Dear Ministers,
Congratulations on winning the confidence of New Zealanders to lead the nation through these uncertain times. The road ahead will not be an easy one. But, make no mistake, this will be one of the most pivotal moments in New Zealand history.
We want to acknowledge that, during the election campaign, you committed to action on climate change and the protection of nature. We also note that New Zealanders roundly rejected some very overt anti-climate and anti-environment election platforms. You have a strong mandate for delivering on your promises. And you must.
Our world is in crisis. The coronavirus pandemic is just the latest symptom of the ongoing erosion of the natural systems that we depend on to survive and thrive. The systematic destruction of forests and land-based ecosystems is increasing epidemiological interactions between wildlife, livestock and people, contributing to zoonotic transfer.1 Soil health is declining dramatically and fish stocks are collapsing, leading scientists to raise the alarm about access to food in the near future. Drinking water supplies are becoming depleted and polluted. And our heating climate is putting our homes, communities, health, food supply and livelihoods at risk through the accelerating frequency of wildfires, superstorms and sea level rise.
The economic recovery from Covid-19 offers a once-in-a-generation opportunity to turn the tide on ecological and climate devastation. You must seize it.
The decisions you make right now could help to restore the natural systems we depend on to survive – from the climate, to healthy soils, to abundant oceans and clean water. You have a chance now to build an Aotearoa New Zealand where native forests are rebounding and once again alive with birdsong. Where water is clean and rivers are safe for swimming in again. A New Zealand that is recognised globally for our world-leading sustainable farming and fishing sectors. Where we power our homes with clean energy from the sun and wind. Where our streets are safe for walking and biking to school and work.
Just as easily, a lack of ambitious and visionary policy – a continuation of business as usual – would lock us into further climate and ecological devastation with long-lasting repercussions for young people, wildlife, and the essentials on which they depend.
Last term, you laid the groundwork. You positioned New Zealand, both domestically and internationally, as a nation that wants bold action on climate change and the ecological crisis. You introduced important frameworks like the Zero Carbon Act. A good house was built, but it is still unfurnished. Now is the time to fill this house with the policies needed to start cutting emissions, stop pollution and restore nature.
You hold the weight of our futures and our children’s futures in your hands. If there ever was a time to be unwaveringly courageous, it is now.
Sincerely,
Russel Norman
SUMMARY OF KEY RECOMMENDATIONS
It is our view that the following policies would have the most significant, positive impact on New Zealand’s ecological and climate footprint.
Tino Rangatiratanga
- Honour the te reo Māori version of Te Tiriti o Waitangi.
- Ensure that the whole of government, including the various ministries, engage with Māori rights holders and their representative organisations.
Transforming New Zealand into a leading regenerative organic food producer
- Phase out synthetic nitrogen fertiliser by no later than 2024, by immediately introducing a sinking cap on its use.
- Bring agriculture into the Emissions Trading Scheme in this term of Parliament.
- Establish a $1 billion regenerative farming fund to help farmers transition to regenerative practices and more plant-based agriculture.
- Phase out all imported feed by no later than 2024, by immediately introducing a sinking cap on its use.
Oceans that are teeming with fish for generations to come
- Conduct an independent review of fisheries management.
- Introduce a mandatory requirement for cameras on all commercial fishing vessels within three years.
- Close all vulnerable marine ecosystems in the New Zealand EEZ to bottom trawling.
- Stop issuing permits for the New Zealand fleet to bottom trawl in the South Pacific.
- Advocate for a UN Global Oceans Treaty which will enable the effective creation of large scale Marine Protected Areas in international waters.
- Ban seabed mining in New Zealand’s EEZ.
- Support an immediate moratorium on seabed mining in the Pacific for no less than ten years
Powering New Zealand on homegrown clean electricity
- Provide grant funding for community energy schemes and zero interest loans for household solar.
- Remove barriers to community energy projects and provide a “one-stop-shop” of information on how to develop community energy projects.
- Install solar panels on government buildings, schools and social housing.
- Extend finance and support for home insulation and heat pumps so that all 600,000 under-insulated homes are insulated in the next 10 years.
- Update the Building Code so that all new homes are net zero, following passive house standards.
- Build all new Kāinga Ora and KiwiBuild homes according to passive house standards, including clean energy generation, rainwater collection and greywater recycling.
- Ban the issuing of new oil and gas prospecting and exploration permits onshore in Taranaki.
- Ban the application for and issuing of new coal mining permits.
- Revoke all unused fossil fuel (coal, oil, gas) permits and end all fossil fuel (coal, oil, gas) permit extensions.
- Ban all new coal, gas and diesel infrastructure and phase out all existing coal, gas and diesel infrastructure by 2030.
Transport infrastructure driving the Covid-19 recovery
- Ban the import of fossil fuel vehicles by 2030.
- Introduce the proposed electric vehicle “feebate” scheme and fuel efficiency standards.
- Unprecedented investment in public transport, including electric rail and busways.
- Unprecedented investment in cycleways.
- Investment in regional rail links, including an overnight link between Auckland and Wellington.
- Investment in a nation-wide electric vehicle charging network.
A circular economy free of single-use plastic waste
- Introduce a ban on plastic drink bottles.
- Develop reusable and refillable beverage container systems.
- Introduce a plastic pollution levy.
- Introduce national targets to phase out single-use plastics.
Fit for purpose laws and government agencies
- Review and reform the Environmental Protection Agency.
- Urgently review the EEZ/CS Act to restore democracy and environmental protections.
- Conduct a comprehensive review of the Official Information Act.
- Give the Climate Commission independent powers to influence the price of emissions.
STATE OF THE ENVIRONMENT
Scientists have identified a set of nine ecological and biophysical limits within which the Earth can continue to sustain human society. These are known as the ‘safe planetary boundaries.’ Scientists warn, “Transgressing one or more planetary boundaries may be deleterious or even catastrophic due to the risk of crossing thresholds that will trigger non-linear, abrupt environmental change within continental- to planetary-scale systems.”2
There are three planetary boundaries that have already been breached. They are biodiversity loss, climate change and the nitrogen cycle.
According to the World Economic Forum, the top four risks that face the world in 2020-2030 are all related to climate change and biodiversity loss.3 They are:
- Extreme weather events with major damage to property, infrastructure and loss of human life
- Failure of climate-change mitigation and adaptation by governments and businesses.
- Human-made environmental damage and disasters, including environmental crime, such as oil spills, and radioactive contamination.
- Major biodiversity loss and ecosystem collapse (terrestrial or marine) with irreversible consequences for the environment, resulting in severely depleted resources for humankind as well as industries.
