Dairy Companies Association of New Zealand (DCANZ) Submission to Emissions Trading Scheme Review Select Committee



Similar documents
NEW ZEALAND. Submission to the ADP. New Zealand s Intended Nationally Determined Contribution. 7 July 2015

Updating the New Zealand Emissions Trading Scheme: Consultation Document

Emissions Trading Scheme Review Committee

EU energy and climate policies beyond 2020

Where does the wine sector sit in terms of Australian climate policy and the global carbon market

Latrobe City Council Submission Emissions Reduction Fund Green Paper February 2014

1.2 The CIOT s Environmental Taxes Working Group has previously commented on the principles of environmental taxes.

Changes in regulated electricity prices from 1 July 2012

New Zealand Emissions Trading Scheme Review 2015/16 Discussion Document and Call for Written Submissions

Review of Non-Forestry Managed Investment Schemes

Your Forestry Investment and the Emissions Trading Scheme

Business Council of Australia

A Guide to Woodland Carbon for Business

New Zealand submission to SBSTA Initial views on Issues related to more comprehensive LULUCF accounting. April 2013

Dairy Industry Restructuring Act 2001: Review of Fonterra's 2012/13 base milk price calculation

The New Zealand Produce Industry Food Safety & Traceability Framework

Australia s 2030 Emission Reduction Target

NEW ZEALAND S RESPONSE TO CLIMATE CHANGE

AUSTRALIA. Submission to the SBSTA May Views on the Elaboration of a Framework for Various Approaches. I. Overview

THE UK CLIMATE CHANGE PROGRAMME AND EXAMPLES OF BEST PRACTICE. Gabrielle Edwards United Kingdom

Updated SCER Demand Side Participation Program December 2013

Rule change request. 18 September 2013

U.S. Submission on Elements of the 2015 Agreement Introduction

Food & Farming. Focus on Market Safety Nets. December Agriculture and Rural Development

E VIRO ME T Council meeting Luxembourg, 14 October 2013

Climate Change and. Environment Position. Statement. and 2017 Action Plan. action. Statement. Action Plan. September 2014

COMMISSION STAFF WORKING DOCUMENT EXECUTIVE SUMMARY OF THE IMPACT ASSESSMENT. Accompanying the document

Saving energy, growing jobs

Australian Government Response to the Senate Committee on Finance and Public Administration

1. a) How effective is the current Climate Change Act 2010 in driving climate change action by:

REFORM OF THE LAW RELATING TO FUTURES EXCHANGES AND CLEARING AND SETTLEMENT SYSTEMS

Scope 2 Accounting Guidance: What it means for corporate decisions to purchase environmental instruments

I CLIMATE AD EERGY POLICY FRAMEWORK

Norwegian position on the proposed EU framework for climate and energy policies towards 2030

ASSOCIATION INC Geothermal Energy: New Zealand s most reliable sustainable energy resource

Changes in regulated electricity prices from 1 July 2012

SUBMISSION Performance Benchmarking of Australian Business Regulation: Planning, Zoning and Development Assessments

New Zealand Electricity Industry Bill and the Importance of Change

Institutional investors expectations of corporate climate risk management

Future drivers and trends in dairy and food markets

COTTON AUSTRALIA LIMITED

Adapting to a changing climate and energy future

PRACTICAL STRATEGIES FOR IMMEDIATE PROGRESS ON CLIMATE CHANGE BUILDING BLOCKS FOR A GLOBAL AGREEMENT

Port Jackson Partners

Statement of Lawrence W. Kavanagh Vice President, Environment and Technology American Iron and Steel Institute Washington, D.C.

Western Australian Feed-In Tariff Discussion Paper

BIRDLIFE INTERNATIONAL S ASKS FOR UNFCCC COP21

Overview - State Tax Review Discussion Paper

Energy Productivity & Pricing

The Levy Control Framework

Nordea Asset Management. Our Approach on Climate Change

Submission by Norway to the ADP

IFA SUBMISSION TO THE DAIRY FORUM 9 th March, Introduction

Submission to the Independent Pricing and Regulatory Tribunal. ~ Draft Report & Determination - Retail tariffs & charges for electricity ~

2014 Residential Electricity Price Trends

NSW Renewable Energy Target

Non Traditional Business Models: Supporting transformative change in the energy market

STATE TAX REVIEW DISCUSSION PAPER

Six greenhouse gases covered by the United Nations Framework Convention on Climate Change (UNFCCC) and its Kyoto Protocol are:

EAST AFRICA DAIRY DEVELOPMENT EADD II PROGRAM, TANZANIA Terms of Reference for Tanzania Dairy Consumer Study

TAX DISCUSSION PAPER. Insurance Australia Group (IAG) welcomes the opportunity to make a submission in relation to the Re: Think Tax Discussion Paper.

