Part 4: Governance

4.1
In this Part, we summarise the results of our assessment of New Zealand's governance arrangements for responding to climate change. The four categories in the governance axis of the ClimateScanner methodology are:

• institutionalisation, which looks at what legislative and regulatory framework countries have to address climate change and what entities are involved;
• strategy, which looks at what long-term strategies and risk management arrangements countries have;
• co-ordination, which looks at how public organisations work together and how they engage with non-government groups; and
• accountability, which looks at what mechanisms countries have to ensure that governments are accountable for their responses to climate change.

Institutionalisation

Legislative and regulatory framework

Criteria we assessed

Existence of legislation framework
Consistency with Paris Agreement
Mainstreaming

4.2
We looked at whether New Zealand has a legislative and regulatory framework that addresses climate change and whether that framework is consistent with the Paris Agreement. We also wanted to know whether the framework requires climate change to be "mainstreamed" – that is, considered in national plans and policies.

4.3
We gave all criteria in this component ratings of "advanced implementation". There is a comprehensive legislative framework to address climate change. The Climate Change Response Act 2002 is the main piece of legislation. There are also several pieces of secondary legislation.¹⁷

4.4
There is consistency with the Paris Agreement. One of the purposes set out in the Act is to contribute "to the global effort under the Paris Agreement to limit the global average temperature increase to 1.5° Celsius above pre-industrial levels". A separate schedule of the Act reproduces the entire Paris Agreement.

4.5
The Act explicitly provides for mainstreaming climate change response actions into national planning instruments and sectoral plans. In particular, the Act requires the Government to prepare:

• emissions budgets;
• an Emissions Reduction Plan, which must include a multi-sector strategy to meet emissions budgets and sector-specific policies to "reduce emissions and increase removals";
• a National Climate Change Risk Assessment; and
• a National Adaptation Plan in response to the risk assessment. The adaptation plan must include strategies, policies, and proposals for meeting the Government's objectives for adapting to the effects of climate change.

4.6
As well as the legislative requirements, there is a Cabinet requirement that central government agencies must estimate and disclose the greenhouse gas emissions implications when:

• decreasing greenhouse gas emissions is a key policy objective; or
• the direct impact on emissions is likely to be equal to or above:
  • - 0.5 Mt CO₂-e within the first 10 years; or
  • - 3 Mt of CO₂-e within the first 30 years.¹⁸

4.7
The Cabinet requirement applies to individual policies and initiatives, but is also applied to the whole Government Budget each year so that the Government can understand the climate implications of its Budgets.

Government structure

Criteria we assessed

Existence of national government structure
Responsibilities defined
No gaps or overlaps
Leadership

4.8
We looked at whether there is a government structure to address climate change and whether the public organisations involved in addressing climate change have clear roles and responsibilities.

4.9
We gave three of the four criteria in this component ratings of "advanced implementation". The Government has assigned organisations responsibilities for climate change activities. This includes leading, co-ordinating, implementing, and monitoring climate actions and ensuring that these activities are transparent to the public.

4.10
The main organisations are the Ministry for the Environment (which is the Government's main adviser on climate change), the Climate Change Commission, and the Climate Change Chief Executives Board. These three entities have clear roles and responsibilities that are set out in legislation, Cabinet decisions, and the Budget process.

4.11
We did not identify any substantial gaps or overlaps in the main entities' roles and responsibilities. Although the Climate Change Commission and the Climate Change Chief Executives Board both have monitoring and reporting responsibilities, the Commission is an independent Crown entity designed to assist in ensuring that there is appropriate transparency and accountability for the Government. In our view, both organisations play important and distinct roles.

4.12
The Climate Change Chief Executives Board is an interdepartmental executive board. Interdepartmental executive boards are set up to "align and co-ordinate strategic policy, planning, and budgeting activities for two or more departments with responsibilities in a subject matter area. This helps support those departments to deliver on relevant cross-departmental initiatives."¹⁹

4.13
The Climate Change Chief Executives Board has a leadership role and operates at the chief executive level. It also has working groups at the deputy chief executive and operational (director/manager) levels.

4.14
The members of the Climate Change Chief Executives Board are the chief executives of the main government departments with significant roles in mitigating and/or adapting to climate change (see paragraph 3.16). Although each chief executive can mobilise their own department, the Board does not have the ability to mobilise any other government bodies.

4.15
Under the ClimateScanner framework, this ability needs to be in place for a rating of "advanced implementation". Therefore, we gave the leadership criterion a rating of "intermediate implementation".

