Caustic soda

Summary of submissions

  • The proposed activity definition contained in the consultation document adequately describes the activity which is carried out by Carter Holt Harvey Pulp & Paper.
  • This activity is the initial part of the integrated chemical plants whose main purpose is to produce caustic soda and chlorine dioxide for the pulping and bleaching processes.

Summary of analysis

Matter Analysis
The requirement to define each activity by reference to a physical, chemical or biological transformation of inputs into outputs. The proposed activity definition is consistent with this matter.
The undesirability of activities being defined by reference to the technology employed, the fuel used, the age of the plant, or the quality of the types of feedstock used when the activity is carried out. The proposed activity definition does not reference technology, fuel used, age of plant, or types of feedstock.
The desirability of defining activities:
  • consistently and equitably across industries.
  • in a way that takes into account the impact that definitions may have on business investment, geographical location, and the structure of activities.
  • in a way that takes into account the potential for intermediate inputs produced when the activity is carried out to be substituted for bought-in inputs.
 The proposed activity definition is consistent with other industries and would not result in different treatment depending on how a business is structured.
The proposed activity definition does not enable intermediate inputs to be bought in.
The desirability of there being no overlap between activity definitions. The proposed activity definition does not overlap with other activities.
Any other matters the Minister considers relevant, including activity definitions proposed to be used in Australia. The proposed activity definition reflects the activity definition for production of chlorine gas and sodium hydroxide (caustic soda) solution in Australia.

Recommendation

We recommend that the proposed activity definition for caustic soda should remain substantively unchanged.

Last updated: 10 May 2010