June 2023
Consultation on Climate Change Commission draft advice on the second emissions reduction plan
Introduction
The Restaurant Association of New Zealand (the Association) welcomes the opportunity to make a submission on the Climate Change Commission’s (the Commission) 2023 draft advice to inform the strategic direction of the Government’s second emissions reduction plan.
The Association remains ready and willing to work in partnership with the Commission on any of the matters raised in this submission.
The Association reiterates its support for calls to create a thriving, climate resilient, low emissions Aotearoa. In particular, we support the Climate Commissioner’s sentiment that all of us have a part to play and have a contribution to make.
However, we strongly oppose the recommendation to prohibit installation of natural gas or LPG connections. We are disappointed by the lack of consideration to the effects that this proposal will have on the Hospitality sector.
For this reason, the Association recommends:
That the Commission engages with the Hospitality sector when developing proposals to ensure any actions are viable and fit-for-purpose.
That the proposed ban on new natural gas connections be removed until a suitable alternative fuel is identified.
That gas connections installed in new builds are required to be easy and cheap to remove or retrofit for alternative energy sources in the future.
That the Commission supports our approach to a phased transition away from gas for the Hospitality industry.
That any food waste requirements developed by the Commission are done in consultation with the Hospitality sector.
Previous feedback
The lack of a viable alternative issue was raised in response to the Commission’s preliminary advice on the first Emissions Reduction Plan. The ban on new gas connections was subsequently excluded from the first Emissions Reduction Plan.
The Association made a submission on the Commission’s draft advice on the first Emissions Reduction Plan. In that submission, we sought the following:
Removal of the proposed ban on natural gas for business use, and
A more concerted effort to engage meaningfully with the hospitality sector on the scope and nature of the Commission’s proposals
The basis of our recommendations were:
- that many in the Hospitality sector are without a suitable, cost-effective alternative to natural gas for cooking
- that while we recognise the need to transition away from the use of natural gas, there must first be suitable alternative energy sources to which we can transition,
- that to adapt business models sustainably, there must be phased approach to this transition, and
- that while some may be able to make the transition easily, without readily available alternative sources of energy that can facilitate the same high temperatures attained by using gas, restaurants that serve many types of Asian cuisine or utilise broiling cooking methods will not be able to make this transition to alternative energies.
These issues remain unaddressed in the second Emissions Reduction Plan. Sequencing of plans
We are concerned that the sequencing of consultations and plans may result in goals and timelines that do not align. In particular:
- the Gas Transition Plan, as set out in the first Emissions Reduction Plan, is not due to be finalised and published until the end of 2023, and
- the first monitoring report, which will cover progress on the first Emissions Reduction Plan and inform the second Emissions Reduction Plan, is due in 2024
- the Energy Strategy is not due until the end of 2024.
Despite the above, advice on the second Emissions Reduction Plan—which does not come into effect until 2026—is due to the Minister of Climate Change by 31 December 2023.
Feedback being sought so early on draft advice that is not able to take into account work which will be done under yet to be finalised plans set out in the first Emissions Reduction Plan makes the work our industry is doing in partnership with the Ministry of Business, Innovation and Employment feel redundant.
Nevertheless, we will continue to progress this work as part of our commitment to play our part in creating a thriving, climate resilient, low emissions Aotearoa. We urge the Commission to take this work—which we have outlined in this submission—into consideration in the preparation of their final advice to the Government on the second Emissions Reduction Plan.
New gas connections
While we support incentives for comprehensive retrofits to deliver healthy, resilient, low-emissions buildings, we are concerned that there is not at present an affordable or technically viable low emissions alternative.
Further, we are concerned that the proposed prohibition of the installation of fossil gas in buildings fails to prioritise the identification of suitable alternatives.
In a recent survey of Association members on the use of gas in their commercial kitchens, it found that 94% of our members use gas. Of those who use gas, 83% said it would not be realistic for their kitchen to operate using electric induction cooking.
What is clear is that our members are open to more sustainable, low emissions alternatives. 69% of those who currently use gas would be willing to transition to a viable alternative if it was widely available, with feedback including comments (edited for brevity and clarity) such as:
“We want to transition, but it is costly to convert. Incentives or subsidies with a phased approach will make this easier on us.”
“It’d be great if there were viable alternatives to using gas!”
“There needs to be much more education about the environmental impacts of natural gas before a law change is made so that people understand the need.”
“If induction cooking was affordable I would switch immediately. We need more options for professional grade induction cooking.”
For those who were not willing to transition, their reasoning includes:
“We need to know the cost of change and phasing out of LPG before making a commitment to change.”
“Gas is the only alternative option we can rely on in the event of electricity sources going down – like they did for a week after Cyclone Gabrielle.”
