Response 92113556

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Submitter details

1. Submitter name

Individual or organisation name (Required)
Dr Alice Miller

Section A: Options for unit settings

1. What do you think of each of the options presented for step 1?

What is your preferred option? Please explain your answer here.
Option 3.
I fully support anything that can be done to cap and reduce emissions as quickly as possible and lock these in.
It seems nonsensical that the sizeable emissions reductions achieved from an initiative such as electrifying the steel furnace could be cancelled out by other industries being allowed to pollute cheaply in return.

2. If option 3 for step 1 was proposed, what criteria could be used to identify eligible reductions and removals?

Please explain your answer here.
I think that eligible reductions and removals which are unanticipated at the time of the budget being set should include those incurred by firm closures and those which have been brought about by a significant government investment to produce that transition away from fossil fuels.

3. Do you agree with the calculation for step 2?

Please select one item
Radio button: Unticked Yes
Radio button: Ticked No
Radio button: Unticked I don't know
Please explain your answer here.
Agriculture emissions should be brought into the ETS.

In particular, the potency and short lived nature of methane means that this sector should be targeted and supported to reduce emissions as soon as possible. This should include a comprehensive system of government support for farmers to transition away from beef and dairy farming to those with lower climate, water and land use impact.

4. Do you agree with the calculation for step 3?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No
Radio button: Unticked I don't know

5. Do you agree with the calculation for step 4?

Please select one item
Radio button: Unticked Yes
Radio button: Unticked No
Radio button: Ticked I don't know
Please explain your answer here.
In general, I would support the Climate Change Commission as the independent expert body on these matters.

However, I struggle to understand why we are allocating any free units to highly polluting industries - I would have thought that for the ETS system to be most effective we should be asking anyone producing GHGe to pay for their NZU at auction.

6. Do you agree with the Commission’s surplus methodology and estimate?

Please select one item
Radio button: Unticked Yes
Radio button: Unticked No
Radio button: Ticked I don't know

7. What is your preferred option for step 5?

Please select one item
Radio button: Unticked Option 1
Radio button: Unticked Option 2
Radio button: Ticked Option 3

8. Do you think the sale of pre-1990 units have increased?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No
Please explain your answer here.
I do not have adequate knowledge to answer this, other than I support the views of Commission as expert advisors on these matters.

Section B: Options for price control settings

9. What is your preferred option for the price control corridor?

Please select one item
Radio button: Ticked Option 1
Radio button: Unticked Option 2

10. Do you consider a price corridor (ie, an auction floor price and a CCR), to be important?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No
Radio button: Unticked Unsure

11. What is your preferred option for the CCR volume?

Please select one item
Radio button: Ticked Option 1
Radio button: Unticked Option 2

Section C: Impacts of NZ ETS unit settings

12. Do you agree with our impact analysis?

Please select one item
Radio button: Unticked Yes
Radio button: Unticked No
Radio button: Ticked Unsure
Are there any further impacts that should be considered, which we have not captured in our analysis? Please write your answer here.
I think it is worth considering the impact of intentionally driving up ETS prices to reduce emissions more aggressively, alongside a per-person household allocation/rebate (as I understand has been done in other countries) which allows people to live sufficiently healthy lives to leave lower income households better off and disincentivises luxury lifestyles.

Or alternatively, a tradeable energy quota to fulfil the same goals of rapid equitable emissions reduction.

Section A: NZ ETS sector-specific regulatory updates and improvements

7. Do you support continuing to regularly review and, where needed, update the DEFs for liquid fossil fuels?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No
Radio button: Unticked I don't know

Provide general feedback

Any general feedback on the consultation

Add your comments, ideas, and feedback here
In general, I strongly support the independent advisory function of the Climate Commission. It is essential that their advice does not get ignored for political strategy/short term gain/vested interests - instead the government must show strong leadership in persuading the public/businesses of the reasons for taking strong climate mitigation measures based on science and policy research. The lives of my children depend on this.

I am doing everything possible in my life to reduce my household emissions and I want the government to step up and match this effort, which in turn will help other people reduce their emissions who may not be as well informed or have the capacity to undertake change independently. This MUST include bringing agriculture into the ETS. New Zealand needs to do its fair share as a rich country in the global community, and arguably, for international trade/diplomacy reasons, should also be setting an example to go further than other countries.

I strongly believe that the ETS alone will not drive adequate emissions reductions, especially if pricing is not high enough. For pricing to be high enough to be effective there needs to be a really strong focus on equity measures to support low income New Zealanders and small businesses. Alternatively, there needs to be a really good look at tradeable energy quotas as an alternative.