Our climate in crisis
Before Covid-19, emissions of carbon dioxide were rising by about 1% per year over the previous decade.4 According to the UN, the world was on course for a more than 3°C spike, even if climate commitments are met. The risks of a 3°C rise in temperatures include irreversible tipping points, where forests turn from carbon sinks to carbon sources, thawed permafrost releases enormous amounts of previously-trapped greenhouse gases and runaway climate change becomes a reality.5
The UN says global emissions need to fall by 7.6% each year over the next decade, if the world is to get back on track towards the goal of limiting temperature rises to close to 1.5°C.6 This is the critical threshold that our Pacific neighbours say we must not cross in order to protect their islands from sea level rise. The ground-breaking 2018 IPCC report famously noted that global carbon emissions would need to be cut by half by 2030.7 As Oxfam has recently pointed out, New Zealand’s fair share requires us to be significantly more ambitious.8 However, three years have now elapsed since the IPCC’s report with no marked change in our emissions trajectory.
The Covid-19 pandemic may offer some reprieve. According to the journal Nature Climate Change, Covid-19 will lead to a reduction in greenhouse gas emissions in 2020 of around four to seven percent, depending how the pandemic unfolds. The higher end of this estimate is comparable with what is needed every year from now on if we are to stop global warming at around 1.5°C.9 Covid-19 has, perversely, given us a second chance. But only if the pandemic is followed up by policies that ensure an accelerated transition to a green economy.
Here in New Zealand, we have the fifth-highest emissions per capita and the second-highest level of emissions per gross domestic product unit of the 35 OECD countries.10 We also have the highest methane emissions per capita in the world – six times the global average. Our net emissions increased by a whopping 65% from 1990 to 2017. Our two largest contributors to gross emissions in 2017 were the agriculture sector (48.1%) and the energy sector (40.7%), with road transport the fastest growing source of emissions in New Zealand.
According to Climate Action Tracker, New Zealand is one of the few countries to have a net zero carbon goal enshrined in law (the Zero Carbon Act), but short-term policies cannot yet keep up with that ambition.11
Nature in decline
According to the Intergovernmental Science-Policy Platform on Biodiversity and Ecosystem Services (IPBES12), nature is declining globally at rates unprecedented in human history – and the rate of species extinctions is accelerating, with grave impacts on people around the world now likely.
Land conversion (especially industrial agriculture and mining), direct exploitation (including overfishing and poaching), pollution (including plastic and agricultural/industrial/mining run-off), climate change and pest species are the key direct drivers.
The UN Food and Agriculture Organisation (FAO) has warned that, if current rates of soil degradation continue, all of the world’s topsoil could be gone within 60 years, risking food system collapse.13 Scientists forecast that large ocean fish could be wiped out by 2050.14
The ongoing erosion of our natural world is also contributing to a global increase in zoonotic epidemics.15 Seventy-five percent of emerging infectious human diseases are closely linked with environmental changes.16 Intact ecosystems naturally restrain the transfer of these diseases. But, when ecosystems are degraded, these natural barriers are stressed and broken down. The Covid-19 pandemic has made it increasingly clear that human, animal and environmental health are all interconnected. Restoration and regeneration of nature is therefore an essential investment in public health.
Here in New Zealand, our biodiversity has declined significantly. Marine, freshwater, and land ecosystems all have species at risk: 90 percent of seabirds, 76 percent of freshwater fish, 84 percent of reptiles, and 46 percent of vascular plants are currently threatened with or at risk of extinction. The extinction risk has worsened for 86 species in the past 15 years. The conservation status has improved for 26 species in the past 10 years, but more than half require active management to stay that way.17
The loss of native vegetation has continued in recent years, with more than 70,000 hectares lost between 1996 and 2012 through conversion to pasture, plantation forestry, and urban areas. Introduced pest species, diseases and climate change are also major drivers of biodiversity decline.
Nitrogen off the charts
The impacts of the nitrogen cycle breach are many and are already being seen around the world. They include; the rapid growth in nitrous oxide emissions, freshwater pollution, ozone depletion, acid rain, oceanic dead zones, loss of potable drinking water and human illnesses.18 Moreover, nitrogen pollution impairs humanity’s efforts to return to or remain within a number of the other planetary boundaries, including stratospheric ozone depletion and climate change.19 Synthetic nitrogen fertiliser is the single largest cause of this breach.20
New Zealand’s nitrogen balance has worsened more than in any other OECD country, primarily due to expansion and intensification of dairy. The largest sources of nitrogen pollution into New Zealand’s rivers, in order of magnitude, are: urine from dairy cattle, urine from sheep followed by synthetic nitrogen fertiliser.21 The application of synthetic nitrogen fertiliser has increased by 670% since 1990.22 The use of synthetic fertiliser in New Zealand has enabled the intensification of dairy farming, leading to higher stocking rates and a substantial increase in the number of dairy cows.
At elevated levels, nitrate in drinking water impacts on human health. At levels higher than the World Health Organisation (WHO) limit nitrate contamination can be fatal. Many groundwater wells in Aotearoa New Zealand already exceed this limit. Recent research indicates that nitrate levels much lower than the World Health Organisation limit are associated with an increased risk of colorectal cancer.2324 The Canterbury Medical Officer of Health has warned that nitrate contamination is a looming public health risk in Canterbury,25 which is home to the highest stocking rates and highest synthetic fertiliser use in the country.
COVID-19 ECONOMIC RECOVERY: BUILDING BACK BETTER
With billions of dollars being created to spend on the Covid Recovery, we have a rare and unique opportunity to redesign our economy and build the new infrastructure needed to address the climate and ecological crises. This moment will not come again. You must not squander this opportunity to come out of today’s public health crisis better able to respond to the climate, biodiversity and inequality crises.
Restoring nature is an investment in health and the economy
Covid-19 has taught us that, when we destroy nature, we open the door to harmful diseases that put people’s health at risk and cause our societies and economies to grind to a halt. It’s becoming harder and harder to argue that you have to trade off the environment for the sake of the economy, when it’s environmental destruction that caused our current recession. The economy is a subset of the functioning natural systems that we rely on. When we push those systems to the brink, our health and our economic prosperity suffer. Investing in the restoration of nature is an investment in long-term prosperity.
What New Zealanders want you to do
Research from Massey University shows seven out of 10 New Zealanders want a green recovery from Covid-19.26 This mirrors global research, which finds that citizens across the world want their Governments to use the Covid recovery to address bigger issues like climate change and to more fairly distribute wealth and prosperity.27
The vast majority of New Zealanders are concerned about the climate crisis and their concerns are growing.28 The number of New Zealanders who feel the issue of climate change is important to them personally has grown to 79 percent, according to IAG polling. But only 35% think the Government is doing a good job.29 This holds strong even after the pandemic. In polling commissioned in April 2020, 63 percent of New Zealanders felt that if the government does not act now to combat climate change, it will be failing the people of this country.30 The top three environmental issues of concern for NZers are waste, climate change and water quality, in that order.
