Updating the New Zealand Emissions Trading Scheme: Consultation Document

Transcription

1 Updating the New Zealand Emissions Trading Scheme: Consultation Document submission: Updating the New Zealand Emissions Trading Scheme: A Consultation Document 11 May 2012 John Johnston Head of Government Relations T: (04) John_johnston@westpac.co.nz A division of ing Corporation ABN

2 Summary This submission is from ing Corporation New Zealand and (referred to collectively as or the ) on the discussion paper Updating the New Zealand Emissions Trading Scheme: A Consultation Document (the Consultation Document ). is an active participant in ongoing public policy dialogue on an appropriate national response to climate change. We welcome the opportunity to provide a submission on the proposed changes to the New Zealand Emissions Trading Scheme (NZ ETS). Over the past decade has played a fundamental role in supporting the emergence of carbon trading and carbon finance market frameworks in the Asia-Pacific region, and has developed an integrated strategic response for our clients across New Zealand and Australia. has played a critical role in the establishment and commencement of the NZ ETS. was the first and remains the only financial institution making a market in the NZ ETS. sees our role in the carbon market as: Promoting an economy-wide perspective; Supporting positive environmental outcomes; Applying our financial market expertise; and Acting as an important intermediary in the community through our employees, customers, suppliers and shareholders. s longstanding commitment to working with clients to transition into a low carbon operating environment is built upon our broader commitment to sustainability as a key differentiator of our business (see Appendix for s climate change credentials). Broadly speaking, supports the proposals outlined in the Consultation Paper. We believe they represent an appropriate response to international developments and the emergence of regional carbon markets. In developing the legislation and subsequent regulation that will underpin the proposed amendments, would strongly support measures which ensure market participants have a clear understanding of how and when future changes to the scheme will be made. This should include the following detail: Timeframes for future amendments; A mechanism for making future amendments; A defined period during which no changes to the scheme will be made; A set of goals, targets or principles that will guide future changes to the scheme; and The mechanism for the release of information to the market. would also recommend that the Government provide a detailed analysis of how offsetting will provide effective compensation to landholders of pre-1990 land under the various options proposed. This submission is in two parts. The first part provides some general comments on the market impact of the package of amendments and the second part addresses specific proposals for the introduction of pre-1990 forest offsetting. Page 2

3 Submission 1. Feedback on the proposed amendments s feedback draws upon the s considerable experience in factoring environmental considerations into business policies and investment decisions and our practical participation in carbon and environmental markets across a number of jurisdictions. strongly believes that any amendments to the NZ ETS should aim to achieve the following objectives: Investment certainty; Market confidence; Environmental integrity; and Affordable and efficient greenhouse gas abatement across the economy. s feedback results from extensive consultation with our clients and other market participants and in our capacity as a major facilitator of the NZ ETS and financier across the New Zealand economy. We have discussed the potential impact of the amendments to the NZ ETS with representatives from a range of industry sectors on both sides of the market and with industry and community groups. This has shaped our feedback on the Consultation Paper. Part one: overall package 1. What do you think of the overall package of amendments the government is proposing to make to the ETS as outlined in this document notes that the stated intent of proposed changes outlined in the Consultation Paper is to refine the NZ ETS to respond to developments in the international arena, facilitate the phasing out of transitional arrangements and to support alignment with emerging regional carbon markets. Based upon the information contained within the Consultation Paper the amendments being proposed would appear appropriate for the evolution of the NZ ETS, given the current state of international climate change negotiations. believes that proposed amendments should enhance the NZ ETS in the following ways: Supporting international linking: ensuring the NZ ETS develops to allow linking with other schemes thereby reducing compliance costs for liable entities and reducing arbitrage between markets; Maintaining cost competitiveness: ensuring that New Zealand has an internationally competitive price on carbon; and Minimising regulatory uncertainty: improving market confidence underpinning the NZ ETS by clearly and consistently setting out proposed changes to the scheme and the timeline for implementation, thereby allowing liable entities and other market participants to pursue longer term carbon price risk hedging opportunities. Page 3

