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Holcim New Zealand believes in operating its business in an environmentally responsible manner. Our company operates an energy intensive business, and we recognise the need to reduce global greenhouse gas emissions and energy consumption while fostering economic and social development. At its very least, we see climate change as a risk to our business. Our shareholders, customers, neighbours, employees, financiers, insurers and our families expect us to manage that risk – in the same say that we are expected to manage currency risk, environmental risk, and health and safety.
The difficulty in framing and executing a unified national policy for climate change action in new Zealand, coupled with the interesting lessons to be learned from the European Union Emissions Trading System (EU ETS) has prompted Holcim New Zealand to scrutinise our own approach to this difficult and complex area of public policy. Since mid 2006, we have delivered on our commitment to the New Zealand government to identify, in detail, emissions trading design elements that would be appropriate for New Zealand’s energy intensive sector – using the wide international experience already gathered by the Holcim Group in the EU ETS and elsewhere.
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New: Submission to Ministry for the Environment on the Second draft Climate Change Regulations (2009)
In mid-2009, the Ministry for the Environment published a series of detailed draft regulations that updated the previous drafts of 2008. The Ministry requested all interested parties to submit on these draft by 13 July 2009.
Holcim New Zealand’s submission concentrated on two particular draft regulations:
- Climate Change (Stationary Energy and Industrial Processes) Regulations 2009 (Draft for Consultation)
- Climate Change (Unique Emissions Factors) Regulations 2009 (Draft for Consultation)
The submission covers both cement and lime businesses of Holcim New Zealand.
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New: Submission to Emissions Trading Scheme Review Select Committee (Digest No. 6)
In February 2009, Holcim New Zealand made two separate written submissions to the Parliamentary Select Committee tasked with a Review of the Emissions Trading Scheme and Related Matters. One submission covered the cement business; the other covered the industrial lime businesses of Holcim New Zealand. The two submissions largely confined their commentary to specific terms of reference that were within the scope of the Select Committee review, namely:
- 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 need for any additional regulatory interventions to combat climate change if a price mechanism (an ETS or a tax) is introduced.
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Submission to Ministry for the Environment on the draft Climate Change Regulations 2008
This submission was made on 15 December 2008 in response to the publication of draft regulations arising from the Climate Change Response Act 2002 and its major amendment in the Climate Change Response (Emissions Trading) Amendment Act 2008.
The 2008 Act established a New Zealand Emissions Trading Scheme (NZ ETS), and the draft regulations seek to define various requirements for participants in the NZ ETS to properly estimate the emissions intensity of their business activities. The draft regulations cover only the activities of the Stationary Energy and Industrial Processes sectors of the New Zealand economy.
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A Comparison of The EU ETS and the proposed NZ ETS
At the conclusion of its hearing of the Holcim New Zealand submission on
the Climate Change Bill in Christchurch on 7 April 2008,
the Finance and Expenditure Select Committee noted that Holcim had, almost
uniquely, attempted to provide it with a hard comparison
of certain features of the design of the proposed NZ ETS and the design of
the EU ETS albeit, related specifically to the cement industry.
The Committee then asked if Holcim was in a position to provide it with a
further and broader comparison of the design of the EU ETS
and the proposed NZ ETS that might more generally inform its
deliberations.
This Digest has been compiled as a response to that request. This is the
fourth in a semi-regular series of Holcim Climate Change Policy
Digests published by Holcim New Zealand.
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Submission To Finance And Expenditure Select Committee On Climate Change Bill (Digest No. 3)
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A consideration of the proposed design of the New Zealand Emissions Trading Scheme
This document is the third in our series of Climate Change Policy Digests and summarises our views on the Climate Change (Emissions Trading and Reusable Pre) Bill that was introduced to parliament in December 2007.
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