Strategy

Long-term strategy

Criteria we assessed

Long-term strategy
Alignment to Nationally Determined Contribution
Interlinkages with Sustainable Development Goals (SDGs)

4.16
We assessed whether New Zealand has a long-term strategy to address climate change. We also assessed whether the strategy aligns with the Nationally Determined Contribution and whether it references the Sustainable Development Goals.

4.17
The Government submitted its long-term strategy to the United Nations Framework Convention on Climate Change in November 2021.²⁰ The strategy sets out how New Zealand plans to use a series of emissions budgets and Emissions Reduction Plans to meet its long-term emissions reduction targets.

4.18
The strategy includes a series of high-level sector plans. It references the updated Nationally Determined Contribution and explains that this will be met through a combination of domestic and international mitigation actions.

4.19
The ClimateScanner methodology states that registering a long-term strategy with the United Nations Framework Convention on Climate Change is considered "advanced implementation". It does not require any assessment of that strategy.

4.20
However, the strategy has not been updated since 2021, and we have not seen any evidence of plans to update it. We are aware that some parts of this strategy, such as the sector plans, might now be out of date. Therefore, we gave the long-term strategy criterion a rating of "intermediate implementation".

4.21
We also gave the alignment to the Nationally Determined Contribution criterion a rating of "intermediate implementation". Although the strategy aligns with the Nationally Determined Contribution to some extent, there are also gaps.

4.22
New Zealand's Nationally Determined Contribution is an international commitment to reduce emissions. New Zealand also has domestic commitments, including long-term emissions reduction targets set in the Act and intermediate targets set through the emissions budgets. Each emissions budget covers five years.²¹

4.23
Figure 4 shows that the Nationally Determined Contribution, the Act, and the emissions budgets express emissions reduction targets differently and cover different time periods. For example, the emissions budgets set a maximum quantity of total emissions, but the other commitments set a target for the percentage that emissions will be reduced by.

4.24
The Nationally Determined Contribution target is also more ambitious than the domestic targets. However, the Nationally Determined Contribution target can be met through a mix of domestic and international mitigation actions, while the domestic targets must be met as much as possible through domestic actions.

Figure 4
New Zealand's international and domestic emissions reduction commitments

Commitment	Target	Time period
International targets under the Nationally Determined Contribution	To reduce net greenhouse gas emissions to 50% below gross 2005 levels by 2030. Based on New Zealand's most recent greenhouse gas inventory, this budget provisionally equates to 571 Mt CO2-e over 2021-2030.	2021-30
Domestic targets under the Climate Change Response Act 2002	Reduce net emissions of all greenhouse gases (except biogenic methane) to zero by 2050. Reduce emissions of biogenic methane to: 24%-47% below 2017 levels by 2050; and to 10% below 2017 levels by 2030.	2019-30 2019-50
Domestic interim targets under the emissions budgets	Budget 1: Total emissions of 290 Mt CO2-e Budget 2: Total emissions of 305 Mt CO2-e Budget 3: Total emissions of 240 Mt CO2-e	Budget 1 (2022-25) Budget 2 (2026-30) Budget 3 (2031-35)

4.25
In its July 2024 discussion document for the second Emissions Reduction Plan, the Government acknowledged that meeting the more ambitious emissions reduction target in the Nationally Determined Contribution will be a challenge.

4.26
The current Nationally Determined Contribution states that, to meet its targets, New Zealand intends to use international market mechanisms, co-operative approaches, and carbon markets as well as domestic emissions reductions. However, we have not seen a clear strategy for how this will be achieved.

4.27
The second Emissions Reduction Plan's discussion document says that the Government is still considering how it will address this challenge.

4.28
Climate action is one of the Sustainable Development Goals, and there are strong links between the success of the 2030 Agenda and international climate agreements (such as the Paris Agreement and the United Nations Framework Convention on Climate Change).

4.29
The third criterion in this component looks at how the Government's long-term strategy aligns with the Sustainable Development Goals.

4.30
The ClimateScanner methodology requires us to assess whether the long-term strategy specifically refers to the Sustainable Development Goals. If it does not, a rating of "no implementation" applies.

