Use your voice to ensure Aotearoa New Zealand reaches Climate-friendly Carbon neutrality by 2050

Creating a submission is your opportunity to share your perspective with decision makers, and you can do this within minutes. Below we’ve written instructions on how to create a submission on the Emissions Reduction Plan, with recommendations on what you may want to include. 

Why does this matter? 

A Green Climate Minister created the Zero Carbon Act, with emissions budgets acting as stepping stones to reach carbon neutrality by 2050. The Emissions Reduction Plans (ERPs) are supposed to outline how exactly we do that. Unfortunately, this Government’s “plan” doesn’t stack up, and we need your help to fix that.  

The new draft ERP shows that Aotearoa is no longer set to reach the 2050 net zero target, because of policy changes by this Government, who have chosen a risky and irresponsible emissions reductions strategy.  The Green Party is asking you to submit on the draft ERP to tell the Government to take urgent steps to address the shortfall created by their policies, so all of us can have a liveable future. 

What is the govt trying to do? 

The coalition Government is consulting on an emissions reduction plan that will see Aotearoa blow out the ‘third emissions budget’ for 2031-2035 by approximately 17 million tonnes of carbon dioxide. This is due to them ditching or minimising policies set under the previous Government, including relaxing standards on car emissions, keeping agriculture from paying a fair price for its emissions, removing EV subsidies, and no longer supporting the replacement of industrial boilers. To reduce emissions by a ‘net’ approach, they are relying on pie-in-the-sky carbon capture technology and pine forests the Climate Commission makes clear won’t actually sequester carbon this decade. They also say they will build better public transport, but their own documents note that the benefits of this will be undone by their increased spending on roads. 

What could my submission say? 

1. Go to this link on the Ministry for the Environment’s website here: https://consult.environment.govt.nz/climate/second-emissions-reduction-plan/consultation/ 
2. Fill in your details in ‘Submitter details’  
3. We suggest answering questions 2 & 4 of the ‘general consultation questions’’. We have provided prompts for these.  
4. We have also provided answers for Chapters 3, 5, 6, 7, 8 & 9. You can choose to use our suggestions answering as many of the Chapters as you like.   

You can also use the Climate Club’s submission guide to help you with your answers.  You could also refer to the Climate Change Commission’s Advice on the direction of policy for the Government’s second emissions reduction plan

Thank you for taking the time to create a submission. Your submission will hold the Government accountable to make choices that protect our planet, and people, now and long into the future.  

General consultation questions 

0.2 The Government is taking a ‘net-based approach’ that uses both emissions reductions and removals to reduce overall emissions in the atmosphere (rather than an approach that focuses only on reducing emissions at the source). A net-based approach is helpful for managing emissions in a cost-effective way that helps grow the economy and increase productivity in New Zealand.  

• A net-based approach aims to remove carbon through forestry or technology rather than by reducing emissions at their source. This is susceptible to reliance on unproven technology and locks in future generations to land use decisions on forestry. A gross emissions approach is based on solutions in sectors like transport, agriculture, and energy which are reliable and ready to invest in.  
• A gross reductions approach which focuses on stopping emissions at the source is the least risky way of ensuring New Zealand meets our domestic and international emissions goals.  

• The Climate Change Commission highlights that reducing gross emissions is a pathway strongly recommended by the Intergovernmental Panel on Climate Change (IPCC). Their Sixth Assessment Report states at a high level of confidence that “reaching net zero CO2 or greenhouse gas emissions primarily requires deep and rapid reductions in gross emissions of CO2, as well as substantial reductions of non-CO2 greenhouse gas emissions.” 

• The Climate Change Commission notes that long-term ambiguity about the intended level of gross emissions is a particular problem for the Emissions Trading Scheme (ETS). To design and operate effective climate policies, and particularly to run the NZ ETS, it is essential to have a clear objective for the balance sought between gross reductions and carbon removals. 

0.4 What Māori- and iwi-led action to reduce emissions could benefit from government support? There are additional questions about Māori- and iwi-led action to reduce emissions and impacts of proposed ERP2 policies on Māori and iwi in chapters 1 and 12.

