ALTERNATIVE ENERGY POSITION STATEMENT Prepared by:
TE KOROWAI O NGĀRUAHINE TRUST
Te Korowai o Ngāruahine Trust (Te Korowai) is the post settlement governance entity for Ngāruahine Iwi as established under the Ngāruahine Claims Settlement Act 2016. Our role is to: •
Give effect to the settlement legislation;
•
Foster and promote the physical, social, and economic well-being and advancement of Ngāruahine uri;
•
Facilitate positive relationships that foster Ngāruahinetanga; and
•
Exercise strategic governance over Trust entities so as to manage prudently the affairs, business activities, assets and liabilities of the Ngāruahine Group.
Ngāruahine includes any individuals or whānau who descend from one or more Ngāruahine Tūpuna regardless of where they may reside. Importantly, it includes the following six Hapū groups from whom the Trustees of Te Korowai are elected: Kanihi-Umutahi me ētehi atu Hapū; Ōkahu-Inuawai me ētehi atu Hapū; Ngāti Manuhiakai Hapū; Ngāti Tū Hapū; Ngāti Hāua Piko Hapū; and Ngāti Tamaahuroa-Titahi Hapū.
“Ka tika ā mua, Ka tika ā muri.”
“If the foundations are properly laid, the relationship will endure.”
Te Ngutu o Te Manu - 2022
CONTENTS
Glossary of Terms / Kuputaka
Pg 1 - 2
Ngāruahine Alternative Energy Position Statement / Ngā Tauāki Pūngao o Ngāruahine Purpose
Pg 3 - 4
Ngāruahine rights and interests How this position statement was developed
Pg 5 - 6
Issues / Raru ki uta, raru ki tai Historical Treaty of Waitangi breaches
Pg 7 - 8
Problem identification
Pg 9 - 10
The alternative energy dilemna Government responses and public perceptions
Pg 11 - 12
National and regional development strategies
Engagement / Whakawhitinga Wānanga Values / Ngā Ūaratanga
Pg 15 - 16
Alternative energy systems and technologies
Pg 17 - 18
Engagement priorities General principles for alternative energy development
Pg 19 - 20
Information requirements
Pg 21 - 22
Outcomes based framework Pg 25 - 26
expectations Appendix 2: Cultural protection area
Pg 27
Terrestrial activities which will be opposed within the Ngāruahine
Pg - 28
cultural landscape area Appendix 3: Outcomes sought by Te Korowai
Pg 29 - 30
po
Te
Appendix 1: Alternative energy potential impacts & Te Korowai
u
ki Te N gu
tu
oT eM an
u-
20 22
GLOSSARY OF TERMS - KUPUTAKA Benthic Environment
Of or pertaining to the collection of organisms living on or in the bottom of a body of water,
CSP
Concentrated Solar Power technologies use mirrors to convert concentrated light energy
especially referring to the ocean depths.
from the sun into heat which drives a turbine and generates electrical power. EROEI
Energy Return on Energy Invested is a measure of an energy gathering systems efficiency. It is assumed that an EROEI of >7 is required for a modern society to function.
LCA
Life Cycle Assessment is an analytical tool for the systematic and quantitative evaluation of the environmental impacts of a product or system through all stages of its life. It includes the extraction, processing and manufacturing of raw materials through to the return of those materials to the Earth.
Kyoto Protocol
This protocol operationalises the United Nations Framework Convention on Climate Change by committing industrialised countries to limit and reduce greenhouse gas emissions in accordance with their agreed targets.
MACA
Marine and Coastal (Takutai Moana) Act 2011. An act to repeal the Foreshore and Seabed Act 2004. It provides for mana moana groups to have their customary rights in the coastal marine area confirmed by the Courts.
Micro Hydro
An energy generation system which redirects a continuous flow from a stream or creek through a turbine. Also known as run-of-river systems they are typically 0.5 – 1kW in size.
Ngāruahine Cultural Landscape
A combination of natural, man-made and historical features within the rohe of Ngāruahine. It
NGO
A Non-Governmental Organisation refers to an organisation that operates independently
includes the kōrero of Ngāruahine tūpuna, the land, waterways and coastal areas which are embedded in our identity as Ngāruahine.
from any government although they may receive funding from a government. They can be clubs, associations or lobby groups for corporations. A legally binding international treaty on climate change adopted by 196 Parties in Paris in wa
2015. Implementation of the Paris Agreement requires economic and social transformation
A
Paris Agreement
and works on 5 year cycles of climate action by participating nations. RMA
The Resource Management Act 1991 is the main piece of environmental legislation in New Zealand. It regulates the effects of activities such as discharges to air, land, water and the coastal marine area.