This polling and the election result indicate a very strong public mandate for visionary, ambitious and transformative change. There is more money on the table than ever before. There is no shortage of well-researched, evidence-based solutions, from academics, iwi leaders, civil society and the numerous reviews commissioned by the Government itself. This new Government is standing before an open door. You need only have the courage to walk through it.
A just recovery
The urgency of addressing the climate and ecological crises, combined with the urgency of creating jobs and income in response to the Covid-induced recession must not lead to a panicked and rushed rebuild that excludes those who are already systematically marginalised in our society.
For example, early unemployment figures show that as many as 10,000 out of the 11,000 people who lost their jobs due to Covid-19 were women. We know that, in Aotearoa New Zealand, recessions hit Māori and Pacific communities the hardest. Our Government must prioritise projects that put women, and particularly women of colour, in good and stable employment.
Furthermore, new infrastructure – from public transport and cycleways to housing developments – must be designed with access for disabled people, elderly people and children at the centre. Priority should be given to infrastructure projects – including the restoration of nature – that serve regions and communities that are currently underserved.
Most importantly, urgency must not be used as an excuse for failing to genuinely work in partnership with Māori in decision-making, as per Te Tiriti o Waitangi.
TINO RANGATIRATANGA
The fact that human health and ecosystem health are connected is largely a novel concept to our Western political and economic institutions. But it is well-understood in many indigenous worldviews including Te Ao Māori.
Greenpeace recognises that a core pillar of environmental protection is indigenous sovereignty. The UN notes that, “Three-quarters of the land-based environment and about 66% of the marine environment have been significantly altered by human actions. On average these trends have been less severe or avoided in areas held or managed by Indigenous Peoples and Local Communities.”31
According to the World Bank, “Traditional Indigenous Territories encompass up to 22 percent of the world’s land surface and they coincide with areas that hold 80 percent of the planet’s biodiversity.”32
Greenpeace recognises the te reo Māori version of Te Tiriti o Waitangi, which guarantees tino rangatiratanga for Māori. We urge the Crown to honour its obligations under Te Tiriti.
TRANSFORMING NZ INTO A LEADING REGENERATIVE ORGANIC FOOD PRODUCER
Industrial dairying is New Zealand’s single largest source of greenhouse gas emissions and water pollution. Intensive agriculture is eroding soil health, threatening access to fertile farm-land in the future. Our country needs a vision for transforming the agriculture sector in line with environmental limits and changing global consumer preferences. Subsequent Governments have shied away from meaningful action. We simply cannot afford another three years of inaction on New Zealand’s biggest climate and water polluter.
Synthetic Fertiliser
The use of synthetic fertiliser in New Zealand has enabled the intensification of dairy farming. It has led to higher stocking rates and a substantial increase in the number of dairy cows.33 This has in turn increased the methane and nitrous oxide emissions from the dairy herd. It has also significantly increased nitrate pollution of New Zealand’s lakes and rivers. Synthetic fertiliser is a water and climate pollutant itself, notwithstanding its effect on intensification. Synthetic fertiliser’s direct emissions are now greater than those from the entire domestic aviation industry.34
Studies show that decreasing synthetic fertiliser application on farms does not reduce profitability. In fact, the opposite is often true. A ten year in-field study by DairyNZ compared a farm with no synthetic nitrogen application and a farm using 181/kg/ha/yr of urea. It found that in a system using no synthetic nitrogen at all ”profitable milk production systems can be achieved without N fertiliser applications”. At lower milk price ($4.60 kg/MS) the farm using no synthetic N was more profitable than the one using 181 kgs.35 A recent economic model done by the NZ Landcare Trust found that the farm with the lowest synthetic fertiliser use and the second smallest herd had the largest increase in profitability (29%) and a 13% reduction in nitrate leaching and an 18% reduction in GHG emissions.36
In your last term, you introduced a nitrogen cap – a significant step for rivers and the climate. However, at 190kg per hectare, it is set far too high and will result in hundreds of thousands of tonnes still being used every year. Ultimately synthetic nitrogen fertiliser use must be phased down to zero.
Based on the above evidence of synthetic fertiliser’s significant environmental impacts and the evidence of the ability to farm profitably without it, Greenpeace recommends a full and regulatory phase-out of synthetic nitrogen fertiliser.
Recommendation: Phase out of synthetic nitrogen fertiliser by no later than 2024, by immediately introducing a sinking cap on its use.
Regenerative Farming
Though agriculture is currently our single biggest source of climate and water pollution, it has the potential to be one of our best solutions to the climate and ecological crises. Transitioning to regenerative organic farming will allow us to store more water and carbon in the soil, improve soil health and bring back biodiversity across rural New Zealand.
This is also what our global trading partners increasingly want us to produce. The value of the New Zealand organic export market grew 42% between 2015-2018. The global market for organic grew 397% between 2000-2016 – a compound annual growth rate (CAGR) of 10.5%.37 Some estimate it will reach US$679 Bn by 2027, with an estimated CAGR of 17.05%.38 In the European Union, the market for organics is growing faster than the area of production leading to high levels of imports. In Denmark for example, imports increased by 180% between 2008-2017; and by 20% in 2016-2017 alone.39
Around the world, many Governments have recognised the environmental and social benefits of regenerative organic farming and increased public spending and policies to support it. We recommend the New Zealand Government follow suit and make the following investments, all of which are already in practice internationally.
Recommendation: Construct plant-based food manufacturing facilities and diversified, value-added food, fibre and timber processing.
Recommendation: Construct large-scale municipal compost and seed facilities.
Recommendation: Provide one-off grant funding for agroforestry, cover-cropping and reduced tillage.
Recommendation: Finance R&D, training and advisory services for regenerative organic farming.
Imported feed
Another significant driver of dairy intensification in New Zealand is imported feed. Palm Kernel Expeller (PKE) holds the largest share of imported animal feed in New Zealand by type, constituting 68 percent of total animal feed imports by volume.40 Almost all PKE goes towards feeding dairy cows. Imported feed makes it possible to push livestock farming beyond the natural limits of the land. Additionally, PKE needs to be shipped thousands of kilometres, carries significant biosecurity risks, and can come from operations associated with deforestation, peatland development and the displacement of indigenous peoples and local communities in Southeast Asia.
