Feedback to The Ministry for the Environment Regarding Consultation on the Zero Carbon Bill 18 July 2018
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Feedback to
The Ministry for the Environment
Regarding
Consultation on the Zero Carbon Bill
18 July 2018
Contact details
The New Zealand Motor Caravan Association
Attention: James Imlach | National Policy & Planning Manager
1
Introduction
1. The New Zealand Motor Caravan Association Inc. (the NZMCA) welcomes the
opportunity to provide the following high-level feedback on the Zero Carbon
Bill (the ZCB). We support in principle the Government’s commitment to
addressing greenhouse gas emissions through the ZCB and recognise this may
be one of the most significant pieces of legislation affecting our environment,
economy and social well-being for generations to come.
2. The NZMCA understands the Government’s commitment is not solely limited to
protecting our ecosystem, rather the ZCB recognises the need to maintain a
stable economy to ensure our collective social well-being for years to come. In
our view, the ZCB provides an ideal opportunity for the Government and
private sector to collaboratively think about future innovation and investments
that will help significantly reduce and offset greenhouse gas emissions, while
advancing the overall value of New Zealand’s tourism industry.
3. The NZMCA acknowledges the impact climate change events, exacerbated
by anthropogenic greenhouse gas emissions, are now having and will continue
to have across the country. We also acknowledge that while New Zealand is a
relatively small emitter on the international stage, it is important for us as a
country to take a leadership role similar to how we have in the past, e.g.
advocating for woman voting rights and more recently marriage equality.
4. A recent survey by Insurance company IAG1 found the majority of New
Zealanders acknowledge the need to prepare for the impact of climate
change and at least three-quarters agree New Zealand needs to start taking
action now even if other countries are not prepared to do the same.
Furthermore, mitigation, adaptation and proactively planning for the future
impact of climate change on communities are front of mind issues for Local
Government New Zealand (of which the NZMCA is a preferred partner).
5. We trust the Government will take into account New Zealand’s growing
domestic motorhome industry and be open to working alongside industry
operators like the NZMCA on opportunities including (but not limited to) native
tree planting projects to help offset emissions, and alternative fuel to incentivise
the development of more biofuel-capable and EV motor caravans.
About the NZMCA
6. The NZMCA represents over 81,500 individual New Zealanders who share a
passion for exploring our country at leisure in their certified self-contained (CSC)
motorhomes and caravans. Our members enjoy camping in a variety of
1https://www.newshub.co.nz/home/new-zealand/2018/07/revealed-what-kiwis-think-about-climate-
change.html
2settings while on holiday throughout New Zealand, including coastal
environments and residential/urban centres – both of which are at high risk
from the adverse effects of climate change.
7. The NZMCA’s vision is to engage with members, industry operators and
communities (including government) on important matters like climate change
to ensure a sustainable future for motorhoming and caravanning across New
Zealand. Our strategic plan recognises the need to maintain our industry
leadership position by, inter alia, investigating opportunities to help mitigate
member greenhouse gas emissions, and review these in partnership with other
entities including central and local government.
8. The NZMCA already has a proud history of caring for the environment and we
support public-private partnerships. For example, since 1990 we have
advocated for the certified self-containment of all motorhomes and caravans
across New Zealand, spearheading the development of NZS 5465:2001. Over
the past two decades we have partnered with numerous local authorities to
co-fund the construction of hundreds of public dump station units built to NZS
5465:2001 specifications nationwide, in order to protect communities from
indiscriminate waste disposal.
9. In 2013, the NZMCA launched its National Spring Clean programme which
enables members throughout New Zealand to adopt and clean up a local
area for the benefit of their communities. Our members have supported
hundreds of local projects, from beach clean ups to tree planting days. As the
Spring Clean programme evolves we hope to support a wider variety of
environmentally-focused community projects, while using these opportunities
to educate our members and raise further awareness around the programmes
long-term benefits. For further information on the NZMCA’s Spring Clean
programme please follow https://www.nzmca.org.nz/spring-clean
10. We acknowledge the majority of our members’ motor caravans rely on fossil
fuels when travelling the country. In 2014, we undertook a baseline assessment
to help gauge the size of the NZMCA’s collective carbon footprint. During our
assessment we estimated that members travelling on the road collectively
emitted around 93,000 tonnes of CO2e emissions2. Recognising their
contribution (albeit relatively small compared to other sectors) our members
have asked us to do more to help mitigate and offset vehicle emissions.