SROI
m
on
ito rin g
,T aik atu
Rd -
20 23
Social Return on Investment is a systematic way of incorporating social, environmental, economic and other values into decision-making processes. This places the perspectives of different stakeholders at the centre of the valuation process.
Glossary of Terms
1
2
Kuputaka
Ngāruahine Alternative Energy Position Statement Ngā Tauāki Pūngao o Ngāruahine PURPOSE The purpose of this position statement is to articulate to developers and environmental regulators: •
the resource management issues of significance for Ngāruahine;
•
the values and principles of Ngāruahine; and
•
the expected outcomes regarding the development, operation and end of life disposal of alternative energy projects in relation to the kaitiaki area of Ngāruahine.
HOW THIS POSITION STATEMENT WAS DEVELOPED This position statement stems from increasing interest in the development of offshore wind generation in South Taranaki. These proposals have shown a discernable lack of treaty partnership in national and regional development strategies around alternative energy. We have asked our Hapū and Iwi members to identify priorities from a Ngāruahine perspective. Subsequently, these have been considered carefully and incorporated into this position statement. This position statement is consistent with the following Te Korowai documents: •
Te Uru Taiao o Ngāruahine – Ngāruahine Kaitiaki Plan.
•
Te Korowai Five Year Strategy 2021 – 2026.
•
Te Ara Toiora – Ngāruahine Procurement Strategy.
The position statement will be reviewed and amended as considered necessary by Te Korowai and the six Hapū groups of Ngāruahine.
A
Ngāruahine Alternative Energy Position Statement
wa
3
4
m
on
itir
ing
,T aik atu Ro ad -
20 23
Ngā Tauāki Pūngao o Ngāruahine
Ngāruahine Alternative Energy Position Statement Ngā Tauāki Pūngao o Ngāruahine NGĀRUAHINE RIGHTS AND INTERESTS While we have been excluded from identifying problems and solutions regarding climate change, we must still ensure that Ngāruahine uri are: •
Aware of the environmental and cultural risks of any alternative energy development in our rohe;
•
In a position to take advantage of any opportunities that are planned for that development.
All alternative energy generation technologies will impact on the Ngāruahine Cultural Landscape and our environment in some way.1 While we understand the need to move to these new technologies, this will not be at the cost of Ngāruahine rights, interests or values. Ngāruahine possess the right to free, prior and informed consent regarding the development of industrial infrastructure in our rohe. This is confirmed by the United Nations Declaration on the Rights of Indigenous Peoples.2 Similarly, Article 2 of Te Tiriti o Waitangi guarantees to the Chiefs the subtribes and all the people of New Zealand in the unqualified exercise of their chieftainship over their lands, villages and all their treasures.3 All six Hapū groups of Ngāruahine have claims before the High Court to determine their customary rights in the coastal marine area under the MACA Act 2011. These claims require applicants for RMA consents (excluding accommodated activities), conservation permissions or marine mammal watching permits in the areas under claim to either gain permission from or notify claimants regarding
re e
T
activities in those areas. See appendix 1 for an assessment of potential impacts and Ngāruahine expectations. https://www.un.org/development/desa/indigenouspeoples/wp-content/uploads/sites/19/2018/11/UNDRIP_E_web.pdf https://nzhistory.govt.nz/files/documents/treaty-kawharu-footnotes.pdf
Ngāruahine Alternative Energy Position Statement
5
6
pl an tin gh ui,
W ait ok ora u-
20 22
Ngā Tauāki Pūngao o Ngāruahine
Issues Raru ki Uta, Raru ki Tai
HISTORICAL TREATY OF WAITANGI BREACHES In the Ngāruahine Deed of Settlement, the Crown acknowledged that the lands and other resources confiscated from Ngāruahine have made a significant contribution to the wealth and development of New Zealand. This was also confirmed in the Treaty of Waitangi Report WAI 796. The Crown also acknowledged that its actions and omissions in the nineteenth and twentieth centuries significantly undermined the traditional systems of authority and economic capacity of the Ngāruahine Iwi. It admits that it failed to protect the rangatiratanga of Ngāruahine, in breach of its obligations under Article 2 of the Treaty of Waitangi. The Crown concludes by stating that it looks forward to building a relationship of mutual trust and co-operation with Ngāruahine founded on respect for the Treaty of Waitangi and its principles. Te Korowai also looks forward to the building of that relationship.
