'We support the government’s intention to act with urgency and improve the ETS. We are, however, concerned by the highly technical nature of the consultation documents. We consider that currently, input is severely constrained from those who will bear not only the impacts of climate change, but also the impacts of climate change mitigation and adaptation policies. The ETS is complex, but because of the far-reaching implications for New Zealanders, it’s essential that every effort is madeto widen this discussion. We consider it essential that there is a clear statement of the principles upon which the ETS is based, and that this is developed with due democratic process.

'Our greatest concerns are firstly, that the ETS continues to fail to deliver reductions in greenhouse gas emissions because not all sectors are included, and/or because there is a weak pricingmechanism and/or there is no “sinking lid” on the number of units being auctioned. Secondly, weare concerned that the ETS will increase social and health inequities – this issue can be mitigated through good recycling of revenue to support a low-carbon transition for low-income, Māori andPacific households. Thirdly, we are concerned about corruption in the ETS process, through the purchasing of overseas credits.'

Read full submission here (PDF).