Speak up on the Emission Reduction Plan – by Sunday 25 August

The government wants to know what you think about its Emissions Reduction Plan for the years 2026-2030, the critical second half of this critical decade for climate action.

The second emissions reduction plan (ERP2) will outline the actions that we intend to take to reduce emissions in New Zealand during the second emissions budget period (2026 – 2030). The ERP2 is a key tool to bring the Government’s climate strategy to life.

Read all about it, and have your say here. Feedback is open until Sunday 25 August.

• Here’s a quick overview of the consultation.
• Here’s the main discussion document (123 pages) and the technical annex.
• And here’s a template of the consultation questions.

Why we should all speak up – again

Because this second Emission Reduction Plan (ERP2) falls far, far short of what is required, and what’s possible. It not only fails to give us a fighting chance at doing our part, it misses out on a huge number of really smart opportunities to transform our lives and our economy for the better. And, despite claiming to pursue a “least cost” approach, it ignores a bunch of truly “least cost” solutions – for what in many cases seem to be purely petty reasons.

Last year the Climate Change Commission consulted with the public on its advice to government on shaping the ERP2. This is important work, said the people, but please do more, go further, with urgency.

This strengthened advice was then passed on to the incoming coalition government, which has now responded: Yeah, nah, as long as we plant enough pine trees she’ll be right.

In terms of ticking the boxes, the ERP2 just about meets the country’s short-term targets – thanks in large part to the efforts of the Labour-Green government that set the first plan – but beyond 2030, it fails.

It ignores easy and equitable ways to decarbonise transport, and experts say it puts our global reputation at risk. Meanwhile, the planet continues to heat up dangerously and is approaching multiple irreversible tipping points.

What the ERP2 does

It relies on five precarious strategies:

1. Planting trees to balance emissions. Let’s be clear, trees are great. But with a rising population, planting will never be enough. What’s more, monoculture forestry (i.e. fields of pines, which is the majority of plantings proposed) can bring in its wake wildfires, disease, slash-strewn flooding, and the displacement of indigenous forestry and productive land.
2. Magicking up unproven new technologies, like cattle feed that reduces burping, and sustainable aviation fuel (still a way off), and, you know, whatever else the rest of the world comes up with – because simultaneously, our government is also cutting back on funding for Research & Development, and financial incentives that encourage industries to make rapid and smart changes.
3. Strengthening the ETS, i.e. the Emissions Trading Scheme – but still planning to subsidise high-emitting exports, and exempting agriculture from the scheme.
4. Electrifying our car-centric growth economy based on renewables. Renewable energy is important, but even an electric car is not carbon-free, and it takes up just as much space as a conventional one. Some public transport will be funded, but walking and cycling budgets have been slashed as this government’s focus is on building more roads, and removing “frills” like pedestrian and cycling safety. To make it worse, they propose to stop assessing the emissions impacts of roading projects. What you can’t see won’t hurt you?
5. Helping New Zealanders prepare, which sounds great, but… how, exactly, if you plan NOT to consider the climate change impacts of your decision-making?

The coalition government seems to have forgotten that pretending a problem doesn’t exist doesn’t make it go away.

What the ERP2 should do

It should pull all the levers that we already know work, right now. These levers – which also deliver myriad benefits beyond just reducing emissions, include straightforward and smart moves like:

1. Land-use planning that significantly reduces the time New Zealanders have to spend in cars to get to work, education and the fun stuff.
2. Financial levers that incentivise industry, farmers and individuals to embrace a low-carbon transition as quickly as possible.
3. A holistic approach to a just transition that doesn’t cause suffering to people and the non-human world. Not only is this the right thing to do, it is the only way the world as a whole will succeed. And we can help lead the way.

The huge missed opportunities for transport are particularly striking.

• By its own carbon budgeting, this ERP2 isn’t going to reduce transport emissions by 2030; instead, it increases them from 2025-28, and relies on as yet uninvented technology in fuels and carbon capture. This is magical thinking, and transparently unambitious.
• The government’s wider transport policies simply don’t back the ERP2’s claims of greater investment in public transport. They’ve removed emissions as a criteria for investment, and pouring the bulk of transport investment into RoNS will make emissions worse.
• Removing the clean car subsidy (with immediate and predictable impact on EV uptake) undermines the proposed minor policy actions on EV charging; lowering the clean car standards also undermines emissions reduction in transport.

Plus, given the government has signalled its intention to rely heavily on the Emissions Trading Scheme (while beefing it up to raise the price of carbon credits), the ERP2 should also recognise that this will mean much, much higher petrol prices, if it is to make any difference to our emissions profile.

Higher petrol prices mean greater transport inequity (in a time of increasing expenses overall) and much, much higher freight costs.

