Part 5: Public policies

5.1
The Government has an important role in implementing public policies that can address the effects of climate change.

5.2
In this Part, we summarise the results of our assessment of the public policies that New Zealand has to respond to climate change. The three categories in the public policies axis of the ClimateScanner methodology are:

• international commitments, which looks at countries' international commitments to emissions reduction, specifically the Nationally Determined Contribution;
• general strategies, which looks at what adaptation plans and mitigation strategies countries have to respond to climate change; and
• sectoral components, which looks at mitigation and adaptation policies for specific sectors.

International commitments

Nationally Determined Contribution

Criteria we assessed

Actualisation
Ambition
Targets per sector

5.3
We assessed whether the Nationally Determined Contribution has been updated in line with the requirements of the Paris Agreement (actualisation) and has more ambitious commitments for New Zealand than the previous Nationally Determined Contribution. We also looked at whether these commitments are broken down into sector-specific targets.

5.4
We also commented on the Nationally Determined Contribution in paragraphs 4.22-4.28, as part of our assessment of the long-term strategy.

5.5
We gave the first two criteria in this component ratings of "advanced implementation". We gave the third criterion – whether emissions reduction targets are broken down by sector – a rating of "intermediate implementation".

5.6
New Zealand submitted its first Nationally Determined Contribution to the United Nations Framework Convention on Climate Change in 2016. It set a target to reduce emissions to 30% below gross 2005 levels by 2030.

5.7
In November 2021, the Nationally Determined Contribution was updated in accordance with the requirement in the Paris Agreement to update it every five years.

5.8
The updated Nationally Determined Contribution sets a target for a 50% reduction of net emissions below gross 2005 levels by 2030. This is clearly a more ambitious target than the previous Nationally Determined Contribution. We did not assess whether this target or the extent of increased ambition is appropriate.

5.9
New Zealand's Nationally Determined Contribution does not include sector targets. The first Emissions Reduction Plan, which covers the period of the first emissions budget, includes domestic emissions reduction targets for the biggest contributing sectors. These sectors include those we selected to look at in more detail: agriculture, land transport, and energy (see paragraphs 5.33-5.64).

5.10
As noted in paragraph 4.24-4.28, the targets in the emissions budgets for 2022 to 2030 are not fully aligned with, or enough to meet, the Nationally Determined Contribution. This means that the sector targets in the Emissions Reduction Plan do not fully account for the Nationally Determined Contribution.

5.11
The Nationally Determined Contribution states that the Government plans to use international market mechanisms, co-operative approaches, and carbon markets to achieve the additional reductions needed, but this strategy currently lacks detail.

5.12
For these reasons, we gave the targets per sector criterion a rating of "intermediate implementation".

General strategies

Mitigation strategy

Criteria we assessed

Mapping
National strategy
Sectoral plans

5.13
We assessed whether the Government has identified the public policies that impact emissions (mapping) and whether there are national mitigation strategies and sector-specific plans that are consistent with these strategies.

5.14
As the ClimateScanner methodology requires, we only looked at whether there are clear policies, policy objectives, and sectoral plans. We did not assess whether those policies, objectives, and plans are appropriate. We also did not assess whether specific plans are adequate or on track to meet the relevant emissions reduction targets.

5.15
We gave all criteria in this component ratings of "advanced implementation". The Emissions Reduction Plans serve as both the national strategy for mitigation and the key planning document, and contain sector-specific plans for the main mitigation sectors.

5.16
As explained in paragraph 4.19, New Zealand's long-term strategy for reducing emissions is based on setting a series of emissions budgets, each with its own Emissions Reduction Plan. The Emissions Reduction Plan contains the main policies for reducing greenhouse gas emissions.

5.17
The first Emissions Reduction Plan was published in 2022. It has dedicated chapters for the transport, energy and industry, agriculture, waste, fluorinated gases, and forestry sectors. Each of these chapters sets out how the targets for each of these key sectors will be achieved.

5.18
After a change in Government in November 2023, a new strategy for responding to climate change was developed. The new strategy, published in July 2024, is structured around five "pillars" for responding to climate change.²⁹ It includes commitments to reduce net greenhouse gas emissions and biogenic methane.