Overview on milk prices and production costs world wide

DEPARTMENT OF FORESTRY DRAFT REVISED NATIONAL FOREST POLICY OF MALAWI

New Zealand s response to climate change. March

By to: ISA qualifying investments: Consultation on including peer-to-peer loans

Carbon Credits: An Opportunity for Forest Landowners. Hughes Simpson Texas Forest Service

The Drinking Water Inspectorate s response to the Consultation on the Cave Review of competition and innovation in water markets

In our member surveys, the following themes are repeatedly mentioned as concerns:

ELECTRICITY DEMAND SIDE MEASURES

Review of the Energy Savings Scheme. Position Paper

Interview: Aurélie Faure, Financial Analyst at Dexia Asset Management

Level 2 Economics, 2013

SUSTAINABLE DEVELOPMENT REPORTING CASE STUDY

Response to the Energy White Paper Issues Paper PREPARED BY EMC ENGINEERING FOR THE AUSTRALIAN GOVERNMENT DEPARTMENT OF INDUSTRY

SETTLEMENT SYSTEMS, FUTURES, AND EMISSIONS UNITS BILL: APPROVAL FOR INTRODUCTION AND PARALLEL POLICY PROCESS

National Energy Action s Northern Ireland response to CFD Implementation in NI Strategic issues Discussion Paper

Promoting the long term interests of electricity customers. IPART s submission SCER on network policies and regulation

Executive summary. Chapter one: Foreword. Jochen Kreusel

Level 2 l Intermediate

Major Economies Business Forum: Perspectives on the Upcoming UN Framework Convention on Climate Change COP-17/CMP-7 Meetings in Durban, South Africa

OVERVIEW CLIMATE ACTION IN BC. BC s Climate Action Secretariat. Action to date on climate change. BC s approach to regulating GHGs

Economic Development and the Risk of Global Climate Change

NSWIC NEW SOUTH WALES IRRIGATORS COUNCIL

Capacity Building in the New Member States and Accession Countries on Further Climate Change Action Post-2012

Electricity Market Reform: Proposals for Implementation

and Al Mussell sector, Farmers; International Environmenta Local Food Analysiss and on supply

Carbon Emissions Trading and Carbon Taxes

Tasmanian Farmers and Graziers Association. Submission: Draft Report on Natural Disaster Funding. To: Productivity Commission

Nurture Our Planet. Nourish Our People. Recommendations from the High Level Roundtable on Food and Nutrition Security and Sustainable Agriculture

Retail Tariffs. Business, Irrigation and Farming Tariffs

Proposal of Upstream Emissions Trading in Japan

Managing Rising Energy Costs for Seniors in the ACT

EXPLANATORY MEMORANDUM TO THE CONTRACTS FOR DIFFERENCE (ELECTRICITY SUPPLIER OBLIGATIONS) REGULATIONS No. [XXXX]

Universities Australia Response to the Review of the ESOS Framework Discussion Paper

Adapting Northern Adelaide - Submission towards the new Climate Change Strategy for South Australia

Occupant: Vacant File reference: 2011/0390

Organic farming. A guide on support opportunities for organic producers in Europe. Agriculture and Rural Development

Reducing CO2 emissions for Offshore oil and gas Operations under ETS. Margaret Christie, Environmental Advisor, UK Business Unit, Premier Oil UK Ltd

Project based assessments in the Energy Saver Incentive

Transcription:

PO BOX 3413 Shortland street Auckland New Zealand ~ h ns. z7a szs7 Dairy Companies Association of New Zealand (DCANZ) Submission to Emissions Trading Scheme Review Select Committee FEBRUARY 2009 INTRODUCTION DCANZ welcomes the opportunity to submit to the Emissions Trading Review select committee. We consider the development of enduring climate change policy architecture in New Zealand, which strikes an appropriate balance between economic and environmental drivers to be of high importance. DCANZ does not believe the current Emissions Trading Legislation appropriately responds to the challenges presented by differing levels of international action in this area. By not doing so the scheme is unsustainable on the grounds that it is heavily slanted towards both economic and environmental leakage DCANZ proposes that the Emissions Trading Legislation be amended to address leakage risks through the provision of an output (intensity) based allocation regime, linked to best practice; to provide greater business confidence in the stability of the scheme, via establishment of an independent regulator authority; and to provide a more supportive environment for investment in the development and adoption of lower emissions technologies. BACKGROUND DCANZ represents the collective views of the dairy industry on trade policy matters, as well as relevant domestic regulation and general public policy. DCANZ members currently include Fonterra Co-operative Group, Westland Milk Products, Tatua Co-operative Dairy Company, Goodman Fielder, NZ Dairies, Fonterra Brands NZ, Open Country Cheese and Synlait. This DCANZ submission supports submissions made by the individual dairy companies. Dairy exports generated 10.2 Billion dollars last year, comprising 24 percent of New Zealand's merchandise trade exports. Downstream activities such as transport, rural financing and retailing mean that dairy production plays an even greater role in the national economy. Over the last 15 years growth from the agriculture sector has more than doubled that of other manufacturing industries. Dairy has in turn been a key driver of the growth within the pastoral sector. Depending on its specific design, New Zealand's climate change response has significant potential to either impact both on the economic contribution of the dairy industry, or to contribute to an overall policy environment that supports the on-going success of the industry. TERMS OF REFERENCE ADDRESSED BY THIS SUBMISSION:

3.1 This submissions responds to the following Terms of Reference for the Emissions Trading Scheme Review: (d) Consider the impact on the New Zealand economy and New Zealand households of any climate change policies, having regard to the weak state of the economy, the need to safeguard New Zealand's international competitiveness, the position of trade-exposed industries, and the actions of competing countries; Examine the relative merits of an emissions trading scheme or a tax on carbon or energy as a New Zealand response to climate change; Consider the timing of introduction of any New Zealand measures with particular reference to the outcome of the December 2009 Copenhagen meeting, the position of the United States, and the timetable for decisions and their implementation by the Australian Government; Identify the centrallbenchmark projections which are being used as motivation for international agreements to combat climate change; and consider the uncertainties and risks surrounding these projections. 3.2 The related nature of many of the terms of reference items result in a number of the submissions points made below are relevant to more than one. 4 GENERAL POSITION Principles 4.1 Long-term climate stabilisation requires a comprehensive international response. The purpose of a New Zealand' climate change response should be to support and encourage global efforts to reduce and stabilise greenhouse gas emissions over the long-term. DCANZ supports New Zealand's active contribution to a global response. We consider the following to be important considerations in determining the exact design of the domestic policy that should be implemented to drive that contribution to global emissions reduction: (d) (e) The uneven international playing field which currently exists due to differing levels of commitment under the international climate change framework and the leakage risks this creates; The importance of a supportive environment for development and deployment of lower emissions technologies. Achieving globally significant emissions reductions without compromise to wellbeing will require technological step-change; The increasing global demand for food and New Zealand's competitive strength in the production and supply of relatively low emissions dairy products; The consumer led response to climate change. Ultimately reduction in global emissions will be driven by consumption responses. Consumers will be informed in their response by the carbon footprint of their products (emissions intensity per unit of output); The evolving nature of climate change related science and its application to the policy context.

Evaluation of current emissions tradina scheme desian DCANZ generally supports a market based approach to climate change policy in New Zealand. However, we consider that the current emissions trading scheme falls short of what is required for an enduring policy response, on the basis of poor performance against the following fundamental criteria: Economic and Political Sustainability; Scientific integrity; Fiscal neutrality; (d) Regulatory Independence. The current Emissions Trading Scheme is slanted towards both economic and environmental leakage from New Zealand. An emissions leakage case study on Fonterra indicated the potential leakage in the form of reduced exports would total $650 million (based on long-term average dairy prices)-. When the exporting activity of other dairy companies is taken into account this number increases. Where New Zealand dairy production reduces as a result of the imposition of carbon costs on the dairy supply chain ahead of our competitors, the supply gap in the international market will be filled by production from less greenhouse gas efficient production systems. This risks both a substantial cost to New Zealand as a country and increases in global greenhouse gas emissions. New Zealand's international competitors within the dairy markets do not yet have any fixed commitment to bring agriculture into an emission trading scheme within the timeframes set by the New Zealand emissions trading legislation. Furthermore, those competitors most likely to fill any international supply gap left by New Zealand do not have emissions reduction commitments under the Kyoto Protocol, as a result of their developing country status. The current emissions trading scheme is neither low-cost nor fiscally neutral. A 2008 NZIER study' concluded that the cost to the New Zealand economy of implementing the proposed ETS (which they estimated at $5.9 billion) would be four times greater in 2025 than meeting New Zealand's international obligations without a scheme. Treasury indications are that the scheme will result in a net fiscal benefit to the Government from 2012. Despite its cost to the New Zealand economy, the current emissions trading scheme is constrained in its ability to support behaviour change and meaningful emissions reductions. The scheme risks exposing efficient producers to a price on carbon well beyond the margin and in excess of current abatement potential; this will constrain the growth environment for these businesses and therefore their ability to invest in development and deployment of lower emissions technology. At the same time setting the point of obligation for agricultural emissions at the processor level (the current default point in the legislation) will restrict the ability to recognise individual farmer's use of lower emissions farm tools and techniques. Proposed alternative 1 The case-study was undertaken by NZIER in accordance with TOR agreed by MfE The impact of the proposed Emissions Trading Scheme on New Zealand's economy. NZIER, April 2008