Fewer cows and a transition to more plant-based regenerative farming, which doesn’t use imported feed or chemical fertilisers, is the solution to the environmental impacts of industrial livestock farming in New Zealand.
Recommendation: Phase out all imported feed by no later than 2024, by immediately introducing a sinking cap on its use.
OCEANS THAT ARE TEEMING WITH LIFE FOR GENERATIONS TO COME
The world’s oceans provide half of our oxygen, food for a billion people, and a home for some of the most spectacular wildlife on Earth. Protecting the oceans is also essential in the fight against climate change. The world’s oceans have taken up more than 90 percent of the excess heat and between 20 and 30 percent of the emissions produced since the 1980s.41
Here in New Zealand, our seas are home to some of the most rare, precious and endangered creatures. Eighty percent of our native biodiversity makes its home at sea42. But it is under enormous pressure. Ninety percent of New Zealand seabirds and twenty-two percent of New Zealand marine mammals (with sufficient data) are classified as threatened or at risk of extinction43. Fisheries pose one of the greatest threats to creatures like Hoiho penguins44, Albatross45 and Māui and Hector’s dolphins46.
We understand that the previous coalition arrangement made fisheries regulation challenging. The election result should be a clear indicator that you have the mandate to implement your commitments to ocean protection.
Independent review of fisheries management
New Zealand’s fisheries Quota Management System (QMS) has had no independent review in over 30 years. Stock collapses47, exposure of systemic illegal fish dumping48 and ongoing evidence of failure to report bycatch4950, indicate the current system of fisheries management is not working for environmental protection nor the long term sustainability of our fisheries.
The current system fails to account for the health of the whole marine environment. The QMS only looks at single fish stocks, while ignoring the effects on other marine wildlife and ocean ecosystems in the catching of those fish. Climate change is causing the ocean to change too. Fishing management must account for uncertainties in climate and ocean science, and use a precautionary principle for decisions related to commercial fishing and its environmental impacts.
There has been a long-standing call for an independent review of the management of fisheries. We were pleased to see an independent review of fisheries management adopted as a Labour Party election commitment in 2017. The previous coalition government was unable to deliver on this, but we strongly encourage a return to this commitment. For a fair and transparent fisheries reform process, the Government must undertake a review of the quota management system via an independent third party group – outside of the Ministry of Primary Industries – and ensure a balance of stakeholders are involved, including iwi and hapū, customary fishers, independent scientists and environmental groups.
Recommendation: Undertake a transparent and independent review of fisheries management.
Cameras on all commercial fishing vessels
There is a pattern of under-reporting51 and illegal dumping52 by the New Zealand fishing industry, which has been exposed over the last decade. MPI has found that commercial fishing vessels are nine times more likely to report catching a seabird when there is an observer on board53.
Cameras on boats regulation was introduced in 2017, following the Heron Report, which exposed systemic illegal fish dumping by the commercial fishing industry, and failures by MPI to prosecute the offenders54. However, the programme has faced continued stalls and delays. There can be no more excuses for delaying this essential legislation.
The implementation of cameras on boats is ultimately about transparency, and compliance with the law. The primary feature of a successful programme therefore will be ‘checks and balances’ built into the systems for collecting, reviewing and using footage. Without ‘checks and balances’ the purpose of cameras on boats will not be served.
- Successful implementation of the cameras on boats programme must include:
- Independence between the commercial fishing industry and all interested parties such as industry lobby groups, and the systems and companies which are used to capture and store the cameras on boats footage.
- Independent, government managed systems, for review of the footage and detection of offenses.
- Transparent reporting from government to the public about findings from the footage, and any actions taken if offenses are detected.
Accessible, cost-free systems for the public and interested parties to gain access to the footage for verification and transparency.
We acknowledge your pre-election funding commitment, which would amount to the implementation of cameras on approximately 20 percent of the registered commercial fishing fleet by 2024. This is a step in the right direction but is not nearly ambitious enough to arrest the decline of fish stocks and ocean biodiversity. Cameras must be introduced on all commercial fishing vessels within this Term of Parliament.
Recommendation: Introduce a mandatory requirement for cameras on all commercial fishing vessels within 3 years.
Recommendation: Ensure transparency by providing cost-free access to footage gathered for independent verification.
End bottom trawling on vulnerable marine ecosystems by the New Zealand fishing fleet
Bottom trawling is an indiscriminate and destructive industrialized fishing technique, where heavily weighted nets are dragged along the seafloor, decimating slow growing corals and sponges in the benthic environment. Areas which have been trawled show no signs of recovery even decades later55. Vulnerable marine ecosystems (VMEs) (defined, in short, by the FAO as areas with benthic life that is easily disturbed and slow to recover56), such as seamounts, are often targeted by commercial fishers as they are biodiversity hotspots. However, these ecosystems provide marine life crucial areas to feed, breed, and take refuge, and their destruction undermines the entire ocean ecosystem. As above, the current approach to fisheries management fails to account for these wider ecosystem impacts of commercial fishing.
Around the world developed nations are moving away from destructive bottom trawling. The practice has been completely banned in Hong Kong57, the North Atlantic Fisheries Organisation has protected all seamounts and vulnerable marine ecosystems from bottom trawling58 and the EU has adopted strict new rules on the practice59.
In contrast in New Zealand waters between 2013 to 2017, 841 square kilometers, or seven Wellingtons, of previously untouched seafloor was trawled for the first time60. The New Zealand fleet destroyed more than 3,000 tonnes of corals and sponges in the 2017/18 fishing season alone61. On the world stage, New Zealand is one of only a handful of nations still bottom trawling international waters and the New Zealand Government has pushed for even less protection from bottom trawling in international waters.
The IPBES reports the world is now in a biodiversity crisis, with more than a million species at risk of extinction62. The vast majority of New Zealand’s native biodiversity is found at sea63. If we are going to protect biodiversity and ensure the long term health of our fisheries and marine environment we must end bottom trawling.
Recommendation: Close all vulnerable marine ecosystems in the NZ EEZ to bottom trawling.
Recommendation: Stop issuing permits for the NZ fleet to bottom trawl in the South Pacific.
Support a strong Global Oceans Treaty
Negotiations for a new legally binding instrument for the conservation and sustainable use of biodiversity beyond national jurisdiction (BBNJ) under the United Nations Convention on the Law of the Sea began in 2018 and are set to conclude in 2021.
This “Global Oceans Treaty” is a once in a generation opportunity to set up the mechanism which will allow for the oceans protections we so urgently need. Scientific consensus is that at least 30% of the global oceans must be fully or highly protected in order for the ocean biodiversity to recover and thrive into the future, and for the oceans to build resilience to the impacts of a changing climate.