4 notes that many of the proposed changes will be subject to further consultation. The construct of the following amendments will require substantial input from market participants as they are likely to significantly impact market outcomes for the scheme: the setting of the scheme cap; the process for auctioning NZUs; restrictions on the use of international units; and the removal of the fixed price option post would note that many of the specific decisions around each of these factors are interdependent. This will necessarily require a consultation process which allows for regulations and proposed amendments to be considered concurrently, in light of their impact on supply/demand dynamics within the NZ ETS. has consistently supported the need for Government to deliver transparent and consistent information on proposed amendments to the NZ ETS, telegraphed well in advance, to build confidence and minimise the market impacts of short term regulatory uncertainty. In developing the subsequent regulation that will underpin the proposed amendments, would strongly support measures which ensure market participants have a clear understanding of how and when future changes to the scheme will be made. This should include the following detail: Timeframes for future amendments; A mechanism for making future amendments; A defined period during which no changes to the scheme will be made; A set of goals, targets or principles that will guide future changes to the scheme; and The mechanism for the release of information to the market. The goal of these changes should be to improve market confidence and reduce the regulatory uncertainty that currently plagues behaviour in the scheme. The biggest challenge currently facing market participants in the NZ ETS is ongoing uncertainty stemming from regulatory change. Uncertainty results in higher transaction costs and short term behaviour. Behaviour that we see impacting the NZ ETS includes: Rumour and speculation as to the timing and detail of future regulatory change; The need for detailed trading documentation addressing all the potential impacts of possible regulatory change; and A preference for short term dealing. believes that it is critical that the process surrounding the implementation of proposed changes to the NZ ETS allows market participants to form a view on what the forward curve for carbon will look like, based on confidence in the timing around scheme review and amendment. The effective establishment of a robust forward curve will encourage investment in emissions reduction projects and an improved carbon cost assumption for businesses assessing the impact of carbon upon their activities. Page 4

5 Part two: the treatment of pre-1990 forestry 2. Should the Government adjust the level of compensation to pre-1990 forest landowners in light of the introduction of offsetting? As previously stated, strongly believes that amendments to the scheme (including the allocation of NZUs) should be made with the following objectives in mind: Maintaining investment certainty for participants and investors; Maintaining market confidence in the scheme design and the regulatory process; Delivering a clear path and rationale for the amendments in support of defined objectives In light of these objectives, believes that there are a number of factors which must be considered when deciding whether to adjust the level of compensation to pre-1990 landholders: Have participants in the NZ ETS made investment decisions based upon the granting of the second tranche of NZUs to the pre-1990 forestry sector? Does the ability to offset a pre-1990 plantation that is harvested provide sufficient compensation to a participant in the scheme? How would the allocation of a second tranche of NZUs to the pre-1990 forestry sector impact the scheme construct that is being proposed? would support the release of further analysis on the level of compensation and impacts for land value in the forestry sector with and without offsetting to allow market participants, landowners and financial institutions to better assess the financial impacts of proposed changes to the scheme. 3. Options for changing the second tranche of pre-1990 forest allocation As stated above, would require further analysis on the options set out in the Consultation Paper to provide a detailed response to this question. We acknowledge that the Government is continuing to consult with impacted parties around these proposed amendments. 2. Concluding comments is well known in the market for adopting strong risk management practices and a forward looking progressive approach to identifying emerging material risks and opportunities for our business. We recognised a number of years ago that climate change is ultimately a business issue requiring the same approach. As markets and policy frameworks develop as a means of taking greenhouse gas emissions out of everyday lives, financial institutions have a key role to play in partnering with customers across all areas of our business to help transition to a low-carbon operating environment. has played a critical role in the establishment and commencement of the NZ ETS. was the first bank to trade the NZ ETS and remains the only financial institution making a market for our clients, for forestry companies and for liable entities covered by the scheme. Page 5