4.31
The previous Government stated that it intended to progress the Sustainable Development Goals "through a combination of domestic action, international leadership on global issues and support for developing countries".²²

4.32
We are aware that the previous Government's strategies and plans for responding to climate change aligned with the Sustainable Development Goals to some extent. For example, the previous Government stated that the 2019 amendment to the Act, which provided a framework for reducing emissions by 2050 and established the Climate Change Commission to monitor progress towards it, was in support of achieving Sustainable Development Goal 13.²³

4.33
We are also aware that climate change actions might also contribute to other Sustainable Development Goals. For example, the Climate Change Commission has found that reducing transport fuel use would improve air quality, saving New Zealand $2.7 billion a year on average in health costs.²⁴

4.34
However, we found no specific references to the Sustainable Development Goals in the long-term strategy, the first Emissions Reduction Plan, or the second Emissions Reduction Plan's discussion document. Therefore, this does not meet the requirements for a rating higher than "no implementation".

Risk management

Criteria we assessed

Risk mapping
Interface with science
Climate risks in planning instruments

4.35
We looked at whether New Zealand has prepared or updated an assessment of climate change risks in the last five years. We also looked at whether the risks identified in the assessment are based on the best available science and whether they have been incorporated into long- and medium-term plans.

4.36
We gave all criteria in this component ratings of "advanced implementation". The Act requires an assessment of the risks to New Zealand from the current and future effects of climate change.

4.37
The first National Climate Change Risk Assessment was published in 2020. The risk assessment gives a national picture of how New Zealand might be affected by hazards related to climate change.

4.38
The Act also requires that a National Adaptation Plan be prepared in response to each National Climate Change Risk Assessment. The first National Adaptation Plan was published in August 2022.

4.39
The risk assessment was prepared by a multidisciplinary team of academics and consultants. These were experts in governance, the economy, the human domain (which covers people's skills, knowledge, and physical and mental health; the norms, rules, and institutions of society; and the knowledge, heritage, beliefs, arts, morals, laws, and customs of society), the built environment, and the natural environment. There was also an extensive team of technical advisors and reviewers.

4.40
A technical report published with the risk assessment cites nearly 30 pages of references that were used to complete the risk assessment. These references include a range of scientific, economic, and social evidence.

Co-ordination

Horizontal and vertical co-ordination

Criteria we assessed

Horizontal co-ordination mechanisms
Dynamic of horizontal interaction
Vertical co-ordination mechanisms
Dynamic of vertical interaction

4.41
We looked at whether there are mechanisms that enable organisations to work together in a co-ordinated way to address climate change, both between central government organisations (horizontally) and with local government (vertically).

4.42
We also looked at whether mechanisms are dynamic – that is, whether central government and local government organisations have adequate opportunities to regularly and consistently discuss climate action.

4.43
We gave the horizontal co-ordination mechanisms and dynamic of horizontal interaction criteria ratings of "advanced implementation".

4.44
The Climate Change Chief Executives Board is the main mechanism that allows central government organisations to work together. In its statement of intent, the Board says that one of its functions is to co-ordinate the implementation of cross-agency actions and strategies in the Emissions Reduction Plan and National Adaptation Plan.

4.45
At the Ministerial level, there is a Climate Priorities Ministerial Group, which consists of senior Ministers and is chaired by the Minister of Climate Change. Although the Minister of Climate Change has statutory responsibility for meeting climate change goals, this responsibility is held on behalf of the Government. Many actions that affect this responsibility are in different Ministerial portfolios. Therefore, the Climate Priorities Ministerial Group provides accountability for cross-agency and individual agencies' responses to climate change.

4.46
Both the Climate Change Chief Executives Board and the Climate Priorities Ministerial Group meet regularly. The Board has various interagency sub-groups that represent different levels of officials, and these sub-groups also meet regularly.

4.47
Although horizontal co-ordination is strong, New Zealand lacks formal structures for vertical co-ordination on matters related to climate change. We gave the vertical co-ordination mechanisms and dynamic of vertical interaction criteria ratings of "early implementation".

4.48
Local authorities have statutory responsibilities to avoid or mitigate natural hazards. They must have regard to the effects of climate change when making certain decisions. They are also responsible for civil defence and emergency management, and for improving community resilience through education and local planning.

4.49
The National Adaptation Plan has measures to support local authorities to take action and adapt to climate change.²⁵ However, the Climate Change Commission's monitoring report on the National Adaptation Plan recommends that the regime for local adaptation planning be strengthened. This includes creating a legislative framework that mandates local government action on adaptation.

4.50
The Commission's monitoring report also noted a lack of clarity in roles and responsibilities for adaptation planning and implementation between central and local government.