- We need the New Zealand delegation to lead the way for a network of fully protected ocean sanctuaries and much stronger control of damaging human activities on the high seas. The Treaty must:
- Include a clear objective to establish a global network of marine protected areas (MPAs).
- Use a Conference of the Parties (CoP) to establish MPAs, with a management plan and associated protective measures implemented by the States.
- Prevent insufficient or inadequate Environmental Impact Assessments (EIAs) or EIA’s of convenience, by including a process for States to request a review of any EIA by the CoP.
- Include both Emergency and Interim measures for the establishment of MPAs when human or natural phenomenon may have a significant adverse impact on marine biological diversity.
Address decision making in the Treaty itself (not left to the CoP), and adopt a majority, rather than consensus approach.
Recommendation: Advocate for a UN Global Oceans Treaty which will enable the effective creation of large scale MPAs in international waters.
Ban seabed mining
Seabed mining is a relatively new and experimental method of extracting metals and minerals from the seafloor. It involves dredging up seafloor to a ship, where it is then sorted and the valuable minerals or metals are extracted and exported offshore64. The unwanted matter (up to 95% of what was dredged) is then dumped back into the water. This dumping causes a sediment ‘plume’ which can cover several kilometers, smothering the surrounding sea floor, and interfering with the light crucial to marine life. Both the extraction and the sediment plume causes destruction of the marine environment, and creates additional pressures on fisheries and other marine life.
Seabed mining at scale is not being undertaken anywhere in the world, yet. However New Zealand waters are under threat from this new extractive industry. This year, a historic case will come before the Supreme Court, as local iwi, environmental and community groups try to hold back a permit for a large scale seabed mine being sought by international miners for the South Taranaki Bight. Several other mining companies are waiting in the wings for the outcome of this case.
This permit application is of international significance as mining companies around the world are looking for a precedent to open the gates for this industry. Across the Pacific several nations, including the Cook Islands65 and Tonga66 are being courted for exploitation by predominantly European-based seabed mining companies. Meanwhile, other Pacific Islands such as Fiji, Papua New Guinea and Vanuatu have called for support for a ten year moratorium on seabed mining67. Many scientists have expressed serious concerns over the multiple potential impacts of seabed mining68.
It is not good enough to rely on the resources and energy of iwi and community groups to protect New Zealand waters against the interests of international miners. The New Zealand Government should be taking a precautionary approach, and leading the defence of the marine environment against experimental and exploitative mining activities, as well as being a strong voice of support for our Pacific neighbours in protecting their marine ecosystems.
Recommendation: Ban on seabed mining in New Zealand’s EEZ.
Recommendation: Support an immediate moratorium on seabed mining in the Pacific for no less than ten years.
POWERING NEW ZEALAND ON HOMEGROWN CLEAN ELECTRICITY
The energy sector is responsible for about 40 percent of New Zealand’s emissions. To turn this around, we need to firstly get more efficient at using what we’ve already got. Secondly, we need to replace fossil fuels with clean, renewable electricity and other sustainable fuels, such as waste wood. Transpower forecasts that our electricity production needs to increase by 68 percent by 2050 to meet growing demand from vehicle electrification and industrial processing.69
We need a huge workforce to construct new wind turbines and transmission wires. We need installers to fit solar panels, battery packs, and efficient heaters in homes. More workers will be needed to upgrade our homes and businesses to be smarter, warmer, and more energy efficient. Who benefits from this massive clean energy programme also matters.
We commend your courageous decision, last term, to ban new offshore oil and gas exploration permits. We also acknowledge the progress you have made on planning for a new energy future for New Zealand. This term, that plan must turn into real action on the ground.
Household- and Community-Owned Energy
The technology exists for communities to be able to generate their own power from clean sources like wind and solar. Many New Zealanders want to be able to produce their own energy independently of large power companies. As it stands now, communities face many barriers to generating their own power, from legal and financial barriers to low/unpredictable buy-back rates and discriminatory lines charges.
Reducing barriers and supporting people and communities to make their own energy is important to ensure that the benefits of clean energy flow to local people – not just large energy companies. But overseas experience shows it is also a critical way to ensure local buy-in to new energy development. So-called NIMBYism has been a barrier to wind energy development overseas. European experience shows that investing in community energy – or requiring new energy developers to offer shared-ownership to local communities – is critical to avoid NIMBYism.
Recommendation: Provide grant funding for community energy schemes.
Recommendation: Provide zero interest loans for household solar.
Recommendation: Remove barriers to community energy projects and provide a “one-stop-shop” of information on how to develop community energy projects.
Recommendation: Require all new energy developers to offer shared ownership to local communities.
Recommendation: Install solar panels on government buildings, schools and social housing.
Energy efficiency
There are over 600,000 under-insulated homes70 that have very little or nothing in the ceilings or between the floorboards to keep the heat in when temperatures plummet. By ramping up existing grants and support schemes to help families insulate their homes and install a heat pump, we could retrofit all cold, damp housing within 10 years. Not only will this prevent tens of thousands of children from being admitted to hospital each year with respiratory illnesses and infectious diseases, it will also reduce energy demand during peak times, which is when polluting and expensive gas and coal-fired power stations are running.
The Government needs to significantly tighten minimum energy efficiency requirements in the Building Code. Building new homes to be net zero, following passive house standards – a rigorous energy efficiency standard – would dramatically cut bills by reducing energy used for heating and cooling, while relieving pressure on the energy grid during the winter evening peak.
Recommendation: Extend finance and support for home insulation and heat pumps so that all 600,000 under-insulated homes are insulated in the next 10 years.
Recommendation: Update the Building Code so that all new homes are net zero, following passive house standards.
Recommendation: Build all new Kāinga Ora and KiwiBuild homes according to passive house standards, including clean energy generation, rainwater collection and greywater recycling.
Fossil fuel exploration and mining
It has long been understood that we cannot afford to burn most of the fossil fuels currently held in reserves, let alone search for more. The most recent study on this has found that oil and gas production from active fields is already more than we can burn if we’re to limit global warming to 1.5°C.71 Even oil giant BP has confirmed this.72
Searching for new fields to open up is both catastrophic for the climate and risks leaving the Crown with a host of stranded assets. The debacle that the bankruptcy of former Tui field operators, Tamarind Taranaki, has caused for the Crown and taxpayers should be a warning.
The Government has shown strong leadership on climate change by banning the issuing of new offshore oil and gas exploration permits. This ban needs to be extended to cover all fossil fuel exploration, on, in and under land and sea.
Recommendation: Ban the issuing of new oil and gas prospecting and exploration permits onshore in Taranaki.