N gu
T
e
Issues
7
8
tu o
Te M an u
Sig nin g-
20 22
Raru ki uta / Raru ki tai
Issues Raru ki Uta, Raru ki Tai PROBLEM IDENTIFICATION Indigenous people have been excluded from identifying the causes of the climate change crisis. Solutions are subsequently developed based on the worldview and values of those responsible for the appalling situation we find ourselves in. Let us be clear in recognising the cause of climate change. Colonisation - and its attendant structures of capitalism, patriarchy, modernity and democracy - are responsible for this and multiple other destructive outcomes around the world. Ngāruahine have always possessed equal explanatory and decision making power to the Crown and New Zealand government. We will not look to those same structures of oppression to provide a solution. Te Korowai acknowledges that international and national capital are required in order for the development of alternative energy systems. That development however should not be at the expense of the cultural, social and environmental values of mana whenua.
THE ALTERNATIVE ENERGY DILEMMA Fossil fuel suppliers and electricity generators have operated under a profit maximisation model for decades. The concepts of classic economics and western capitalism were introduced to Aotearoa by colonisation. The destructive consequences of predatory capitalism are evident in the extractive methods of commodification now normalised but unchecked in our society. This capitalist model exploits both the environment and human beings. Basic needs have been turned into commodities available only to those who possess adequate financial capital. This impacts greatly on the most vulnerable in our society and this group is growing. Housing, health, education, freshwater, energy and clean air are examples of basic needs which all people need to live happy, healthy and productive lives. All of these fundamental human needs
M
au ng a
have been subject to the process of commodification. The days of fossil fuels are over. In order for new energy systems to be sustainable, they must leave behind the exploitative and extractive practices of colonial and imperial control.
Issues
9
10
Ta ran a
ki
-2
02 2
Raru ki uta / Raru ki tai
Issues Raru ki Uta, Raru ki Tai
GOVERNMENT RESPONSE AND PUBLIC PERCEPTIONS New Zealand’s Nationally Determined Contribution 2021 (NDC1) sets a headline target of a 50 percent reduction of net emissions below our gross 2005 level by 2030 under the Paris Agreement. This has largely been set based on the European Unions (EU) approach and existing guidance contained in the Kyoto Protocol. While the EU has been at the forefront of the climate change response globally, it is difficult to see any similarities New Zealand might have with an economic and political union of 27 European Countries. The New Zealand government frames climate change as a political issue while public perception is centred around uncertainty over human influence including risks which are spatially distanced and can be deferred until a later date. Both are typical of the capitalist narrative which denies all liability in order to maintain its competitive advantage in a globalised economy.
NATIONAL AND REGIONAL DEVELOPMENT STRATEGIES Development strategies have been created without Iwi and Hapū input. In 2022, it is lamentable that treaty partners are still considered one of many communities of interest amongst multiple stakeholders. Government policy and regional development NGO’s use the rhetoric of iwi engagement frequently. It is apparent that these superficial statements have no substance but serve to perpetuate and justify the status quo. A Just Transition has been proposed as a process to move to more sustainable energy generation. We believe a just transformation is required if the development
N
gā
of alternative energy is to be truly sustainable.
Issues
11
12
ku ia
o
Ng āru a
hin e-
Ka nih i Pā -
20 22
Raru ki uta / Raru ki tai
“Kia manawa Tītī, Kia manawa Piharau.”
“The endurance of the Tītī, The resilience of the Piharau.”
Te Rua o Te Moko - 2022 13
14
Engagement Whakawhitinga Wānanga VALUES / NGĀ ŪARA
Ūkaipōtanga
Reducing environmental impacts, enhancement of biodiversity,
Whanaungatanga
Collaboration with Ngā Iwi o Taranaki, local communities, local
Ngāruahinetanga
Focus on mahi, kāinga and educational opportunities for
prioritising the South Taranaki economy.
industries, local government and central government.