• As recommended by the Climate Change Commission, the Plan should directly allocate resources to iwi and Māori and augment funding to Māori landowners to enable them to accelerate emissions reductions and removals in accordance with their priorities. Iwi Māori must be empowered to lead the weaving of mātauranga Māori into policy design, development, and implementation at central and local government levels. This includes providing sufficient resources to iwi and hapū. 

• As recommended by the Climate Change Commission, the Plan should support education and training by Māori, for Māori, including enabling iwi and Māori to train/re-train for the skilled jobs that will be needed in the transition to a low emissions economy, and investments in schools, kura, and wānanga to ensure they have the necessary resources and technology to prepare rangatahi for jobs of the future. 

• The Plan should recognise iwi representatives and other Māori representatives as partners under Te Tiriti and facilitate partnerships in Aotearoa’s national climate action strategy. This could help fast track iwi and Māori local climate action and initiatives to reduce emissions and accelerate preparedness to adapt.  

• The Plan should bring together unions, government, employers, iwi and hapū to implement the Equitable Transition Strategy (from the first Emissions Reduction Plan) towards a low-emissions economy where workers throughout Aotearoa have good and sustainable jobs. 

• The Plan should include policies which enable an equitable transition grounded in Te Tiriti o Waitangi for Māori working in emissions intensive areas, including by prioritising the Māori economy when developing low-emissions jobs in affected regions. 

• The Plan must ensure long-term resourcing and support for the Māori Climate Platform. 

• The Plan could include initiatives like reforming Rau Paenga to operate as a Ministry of Green Works to support a low emissions and climate resilient Aotearoa, with stable jobs delivering public infrastructure. 

 Once you have finished this section, go to Chapter 3.  

3.1 What else can the Government do to support NZ ETS market credibility and ensure the NZ ETS continues to help us to meet our targets and stay within budgets? 

The ERP should incorporate the Climate Change Commission’s advice, to ensure the ETS is fit for purpose. This includes, but is not limited to: 

• Each year, hundreds of millions of dollars’ worth of industrial allocation is provided to New Zealand’s largest emitters. This industrial free allocation should be gradually phased out, while ensuring Government supports industry in this transition towards less emissions-intensive processes. Instruments like a Carbon Border Adjustment Mechanism could be used to address the issue of carbon-intensive production overseas.  

• Policies to restrict forestry in the ETS should be investigated, to ensure that high quality forestry is captured by the ETS, in line with recommendations made by the Climate Change Commission. 

• Setting of NZU supply should be carried out by the Climate Change Commission. 

• Government investment in the governance and market integrity of the scheme should be increased, ongoing, and work to build a robust, credible market.  

• International research indicates that emissions pricing policies are likely to be better supported by stakeholders where the funds generated are recycled. For this reason, the Climate Emergency Response Fund should be re-instated and policies such as carbon rebates, which increase the political feasibility of emissions pricing, should be investigated. 

3.2 What are the potential risks of using the NZ ETS as a key tool to reduce emissions? 

• The Emissions Trading Scheme should not be the only vehicle for achieving emissions reductions in Aotearoa. New Zealand is an international outlier in relying exclusively on emissions pricing to achieve emissions reductions, and for good reason.  

• There many risks in relying mostly on the ETS as a key to reduce emissions, including:  

• The risk of exposing New Zealand’s export market to claims of ‘greenwashing’ due to the ETS’s current reliance on net-based forestry removals,  

• The pace of emissions reductions relying on the New Zealand unit (NZU) price rising, which due to current ETS settings, is not rising quickly enough,  

• The current market integrity and governance arrangements of the ETS damaging the credibility of the system,  

• The current settings risk flooding the market with cheap NZUs from forestry which will not drive the emissions reductions necessary for a liveable future.  

 Once you have finished this section, go to Chapter 5. 

5.8 Please provide any additional feedback on the Government’s proposals to reduce emissions in the energy sector and the industrial processes and product use sector. 

• The Government should reinstate the oil and gas exploration ban. Undoing the oil and gas exploration ban will result in an extra 51 million tonnes of planet-heating emissions being pumped into the atmosphere in the years to 2050.  

• Restore funding for energy efficient equipment rebates. 

• Restore the Government Investment in Decarbonising Industry, to ensure industry is supported in the transition to zero emissions processes. 

• Scale up initiatives that support energy efficiency and protect against energy poverty like the Warmer Kiwi Homes scheme.  