Recommendation: Ban the application for and issuing of new coal mining permits.
Recommendation: End all fossil fuel (coal, oil, gas) permit extensions.
Recommendation: Revoke all unused fossil fuel (coal, oil, gas) permits.
Recommendation: Update the purpose of the Crown Minerals Act so that the law regulates, rather than promotes, petroleum and minerals activities.
A managed phase-out of existing oil, gas and coal infrastructure
The Government’s commitment to a Just Transition, including the establishment of a dedicated unit at MBIE, is admirable. However, this work has not progressed at pace. We have no choice about whether or not to cease using fossil fuels – we must. You cannot negotiate with climate science. We do, however, have a choice about what opportunities and support are provided to those workers and communities who are currently dependent on the fossil fuel industry. The Government must plan now for the managed closure of existing fossil fuel mining, including developing pathways for supporting workers and affected communities with employment and development opportunities in sustainable industries.
- The Government must also carefully plan how to use remaining fossil fuel reserves, in particular gas. The Energy Minister should instruct MBIE to carry out a review and prioritisation of existing fossil fuel use, based on:
Which current uses of fossil fuels can be easily replaced
- Which areas require research and development spending to find alternatives
Which uses should be prioritised due to a lack of readily-available alternatives in the short-term
Recommendation: Produce a Managed Phase Out Plan for the fossil fuel industry.
Recommendation: Ban all new coal, gas and diesel infrastructure.
Recommendation: Phase out all existing coal, gas and diesel infrastructure by 2030.
TRANSPORT INFRASTRUCTURE DRIVING THE COVID-19 RECOVERY
Transport is New Zealand’s fastest growing source of carbon emissions.73 New Zealand’s car ownership is the highest in the OECD. We are one of the only countries in the world without vehicle fuel efficiency standards.
Transport is fundamentally an infrastructure challenge. We need to build public and active transport options so that people can choose to leave the car at home, without compromising on convenience or cost. The Covid-19 Recovery, and particularly the focus on infrastructure development, creates a unique, once-in-a-generation opportunity to upgrade our transport systems so that they are low-carbon and accessible.
Mode-shift is critical. To address climate change, congestion and access issues, we cannot simply replace our large existing car fleet with electric cars.
Recommendation: Unprecedented investment in public transport, including electric rail and busways.
Recommendation: Unprecedented investment in separated cycleways.
Recommendation: Investment in regional rail links, including an overnight link between Auckland and Wellington.
Recommendation: Investment in a nation-wide electric vehicle charging network.
Reducing emissions from the vehicle fleet
As we build the essential infrastructure needed to shift more people onto public and active transport, we must also address emissions from the private vehicle fleet. New Zealand is falling behind many peer nations in adopting policies to discourage petrol/diesel vehicles and instead encourage electric vehicle uptake.
The so-called “feebate” legislation has already been written. We understand that coalition politics prevented it from getting through Cabinet last term. The election result has lifted that barrier and the legislation should be brought before Cabinet once again.
Recommendation: Ban the import of fossil fuel vehicles by 2030.
Recommendation: Introduce the proposed electric vehicle “feebate” scheme and fuel efficiency standards.
A CIRCULAR ECONOMY FREE OF SINGLE-USE PLASTIC WASTE
Up to 9 of 10 seabirds,74 1 in 3 sea turtles75 and more than half of whale and dolphin species have ingested plastic.76 Seven out of eight of New Zealand’s most common caught fish have been shown to have eaten plastics.77 Just nine percent of all the plastic that’s been produced in the world has actually been recycled.78 The rest ends up in landfills or in the oceans, where it’s choking wildlife or even turning up on our plates in sea salt and seafood. A whole rubbish truck worth of plastic gets dumped into the ocean every minute.79 And global plastic production is accelerating.
The Government should follow international best practice and ensure that policy to address plastic pollution adheres to the waste hierarchy.80 The waste hierarchy prioritises the prevention, reduction and reuse of waste over attempts to divert, recycle or dispose of waste once produced. As a pollution mitigation strategy, reducing plastic consumption is more cost-effective and efficient than researching, developing and investing in on-shore processing plants for the wide range of polymer types that exist, getting waste plastic to those plants, and spending money stockpiling or disposing of low-value, non-recyclable plastic.81 Simply put, if the plastic doesn’t exist in the first place, we need fewer elaborate systems to deal with it.
According to polls, waste is New Zealanders’ top environmental concern. There is a huge public mandate for Government leadership.
Ban avoidable plastics, including plastic bottles
Domestically and internationally, plastic bottles, caps and lids are consistently in the list of top 10 items found in terrestrial, marine and coastal plastic pollution surveys.82 Every year it is estimated that 2.23 billion beverage containers are consumed in New Zealand,83 with more than half of these being plastic. Other prevalent plastics include coffee stirrers and disposable cutlery.
The Government has already banned plastic bags, resulting in an estimated 1.1 billion plastic bags a year removed from circulation.84 Banning plastic bags was perceived by some as a radical move, but is now widely accepted. Banning plastic bottles and other unnecessary single-use plastics is the obvious next step. Introducing a system for collection, sterilisation and refill is also a great regional job creator at a time when we need new sources of employment. The Container Return Scheme, currently being developed, provides a strong foundation for developing a more comprehensive refillable system.
Recommendation: Introduce a ban on plastic beverage containers.
Recommendation: Develop reusable and refillable beverage container systems.
Plastic pollution levy and reduction targets
The low cost of plastic makes it hard to dissuade companies from making and selling them. Unnecessary problem plastics are everywhere, including coffee cups and lids, food packaging, takeaway containers, cigarette butts, balloon and lollipop sticks. We propose a levy is introduced on these kinds of single-use plastics, making it more economic to produce reusable alternatives or reduce excessive and ridiculous packaging. The revenue could be used to fund research on redesigning products and packaging so they don’t end up floating around in the oceans for centuries.
We need a national target to keep us on course. We recommend a 50 percent reduction of single-use plastics by 2025, and 80 percent by 2030. Ultimately they would be phased out altogether.
Recommendation: Introduce a plastic pollution levy.
Recommendation: Introduce national targets to phase out single-use plastics.
FIT FOR PURPOSE LAWS AND GOVERNMENT AGENCIES
It is our experience that a number of laws and agencies whose purpose is to protect the environment or promote democracy are failing in their mandate and must be updated or reformed.
Environmental Protection Authority
The Environmental Protection Authority has, in our view, been little more than a rubber-stamp agency for numerous destructive projects, including deep sea oil and gas exploration and seismic testing. Over the many years the Authority has been considering oil and gas drilling applications, it has given the green light to every single one of them.
