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8      How to make a submission

Please ensure your submission addresses each of the questions asked in the text and gathered together below, and contains the following contact details:

  1. your name
  2. the name of the organisation you represent
  3. your address
  4. your email address
  5. your telephone number.

We encourage you to email your submission to emissionstrading@climatechange.govt.nz, using the electronic form (Word doc, 234 KB) available on the Ministry’s website. If you do not have access to the internet, or would prefer to submit a hard copy submission, please post your submission to:

2009 Industrial Allocation Consultation
Ministry for the Environment
PO Box 10362
Wellington 6143

Submissions close 5.00 pm 12 February 2010.

Publication of submissions

The Ministry of for the Environment may post all or parts of any written submission on its website at http://www.climatechange.govt.nz. We will consider you to have consented to such posting by making a submission, unless you clearly specify otherwise in your submission. The content of submissions provided will be subject to public release under the Official Information Act 1982 following requests to the Ministry.

Please note in your submission if you have any objection to the release of any information contained in a submission, and, in particular, which part(s) you consider should be withheld, together with the reason(s) for withholding the information. We will take into account all such objections when responding to requests for copies of, and information on, submissions to this document under the Official Information Act 1982.

Consultation questions

Defining activities eligible for an allocation (section 3)

Question 1
  1. Are you conducting an activity or activities contained in Annex 1? If yes:
    1. What is the activity or activities you are conducting?
    2. Please list other persons you are aware of who are or may be undertaking the activity or activities in New Zealand.
  2. Do you have any comment on the activity descriptions, products, inclusions/exclusions and years for collection of data proposed in Annex 1?
  3. Do you have any comment on the consistency of the definition of activities in Annex 1 with the matters contained in Box 1?
Question 2
  1. Are you conducting an activity or activities that you think is/are emissions intensive and trade exposed and not listed in Annex 1? If yes, please include the following in your submission for each activity:
    1. A clear description of the activity (what inputs are being transformed into what outputs).
    2. A simplified process diagram.
    3. Your estimate of the revenue from the outputs of the activity in a typical year.
    4. Your estimate of the amount of coal, natural gas, or used or waste oil used in carrying out the activity in a typical year.
    5. Your estimate of the amount of greenhouse gas emissions resulting from carrying out the activity from the direct use of coal, natural gas, used or waste oil (including the use of steam generated from these fuels), geothermal fluid, and industrial processes listed in Part 4 of Schedule 3 of the Climate Change Response Act in a typical year.
    6. Your estimate of the electricity used in carrying out the activity in a typical year.
    7. Your understanding of whether the output(s) of the activity are internationally traded across oceans.
    8. Your understanding of whether the output(s) of the activity are economically viable to import to or export from New Zealand.
    9. Whether you are aware of any other people undertaking the activity in New Zealand, and who these people are.
    10. Whether or not you were conducting the activity in all of the (July to June) financial years 2006/07, 2007/08 and 2008/09.

How much will be allocated (section 4)

Question 3
  1. Do you have any comments on the proposed use of an electricity allocation factor of 0.52 tonnes of CO2 per megawatt hour when adjusting allocative baselines from Australia and creating baselines from New Zealand data?
  2. Do you have any comment on the proposed use of an electricity factor of 1 tonne of CO2-e per megawatt hour when testing activities against the emissions intensity thresholds in the Act?
Question 4
  1. If you are conducting an activity or activities listed in Annex 1, or an activity that you believe would be eligible, do you consume more than 2000 gigawatt hours of electricity at a single facility in a typical year?

Proposed requirements for data submitted under gazette notices (section 5)

Question 5
  1. Would the proposed rules covering production, revenue and emissions allow you to calculate emissions and revenue for your activity if the Minister for Climate Change Issues decided to call for data for that activity?
  2. Are there any situations the rules do not cover, and which would need to be covered for revenue or emissions from your activity to be calculated? If so, please describe the situation the rules would need to cover.
  3. Do any of the emissions and financial data requirements need to be clarified? If so, please explain the issues that need to be clarified.
  4. Do you have any other comments or questions on the proposed rules?
  5. If a Gazette notice were issued requesting data on your activity in accordance with the proposed rules in this section, how long do you estimate it would take to collect this data?

Penalties and verification (section 7)

Question 6
  1. Do you have any views about the types of records that should be kept by those applying under regulations for allocation to enable their applications to be verified by the Government?

Other comments

Question 7
  1. Do you have any other comments or suggestions on the issues covered by this consultation document?