The nationally determined contribution, or NDC, is a country’s agreed target to reduce emissions under the United Nations’ Paris Agreement.

Every five years these NDCs are required to be updated, with each update intended to increase in ambition to limit warming.

The target for the 2030-2035 period needs to be delivered by early February, and many other countries have already announced their new targets, including Brazil, the United Arab Emirates, and the UK.

Government response

New Zealand’s current target for the 2021-2030 period is a 50% reduction of net emissions below gross 2005 levels, with a major proportion of that - nearly 100 million tonnes, about two-thirds of the total reduction - set to be through purchasing offshore climate mitigation.

While the government has said it would seek public feedback on the next NDC, Carbon News understands that the Ministry for the Environment is currently only undertaking “targeted consultation” through invitation-only meetings.

Climate change minister Simon Watts wouldn’t comment on whether this was the case, or who had been invited to participate so far.

In an email statement, Watts said he had asked the Climate Change Commission for advice on the level of domestic emissions reduction possible between 2031 and 2035, the NDC2 period. 

“This advice will be a key input for the Government’s final decision-making.”

That advice was made public last week.

While Watts said the government “intends to seek public feedback before the final NDC2 decision is made," he did not answer questions about whether all members of the public would be invited to submit and what time frame would be allowed.

A spokesperson for the Minister’s office said arrangements for the process going forward to set the NDC are still being finalised.

However the timeframe is now extremely tight to undertake public consultation, with the NDC due in early February and Parliament closing for the year on December 18, with Cabinet agreement needed on how much to promise to cut.

Getting Cabinet’s support might not be an easy task for Watts, with National’s coalition partners ACT campaigning on getting rid of the Zero Carbon Act and the Climate Change Commission, while New Zealand First is continuing to indulge in climate denying rhetoric, and won’t say whether it will support purchasing international climate mitigation, which is key to reaching New Zealand’s first NDC.

The government recently copped criticism for poor consultation over climate-related legislation amending the Crown Minerals Act, allowing only a few days for public submissions.

By contrast, the government under National and John Key consulted widely on the previous NDC target.

Lack of consultation 'concerning'

Jessica Palairet, executive director of Lawyers for Climate Action, says her organisation wrote to the minister on 2 September asking for clarification on whether and how the Government intends to consult on the NDC. “We did not receive any response.”

Palairet says it is concerning that consultation is only being undertaken on a targeted basis.

“Our next NDC is a major decision. Not widely and openly consulting with the public is out of step with past practice, and flies in the face of significant public interest in New Zealand's climate change commitments.”

For context, when the Government set the first intended nationally determined contribution, it carried out “substantial public consultation,” in 2015, Palairet says. “There was a high level of public interest in New Zealand’s NDC, with the Government receiving around 17,000 written submissions.”

In 2020, the Climate Change Commission was asked to provide advice on compatibility of the NDC with global efforts to limit temperature rise to 1.5C. They consulted on their advice as part of a broader consultation that received over 15,000 submissions.

Palairet also notes that minister Simon Watts asked the Climate Change Commission to provide advice on the level of domestic emissions reductions that New Zealand could feasibly achieve as part of NDC2.

“This was a change, as the Commission had previously been asked to provide advice on NDC2 as a whole in October 2023. The scope of the request was narrowed by Minister Watts in June 2024 following what appears to have been discussions about resourcing.

“The fact the Minister changed the advice sought from the Climate Change Commission doesn't preclude the Government from receiving advice from officials on the international component of NDC2. However, we would obviously have preferred the Commission to have been given enough resources to consider the appropriate NDC2 settings as a whole, to provide the Minister with a more complete picture.”

Palairet says that, regardless of the more limited nature of the advice requested by the minister, New Zealand is still obliged to set an NDC2 that is more ambitious than NDC1. “It is difficult to imagine how that could feasibly achieved without an international component, and so we would be surprised if there isn't an international component to NDC2.”

Troy Baisden, co-president of the New Zealand Association of Scientists, says it’s easy to be of two minds about what we’ll see around the next NDC - and whether more consultation is good.

“In terms of effective consultation, we're certainly in a worse position than I would have imagined a couple years ago, and even coming out of the election. Pressure will be on the Minister to make progress and maintain credibility.”

Recent consultation around the second emissions reduction plan wasn’t fit for purpose for public input, according to Baisden, and he said as much in his submission. “There were simply too many inconsistencies.”

Baisden says the benefits of experts and concerned parties from the public, NGOs and business engaging with so many consultations is questionable to begin with, “and worse when the quality of the draft documents out for consultation is simply not good enough.

“From the standpoint of integrating science and economics - when forestry, agriculture and the transition from fossil fuels to renewables all seem to be at inflection points - we need good and appropriate models that can be transparently summarised,” Baisden says.

“Currently those models are largely missing - the models we have can’t be connected together well enough to understand which way interconnected issues may head given policy choices.”

Baisden says that’s a result of underinvestment over the past decade, and leaving climate change mitigation entirely out of National Science Challenges. 

“Even if we start now, it will take a long time to recover to the point where New Zealand’s unique land and energy systems can be modelled in the same way that peer nations do when setting domestic targets, NDCs and supporting policies.

“Currently the Climate Change Commission has the most capacity, but they can’t do a great job modelling highly-nonlinear projections into the 2030s. Teams and institutions across the research systems should have been providing them tools to work with, but such an effort needs funding and capacity building.”

Baisden says consultation still must play a role - even if it is dissatisfying or imperfect. "Transparency and scrutiny are part of international expectations as well as the Zero Carbon Act provisions now embedded in our legislative frameworks."

He hopes consultation might create demand for the information needed to support and provide certainty “for policy, innovation and action”.

“The energy transition is worth trillions globally and we’re falling behind in chasing that. But we know abundant renewables will help us improve productivity and reduce debt and current account deficits. Consultation plays an essential role in helping government policy, research, and innovation work together toward the potential and make the most of what’s achievable.

“At the very least, poor or missed consultations will help international investors and supply chains call New Zealand’s bluff if its domestic targets and NDCs seem adrift or less than meaningful given the state of policies and evidence.”

Next week: How ambitious should New Zealand’s next NDC be?