This page provides supporting information for firms who need to provide industrial allocation data. It supports the instructions in the industrial allocation guide to data collection 2023.
A firm’s data form can be submitted by either the parent company or by each of its individual subsidiaries.
If the parent company provides the data form on behalf of its subsidiaries it should state that this is the case and provide details of each subsidiary in the basis of preparation form.
In the basis of preparation form you need to provide sufficient detail to justify assumptions and methods used. This is to enable the Ministry to reproduce the emissions, revenue and production values if the raw data was requested.
Any assumptions and methodologies you apply should be reasonable and clearly explained in the basis of preparation form. If you provide insufficient detail the Ministry will contact you to provide additional detail.
The declaration form sets out who should sign it.
If an incorporated body, the declaration form should be signed by an authorised person such as the chief executive officer or another executive team member. You must provide the contact details for the person signing in the data and basis of preparation forms.
As per emissions rule 10, you should describe the approach used in the basis of preparation form for cases of uncertainty to demonstrate materiality is below five percent.
Data preparation rule 2 does not require detailed estimates of uncertainty. However, if some data is particularly uncertain information is required on these uncertainties.
An estimate of uncertainty is not required for the emission factors as provided in the data form.
You should retain records to demonstrate that the data supplied is reasonable. It is likely that some record retention systems may not be able to hold significant volumes of data, such as meter readings, over many years. Therefore, it is acceptable if you analyse available records, prepare summary schedules of these records and copy key data samples into these summary records. Ideally the minimum resolution of summary data should be monthly.
Records should be kept in electronic format. The Climate Change Response Act 2002 requires that records be retained for seven years.
Information presented to and held by the Minister and Ministry could be released under the Official Information Act 1982 (the OIA).
There may be grounds in the OIA for withholding information. For instance, the information may be withheld if releasing it would:
The grounds for withholding must always be balanced against public interest considerations that may justify release.
Although the Ministry cannot give any guarantees as to whether information will be withheld under an OIA request, consider advising in your response the data you consider to be commercially sensitive. It will be assumed that any information not identified as commercially sensitive may be released in response to an OIA request. See further information on the OIA [Ombudsman website]
Assumptions should be appropriate for the characteristics of each subsidiary firm. Each subsidiary firm carrying out an activity must endeavour to provide accurate data. Each subsidiary firm may have differing records and methods for recording and retaining data which will be reflected in the data form and basis of preparation form.
Where data does not exist, there are a number of ways these data gaps can be estimated. The approach should be disclosed in the basis of preparation form. An example is where data is not available for a particular month (or other period).
It would be acceptable to estimate the missing data by reference to a comparable month (or other period of time) for which data is available. This data may be comparable in terms of the level of output produced or the level of other inputs used and could therefore be used to estimate the missing period’s consumption data.
Alternatively, where production is relatively constant over time, an average over a 12-month period could be calculated and used as an estimate for the missing period. Alternatively, data may be available from a third-party source such as a utility bill which may be used to derive the missing data.
Recognising the impact that COVID-19 may have had on a firm’s production, Data preparation rule 3 allows the firm to nominate either their 2019/20 or 2020/2021 data to be disregarded from allocative baseline and emissions intensity calculations. The firm also has the option not to nominate data from either of these years.
When preparing the data and basis of preparation forms, you must still provide data for all years regardless of whether or not they choose to nominate a COVID-19 opt-out year. If the firm chooses to disregard the data from one of the COVID-19 affected years, justification of this decision should be disclosed in the basis of preparation form.
Data forms contain one co-generation tab by default. If the firm has more than one co-generation plant contact the Ministry for a sheet with additional co-generation tabs.
The Industrial allocation guide to data collection 2023 explains the subtle differences between the three different outputs required for sheet two of the data form. For many activities the values entered will likely be the same.
Revenue for the purpose of determining an emission intensity is calculated based on the total value of the product produced – not on the revenue a firm might have recorded on their statement of financial performance.
