Rushing Emission Plans

It looks like the Ministry for the Environment is running a rather hasty process in setting the Emissions Reduction Plan. 

This week's column over in Newsroom:

Submissions on the draft plan had closed four months ago, but none of the submissions were yet available on the relevant website. So I asked the Ministry for the Environment where I may find them.

The ministry’s response was rather worrying:

"Consultation on the draft Emissions Reduction Plan resulted in over 10,000 submissions being made, and our team is currently reviewing each of these submissions to incorporate what we have heard into the ERP as part of the ongoing policy work on this significant document.

"The ERP is due to be published in May, and we are aiming to publish a Submission Analysis Report shortly afterwards to capture the submissions we received. We will endeavour to give you a heads up when we have a confirmed date for the release of that report."

While the final plan will be published in May, the relevant decisions must be made well before that date.

That only a summary of submissions would be made available, and only after the plan had been published, suggested a very rushed process.

Compared with other legislation and regulation, the Emissions Reduction Plan has complexity and consequences where substantive submissions would add more value than is usually the case.

Submissions from affected sectors could reveal detail critical to any successful plan, self-interested special pleading, or a complicated mix of the two requiring judicious treatment. Hurried treatment of submissions would be a mistake.

On making inquiries around Wellington, we were told that sector-level decisions were close to being finalised or had already been finalised.

A good process would have submissions considered well before plan finalisation. But inquiries around Wellington suggested that plan finalisation had to run in parallel with analysis of submissions because of the tight timelines and the volume of submissions.

It makes for a risky process. If a submission providing critically important detail is not unearthed until much of the plan is finalised, it would be too late to fix things.