Improvements to the New Zealand Emissions Trading Scheme (NZ ETS)

The New Zealand emissions Trading Scheme (NZ ETS) is the Government’s main tool for reducing greenhouse gas emissions. It does this by putting a price on greenhouse gas emissions.  The price on emissions is intended to create a financial incentive for businesses who emit greenhouse gases to invest in technologies and practices that reduce emissions. It also encourages forest planting by allowing eligible foresters to earn New Zealand emission units (NZUs) as their trees grow and absorb carbon dioxide. The Government seeks feedback on a range of proposals to improve the NZ ETS. The Government is also seeking feedback on a proposed package of changes to improve the ETS for forestry participants.  You can read the consultation documents on the [url=http://www.mfe.govt.nz/consultation/ets]Have your say on proposed improvements to the New Zealand Emissions Trading Scheme[/url] page. [b]Submissions close at 5.00 pm on 21 September 2018. [/b] [b]Submission form[/b] The questions below are a guide only and all comments are welcome. You do not have to answer all the questions. To ensure your point of view is clearly understood, please explain your rationale and provide supporting evidence where appropriate. Please fill in the form below, then click Continue to review your submission. At any time you may click Save and Exit so that you can return later.

You must provide either a company name or given name(s)

Improvements to the New Zealand Emissions Trading Scheme - click here to expand questions
1. What issues should the decision maker consider when making unit supply decisions? (Select all that apply.)
2. What, if any, restrictions should be placed on the NZ ETS decision maker when making unit supply decisions? (For example, currently one year’s notice must be given for changes to unit supply volumes.)
3. Do you agree with the proposal to implement a single-round, sealed bid auction format with uniform pricing? If not, why not?
4. Do you think that auctioning frequency should be:
5. Do you agree with the proposal that all NZ ETR account holders should be able to participate at auction? If not, why not?
6. Do you think that the Government should use the proceeds gained from the auctioning of NZUs for specific purposes? If so, please explain what those purposes would be.
7. Do you agree with the proposal to replace the $25 fixed priced option with a cost containment reserve price ceiling implemented through the auctioning mechanism? If not, why not?
8. How do you think the price level and number of units in the cost containment reserve should be managed over time? (Note: specific settings will be consulted on later.) (Select all that apply.)
9. What actions should occur if the price ceiling is struck? (Select all that apply.)
10. Do you agree with the proposal to review the price ceiling if another significant event occurs (such as a decision to link the NZ ETS with another carbon market)?
11. Do you agree that the $25 FPO may not be appropriate for the short term, and may need to be adjusted before 2020? Please explain.
12. Which mode of purchase for international units (direct or indirect) would be the best approach for the NZ ETS, acknowledging that there are other significant factors that will influence this decision? Please explain.
13. If NZ ETS participants are able to purchase and surrender international units directly, do you think that there is justification for varying the percentage of allowable international units by participant type? If not, why not?
14. How do you think decisions on a phase-down of industrial allocation should be made? (Select all that apply.)
15. If a decision-making process for industrial allocation is implemented, which of the following factors should the decision maker take into account? (Select all that apply.)
16. If a phase-down is initiated in future, which of the following rates for phasing down industrial allocation should be considered? (Select one option only.)
17. What impact would changes to the levels of industrial allocation from 2021 have on your investment or business decisions?
18. For each of the seven areas that we have identified as being sources of potential risk, what is your assessment of the level of risk that they create, both now and in the future? Please provide examples or evidence if possible. (Select all that apply.)
18a. inadequate, false or misleading advice (please explain)
18b. a lack of transparency, monitoring and oversight for trades (please explain)
18c. risks of manipulation of the NZU price (please explain)
18d. insider trading (please explain)
18e. money laundering risks (please explain)
18f. credit and counterparty risks (please explain)
18g. potential conflicts of interest (please explain)
18h. other (please explain).
19. Do you think that there would be benefits from publishing individual emissions data reported by NZ ETS participants? (Please explain.)
20. Do you think cases of non-compliance should be published? (Please explain.)
21. How would publishing these types of information affect you?
22. Do you agree with the proposal to introduce strict liability infringement offences for low level non-compliance? If not, why not?
23. What are your views on the levels of the proposed fines?
24. Has the excess emissions penalty for failing to surrender or repay units by the due date caused issues for you? If so, please explain.
25. Should the excess emissions penalty for failing to surrender or repay units by the due date be changed? If so, please explain.
