A Redesigned NZ ETS Permanent Forest Category

Introduction
Climate Karanga Marlborough is a citizen’s organisation of about 120 members with the purpose of educating the public and our decision-makers as to the dangers of climate breakdown, and to support local and national decision-makers to take action.
We submitted on the earlier permanent forestry consultation and were disappointed that now MfE is asking for a second submission.  We appreciate the complexities, but also recognise that the Climate Change Commission has put forward recommendations similar to what we've presented here. 

We urge the government and MfE to work with the Commission and endeavour to follow their recommendations.  They are the experts charged to advise the government on these matters.  The government should use them.

Question 1: How do you think the Inquiry’s recommendations could be reflected in proposals to redesign the permanent forest category?
The inquiry examines a quite pertinent and recent failure in forestry management, so its recommendations are relevant.  We agree with many of the Inquiry’s recommendations, in particular Recommendation 36 (which refers to Paragraph 54 and second bullet point): “incentivising indigenous and slower-growing exotics (such as through front-loading the earning of credits – effectively a loan, and not a fake credit).”

Question 2: Do you agree with our assessment criteria for the redesigned permanent forest category? If not, what would you change and why?
There is no mention of wildfire risk, which is a major problem in forests overseas.  Many exotic tree species have adapted to wildfire and depend upon wildfire for regeneration.  As such, many of these species will burn more readily than tree species not adapted to fire. 
Wildfire not only risks returning sequestered carbon to the atmosphere, potentially negating whole carbon farming enterprises, it also risks local ecological devastation and damage to nearby infrastructure and communities and the lives of firefighting personnel.
An additional criteria should be: Permanent forests should be designed to minimise risks of wildfire, disease, climate disruption and wilding. 
On an additional note, the assessment criteria in Item 2 is not clear.  How do permanent forests improve climate adaptation and resilience other than by stabilising erosion prone land (mentioned page 19), which is an environmental outcome and mentioned already in Item 3?  Why is Item 2 criteria included?

Question 3: Do you think any of these criteria are more important than the others? If so, which criteria and why?
Of primary concern should be the risks from climate change, disease and wilding.  Forest inability to withstand drought, disease and wildfire have resulted in the devastation of large tracts of forest overseas.  As the climate warms, we can expect the same situation here.  There is also the risk of disease, which is particularly high in monoculture exotic forests.  Disease pathogens are projected to spread more readily as the planet warms.  Finally, there is the risk of wilding, which can upset and degrade nearby pasture, grasslands and regenerating forests.  It does little for carbon sequestration, environmental co-benefits, Maori aspirations and local communities if forest die, succumb to wildfire or spread unwanted weed species.  The long term risks to forests should be the primary concern and permanent forest design criteria.  Remember, right tree, right place.

Of secondary concern are the environmental benefits in terms of water quality, erosion control, habitat for indigenous biodiversity, etc.  We need forests that both survive long term and provide ecosystem services to wildlife and communities.  The lack of erosion control afforded by recently harvested production forests in Tairawhiti was a major factor in the damage due to Cyclone Gabrielle (Item 3).
The tertiary concern with respect to the nation’s net zero emissions target for 2050 and beyond, is the ability of permanent forests to sequester emissions long-term (Item 1).  Contrary to what is stated in the consultation document (page 15), and as the Climate Change Commission has pointed out, some permanent exotic forests (particularly pine forests) will provide carbon offsets in the short term, through 2050, but will reach senescence and stop sequestering more carbon after about 60 years, therefore providing few offsets in the decades after 2050, when New Zealand is expected to remain “net zero”.  This is the reason the Climate Commission recommends significant indigenous afforestation.  This criteria is listed as tertiary because many different combinations of exotic and indigenous forests will sequester carbon long term, but not all will survive to do so.  In addition, the country’s international commitments are simply words on paper; real life concerns for a healthy environment are more important than these words.
Support for Maori aspirations and rural communities can be designed by economic levers put into whatever policy is decided. 

