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Further Submission on NPS for Renewable Electricity Generation

To Dr Royden Somerville
Chairperson
Board of Inquiry, National Policy Statement for Renewable Electricity Generation

Name of person / organisation making further submission:

New Zealand Recreational Canoeing Association
c/- Duncan Catanach
North Island Conservation Officer
PO Box 284
Wellington



This is a further submission in opposition to (see position below), the proposed national policy statement for renewable electricity generation (the proposal).


Background to NZRCA

  • Formed in 1957, the New Zealand Recreational Canoeing Association (NZRCA) is the national representative organisation of canoe clubs and recreational kayakers throughout New Zealand. NZRCA is a voluntary, non-profit, incorporated society and is affiliated to the NZ Canoe Federation (NZCF).  The NZCF is in turn affiliated to the International Canoe Federation. NZRCA has delegated authority to represent the NZCF and all its member disciplines on advocacy issues.
  • NZRCA was known as the New Zealand Canoe Association until 1995/6.  At this time the competitive canoeing disciplines were spun off into their own associations, the new umbrella body the NZCF was formed, and NZCA renamed itself to the NZ Recreational Canoeing Association to reflect its non-competitive advocacy role.
  • NZRCA has been an active, responsible and respected participant in RMA processes concerning river systems for many years.
  • NZRCA has developed a draft Conservation Policy, an excerpt of which is included in this further submission as an Appendix.  This submission should be taken in the context of that policy document and we urge the Board of Inquiry to read this document carefully as many of the points made by submitters and supported by us are reflected here.

Summary of Submission

The NZRCA believes that the cost to New Zealand’s river systems due to hydro electricity generation has already been very high1 and that the pressure on individual river systems is likely to get significantly greater in the future.2  The NZRCA also notes that in general, recent policy changes have had the overall effect of making further development of rivers more likely.

The NZRCA opposes the NPS as it currently stands believing that it is likely to result in many of our finest rivers, and New Zealand’s internationally recognised and valued whitewater resource being destroyed.

The NZRCA supports the following general principles put forward by submitters:

  • The definition of “renewable” generation is flawed. While water is renewable, rivers are not (Fish and Game NZ, paras 2, 26, 51; Ecologic, p1)
  • The exclusion of other forms of energy generation and demand management is likely to make the integrated management of natural and physical resources as required by the Act difficult (Fish and Game NZ, paras 10 – 14; WRAP para 2)
  • There is a need for a national, strategic and consultative approach to be taken to the management of New Zealand’s river systems, including hydro generation (Forest and Bird NZ, p7)
  • The full cost of a renewable electricity scheme must be considered in any decision making, including the cost of dam removal and environmental remediation (Ecologic, p6)
  • The exclusion of other forms of energy generation and demand management is likely to make the integrated management of natural and physical resources as required by the Act difficult (Ecologic, p1; Fish and Game NZ para 5)
  • The NPS should also address best practice in a number of areas such as consultation, siting, operations and so on (Forest and Bird NZ, pp 6 -7, WRAP)
  • New Zealand’s environmental reputation is likely to be significantly damaged by application of this National Policy Statement (Fish and Game NZ, paras 5 -9)

The NZRCA’s position on the NPS itself is as follows:

Objective: Conditional support (in part)

Policy One: Oppose

Policy Two: Oppose

Policy Three: Support

Policy Four: Oppose

Policy Five: Conditional support (in part)

NZRCA supports those submissions who offer similar support / opposition to the policy statements and points made by the NZRCA.  In particular, the NZRCA notes that:

  • The underlying objective of this NPS is to reduce greenhouse gas emissions not “renewable” electricity generation (Ecologic, p1, a(i))
  • The objective makes no explicit provision for weighing adverse effects (Ecologic p1, a(i))
  • It is highly questionable whether all “renewable” generation is nationally significant (Forest and Bird NZ, p5, Fish and Game NZ, para 17, 39-40)
  • It is not appropriate, nor consistent with the RMA, for “renewable” energy to take precedence over other matters (Helen Brosnan, s1.2; Forest and Bird NZ, p5; Fish and Game NZ, para 23)
  • NZRCA strongly opposes Policy Two which appears to give undue weight to matters which would enable a consent authority to overlook actual or potential adverse effects of a proposal where “avoiding, remedying or mitigating adverse effects would be impractical” (Fish and Game NZ, para 41, Forest and Bird NZ, p5)
  • NZRCA strongly supports the notion of reversibility in Policy Three, though agrees with submitters that this concept needs to be better defined (Fish and Game, paras 7 – 9, 44-45 and Appendix; Ecologic, pp 2, 4-6
  • Regionally and nationally significant environmental and recreational resources, including whitewater resources, should be identified as well as “renewable” energy resources within a region (Fish and Game, para 48; Brosnan s6.4, p7)
  • Small and community-scale distributed generation can still have significant impacts on the whitewater amenity value and the safety of recreation on a river section and these must still be taken fully into account (Forest and Bird NZ – p6).