4.51
That said, local government actively engages with central government on climate change mitigation and adaptation through its membership institutions Local Government New Zealand (representing elected members) and Taituarā – Local Government Professionals Aotearoa.

4.52
The local government sector is actively involved with central government in law reform processes and implementation, such as the previous Government's work on the Resource Management Act and three waters reforms. More recently, a local government emissions reduction advisory group supported central government's consideration of the second Emissions Reduction Plan.

4.53
However, we are not aware of any formal institutional mechanism for central and local government to co-ordinate on climate action (such as a law, regulation, or agreement for joint policy formulation or implementation), which is what this criterion requires.

Stakeholder engagement

Criteria we assessed

Existence of participation mechanisms
Representativeness
Dynamic of interaction

4.54
We looked at whether there are mechanisms that allow a representative range of stakeholders to participate in the design and implementation of climate change policies, strategies, and plans. We also looked at whether this participation mechanism is "dynamic" – that is, whether it allows for regular and consistent engagement.

4.55
We did not look at how effective those mechanisms are or how policies and plans might have been adjusted in response to stakeholders' participation.

4.56
We gave all three criteria in this component ratings of "advanced implementation". The Act requires the Government to carry out adequate consultation when it prepares an Emissions Reduction Plan. This includes consulting with sector representatives, affected communities, and iwi and Māori.

4.57
For the first Emissions Reduction Plan, the Government consulted with a range of groups that included iwi, hapū, Māori, Pacific peoples, business and industry, local government, non-government organisations, and youth.

4.58
For the second Emissions Reduction Plan, the Government consulted with the Climate Business Advisory Group, the Local Government Emissions Reduction Advisory Group, and the Climate Youth Advisory Group. The Government also publicly consulted on the second Emissions Reduction Plan's discussion document during July and August 2024.

4.59
The Act requires the responsible Minister to carry out public consultation on its draft National Adaptation Plan. As part of the consultation on the first National Adaptation Plan, the Government also consulted on the system for managed retreat and emerging issues relating to home insurance for flood risk.

4.60
The Government published a summary of the submissions it received for the first Emissions Reduction Plan and the first National Adaptation Plan. Consultation on the first Emissions Reduction Plan received more than 10,000 submissions, and consultation on the first National Adaptation Plan received 294 submissions.

4.61
We have not assessed how the Government used these submissions in developing its policies.

Accountability

Inclusiveness

Criteria we assessed

Identification of vulnerable groups
Inclusion in decision-making process
Equitable policies

4.62
We looked at whether the Government has identified the communities most vulnerable to the effects of climate change and whether it includes them in the development of climate change policies, strategies, and plans. We also looked at whether equity has been considered in the development of climate change policies, strategies, and plans.

4.63
We gave all criteria in this component ratings of "advanced implementation". The Act requires the Government to:

• when preparing a National Climate Change Risk Assessment and a National Adaptation Plan, take into account the:
  • economic, social, health, environmental, ecological, and cultural effects of climate change, including effects on iwi and Māori; and
  • the distribution of the effects of climate change throughout society, taking particular account of vulnerable groups or sectors; and
• include in any Emissions Reduction Plan a strategy to mitigate the impacts that reducing emissions and increasing removals will have on employees and employers, regions, iwi and Māori, and wider communities.

4.64
These requirements have been put into practice. For example, the first Emissions Reduction Plan has a chapter on empowering Māori. The first National Climate Change Risk Assessment identifies communities that are vulnerable to the effects of climate change, and the Ministry for the Environment includes information on its website about adaptation for specific groups, such as disabled people and rural communities. Many of the actions in the first National Adaptation Plan have a specific focus on Māori.

4.65
However, even though this component meets the criteria for a rating of "advanced implementation", the Parliamentary Commissioner for the Environment found that engagement with iwi and Māori could have been improved. For example, some of the tools used for consultation were not effective in reaching the communities that the proposed policies would most disproportionately impact.

Monitoring mechanisms

Criteria we assessed

Existence of mechanisms
Feedback for policy-making

4.66
We assessed whether there are monitoring mechanisms for tracking progress towards the targets in the Nationally Determined Contribution and the implementation of national laws, policies, and strategies related to climate change. We also looked at whether there is a mechanism that enables the information from climate change monitoring to inform policy-making.

4.67
We gave the first criterion in this component a rating of "advanced implementation" and the second criterion a rating of "intermediate implementation".