This means the ERP2 should have a solid framework in place to minimize the negative effects of these much higher fuel prices.

What would that look like, you ask?

Much more investment in public transport and active modes, and much greater support for mode shift. More streets that are friendly for walking and cycling, and more accessible and affordable buses and trains, to decarbonise the short trips that make up the majority of urban travel.

Everyday solutions that reduce traffic jams and rat-running, and help more get people out of traffic – which, you’d think, is something everyone can get behind.

Unfortunately, under the eye of this government, numerous programmes and policies have been dumped that were already tackling climate challenges holistically and effectively, and delivering other benefits. Just to give a few examples:

• The Climate Emergency Response Fund. This channeled money from the ETS towards projects designed to mitigate or help communities adapt to climate change, and included dozens of transport choice projects in towns and cities across the motu, which improved public transport and made it easier and more attractive for people to walk and bike – including safe routes to schools.
• Requiring new investments for transport projects to demonstrate how they will contribute to emissions-reduction objectives, and setting a high threshold for approving new investments for any transport projects if they are inconsistent with emissions-reduction objectives.
• Ensuring the Government Policy Statement on Land Transport (GPS-LT) guides investment consistent with the emissions reduction plan.
• Revising Waka Kotahi’s national mode shift plan (Keeping Cities Moving) to ensure nationally-led activities align with the pace and scale of vehicle kilometres travelled (VKT) reduction and mode-shift required in urban areas. (In other words, the goal was to design cities so people can access more of what they need without needing to drive, are not forced into a life that requires long journeys by car… this government has replaced that goal with the impossible one of just getting there faster.)
• Equitable transition plans
• Income insurance schemes
• Commencing a Circular Economy and Bioeconomy Strategy.
• Rolling out the Government Investment in Decarbonising Industry (GIDI) fund, which among other things supported businesses to transition to electric arc heating instead of coal furnaces
• Developing an emissions pricing mechanism
• Ensuring regulatory settings deliver the right type and scale of forest planting, in the right places.
• Banning new fossil-fuel baseload generation.
• Managing the phase-out of fossil gas and developing a gas transition plan.

And the list goes on.

We generally like to stay optimistic around here, but New Zealanders should really be mad about this. The cancelled climate action policies (35 in total) used a number of levers to meet the challenges ahead, and they were working at driving change. Emissions were going down.

You have to ask: what is this coalition government doing, snatching defeat from the jaws of victory? It’s embarrassing.

And, if they think New Zealanders are ambivalent about this, they are wrong. Recent polls show that the vast majority of New Zealanders (80% of us in 2023) believe climate change is an important issue – and say that they will or already have been personally be impacted by climate change. This is not a fringe issue.

In 2024, the vast majority (83%) believe the government is responsible for taking action, and 70% say they are prepared to take action themselves. But only 32% of New Zealanders (down 5 points from last year) say our government is on the right track on climate.

Of course any new government will have its own ideas on how to tackle climate change. We need all the ideas we can get! But planning more pine plantations, fiddling with the RMA, and providing electric car charging points is nowhere near enough. Everything this government is doing was planned by the last government and already underway – only they’re choosing to do it on a smaller, far less ambitious scale, while cancelling things that were working just fine.

This is a national shame. It’s also a national opportunity, because New Zealanders deserve better. Our children expect better. We know better, and we can tell the government to do better. They might choose not to listen – but they can’t say they weren’t told.

How to make your voice heard

You can provide feedback here until midnight Sunday 25 August.

Need help putting your thoughts into words? The good people of Climate Club have provided these handy links:

If you have 5 mins:
Climate Club’s fast submission guide (general)
Don’t Subsidise Pollution’s guide (ending free carbon credits for big polluters)
Rewiring Aotearoa’s guide (energy systems & electrification)

If you have 15 mins: Use the submission guides above, but personalise it – this makes it much more effective. You could even pick & choose your favourite points from all three!

Bonus: Gather submissions from your community with this guide

Here’s a great explainer of what’s in the ERP2 – and what’s not – by Shanti Mathias at The Spinoff.

Here’s a good read from the Public Health Communication Centre, explaining why the ERP2 is “a weak response to a weak target”, plus a look at the inequities of transport emissions.

Here’s a submission by Prof Robert McLachlan, characterising the ERP2 as high cost, high risk, and low ambition.

And here’s the Greens guide to ERP2 feedback.

If you know of others, please add them in the comments below!

Update: thanks to a reader for adding Auckland Council’s (draft) submission, which makes some good points about making sure national transport emissions reduction strategies align with the TERP. Decarbonising the transport that makes up a third of the emissions from a city with a third of our population, has to be a priority!

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