Question 4: Of these options, what is your preferred approach? Why? Are there other options you prefer, that we haven’t considered? (Note, options 1.2a and 1.2b are not mutually exclusive)
This is a difficult “either/or”.  We support either Option 1.1 or Option 1.2 depending upon assurances that the end goal is stable mature forests which sequester carbon and provide a habitat for wildlife and other ecosystem services. 
While we feel that indigenous forests are preferable in most circumstances, there may be forest types and locations where exotic forests or mixed forests provide better long-term stability, wildfire and disease resistance and ecosystem services.  The New Zealand climate is changing and our indigenous forests may not cope well with a changing climate in all areas.  In these cases, exotic forests may be better adapted to the conditions.

At the same time, we remain sceptical that transition forests will be successful in establishing permanent indigenous forests in all settings, particularly when first established with radiata pine.  Pine is prone to wildfire and wilding.  Its only advantage is quick sequestration rate.  Transition forestry models based upon pine need to be carefully managed and should come with added precautionary measures against wildfire and wilding to nearby properties.

We support both Options 1.2a and 1.2b.  We believe that, since Maori are to retain title to their land for perpetuity, they will be less prone to make short sighted forestry choices.

We do not agree with Option 1.2c, an exception for small scale exotic forests planted on farms.  This, we feel, will be driven mostly by short-term economic incentives and thus be prone to short-sighted forestry choices and mismanagement.  Who is to stop a farm business from claiming bankruptcy and leaving a mismanaged or unmanaged, decaying and fire-prone pine forest for the rest of us to deal with?
 
Question 5: If you support allowing exotic species under limited circumstances, how do you think your preferred ‘limited circumstance’ should be defined? (for example, if you support allowing long-lived exotics to register, how do you think we should define ‘long-lived’?)
We feel that exotic permanent forests should meet the following criteria:

1. Deemed as fire and disease-resistant as the average of local indigenous species.  In other words, exotic forest should not add to the fire risk of local forests and should not be known to be vulnerable to diseases which might be present or introduced.
2. Should not be a source of wilding, especially where those wildings modify important natural habitats or result in economic costs for adjacent landholders.
3. Deemed as long lived as the average of local indigenous forest, or longer. 
4. If to be select cut harvested at some point, only in areas with suitable soil stability so as not to increase erosion and stream sediment problems.
5. Should provide a habitat for local wildlife that is no less acceptable than indigenous forest.
   
   

Question 6: Do you think there is an opportunity to use permanent forests to stabilise erosion-prone land?
Yes, very definitely so.  The Inquiry has concluded that the effects of Cyclone Gabrielle would not have been so severe had much of the inland forest been permanent and not recently cleared for production forestry.  

Question 7: Do you think the Government should consider restricting the permanent forest category to exotic species with a low wilding risk?
Yes, wilding risk needs to be taken into account in allowing exotic permanent forestry.  We already spend large amounts in areas like the Marlborough Sounds to eliminate wilding pines.  We should not be making the problem worse by allowing wilding tree species in permanent forests.

Question 8: Do you agree with the proposal for a specific carbon accounting method for transition forests? If you disagree could you please provide the reasons why? If there are other options you think we should consider please list them.
We agree with the proposed new carbon accounting approach for transition forests.  We see potential for abuse of the status quo stock accounting method when significant surrender obligations come due.  Without a bond put down to cover that obligation, some forestry owners will attempt to skip out on the transition phase by declaring bankruptcy or avoiding liability through shell corporations.   And no forestry owner will be in the position to guarantee a bond that would cover this obligation beforehand.  The proposed “averaging” method avoids this problem.

Question 9: If you agree with the proposal for a specific carbon accounting method for transition forests, what do you think it needs to achieve?
We agree with the need for some type of “averaging” credit accounting for transition forests.
We feel that it is also important that allocated credits should be spread out over the life of the forests, up to the climax carbon storage of the resulting indigenous forest, so as to provide transition foresters a steady stream of income needed for continued forest management.  It is critical that foresters have the cash on hand to remove old growth exotic trees during the transition phase 30 to 50 years down the track.
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Question 10: What do you think should occur if a forest does not transition from a predominately exotic to indigenous forest within 50 years?
Although there are a number of options available to deal with transition failure, we provisionally would agree with an imposed management plan, at the forester’s expense, to try to address the lack of transition.  This would include the option to allow conversion to production forestry, if local soil and erosion characteristics allow.  This would, hopefully, create the conditions that would induce the forester to carefully monitor and insure progress toward the indigenous forest goal.