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Forestry in the ETS: Second set of proposed cost recovery fees and charges


DEADLINE IS 3.5.2023

This submission opportunity is relevant to NTCF as it involves the NZ carbon emission trading scheme


The Ministry for Primary Industries is seeking feedback on changes to cost recovery settings for the forestry in the Emissions Trading Scheme (ETS). For this consultation, they’re looking at introducing new fees for 22 services and an annual charge for 6 services. This is the second set of changes to ETS cost recovery settings. MPI consulted on the first set in September and October 2022 and the changes came into effect in January.

MPI are looking at introducing new fees for 22 services and an annual charge for 6 services.

The charges will recover the costs of running Te Uru Rākau – New Zealand Forest Service’s new operating model for the forestry ETS. In recent years, participation in the ETS has grown rapidly because of increases in the carbon price and the profitability of participation. A new operating model and technology solution was needed to properly manage this growth.

Growing participation and the introduction of the new operating model have meant that the costs of maintaining the forestry ETS have increased significantly over the past several years. These costs are currently being paid for with taxpayer funding. These new charges will reduce the impact on taxpayers and ensure that those who benefit from the forestry ETS are paying the costs for maintaining it.

The proposed new fees will cover services that provide direct benefit to individual participants, such as adding Carbon Accounting Areas or applying to offset deforestation. The annual charge will cover services that provide benefits to participants as a whole, such as the new IT system and the administration and management of general enquiries.

Many of the fees that carry a higher cost cover bespoke services that apply to specific, optional situations. It is expected that most participants, particularly smaller forest holders, will not need to use these services.

The annual charge is proposed to be based on the total area of post-1989 forest land that the person is recorded as a participant for at the point in time. It is considered that the initial annual fee will be charged at the earliest opportunity following the Regulations coming into effect and will be pro-rated based on the number of months remaining in the year.

Full details are in the consultation document here.

How to make a submission:

Email your submission to

MPI encourage you to use their  submission template [DOCX, 82 KB]

While they prefer email, you can post written submissions to:

Cost recovery
Ministry for Primary Industries
PO Box 2526
Wellington 6104
New Zealand

Note that all, part, or a summary of your submission may be published on this website. Most often this happens when MPI issue a document that reviews the submissions received.

People can also ask for copies of submissions under the Official Information Act 1982 (OIA). The OIA says MPI must make the content of submissions available unless they have good reason for withholding it. Those reasons are detailed in sections 6 and 9 of the OIA (here)

If you think there are grounds to withhold specific information from publication, make this clear in your submission or contact MPI. Reasons may include that it discloses commercially sensitive or personal information. However, any decision MPI makes to withhold details can be reviewed by the Ombudsman, who may direct MPI to release it.

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