5.19
The Government has also committed to meeting the targets in the first two emissions budgets. It has included them as one of nine key targets it has set for the public sector.³⁰

5.20
The Government released a discussion document on the second Emissions Reduction Plan in July 2024. The discussion document sets out the main policies that the Government is proposing to implement.

5.21
The discussion document proposes policies for the energy, transport, agriculture, forestry, non-forestry removals, and waste sectors, as well as sections on cross-sectoral policies about the Emissions Trading Scheme and funding.

5.22
Public consultation has now closed, and the second Emissions Reduction Plan is scheduled to be published by the end of 2024.³¹

5.23
Based on this, New Zealand's mitigation strategy meets the criteria for "advanced implementation". However, in our view, there is a lack of clarity about whether the first Emissions Reduction Plan is still up to date.

5.24
Although the first Emissions Reduction Plan remains current until the end of 2025 (which is the end of the first emissions budget period), many of the actions it originally contained have been discontinued. This means that it might not be an accurate reflection of the Government's mitigation policies for the first emissions budget period.

5.25
The Government has now indicated that it intends to amend the first Emissions Reduction Plan. The second Emissions Reduction Plan's discussion document includes a section consulting on amendments that the Government is proposing to make to the first Emissions Reduction Plan. These amendments are based on the key climate change policy initiatives that the Government has announced.

National adaptation plans and strategies

Criteria we assessed

Existence of national adaptation plan
Coverage
Up-to-date plans and strategies

5.26
We looked at whether a National Adaptation Plan that identifies the main adaptation sectors has been prepared or updated in the last five years.

5.27
As specified by the ClimateScanner methodology, we only looked at whether there are policies, policy objectives, and sectoral plans and whether they are based on key risks. We did not assess whether those policies, objectives, and plans are appropriate or practicable for addressing the key climate change risks that have been identified.

5.28
We gave all criteria in this component ratings of "advanced implementation". The Climate Change Response Act 2002 requires that climate change risks be identified and that an adaptation plan to address those risks be prepared. This requirement has been met.

5.29
The first National Climate Change Risk Assessment was published in August 2020. It identified 43 priority risks across five domains: human, natural environment, economy, built environment, and governance. The National Climate Change Risk Assessment categorises the 10 most significant risks as being the two risks from each domain with the highest adaptation urgency rating. Figure 5 sets out the top 10 risks.

Figure 5
The top 10 risks from climate change in 2020-26

Risk		Domain
	Risks to coastal ecosystems, including the intertidal zone, estuaries, dunes, coastal lakes and wetlands, due to ongoing sea-level rise and extreme weather events.	Natural
	Risks to indigenous ecosystems and species from the enhanced spread, survival, and establishment of invasive species due to climate change.	Natural
	Risks to social cohesion and community well-being from displacement of individuals, families, and communities due to climate change impacts.*	Human
	Risks of exacerbating existing inequities and creating new and additional inequities due to differential distribution of climate change impacts.*	Human
	Risks to governments from economic costs associated with lost productivity, disaster relief expenditure, and unfunded contingent liabilities due to extreme events and ongoing gradual changes.	Economy
	Risks to the financial system from instability due to extreme weather events and ongoing gradual changes.	Economy
	Risks to potable water supplies (availability and quality) due to changes in rainfall, temperature, drought, extreme weather events, and ongoing sea-level rise.*	Built
	Risks to buildings due to extreme weather events, drought, increased fire weather, and ongoing sea-level rise.*	Built
	Risk of maladaptation across all domains due to the application of practices, processes, and tools that do not account for uncertainty and change over long time frames.	Governance
	Risks that climate change impacts across all domains will be exacerbated because current institutional arrangements are not fit for climate change adaptation.	Governance

* The risk has disproportionate impacts on Māori.

Source: Ministry for the Environment (2022), Aotearoa New Zealand's first national adaptation plan, page 37, at environment.govt.nz.

5.30
The first National Adaptation Plan was published in August 2022. It sets out actions for responding to those risks and addresses all of the top 10 risks. The National Adaptation Plan Table of Actions lists all the actions and the risks that each is intended to address.

