Consultation on the Government’s proposed changes to the ETS


The Government is now consulting on the proposed changes to the ETS. They are holding meetings which start this week, (I have been away for a week so I am sorry for last minute notice, although it has been fairly last minute by the Govt.)

Click here for consultation document consultation document consultation document (PDF, 4.49 MB) This has been published setting out the proposed changes and a number of regional hui and public meetings have been scheduled to discuss the proposed changes.

In the document they say this

the Government supports the entry of agricultural emissions into the scheme only under two conditions:

• there are technologies available to reduce these emissions

• international competitors are taking sufficient action on their emissions in general.

Consistent with this position, the Government proposes to undertake a review, to report in 2014, on whether these conditions have been met.

To enable the results of this review to be implemented, the Government proposes to include the power to defer the entry of these agricultural gases by up to three years. As it is possible that different gases or agricultural activities could have varying levels of opportunities to reduce emissions, it will set up this power to enable the Government to defer obligations for some or all activities.

So it is not cut and dried that they will defer agriculture’s entry for all bio emissions. It is also disconcerting that they put a time limit for the deferral of a maximum of three years should they wish to defer some or all of these livestock emissions; this implies that after three years the Government will throw our farmers to the wolves even if the two conditions are not met. I would think a submission that no maximum is put in place here is in order.

It is also noticelable that the Govt does not see it as important to require competitors to pay for livestock emissions only that they take sufficient action on their emissions in general. (whatever thta means)

The other change which is significant is that the Govt wants to limit the number of international units bought and is proposing limiting the proportion of international units an emitter can surrender and also auctioning NZ Units by the Govt as well as continuing with the free allocation it gives to trade exposed industry and forestry. They say this process will be revenue neutral to the Govt as each additional NZU sold would mean one less international unit of equal value would be surrendered to the Government to meet participants’ obligations.

Of course the whole scheme is supposed to be revenue neutral which makes a lie of Russel Norman’s repeated bleating that farmers are being subsidised by taxpayers.


The Government wishes to consult on the following questions:

  1. What do you think of the overall package of amendments the Government is proposing to make to the ETS as outlined in the consultation document?
  2. Should the Government adjust the level of compensation to pre-1990 forest landowners in light of the introduction of offsetting?
  3. If the Government was to adjust the level of compensation, which of the three options for adjusting the second tranche of allocation, as outlined in this document, do you prefer and why?
    1. a full removal of the second tranche of pre-1990 compensation for all eligible landowners
    2. a reduction of the second tranche of pre-1990 compensation for all eligible landowners
    3. a removal of the second tranche of pre-1990 compensation only for those landowners who take up offsetting.
  4. If a reduction of the second tranche is your preferred option (option 3b) what do you consider the most desirable way to do this and why?

Responding to the consultation

You can send your submission by email to:
or post to:

ETS Review Consultation
Ministry for the Environment
PO Box 10362
Wellington 6143

The closing date for submissions is 5pm Friday 11 May 2012.

About submissions

The Ministry for the Environment may publish all or part of any written submission on the Government’s climate change website. We will consider you to have consented to such publishing by making a submission, unless you clearly specify otherwise in your submission.

The content of submissions is subject to the Official Information Act 1982. Copies of submissions sent to us will normally be released in response to an Official Information Act request from a member of the public. If you object to the release of any information contained in your submission, please clearly state this in your submission, including 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.

If you do not wish your name and any identifying details in your submission to be released in response to a request, please clearly state this in your submission. At your request, we will make your submission anonymous before it is published on the climate change website. However, please note that the Ministry for the Environment will not be able to withhold any information if doing so would contravene the requirements of the Official Information Act.

