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Information on the Product Stewardship Scheme

Kate A made this Official Information request to Ministry for the Environment

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From: Kate A

Tēnā koe

Pursuant to the Official Information Act 1982, I request the following information. I have itemised my request into clear sections, consistent with the Ombudsman’s guidance for specificity and ease of processing.

1. Correspondence with Specified Organisations
Please provide all correspondence (including emails, letters, file notes, and meeting records) between the Ministry for the Environment and the following organisations, from 1 January 2025 to the present:
a) The Trust for the Destruction of Synthetic Refrigerants (Cool-Safe)
b) A-Gas New Zealand
c) Beijer Ref and any subsidiaries
d) RefDestruct
e) Heat Pump Suppliers Association
f) Institute of Refrigeration, Heating and Air Conditioning Engineers of New Zealand (IHRACE)

2. Synthetic Refrigerants Product Stewardship Scheme
Please provide all briefings, memos, and advice prepared by the Ministry for, or provided to, the Minister for the Environment regarding the synthetic refrigerants product stewardship scheme, from 1 January 2025 to the present.

3. Meeting-Specific Briefings and Notes
Please provide all briefing papers, meeting notes, memos, or other advice prepared by the Ministry for the Minister for the Environment in advance of, or following, the following meetings:
a) A-Gas New Zealand meeting with Mitchell Williamson – 5 March 2025
b) Chemical Destruction Services meeting with Clifton Madgwick, Michelle Kazor, and Aimie Hines – 27 March 2025
c) Trust for the Destruction of Synthetic Refrigerants (Cool-Safe) meeting with Janine Brinsdon and Michelle Kazor – 1 April 2025
d) Heat Pump Suppliers Association meeting with Darryl Rochester and Greg Picker – 15 May 2025

4. Timeliness of Response
I draw your attention to section 15(1)(b) of the Official Information Act, which requires that information be made available “as soon as reasonably practicable.” The Ombudsman has also made clear that agencies should not delay releasing information until the maximum statutory timeframe, nor hold all material for release in a single batch if some is available earlier.

Accordingly, I request that the material covered by this request be released progressively and without undue delay, in tranches if necessary, as soon as it is identified and ready for release.

Ngā mihi nui,

Kate A

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From: Taku Mahi
Ministry for the Environment

Kia ora Kate A,

Thank you for your Official Information Act request received on
02/10/2025.

We will endeavour to respond to your request as soon as possible and in
any event no later than 20 working days after the day your request was
received. If we are unable to respond to your request by then, we will
notify you of an extension to that timeframe.

Please note the Ministry for the Environment will release responses to
selected OIA requests on our [1]OIA responses page shortly after the
response has been sent.

If you have any queries, please feel free to contact us at
[MFE request email].

Please note that this Taku Mahi inbox is not monitored.

Ngâ mihi nui

Ministerial Services Team 

Ministry for the Environment – Manatû Mô Te Taiao

Email: [MFE request email] Website: [2]www.mfe.govt.nz 

8 Willis Street, Wellington Central, Wellington 6011

References

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1. http://www.mfe.govt.nz/about-us/official...
2. http://www.mfe.govt.nz/

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From: Rebecca Archibald
Ministry for the Environment


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Tçnâ koe Kate,

 

Thank you for your below Official Information Act (OIA) requesting the
following information:

 

“Pursuant to the Official Information Act 1982, I request the following
information. I have itemised my request into clear sections, consistent
with the Ombudsman’s guidance for specificity and ease of processing.

1. Correspondence with Specified Organisations
Please provide all correspondence (including emails, letters, file notes,
and meeting records) between the Ministry for the Environment and the
following organisations, from 1 January 2025 to the present:
a)The Trust for the Destruction of Synthetic Refrigerants (Cool-Safe)
b)A-Gas New Zealand
c)Beijer Ref and any subsidiaries
d)RefDestruct
e)Heat Pump Suppliers Association
f)Institute of Refrigeration, Heating and Air Conditioning Engineers of
New Zealand (IHRACE)

2. Synthetic Refrigerants Product Stewardship Scheme
Please provide all briefings, memos, and advice prepared by the Ministry
for, or provided to, the Minister for the Environment regarding the
synthetic refrigerants product stewardship scheme, from 1 January 2025 to
the present.