The NZRCA supports/opposes, the submission of:

This matter is summarised in the following table:

#

Submitter Name

Any Particular Points

Support / Oppose

34

Royal Forest and Bird Protection Scoity of NZ (Inc)

All, but particularly pp 5 – 7. See commentary below

Support

51

Ecologic Founcation Inc

All, but particularly pp 1-2, 4 – 6. See commentary below

Support

112

Fish and Game New Zealand

All, but particularly paras 2, 5-14, 17, 23, 26, 39-41, 44-45, 48, 51. See commentary below

Support

63

Helen Brosnan

All but particularly s1.2 and 6. See commentary below

Support

16

Nelson Canoe Club

Particularly commentary on Policy 3

Support

102

Wild Rivers Action Project

Particularly paras 2 (the second one!), 3 and 6

Support

22, 23, 94

Pioneer, King Country Energy and TrustPower

NZRCA opposes their conditional support for Policy 2, particularly the statement that Policy 2 should be extended to provide direction to the removal of barriers to access to land, particulary with respect to conservation land.  NZRCA also opposes their opposition to Policy 3 and support for Policy 2

Oppose

73

Mighty River Power

NZRCA opposes their request that the identification and assessment of potential sites should not require the exact sites to be identified and assessed.  NZRCA believes this is contrary to best practice and a consultative approach.  NZRCA also opposes their opposition to Policy 3 and support for Policy 2

Oppose

88

Meridian Energy

NZRCA disputes that there is no scientific, legal or rational basis for the inclusion of Policy 2.  We refer to the Cawthron report later in our submissions as evidence to the contrary.

Oppose

43

Bioenergy Association of NZ Inc

Particular objection to suggestion by Bioenergy “that section 6 of the RMA be amended to include renewable energy as being of national importance”

Oppose

The particular parts of the submission NZRCA supports/opposes are detailed below:

  • Support for General Points made by Submitters

Many submitters have provided commentary and context to their submission over and above specific comment on the objective and each policy statement.  The NZRCA would like to do single out a number of important concepts made in various submissions that we would strongly support.

  • The definition of renewable generation is flawed. While water is renewable, rivers are not.
  • The exclusion of other forms of energy generation and demand management is likely to make the integrated management of natural and physical resources as required by the Act difficult
  • There is a need for a national, strategic and consultative approach to be taken to the management of New Zealand’s river systems, including hydro generation
  • The full cost (including rehabilitation and loss of option value) of a renewable electricity scheme must be considered in any decision making
  • There is a need to differentiate between existing generation schemes and proposals for new generating schemes
  • The NPS should also address best practice in a number of areas such as consultation, siting and so on
  • New Zealand’s environmental reputation is likely to be significantly damaged by application of this National Policy Statement

We now take each one of these points in turn and explain our rationale for supporting submitters who make these points.

  • The definition of renewable generation is flawed. While water is renewable, rivers are not.

The definition of “renewable” generation is seriously flawed.  As Fish and Game (para 26) point out the definition used appears to mean electricity generated from non or low carbon emitting sources as opposed to carbon emitting resources.  However, as implied by Policy 3 around reversibility, not all low-carbon emitting resources are renewable, particularly hydro.  Fish and Game also make the point (para 51) that “low carbon emitting generation” does not suggest any “sustainability preference” as it is clear that hydro generation, particularly schemes which inundate parts of river systems, cannot be classified as sustainable.

We agree with those submitters who have made the point, that while the water flow that generates the power is renewable, the river environments themselves (on which the electricity generation schemes are built) are not renewable.  This is consistent with interpretation of Policy 3 – hydro schemes generally cause largely irreversible and often highly significant adverse environmental effects.  A significant number of submitters have made this point – we single out a few here:

  • “the river flow is perpetual and non-carbon emitting, .... the number of rivers from which hydro energy may be generated is finite.  ... Rivers depending on the criteria used, fall into both renewable and non-renewable categories.  As such they can be accurately described by the term ‘finite renewable’” (Fish and Game p2)
  • “use of the misleading definition of “renewable electricity generation” even though the activities so defined may have large adverse effects on resources and values which cannot simply be “renewed”” (Ecologic, p1)

We also refer to the NZRCA’s draft “Conservation Policy” para 17.