Hui and public meetings

Regional hui






Kaikohe Mid North Motor Inn 158 Broadway 17 April 10.30am
Gisborne Emerald Hotel 13 Gladstone Road 17 April 10.30am
Christchurch Rehua Marae 79 Springfield Road 18 April 10.30am
Whakatane Mataatua Wharenui Muriwai Drive 18 April 10.30am
Nelson Tahuna Function Centre 70 Beach Road 19 April 10.30am
Rotorua Rydges Hotel 272 Fenton Street 19 April 10.30am
Wanganui Tupoho Community Complex 97 Bell Street 20 April 10.30am
Hamilton Waikato-Tainui Conference Centre 451 Old Taupiri Road, Hopuhopu 20 April 10.30am
New Plymouth Copthorne Grand Central Hotel 42 Powerderham Street 23 April 2.00pm
Napier Pukemokimoki Marae 191 Riverbend Road, Marenui 24 April 2.00pm


Forestry industry and public meetings






Whangarei Flame International Hotel 142 Waverley Street, Onerahi 17 April 5.00pm
Gisborne Emerald Hotel 13 Gladstone Road 17 April 3.00pm
Christchurch Riccarton Park Function Centre 165 Racecourse Road 18 April 3.00pm
Nelson Tahuna Function Centre 70 Beach Road 19 April 3.00pm
Rotorua Rydges Hotel 272 Fenton Street 19 April 5.00pm
Wanganui Davis Lecture Theatre at the Wanganui Regional Museum 20 April 3.00pm
Balclutha Rosebank Lodge Motor Hotel 265 Clyde Street 23 April 3.00pm

I can’t make the Whangarei meeting as I will be in Christchurch and so I may be able to attend the Christchurch one for a part of it, although I think there will only be limited participation by public and the best way to get your message across is by submission. Having said that I do encourage any one with a gripe on this issue to go along and say your piece. It doesn’t hurt to tell them again and again that livestock emissions do not alter the composition of the atmosphere.

Also that there should be no maximum on the three year delay for agricultural bio emissions because these emissions are quite harmless and Tim Groser does not possess one piece of evidence to say otherwise.

I think he should be questioned on why he i sprepared to allow a scheme where NZ farmers are the only one’s in the world facing a cost on these harmless emissions.

I will try to get a copy of my submission out to you as soon as I can so that if you want you can use it for information to help with your own submissions.

All the best Robin


  1. I attended the both the consultations in Gisborne today.
    Associate Minister Simon Bridges was there for the hui. He says speaking to him is the same as speaking to Tim Groser, and that he will be very much a part of the domestic scene as Tim is very involved with international negotiations, not just on climate change but also trade. It is clear from his comments and also this speech from Tim Groser (see here; ) that climate change policy is here to stay.
    Points I took from the meeting, relevant to livestock, are:
    -The condition that livestock will not be included unless our competitors take action is dependent on their taking action generally. It is NOT dependent on them bringing their agriculture in to their scheme, as several of our farming leaders have assumed.
    -I was told that it would be extremely naive to assume that agricultural emissions would never come in. Having said that, they have got agricultural emissions on the table, but it would appear to be more around measurements of the emissions. Apparently part of the Global Research Alliance work is on better quantifying biological emissions. They could not provide an answer as to how big a part of their work that is.
    -When I pointed out that a constant number of livestock don’t cause global warming, heads nodded in agreement but in their answer they bypassed it and talked about the importance of things like the Global Research Alliance.
    – Someone asked why there is not provision to exempt agriculture beyond 2018. There should be a full review of the ETS in 2016. (The 2014 review is only for agriculture, though the Minister does have discretion to make it a full review.) It was said that by 2018 international players may have schemes well advanced. NZ would then need to bring livestock in even if there were no technologies to reduce our emissions, just so that we were doing our share.
    The meeting said very little that is not in the consultation document. They gave the impression that they were very keen to hear our views. Can I urge everyone to send in a submission.
    I would suggest that one thing we ask for is that livestock don’t come into the ETS until their emissions are based on solid science that measures the nett emissions. If they do that the problem of livestock emissions will look after itself.
    They made a big thing about the victory they won with the forestry offsetting. To me it is just common sense. That is what should have been the case in the first place. Apparently Europe did not want forestry in the Kyoto agreement initially. Let us now insist on getting common sense on the issue of biological emissions.

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