Borrow From Our Submission on the Pricing Agricultural Emissions Proposal
Updated: Nov 7
If you agree with us on sequestration, feel free to use what we've written.
If you’re thinking about making a submission on the Pricing Agricultural Emissions proposal but aren’t sure exactly what to write about sequestration specifically, borrow a couple of key points from ours if you agree with our position. We’re sharing these because the more voices we add to the movement before submissions close on 18 November, the better our chances of an incentive system that rewards more native forests and better native forests. Every growing native tree should count.
Details on how to submit and an open letter template you can use are at the bottom of the page.
Ongoing activity resulting in carbon sequestration is just as deserving of recognition as newly started activity. Incentive systems which recognise and drive all carbon removal activity are inevitably also ‘additional’.
Pre-1990 regenerating indigenous forests, including those on private land, are sequestering large amounts of carbon - more than 1.5 million tonnes per year - and this could increase further.
Sequestration of pre-1990 native forests can be and are recognised under UNFCCC - and the Government is already making such claims - more than NZ$1.6B worth over the 2013-2020 commitment period
A just and equitable system must not penalise those farmers who started protection and restoration the earliest and have done the most. An unjust or inequitable system would be against the UNFCCC transition goals, and will also struggle with acceptance and effectiveness.
A just and equitable system should be available to anyone who is restoring forests, not just farmers. Any system that denies access and incentives to those restoring and protecting forest will have reduced impact and increased costs.
There has to be an obligation to maintain the carbon sequestered in the forest for the long term - ideally at least 100 years. Otherwise, the sequestration is not ‘permanent’ and cannot be treated as equivalent under emissions accounting frameworks..
A robust and sufficiently accurate system which would achieve fair and well-aligned incentives and recognition is not ‘too hard’, not even in the initial 2025 time frame. CarbonCrop already provides the majority of the registration and monitoring required at the necessary scale, and provides it economically. CarbonCrop stands ready to support a feature-complete deployment in the required timeframe.
He Waka Eke Noa and the Agricultural Emissions Pricing review are a great opportunity to boost investment and innovation in Nature Based Solutions and additional sequestration in NZ in parallel with the ETS, and this opportunity should not be squandered. They present an ideal framework and trial platform within which to enable and trial the necessary innovations - with the potential for them to ultimately make their way into the ETS for forestry where appropriate.
To Minister David Parker,
In response to the call for submissions on the Pricing Agricultural Emissions proposal:
The proposal for pricing agricultural emissions has significant flaws specific to sequestration in vegetation. The proposed system does not treat all farmers justly and equitably. The proposed system does not sufficiently incentivise an outcome of more native forests and better, more biodiverse native forests.
We feel these issues can be resolved within the initial launch time frame, with the delivery of a just, equitable, high-integrity solution that will deliver outcomes aligned with both climate and biodiversity objectives. We think He Waka Eke Noa and the Agricultural Emissions Pricing plan are an ideal framework and trial platform within which to enable and drive the necessary innovations - even if they are to ultimately make their way into the ETS for forestry.
What we agree with
It’s great to see the position that any ongoing action such as the continued exclusion of stock or control of pests should qualify as “additional”, as would be the case for newly started activity, regardless of the date the activity may have started. We feel this is a key element of any just, equitable, and effective incentive framework to support forest and biodiversity restoration and protection. If a patch of bush has become established in an area where stock was excluded 40 years ago, and the stock are still excluded with the regeneration still delivering ongoing carbon sequestration, that ongoing sequestration must be accepted as legitimate for recognition and incentivisation.
What we disagree with
1 Any suggestion that regenerating indigenous forests which began to grow before 1990 are not sequestering a meaningful amount of carbon and that on this basis aren't worth including is incorrect. The Government's analysis indicates those forests are sequestering large amounts of carbon. Even the low-end estimates for pre-1990 regenerating forest, much of which is on private land, indicate ongoing sequestration equivalent to more than 1.5 million tonnes of CO2e per year (NZ Forest Management Report, NZ Greenhouse Inventory Report). With the right market incentives, this could be increased further, but it's already substantial. For many private landholders the returns from fair recognition would more than justify the monitoring and compliance costs, assuming appropriate application of modern technologies, and the resulting incentives would drive progress towards New Zealand's climate and biodiversity targets.
2 We disagree with the suggestion that pre-1990 forest carbon sequestration can't be recognised within the constraints of the UNFCCC rules. Not only can pre-1990 sequestration be legitimately recognised in NDC's, but the NZ government has claimed ~18 million tons of sequestration in pre-1990 forest for the last Kyoto period (NZ Greenhouse Gas Inventory 2013-2020). This is ~NZ$1.6 billion at current equivalent NZU prices, all for pre-1990 forest. We are not aware of any corresponding recognition for private landowners of associated forests for that time period within the ETS.
3 We feel that any system which rewarded farmers who have done nothing until now, while punishing those who started forest restoration earliest and did the most, would be unjust, inequitable, and create strong perverse incentives. For decades farmers have been encouraged to act as stewards of the land, to take a long-term perspective, to consider the broader environmental footprint of their operations, and embrace the principles of kaitiakitanga. Many farmers have retired marginal grazing land, reduced stocking, and protected areas of regenerating indigenous vegetation on their properties. To now subject farmers to a tax on all ongoing emissions, but discount the ongoing sequestration associated with some of their land use decisions is unjust, and against the stated objectives of the pricing system. Why should only those who have failed to act so far be recognised for future benefits they deliver in the markets that eventually emerge? Those who acted urgently and with ambition in their early contributions to our collective future should be rewarded, not just applauded.
4 The government wants “real and verifiable changes, seeing permanent stores of carbon” (page 50) but proposes to not require the carbon sequestered in the forest to be maintained after the contract ends. This is not ‘permanent’ - the forest could go backwards and the carbon be lost. Long-term commitments and robust monitoring mechanisms, aligned with global emissions reduction principles, should be used for the best outcomes - ideally with a minimum durability term of 100 years, consistent with the GWP equivalent used in associated accounting frameworks.
5 Finally, we view any exclusion of landowners from a system based on their lack of emissions as highly perverse given climate and biodiversity objectives. Any system of incentives for the recognition and incentivisation of ongoing carbon sequestration in regenerating native forest should be accessible to all owners of such forest, not just those with significant on-farm emissions. Similarly, any system that denied ‘willing buyers’ access to carbon sequestration outcomes would harm New Zealand's progress towards climate and biodiversity targets.
Getting the right incentives in place for native forest restoration is critical to our climate response and improving native forest and biodiversity outcomes in New Zealand. The technology required to robustly recognise and incentivise carbon sequestration in other vegetation sources than post-89 forest exists right now. We do this at CarbonCrop every day.
Jo Blundell Nick Butcher
CarbonCrop CEO CarbonCrop CTO
How to make a submission
Making a submission is easy, and you can do it at the Ministry for Environment. Submissions close on 18th November.
Apart from a few required questions on who you are, who you’re submitting on behalf of, and your consent to release the information, all questions are optional.
At the very least, you can write whatever you like under ‘Provide general feedback', copy sections of this post you agree with, or upload something you’ve already written.
If you want to get into a few specific responses on sequestration, addressing the inequality of the proposal is in Section 4, and the handling of native forest and riparian planting is in Section 3 (question 8 - scroll down).