  • The exclusion of other forms of energy generation and demand management is likely to make the integrated management of natural and physical resources as required by the Act difficult

This point which we support is made directly by Fish and Game (paras 10 – 14, esp para 14) and by others (e.g., WRAP, para 2) and is a point in which we support

  • There is a need for a national, strategic and consultative approach to be taken to the management of New Zealand’s river systems, including hydro generation

The current system is adversarial and not strategic.  Decisions are made on river sections on a piecemeal basis and in isolation in time and place.  There is no mechanism for a consultative process to occur where decisions can be made on a national basis or for culmulative effects to be considered.  For instance, there is no mechanism to decide whether further developing one highly modified and already dammed river with a substantial (say 400MW) hydro generation facility is preferable to developing a much larger number of wild and scenic rivers with much smaller (typically 10 – 20MW i.e., 20 – 40 wild and scenic rivers irreversibly destroyed) for the same generating capacity.  There is no mechanism or incentives for a collective consensus to be reached on which rivers, if any, should be saved or developed and if so, how.

Forest and Bird make this point (p7), which we support: “Central government has shown a lack of action in proactively providing for national networking in the establishment and management of renewable generation, leaving it to the vagaries of a competing market”.

We also make this point in our draft Conservation Policy (paras 9 and 10) and note that this approach is supported in principle by the Cawthron Institute3.

  • The full cost of a renewable electricity scheme must be considered in any decision making

To quote from the NZRCA draft Conservation Policy (see Appendix): “NZRCA seeks that the long-term and often irreversible environmental effects of hydro electricity generation or irrigation developments4, the loss of option value5 and the true whole of life cost (including decommissioning and rehabilitation) are fully recognised and given serious weight in any decision-making and/or management processes involving a river section or catchment.”

This observation we believe should be the basis of Policy 3.  Ecologic (p6) points out that if the NPS required the lodging of a bond for removing structures and restoring affected resources to a state approximately their original state at the end of the consent term, this would clarify that many projects, particularly hydro are not reversible in practical terms and therefore not sustainable.  We support this proposition.

  • There is a need to differentiate between existing generation schemes and proposals for new generating schemes

As Ecologic (p1) and Fish and Game (para 5) and others point out, a distinction should be made between existing and new generation.  While a generation scheme is still viable it makes more sense to maximise generation from the scheme as the environmental damage has largely been done.  Maximising the potential existing generation schemes reduces the need for additional new generation schemes to be built which has a much higher marginal environmental cost per MW than maintaining existing schemes.

  • The NPS should also address best practice in a number of areas such as consultation, siting and so on.

The NPS does not address minimum standards in evaluating, developing, managing or decommissioning renewable generation schemes.  The siting and design of the generation scheme can have an enormous effect on the loss of whitewater amenity value due to the scheme and consultation with affected parties often only occurs after this has been chosen and extensive feasibility studies have taken place.  In our experience this usually means that the consultation is a “clayton’s consultation” – there is little or no interest on the side of the developer to consider an alternative location or design to reduce the adverse effects.  

Forest and Bird make this point strongly (pgs 6-7) as do a number of other submitters (e.g., WRAP who suggest requiring developers to site and configure proposals to minimise ecological impact) and we support those comments.

It is critical that consultation is carried out prior to cost being incurred in plan drawing.  Holding a public meeting when the plans are all drawn up and ready to go to the council for decision is too late in the process to get any real discussion about siting and design of hydro developments.

Furthermore, ‘mitigation’ proposals should form part of the application and not be left to consent conditions to deal with. Siting, design and working details of any such mitigating structures (e.g., whitewater slalom courses / features) should also be planned and designed with the similar resourcing (financial and expertise) as the rest of the hydro power development.

  • New Zealand’s environmental reputation is likely to be significantly damaged by application of this National Policy Statement

NZRCA agrees with Fish and Game who argue (paras 5 – 9) that further loss of New Zealand’s remaining stock of free flowing rivers is “now a matter of high public interest and expectation” and that sacrifice of these rivers to generation will have also “sacrificed a key component of its natural environment based international brand”.