26. What option do you see as most appropriate for the excess emissions penalty?
27. Do you agree with the proposal to use approved units to repay any overdue unit obligation from a previous reporting period, before any remaining balance is transferred to the owner? If not, why not?
28. Should large purchasers of coal, natural gas or obligation fuels have the ability to opt-in for only a portion of their obligations?
29. As a mandatory participant that supplies this controlled fuel, what burden would it create if more of your large purchasers were to opt-in? Please explain.
30. Do you agree with the proposal that all coal sold or used from a stockpile be reported, regardless of whether the participant meets the threshold for coal importing or mining in the year the coal was sold or used? If not, why not?
31. Do you agree with the proposal that the Government should be able to amend Unique Emissions Factors from previous years? If not, why not?
32. Do you agree with the proposal that participants should repay the same type of units, rather than the exact same unit? If not, why not?
33. Do you agree with the proposal to extend the general 30 day due date for repayments to annual allocation adjustment repayments? If not, why not?
34. Do you agree with the proposal that the deadline for surrenders and repayments is 60 working days from the date a notice is sent? If not, why not?
35. Do you agree with the proposal that industrial allocations can be transferred to a consolidated group account? If not, why not?
36. Do you agree with the proposal that account operators continue to operate NZ ETS accounts until a succession plan is in place? If not, why not?
37. Do you agree with the proposal that units should vest in the Crown if the account operator chooses to close the account? If not, why not?
Forestry - Simplified Accounting Approach for the ETS (A Better ETS for Forestry) - click here to expand questions
1. Do you agree with the Government’s preferred option to require all people who register new forests in the ETS to use averaging accounting? If you disagree, could you please provide your reasons why. What do you think will be the main impacts of this option for you or other land owners?
2. Out of the three options presented regarding averaging accounting and existing forests, could you please select your preferred option. Could you please explain below why it is your preferred option. What do you think will be the main impacts of this option for you or other land owners? If there are other options you think we should consider, please list
3. Do you agree with the Government’s option regarding transition considerations in a move to averaging accounting? If you don’t agree, could you please explain why below. What do you think will be the main impact of this option for you or other land owners? If there are other options you think we should consider, please list them below.
4. Do you agree with the Government’s preferred option that trees planted after 1 January 2020 are ‘new’ forests? If you disagree, could you please provide your reasons why. What do you think will be the main impacts of this option for you or other land owners?
5. Do you agree with the Government’s preferred option to continue to require all ETS post-1989 forestry participants with land below 100 hectares to use default look-up tables and those with land over 100 hectares to use the FMA approach to measure carbon storage in their forests? If you disagree, could you please provide your reasons why. What do you think will be the main impacts of this option for you or other land owners?
6. Out of the two options presented regarding how to calculate the long term average carbon storage age what is your preferred option? Could you please explain below why it is your preferred option. What do you think will be the main impacts of this option for you or other land owners? If there are other options you think we should consider, please list them below.
7. Do you agree with the Government’s preferred option regarding how a change to the average age in regulations can be applied to existing participants who are above the average age? If you disagree, could you please provide your reasons why. What do you think will be the main impacts of this option for you or other land owners? If there are other options you think we should consider, please list them below.
8. Do you agree with the Government’s preferred option regarding how a change in the average age can be applied to existing participants who are below the average age? If you disagree, could you please provide your reasons why. Could you also tell us below how you expect this change will affect you or other land owners.
9. Do you agree with the Government’s preferred option regarding how far back can a participant claim NZUs/emissions units on entry to averaging accounting? If you disagree, could you please provide your reasons why. What do you think will be the main impacts of this option for you or other land owners? If there are other options you think we should consider, please list them below.
10. Do you agree with the Government’s preferred option for ongoing reporting requirements? What do you think will be the main impacts of this option for you or other land owners? If there are other options you think we should consider, please list them below.
11. Do you agree with the Government’s preferred option for ETS participants with forests subject to a temporary adverse event? If you disagree, could you please provide your reasons why. What do you think will be the main impacts of this option for you or other land owners? If there are other options you think we should consider, please list them below.
12. Do you think removing temporary adverse event emissions liabilities will reduce insurance premiums and incentivise people to register more forests in the ETS?
13. Do you agree with the Government’s preferred option to introduce offsetting for ETS forestry participants with post-1989 forest land who use averaging? If you disagree, could you please provide your reasons why. What do you think will be the main impacts of this option for you or other land owners? If there are other options you think we should consider, please list them below.