DCANZ considers that a modified emissions trading scheme which focuses on the emissions efficiency of output, particularly where there is a risk of leakage for no environmental gain, is the best way to achieve a balance between environmental and economic drivers in the absence of a level international playing field. A full cap and trade scheme is in appropriate until such time as there is a global price on carbon We consider it both feasible and desirable to amended the Emissions Trading Legislation to: (d) Adopt an output intensity based approach to allocation that is referenced to best practice targets; Place the point of obligation at the individual farm level; Provide greater flexibility in responding to evolving emissions related science, and new emissions management tools and technologies. Establish an independent regulatory authority to set allocation provisions and undertake reviews. DCANZ views it as appropriate that a modified ETS be accompanied by an on-going commitment by the New Zealand Government to emissions reduction research, focused on those areas where New Zealand has a particular competitive advantage as a country. Alongside the establishment of an economic sustainable and scientifically sound domestic policy response, New Zealand should place a high priority in seeking quality outcomes from the current negotiations. DCANZ considers the outcomes of the current international framework negotiations to be highly uncertain at this time. But notes that they provide an important opportunity to address weaknesses in the current Kyoto framework, particularly in relation to treatment of food production. Related to this we note that there are questions being raised regarding the current treatment of biological methane and encourage the New Zealand Government to commit resources into ensuring that these are addressed. OUTPUT INTENSITY BASED ALLOCATION Basing allocation on the intensity of output, referenced to best practice, and without a cap, is necessary to achieve the appropriate balance between encouraging emissions reductions within New Zealand and avoiding leakage for no environmental gain. Under an output intensity based approach to allocation, participants in sectors at risk of leakage (agriculture and stationary energy) would receive allocations equal to a best practice target level of emissions per unit of output for their total production volume. The objective of this would be to fully compensate participants at risk of leakage, who are operating on an emissions efficient basis, for the additional costs arising throughout their supply chains as a result of New Zealand adopting a cost on carbon ahead of competitor countries. DCANZ considers that this approach to allocation would: Avoid punitive penalty to efficient producers; Drive reductions in NZ emissions from business as usual without risking increases to global emissions via leakage to less efficient

competitors. This approach sets a requirement for New Zealand participants to operate on an emissions efficient basis, including by adoption of new cost effective technology. Best practice targets will phase-downwards to reflect advances in emissions efficiency technology and practices; Provide effective behaviour change signals. It will: (i) (ii) (iii) (iv) Maintain a price at the margin; Set clear commercial drivers for participants to optimise their investment in carbon efficient technology; Recognise and reward the use of lower emissions practices at an individual level; Create the right environment for investment in new technology. 5.4 We view an output intensity based approach to allocation as being practical. It aligns with consumer market responses to climate change by focusing on emissions intensity per unit of output. While some work would be required to determine the mechanisms for setting best practice targets the need for complex plans for allocating within a cap would be removed. 5.5 An output intensity approach to allocation for agriculture would necessitate an on-farm point of obligation. DCANZ considers an on-farm point of obligation to be a necessary element of a behaviour change focused scheme. The alternative - a processor level point of obligation - will in-practice work as an output levy and will be constrained in terms of its ability to recognise new technology or reward behaviour change. The tools to support an on-farm point of obligation (the OVERSEER model) are already being used by the dairy industry. 6 RESPONDING TO EVOLVING SCIENCE AND NEW EMISSIONS MANAGEMENT TECHNOLOGIES 6.1 To be most effective, an ETS must recognise and reward all techniques and technologies that are scientifically proven to reduce net emissions. If the scheme recognises only internationally agreed technologies, the motivation for participants, including farmers, to innovate and invest in emissions reduction will be weakened and the scheme will be far less effective. 6.2 DCANZ considers that a modified ETS should allow for recognition of land switching and sequestration of carbon by trees located in plantings of less than 1 hectare. It should also include provision for emerging management technologies to be credited at the time that New Zealand has confidence that they are scientifically robust. This recognises that the international recognition process for new technologies, such as nitrification inhibitors, could be lengthy. 6.3 Alongside the implementation of a modified emissions trading regime DCANZ considers it important that the Government continues to actively supports research and technology in areas where New Zealand can make significant contribution to global emissions solutions. In particular the success of the Government-Industry partnership for agriculture emissions mitigation research, via the Pastoral Greenhouse Gas Research Consortium should be built upon. 6.4 It is important that New Zealand recognises that the many of the tools required for long-term climate stabilisation on not yet available. An on-going

commitment to research and a support environment for business investment is critical to their development and adoption. 7 REGULATORY INDEPENDENCE 7.1 DCANZ considers that the operation of an emissions trading scheme, including setting and reviewing emissions targets and recognising new technologies, should be governed by an independent regulatory authority. This is important for business and markets as it will instil confidence the scheme will be stable and predictable over the long-term. 7.2 Both the Reserve Bank and Commerce Commission provide potential models for further consideration.