Ngāruahine uri. Protection of the Ngāruahine Cultural Landscape.
Mana Motuhake
Development priorities and aspirations are determined collectively by the six Hapū groups of Ngāruahine. They will determine when, how and where engagement takes place.
Kaitiakitanga
The individual and collective Hapū are the customary owners, guardians and trustees for all things pertaining to their respective social, economic and political development, including how they manage their taonga tuku iho. Kaitiakitanga is an expression of rangatiratanga.
Kotahitanga
Togetherness, solidarity and collective understanding and action. This has been sadly lacking from our treaty partners and regional development NGO’s. We understand the value of unity as the collective Hapū of Ngāruahine Iwi and will seek out those who
M
at ua
share common objectives for our Taiao and people.
Values
15
16
Ho n
eH oo ke r
-2 02 2
Ngā Ūara
Engagement Whakawhitinga Wānanga ALTERNATIVE ENERGY SYSTEMS AND TECHNOLOGIES Renewable energy resources and technologies are a strategic component of sustainable development. The main reasons for their significance are: •
They potentially cause less environmental impact than other energy sources;
•
They tend towards system decentralisation where local communities can better influence their own wellbeing and resilience; and
•
Diversification of supply and a reduction in dependence on imported fuels.
We are aware and supportive of the need to move away from fossil fuels and reduce our impacts on the air and atmosphere. We are also aware that government legislation, policy and strategy has historically been mobilised to dispossess Hapū and Iwi of their rights and interests as in the breach of Article 2 of Te Tiriti o Waitangi.
ENGAGEMENT PRIORITIES Positive, constructive and meaningful engagement develops from trust and reciprocity and is the basis of any relationship. We expect no surprises and will not offer any. Developers are encouraged to provide all proposal information up front and prior to initiating the engagement process. Early engagement allows us the opportunity for: •
Involvement of our Hapū in understanding the proposal;
•
Identifying potential issues they might have; and
•
Hapū expression of mana motuhake in their own time and on their terms.
M
au ng a
Engagement
17
18
ki
te mo an ah
iko i
-2
02 1
Whakawhitinga Wānanga
Engagement Whakawhitinga Wānanga GENERAL PRINCIPLES FOR ALTERNATIVE ENERGY DEVELOPMENT 1.
Our natural environment is protected and enhanced for generations to come. New and emerging technologies are not without their drawbacks. They are often developed and installed before satisfactory environmental regulation is established. Potential environmental impacts of alternative energy development should be clearly identified by the developer and communicated and understood by our Hapū.
2.
The unique Ngāruahine Cultural Landscape is protected and maintained for current and future generations. We will actively oppose the degradation or destruction of: a. any aspects of Ngāruahinetanga not consented to by the relevant Hapū. b. any Ngāruahine site of significance. c. the relationship of Ngāruahine to any such sites of significance
3.
Reductions in greenhouse gas emissions should be measured and proven, not assumed. There is much hype and optimism around the utilisation of alternative energy to meet the New Zealand government’s international commitments under the Paris Agreement. Developers should consider a LCA to clearly demonstrate embedded emissions rather than operational reduction comparisons to traditional energy systems.
4. Economic Analysis needs to be based on social and environmental outcomes rather than contribution to National or Regional GDP or GNP. This means identifying increases in the quality of families and communities lives as an outcome as opposed to an increase in economic output as a proxy measure of well-being. 5.
7.
aw n
D
6.
Transformative change empowers local communities. We do not believe that the Just Transition stratagem goes far enough to making meaningful and long lasting change. There is little point in changing the technologies we use to generate energy if historical exploitative and extractive practices remain. Commodification does not work for the provision of peoples basic needs. We will all need to change our resource depleting lifestyles if true transformation is to occur. Net Energy and EROEI. The move away from fossil fuels is not about replacing them with another technology. It is about replacing them with sustainable, long term alternatives. This means we need to focus on the amount of energy that is left after the total costs of production. Allocation. The current lack of a regulatory and/or licensing framework for offshore energy generation is not a coincidence. We know that industries and the government favour low regulation as a means to progress development urgently. Treaty rights and partnership should be at the centre of all decision making for alternative energy projects.
Engagement
19
20
ce re mo
ny -
Te Ng u
tu o
Te Ma nu -
20 22
Whakawhitinga Wānanga
Engagement Whakawhitinga Wānanga INFORMATION REQUIREMENTS 1.