4.68
The Act requires the Climate Change Commission to monitor and report on progress. From 2024, the Commission will monitor and report annually on the Government's progress towards meeting the 2050 emissions reduction target, emissions budgets, and Emissions Reduction Plans.

4.69
The Climate Change Commission published its first monitoring report in July 2024. This report assesses the adequacy of the Government's Emissions Reduction Plan and the progress of its implementation, including any new opportunities to reduce emissions.

4.70
The Climate Change Commission must also report on progress at the end of each emissions budget period. The first of these reports is due in 2027.

4.71
The Climate Change Commission is also required to provide a two-yearly progress report on the implementation and effectiveness of each National Adaptation Plan. It published its first progress report in August 2024. The report assesses how well the plan is achieving its objectives and how well it responds to climate risks. It also identifies barriers to implementation and effectiveness, and how these might be overcome. The Act includes a requirement for Ministers to respond publicly to the Climate Change Commission's reports.

4.72
The Climate Change Chief Executives Board also carries out monitoring and reporting. The Board reports on the progress of the actions identified in the Emissions Reduction Plan and the National Adaptation Plan every six months. These reports are based on more detailed reporting from the relevant lead agency for each action.

4.73
The Climate Change Chief Executives Board is responsible for advising how organisations can respond to the results of monitoring and reporting. It also advises the Government on whether any changes in response might be needed.

4.74
Although these mechanisms are in place, the Climate Change Commission only published its first monitoring reports in July and August 2024. It is too early to assess how the Government will use the information in the monitoring reports. It is also too early to see how the Government will use the Climate Change Chief Executives Board's assessments and reporting to inform future policy-making.

Transparency

Criteria we assessed

Global transparency
Transparency at the national level
Publicly accessible reporting

4.75
We assessed whether the Government is reporting on its progress towards meeting climate change objectives internationally and domestically. We also looked at whether there is reporting that is transparent and accessible to the public.

4.76
We gave the first two criteria in this component ratings of "advanced implementation", and we gave the last criterion a rating of "intermediate implementation".

4.77
The Government is meeting the requirements to prepare, update, and submit National Communications and Biennial reports to the United Nations Framework Convention on Climate Change.

4.78
National Communications must be updated every four years, and Biennial reports must be updated every two years. The Government submitted the most recent National Communications and Biennial report in December 2022.

4.79
The Ministry for the Environment has a large amount of information on its website about what the Government is doing about climate change. This includes information on emissions reductions and adaptation.

4.80
For example, the Ministry's website provides information sheets explaining the National Adaptation Plan, relevant actions, and programmes of work to support adaptation actions affecting different groups, such as rural communities, disabled people, and younger New Zealanders.

4.81
The Ministry's website also includes information about progress made in reducing emissions through the Carbon Neutral Government Programme. This programme requires public organisations to report on their emissions, their reduction targets, and their plans to achieve those targets. The requirements are mandatory for some public organisations and encouraged for others. In December 2023, 84 public organisations reported this information.

4.82
Information on government progress towards achieving climate change objectives is also publicly available. This information includes meeting packs and advice from the Climate Change Chief Executives Board to Ministers and the Prime Minister.

4.83
The Climate Change Commission's monitoring reports (see paragraphs 4.68-4.71) are also available on its website. The public can also request information about the Government's response to climate change through the Official Information Act 1982.

4.84
Although a lot of information is available to the public about current progress towards emissions reduction targets, different sources present this information differently and the public may find the different sources hard to reconcile. In our view, this is information that the public would want to know.

4.85
The Government's factsheet for its target for reduced greenhouse gas emissions provides some key information about progress in a more understandable way, although some technical information is not explained.

4.86
The Government's discussion document for the second Emissions Reduction Plan is easily accessible online and presents information on how New Zealand is tracking its progress towards meeting the emissions budgets. However, this information has not been calculated on the same basis as the official emissions projections that were published in late 2023. This makes it difficult to understand how much progress has been made.

Oversight and climate litigation

Criteria we assessed

Parliament
Audit institutions
Climate litigation

4.87
We looked at whether Parliament has commissions or committees that focus on climate change issues. We considered our own climate change work programme in the last five years. We also looked at whether the New Zealand judiciary considers claims related to climate change issues.

4.88
We gave all criteria in this component ratings of "advanced implementation".

4.89
Parliament's Environment Committee looks at matters related to conservation, the environment, and climate change. The Committee specifically focuses on climate change issues.

