New Zealand's Draft Second Emissions Reduction Plan

This morning, the government released its draft second emissions reduction plan (ERP). At first blush, there are reasons to be concerned.

We continue to be encouraged by the Government’s stated focus on meeting New Zealand’s climate change targets and commitments. However, we have significant concerns about whether the path set by this Draft ERP will enable New Zealand to actually achieve these targets. 

Under the Climate Change Response Act 2002, the central legal requirement of an ERP is that it must set out the policies and strategies the Government will rely on to meet the relevant emissions budget. The Minister for Climate Change also has a legal obligation to ensure that the emissions budgets are met.

However, the Ministry for Environment’s own modelling indicates ‘significant uncertainty’ about New Zealand’s ability to meet its next emissions budget.

According to the Draft ERP’s baseline model, which factors in optimistic emissions reductions driven by the ETS, New Zealand is not on track to meet the second emissions budget. It is only when additional potential policy measures are considered that the modelling suggests New Zealand is likely to meet the net emissions target.

But many of those policies are speculative, reliant on technological advances that don’t exist yet or are unproven, and will likely be offset by some of the Government’s other policy decisions. We are also concerned about a continued focus on ‘net emissions’, which ignores the importance of reducing emissions at source.

The Draft ERP also highlights that New Zealand is far from meeting its international obligations under the Paris Agreement. The government’s policies have resulted in a shortfall for the 2030 NDC that is 22 million tonnes larger than it was under the previous government. This will come at a significant financial cost.

One positive from the Draft ERP was that it appears to respond to our previous concern that the Government was not complying with its obligation to amend the existing ERP, which continues to have effect until 2026. To this end, the Government is also consulting on amendments to the First ERP.

Lawyers for Climate Action NZ will make a detailed submission on the Second ERP ahead of the submission deadline next month.