In the discussion documents released in November 2015 government sought feedback on the review of the Emissions Trading Scheme (ETS) in two phases. The FOA has already submitted on the first phase - Priority Issues. The second phase relates to Other Issues and includes free allocation, international units, use of auctioning and technical matters including those related to forestry. The FOA is also submitting on the Forestry Technical Note. As a number of the issues are inter-related with this, submissions should be read collectively.

In March 2016 the government sought feedback on a number of matters specifically related to the treatment of forestry under the Emissions Trading Scheme (ETS). This was in addition to an Operational Matters Technical Note and the November 2015 Discussion Document. This submission should be read in conjunction with the other submissions made by FOA on those papers. The Forestry Technical Paper covers structural design settings for forestry, other forest programmes, the international context and two important potential approaches for recognising forest carbon sequestration viz. Averaging and Harvested Wood Products.

In the discussion documents released in November 2015 government sought feedback on the review of the Emissions Trading Scheme (ETS) in two phases. The FOA has already submitted on the first phase - priority issues. The second phase relates to other issues and includes free allocation, international units, use of auctioning and technical matters including those related to forestry. The comments in this submission are provided in response to these issues and key questions raised in the second part of the November discussion document

The FOA is also submitting on the Forestry Technical Note and the Operational Matters Technical Note which were both released in March 2016. As a number of the issues are inter-related these submissions should be read collectively.

Commencing in 2015 in the lead up to Paris, the Wood Council of New Zealand led industry discussions on how the deferred liability benefit associated with the prolonged storage of carbon in wood products should be dealt with under the ETS. Officials have participated in some of this debate. The government has sought feedback on a range of issues by 30 April as part of the 2015 review of the Emissions Trading Scheme. Included in a Forestry Technical Note released in March 2016 is the question of how to treat Harvested Wood Products in the NZ ETS. The NZ forest industry has had a long involvement with the development of the international rules relating to Harvested Wood Products, recognising that the previous instant oxidisation rule was inaccurate and undervalued the contribution of the sector. As such the inclusion of this topic in the Technical Note is welcomed and this Wood Council submission focusses only on this issue. This submission presents some potential policy approaches for devolving the deferred liability associated with the carbon in both forests and wood products ...

Government has sought feedback on the review of the Emissions Trading Scheme in two phases. The first phase relates to priority issues. Priority issues are restricted in the discussion document to:

a. Moving to full surrender obligations

b. Managing the cost of full surrender obligations

FOA's submission to the Climate Change Consultation Contribution, Ministry for the Environment, on New Zealand’s post-2020 climate change contribution under the United Nations Framework Convention on Climate Change

The proposed changes in the document that will increase the incentive for action on emissions reduction and reduce price volatility are essential for the ongoing viability of the ETS and are welcomed. Unfortunately, on many important issues critical to forestry and forestry investment, the document is merely a placeholder that speaks of changes to come but provides no further indication of what they are or how they will operate.

Submission to Ministry for the Environment on the gazetting of New Zealand’s 2050 emissions reduction target

Submission to MAF on the Draft Forestry Allocation Plan

The FOAhas reviewed the discussion document covering the Forestry Schemes Review and has analysed the make-up,cost and performance of the four schemes under review ...

The objective of the review is to provide the government with recommendations on steps that can be taken to ensure that, beyond 2012, the ETS

1. helps New Zealand to deliver its ‘fair share’ of international action to reduce emissions, including meeting any international obligations;
2. delivers emissions reductions in the most cost effective manner; and
3.  supports efforts to maximise the long term economic resilience of the New Zealand economy at least cost.

The FOA supports the proposed restrictions on the use of HFC-23 and N2O CERs in the NZ ETS on the basis that such restrictions are consistent with the objectives of the NZ ETS and that without such restrictions the ETS will fail to function as intended. As the consultation document notes, this is consistent with the approach being taken by other jurisdictions internationally that operate carbon reduction schemes.

The New Zealand Forest Owners' Association welcomes the opportunity to comment on the Government's Climate Change Consultation Paper Kyoto Protocol — Ensuring our Future. In terms of the Kyoto Protocol, Association members have a mix of different age classes of plantations. The age profile of the larger members' forests will include both pre and post 1990 forests while many of the smaller owners will have largely post 1990 (Kyoto) forests. Overall 67% of New Zealand's radiata pinus forests were planted before 1990

A joint Kyoto Forestry Association and NZ Forest Owners Association Submission to the Local Government and Environment Select Committee on the Resource Management (Climate Protection) Amendment Bill 2006. The submission argues that the approach envisaged by the Bill is flawed and that the Bill will therefore not achieve its objective.

FOA submission to Parliamentary Finance and Expenditure Select Committee

In this submisssion, the FOA draws attention to four major anomalies in the draft regulations and proposes workable remedies. The four areas of anomaly are:

1. The Generalised Nature of the Look-Up Tables – Potential Inequities
2. Geo-Spatial information (Mapping)
3. Fees and Charges
4. Determination of Liable Party Contribution (Transmission Line Corridors and Regulatory Deforestation Impositions)

FOA submission to Parliamentary Finance and Expenditure Select Committee on the Climate Change(Emissions Trading and Renewable Preference) Bill

FOA submission to the Finance & Expenditure Select Committee