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1. Introduction


This report summarises the submissions made to the New Zealand government on The Discussion Paper on Transitional Measures: Options to Move Towards Low Emissions Electricity and Stationary Energy Supply and to Facilitate a Transition to Greenhouse Gas Pricing in the Future (referred to hereafter as Transitional Measures).

The report begins with background information on how the Transitional Measures discussion document was developed, the subsequent consultation process and how submissions were received and analysed, and a sectoral breakdown of submitters. Section 2 then summarises the comments from submitters under the following eight principal themes:

  • emissions trading

  • a narrow-based carbon dioxide charge

  • renewable obligations

  • incentives

  • project-based measures

  • regulatory measures

  • voluntary measures

  • overarching comments.

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 have been summarised in section 3, and relate 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.


In August 2006 Cabinet approved a series of whole-of-government climate change policy work programmes. These work programmes were designed to enable New Zealand to manage climate change as a long-term issue, to play its part in reducing emissions, and to encourage other countries - especially the major emitters - to reduce their emissions.

The work programmes culminated in the following five discussion documents being produced for consultation in December 2006:

  • Transitional Measures for Electricity and Stationary Energy Supply (part of the New Zealand Energy Strategy - NZES)

  • Powering Our Future: Draft New Zealand Energy Strategy to 2050 (the NZES)

  • Draft New Zealand Energy Efficiency and Conservation Strategy (an integrated subset of the NZES)

  • Discussion Paper on Measures to Reduce Greenhouse Gas Emissions in New Zealand Post-2012 (post-2012 measures)

  • Sustainable Land Management and Climate Change: Options for a Plan of Action.

The Transitional Measures discussion document is part of the Draft New Zealand Energy Strategy. It explores ways to reduce greenhouse gas emissions in the stationary energy sector before 2012 (the end of the first commitment period of the Kyoto Protocol). In particular, the document presents options for lowering emissions from the supply of energy from stationary sources (electricity and industrial heat and power).

All five of the discussion documents are available online.

Public consultation and consultation with Māori as Treaty partners took place between December 2006 and March 2007. The consultation process included approximately 50 public or multi-sector meetings, workshops and hui, and approximately 100 focused stakeholder meetings. These events took place throughout the country, with over 4,000 people attending. The public were given until 30 March 2007 to make written submissions on the five discussion documents, and 123 submissions were received on the Transitional Measures document.

This summary report results from a detailed review of submissions on the Transitional Measures discussion document. The review is primarily based on responses to the questions (from 1 to 29) in the Transitional Measures document, grouped into eight principal themes.

Where possible we have attempted to provide statistics for the responses to the 29 questions. However, many submissions did not give specific answers to the questions set out in the discussion document, and many submissions did not specify whether their detailed preference was an interim or long-term measure, with many commenting only generally in terms of timeframes. Consequently, some interpretation was required when analysing the responses to some questions.

Also, a submitter’s support of a certain measure was generally provisional on a number of additional conditions being met, so it was often difficult to tell whether a submission supported or rejected a specific policy measure. This is partly a result of the broad nature of the discussion document, which proposed a large number of policy options for consultation but did not set down any firm policy preferences.

We have used consistent qualitative statements to indicate the level of support for a given message. The qualifiers we have used, in order of weighting, are as follows: one, few, some, several, relative majority, majority and vast majority. A relative majority is defined as the largest share of something, which may not be considered a majority; ie, it is the largest group/category, but is not necessarily a majority (ie, more than 50%).


The table below shows the number of submitters from various sectors or interest groups. A full listing of submitters can be found at: line represents 4 underscores)

Sector/interest group

Number of submissions

Academic and research


Business and industry:

  • agriculture/dairy

  • energy

  • forestry

  • other





Government, local government and political parties


Consulting and professional


Māori (iwi or hapū)



  • business (includes chambers of commerce, professional and business associations)

  • environmental

  • community






Total number of submissions