Forestry - Recognising the Emissions Mitigation from Harvested Wood Products (A Better ETS for Forestry) - click here to expand questions
14. Out of the three options presented regarding how to pass on the international harvested wood products accounting benefit to the NZ forestry sector, what is your preferred option? Could you please explain below why it is your preferred option. What do you think will be the main impacts of this option for you or other land owners? If there are other options you think we should consider, please list them below.
Forestry - Creating a Permanent Forests Category in the ETS (A Better ETS for Forestry) - click here to expand questions
15. Do you agree with the Government’s preferred approach to introduce a new activity into the ETS for permanent post-1989 forests? If you disagree, could you please provide your reasons why. Could you also tell us below how you expect this change will affect you or other land owners.
16. Do you agree with the Government’s preferred approach to use the existing stock change accounting process for permanent forests? If you disagree, could you please provide your reasons why. Could you also tell us below how you expect this change will affect you or other land owners.
17. Do you agree with the Government’s preferred approach that the majority of the operational processes and regulations should be shared between permanent post-1989 and post-1989 forests, with the key difference being the non-clear-fell harvest period? If you disagree, could you please provide the reasons why. Could you also tell us below how you expect this change will affect you or other land owners.
18. Do you agree with the restrictions proposed for permanent forests? If you disagree, could you please provide the reasons why. Could you also tell us below how you expect this change will affect you or other land owners.
19. Do you agree that 50 years is an appropriate non-harvest period for ETS registered permanent forests? If you disagree, could you please provide the reasons why. Could you also tell us below how you expect this change will affect you or other land owners.
20. Do you agree with the Government’s preferred option of not offering a covenant for permanent forests registered in the ETS? If you disagree, could you please provide the reasons why. If there are other options you think we should consider, please list them below.
21. What assistance could the Government offer to make it easier for indigenous forest to be registered in a covenant from other organisations (e.g sharing mapping information)?
22. Do you agree with the Government’s preferred option that transfer for current PFSI participants to a permanent post-1989 forest activity in the ETS should be mandatory with a one-off option to exit? If you disagree, could you please provide the reasons why. Could you also tell us below how you expect this change will affect you or other forest owners.
23. Do you agree with the Government’s three choices for dealing with permanent forests registered in the ETS when the 50-year permanence clause ends? If you disagree, could you please provide the reasons why. If there are other options you think we should consider, please list them below.
24. Do you agree whether there should be an option to sign up for another non-harvest period? If you do agree, could you please state below how long this should be and why.
25. Do you agree that a retrospective averaging approach is the best way to allow forests to be harvested after 50 years? If you disagree, could you please provide the reasons why.
26. Out of the three options presented for participants to exit the ETS permanent forest category prior to the end of the 50-year non-harvest clause, which do you prefer? Could you please explain below why it is your preferred option and how this will affect you or other forest owners. If there are other options you think we should consider, please list them below.
27. Do you agree with the Government’s preferred option for participants who transfer to permanent forests to only earn units from the start of the MERP during which the move to permanent forest is made? If you disagree, could you please provide the reasons why. If there are other options you think we should, consider please list them below.
28. Do you agree with the Government’s preferred option regarding transitioning rotation post-1989 forests in the ETS over to the permanent forest category once they are past the first rotation? If you disagree, could you please provide the reasons why. If there are other options you think we should consider, please list them below.
29. Do you agree with the Government’s preferred option that harvesting restrictions are applied from the date of transfer to permanent post-1989 forest? If you disagree could you please provide the reasons why below. If there are other options you think we should consider please list them below.
Forestry - Operational Improvements to the ETS (A Better ETS for Forestry) - click here to expand questions
30. Do you agree that publicly available maps are the best way to provide more certainty on forest eligibility in the ETS? If you agree, could you please list below how much information the map should contain (eg, just land eligibility, unit balances etc). If you disagree, could you please provide the reasons why.
31. Would you be comfortable with your information on the above maps being publicly available?
32. How would you see the information in these maps interacting with other publicly available maps?
33. Do you agree with the options for improving the deforestation offsetting process for pre-1990 forests? If you disagree, could you please provide the reasons why. If there are other options you think we should consider, please list them below.
34. Have you considered using the current offsetting rules for pre-1990 forest? If so, did you face barriers to using offsetting and could you list them below?
35. Do you agree with the proposal to improve the tree weed deforestation exemption process? If you disagree, could you please provide the reasons why. If there are other options you think we should consider, please list them below.
36. Have you attempted to control tree weeds on your land and, if so, did you face any barriers? Could you please include below any suggestions for how the process could be made easier?