5.31
The next National Adaptation Plan is not due until 2028, so the existing plan can be considered current.

5.32
In addition to the National Adaptation Plan, and as mentioned in paragraph 4.92, the Finance and Expenditure Committee recently completed an inquiry into climate change adaptation. The purpose of the inquiry was:

... to develop and recommend high-level objectives and principles for the design of a climate change adaptation model for New Zealand, to support the development of policy and legislation to address climate adaptation.³²

Sectoral components – Mitigation

5.33
This component assesses elements of mitigation policies in sectors with the highest emissions. For each selected sector, we considered whether there are national policies that consider emissions reductions (policy design) and whether those policies are translated into specific actions.

5.34
We assessed whether government organisations have identified the challenges they could face in implementing those actions. We also assessed whether there are appropriate mechanisms to monitor and evaluate progress towards achieving the emissions reduction outcomes for each sector.

5.35
We looked at the agriculture, energy, and land transport sectors. Agriculture is the source of more than 50% of total emissions in New Zealand (53% in 2022). The next highest-emitting sector is energy, which contributes 37% of total emissions (including 17.5% from the transport sector in 2022). For transport, we focused on land transport because it is responsible for more than 90% of transport emissions.

5.36
We gave the criteria in this component and each sector a mix of ratings. Policies in agriculture and land transport are at a more advanced stage than policies in the energy sector. We rated the actions in the energy sector lower than the other sectors because, at the time of our assessment, there was less detail available about them.

Mitigation in the agriculture sector

Criteria we assessed

Climate policy design
Specific actions
Implementation challenges
Monitoring and evaluation mechanisms

5.37
We gave agriculture an intermediate rating for three criteria in this component: climate policy design, specific actions, and implementation challenges.

5.38
The Climate Change Response Act 2002 includes quantified medium- and long-term targets for reducing emissions of biogenic methane. The Government has announced a review of methane science and targets. However, there is limited information about this work because it is at an early stage.

5.39
Although agriculture is the largest source of New Zealand's greenhouse gas emissions, the Government has announced that it will pass legislation to remove agriculture from the Emissions Trading Scheme, which is New Zealand's main tool for reducing emissions.

5.40
This means that the Government's main policy for reducing emissions from agriculture is to rely on tools and technology that will reduce emissions without reducing agricultural production or exports.

5.41
To support this approach, the Government is investing $400 million over four years in research, development, and commercialisation of tools for reducing agricultural emissions. The Ministry for Primary Industries has developed detailed objectives and targets for this work. There is also a related action to develop measurement of on-farm emissions by 2025.

5.42
We gave the climate policy design criterion an intermediate rating because, in our view, there are not yet clear links between these policies and actual emissions reduction. Research and development is an important phase, but until it results in effective, commercially available tools or products for reducing emissions, there is uncertainty about whether it will actually reduce emissions by the amount required.

5.43
Additionally, being able to measure emissions is important, but it does not directly result in any emissions reductions.

5.44
At the same time, we understand that some potential products are in the later stages of development, and the Ministry for Primary Industries expects that four new products for reducing emissions will be available for farmers in the next three years.

5.45
We gave the specific actions criterion an intermediate rating because the Ministry for Primary Industries has detailed and up-to-date planning documents for these pieces of work. These documents include detailed targets and measures, as well as more detailed tasks and assigned roles and responsibilities. However, we only saw detailed information about risks for the action to develop measurement of on-farm emissions.

5.46
The technical annex to the second Emissions Reduction Plan's discussion document shows that, overall, these policies are provisionally estimated to decrease emissions by 0.1 Mt CO₂-e over the second emissions budget period (2026-30) and 5.5 Mt CO₂-e over the third emissions budget period (2031-35).

5.47
However, the Climate Change Commission found that the sector is at risk of not being on track to meet the second and third emissions budgets and the 2050 biogenic methane target. The Commission said that this is because there is not a confirmed emissions pricing system or alternative policy measures to incentivise agricultural emissions reduction.