3. Meeting-Specific Briefings and Notes
Please provide all briefing papers, meeting notes, memos, or other advice
prepared by the Ministry for the Minister for the Environment in advance
of, or following, the following meetings:
a)A-Gas New Zealand meeting with Mitchell Williamson – 5 March 2025
b)Chemical Destruction Services meeting with Clifton Madgwick, Michelle
Kazor, and Aimie Hines – 27 March 2025
c)Trust for the Destruction of Synthetic Refrigerants (Cool-Safe) meeting
with Janine Brinsdon and Michelle Kazor – 1 April 2025
d)Heat Pump Suppliers Association meeting with Darryl Rochester and Greg
Picker – 15 May 2025”

 

Clarification of your request

 

We are currently preparing a response to your request. However, in
assessing the scope of your request, we consider it is very broad and
likely captures a large amount of information. In its current format, the
Ministry may be unable to respond to your request in a reasonable
timeframe and would need to consider refusal under section 18(f) of the
Act.

 

We therefore invite you to refine your request by:

 

o Reducing the scope of part one of your request to correspondence with
one or two organisations of most interest.
o Clarifying the scope of part one and two of your request by
identifying which aspect(s) of the Synthetic Refrigerants Product
Stewardship Scheme are of most interest, i.e.

o data reporting requirements
o training requirements
o domestic destruction facility standards 
o the Trust for the Destruction of Synthetic Refrigerant’s role as the
Product Steward Organisation
o The role of the New Zealand Emissions Trading Scheme in the
destruction/export of synthetic refrigerants
o Progress on the drafting and implementation of the scheme’s
regulations    

 

We consider that refining your request would target the information that
you consider to be most relevant to your interest, while also enabling us
to respond in a reasonable timeframe. If you could please confirm whether
you are willing to refine this part of your request by 5pm Tuesday 21
October that would be greatly appreciated.

 

The Ministry understands that you have also submitted an identical request
to the Minister for the Environment, Hon. Penny Simmonds. Please be
advised that any refinement to this request will likewise apply to the
request submitted to the Minister. 

 

Please note that, regardless of whether a refinement is made, the Ministry
may need to refine further and/or extend the timeframes to respond to your
request in accordance with section 15A(1) of the Act.

 

Thank you in advance and please reach out if you have any questions or
concerns.

 

Ngâ mihi nui

Rebecca Archibald-Williams

Advisor – Official Information and Proactive Release | Kaitohutohu
Ministerial Services | Ngâ Pûnaha Minita
Ministry for the Environment | Manatû Mô Te Taiao

 

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From: Kate A

Tēnā koe Rebecca,

Thank you for your email of 16 October.

I appreciate the Ministry’s consideration of my request. I do not wish to refine the subject matter of Parts 1 and 2 at this stage, but I am open to discussing practical arrangements for staged release if the volume proves larger than anticipated.

To assist both parties in ensuring the request can be met without undue difficulty, I ask the Ministry to:

1 - Provide an estimate of the volume of correspondence identified under Part 1 of my request, broken down by organisation if possible.

2 - Provide an estimate of the number of briefings, memos, or advice papers that fall within Part 2 of my request (synthetic refrigerants product stewardship scheme, from 1 January 2025). My expectation is that the number of such documents will be modest, likely fewer than 25 in total this year, which should be readily manageable within the Act’s requirements.

For clarity, I am not lodging a new request for official information. I am asking the Ministry to provide these estimates as part of its duty under section 18B of the OIA to assist me in making my request manageable.

I also note:

Part 3 of my request is inherently narrow and specific to particular meetings. The relevant briefing notes and papers will already exist as stand-alone documents. In line with section 15(1)(b) of the Act and Ombudsman guidance on progressive release, I ask that this material be released without delay and well within the 20-working-day statutory timeframe.

More generally, I ask that the Ministry adopt a progressive release approach across all parts of the request, releasing material as it is identified and cleared, rather than holding everything until the final day of the deadline.

