign.

Labour's preferred means of pricing is to fix the the existing ETS. Using an ETS to price carbon is the only broad area of agreement in climate change policy, particularly particularly between the two largest parties (despite National's lip service for an ETS). Labour would not throw that agreement away lightly to start again with a carbon tax.

In other words, Labour will flog the dead horse better than National. As I noted in 2014:

National and Labour in effect have the same policy narrative that explains the problem; 'THEY undermined the NZETS', and a narrative solution, 'WE will fix the NZETS'. This creates the on-going cycle of the 'horse is under performing' and the narrative solution (keep flogging the horse). But beneath the impenetrable detail and complexity of the arguments about fixing the NZETS, it will remain ineffective.

Groser saves his well-known invective for Russel Norman and the Greens and their carbon tax policy. And stretches a very long bow to equate that policy with the Rudd-Gillard-Rudd Australian Labor Prime Ministers' revolving door.

What I didn't appreciate was that Russel Norman - then leader of the Green Party - saying you want to throw the policy structure away and have a carbon tax... I can guarantee you what that would have done - it would have set us back on a cycle of internal political conflict, which would have repeated exactly the problem in Australia.

Groser concluded:

I do not believe there is anything fundamentally wrong with the emissions trading scheme'.

I rest my case that the best science-based and ethically based climate mitigation policy is the opposite of what Groser says!

A 'horse-flogging' process of 'fixing the NZETS' will last a very long time - if it ever concludes. It could just become an social and cultural institution like the never-ending debate over the Resource Management Act. In a previous post I used the metaphor of flogging the dead horse after the snake swallows the elephant in the room to describe this possibility.

Applying the maths of our carbon budgets, Kevin Anderson's analysis and the Paris Agreement, we just don’t have enough time for a never-ending institutionalised horse flogging debate over the NZ emissions trading scheme. The political goal must be to remove the social licence of the NZETS, to de-legitimize it in the eyes of the public and then to scrap it so a simple carbon tax can be adopted instead.