11. In response to member feedback, the NZMCA began searching for practical
and innovative solutions to reducing and offsetting our members’ vehicle
emissions. In 2016 we partnered with the Sturrock family (a.k.a “The Loop
Crew”) who embarked on a long journey across New Zealand in their
22014 estimate using the ACE Carbon Calculator as recommended by the Sustainable Business
Network, downloaded from http://catalystnz.co.nz/publications-resources
3retrofitted bio-diesel bus. This was an opportunity to test the viability of biodiesel
for motor caravanning, while educating other NZMCA members on the road
about the benefits of sustainable motor caravanning generally. Follow this link
for information on the Loop Crew’s journey - https://www.theloopcrew.kiwi/
12. In 2017, the NZMCA partnered with Greenfleet to launch the Greenfund
initiative. The Greenfund is a 12 month trial project that encourages NZMCA
members to voluntarily offset their vehicle emissions through the purchasing of
New Zealand native trees. If the trial is successful, the Greenfund may be
extended to the commercial industry and will be made available to help
financially support New Zealand-based tree planting projects.
13. We envisage tree planting projects taking place in partnership with community
groups, iwi/hapu, local authorities and central government agencies, e.g.
DOC. Please follow this link for further information on the Greenfund -
https://www.nzmca.org.nz/the-greenfund-initiative/
General feedback on the CZB discussion document
14. The CZB discussion document raises a number of important issues, reasons for
action, and beneficial opportunities for New Zealand. We support:
Tacking early action and setting a long-term target, irrespective of what
other countries may or may not be committing to right now. Early action
will help reduce our overall infrastructure and insurance costs in the long
run. Further, a long-term target provides time to adjust and upgrade our
economy.
Realising opportunities to support tangata whenua and the local Maori
economy through the transition.
Planting more native trees to help offset greenhouse gas emissions, while
improving local biodiversity and the health of our waterways. The NZMCA
and its 81,500 members are very interested in supporting native tree
planting projects for these reasons.
Investing in new technologies and innovation to help shift our cars and
trucks etc. away from the reliance on fossil fuels. The NZMCA has previously
supported biofuel projects and technical working-groups led by the
Sustainable Business Network. We acknowledge there are logistical and
commercial obstacles to improving New Zealand’s biofuel infrastructure;
however this legislation could help overcome many of those barriers.
Both Jucy Campers and Tourism Holdings Limited recently launched
prototype EV campervans, which we believe is the future direction of the
4campervan industry. Infrastructure required to support the use of EV
campervans includes more quick charging stations dispersed across NZ,
including those areas off the beaten track. Financial incentives may help
stimulate further growth in this sector.
Incorporating tea ao Maori and kaitiakitanga, as the underlying principles
will help ensure the transition towards a low-carbon economy is both
effective and sustainable.
Establishing a Climate Change Commission to provide independent,
expert advice to the existing and successive governments.
Feedback on specific questions
1. What process should the Government use to set a new emissions reduction
target in legislation?
Establish a goal to reach net zero emissions by the second half of the century
and the Climate Change Commission advises on the specific target for the
Government to set later.
8. Do you agree with the considerations we propose that the Government and
the Climate Change Commission take into account when advising on and
setting budgets?
Yes
9. Should the Zero Carbon Bill require Governments to set out plans within a
certain timeframe to achieve the emissions budgets?
Yes
13. The Government has proposed that Climate Change Commissioners need to
have a range of essential and desirable expertise. Do you agree with the
proposed expertise?
Yes
14. Do you think the Zero Carbon Bill should cover adapting to climate change?
Yes as climate change adaptation may influence the emissions budget
if/when the budget is under review.
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