The total number of activity outputs produced is multiplied by the market price to determine the revenue if the firm were to sell all the product it produced in a given financial year.
This output is used solely to determine a ‘market price’ for the activity output.
To calculate an appropriate market price, only sales to ‘external’ parties are to be included (ie, the transaction is to an unrelated party, or if it is to a related party it is at an arm’s length price).
In calculating the market price only revenue from external sales can be entered into box 5. This means the market price is not diluted by including internal sales. This quantity could be more or less than the amount of activity outputs produced. This depends on the level of output retained as inventory at year-end.
This output is the parameter used to determine the allocative baseline – and subsequently the parameter that firms record each year to determine the total amount of allocation they receive. It is seen as a natural quantity to which emissions can be attributed.
For many activities the units of product produced will be the same as the overall activity output produced.
Some activity definitions have slightly different specifications for product used as a basis for allocation and output. This is usually due to purity or compositional differences (eg, for the production of ethanol the basis of allocation is defined as 100 per cent pure ethanol, whereas the output is defined as ethanol with a concentration equal to or greater than 95 per cent).
For some activities, there will be multiple activity outputs or products (basis of allocation) defined in the Gazette notice. You should look to re-create sections 3 and 4 of the basis of preparation form for each individual activity output/product respectively.
Revenue rule 3 requires that an appropriate market price must be calculated from revenue received from all external activity output sales or by using an observable market price.
If actual sales data is used, only external sales of the output specified in the Gazette notice may be included in calculating an appropriate market price. Internal sales of output for subsequent further processing should not be included, nor should sales of further processed output be included. Refer to the Industrial Allocation Guide to Data Collection for the definition of external sales.
All revenue from sales of activity outputs (as defined in the Gazette notice) together with associated production data must be disclosed in the revenue and production information section contained in the data form. If an intermediate product is produced which is sold to other firms, or goes into secondary processing, and is not a specified activity output, the associated revenue and production must NOT be included.
Revenue rule 1 states that revenue must be calculated using an appropriate market price. In the Industrial allocation guide to data collection 2023, an appropriate price is defined by its time period, location and product. It is possible that an observable market price may need to be adjusted to ensure it is a ‘plant gate’ price relevant to New Zealand market conditions. Any adjustments to an observable market price used must be disclosed in the basis of preparation form.
If the firm’s revenue from sales data includes the recovery of transport costs, all transport costs associated with the movement of activity outputs to that market should be included in Box 6.
For example, if the sale is at some point distant from the plant - Box 6 would contain transportation costs such as road and sea freighting and port costs.
Internal transportation costs should not be included in Box 6 as these are prior to the actual ‘gate’ of the firm.
Transport costs do not need to be included in Box 6 if the firm’s revenue from sales data does not include transport costs (ie, sales are at the plant gate).
Rebates would generally be accrued on an ongoing basis during the financial year for financial accounting purposes.
When a firm’s financial year does not align with the specified year, you will need to make reasonable and transparent accruals of financial, production, and emissions data to the specified year.
Adjustments should be made to the revenue data to account for any customer rebates which may be outstanding. This needs to be stated in the basis of preparation form.
Emissions rule 10 applies only to emissions data.
The revenue data provided must comply with the revenue rules set out in the Gazette notices. In addition and consistent with the data preparation rules if revenue data has needed to be estimated then the methods, assumptions and calculations used, and any uncertainties arising must be disclosed in the basis of preparation.
Units sold externally can be greater than the units of activity output produced in a specified financial year due to changes in inventory levels.
This can be changed on a year-to-year basis.
In the basis of preparation form firms should explain why different methods have been used for different financial years.
Where a firm conducts the same activity at multiple sites, the data should be aggregated across all sites to be entered into the data form.
For most data categories this simply requires the data across all sites to be added together. For the specific case of transport costs and the calculation of a gate price a different approach will be required.
