Submitter details
1. Submitter name
Individual or organisation name
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WasteMINZ
Section A: NZ ETS sector-specific regulatory updates and improvements
8. Do you support updating the waste DEF used to calculate UEFs?
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Yes
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No
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I don't know
Please explain your answer here.
Yes we support this change. We understand this would apply to the equation in Clause 23C(1)(g) of the Regulations to bring this in line with the current DEF.
9. Do you support using historical waste composition to inform the calculation of UEFs?
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Yes
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No
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Please explain your answer here.
Yes we support using historical default waste composition where this is based on data for Class 1 landfills throughout New Zealand. We understand that this will result in a change to Clause 23C(2)(b)(ii), and that Schedule 3 will be expanded to present the default waste compositions to be applied for specific time periods based on the available Class 1 composition data.
10. Do you support allowing landfill gas to be destroyed offsite, potentially by a third party?
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Yes
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No
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Yes we support the ability to destroy landfill gas away from the landfill facility, and for additional parties to be involved in the management, beneficial use and destruction of landfill gas.
We are aware of some landfill operators currently working with, or considering working with, third parties for the management and destruction of landfill gas, including both onsite and offsite activities.
We are aware of some landfill operators currently working with, or considering working with, third parties for the management and destruction of landfill gas, including both onsite and offsite activities.
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About WasteMINZ
WasteMINZ, formed in 1989, is the largest representative body of the waste, resource recovery and contaminated land sectors in Aotearoa New Zealand. Our aim is to ensure an evidence-based approach to addressing these challenges which allows Aotearoa New Zealand to thrive.
The proposed changes to the UEF Regulations (in particular proposal 4a and 4b) will have a material impact on the UEF values for some waste participants. For waste participants who have not achieved 90% efficiency, the changes could result in significantly higher UEF values. This increased cost will need to be accounted for, and likely passed on to customers.
Disposal rates are often subject to contractual arrangements and are fixed for set periods of time. As such, advanced notice is needed for operators to implement any rates changes. For facilities operated by Councils, this often aligns with the local government financial year (July - June).
The proposed changes to the UEF Regulations are currently intended to come into effect on 1/1/2025. This means that UEFs for the 2024 calendar year would need to reflect these changes, and they would apply to waste that has already been accepted. Operators have no ability to recoup these additional costs, and in some cases, will not be in a position to adjust their rates until July 2025. As such, we request that the changes to the UEF Regulations do not come into effect until 1/1/2026 or 1/1/2027 in order for waste participants to have sufficient time to account for the changes in their pricing structures.
As the largest industry group representing the waste and resource recovery sector, we would welcome the opportunity to view the draft wording for the UEF Regulation changes before they are gazetted, for example in the form of an exposure draft. This could help provide surety to MfE that the changes reflect MfE's intentions, and to avoid any misinterpretation or unintended outcomes of the changes.
WasteMINZ, formed in 1989, is the largest representative body of the waste, resource recovery and contaminated land sectors in Aotearoa New Zealand. Our aim is to ensure an evidence-based approach to addressing these challenges which allows Aotearoa New Zealand to thrive.
The proposed changes to the UEF Regulations (in particular proposal 4a and 4b) will have a material impact on the UEF values for some waste participants. For waste participants who have not achieved 90% efficiency, the changes could result in significantly higher UEF values. This increased cost will need to be accounted for, and likely passed on to customers.
Disposal rates are often subject to contractual arrangements and are fixed for set periods of time. As such, advanced notice is needed for operators to implement any rates changes. For facilities operated by Councils, this often aligns with the local government financial year (July - June).
The proposed changes to the UEF Regulations are currently intended to come into effect on 1/1/2025. This means that UEFs for the 2024 calendar year would need to reflect these changes, and they would apply to waste that has already been accepted. Operators have no ability to recoup these additional costs, and in some cases, will not be in a position to adjust their rates until July 2025. As such, we request that the changes to the UEF Regulations do not come into effect until 1/1/2026 or 1/1/2027 in order for waste participants to have sufficient time to account for the changes in their pricing structures.
As the largest industry group representing the waste and resource recovery sector, we would welcome the opportunity to view the draft wording for the UEF Regulation changes before they are gazetted, for example in the form of an exposure draft. This could help provide surety to MfE that the changes reflect MfE's intentions, and to avoid any misinterpretation or unintended outcomes of the changes.