Ngā mihi nui,
Kate A

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From: Rebecca Archibald
Ministry for the Environment


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Tēnā koe Kate,

 

Thank you for your email of 17 October.

 

Regarding part 1 of your request, our initial search of our email archive
system has captured over 3,000 results. The time and resource commitment
required to assess and review this volume of correspondence to determine
what is in scope of this request is substantial. As it stands, the
Ministry would likely need to consider refusal under section 18(f) of the
Act due to the significant administrative efforts required.

 

To assist us in progressing your request, we would appreciate your help in
narrowing the scope of this part of your request. Specifically, could you
please clarify the topics or themes of information you are seeking in the
correspondence with the listed organisations? This will enable us to
refine our search terms and focus on the material most relevant to your
interests, while also ensuring efficient use of our resources.

 

For part 2, we have identified 31 documents that fall in the current scope
of this part of your request. We are in the process of assessing these for
release and will provide you with an update in due course.

 

Please note that, regardless of whether a refinement is made, the Ministry
may need to refine further and/or extend the timeframes to respond to your
request in accordance with section 15A(1) of the Act.

 

Thank you in advance and please reach out if you have any questions or
concerns.

 

Ngā mihi nui

Rebecca Archibald-Williams

Advisor – Official Information and Proactive Release | Kaitohutohu
Ministerial Services | Ngā Pūnaha Minita
Ministry for the Environment | Manatū Mō Te Taiao

 

 

 

 

 

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From: Kate A

Tēnā koe Rebecca,

Thank you for your update of 20 October. I appreciate the Ministry providing further detail on the search results.

Part 1 – Correspondence
You note that the initial search captured over 3,000 results. To help me make an informed decision about whether refinement is necessary, could the Ministry please:

Provide a breakdown of the approximate number of results by organisation (e.g., A-Gas, Cool-Safe, IHRACE); and

Confirm whether that figure includes duplicates, internal forwards, or newsletters or other generic stakeholder updates, and what search filters or parameters were applied.

Understanding the distribution by organisation will assist me in narrowing the scope in a meaningful and evidence-based way.

Parts 2 and 3 – prioritisation
Given that the Ministry has already identified 31 documents under Part 2 and that the materials under Part 3 are discrete ministerial briefings for specified meetings, I ask that these two parts be prioritised for assessment and release. Receiving them first would materially assist me in refining the correspondence component of my request.

Clarification regarding the Minister’s Office
For clarity, this correspondence and any subsequent consultation relate only to my request to the Ministry for the Environment. I do not intend to rescope or limit the parallel request made to the Minister for the Environment, as the quantity of relevant correspondence held by the Minister’s Office is expected to be far lower than the 3,000 items identified within the Ministry’s systems. If this assumption is incorrect, I would appreciate an opportunity to rescope my request to the Minister, rather than a refusal under section 18(f).

Please note that this correspondence forms part of the consultation process under section 18(b) of the OIA and is not a new request for official information.

Ngā mihi nui,
Kate

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From: Rebecca Archibald
Ministry for the Environment

Tçnâ koe Kate,

 

Please find below the breakdown of the approximate number of email results
by organisation:

 

o The Trust for the Destruction of Synthetic Refrigerants (Cool-Safe) =
2572
o A-Gas New Zealand = 147
o Beijer Ref and any subsidiaries = 0
o Refdestruct = 38
o Heat Pump Suppliers Association = 219
o Institute of Refrigeration, Heating and Air Conditioning Engineers of
New Zealand (IHRACE) = 110

 

These figures reflect all emails exchanged between the domain
‘mfe.govt.nz’ and the respective company domains. As your request was for
“all correspondence,” the results may include duplicates, internal
forwards, newsletters, and other generic stakeholder updates. Please note
that removing these would require a manual review, which is not feasible
due to the significant results until we narrow the search terms.

 

Is there a specific topic or theme information you are seeking in the
correspondence with the listed organisations? Would you like to refine the
correspondence search to be emails specifically about the “Synthetic
Refrigerants Product Stewardship Scheme”? Or would you consider excluding
certain organisations from the scope?

 

To reiterate, without narrowing the scope of the first part of your
request, the Ministry would need to consider refusal under section 18(f)
of the Act due to the significant administrative efforts required, as well
as extensive consultation that may be necessary in order to make a
decision on this request.

