Monday, May 09, 2011

Climate change: Avoiding analysis

Earlier this year, the government formally adopted its climate change target of a 50% reduction (from 1990 levels) by 2050. You would expect that when the government was setting this sort of target, with important and long-term effects, they would consider somewhere in the process whether it was achievable. This being National, you are probably no longer surprised that they didn't.

The target was set by Cabinet last December in a paper titled New Zealand Greenhouse Gas Emissions Reduction target "50 by 2050": Release of Minister's position paper [PDF]. Cabinet permission was required because the exercise involved public consultation and because Cabinet had agreed in a one-line aside in 2009 [para 31] to set the target by regulation rather than a gazette notice. The paper notes that the target has been

developed taking into account other Annex 1 country targets, New Zealand's agriculture intensive economy, and international agreement that global temperature increase needs to be limited to no more than 2 degrees Celsius (to avoid dangerous climate change).
It talks about the need for a target to "make a definitive and credible statement" about our commitment to climate change, and send a message to investors. It notes in passing that there is "no mechanism for enforcement" and that the consequences of failing to meet the target are "predominantly reputational". But nowhere in the paper, or in any of the other documents I have received or viewed on this issue, is any analysis of whether it can be met. In fact, reading between the lines, the decision to impose a target by Gazette notice rather than regulation was driven by a desire to avoid such analysis. The paper notes that using a Gazette notice means that no Regulatory Impact Statement is needed. Meanwhile, an earlier briefing note from MfE ("Options for setting a 2050 emissions reduction target", 10-B-04111, 28 October 2010), notes that
[a] regulatory impact statement would rely on existing data on domestic abatement potential. This data is currently insufficient to provide meaningful analysis on how the target might be achieved, the costs and benefits of the proposed target compared to alternatives, and the regulatory, economic and environmental impacts of the proposal. Setting a target by regulation is likely to draw public attention to the fact this data does not yet exist...
(Emphasis added)

Using a Gazette notice allowed this unpleasant fact - as well as the unpleasant fact that the government has already legislated for failure through high pollution subsidies - to be glossed over. Its another triumph of PR over policy. Which is par for the course for National.