We thank the Ministry for Environment for the opportunity to comment on our draft National Adaptation Plan Te mahere urutaunga ā-motu (tuhinga hukihuki). Toitū Tahua: Centre for Sustainable Finance (the Centre) broadly supports the need for an adaptation plan and for it to be enabled by an effective, sustainable funding and finance strategy.The March 2022IPCC reportin to climate change adaptation, impacts and vulnerability, made clear that Aotearoa New Zealand, with the rest of the world, has a brief and closing window of opportunity to secure a liveable future through climate change mitigation and adaptation.
The IPCC has also highlighted that current commitments put humanity on a 3.2 degree trajectory, and reminded us that adaptation without mitigation is an insufficient response.Keepingwithin 1.5 degrees will require reaching peak emissions in 2025. Projected warming under current global emissions reduction policies would leave many human and natural systems at very high risk and beyond adaptation limits.New Zealand scientistsproposed that the required steep emission cuts and adaptive responses will take unprecedented, genuine collaboration between central and local governments, the private sector, indigenous peoples, and all communities. This reasoning is very much in line with our previous submission on discussion document‘ Te hau mārohi ki anamata | Transitioning to a low-emissions and climate-resilient future’.
The present submission builds on the previous. Our most urgent and critical message was, and continues to be, the need for private and public sector leadership and collaboration in funding and financing the equitable and fair transition to net zero by 2050.
Key points in the present submission are:
•We strongly support government leadership in the provision of data and data infrastructure to enable equitable access to climate and nature-related data and insights.
•We recommend developing a strategic framework for sustainable investment, which willset out a coherent narrative and logic, provide visibility over which activities are considered sustainable (thereby helping to avoid greenwashing) and create incentives for reporting entities, investors and capital providers to be transparent and honest.
•We encourage further consideration of the full role of the insurance industry in adaptation and mitigation.
•We support further guidance for the entities the RBNZ regulates, fund managers and all relevant financial service providers.
We encourage the active, formal, mandated participation of public officials in industry partnership networks and international platforms.We offer our support and engagement to work with Government and other stakeholders on this.
Ahakoa ko hea tāua haere atu ai. Ka kōkiri tahi tāua.Regardless of where wego on this journey, we’ll go together.
Ngā manaakitanga,