Decommissioning plans will be required for all projects regardless of type or planned operational life. These plans will be co-designed with the relevant Hapū.
2.
Project cost/Benefit analysis should include a SROI assessment at a minimum.
3.
Any Assessment of Environmental Effects should include both an LCA and an EROEI report to show the projects effectiveness at reducing greenhouse gas emissions.
Only when the relevant Hapū are fully informed will the formal engagement process begin. This may culminate in one or more of the following: •
A Cultural impact assessment;
•
A Relationship agreement;
•
A Memorandum of understanding;
•
A Joint venture agreement;
•
A Service level agreement.
OUTCOMES BASED FRAMEWORK Te Korowai is aware that the performance of alternative energy technologies will increase as investment and innovation is encouraged leading to more efficiency and effectiveness. We have assessed a range of alternative energy technologies and their current potential impacts. The
N
gā
following table is based on this assessment and the Crowns commitment to building a relationship of mutual trust and co-operation with Ngāruahine.
Engagement
21
22
Hi wi
M au
ng a
,T eR ere
oK ap un i-
20 22
Whakawhitinga Wānanga
“Ko wai ahau?
“Who am I?
He uri ahau o ōku tūpuna. Ko te wai ahau, ko te hau ahau e.”
I am a descendant of my tūpuna. I am the water, I am the wind.”
Ohawe Beach - 2023 23
24
APPENDIX 1: ALTERNATIVE ENERGY POTENTIAL IMPACTS AND TE KOROWAI EXPECTATIONS Energy Type
Issues
EROEI
Contribution to Energy Resilience
Te Korowai Support
Te Korowai Conditions
Land compaction and increased erosion during land clearance. End of
Medium
High
Conditional
Large scale projects should incorporate maara kai or other
Solar Photovoltaic
life disposal of materials is not currently reflected in pricing.
productive land uses. Papakāinga, marae and home installations are supported.
CSP
Need water for cooling at the back end of the thermal cycle to maintain
High
High
No
efficiency. Thermal
birds.
Need water for cooling at the back end of the thermal cycle to maintain
Medium
High
Conditional
efficiency (electricity generation). Hydrogen
Visual impacts and water demands are too great. Potential to burn
Store of energy, not a source. High external energy requirements to
Water heating for homes and marae is supported. Larger projects will need assessing on a case-by-case basis.
Low
Medium
Conditional
Projects should not result in an increase in freshwater abstraction.
Medium
Medium
Conditional
Turbine towers should not be located in the Ngāruahine Cultural
utilise mean reduced efficiency. Wind Generation On-shore
Severe impacts on Ngāruahine Cultural Landscape.
Landscape Protection Area. Off-shore
Impacts on Ngāruahine Cultural Landscape less severe than onshore.
High
Medium
Conditional
Impacts on marine mammal and seabird populations unknown. Biofuels
Decreases land available for food production. Fertiliser and pesticide
Development results in minimal impact on marine mammals, seabirds and benthic environments.
Low
Medium
Conditional
use. Threat of monoculture or GMO farming if successful.
Should not result in an increase in water abstraction. Monocultures or GMO crops will be opposed.
Hydropower Large Scale
Reduction in river flows and water quality. Increase in water
Very High
High
Conditional
temperature. Impacts on indigenous biodiversity and habitats.
Native fish passage should be enhanced or protected on a catchment scale. Minimum ecological flows are maintained for all awa in the Ngāruahine rohe.
Micro Hydro Diversion
Effects not well understood. Minimal ecological impacts may be
Medium
No
intensified by multiple installations on streams.
Ngāruahine rights and interests in freshwater not yet realised in co-governance.
Nuclear
Disposal of spent radioactive waste components.
High
High
Conditional
Dependant on acceptable disposal methods being developed.
Tidal
Disturbs migration of living creatures in the ocean. Only produces
Low
Low
Conditional
Development results in minimal impact on marine mammals,
power during tidal movements (approx. 10 hours per day).
seabirds, benthic environments and the protection of tuna & piharau migratory routes.
Wave
Infrastructure, electromagnetic fields and noise could harm marine life.
