Rewarding carbon storage in New Zealand native forests

Transcription

1 Rewarding carbon storage in New Zealand native forests Feedback to the Ministry for Agriculture and Forestry on the Development of Regulations regarding the Indigenous Sequestration Rate under the New Zealand Emissions Trading Scheme 29 March 2010 Dr Jan Wright Parliamentary Commissioner for the Environment

2 Summary of recommendations by the Commissioner My recommendations on the forestry regulations aim to reduce disincentives for indigenous forestry under the Emissions Trading Scheme. Recommendation 1: I recommend that the proposed amendments to the carbon stock tables for indigenous forest be implemented. Recommendation 2: I recommend that work continues to improve the accuracy of the indigenous forestry sequestration rates in the carbon stock tables. Recommendation 3: I recommend either: exempting indigenous forests from the requirement to assess carbon sequestration through field measurement for forests larger than a specified area. or defining the threshold above which field measurement for carbon sequestration is mandatory by the size of the carbon credit entitlement, rather than by forest area.

3 Introduction In February 2010, the Ministry for Agriculture and Forestry requested feedback from the public on the indigenous carbon sequestration rate in the stock tables of the forestry regulations under the Emissions Trading Scheme (ETS). My recommendations here aim to reduce any artificial barriers for indigenous forestry that are imposed by the ETS. I appreciate the opportunity to provide advice on this important forestry issue. Context I have been concerned about this issue for some time. In 2008, I recommended that MAF investigate how the regulatory carbon stock values for indigenous forests could be modified to better capture actual carbon sequestration rates 1. Following this, in 2009, I advised the ETS Review select committee that the indigenous carbon look-up tables in the regulations should be amended to make them consistent with the best science 2,3. The Indigenous Sequestration Rate Afforestation plays a major role in mitigating New Zealand s greenhouse gas emissions and should be encouraged. The Emissions Trading Scheme provides an incentive for new forests by rewarding foresters for carbon sequestration. However, there is a risk that current regulations incentivise exotic forestry, like plantation pine, at the expense of native forestry. Since increasing native forestry generally offers greater environmental benefits than increasing exotic forestry 2, this is unfortunate. A particular problem relates to the current carbon look-up tables that state how many credits a forest can earn. The current rate for indigenous forests is three tonnes CO 2 per hectare per year. This rate is lower than current science indicates. I welcome updating the indigenous sequestration values in the regulations from the flat rate of three tonnes CO 2 per hectare per year to values that vary with the age of the forest, reflecting current understanding of carbon sequestration rates. Recommendation 1: I recommend that the indigenous sequestration rates proposed in the February 2010 consultation document be implemented.

4 Ideally, the carbon sequestration rates in the regulations for indigenous forests should be as detailed and as accurate as those for exotic forests. There should be ongoing efforts to improve the indigenous carbon stock tables. This could include making them region or species specific. Recommendation 2: I recommend that work continues to improve the accuracy of the indigenous forestry sequestration rates in the carbon stock tables. Mandatory field measurement for large forests The consultation document proposes introducing mandatory field measurement for carbon sequestration assessment for all forests larger than a specified area. In other words, for forests which are larger than the area threshold, actual carbon sequestration must be measured in order to calculate their credit entitlement, rather than determined from carbon stock tables. The intention of mandatory field measurement is to reduce the risk of over-awarding credits to forests which sequester less carbon than the carbon look up tables. But because field measurement can be expensive, this requirement puts a disproportionate burden on indigenous forest owners. This is because indigenous forests generally earn significantly lower number of carbon credits per land area than exotic forests. Further, they are unlikely to be a commercial operation, unlike large exotic forests. Recommendation 3: I recommend either: exempting indigenous forests from the requirement to assess carbon sequestration through field measurement for forests larger than a specified area. or defining the threshold, above which field measurement for carbon sequestration is mandatory, by the size of the carbon credit entitlement, rather than by forest area.

5 Endnotes 1 Parliamentary Commissioner for the Environment, June 2008 Seeding the carbon storage opportunity in indigenous forests, Comments on the draft Climate Change (Forestry Sector) Regulations Parliamentary Commissioner for the Environment, May 2009 Report to the Emissions Trading Scheme Review Select Committee: Impact of the ETS on Indigenous Land Cover 3 Parliamentary Commissioner for the Environment, July 2009 Advice to the Emissions Trading Scheme Review Select Committee: Impact of the ETS on indigenous land cover Recommendations.