How to submit your thoughts on the Govt's emissions reduction plan (ERP2)

Cool-Safe's guide to making a submission on the Government's Emissions Reduction Plan (ERP2)

Why make a submission?

The government often ask for industry’s advice and feedback to policies, new rules, laws and plans that affect our sector and the climate. The ERP2 has major implications for our industry and it’s important that we’re involved in the decision-making process. The Trust for the Destruction of Synthetic Refrigerant (Cool-Safe) has prepared our own submission but many of you asked how you could get involved too so we’ve prepared some handy advice to help you submit your own.

2. How do I make a submission? What does it need to include?

The best part about this process is that you don’t have to be an expert. The Ministry for the Environment has prepared a document you can use if you like, however, we have found that submitting our own thoughts outside this format means we can include more about F-gases than is asked for in the consultation pack (and focus on what we know!).

It needs to include either your name or business name, address, phone number and email and whether or not you’re happy for the ministry to publish your submission on their website. If you have included any commercially sensitive information, make sure you ask for that section to be redacted (not made public).

It’s a good idea to read the summary document beforehand.

3. How do I submit it?

Once you have written your submission, you can email it to ERPconsultation@mfe.govt.nz . Once they receive it, they'll send you a confirmation email.

You need to submit this by 25 August 2024.

4. What should I say?

The body of your submission should include:

• Your concerns with the proposed plan

• What should be different in the plan

• Any relevant evidence to support your opinion. 

• Any personal context or experience that supports your perspective. You don’t need to be an expert, simply say what brings you to care for the best outcome in this situation.

5. ERP2- what we’ve said. You are welcome to use this

·  F-gases are not included in this plan- we think F-gases should be included due to the high global warming potential of refrigerants and the initiatives recommended in the first Emissions Reduction Plan (2022). The reason given by MfE was that the recommendations under the first Emissions Reduction Plan were sufficient. We do not agree. The Climate Change Commission provided further recommendations that we agree with (see below)

·  The industry has called for a regulated product stewardship scheme, until this has been implemented, this recommendation should remain in all plans

·  Like the above recommendation, appropriate training and recognition was highlighted by industry and the Climate Change Commission as a key driver to reduce emissions from our sector

·  Develop and support initiatives to incentivise industry to move to using low global warming potential (GWP) alternatives- i.e. help businesses who are ready to upgrade systems and need help with funds and advice

·  Import restrictions on pre-charged equipment with high-GWP F-gases

So now you’re ready to prepare your own submission- good luck and thank you for making your voice and that of the industry, heard.