NZRCA supports this assertion and notes that New Zealand, particularly the West Coast region (including Buller and Fiordland) is highly ranked, receiving many international kayakers every year.  The loss of even a few rivers in such a pristine environment is likely to severely damage New Zealand’s reputation and the overall whitewater amenity value of the region.

  • Support / Opposition for Specific Points made by Submitters on the NPS

The reasons for our support or opposition for the objective and each statement and policy is given below:

NPS Objective

The NZRCA gives conditional support to this objective agreeing with the following points made by various submitters:

  • The objective should focus on the underlying environmental purpose of the NPS – to reduce greenhouse gas emissions (see Ecologic, p1, a(i)).  This is also consistent with the points made about Policy One
  • The objective makes no explicit provision for weighing adverse effects.  As Ecologic points out this is not consistent with the purpose of the RMA (see Ecologic, p1, a(i)) nor with other NPS’s (e.g., NPS on Electricity Transmission).

Policy One

NZRCA opposes in part Policy One and ask that it either be deleted or modified. We oppose those submitters who support the notions that all renewable energy is nationally significant or that renewable energy should take precedence over other matters of national importance.  We agree with submitters who make the following points:

  • “It is questionable whether all renewable electricity generation is nationally significant” (Forest and Bird, p5).

In fact, we would argue that it is almost certain that not all, and maybe even not a majority of “renewable” electricity generation is nationally significant.  We would support Fish and Game’s notion (paras 39 and 40) that “decision makers must have particular regard to the national, regional and local benefits and costs [our italics] relevant to renewable electricity generation”.

Fish and Game also make the point (para 17) that the Section 32 report promotes the nationally significant (and globally) significant benefits of any ‘renewable’ electricity development whatever its scale against the “locally” significant environmental effects of such developments.  New Zealand’s whitewater, particularly the West Coast (including Buller and Fiordland) region, is regarded as internationally significant as evidenced by the large number of international paddlers who visit New Zealand each year.  In other words, many of the rivers which may be affected by a hydro development are nationally and internationally significant resources – while strictly speaking the the effects might be local, the values affected (e.g.,whether it be whitewater recreational amenity values or biodiversity) may be regionally, nationally or internationally significant.

  • “It is not appropriate for renewable energy to take precedence over other matters” (Brosnan, s1.2)

As Brosnan points out, the NPS on renewable energy has the potential to conflict with other National Policy Statements and other matters of national importance in Section 6 and 7 of the RMA.  Forest and Bird (p5) also state, “the NPS must be careful not to override the purpose and principles of the RMA in its direction”.  Gisborne District Council also suggests that “specific guidance is required on specific sites and locations of national importance for recreational, cultural and environmental reasons that would not be appropriate for the development of renewable electricity generation i.e exclusion zones”.

Fish and Game point out (paras 23) gives a number of examples of relevant sections of Part II of the Act including Section 7 clauses on the following areas:

  • the efficient use of the resource
  • the end use of energy,
  • intrinsic value of ecosystems
  • maintenance and enhancement of the quality of the environment
  • maintenance and enhancement of amenity values,
  • any finite characteristics of natural and physical resources

These relevant aspects are likely to be conflicting with the NPS as it stands and we support those submitters who note that renewable energy should not take precedence over other relevant matters.

An NPS should not change the weighting that is given to matters in Part Ii of the Act.  That would effectively be attempting to amend the purpose and principles of the Act.

Policy Two

NZRCA strongly opposes Policy Two and requests that it be deleted.

“Policy 2 appears to exist to give undue weight to matters which would enable a consent authority to overlook actual or potential adverse effects of a proposal” (Fish and Game, para 41)

As argued by Fish and Game, particularly given Policy One (all renewable generation is of national significance), this is likely to tip the balance too far in favour of ‘renewable’ generation as an applicant could argue that “avoiding, remedying or mitigating adverse effects would be impractical”.  As Forest and Bird point out, this undermines the purpose of the RMA Act (sustainable management).  This is such a fundamental change in the value weighting established by Part II of the RMA that it should properly be the subject of legislative change, not an NPS.  To have an NPS in isloation saying something that is seemingly contrary to section 5 will inevitably lead to protratcted litigation arguing the interpretation of such a clause in light of section 5, rather than providing additional guidance and clarity.

