Submission on the proposed changes to NZ ETS limit and price control settings for units

LCANZI submitted on the 'Proposed changes to NZ ETS limit and price control settings for units 2022' on 6 October 2022. 

The emissions trading scheme is intended to be a key tool to ensure that New Zealand meets its international obligations, the emissions budgets and the 2050 target.  However, it is not currently fit for purpose.  The ETS is referred to as a “cap and trade” system, but it does not cap our emissions.  Furthermore, by treating forestry removals as equivalent to gross emissions it has encouraged forestry but has failed to reduce our gross emissions.  It is vital that these issues are addressed and resolved urgently.

One of the issues being consulted on is the level of auction volumes.  We consider that the proposed volumes are much higher than those implied by our commitments under the Paris Agreement.  We consider that the proposed settings could be susceptible to judicial review. 

You can read the full submission here. This submission was written by LCANZI ETS subcommittee members; James Every-Palmer KC and Jeremiah McLanahan. If you are interested in joining our ETS subcommittee please email admin@lawyersforclimateaction.nz.