This morning, the government released its draft second emissions reduction plan (ERP). “At first blush, there are reasons to be concerned”, says Executive Director of Lawyers for Climate Action NZ, Jessica Palairet.

“We continue to be encouraged by the Government’s stated focus on meeting New Zealand’s climate change targets and commitments. However, the path set by this Draft ERP raises significant concerns about whether New Zealand will 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 would not be 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 significant shortfall in meeting the 2030 NDC, requiring around 93 Mt CO2-e additional abatement above the government’s proposed policies. This shortfall will come at a significant financial cost to the Government. And it’s still not clear what the plan is for meeting that shortfall, or whether the Government will even recognise it as a liability in the Crown accounts. We have previously written to the Government about this issue.”

“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”, Palairet adds.

Lawyers for Climate Action NZ will make a detailed submission on the Second ERP, and proposed amendments to the First ERP ahead of the submission deadline.

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