Submission on Draft Climate Adaptation Plan

3 June 2022

To Ministry for the Environment, Wellington, Aotearoa/New Zealand.

Submitter: Dr Cliff Mason, for The Pacific Institute of Resource Management, Wellington, Aotearoa/New Zealand;

Contact: Dr Cliff Mason, Lyttelton —

The Pacific Institute of Resource Management (PIRM) welcomes the opportunity to make this submission. PIRM is a long-established organisation dedicated to promoting the sustainable use of the earth’s resources. It publishes the occasional journal “Pacific Ecologist”. We have made frequent submissions to government on Climate Change issues over the last 20 years including submissions on New Zealand’s Climate Change Target (3rd June 2015 and 31st July 2009), Emissions Trading (26th February 2009 and 28th May 2007), Zero Carbon Bill (15th July 2019) and the Climate Action Plan. These and other Submissions are available on our website (

It is gratifying to see such a comprehensive Plan which recognises the importance and pervasiveness of climate change effects. Rather than answering the multitude of questions in the consultation document, this submission addresses a small number of overarching matters which are underemphasised in or absent from the Draft National Adaptation Plan .

1) The limits to adaptive capacity

2) The emissions cost of adaptive actions

3) The conflict between property rights and protection of nature

Limits to adaptive capacity

There will be increasing difficulty in providing basic needs and the growth imperative that underpins our present economy will be negated. A long descent in standards of living appears inescapable. There is a suggestion that this has been recognised in the vague reference of Objective SW3 to “different socio-economic scenarios”. The nature of these scenarios will hopefully be more apparent in the delivery plan for guidance in their use, promised by September this year.

There is obviously a strong desire not to scare the public and to bring the matter into the familiar and comfortable context of risk management. This submission contends that a more open and honest expression of the limits on our ability to adapt would be valuable, especially in the maintenance of social cohesion. There is a need for widespread acceptance that our world is now radically destabilised and unpredictable. That many still call for ‘certainty’, despite the lessons of the pandemic, indicates that there is a lot of attitudinal change to be made.

The Draft Plan proposes to introduce a large amount of new activity in the administration of ever-enlarging and changing datasets. This introduces the possibility of an unsustainable administrative burden and consequent systemic collapse as described in the work of Joseph Tainter. It might prove better to adopt a simple and more generally applied ‘worst case’ approach to many of the threats rather than attempting to particularise and accurately quantify risks.

Emissions cost of adaptive actions

It is essential there is emission costing of all proposed activities and that an allowance is made for increasing emissions as a consequence of remedial action. The former will be an important factor in choosing the most appropriate course of action or inaction. In the present state of Climate Emergency, activities which involve emissions without any net benefit — especially in reducing future emissions — are untenable. Increasing needs for remedial action will also shrink the budget allowance for adaptive action.

Emissions accounting of adaptive activities should be added to the Plan as a guiding principle — to avoid or mitigate emissions resulting from adaptation — and included as a mandatory part of all monitoring, evaluating and reporting.

It is tacitly acknowledged in the Minister for Climate Change’s introduction that adaptation may distract from mitigation activity. Including the emissions cost in all considerations of adaptive activity would preclude such dangerous distraction.

Conflict between property rights & preservation of Nature

Apart from this omission, the discussion on managed retreat is comprehensively set out and conclusions should be forthcoming after a period of difficult negotiation. In passing it is noted that the situation could be considerably simplified if we had a capital gains tax. Such a tax which recognises the social creation of private wealth and claims a proportion for society could conceivably be extended to include the taking of responsibility for social destruction of capital value as a consequence of climate change with a compensatory return to the private owner as tax credits. Such a system would allow for the continued use of resources at risk until such time as they are physically disabled by climate change effects.

Yours sincerely,

Cliff Mason MB, ChB, BSc



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