Greenpeace has experienced a series of concerning interactions with the EPA in relation to the consenting process for oil and gas development. This includes carrying out fractured and confusing consenting processes, withholding information that is in the public interest and pursuing public interest organisations for legal costs.
The EPA should be one of our Government’s most important environmental regulators, but it is failing to serve its function: to protect our natural environment. It needs to be reformed.
Recommendation: Review and reform the Environmental Protection Agency.
Amend the Exclusive Economic Zone and Continental Shelf Act
The Exclusive Economic Zone and Continental Shelf (Environmental Effects) Act 2012 (EEZ/CS Act) needs to be reviewed to restore public participation and environmental protections.
In 2013, a number of potentially damaging activities were gazetted as permitted activities including seismic testing, and marine scientific research, prospecting and exploration, with no effective controls over damage that may be thereby caused, no public scrutiny, and no transparency. Then in 2014, the Government made exploration drilling for petroleum in the EEZ or continental shelf non-notified activities so an application for a marine consent for any of those activities may not be publicly notified.
These regulations not only undermined the important procedural steps built into the EEZ/CS Act but meant that potentially damaging activities in the EEZ can be carried out, out of sight of the public and beyond regulatory controls, specifically to enable oil and gas exploration.
In addition, section 59(5) of the EEZ/CS Act provides that “the marine consent authority must not have regard to (b) the effects on climate change of discharging greenhouse gases into the air.” This regulatory framework is inconsistent with the latest climate science, as well as the recent amendments to the Resource Management Act.
Recommendation: Urgently review the EEZ/CS Act to restore democracy and environmental protections.
The Official Information Act
The OIA is a vital tool for holding Government to account, and is sometimes the only tool available to bring to light concerning actions by those in government. However, there are serious problems with the OIA, and this is preventing the Act from doing what it was designed to do – make government more transparent.
- Submissions to a recent review by the Ministry of Justice highlighted serious issues, including:
- Excessive deletions in released information. Although the OIA contains grounds for withholding information, there is concern information is withheld for reasons not allowed by the Act, such as when it is seen as potentially controversial or politically damaging.
- Delays – requests are meant to be answered within 20 days at the most. This is important; holding Government to account requires timely information.
The need to expand the OIA to include bodies carrying out public functions such as the auditor-general.
Together with the Child Poverty Action Group, Forest and Bird, JustSpeak, New Zealand Council for Civil Liberties and Amnesty International, we are calling for a comprehensive, independent review of the Official Information Act.
Recommendation: A comprehensive review of the Official Information Act.
Independent Powers for the Climate Commission
The Climate Commission was established by the Zero Carbon Act to provide advice to the Government on achieving its climate goals. However, the Climate Commission has no power of its own to actually achieve these climate goals, unlike other independent institutions like the Reserve Bank.
Climate change is an existential intergenerational threat, which needs an independent institution to provide advice to the Government free from the pressures of day to day politics. Therefore we need to empower that institution. This is precisely the logic for giving the Reserve Bank independent powers to address inflation, amongst other things. And surely climate change is at least as important as inflation.
The key power that the Climate Commission should be given is the power to influence the price of emission units under the ETS. This could be done in multiple ways but the obvious one is to give the Climate Commission the power to decide how many ETS emission units are auctioned each year. The Commission could look at New Zealand’s performance in achieving its emission budgets, and if the country was falling behind and emitting too much, then the Commission could auction fewer carbon units, thereby driving up the price of emission units.
This would have the direct effect of reducing emissions via higher prices. But it would also have the indirect effect of encouraging governments to implement credible climate policies or face the prospect of the independent Climate Commission pushing up the price of emissions.
Recommendation: Give the Climate Commission independent power to influence the price of emissions.
CONCLUDING REMARKS
Once again, congratulations on a landslide election result, showing a strong vote of confidence in this Government’s direction. The Prime Minister’s promise of kindness, hope and protecting nature has clearly mirrored Kiwis’ aspirations for a better future.
This election was all about Covid-19. The coronavirus pandemic has exposed how fragile our society and economy are to disasters that are driven by ecological destruction. This pandemic is a timely reminder that human health and wellbeing is inextricably linked to the health of the natural systems we depend on. Investing in the restoration of nature is an investment in public health and prosperity.
Covid has also created a once-in-a-generation opportunity to restore nature. It has put a brake on business as usual and given us a chance to reassess our trajectory. The Government’s decision to stimulate the economy through an unprecedented boost in public spending, particularly on infrastructure, has given us the financial means that were previously perceived to be lacking.
This is the greatest opportunity in our lifetime to reorient our economy and society so that it works within the natural limits of the Earth. We believe the aforementioned policies are essential for delivering on this vision. Some mirror with your existing pledges, while others encourage you to go a step further to align with what the science tells us is needed. We recognize that this is not an exhaustive list and in particular there are gaps in our in-house expertise on conservation. We trust that other organisations with greater expertise in this area will also be offering their advice.
We are truly at a pivotal moment in history, with one of New Zealand’s most popular leaders at the helm. This Government must not squander the opportunity to take meaningful action on agriculture, ocean protection, energy, transport and waste. It is almost certainly our last chance.
We welcome the opportunity to meet with you to discuss any of these policies in more detail. In the meantime, we are happy to provide more information in written briefings on any of these issues.
REFERENCES
Take Action
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9 https://www.nature.com/articles/s41558-020-0797-x
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12 https://www.un.org/sustainabledevelopment/blog/2019/05/nature-decline-unprecedented-report/
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16 https://www.unenvironment.org/news-and-stories/story/coronaviruses-are-they-here-stay
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21 Ministry for the Environment & Stats NZ 2017: New Zealand’s Environmental reporting series : Freshwater and nitrogen leaching.
22 Ministry for the Environment 2020, Snapshot – New Zealand’s Greenhouse Gas Inventory 1990–2018. Page 4.
23 Espejo‐ Herrera, et al. 2016 “Colorectal Cancer Risk and Nitrate Exposure through Drinking Water and Diet.” International Journal of Cancer, vol. 139, no. 2, 2016, pp. 334–346.
