Submit on the government's 15-year Emissions Reduction Plan

Make a submission on the Government’s first Emissions Reduction Plan 

The Government is consulting on its plan to reduce emissions over the 15 next years from transport, energy, waste, f-gases, building, construction, agriculture and forestry. We have prepared the submission guide below to help inform you of major points you may choose to include in your own organisational or individual submission. The closing date for making a submission is Wednesday 24 November 2021.

We have kept this submission guide to major points only. For more information on how to make a submission see here

The main points we would recommend are as follows

  1. The Emissions Reduction Plan (ERP) continues the recent history of the Zero Carbon Bill through the Climate Change Commission process of having little or no regard for either the effects of climate change on health or, more importantly, the health and wellbeing co-benefits from well-designed climate action. Health is barely mentioned in the entire document, except as occasional throw-away comments and without any clear plan as to how to maximise the health gains.

  2. Te Ao Māori is given more attention, but it can be further strengthened. The discussion is too often on “partnership” without any firm plan regarding giving proper agency to Māori leadership and groups. This is particularly important in the health sector with the impending establishment of the Māori Health Authority, which could be used as an example for the rest of the public sector of a commissioning body which will have real clout and ability to lead (if the Ministry of Health follows through on their promises)

  3. The document is profoundly and inexcusably deficient in how it addresses agriculture and food systems. As it acknowledges, this is responsible for nearly half of Aotearoa’s emissions, but is given a mere 4 pages in the 130-page document (waste on the other hand, at 4% of emissions, warrants 10 pages). There is little or no detail within these pages, and more importantly, none whatsoever of one of the recommendations of the Climate Change Commission, that of national herd size and stocking rate reduction.

  4. As Minister Shaw has the ultimate authority to decide on the representation of health expertise, either directly to the ministry, or to the Climate Change Commission, OraTaiao recommends continuing a strong call for adequate health representation, including public health expertise, to those bodies planning our climate change response. This could be recommended under Q.21 (p35 of the document)

  5. F-gases are a particular area of focus for the health sector, due to their presence in anaesthetic gases and metered-dose inhalers. This is completely absent from the discussion document, which focuses solely on refrigeration and air-conditioning.

  6. Further specific recommendations are outlined below. Firstly, under the ‘3 specific questions’ for the brief submission and with further bullet points under the respective headings: transport, energy, agriculture, waste and f-gases should you wish to draft a longer submission.

Put human health & wellbeing at the heart of Aotearoa’s Emissions Reduction Plan

1. What are the most important things to consider in developing Aotearoa’s Emission Reduction Plan?

Health at Heart of Plan

Well-designed health-centred climate action will maximise both the health-benefits and emissions reductions (1).

Fit for Purpose

This plan has to work. The purpose of Aotearoa’s climate legislation is to fairly contribute to limiting global warming below humanly adaptable 1.5’C and to achieve net zero long-term emissions by 2050. Early action matters most. The next few years are crucial to keeping the 1.5-degree window open.

Post-COP26, Aotearoa must scale up our current Nationally Determined Contribution (NDC) from disguised domestic emissions cuts of around 7-9% below 2005 levels by 2030 on a net-net basis. This enhanced NDC must be primarily met by the Emissions Reduction Plan.

Invest in Aotearoa

Invest in urgent climate emission cuts here in Aotearoa now. Offsetting emissions with forestry expansion and land-use change must not be used to delay the necessary decarbonisation needed.

Tiriti-based and Equitable
Every part of this plan must be based in te ao Māori and Tiriti partnership - resourced and representative, and with Māori leadership to the fore.

Prioritise real measures that reduce vulnerability now, so that low emissions living is easy and affordable for everyone. That includes affordable housing, adequate incomes, decent jobs, healthcare, education and enabling environments.

Aotearoa’s worst climate polluting companies must be fully accountable now - especially the top ten companies who account for most of Aotearoa’s emissions.

2. What new initiatives to include in Aotearoa’s Emissions Reduction plan?

Our ERP needs an urgent and comprehensive plan to help the agricultural sector improve their emissions.

A clear plan to guide health sector emission reductions- the health sector is the largest greenhouse gas emitter in the public sector. This will need the incorporation of a sustainability unit in the new Health NZ and Māori Health Authority structures, along the lines of the Greener NHS system in NHS England

3. What do you see as the main opportunities and impacts of emission reduction policies in Aotearoa?

As above, the results of well-designed action will be a healthier, more resilient and more equitable Aotearoa. The health benefits must not be underestimated, and can be a crucial driver of behaviour change as they will be realised far earlier than any climate benefit.

Global and local evidence shows health-centred climate action self-funds in health gains - before counting savings from avoided climate changes (2).

Health co-benefits must be counted in evaluating mitigation strategies.

Extra information under specific headings:

i. Transport

The new transport targets set for 2035 are too little and too late. We are however pleased to see an increased focus on active transport compared with the Climate Change Commission advice.

We support the minimum target reduction of 20% of Vehicle Kilometres Driven but recommend the target be brought forward to 2030. However, in order to achieve the best health outcomes this needs to be coupled with a defined increase in active transport. We recommend a minimum of an absolute increase of 10% in each active mode or a doubling of active transport (cycling and walking) modeshare- whichever is larger- in all urban areas with a population over 10,000 by 2030. Investment and development of completely interconnected cycling and walking infrastructure must be available to meet this minimum goal, along with extensive links between active and public transport routes

Fund free public transport for everyone under 25, plus community services card holders, effective immediately.