5.48
We gave an "advanced" rating for the monitoring and evaluation criterion. Although it is too early to evaluate its implementation of the Government's key mitigation policies, the Ministry for Primary Industries has detailed plans for how this work will be monitored and evaluated.

Mitigation in the land transport sector

Criteria we assessed

Climate policy design
Specific actions
Implementation challenges
Monitoring and evaluation mechanisms

5.49
For land transport, we gave the climate policy design and monitoring and evaluation mechanisms criteria ratings of "advanced implementation". We gave the specific actions criterion a rating of "intermediate implementation" and the implementation challenges criterion a rating of "early implementation".

5.50
The Government published its Government Policy Statement on land transport in June 2024. The statement does not list climate change mitigation as a strategic priority.

5.51
However, the Government Policy Statement says that steps need to be taken to reduce transport emissions as part of achieving the overall emissions reduction budgets and the target of net zero emissions by 2050. The statement also says that the second Emissions Reduction Plan will include key transport policies aimed at meeting these targets.

5.52
The second Emissions Reduction Plan's discussion document lists four key proposed policies for land transport, but some of the actions from the first plan are also expected to continue.

5.53
In its 2024 Budget, the Government committed $257 million (or 3% of Vote Transport) to four initiatives aimed at reducing transport emissions for 2024/25.

5.54
More detailed information about individual actions can be found in the Ministry of Transport's Decarbonising Transport Action Plan. This plan includes all the transport actions from the first Emissions Reduction Plan, with specific targets for each of that plan's five focus areas.

5.55
Some of these actions also have their own strategies – for example, the Electric Vehicle Charging Strategy. These documents contain more information about what is involved for each action, but less detail about how each is being implemented. They also contain only very limited information about the implementation challenges or risks for each action.

5.56
The Ministry of Transport's Transport Evidence Base Strategy includes an evaluation plan for the Ministry's key initiatives, including those related to emissions reduction. We have also seen examples of completed evaluations and monitoring reports.

5.57
The technical annex to the second Emissions Reduction Plan's discussion document shows provisional estimates for the decrease in emissions in the second and third emissions budget periods from enabling a network of 10,000 electric vehicle chargers and from better public transport.

5.58
In its first annual monitoring report on emissions reduction, the Climate Change Commission reported moderate to significant risk that the transport sector will fall short of its expected contribution to meeting the second and third emissions budgets.

Mitigation in the energy sector

Criteria we assessed

Climate policy design
Specific actions
Implementation challenges
Monitoring and evaluation mechanisms

5.59
We gave the energy sector a rating of "intermediate implementation" for the first criterion in this component and a rating of "early implementation" for the other three criteria.

5.60
The Government has committed to doubling renewable energy by 2050. One of the Government's key policies to achieve this is its Electrify New Zealand plan, announced in August 2024. Electrify New Zealand intends to make it easier to invest in the infrastructure needed for electrification by removing barriers. For example, the Government intends to introduce a fast-track consenting process for major renewable energy and transmission projects.

5.61
Electrify New Zealand is still at an early stage of development. The discussion document for the second Emissions Reduction Plan shows the projected emissions reductions impact from Electrify New Zealand on the second and third emissions budgets. However, it is not entirely clear how those reductions will be achieved.

5.62
Another key policy that is projected to have a significant impact on emissions reduction is enabling a regime for carbon capture utilisation and storage. This policy is also at an early stage. The Government recently undertook public consultation on this proposed policy.

5.63
In addition to these two key policies, there is a range of both ongoing and proposed new policies for reducing energy emissions. However, we have not seen clear objectives for reducing emissions from these policies or details about their implementation. We also note that some policies from the first Emissions Reduction Plan have been discontinued. We have not seen any monitoring or evaluation plans or reports for current energy policies.

5.64
Although some key specific actions are at an early stage of development, the Climate Change Commission found that energy emissions pose moderate to low risk to the second and third emissions budgets.

Sectoral components – Adaptation

5.65
This component assesses policies in two important adaptation sectors. For each sector, we considered whether New Zealand has policies that address the main adaptation risks, whether these policies have been translated into specific actions, whether implementation challenges have been identified, and whether there are appropriate monitoring and evaluation mechanisms.