 

Please be assured that we have continued progressing the remainder of your
request while awaiting clarification on the correspondence.

 

Ngâ mihi nui

 

Rebecca Archibald-Williams

Advisor – Official Information and Proactive Release | Kaitohutohu

Ministerial Services | Ngâ Pûnaha Minita

Ministry for the Environment | Manatû Mô Te Taiao

 

 

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From: Kate A

Tēnā koe Rebecca,

Thank you for providing the organisational breakdown and further clarification.

To assist the Ministry in progressing the request efficiently, I propose the following approach:

Part 1 – Correspondence
Please proceed for now with the approximately 500 items of correspondence identified with A-Gas NZ, RefDestruct, the Heat Pump Suppliers Association, and IHRACE. This represents a substantial narrowing from the original scope and should be readily manageable within the Act’s requirements. The Ministry may exclude duplicates, automated messages, and other clearly administrative traffic at its discretion.

I do not wish to exclude the correspondence with Cool-Safe altogether. However, I propose that this portion be addressed after the release of information under Parts 2 and 3. Receiving those materials first will allow me to frame any subsequent, more targeted follow-up on the Cool-Safe correspondence. This sequencing is a practical staging of the same request rather than a change of subject matter.

Should the Ministry nonetheless consider refusal under section 18(f), I note that the remaining volume is modest for an agency of this size. The Ombudsman’s published guidance on “large or broadly framed requests” recognises that processing several hundred emails is normally considered reasonable where standard filtering tools can remove duplicates and clearly irrelevant material. In such circumstances, refusal under 18(f) would be difficult to justify when other options remain available.

Parts 2 and 3 – Priority
As previously discussed, please prioritise assessment and release of these parts. Having those documents will materially assist in refining any further request concerning the Cool-Safe correspondence.

Please note that this correspondence forms part of the consultation process under section 18B of the OIA and does not constitute a new request for official information.

Ngā mihi nui,
Kate

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From: Penny Simmonds (MIN)


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Dear Kate  

 

Thank you for your email of 2 October 2025 requesting the following under
the Official Information Act 1982 (the Act): 

 

Pursuant to the Official Information Act 1982, I request the following
information. I have itemised my request into clear sections, consistent
with the Ombudsman’s guidance for specificity and ease of processing. 

 

1. Correspondence and Advice with Specified Organisations 

Please provide all briefings, memos, meeting advice notes, and
correspondence (including emails, letters, and file notes) between you and
your office staff, and the following organisations, from 1 January 2025 to
the present: 

a) The Trust for the Destruction of Synthetic Refrigerants (Cool-Safe) 

b) A-Gas New Zealand 

c) Beijer Ref and any subsidiaries 

d) RefDestruct 

e) Heat Pump Suppliers Association 

f) Institute of Refrigeration, Heating and Air Conditioning Engineers of
New Zealand (IHRACE) 

 

2. Synthetic Refrigerants Product Stewardship Scheme Please provide all
briefings, memos, and advice prepared for you or your office regarding the
synthetic refrigerants product stewardship scheme, from 1 January 2025 to
the present. 

 

3. Meeting-Specific Briefings and Notes 

Please provide all briefing papers, meeting notes, memos, or other advice
prepared for your office in advance of, or following, the following
meetings: 

a) A-Gas New Zealand meeting with Mitchell Williamson – 5 March 2025 

b) Chemical Destruction Services meeting with Clifton Madgwick, Michelle
Kazor, and Aimie Hines – 27 March 2025 

c) Trust for the Destruction of Synthetic Refrigerants (Cool-Safe) meeting
with Janine Brinsdon and Michelle Kazor – 1 April 2025 

d) Heat Pump Suppliers Association meeting with Darryl Rochester and Greg
Picker – 15 May 2025 

 

 

My office does not hold any further information relating to parts 2 and 3
of your request that is not already held by the Ministry for the
Environment (the Ministry), who I understand has also received a similar
request from you. In these circumstances, I consider it is more
appropriate for the Ministry to respond to these parts of your request,
therefore the information requested will be provided in the departmental
Official Information Act request you have made to the Ministry for the
Environment.