The revenue rules require the calculation of prices and revenues on the basis of a gate price, but the gate price may differ between multiple physical locations. You will need to estimate the transport costs to each plant and use these to estimate the gate price.
You can use either an approach based on actual sales revenue or an observable market price for this.
The steps below outline:
For each site and for each activity output you are required to record the:
The total across all sites should be entered into the data form.
A single market price per unit should be used that is representative of the output from all sites (refer to guidance). Enter this into the data form.
Calculate a weighted average of transport costs per unit for all sites by:
The purpose of the above is to enable the data form to calculate a gate price per unit. This is multiplied by the total number of output units produced to estimate total revenue based on the market price.
In both cases, all workings should be provided in the basis of preparation form to show how aggregated inputs have been calculated.
Emissions from activities such as head office, marketing and administration are likely to be less than five per cent of total emissions.
Emission rule 10 provides for simplified and reasonable emission calculation methods to be used in these situations. Such methods may be derived from sources such as floor space, head count, or likely standard energy data including ratings for equipment and lighting used.
The method adopted should be reasonable for the activity’s specific circumstances and be disclosed in the basis of preparation form.
Emission rule 11 requires all emissions associated with the activity to be included. Emission rule 10 allows simplified and reasonable calculation methods to be used for small emissions sources.
This will depend on the description of the activity and the directions in the Gazette notice calling for information as to what are included emissions and what are excluded emissions.
Where the description of the activity and the included emissions encompass a part of the activity that is carried out off-site or by another person, the emissions from that part of the activity will need to be included in the information provided.
Emissions from the transport of prepared materials between sites are excluded as specified in schedule 3 of the Gazette notice.
The data form treats waste oil and used oil in the same way and therefore it is not necessary to distinguish between them.
Transmission and distribution losses need to be excluded from emissions associated with electricity.
The intention is to not differentiate between firms undertaking the same activity at different locations. Transmission and distribution charges are the cost of transporting electricity to the geographic location of the activity. This approach is consistent with the approach adopted for gas distribution losses and the transportation of other inputs to the location where the activity takes place.
The calorific value for each type of coal (or used/waste oil or tyres) needs to be representative of the amount used.
Many firms will periodically test the calorific value of the coal used in the activity. For others, suppliers will have tested the calorific value of the coal and provided this information to their customer.
The data form requires only one calorific value for each coal type to be entered for all of the specified financial years.
Where there are a range of calorific values used for a particular coal type, you should apply a weighted average calorific value which most accurately portrays the calorific value of the coal consumed by the activity during those years.
The basis for the calorific value used is required to be disclosed in the basis of preparation form.
All calorific values should be stated in gross terms (higher heating value), not net terms (lower heating value).
Emissions rule 10 applies where small emissions sources are in aggregate estimated to be no more than five percent of total emissions from the activity. In this context, ‘in aggregate’ should be interpreted to mean all specified financial years.
As detailed in the Industrial Allocation Guide to Data Collection 2023, where the contract to purchase natural gas specifies the field from which the natural gas is obtained, the emissions factor for that field must be used.
A natural gas emissions factor from Table 10 in Schedule 2 of the Climate Change (Stationary Energy and Industrial Processes) Regulations 2009 must be used. The particular natural gas emissions factor that must be used will depend on how gas is supplied.
Where natural gas is supplied through a dedicated supply line, you must enter data against the emissions factor for that specific field.
Where natural gas is not supplied through a dedicated supply line and the contract to purchase natural gas does not specify the field from which the natural gas is obtained, the national average emissions factor must be used (see data form).
Where the contract to purchase natural gas does specify the field(s) from which gas is obtained and the natural gas is supplied through an integrated network (that also transports gas from other fields), one of the following emissions factors must be used:
Although the electricity consumed by functions outside the activity may be immaterial in size, they are material in nature because they are specifically listed as excluded emissions in the Gazette notice.
