Reallocate the grandfathered permits each phase-down Benefits: This would ensure the quota system is staying relevant to the current situation. period by reflecting percentage share of the imports in the Costs: This is not preferred, as it would not provide business certainty about the amount they can previous period. import in the next period and would add administrative costs to the EPA. How should Rely on existing mechanisms under the NZ ETS. Benefits: Businesses would only need to report once to the EPA. importation of HFCs be Costs: The information under the NZ ETS may not be fit for purpose. reported? How should recycled Mirror the HCFC requirements; that is, have recycled HFCs See above on what we should include in the permitting system. HFCs be managed? subject to the same permit and phase down as new bulk HFCs. How should the export Have HFC exports included in the import permitting system, Benefits: This would mean an exporter would not be discouraged by having to export new HFCs out of of HFCs be controlled? ie, if an export is made, then the importer would be able to their import quota. import more under their cap. Costs: This would add administrative costs to the EPA and businesses that would be disproportionate to the size of the activity.
Reallocate the grandfathered permits each phase-down period by reflecting percentage share of the imports in the previous period. Benefits: This would ensure the quota system is staying relevant to the current situation. Costs: This is not preferred, as it would not provide business certainty about the amount they can import in the next period and would add administrative costs to the EPA. How should importation of HFCs be reported? Rely on existing mechanisms under the NZ ETS. Benefits: Businesses would only need to report once to the EPA. Costs: The information under the NZ ETS may not be fit for purpose. How should recycled HFCs be managed? Mirror the HCFC requirements; that is, have recycled HFCs subject to the same permit and phase down as new bulk HFCs. See above on what we should include in the permitting system. How should the export of HFCs be controlled? Have HFC exports included in the import permitting system, ie, if an export is made, then the importer would be able to import more under their cap. Benefits: This would mean an exporter would not be discouraged by having to export new HFCs out of their import quota. Costs: This would add administrative costs to the EPA and businesses that would be disproportionate to the size of the activity.