5.66
We selected the land and ocean ecosystems and the disaster risk management sectors. These sectors relate to two of the top 10 most significant climate change risks New Zealand faces.³³

5.67
The National Adaptation Plan sets out adaptation policies. The plan is organised into four priorities and five outcome areas, and policies and actions address the key risks for each of these.

5.68
The National Adaptation Plan includes actions to address the main adaptation risks for the land and ocean ecosystems and disaster risk management sectors. Therefore, we gave the climate policy design criterion a rating of "advanced implementation" for both sectors. However, we consider that, overall, New Zealand has more work to do.

5.69
When we looked at a sample of those actions in more depth, we found that the level of detail varied. For land and ocean ecosystems, we gave the specific actions criterion a rating of "intermediate implementation". For disaster risk management, we gave the specific actions criterion a rating of "early implementation". We explain these ratings in more detail in paragraphs 5.77-5.94.

5.70
The Finance and Expenditure Committee's adaptation inquiry (see paragraph 5.32) is expected to help address some of the gaps in the current National Adaptation Plan.

5.71
We did not find evidence that government organisations have identified implementation challenges for any of the policies or actions that we looked at for either land and ocean ecosystems or disaster risk management. Therefore, we gave the implementation challenges criterion a rating of "no implementation" for both sectors.

5.72
The Climate Change Commission and the Climate Change Chief Executives Board both have a responsibility to monitor and report on the progress of the National Adaptation Plan.

5.73
The Climate Change Chief Executives Board's reports to Climate Ministers include progress on the implementation of the high-level actions in the National Adaptation Plan. The report for March 2024 states that there is not currently a complete set of formal indicators to measure the overall sufficiency of the adaptation response.

5.74
The Climate Change Commission published its first monitoring report on the National Adaptation Plan in August 2024. The lack of detail about specific actions that we found is consistent with some of the Commission's findings. These include that:

• clearer links are needed between climate change risks and impacts, the long-term adaptation strategy, and actions in the plan; and
• future plans could have more precise and outcomes-focused goals and objectives, including specific measurable outcome targets and milestones.

5.75
Although the Climate Change Chief Executives Board and the Climate Change Commission monitor progress on implementing the National Adaptation Plan, this monitoring is limited. We have not seen any evidence of, or plans for, evaluation of the activities included in the Plan.

5.76
Therefore, we have given the monitoring and evaluation mechanisms criterion a rating of "early implementation" for the land and ocean ecosystems and the disaster risk management sectors.

Adaptation in the land and ocean ecosystems sector

Criteria we assessed

Climate policy design
Specific actions
Implementation challenges
Monitoring and evaluation mechanisms

5.77
The National Adaptation Plan has a chapter on the natural environment. We have based our assessment of adaptation in the land and ocean ecosystems sector on this chapter.

5.78
The chapter sets out high-level actions designed to address the 12 risks to land and ocean ecosystems identified in the National Climate Change Risk Assessment. Many of these actions relate to the implementation of strategies, policies, or initiatives.

5.79
We selected three high-level actions to consider in more detail. The three we selected are critical actions, and a different public organisation leads each one. We looked at whether specific activities have been identified for the high-level actions and whether there are any monitoring and reporting mechanisms in place for them in the National Adaptation Plan.

5.80
The three high-level actions we looked at were to implement:

• the Department of Conservation Climate Change Adaptation Action Plan (led by the Department of Conservation);
• the Water Availability and Security programme (led by the Ministry for Primary Industries); and
• the National Policy Statement on Freshwater Management 2020 (led by the Ministry for the Environment).

5.81
The detail available for these three actions varied. For example, the Department of Conservation Climate Change Adaptation Action Plan has detailed tables of specific activities, with assigned responsibilities and time frames. We understand that some progress has been made on the plan, such as completing a drought risk assessment for key species and infrastructure.

5.82
However, in its March 2024 progress report, the Climate Change Chief Executives Board expressed low confidence in delivery of the plan. The Climate Change Commission said in its first monitoring report on the National Adaptation Plan that progress on implementing the Department of Conservation's plan has been slow because of funding and resource constraints.

