Submission on Draft Climate Adaptation Plan

Pacific Ecologist magazine
5 min readAug 11, 2022


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

The risks identified in the Draft Plan are so numerous and compounding that it is obvious that climate change effects will exceed our ability to adapt. This fact is most overtly shown in the section dealing with “the seven economic risks and their cascading impacts across the economy”. That only the ‘top ten’ of forty-three risks identified in the National Climate Change Risk Assessment 2020 are addressed in detail further indicates the overwhelming magnitude of climate change and related effects. There is some acknowledgement of this in the introduction by the Chair of the Climate Change Chief Executives’ Board — “More change will come and impacts will increase, disrupting nature and society, affecting people’s health and wellbeing and damaging livelihoods.” It is not so clearly acknowledged that some of this disruption and damage will be irreparable and/or unforeseen. Much of the response will be purely reactive. While it is certain that “We need to change how we do things..” this is so we can survive rather than “..thrive in a climate that that continues to change.”

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

There is no mention in the Plan of the emissions which would be incurred by many adaptive actions. Activities such as infrastructure upgrades and defensive earthworks are highly emissions intensive. Despite the best adaptive planning there will also inevitably be increasing requirements for urgent remedial action. At present, the financial cost of such responses is regularly reported but the emissions cost is not. The Plan makes no mention of such costs although these will materially affect our overall emissions. In the situation of a scientifically informed and politically agreed emissions budget this is a curious oversight.

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

In the matter of managed retreat there is a particular point of difficulty that is implied but not openly addressed. This is the problem of allowing for landward migration of coastal ecosystems such as saltmarshes where there is privately-owned land, possibly with buildings, in the places where such migration must occur. Although it is conceivable that property owners will accept that they must abandon land and homes that are at risk of damage from sea-level rise, it is less likely that they will be quite prepared to make way for Nature. Unless this point is addressed by such a mechanism as compulsory purchase as has been employed for the purposes of essential public infrastructure, these critical habitats and their biodiversity will be lost. The intent to pursue such a course of action should be signalled early in the complex discussions around managed retreat. Although coastal ecosystems are a particularly important case, this conflict between property rights and Nature preservation and enhancement is a general issue of long standing which will be amplified by adaptation to climate change.

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