 

I am also extending the timeframe for response to part 1 of your request
under section 15A(1)(b) of the Act, as consultations necessary to make a
decision on the request are such that a proper response cannot reasonably
be made within the original timeframe. 

 

We will now respond to your request on, if not before, 28 November 2025,
which is an extension of 20 working days.  

 

You have the right to seek an investigation and review by the Office of
the Ombudsman of my decisions relating to this request, in accordance with
section 28(3) of the Act. The relevant details can be found at:
[1]www.ombudsman.parliament.nz. 

 

Kind regards,

Office of Hon Penny Simmonds

Minister for the Environment | Minister for Vocational Education

Associate Minister for Social Development and Employment
MP for Invercargill
 

P: 04 817 6815

Private Bag 18041, Parliament Buildings, Wellington 6160, New Zealand

Authorised by Hon Penny Simmonds, Parliament Buildings, Wellington

 

Disclaimer: The information in this email (including attachments) is
confidential and may be legally privileged. If an addressing or
transmission error has misdirected this email, please notify the author by
replying to this email and destroy the message. If you are not the
intended recipient, any use, disclosure, copying or distribution is
prohibited and may be unlawful.

 

References

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1. http://www.ombudsman.parliament.nz/

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From: OIA
Ministry for the Environment


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Tēnā koe Kate,

 

Thank you for your response.

 

We would need to individually assess each of the 500 emails to confirm
they are in scope, manually remove duplicates, consult with relevant
stakeholders, incorporate their feedback, and redact any sensitive
information from each email prior to release. It would take a significant
amount of time and administrative effort, even with a substantial
extension of time to provide a decision on your request. In these
circumstances, we consider it is necessary to refuse this part of your
request under section 18(f) of the Act as the information requested cannot
be made available without substantial collation and research.

 

Regarding your request to receive the Cool-Safe emails following a
response to the other parts of your request; the Act does not allow the
Ministry to delay the release of information without first providing a
decision on the request. We cannot make an informed decision without first
reviewing and assessing all Cool-Safe material. Again, given the amount of
information to assess, we would not be able to undertake this in a
reasonable timeframe and must refuse this part of your request under
section 18(f) of the Act. However, we would encourage you to submit a new
request once you have reviewed any further information released. We would
be happy to work with you on a new request under the Act so that we can
provide you with information that is of use to you. Communications on a
specific aspect of the product stewardship scheme may hold the information
you are seeking.

 

It is likely we will be able to provide you with a more fulsome response
to parts 2 and 3 of your request. However, the Ministry is extending the
timeframe for our response to your request under section 15A(1)(b) of the
Act, as consultations necessary to make a decision on the request are such
that a proper response cannot reasonably be made within the original
timeframe.

 

We will now respond to parts two and three of your request on, if not
before, 28 November 2025, which is an extension of 20 working days.

 

You have the right to seek an investigation and review by the Office of
the Ombudsman of the decisions relating to this request, in accordance
with section 28(3) of the Act. The relevant details can be found at:
[1]www.ombudsman.parliament.nz.

 

Ngā mihi nui

 

Chelsea Cooper (she/her)

Acting Manager | Kaiwhakahaere

Ministerial Services
Ministry for the Environment – Manatū Mō Te Taiao

 

[2][email address] | environment.govt.nz

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generated

 

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From: Kate A

Tēnā koe Chelsea,

Thank you for your letter of 31 October 2025.

I note the Ministry’s decision to refuse Part 1 of my request under section 18(f) of the Official Information Act 1982 (the Act) and to extend the timeframe for Parts 2 and 3 under section 15A(1)(b).

This position is difficult to reconcile with both the scale of the material involved and the Ministry’s obligations under the Act. The Ministry has stated that approximately 500 emails were identified for Part 1, and 35 documents have already been identified as falling within scope for Parts 2 and 3. These figures are modest for a central agency and should not require refusal or prolonged extension. Moreover, the 35 documents were identified by at least 20 October 2025, yet the Ministry now asserts that further consultation prevents completion within the original 20-day statutory period.

