Our Submission on the Draft Second Emissions Reduction Plan
We have submitted on the Government’s Draft Second Emissions Reduction Plan.
Emissions reduction plans are critically important components of New Zealand’s legal climate framework. They set out the plans and strategies for how the Government will meet the relevant emissions budget, which the Minister for Climate Change is under a legal duty to ensure is met.
We're concerned that the second emissions reduction plan is not ambitious enough and takes an unnecessarily high-risk approach to meeting our climate targets. Lacking significant detail, it does the bare minimum of what might enable the next emissions budget to be met, and likely takes New Zealand off course for meeting future emissions budgets and our 2050 statutory target, all while claiming that this is a “least cost approach”.
Some of our key concerns, as detailed in the submission, include:
The consultation is inadequate, as it does not adequately detail the policy assumptions behind the interim baseline, which is responsible for around 95% of the planned emissions reductions. Rather, the interim baseline is something of a ‘black box’. It doesn’t provide the public with the information necessary to show impact of each policy, or their associated delivery risk, on the ability to achieve the second emissions budget.
The consultation on the First Emissions Reduction Plan is treated as a tick-box exercise. While we are pleased to see the Government consulting on the First Emissions Reduction Plan, the Government is largely retrospectively consulting on policy cuts they have already made. We are also concerned the limited detail provided on the proposed strategy to mitigate the impacts of reducing emissions on iwi and Māori.
On the plan itself, there is significant uncertainty about whether the second emissions reduction plan will enable New Zealand to met the second emissions budget. The Climate Change Commission in its First Monitoring Report expressed significant concerns about the delivery risks of the second and third emissions budgets, and many of the assumptions behind ERP2 are debatable.
The Government is heavily relying on emissions removals (largely through exotic afforestation and novel technologies), rather than prioritising emissions reductions at source. This is inconsistent with Climate Change Commission’s advice, and is an unnecessarily risky approach.
The Government also continues to rely on the Emissions Trading Scheme as its major policy lever, but does not appear to intend to make the reforms necessary to ensure the ETS is fit for purpose.
You can read our full submission above.