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5 min read - June 14, 2022


The Government is required to provide an Emissions Reduction Plan (ERP) to the Climate Change Commission (CCC) to outline the future pathway to achieving carbon neutrality by 2050*. As part of that, the Government is inviting feedback on its ERP consultation document. Read on to find out about the ERP and have your say before 24 November 2021.



In June 2021, the CCC published its advice on how New Zealand’s future emissions reduction targets under the Climate Change Response Act 2002 can be met. The Government is required under that Act to provide an ERP that sets the direction for New Zealand’s climate action for the next 15 years.


This ERP is to set out policies and strategies to reduce greenhouse gas emissions for specific sectors including transport, energy, waste, building and construction, and agriculture and forestry. The ERP will also include a multi-sector strategy to meet the emissions budgets and improve the ability of sectors to adapt to the effects of climate change, while mitigating the impacts which reducing emissions and increasing removals will have.


The Government has acknowledged in the ERP that legislative reform alone will not be enough to hit the targets needed to drastically cut emissions. In the worst-case scenario, the budgets call for reductions that amount to approximately one third of what is needed. At best, two thirds. Therefore, the Government is seeking additional proposals and commitments from the private sector to close that gap.


The Consultation Document

The consultation document is made up of ideas developed following conversations between Ministries and agencies. Ideas that have already been consulted on through previous policy documents or through the CCC’s consultation are not included in this document.

The Government wants feedback on:

The steps your community can take.
Investments your business can make.
Changes you can make as an individual.
How the Government can best support those changes happening.
The consultation document provides information on the emissions and the plans proposed to reduce those emissions in some key sectors.


Plans per sector

The transport, energy and industry sectors are the focus of the first emissions budget. These sectors are where the most efficient and cost-effective reductions can be made in a short period of time.



Emissions from this sector makes up 43% to New Zealand’s total emissions. The following plans are proposed to be implemented by 2035:

Reduce vehicle kilometres travelled by cars and light vehicles by 20%.
Increase zero-emission vehicles to 30% of the light fleet.
Reduce emissions from freight transport by 25%.
Reduce the emissions intensity of transport fuel by 15%
A number of other key themes also emerge, such as increasing congestion charging, integrating housing development and public transport infrastructures, and imposing CO2 limits for fossil fuel powered vehicle imports.


Energy and Industry

Emissions from energy and industry make up 26% of total emissions in New Zealand. The ETS is a key mechanism to reduce emissions in these areas*. The plan suggests:

Setting a renewable energy target and strategy.
Developing a plan for phasing out fossil gas and/or decarbonising.
Developing a mandatory emissions reporting scheme for large energy users.
Developing a hydrogen and bioenergy roadmap.
A switch from coal to biomass within the first budget period.
The plan also assumes the Marsden Point oil refinery converts to an import-only terminal in 2022 and the Tiwai smelter shuts in 2024.



The ultimate plan for this sector is to ban organic material going into landfills without gas capture by 2030. However, other plans include:

Implementing food waste collections or viable alternatives to landfill disposal.
Reducing waste production.
Moving towards a circular economy.

Forestry plans include:

Establishing long-term carbon sinks (possibly by extending native forests).
Managing existing forests.
Working with Māori to develop and implement forestry policies.
It is predicted that forestry will over-deliver on the sequestration needed to meet targets, which could provide a low-cost buffer if other sectors under-deliver.



Emissions in this area make up 48% of our gross emissions. The He Waka Eke Noa programme is putting in a substantial amount of work into emissions reductions. Plans include acceleration of mitigation practices through research and development (such as methane inhibitors and methane vaccines). Although touched on in this consultation, it is likely these actions will have a bigger impact in later emissions budgets.


Next steps

If you would like to discuss these changes or require assistance with making a submission, please get in touch. Submissions close on 24 November 2021.

Contact: Solicitor Harriet Kebs: Harriet@k3.co.nz or Solicitor Evie Bello:  Evie@k3.co.nz.  


This article is part of a series of climate change articles that will be released by K3 in the coming months. Keep an eye out for the next issue in the series!


*Information on Emissions Budgets are contained in a previous article published on K3’s blog at – http://blog.k3.co.nz/emissions-trading-scheme-mfe-paving-the-way-for-significant-reform

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