4.90
The Environment Committee scrutinises the performance and finances of the Ministry for the Environment, the Climate Change Commission, and the Climate Change Chief Executives Board through annual reviews of their budgets. It also started an inquiry into climate adaptation in 2023.

4.91
The Finance and Expenditure Committee recently completed its own inquiry into climate change adaptation, including its financial aspects. The committee made several recommendations in its inquiry report that will inform the development of a policy framework for how New Zealand will adapt to climate change. The framework is intended to set out the Government's approach to sharing the costs of adaptation and provide more certainty for local communities about the adaptation activities happening in their areas. This inquiry also considered written submissions made to the Environment Committee's earlier inquiry.

4.92
Other select committees in Parliament also look at climate change issues. These include the Economic Development Committee, the Science and Innovation Committee, and the Transport and Infrastructure Committee.

4.93
Parliament's oversight of climate change matters is further strengthened by the Parliamentary Commissioner for the Environment. The Commissioner is an independent Officer of Parliament and has broad powers to investigate and report on environmental concerns, including concerns about climate change. The Commissioner reports directly to Parliament.

4.94
This component's second criterion asks whether the relevant national audit institution is currently conducting, or has conducted in the last five years, at least one audit with climate change issues as its main focus.

4.95
Our Office has recently completed a performance audit of how well councils are implementing climate change actions. This audit looks at how four councils are responding to climate change and how they have translated climate change strategies, commitments, and plans into action.

4.96
Our Office has also published a range of other reports, articles, blogs, and guidance on measuring and reporting on government actions responding to climate change.²⁶

4.97
Other types of audits of public organisations by our Office also consider information relating to climate change, including:

• audits of councils' long-term plans, which have to consider the physical impacts of climate risks (including the impact on infrastructure strategies) and transition risks;
• annual audits, where some public organisations have chosen to include performance information about greenhouse gas emissions in their annual report;
• the annual audit of the Financial Statements of Government, which considers whether the disclosures made about New Zealand's commitments under the Paris Agreement, including the Nationally Determined Contribution, are appropriate and meet financial reporting standards; and
• from 2025, the Climate Related Disclosures regime will introduce mandatory climate reporting for large banks, insurers, managers of investment schemes, and publicly listed entities. As at September 2024, there are 13 public organisations subject to this requirement. Reporting and auditing requirements have not been finalised but some auditing and assurance is intended.

4.98
Therefore, the requirements for a rating of "advanced implementation" have been met.

4.99
The New Zealand judiciary adjudicates claims related to climate change issues. Courts in New Zealand have considered several claims related to climate change, including against Ministers, public organisations, and corporate entities. Notably, New Zealand's highest court, the Supreme Court, recently held that a claim by a citizen against corporate entities in relation to their emissions should proceed to trial.²⁷

4.100
The Global climate litigation report cites 26 litigation cases in New Zealand as of December 2022 and discusses several of them.²⁸

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17: Some examples of secondary legislation include the Climate Change (Agriculture Sector) Regulations 2010, Climate Change (Auctions, Limits, and Price Controls for Units) Regulations 2020, and Climate Change (Eligible Industrial Activities) Regulations 2010.

18: The Government expresses its emissions reduction targets in megatonnes of carbon dioxide equivalent, written as Mt CO₂-e.

19: The Treasury, "Interdepartmental executive boards", at treasury.govt.nz.

20: Ministry for the Environment (2021), Transitioning to a low-emissions and climate-resilient future: Aotearoa New Zealand's long-term low-emissions development strategy, at environment.govt.nz.

21: The first emissions budget was for four years from 2022 to 2026.

22: Ministry of Foreign Affairs and Trade (2019), He waka eke noa – Towards a better future, together: New Zealand's progress towards the SDGs – 2019, page 6, at mfat.govt.nz.

23: Ministry of Foreign Affairs and Trade (2019), He waka eke noa – Towards a better future, together: New Zealand's progress towards the SDGs – 2019, page 91, at mfat.govt.nz.

24: Climate Change Commission (2024), Draft advice on Aotearoa New Zealand's fourth emissions budget, at climatecommission.govt.nz.

25: Ministry for the Environment (2022), Climate change and local government: What the national adaptation plan means for you, at environment.govt.nz.

26: For our work on climate change, see oag.parliament.nz/reports/climate-change.

27: Michael John Smith v Fonterra Co-operative Group Limited [2024] NZSC 5.

28: United Nations Environment Programme (2023), Global climate litigation report: 2023 status review, at unep.org.