Failure to avoid, remedy or mitigate is likely to result in a relative overinvestment in hydro generation and the loss of significant whitewater amenity value. The NZRCA will seek appropriate mitigation for the full loss of whitewater amenity.

NZRCA supports those submitters that argue for the deletion of this Policy and opposes those support in part or full this Policy.

Policy Three

NZRCA strongly supports the notion that different generation technologies have different degree of of “reversibility” and thus this Policy.  Reversibility provides options for future generations – the essence of all notions of sustainable management.

NZRCA supports those submitters who support it (e.g., Ecologic – pp 2, 4-6, Fish and Game – paras 43 - 46, Forest and Bird – pp5,6, Nelson Canoe Club – p1, Helen Brosnan – 6.3, WRAP – para 3 etc).  We explain our rationale for this below.

As Ecologic points out “the nature of the RMA consenting environment will play a crucial role in protecting or destroying New Zealand’s remaining undeveloped rivers” (p5).  We agree with this notion as without Policy 3, the NPS is likely to result in our rivers, and New Zealand’s internationally recognised and valued whitewater resource, being rapidly decimated.  

As Fish and Game graphically demonstrate in the appendix to their submission (“Fact Sheet – Where to after the last river?”) and in paras 7 – 8 of their submission the total electricity potential from sacrificing these rivers is modest.  As Ecologic states (pp. 4 – 5):

“The current push into hydro development is clearly not a long term solution to New Zealand’s growing energy needs.  New Zealand will either have to change to new sources of energy in the very near future, when there are many fine rivers still left, or we will change over later on, when rivers have been lost.” (see also Fish and Game, para 7 for a similar argument).

A further point made by Ecologic (p5) and Fish and Game (para 44) is that at some time in the future other alternative and potentially more environmentally friendly energy sources (e.g., photovoltaics, tidal power) are likely to become available at a commercially viable scale, potentially sufficient to meet demand.  As Ecologic notes, electricity is a homogenous commodity and there is “no compelling need for economic considerations to over-ride environmental ones in this area” (p6).

The NZRCA draft Conservation Policy notes that the effects from hydro generation are essentially irreversible either because the environmental damage itself is long-lasting and/or cannot be reversed or because the true whole of life cost (including decommissioning and rehabilitation at the end of the scheme’s life) is not fully provided for.  We note (as does Ecologic – p5) that in contrast to geothermal and wind, rarely is the removal of generation structures or the rehabilitation of the river ecosystem, accepted as a responsibility of hydro developers, in which case, the environmental effects become irreversible.

In short, hydro generation cannot function as a “transition” technology prior to new energy technologies coming on stream.  In the future it is highly likely we will look back and realise the permanent loss of a unique part of our landscape and culture and wonder “what were we thinking back then?” “New Zealand will have sacrificed a key component of its natural environment based international brand” (para 9).  As Ecologic points out some other countries have simply said “no more rivers development” and while that might not be entirely feasible for New Zealand, we would support the sentiment.

Consequently, we would agree with Ecologic (p2) that this policy needs to be given more weight.

Almost all submitters have commented on the lack of definition of reversibility.  NZRCA would agree that the definition does need to be more specific.  Ecologic (pp. 2, 5 and 6) provides a good discussion of this concept and Fish and Game provides further guidance on this too (para 44, 45) which we support.  

Another approach would to be explicitly state an in principle the ranking of alternative generation technologies in terms of reversibility as suggested by Brosnan.  NZRCA supports this sentiment, noting that almost all environmental or recreation organisations as well as the Section 32 report suggest that, the lowest ranking of reversibility would go to hydro schemes which inundate river sections.  We would also note that the highly respected Cawthron Institute suggests this ranking in-principle6:

  • p. 81, “Biodiversity effects of other renewable energy, such as geothermal or wind power, have been noted but are generally minor and localised, as long as construction effects are minimised by good management through the RMA.”
  • p21 “Hydroelectric development creates largely irreversible local environmental changes ... While these effects are local, the values affected, such as biodiversity, may also be national or even international values.”

Policy Three should be retained and strengthened e.g., consent conditions requiring power companies to remove all equipment and structures and rehabilitate the site should the scheme cease to function or be used for more than two years.

We would also note that in general the preference of kayakers is to have rivers as close to their natural state as possible.  Schemes involving inundation of river sections generally have far greater environmental effects than schemes which leave the river bed intact and irreversibility is generally unquestionable.