“There is nothing available in our area at this point. We’d consider alternatives if there was something.”
“Capital outlays to re-engineer our kitchen and storage areas will be huge, not to mention the cost of replacing appliances.”
Given the lack of viable alternatives at present, we recommend that the proposed ban on new natural gas connections be removed until a suitable alternative fuel is identified.
Instead of adopting a blanket prohibition on the installation of gas connections in new builds, we recommend that gas connections installed in new builds are required to be easy and cheap to remove or retrofit for alternative energy sources in the future.
The reliability of the power grid also raises concerns, given the recurring energy shortages in recent winters and the possibility of blackouts during severe weather.
It is crucial for us to ensure that the supply will consistently meet the demand and remain accessible to our business, particularly during periods of peak usage.
While it is acknowledged in the first Emissions Reduction Plan that fossil fuels are currently the only viable energy option in some rural and off-grid communities, homes and marae, addressing this is not addressed within draft advice on the second Emissions Reduction Plan. We cannot move forward without adversely impacting rural or off-grid communities.
Gas Transition Plan
We are working with MBIE on the development of a Gas Transition Plan, as set out in the current Emissions Reduction Plan.
Our proposal is for a phased approach to transitioning away from fossil gases. It is important to note that the timing for implementation of this phased approach is wholly dependent on the identification of a suitable and readily available alternative energy source.
Our proposed four-step phased approach is as follows:
- Phase one: trial. In this phase, a comprehensive trial will be conducted with a single large consumer of gas to identify the steps required to ensure a just transition away from gas. This phase will involve close collaboration with the consumer, industry experts, and relevant stakeholders to develop a detailed transition plan that can be adopted by the wider Hospitality industry. By focusing on a single large consumer, the trial will identify the challenges, opportunities and solutions for phasing out gas use for the wider industry.
- Phase two: scaling. Building upon the insights gained from phase one, phase two will aim to transition a number of large gas consumers. During this phase, the focus will be on scaling up the transition efforts, while ensuring the availability of viable alternatives to smaller gas users. It will involve developing robust supply chains for alternative energy sources to meet the increased demand. This phase will emphasise the importance of maintaining a consistent and reliable supply of alternative fuel options, ensuring that the transition is sustainable for all gas consumers involved.
- Phase three: expansion. In phase three, the focus will shift to medium and small consumers of gas, to ensure the transition plan as has been developed up to this point is fit for purpose for smaller consumers who may not have the resources of large consumers. This phase will involve conducting pilots with different types of businesses to adapt and refine the transition plans accordingly. By understanding the diverse needs of smaller businesses, the trial will facilitate the development of tailored strategies and solutions that can effectively support their transition away from gas. Lessons learned from these pilots will contribute to the overall framework for businesses of varying sizes.
- Phase four: implementation. The final phase will implement a sector-wide transition. The lessons learned from previous phases will be utilised to develop comprehensive transition plans for gas consumers in the Hospitality sector.
The Association recommends that the Commission supports our approach to a phased transition away from gas for the Hospitality industry.
Food processing and waste
While we support the draft advice that seeks to reduce the amount of organic waste sent to landfills, there is little detail as to how these goals will be achieved—nor how they will apply to the Hospitality industry.
Food waste is a major cost to any hospitality business, and limiting such waste is often a priority for our members. Specific actions our members take to reduce food waste are outlined below (selected comments, edited for brevity/clarity):
“We compost waste, have a local pig farmer who collects scraps and use the Foodprint app to advertise leftovers at a reduced price.”
“Leftover prepared product is given away to pātaka, community groups, food rescue organisations or regular customers.”
“We monitor our trading trends closely so we can order appropriate levels of stock. Being creative with our menu helps to utilise potential leftover stock in new ways.”
We recommend that any food waste requirements developed by the Commission are done in consultation with the Hospitality sector. Many assume that our sector is the largest contributor to food waste; in reality we are likely doing the most per capita to reduce food waste in Aotearoa.
The Association supports the proposal to investigate a strategic approach to food rescue sector resourcing, funding, and research across Aotearoa, and would welcome the opportunity to support this mahi with insights from the Hospitality sector.
F-Gases
The Association acknowledges the goal for a 21% reduction in emissions of hydrofluorocarbons (HFCs), and the statement of the need for a “robust and transparent refrigerant training, management, and tracking framework reflecting industry best practice and overseen by the government.” This is paramount to achieving the desired reduction of F-gas emissions.
We support the commissioning of a refrigerant waste management facility in Kawerau, which will reduce transport emissions of F-gases currently exported to Australia for destruction by establishing a local refrigerant destruction facility in Aotearoa.