5.83
We found less information about the other two actions.

5.84
The Ministry for Primary Industries has completed the first phase of its Water Availability and Security programme. In this phase, the Ministry gathered information about water supply and demand. The Ministry completed this work in 2022. It is currently considering the next phase, which will include more research, creating partnerships, and finding ways to help reduce risks.

5.85
The Climate Change Commission's first monitoring report on the National Adaptation Plan said that, even though this action does not have clear milestones and dates, the Climate Change Chief Executives Board has expressed a high level of confidence in its delivery.

5.86
The National Policy Statement on Freshwater Management 2020 required regional councils to notify their updated regional freshwater plans by the end of 2024. We understand that, after the change in Government, this action has been delayed until the end of 2027 to allow the Government time to replace the National Policy Statement.

5.87
Despite this, the Climate Change Chief Executives Board's regular reporting has expressed a high confidence of delivery for the National Policy Statement.

Adaptation in the disaster risk management sector

Criteria we assessed

Climate policy design
Specific actions
Implementation challenges
Monitoring and evaluation mechanisms

5.88
For the purposes of this assessment, we defined "disaster" as an emergency, in keeping with the definition in the Civil Defence Emergency Management Act 2002. However, we limited the definition to an emergency caused by risks that have been exacerbated by climate change.³⁴

5.89
Both the National Climate Change Risk Assessment and New Zealand's National Risk Register identify risks from natural disasters that are related to climate change. Although the National Adaptation Plan does not have a dedicated chapter on emergency or disaster risk management, actions related to the impacts of severe weather events are included throughout the Plan.

5.90
One key action in the National Adaptation Plan is to implement the National Disaster Resilience Strategy. This strategy aligns with the overall goals in the National Adaptation Plan in terms of managing risks and promoting resilience. However, apart from the National Emergency Management Agency's website referring to developing a roadmap, there is little detail about how the strategy is to be implemented.

5.91
The Climate Change Commission's first monitoring report on the National Adaptation Plan said that there is uncertainty about how the strategy is progressing. It also said that it is subject to funding and resource constraints.

5.92
Other actions in the National Adaptation Plan are to modernise the emergency management system and to develop the emergency management workforce. The Climate Change Commission's first monitoring report on the National Adaptation Plan said that the Climate Change Chief Executives Board has expressed low confidence that the modernisation of the emergency management system will be delivered.

5.93
We understand that some progress has been made on this and that an Emergency Management Bill was prepared. However, the Government decided to discharge this with the intent of introducing an amended Bill in 2025.

5.94
The National Emergency Management Agency has also reported that, in 2023/24, 543 people from 46 public and private organisations, volunteer groups, and universities participated in Coordinated Incident Management System courses delivered by the Agency and that 20 people were trained in how to deliver the training.

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29: The five pillars are that infrastructure is resilient and communities are well prepared, that credible markets support the climate transition, that clean energy is abundant and affordable, that world-leading climate innovation boosts the economy, and that nature-based solutions address climate change. See Ministry for the Environment (2024), Responding to a changing climate – The Government's climate strategy, at environment.govt.nz

30: Department of the Prime Minister and Cabinet (2024), Factsheet: Target 9 – Reduced net greenhouse gas emissions, at dpmc.govt.nz.

31: The Climate Change Response Act 2002 has a specific requirement that an Emissions Reduction Plan be prepared for each emissions budget period. It also requires that the plan be published at least 12 months before the start of that budget period. The second emissions budget is for 2026 to 2030.

32: Finance and Expenditure Committee (2024), Final report: Inquiry into climate adaptation, at selectcommittees.parliament.nz

33: Ministry for the Environment (2020), National Climate Change Risk Assessment for New Zealand: Main report, page 9, at environment.govt.nz.

34: The Civil Defence Emergency Management Act defines an emergency as a situation that causes or may cause loss of life, injury, illness, or distress, or in any way endangers the safety of the public or property and cannot be dealt with by emergency services or otherwise requires a significant and co-ordinated response under the Act.