• Initiatives such as the Green Party’s Clean Power Payment can rapidly increase the energy efficiency of the nation’s housing stock and move towards warm, fully-electrified homes in every part of Aotearoa.  

• The advice of the Climate Change Commission must be followed when working through development of renewable projects. This should be done in a manner that gives effect to the Te Tiriti o Waitangi and upholds Te Tiriti settlement legislation. This includes related legislation such as the Marine and Coastal Area (Takutai Moana) Act where the Crown-Māori relationship is in the process of addressing the scope of mana whenua and mana moana legal interests regarding areas currently under consideration for offshore wind development. Emphasis on rangatiratanga and a genuine partnership is essential to ensuring future energy developments take a kaitiaki approach to resource management within the takiwā of iwi and Māori. 

• Progress towards the aspirational renewable electricity target should be monitored.  

• Ban gas connections to new-builds. 

 Once you have finished this section, go to Chapter 6. 

6.8 Please provide any additional feedback on the Government’s thinking about how to reduce emissions in the transport sector. 

• EV charging and weakening the Clean Car Standard carbon dioxide targets will not be sufficient to drive the emissions reductions we need to see in the transport sector, our second biggest emitter after agriculture. The transport system largely needs to decarbonise if we are to meet the 2050 net zero target. 

• Further, there are greater emissions reductions potentials using the avoid-shift-improve framework to reduce transport emissions, successfully used by other countries, and recommended by the Climate Change Commission: 

• Reduce the need to travel by building more housing in our cities where people want to live, work and play, rather than allowing further greenfield development, which require people to travel further to amenities.  

• Shift how we travel from high emissions modes to lower emissions ones, by giving people better choices. This includes: 

• Investing in safe biking and pedestrian infrastructure, making it a safer choice to walk and bike. 

• Investing in regional rail to reduce the number of domestic flights required, and investing in coastal shipping and rail freight to improve efficiency in the system and get more trucks off the road.  

• Improve the uptake of technology we already have by reducing barriers to electric vehicles, including range-anxiety, but also pricing incentives. Vehicles stay in the New Zealand fleet for an average of 20 years before they are scrapped, therefore a ban on the import of fossil-fuel vehicles should be implemented as soon as 2030 to ensure we meet our net zero target, as other jurisdictions have done. Regulatory barriers to investment in low-carbon aviation, and shipping modes should also be investigated, as well as a Sustainable Aviation Fuel Mandate, and support for coastal shipping. 

• A transport emissions reduction plan chapter using this framework would not only reduce far more emissions than what is proposed, but it has a multitude of co-benefits: health benefits, from reduced air pollution and increased active travel; reduced congestion and road maintenance costs by shifting more cars and trucks off the road and onto public transport, rail and coastal shipping, and; more pleasant cities to live in, with streets for people, instead of cars. 

Once you have finished this section, go to Chapter 7. 

Chapter 7 

7.6 Please provide any additional feedback on the Government’s thinking about how to reduce emissions in the agriculture sector. 

• The Climate Change Commission recommended the implementation of an effective agricultural emissions pricing system. The Government should implement the legislative backstop for agricultural processers to enter the ETS in 2025, as legislated, to ensure that sector participants are incentivised to devise a pricing scheme that works for everyone and that crucial reporting information is collected. It is crucial that farmers pay their fair share for emissions, and don’t rely on other sectors and households to pick up their slack.  

• The Government’s approach relies on technology that is unlikely to be commercially available in Aotearoa until 2039 – after the timeframe for this plan. Additionally, there is no plan in place to address emissions of nitrous oxide, which have increased by over 600% since 1990. Synthetic nitrogen fertiliser should be priced at the manufacturer and importer level in the ETS as soon as practicable. 

• With an effective emissions pricing system for agriculture, new technologies, some land-use diversification, and on-farm efficiency increases, the sector could make the changes needed to meet Aotearoa New Zealand’s emissions reduction targets while limiting impacts on agricultural production. It is critical that the Government quickly implement this alternative and rapidly advance it in the second emissions budget period to a more detailed pricing system to create more long-term incentives to reduce emissions. This pricing system should be complemented by advisory and extension services to help farmers make necessary changes​. 

• Financial assistance could provide a means to limiting disruptive change to the agricultural sector. The Government could also choose to give targeted assistance based on certain criteria to manage more specific impacts. 