No data
Displacement of commercial and recreational fishers.
available
25
Unknown
Conditional
Fishing exclusion zones are designed with mana whenua. Tuna and piharau migratory routes are protected. 26
Ngruahine Cultural Protection Area
APPENDIX 2: CULTURAL PROTECTION AREA Figure 1 Ngāruahine Cultural Landscape Protection Area
TERRESTRIAL ACTIVITIES WHICH WILL BE OPPOSED WITHIN THE NGĀRUAHINE CULTURAL LANDSCAPE PROTECTION AREA:
•
Concentrated solar power projects.
•
Wind turbine towers.
•
Structures greater than 20 metres in height.
•
Large scale solar projects.
•
Increased water abstractions (including micro hydro diversion).
Kanihi Mawhitiwhiti Pā Oeo Pā
Okare ki Uta Marae
Te Aroha o Titokowaru Marae
Aotearoa Marae
Tawhitinui Marae
Note: Alternative energy development proposals in the coastal marine area and exclusive economic zone should address Te Korowai expectations as set out in Appendix 1. The areas to the East (Waihi
Waiokura Marae
Stream) and West (Taungatara Stream) of the Ngāruahine Cultural Protection Area are areas of shared interest with Te Rūnanga o Ngāti Ruanui Trust and Te Kāhui o Taranaki Iwi Trust respectively.
Rangatapu Pā
Any proposals in these areas will necessitate active engagement with Te Korowai, the relevant Iwi entity and the relevant Hapū. Key: 02.28.2023
Ngāruahine rohe/kaitiaki area 0
2
4
6
8 10km
Ngāruahine cultural landscape protection area Ngāruahine pā
27
28
APPENDIX 3: OUTCOMES SOUGHT BY TE KOROWAI Table 2 Ngāruahine Outcomes Based Framework
NGĀRUAHINETANGA
CURRENT STATE
METHODS
PARTNERS/ENABLERS
OUTCOMES SOUGHT
The cultural impacts of
Conduct research on the
Hapū members, Hapū researchers, tohunga
Cultural impacts are clearly
alternative energy development,
cultural impacts of alternative
tikanga, industry developers, MBIE, MfE, DoC
understood and communicated
including opportunities, are
energy development with
not well understood leading to
Ngāruahine Hapū, Whānau
uncertainty.
and uri based on Ngāruahine
The Ngāruahine Cultural
tikanga.
Landscape is protected for
Investigate solar solutions for
generations to come.
by applicants to Ngāruahine uri.
marae and papakāinga. KAINGA
MBIE, HUD, Te Puni Kōkiri, Kainga Ora
Ngāruahine uri are empowered
Ngāruahine uri are uncertain of
Identify and communicate
the changes they need to make
important information which
to understand and action the
with new energy technologies
will guide Ngāruahine
behavioural and technological
and efficiencies.
adaptation actions.
changes needed to ensure they can adapt and remain resilient.
Ngāruahine uri live in cold, damp
Promote and support
and inefficient homes.
adaptation and efficiency
Ngāruahine homes are healthy
measures to Ngāruahine uri.
and inexpensive to heat and cool.
MAHI
Witt, Industry Developers, MOE
Ngāruahine uri possess a wide
Ngāruahine uri lack the skills
Identify and support training
and qualifications needed in an
opportunities for Ngāruahine
range of formal qualifications
energy transformation process.
uri to enter high value, long
and skills to enable them to
They risk being spectators rather
term employment.
take full advantage of any opportunities that may arise in
than full participants.
the alternative energy sector. TAIAO
There is a lack of credible
Locate and disseminate
MFE, TRC, DoC, STDC, SDC, Academic
The environmental impacts
information on the environmental
high quality information on
Institutions, Hapū researchers
and real benefits of alternative
impacts of alternative energy
the wide range of potential
energy development are known
development. This includes
impacts that alternative
and understood by Ngāruahine
biodiversity and the reduction of
energy development may
uri. This enables them to make
greenhouse gases.
have.
informed decisions on how they will be impacted.
29
30
Taranaki Maunga mai Taikatu Rd - 2023
This document is printed on an environmentally responsible paper, produced using Third Party certified 100% Post Consumer Recycled, Process Chlorine Free (PCF) pulp from Responsible Sources. Manufactured under the strict ISO14001 Environmental Management System, and carries the internationally recognised Blue Angel, Nordic Swan, Austrian Environmental Label & the NAPM Recycled Mark.