Policy Four

NZRCA opposes this policy unless this is to be balanced against sites with “national or regionally significant resources” (Fish and Game, para 48).  Brosnan (s6.4, p7) states that it is not clear how councils will balance the requirements for the need for protection of cultural, recreation, ecological and landscape values to be undertaken in tandem.  Indeed, in the case of whitewater recreation, there is no recent survey which adequately captures this data.  Without data, protection of regionally or nationally significant resources is unlikely to happen.  NZRCA supports Brosnan’s call for this issue to be explicitly recognised and addressed, or otherwise this Policy should be deleted.

A further issue raised by Brosnan (s6.4, p7) is the ability of local councils to lead this work.  We would support this assertion.  In our experience, it is it is likely that only large local councils have the resouces and skills necessary to undertake such analysis and even then an assessment of whitewater amenity value will necessitate the engagement of a whitewater expert.  The identification of nationally important amenity values is obviously most appropriately dealt with in the NPS on Freshwater – however unless it is certain that both NPS's will be implemented contemporaneously there will be a significant imbalance, that is inconsistent with Part II of the Act.

As discussed earlier, a key concern of the NZRCA is that there is no strategic, consultative and nationwide approach to the management of river environments, including hydro generation.  Approaching this on a local basis, and not even a catchment basis, is unlikely to result in a efficient, strategic or consultative outcomes.

Policy Five

The NZRCA conditionally supports the notion of small and community-scale distributed generation as do other submitters.  However, even schemes with an installed generation capacity of less than four megawatts can significantly affect whitewater amenity value (e.g., Taranaki scheme, Normanby Power Ltd  – Waingongoro River) and the design of such schemes is frequently unsafe for kayakers.  

Additionally, the NZRCA question the use of  the term “enable” without a corresponding requirement to mitigate the effects of such small scale schemes.  Without such a requirement there could be a misguided assumption that such schemes should be permitted. NZRCA will not support this policy if its effect is to not allow for the full assessment of all benefits, costs and risks associated with a scheme, including effects on whitewater amenity value. NZRCA would oppose a Permitted Activity status for micro generation hydro as they could obstruct or be dangerous to navigation of surface recreation activity (e.g. kayaking).

The NZRCA wishes to be heard in support of our submission.

Date: 20 December 2008

Address for service of submitter: PO Box 284, Wellington
Telephone: 027-293-7014
Fax/email: conservation@rivers.org.nz
Contact person: Duncan Catanach, North Island Conservation Officer, New Zealand Recreational Canoeing Association

Footnotes

1:  By the Government’s own calculations, over 80% of New Zealand’s economic hydro electricity resource has already been developed (New Zealand Energy Strategy, 2007, Section 9.1.2)

2:  See for instance, Cawthron Institute (2008), “Scoping Report for an Environmental Assessment of the NZ Emissions Trading Scheme and closely related measures”, p xvi.,”The ETS [Emissions Trading Scheme] price signal and the renewable energy preference are expected to significantly increase pressure to dam or divert more of New Zealand’s rivers. A significant move to electric vehicle technology could further increase this pressure.”  The NZRCA would also note that few major hydro power schemes are proposed and so a substantial number of smaller schemes will be required to achieve the Government’s renewable energy targets.  Many of these smaller schemes are on rivers highly valued by recreationalists.

3:  Cawthron Institute (2008), ibid., pp.108-9, which comments on the need for such an approach in its report, “A comprehensive [strategic environmental] investigation could facilitate a more proactive approach to this issue. Absent such measures, pressure will grow over time, unless and until a significant and sustainable alternative emerges. There may be value in extending this investigation to other renewables, but hydro-electric development is a priority due to the potential scale, significance and irreversibility of effects”.

4:  Effects can be long-lasting or largely irreversible either because the environmental damage itself is long-lasting or largely irreversible or because the cost of mitigation or true whole of life cost (including decommissioning and rehabilitation at the end of the scheme’s life) is not fully accounted or provided for.  

5:  Option value is based on an economic concept which recognises that value can be lost if future uses of a resource are foreclosed by decisions made today.  For instance, skills and equipment are continuing to change and so do the rivers paddled.  Twenty years ago the Kaituna River was not paddled.  Now the Kaituna River is one of the most commonly paddled (both recreationally and commercially) rivers in New Zealand.

6:  Cawthron Institute (2008), “Scoping Report for an Environmental Assessment of the NZ Emissions Trading Scheme and closely related measures”,


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