• Policy settings and allocated resources should reflect the significant role of agriculture in the Māori economy and the unique characteristics of Māori-owned land. There should be a focus on partnership, active protection, participation, and equity in line with Te Tiriti o Waitangi​. 

Once you have finished this section, go to Chapter 8. 

Chapter 8 

8.5 Please provide any additional feedback on the Government’s thinking about how to reduce emissions in the forestry and wood-processing sector. 

• The second emissions reduction plan is an opportunity for the Government to clarify the role of forests and other carbon stocks in achieving Aotearoa New Zealand’s emissions reduction goals. Policies should ensure diverse, multifunctional, and resilient landscapes to support long-term carbon removal, and should investigate the way that the ETS can support indigenous biodiversity. 

• As highlighted by the Climate Change Commission, different policy settings – such as those under Te Ture Whenua Māori Act – (and ownership settings) have an impact on what Māori landowners can do with their land, which in turn may have wider implications under Te Tiriti. It is necessary to consider the specific effects such policies have on iwi/Māori in relation to forests, in light of Te Tiriti and the unique cultural, economic, social, and environmental considerations of tangata whenua. 

• The Government’s plan should address how carbon removal activities will be recognised and incorporate principles of additionality (activities that contribute to carbon removal beyond the status quo) and permanence (ensuring long-term carbon storage). In their 2023 advice to government, the Climate Change Commission also noted: 

• Effective policy incentives, such as those provided by the NZETS, are necessary to maintain stored carbon. These incentives must be robust and maintained over long periods. 

• There is a need for integrated policy approaches that consider the broader impacts of forestry practices, such as water and air quality, land stabilisation, and biodiversity conservation 

• Policies and objectives need to be co-designed so that the diversity of iwi/Māori rights and interests is understood and recognised appropriately, including the complexity of historical grievances among rohe. 

• The Commission also stressed that excessive reliance on forestry for carbon removals could undermine incentives to reduce emissions at the source. 

Once you have finished this section, go to Chapter 9. 

 Chapter 9 

9.6 Please provide any additional feedback on the Government’s thinking about how to reduce emissions through non-forestry removals. 

• Overall, the Climate Change Commission has recognised the potential of non-forestry removals like Carbon Capture and Storage (CCS) and Carbon Capture and Uptake (CCU) but emphasises the need for significant legislative and policy advancements to make these technologies viable and scalable in New Zealand.  

• In Aotearoa New Zealand, non-biogenic Carbon Dioxide Removal, CCS and CCU technologies have not advanced beyond the concept and research stage. This lag is attributed to the current lower-cost option of forestry for emissions removal and the economic viability of low emissions substitutes for fossil fuel energy under existing policies​ 

• The Commission states the focus should remain on ensuring these technologies complement, rather than substitute, efforts to reduce gross emissions. 

• The Commission warns that insufficient progress in reducing gross emissions can lead to increased reliance on offshore mitigation and higher long-term costs. They recommend that clear targets and policies be set to drive gross emissions reductions and carbon removals. 

Once you have finished this section, go to Chapter 12 

 Chapter 12 

12.2 The Government can use a lot of existing tools to support people affected by reducing emissions (welfare and income support systems, employment and training services). 

Do you think additional climate-specific services, supports or programmes should be considered by the Government over the coming years?  

Please describe what additional climate-specific services, supports or programmes could be useful.  

• The Plan must ensure that workers and unions have a strong voice in transition plans for specific industries. Develop active labour-market measures to support workers to retrain and to match skills development with available jobs when workers are made redundant due to industry changes. 

• The Plan can outline initiatives to train more people for clean energy careers with a Clean Energy Industry Transition Plan, developed with the energy industry, training providers, and unions. 

• The Plan should reinstate the Equitable Transitions Strategy, to ensure there is a cohesive long-term strategy focused on the just transition.  

• The Government’s own advice demonstrates that emissions pricing impacts lower income households four times as much as wealthier households, and it is crucial that any emissions reduction plan takes this into account, devising policies to insulate families from the impacts of rising emissions pricing. The ERP should include targeted policies to support groups who are more impacted by pricing, including through recycling New Zealand ETS proceeds and considering a robust carbon rebate to low-income households.