Lawyers for Climate Action NZ Inc says the Emissions Trading Scheme is inadequate to achieve the reductions in emissions that are needed for New Zealand to meet its international obligations and to do its part to avoid catastrophic global warming.
In its submission on the Ministry for the Environment's Reforming the New Zealand Emissions Trading Scheme: proposed settings consultation document, the group calls on the Government to acknowledge this and to either undertake a more fundamental reform of the ETS framework and settings, or to introduce a carbon tax as the main policy tool to reduce emissions.
Lawyers for Cllimate Action says there are a number of flaws with the scheme. It says these will not be fixed by the amendments currently being considered by Parliament, or by new settings for the scheme proposed by the Ministry for the Environment.
"Even with the proposed changes, the ETS will continue to suffer from major flaws and will not achieve the emissions reductions that are needed to meet New Zealand’s commitment under the Paris Agreement," the submission says.
"LCANZI considers that carbon pricing can and should play a fundamental role in reducing greenhouse gas emissions and responding to the threat of climate change. To achieve this, either further substantial changes to the ETS are required or else our focus should be on other policy measures, such as a carbon tax."
Submission co-author James Every-Palmer QC says while the group supports the broad direction of the proposals, it is concerned that the proposed emissions budget is too generous and the proposed price parameters are too low.
More fundamentally, he says, the group questions whether the ETS will have any impact on the total emissions that New Zealand will generate going forward, given only 30% of New Zealand’s total emissions are properly covered by the ETS and there is a substantial existing stockpile of emissions units. Emissions from international transport to and from New Zealand are not accounted for at all.