Ensure easy affordable access for those of us living with disabilities which limit access. Focus on low income communities for co-developed low emissions access solutions

Sign off light rail construction contracts in all our main cities by July 2023.

We recommend no further motorway investment, and a target reduction in private vehicle ownership of 10% by July 2023, with an immediate and concomitant increase in funding for urban public transport, community car-share schemes, rail investment and intercity non-aviation transport options.

We strongly support the phase-out of the importation or assembly of all internal combustion engine light vehicles by 2030 at the latest. This must apply to all light vehicles, whether or not a non-ICE version is available. It is crucial that the definition of light vehicles be strengthened, as some models of large ute are already approaching the 3.5 tonne limit.

Consideration must be given to stopping the importation of used ICE vehicles earlier to avoid Aotearoa becoming a dumping ground for these. Due consideration and planning must also be given to a just transition away from ICE-vehicles, as an accelerating shift will run the risk of poorer families being left with stranded assets with an increasing cost to run

Support the ‘at point first registration charge’ starting 1 January 2022. To be effective, the charge should rapidly grade up, because the charges as set will only represent a few percentage points increase in the price of new vehicles.

Buses: only zero-emission buses should be purchased as of now. Current contracts for purchase of ICE buses should be the subject of Governmental review and ways sought to cancel these in favour of zero-emission buses.

Schools: need safe active transport corridors that avoid any arterial traffic and extensively traffic calmed suburban streets through street redesign (cf. the Future Streets Te Ara Mua project) and speeds restricted to around 20 30 km/hr or less on suburban streets. Recommend extensive infrastructure investment in safe road crossings and cycle/scooter lanes. We strongly support the conversion of road space to active and public transport space, especially in suburban areas where children go to and from school.

ii. Energy and industry; Building and construction

We broadly support the recommendations around building and construction. We support emissions caps for all public buildings, and a rapid scale-up of grants and support to private homeowners to adequately insulate properties.

We recommend a target of 2025 for the end of coal-use within Aotearoa. This will need a rapid expansion of the government's current plan to replace or repurpose coal-boilers to renewable fuels within the public sector, a similar plan to support private sector reduction and an accelerated plan to expand renewable electricity generation.

In order to optimise the health gains from reduced air pollution, the aim must be to replace coal-fired boilers with electric heating and measures to reduce heat loss whenever possible, as distinct from wood-pellet boilers.

iii. Agriculture and forestry

Cutting climate pollution needs every sector and every climate-damaging gas.

Essentially excluding the half of Aotearoa’s emissions that come from agriculture from this plan (and the Emissions Trading Scheme) is indefensible. Aotearoa should be a world-leader in pivoting to climate friendly food production

Immediate and rapid reduction of artificial fertiliser use will help reduce climate emissions, improve waterways and reduce groundwater pollution. There is increasing acknowledgement of the links between nitrate drinking water pollution and colorectal cancer

Aotearoa’s lands must be used for food production that is healthy for humans and for our environment. This means diversity within farms and much more plant- based foods.

A plant-based diet is potentially more cost-effective than an omnivore or pescatarian diet within middle to upper-income countries, such as Aotearoa. A population shift to healthier and more sustainable diets can therefore support reductions in our unnecessarily high food insecurity rates (1 in 5 children)

The current Healthy Eating and Activity Guidelines (for all age groups) must prioritize sustainable diets and food productions. Robust criteria for sustainable and healthy food must be included in all food-related procurement policies.

Food sovereignty (people’s right to their own food systems including culture and production) must feature in our understanding of well-being.

The use of fossil fuel derived energy within the food production system, for example in milk drying with coal boilers needs a specific focus and rapid phase-out.

We acknowledge and support the Ministry’s position on forestry planting and agree that it must not be used to unnecessarily delay decarbonisation. We advise an increased stress on native forest plantation and restoration, as recommended by the Climate Change Commission.

iv. Waste and F-gases

F-gases are a significant contributor to healthcare emissions, via anaesthetic gases or metered-dose inhaler propellants (3). These are not addressed within the plan. We advise two measures- an establishment of a Sustainability Unit within the new Health NZ and Māori Health Authority to oversee and guide the clinical decisions that will need to be made to achieve health sector decarbonisation, and a target ratio of a minimum use of dry powder inhaler to metered dose inhaler of 70:30 (from the current 30:70) by 2030, this being an already clinically-beneficial indication.

Make your submission here. The closing date for making a submission is Wednesday 24 November 2021.


(1) Hamilton, I. et al. (2021) The public health implications of the Paris Agreement: a modelling study. The Lancet Planetary Health. 5(2), E74-83.

(2) Chan Fung Fu-Chun, M. (2021) Accelerating towards net zero emissions: the most important global health intervention. The Lancet Planetary Health. 5 (2), e64-e65

(3) Beasley, R. (2020) NZ Adolescent and Adults Asthma Guidelines. Asthma and Respiratory Foundation NZ: Wellington. Available here. (accessed 14/11/2021)

Our extensive Climate Change Commission submission from March 2021 contains a wealth of further information, links and references. See here.

Download our ERP Submission Guide (PDF).



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