Submission on Amendment to New Zealand’s Second Emissions Reduction Plan (ERP2) 2026–30
The Commissioner has provided feedback on the Government’s proposed amendment to New Zealand’s second Emissions Reduction Plan (ERP2) and the decision not to progress with an on-farm emissions pricing system by 2030. The submission expresses concern that the consultation document does not provide enough information to enable meaningful scrutiny.
The information provided in the consultation document is inadequate to inform a reasonable consultation for a number of reasons:
- Modelling results need to decompose external factors (e.g. changes to how we measure emissions, changes in forecasts) from the effects of policy changes to allow suitable scrutiny.
- Changes in modelling assumptions that clearly aren’t driven by policy changes need greater explanation.
- The Government should quantify and comment on the uncertainty and risks associated with meeting each emissions budget given the suite of policies it has and assumptions around eternal factors (e.g. afforestation).
- As a result of sometimes long time-lags between implementing a policy and its effect on emissions reductions, it is important to consider the impact of policy changes beyond the next budget period (2025–2030).
The Commissioner states that, at a bare minimum, the Government should explain why market-based mechanisms are favoured for other sectors but not agriculture. If there is no incentive to adopt new technologies that can reduce emissions, it is hard to see why taxpayers should continue to support the development of those technologies. The consultation document should also quantify the impact of the decision to not price agricultural emissions on meeting emissions budgets, including those beyond 2030.