Under section 15A(3), the Ministry must explain the reasons for any extension. Could you therefore specify what consultations are required, with whom, and why those consultations could not reasonably have been completed within the original timeframe? The obligation to consult other parties does not, in itself, justify an extension or refusal unless the Ministry can demonstrate that the process is unusually complex or voluminous.

Regarding Part 1, a refusal under section 18(f) is not justified merely because manual review and redaction are required. The Ombudsman’s published guidance on sections 18(f) and 18B makes clear that agencies are expected to consider all reasonable alternatives, such as progressive release under section 15(1)(b), partial processing, or an extension under section 15A, before resorting to refusal. The claim that the Act “does not allow” progressive release is incorrect. Section 15(1)(b) explicitly requires that information be made available as soon as reasonably practicable, which encompasses release in tranches where appropriate.

The Minister for the Environment has already advised that equivalent information would be released by the Ministry, yet the Ministry has delayed the remaining parts. This inconsistency results in an effective denial of access under section 15(1).

I therefore request that the Ministry:

1 - Reconsider its refusal of Part 1, and provide the estimated time or work hours required to process the 500 items so that a proportionate and staged approach can be agreed; and

2 - Explain the basis of the 20-day extension for Parts 2 and 3, including what specific consultations are being undertaken and why these could not have been completed within the original statutory period.

Please treat this correspondence as forming part of the consultation and clarification process under sections 15A(3) and 18B of the Act. It does not constitute a new request for official information.

For transparency, I have referred this matter to the Office of the Ombudsman for investigation, given the refusal under section 18(f), the extended delay, and the inconsistency between the Minister’s office and the Ministry.

Ngā mihi nui,
Kate A

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From: OIA
Ministry for the Environment


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Kia ora Kate,

 

Thank you for your response. I have provided explanations below, as
requested.

 

Refusal under section 18(f)

 

On the assumption that each of the 500 emails is in scope of your request,
we estimate it would take around 25-30 minutes per email to download,
thoroughly assess, consult, mark up any necessary redactions, and finalise
for release. This equates to approximately five working weeks in total.
This timeframe does not account for other administrative work such as
approvals, preparing consultation emails, aggregating feedback etc. It
also assumes that staff members do not undertake their usual work and are
only focused on reviewing these documents.

 

The Ministry has considered whether charging or extending the timeframe
for responding to your request would help us grant your request, as
required by section 18A of the Act. However, due to large amount of
information potentially in scope of your request, the Ministry does not
believe charging for this information, or extending the timeframe for
response, would allow for your request in its current form to be granted
without substantial collation or research that would have a significant
and unreasonable impact on the Ministry’s operations.

 

To reiterate, while the Act allows for release of information without
'undue delay', such as in tranches, the Ministry is first required to
provide a decision on your request - i.e. agreeing to release all material
to you, in full or in part. Without first assessing the emails for
release, we are unable to provide a considered, accurate decision on your
request. Therefore, we cannot release information to you in tranches. 

 

For these reasons outlined above, the Ministry is maintaining its refusal
of your request in its current form under section 18(f) of the Act, as the
information requested cannot be made available without substantial
collation or research.

 

The Ministry would be happy to work with you on a new request under the
Act so that we can provide you with useful information in a reasonable
timeframe.

 

Extension of parts two and three of your request

 

Consultation is required with all parties where the Ministry holds
correspondence in scope. This includes, but is not limited to, A-Gas New
Zealand, RefDestruct, CoolSafe and IHRACE.

 

Consultation could not be completed within the original timeframe because
of the amount of time required to first identify, collate and assess these
documents, prior to engaging with the above listed third parties.

 

The Ministry needs to give these parties a reasonable amount of time to
consider the information for release and provide feedback, to allow us to
make an informed decision on your request. The time and effort required to
undertake these tasks could not be completed within the original
timeframe.

 

Please be assured we will endeavour to provide you with information as
soon as possible.

 

Ngâ mihi nui,

 

Lachlan Brown ([1]he/him)

Kaihautû rôpû – Ngâ Môhiohio Ôkawa me te Tuku Kakama

Team Leader – Official Information and Proactive Release
Ministry for the Environment – Manatû Mô Te Taiao

 

 

 

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