37. Do you agree that a generic threshold for using exemptions for less than 50-hectare blocks of pre-1990 forest land should be 10 owners on 1 September 2007? If you disagree, could you please include below what number of owners you would set it at and why?
38. Do you agree that any subsequently appointed trustee or agent should be able to apply for the above exemption (provided it has met the statutory requirements under Te Ture Whenua Maori Act 1993)? If you disagree, could you please provide the reasons why. If there are other options you think we should consider, please list them below.
39. Do you agree with the proposal for a simpler process for section 60 exemptions? If you disagree, could you please provide the reasons why. If there are other options you think we should consider, please list them below.
40. Do you agree that a mini-MERP is the best way to align participants’ ETS obligations with New Zealand’s international emissions targets? If you disagree, could you please include below what alternatives to a mini-MERP you would propose.
41. Are you comfortable with the operational detail for post-1989 offsetting being largely the same as pre-1990 offsetting?
42. Which yield table do you think should be used to define the carbon equivalence of the new forest?
43. Should the land the new (offset) forest is planted on be differently recorded from pre-1990 forest offset land? If so, could you include below why. Could you also include below if you have any other input regarding this proposal.
44. Do you agree with extending section 60 exemptions to post-1989 forest land? If you disagree, could you please provide the reasons why. If there are other options you think we should consider, please list them below.
45. Do you agree with the proposed change to extend the cost recovery framework? If you disagree, could you please provide the reasons why. If there are other options you think we should consider, please list them below.
46. Do you agree with the proposal to treat executors of wills as if they were the registered participants? If you disagree, could you please provide the reasons why. If there are other options you think we should consider, please list them below.
47. Do you agree with the proposed change for the notification of interested parties? If you disagree, could you please provide the reasons why. If there are other options you think we should consider, please list them below.
48. Do you agree with the proposal to allow reconfiguration of carbon accounting areas (CAAs) without participant cost? If you disagree, could you please provide the reasons why. If there are other options you think we should consider, please list them below.
49. Do you agree with the proposed change regarding timing of deforestation? If you disagree, could you please provide the reasons why. If there are other options you think we should consider, please list them below.
50. Do you agree with the proposal to ensure all emissions or removals from all trees in a CAA are included in an emissions return? If you disagree, could you please provide the reasons why. If there are other options you think we should consider, please list them below.
51. Do you agree with the proposal to change emissions returns for natural disturbance events that permanently prevent forest re-establishment? If you disagree, could you please provide the reasons why. If there are other options you think we should consider, please list them below.
52. Do you agree with the proposed change to remove unnecessary emissions return requirements? If you disagree, could you please provide the reasons why. If there are other options you think we should consider, please list them below.
53. Which of the two proposed options to exclude post-1989 forest land with tree weeds do you prefer? Could you please provide your reasons why below.
54. Do you currently have any tree weeds registered?
55. Do you agree with the proposal to allow the EPA to review its decisions? If you disagree, could you please provide the reasons why. If there are other options you think we should consider, please list them below.
56. Do you agree with the proposed change for deregistration of forestry participants? If you disagree, could you please provide the reasons why. If there are other options you think we should consider, please list them below.
57. Do you agree with the proposed change to rounding rules? If you disagree, could you please provide the reasons why. If there are other options you think we should consider, please list them below.
58. Do you agree with the proposal to allow more flexibility in submitting emissions returns? If you disagree, could you please provide the reasons why below. If there are other options you think we should consider, please also list them below.
59. Do you agree with the proposal to standardise timeframes for unit surrenders and payments? If you disagree, could you please provide the reasons why below. If there are other options you think we should consider, please also list them below.
60. Do you agree with the proposal to require all returns to be net returns? If you disagree, could you please provide the reasons why below. If there are other options you think we should consider, please also list them below.
61. Do you agree with the proposed change regarding the transfer of participant when forestry rights are granted? If you disagree, could you please provide the reasons why below. If there are other options you think we should consider, please also list them below.
62. Do you agree with the proposed change to cover cases where cleared land is re-established in forest by both planting and natural regeneration? If you disagree, could you please provide the reasons why below. If there are other options you think we should consider, please also list them below.
63. Do you agree with the proposal that deforested exempt land is considered post-1989 forest land if it becomes forest land again nine years or more after being deforested? If you disagree, could you please provide the reasons why below.
64. As per above, do you agree with the stand-down period of nine years or more? If not, what period do you think should be used?
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