New Zealand Shipping Federation submission to the Ministry for the Environment (MFE) on its consultation document titled the Review of the Emissions Trading Scheme.
The Shipping Federation supports a credible ETS that supports meeting our climate change targets. The Government recognises the ETS as its “main emissions pricing tool” and acknowledges the “critical role” it plays within New Zealand’s climate change policy. All Shipping Federation members face the cost of carbon through their fuel costs.
The Shipping Federation has several concerns with the proposals set out in the discussion document, namely that:
- The review introduces significant political and regulatory uncertainty into the market and has the potential to impact property rights (if the Government does not rule out any retrospective changes to carbon units)
- The discussion document fails to properly consider the other tools that Government could utilise to address its concerns with the role of forestry, and rather relies on substantial changes to the ETS. Moreover, the discussion document does not adequately explain why the Government is not considering other tools rather than relying on the ETS to limit afforestation.
- The discussion document provides very limited and insufficient analysis of the four options, making it difficult to provide meaningful feedback on the options.
Read the document: