Submission to MfE on National Adaptation Plan

The March 2022 IPCC report on 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.

Which is why The Centre for Sustainable Finance: Toitū Tahua (CSF) took the opportunity to submit to the Ministry for the Environment on the draft National Adaptation Plan Te mahere urutaunga ā-motu (tuhinga hukihuki).

New Zealand scientists have suggested 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. CSF broadly supports the need for an adaptation plan and for it to be enabled by an effective, sustainable funding and finance strategy.

Key points of the submission:

  • Support for government leadership in the provision of data and data infrastructure to enable equitable access to climate and nature-related data and insights.
  • Recommendation to develop a strategic framework for sustainable investment, which will set 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.
  • Further consideration to be given to the full role of the insurance industry in adaptation and mitigation.
  • Further guidance for the entities the RBNZ regulates, fund managers and all relevant financial service providers.
  • Encouraging the active, formal, mandated participation of public officials in industry partnership networks and international platforms.

Submitted: June, 2022

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