Parliament's environment watchdog has questioned the government's claims that it is on track to meet climate targets.
The comments were made in a submission on the draft emissions reduction plan, which the government has to have completed by the end of the year.
Few parts of the government's plan emerged unscathed from the submission by Simon Upton, a former National Cabinet minister turned parliamentary commissioner for the environment.
He said relying on carbon pricing to drive down pollution in areas such as transport was "not coherent".
He said the government was taking a "massive gamble" by relying on planting pine trees to offset carbon emissions instead of actually cutting emissions.
And he said calculations showing progress was on track to meet targets seemed optimistic, in some cases relying on speculative new technology.
The commission also took aim at the government's claim to be taking a "least cost" approach to tackling climate change, saying it had used a narrow definition of cost, and was pushing a burden on future generations.
Upton was not available to be interviewed on Friday.
Under the Zero Carbon Amendment Act, the Government needs a plan to meet a shrinking series of carbon budgets, each one lasting five years, on the way to being carbon neutral in 2050.
That is in aid of the global goal of keeping the planet inside 1.5C-2C of heating, which countries signed up to under the Paris Agreement, after years of peer-reviewed research showed this could avert the worst impacts of a hotter, turbulent climate.
The Government released its draft plan in July, along with calculations saying New Zealand was on track to meet its first emissions budget (2022-2025), narrowly meet its second budget (2026-2030), and miss its third budget (2032-2035).
However, Upton cast doubt on whether even the first and second budgets would be met, saying the margins were so thin there was a risk of missing them.
He said even the numbers showing the third budget being missed were overly optimistic. He said the plan relied on new methane-cutting technology for farmers that did not yet exist and assumptions about carbon capture in underground caverns that were "speculative and based on optimistic assumptions".
He said the government showed "an unwillingness to take action now where alternatives are available" and apparently believed pollution-cutting tech would always be much cheaper in the future. The submission said that the history of green technology such as green hydrogen showed that kind of thinking did not always pan out.
Upton's comments on other aspects of the draft plan included:
On taking a 'least cost' approach
Upton questioned the government's definition of "least cost", arguing it was only considering some costs, and only in the short term.
The submission said the draft "currently gives little or no serious thought to the wider environmental costs at stake or the economic impact of those costs. For example, no thought is given to the significant health and productivity benefits from cleaner air as a result of reduced fossil fuel emissions".
It used the example of government plans to pass a law allowing a liquefied natural gas terminal to address the energy crisis.
"Removing regulations in order to speed up construction of facilities to support the importation of LNG...may be least cost from the perspective of gas users but may prolong the use of the gas network long term.
"If upstream emissions... were included, imported LNG may no longer be the "least cost" solution," the submission said.
Relying on the Emissions Trading Scheme
The government has said the ETS is its main tool for cutting emissions. The scheme requires polluters to buy one permit for every tonne of emissions.
Paying for carbon emissions is meant to give polluters an incentive to cut their planet-heating gases.
However, it only covers 43 per cent of emissions, because methane and nitrous oxide from farming are not covered. The government also gives free permits to "trade exposed" polluters like NZ Steel and Methanex.
Upton said there was another big weakness, too - allowing polluting companies to offset all their emissions with forestry.
He said planting trees would be always be cheaper than cutting emissions, and companies would not cut pollution.
The submission said the ETS would reduce real emissions by only 10 per cent, unless the design of the scheme was changed.
He said the country was tying up land forever in forestry.
"Because carbon stays in the atmosphere effectively forever these forests will also need to remain on the land in perpetuity," the submission said.
"Future generations will inherit a vastly expanded forestry estate that will have to be maintained in the face of a changing climate and the risks of extreme weather events, disease, and fire.
"Reliance on offsetting was never intended to be a 'long-term' solution....it was envisaged that cheap forestry offsets would be used to buy us the time we needed to see new low emission technologies developed, commercialised and brought to market. That was an entire generation ago....The time has been wasted. This plan risks wasting even more time.
"I consider that the country is taking a massive gamble in relying on unlimited forestry offsets."
Tackling transport with carbon pricing
Upton said it was unlikely that carbon prices transmitted through the ETS would be sufficient, and several studies had highlighted the unresponsiveness of transport sector emissions to carbon prices.
"For example, the value of a [tonne of emissions] may need to rise to over $200 for modest emission reductions of between 10-20 percent," he wrote.
"A doubling in the current carbon price to around $100 would still only mean a 15 cent increase at the pump. Increases much larger than this are transmitted to drivers as a result of international events and exchange rate movements
without affecting driver behaviour.
"Believing that the ETS as currently designed will assist the shift to zero emissions transport lacks credibility."
The submission said the ETS - which encouraged sheep and beef land to be converted into forestry - was the only incentive driving reductions in agricultural emissions.