Therefore, this electricity consumption must be excluded from the data provided. Some of these adjustments may be immaterial in size in which case a reasonable estimation would be acceptable consistent with emissions Rule 10, accompanied by disclosure of the basis of the estimation in the basis of preparation form.
Schedule 3 of the Climate Change Response Act 2002 identifies which persons must be participants to the Emissions Trading Scheme on the basis of the activities they undertake.
A person may be exempted from being a participant under the Climate Change (General Exemptions) Order 2009 or under section 60 of the Climate Change Response Act 2002 when carrying out an activity covered by that Order if they fall under a threshold.
|
Using geothermal fluid to generate electricity or industrial heat |
4,000 tonnes of CO2-e per annum |
|
Combusting used or waste oil to generate electricity or industrial heat |
1,500 tonnes of used or waste oil per annum |
|
Importing coal |
2,000 tonnes of coal per annum |
|
Producing iron or steel |
100 tonnes of carbon added per annum |
If, due to exemption there is no obligation to surrender units, then no assistance will be provided for the emissions from these sources. However, the emissions still need to be specified in the data form as per emissions rule 4. When determining eligibility or allocative baseline for an activity, the Ministry will assess whether a threshold is met and disregard those emissions where appropriate.
It is likely that some firms will need to apportion included or excluded emissions sources to fulfil the requirements of the Gazette notice. The application of this apportionment is not necessarily intuitive.
Firm A is using its utility bills to calculate its electricity usage. It has determined it has used 150 GWh for the 2016/17 financial year which excludes transmission losses.
Its electricity consumption includes electricity usage of the head office, the production of its product, the packaging and distribution centre, and its storage warehouse. In this instance only the electricity used for the production of its product is an eligible emissions source.
To subtract the excluded emissions the firm has used the following process.
The process of apportioning these excluded emissions was a multi-step process that required a significant amount of approximation. In the basis of preparation form all of these steps require explanation of where the numbers originate (such as the power rating of a packaging machine) and the rationale behind assumptions.
If a firm produces multiple products that use the same electricity supply and only one of its products is subject to a Gazette notice then similar apportionments will need to be made to exclude emissions from the out-of-scope product. Conversely a similar exercise might be done if a firm needs to include an emission source that is not accounted for in its metered or billed energy use.
This exercise does not only apply to electricity usage but to any energy source that is responsible for emissions. For example, natural gas that is used to heat a storage area and which uses the same supply line as the natural gas that goes into production would need to be deducted.
To reiterate the point above – if a firm needs to apportion its emissions the process needs to be detailed in its basis of preparation form. If the process is transparent and reasonable apportionment methods have been used, it is likely to satisfy the Ministry. We will be in contact if we have concerns about the methods used.
If a firm fails to provide the data required under the Notice, the Minister for Climate Change may give further notice to provide information within 10 working days. Failure to comply may render that firm ineligible for an allocation, in accordance with section 161D(6) of the Act.
In addition, under section 132 of the Climate Change Response Act 2002 the penalties for knowingly providing altered, false, incomplete or misleading information consist of a fine of up to $25,000 for an individual or $50,000 in the case of a body corporate.
If such altered, false, incomplete or misleading information is provided with intent to deceive and for the purpose of obtaining any material benefit or avoiding any material detriment, section 133 of the Act provides for penalties of up to five years imprisonment and/or a fine of up to $50,000.
These checks will ensure that the data, basis of preparation and declaration forms are complete and that the information contained within them is reasonable and consistent with the data collection rules.
In addition, the Ministry may conduct more detailed verification of the information provided in the future. The Minister has powers under the Climate Change Response Act 2002 to require any further information considered necessary to enable the verification of the accuracy of the information provided. This may include source data or other records. The Climate Change Response Act 2002 requires that records be retained for seven years.
It is important that any assumptions made by a firm regarding its revenue and emissions data are representative of the firm’s position.
If different firms conducting the same activity make materially different assumptions in their basis of preparation form, it is likely that the Ministry will contact the firms to gain an understanding of the differences.