6 In s experience the implementation of the NZ ETS has been remarkably smooth for such a new market established by regulation and particularly considering current global economic conditions. Considering its size, the market is reasonably efficient and liquid. Participants have good indications of where carbon units are trading and the market has linked well with the international market. would strongly advocate that any adjustments or amendments to the NZETS support the continued smooth operation of the functioning of the market and continue to deliver environmental outcomes for the New Zealand economy will minimizing compliance costs for business. would welcome the opportunity to continue to engage constructively with the Ministry for Environment to ensure the ongoing success of the development of the NZ ETS. Page 6

7 Appendix s climate change credentials s longstanding commitment to working with clients to transition into a low carbon operating environment is built upon our broader commitment to sustainability as a key differentiator of our business. is determined to play a constructive and positive role in promoting effective and practical solutions for our customers and across our business. As a facilitator of the growth of the Australian economy for the last 200 years, we will work with all of our customers to make this transition happen. Recent significant achievements include: was recognised as one of the Global 100 Most Sustainable Corporations at the 2011 Davos World Economic Forum in Switzerland. In 2011, was ranked number one out of 190 banks globally as a leader in sustainability by the Dow Jones Sustainability Index, and included for the 10th year running. The Group was ranked sixth in the world in the Carbon Disclosure Project (CDP) 2011 Global 500 report. has been included in the global Carbon Disclosure Project Climate Leadership Index since was one of only three banks globally, to be named as one of the 2010 World s Most Ethical Companies by the Ethisphere Institute. In 2010 and 2011, was voted Best Trading Company in Australasia in the global Environmental Finance awards. In 2003, was the first Australasian bank, and one of only ten founding signatories globally to sign the Equator Principles, a voluntary global set of guidelines developed for managing social and environmental issues related to the financing of projects. Today there are over 50 signatories worldwide. In 1991 was one of six founding members of the United Nations Environment Programme Finance Initiative (UNEP FI). Today there are over 250 signatory institutions, in more than 45 countries. first launched an Environment Policy in 1991 and began measuring and reporting on operational greenhouse gas emissions and broader environmental impacts in reduced our emissions by over 40% between 1996 and 2008, and is targeting a further 30% reduction by The Climate Change Position Statement was published in 2008 and is endorsed by the Group Executive and the full Board. Progress is reported to the Board on a quarterly basis and performance against Key Performance Indicators is built into the remuneration scorecard of the full Group Executive. s Renewable Energy Strategy was revitalized in 2008 to increase our involvement in clean energy and large scale renewable financing. Today, now more than 50% of our global infrastructure and utilities financing is directed towards hydro and renewables. WIB has also established a dedicated team of carbon specialists to hothouse carbon and carbon related solutions. This team brings together expertise from across the business to focus on delivering integrated carbon solutions for our customers. This includes debt and equity funding for emerging business opportunities in the domestic offset sector (forestry and agriculture), clean energy opportunities, energy efficiency, internal abatement financing requirements and carbon credit off-take, price risk management or origination activities. This team has a global mandate across. Page 7

8 In 2007, brought together financial markets teams trading commodities markets and the National Energy Market (NEM) in Australia, along with Group Sustainability and emerging carbon market expertise in New Zealand and Europe to form an integrated global trading team Commodities, Carbon and Energy (CCE). This approach recognizes overlapping market dynamics and resource conditions influencing pricing as well as how our clients look to manage their own price risk exposure. CCE continues to build a strong track record of market firsts: has been trading the EU ETS since undertook the very first trade of Australian compliance credits in May was the first and remains the only financial institution making a market in the New Zealand Emissions Trading Scheme (NZ ETS), which has been operating since January More recently, in 2011 and Perenia partnered to develop a joint primary CER (pcer) deal, where agreed to offtake pcers for sale into New Zealand and Australian compliance markets. believes that managing the risks and opportunities posed by climate change will be a defining factor in achieving long term profitability for our clients and for business. is committed to developing practical and effective solutions for our customers at every level of the economy. Page 8