In our submission to the Commerce Commission on its open letter "Ensuring our energy and airports regulation is fit for purpose" we urge the Commerce Commission to act consistently with our statutory emissions targets as they are worded in the legislation. Terms like “decarbonisation,” “energy transition” and “low carbon economy” are not consistent with our statutory targets.

We recommend the Commerce Commission:

• Declare an objective, with respect to emissions, to reduce emissions at least-cost.
• Define emissions benefits according to changes in overall emissions, not Part 4 companies in isolation.
• Use cost-benefit analysis to assess any proposed changes to Part 4.
• Develop a framework which recognises the interaction between the ETS and other policies, including an imperfect ETS, then use this framework in any cost-benefit analyses.
• Pursue net emissions reductions, consistent with the statutory target.

For further information, download the full submission.