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25 https://www.rnz.co.nz/national/programmes/outspoken/audio/2018627863/outspoken-canterbury-water
26 https://www.researchgate.net/publication/343486253_Aotearoa-New_Zealand_Public_Responses_to_COVID-19_and_Climate_Change
27 https://cic.nyu.edu/sites/default/files/zhttps://www.iag.co.nz/latest-news/articles/Kiwi-concern-grows-about-climate-change.htmlamore-phillips-covid19-public-support-radical-policies-web-final.pdf
28 https://www.iag.co.nz/latest-news/articles/Kiwi-concern-grows-about-climate-change.html
29 https://www.ipsos.com/sites/default/files/ipsos-nz-climate-change-and-covid19-april-2020.pdf
30 https://www.ipsos.com/sites/default/files/ipsos-nz-climate-change-and-covid19-april-2020.pdf
32 World Bank (2008) The Role of Indigenous Peoples in Biodiversity Conservation. http://documents1.worldbank.org/curated/en/995271468177530126/pdf/443000WP0BOX321onservation01PUBLIC1.pdf
33 PCE 2013: Water quality in New Zealand: Land use and nutrient pollution. Page 16.
34 Ministry for the Environment 2020, New Zealand Greenhouse Gas Inventory 1990-2018. Page 41.
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37 Organic Association of NZ, 2018. New Zealand Organic Market Report 2018.
39 16 Willer, H., Schlatter, B., Travnicek, J., Kemper, L., Lernoud, J., 2020.The world of organic agriculture. Statistics and emerging trends 2020. Research Institute of Organic Agriculture FiBL and IFOAM Organics
40 https://www.mpi.govt.nz/dmsdocument/40808-economic-update-for-the-primary-industries-june-2020
41 See for example https://www.ipcc.ch/srocc/chapter/summary-for-policymakers/ and https://www.pnas.org/content/pnas/early/2019/01/04/1808838115.full.pdf
42 Brake, L, & Peart, R. (2015). Sustainable Seas: Managing the Marine Environment. Environmental Defense Society
45 https://www.doc.govt.nz/nature/native-animals/birds/birds-a-z/albatrosses/conservation/
47 https://www.mfe.govt.nz/publications/marine/our-marine-environment-2019
48https://www.rnz.co.nz/news/national/304235/mpi’s-own-officials-think-fish-dumping-is-high
49 https://www.nzherald.co.nz/nz/fishing-boat-camera-trial-in-hauraki-gulf-shows-seabird-bycatch-reporting-doubles/7YRBBNJ3H67LBMMNII3S7VK3JE/
50 https://www.nzherald.co.nz/nz/new-zealand-commercial-long-line-fishers-nine-times-more-likely-to-report-bycatch-with-observers-on-board-fisheries-nz-report/NUCLC4KB62X6P4EMAJUMNJ4XK4/
53 https://www.nzherald.co.nz/nz/news/article.cfm?c_id=1&objectid=12302577
55 https://www.frontiersin.org/articles/10.3389/fmars.2019.00063/full
56 http://www.fao.org/3/i0816t/i0816t00.htm
57 https://science.time.com/2011/06/10/hong-kong-sets-high-bar-with-trawling-ban/
58 http://www.savethehighseas.org/2019/09/27/nafo-closes-last-remaining-seamount-trawl-fishery-on-the-high-seas-in-the-northwest-atlantic-sets-some-quotas-too-high-to-ensure-sustainable-fisheris-and-stock-recovery/
59 http://www.savethehighseas.org/2016/12/13/european-parliament-bans-trawling-800m-eu-waters/
60 https://www.wwf.org.nz/media_centre/publications/?16901/The-ever-increasing-destruction-of-the-sea-floor-in-New-Zealand-Aotearoa
61 https://www.greenpeace.org/aotearoa/press-release/bottom-trawled-coral-stolen-by-talleys-dumped-at-parliament/
62 https://ipbes.net/global-assessment
63 Brake, L, & Peart, R. (2015). Sustainable Seas: Managing the Marine Environment. Environmental Defense Society.
64 http://kasm.org.nz/seabed-mining/what-is-seabed-mining/
65 https://www.ecowatch.com/cook-islands-mining-2646199832.html?rebelltitem=4#rebelltitem4
68 https://miningwatch.ca/sites/default/files/nodule_mining_in_the_pacific_ocean.pdf
69 https://www.transpower.co.nz/resources/whakamana-i-te-mauri-hiko-empowering-our-energy-future
70 EECA (2016) Programme Review: Warm Up New Zealand.
71 Global Witness (2019) Overexposed: How the IPCC’s 1.5°C report demonstrates the risks of
overinvestment in oil and gas. https://www.globalwitness.org/en-gb/campaigns/oil-gas-and-mining/overexposed/
72 “Existing reserves of fossil fuels – i.e. oil, gas and coal – if used in their entirety would generate somewhere in excess of 2.8 trillion tonnes of CO2, well in excess of the 1 trillion tonnes or so the scientific community consider is consistent with limiting the rise in global mean temperatures to no more than 2 degrees Centigrade. And this takes no account of the new discoveries which are being made all the time or of the vast resources of fossil fuels not yet booked as reserves.” https://www.bp.com/content/dam/bp/business-sites/en/global/corporate/pdfs/news-and-insights/speeches/new-economics-of-oil-spencer-dale.pdf
74 http://www.pnas.org/content/112/38/11899.full.pdf
75 http://www.huffingtonpost.com.au/2016/03/17/turtles-marine-plastic_n_9455496.html
76S. Baulch, C. Perry / Marine Pollution Bulletin 80 (2014) 210–221
78 https://wedocs.unep.org/bitstream/handle/20.500.11822/25496/singleUsePlastic_sustainability.pdf
79 http://www3.weforum.org/docs/WEF_The_New_Plastics_Economy.pdf
80 See, for example, United Nations Environment Assembly of the United Nations Environment Programme Marine Plastic Litter and Microplastics UNEP/EA.2/Res.11 (2016) para 7.
81 As the explanatory memorandum of the European Commission’s proposed EU plastic Directive notes “[u]pstream measures aiming to reduce consumption are more efficient” (p.10).
82 Ocean Conservancy (2017) International Coastal Clean Up 2017 Report, p.13; Greenpeace New Zealand (2018) Plastic-Free NZ: An action plan to end plastic pollution, p.2; Waste Not Consulting (2018)
National Litter Survey, 2017/18: Summary of Results, , p.1; Keep New Zealand Beautiful (2019) National
Litter Audit; 5 Gyres (2018) Better Alternatives Now: BAN List 2.0, pp.6-7; Anne Schroeer, Matt Littlejohn and Henning Wilts (2020) Just one word: refillables. How the soft drink industry can – right now – reduce marine plastic pollution by billions of bottles each year (Oceania), p.2; Eilidh Robb and Grainne Murphy (eds) Moving Away from Single-Use: Guide for National Decision Makers to Implement the Single-Use
Plastics Directive (Report by Rethink Plastic alliance and Break Free From Plastic, 10 October 2019),
p.23.
83 https://www.nzpsc.nz/wp-content/uploads/2019/02/CDS-Model-FINAL-26-FEB-2108-1.pdf page 2
