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3. Additional comments in submissions

Several submitters made comments that were not covered by questions in the Transitional Measures discussion document but which are relevant to climate change policy development. These comments related to:

  • competitiveness issues

  • coverage of a price-based measure

  • taking account of other existing or proposed policies

  • Māori submissions

  • further consultation and communication

  • criticism or praise for the consultation documents.

Competitiveness issues

Forty-two submissions had a clear stance on ‘competitiveness at risk’. Of these, 93% considered competitiveness at risk to be an important issue. Submitters from a wide range of sectors - particularly business, industry, energy and government - commented on this issue. Many industry and business submitters expressed concern that insufficient consideration had been given to competitiveness-at-risk issues in the Transitional Measures discussion document.

A range of solutions was suggested to address competitiveness-at-risk issues, including gratis allocation methods under any emissions trading measure, NGA-style agreements with exemptions from price measures, and alignment with major trading partners.

One submission supported the use of emission reduction agreements (ERAs) for competitiveness-at-risk firms. The submission noted that any ERA process must involve union consultation, because change of work patterns, loadings and technologies is inherent in any ERA. The submission also noted that an effective way to mobilise collective action is to have clear targets for emissions reductions and practicable mechanisms for achieving those targets.

This submission also argued that transitional measures could include improving the capacity of major emitters to measure, monitor and report on emissions; increasing the capacity of major emitters to participate in emissions trading; and developing measures to influence investment in new plant capacity.

Coverage of a price-based measure

Some submitters criticised narrow price-based measures because they believe that such measures would be better suited to sectors that have a reasonable number of emitters and where the transaction costs of including those emitters are not unreasonably high. These submitters noted that New Zealand has only three thermal electricity generators and around 15 large industrial companies, so a narrow price-based measure would result in very high transaction costs for a small percentage of emissions being covered. They suggested that this would create very limited opportunities to find least-cost abatement.

The relative majority of submitters across a wide range of sectors - including individuals, environmental NGOs, business, industry and energy submitters - considered that any price-based measure must be broad-based and apply to all sectors of the economy.

Taking account of other existing or proposed policies

Some submissions expressed concern that any transitional measure would need to be consistent with policies adopted in the post-2012 environment. Some submitters considered it more important that the longer-term post-2012 policy be designed correctly, and that ‘stop-gap’ interim measures that might constrain the design of post-2012 policy should be avoided.

Comments specific to Māori submissions

Submissions from Māori organisations emphasised a number of concerns, including:

  • the status of Māori as Treaty partner

  • the need for an integrated Sustainable Development Strategy as a starting point for climate change policy development

  • the importance of considerations of equity across economic sectors in terms of policy impact

  • the incorporation of tikanga/value-based and evidence-informed analysis of climate change impacts

  • the need to consider the specific issues and realities facing Māori communities

  • the need for greater collaboration between government agencies on climate change

  • the need for inter-departmental resourcing of an active Māori reference group on climate change, with Māori determining the representation.

Further consultation and communication

Many stakeholders, particularly Māori and industry groups, expressed an expectation or desire for further consultation on detailed preferred options, supported by further quantitative analysis of impacts, prior to final Cabinet policy decisions. Industry groups recommended that further consultation be undertaken so that policies can be developed in a thorough and open way, in order to achieve widespread ‘buy-in’.

Criticism or praise for consultation documents

During public consultation meetings and in some submissions on the discussion documents, some stakeholders noted that the discussion documents presented high-level policy options and did not include detailed information on policy design or cost-benefit analysis of policy impacts. A number of submitters criticised a perceived lack of coherence and consistency between the various climate change consultation documents.

Some submitters felt there was ambiguity over which transitional measures were limited to the discussion of the energy sector, and which were more wide-ranging. This was reflected in submissions, in that many were unclear as to whether the submissions referred to the stationary energy and/or industrial processes sector, and what time period they referred to (eg, pre- or post-2012).