Submissions
Bioenergy Association regularly makes submissions on issues affecting bioenergy and energy in general in New Zealand. Use the links below to access generic bioenergy or energy submissions. Special topic submissions can be found on the topic websites Biogas, Liquid biofuels and Bioproducts and Wood energy.
- Sustainable Biofuel Obligation Bill (12 January 2023) - Bioenergy Association's submission on the Sustainable Biofuel Obligation Bill covered:
the need for the legislation; the need for certainty; the importance of flexibility, and the importance of sound sustainability criteria which did not inhibit domestic manufacture of liquid biofuels.
Read submission
- Submission for National direction for plantation and exotic carbon afforestation (22 November 2022)- In its submission the Association was very critical of the proposals to create carbon forests with different rules than other plantation forests. The association view is that all plantation forests should be sustainably managed under the same rules. Read submission here.
- Pricing Agriculture Emissions (18 November 2022) - Bioenergy Association provided a submission on the draft agriculture emissions pricing proposals from Government. A key point made to government was the important of including for all emissions mitigation options available to farmers, including those from bioenergy and biofuels. Read Submission
- The draft Forestry and Wood Processing Industry Transformation Plan (Sept 2022) - The Bioenergy Association has provided a strong supporting submission on the draft Forestry and Wood Processing Industry Transformation Plan. The draft plan sets a vision for how New Zealand can gain additional value from forestry and land use by transformation to a bioeconomy based on wood. The Plan builds on the existing industry strengths for producing bioproducts including bioenergy and biofuels. The Association suggests that the transformation can go faster because of the strong foundations which the industry already has. For example bioenergy and biofuels production and use could triple by 2050, based on existing sources of biomass. Greater quantities of biomass from additional planting etc., could result in more than tripling of the use of bioenergy and biofuels. Read submission
- Sustainable biofuels mandate consultation (June 2022) - The Biofuels Association supports having dual options. Whilst in principle default values based on the EU RED scheme may be applicable their suitability for specific fuels should be checked by EPA before adoption from real values.
Bioenergy Association supports the Government publishing default emissions standards for biofuels. This will encourage domestic production and simplify supply. Read submission
- Transforming Recycling Consultation (May 2022) - The Bioenergy Association is pleased to see the importance placed on recycling and in particular separation of organic material at source. Separation of organics at source results in more and a better quality organic material less contamination being able to be recycled into energy, gaseous biofuel and other products such as bio-fertilser because greater volumes of suitable organics are available, and costs of recycling are able to be kept to a minimum. Read submission
- Proposed changes to regulations for the New Zealand Emissions Trading Scheme 2022 (April 2022) - The Bioenergy Association is pleased to make this submission on the proposals in the discussion document Proposed changes to regulations for the New Zealand Emissions Trading Scheme 2022. The association submission is limited to the proposed change to the Climate Change (Liquid Fossil Fuels) Regulations 2008.
Read submission
- Managing exotic forestry incentives (April 2022) - Work by the Bioenergy Association has shown that with supportive programmes to incentivise plantation forest owners and farmers to optimise the integration of farm forestry (shelterbelts, erosion control, woodlots, managed riparian plantings etc.) that there can be adequate quantities of biomass available to replace fossil fuels for energy and reduce greenhouse gas emissions. More here
- Emissions reduction opportunities for farmers (March 2022) - The Bioenergy Association is pleased to see the proposals in the discussion document He Waka Eke Noa Agriculture emissions pricing options and is generally very supportive of the proposals to have a single net emissions regime across all agriculture types where farmers are incentivised to reduce their individual emissions. Read submission
- Te Ara Paerangi: Future Pathways Green Paper (March 2022) - Te Ara Paerangi Future Pathways Green Paper focused on the future of New Zealand’s research system. The consultation sought to start an open and wide-ranging conversation on a range of issues facing the future of New Zealand’s research system. Read submission
- Emissions Reduction Plan (August 2021) - The Emissions Reduction Plan sets out the policies and strategies Aotearoa New Zealand will take to meets its first emissions budget, helping to transition to a low-emissions future in a way that is achievable and affordable. Read submission
- Call for evidence: Options available to reduce greenhouse gas emissions over the period 2022 to 2035 (November 2019) - from 19 September to 15 November 2019, the Interim Climate Change Committee opened a Call for evidence on options available to reduce greenhouse gas emissions over the period 2022 to 2035. The Committee received 77 responses from a wide range of organisations and individuals and the responsibility of considering this data transferred to the Commission in December 2019. Read submission
- Action on agriculture emissions (August 2019) - The Bioenergy Association supports in principle the proposals to bring agriculture into the ETS as if done wisely there are a number of mitigation initiatives which farmers can undertake to offset any liabilities. Read submission
- Climate change response (zero carbon) amendment bill (July 2019) - The Climate Change Response (Zero Carbon) Amendment Bill (“ZCB”) is a great start towards assisting the citizens of New Zealand to start reducing greenhouse gas emissions. New Zealand has many bioenergy and biofuels related methods for reducing greenhouse gas emissions which use proven technologies and can be implemented immediately. Read submission
- Process heat in New Zealand: Opportunities and barrier to lowering emissions (February 2019) - The Bioenergy Association welcomes the work being undertaken by MBIE and EECA with regard to process heat. The Association agrees that process heat is an area where transition from use of coal and natural gas can provide significant reduction in greenhouse gas emissions reduction by 2050. Read submission