Emissions Reduction Plan consultation

This page contains useful information about the Government’s discussion document on the Emissions Reduction Plan, which will outline how the reductions required in the Climate Change Response Act will be met in the short term.

The Government’s Emissions Reduction Plan consultation – information for farmers

The Government has finished consulting on the Emissions Reduction Plan. You can find B+LNZ’s submission below.

Also on this page is the guidance we provided to farmers for making their own submissions.

Submissions closed on Wednesday 24 November and the plan will be finalised early 2022.

More information about the Emissions Reduction Plan and consultation is on the Ministry for the Environment’s website.


Advice to farmers about the consultation and making a submission (19 November 2021)

  • The Emissions Reduction Plan Discussion Document describes existing and proposed actions to reduce emissions across the economy. The Government is seeking feedback to better understand the impacts the proposed actions will have, and how New Zealand can successfully achieve carbon net zero by 2050.
  • This plan needs to outline how the reductions required in the Climate Change Response Act will be met in the short term and the actions must also be technologically achievable, economically viable and socially acceptable. This Emissions Reductions Plan is intended to cover the emissions reductions needed between 2022-2025 but also signals what actions are needed between 2025-2035. 
  • The short-term focus of the document is to see emissions reductions in the energy, transport, and industrial heating sectors. This reflects the existing tools and technologies in these sectors that can be deployed at scale and pace. 
  • The actions taken to reduce emissions must help New Zealand get to the targets for emissions reductions in the future. They are:
    • greenhouse gases, other than biogenic methane, reach net zero by 2050, and
    • emissions of biogenic methane to reduce to at least 10 per cent below 2017 levels by 2030, and to at least 24–47 per cent below 2017 levels by 2050.

Key points to focus on

We suggest farmers focus on the following. You can copy and paste some of what we’ve provided but submissions in your own words are always better. 


  • There needs to be clear differentiation in the Emissions Reductions Plan between short and long-lived greenhouse gases, in line with the Climate Change Response Act and the recommendations made by the Climate Change Commission. (More on this below).
  • The Government needs to work with our sector and the forestry sector to find ways to limit carbon forestry offsetting while ensuring productive landscape usage, and aid native forestry and permanent sink establishment. (More on this below)
  • The Government’s ongoing support for the He Waka Eke Noa partnership, which is developing an alternative pricing (and reward) mechanism to the ETS for agricultural emissions and removals, is essential.
  • The best way to get action of the ground is to work with the farming communities to co-design policies and activities that are owned by the community and support farmers to change.
  • Continued support for research and development is essential. For the agriculture sector this would support much needed technologies and tools that further enable emissions reductions on farm without negatively impacting farm productivity.
  • As farmers and people who work with the land, climate change is an important aspect of our farming businesses and our sector wants to be a key partner in New Zealand’s just transition to a lower emissions economy.

Reporting on the warming impact of the different gases 

  • The global target is to reduce warming – that is, to limit the global rise in temperature to 1.5°C above pre-industrial levels – therefore policies should focus on warming, not just emissions.
  • The Emissions Reduction Plan must separate out the goal of reducing carbon emissions in line with meeting the net zero emissions in 2050 from the goal of managing short-lived gases like methane. 
  • The Government’s emissions reduction plan should also clearly lay out what the warming impact will be of the various sector/gas targets under their proposed budgets, rather than just the emissions.
  • This will build greater public understanding of the climate impact of the various gases and also build understanding of what is being asked of the sectors from a climate warming perspective.  
  • Based on the recent IPCC report, it is clear the current methane reduction targets in the Zero Carbon Act that the Emissions Reduction Plan is seeking to achieve mean that agriculture is being asked to add no additional warming and even ‘cool’, while other gases are able to continue adding additional warming.  
  • The Emissions Reduction plan places high importance on the implementation of the He Waka Eke Noa framework. It is important the methane targets are more appropriate to avoid the potential overpricing of methane under this approach.   
  • Farmers need to be supported to measure and manage their greenhouse gas emissions. [We suggest you provide examples in your submission of how this could happen]

Restrictions needed on carbon forestry offsetting 

  • Although the consultation document acknowledges that forestry conversions are being driven at significant rates by the carbon price, there are no concrete plans for how carbon farming will be limited. 
  • The Climate Change Commission recommended to Government to develop a plan to ensure that carbon farming is curtailed and planted in line with our long-term targets.
  • Current planting rates are occurring at a much faster rate than planned or required and urgent policy actions must be taken to both limit the overall use of forestry offsets, when these are established, as well as manage the location of these forests. 
  • There needs to be limits on the use of forestry offsets through the Emissions Trading Scheme (ETS) as well as criteria established to determine the extent of these carbon forests to address the wholesale conversion of sheep and beef farms into forestry for carbon farming. [We suggest you provide examples of whole sheep and beef farm sales in your region into forestry and the impacts this may have had]
  • Limits on the wholesale conversion of farms for carbon farming also need to be addressed in Overseas Investment Office (OIO) rules. Current rules mean the only foreign investment access to New Zealand land is through use for forestry/carbon farming, which is further distorting the market.
  • [You could also suggest ways the Government could support new employment and enable employment transitions in rural communities affected by land-use change into forestry.
  • Instead of exotic carbon forests, the Climate Change Commission recommended a much higher rate of native plantings, which our sector supports. Farmers must be able to have the tools, knowledge, capital, and labour needed to establish trees within their farming systems.
  • There are a range of ways to incentivise and increase native planting and regeneration on farmland. [We suggest you provide some examples of what would work for you.
  • The Government needs to work with groups such as B+LNZ, and others, on developing policy options to address this issue.