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.
Ongoing uncertainty in any area of business activity makes long-term planning extremely difficult. So, after more than a decade of uncertainty, the enacting of the Climate Change (Emissions Trading) Act in November 2009 was welcome.
Holcim New Zealand has always supported the application of an emissions trading scheme in New Zealand (NZ ETS), but has consistently submitted that earlier Government proposals would make the cement industry uncompetitive against overseas cement producers.
Whilst the risks remain real, the final form of the NZ ETS appears to have reduced trade-exposure vulnerability for a number of energy-intensive industries which otherwise would have been at serious risk of closure, with the loss of a large number of jobs and national income. Those industries included Holcim New Zealand's cement business.
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.
In April 2012, Government called for submissions on a series of proposed amendments to the existing NZ ETS that arose from the recommendations of the independent 2011 NZ ETS Review Panel.
Holcim New Zealand submitted on these proposals on the due date of 11 May 2012. As always, we value feedback on our submissions. You can contact us with your feedback using the “Contact” link at the bottom of this page.
A Submission on updating the Holcim New Zealand Emissions Trading Scheme
In February 2010 Holcim New Zealand made a submission on the consultation document for development of Industrial Allocation Regulations. This submission asserted that the clinker-based activity definition in the document was practically unworkable.
Submission to Ministry for the Environment on Industrial Allocation Regulations
In October 2009 submitted, welcoming the broad intent of the Amendment Bill.
Submission on Climate Change Response (Moderated Emissions Trading) Amendment Bill
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 regulations by 13 July 2009.
Holcim New Zealand's submission concentrated on two particular draft regulations:
The submission covers both cement and lime businesses of Holcim New Zealand.
Submission to Ministry for the Environment on the Second draft Climate Change Regulations (2009)
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:
Cement - Submission to Emissions Trading Scheme Review Select Committee (Digest No. 6)
Earlier documents can be viewed at:
Archived climate documents