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Facilitating Carbon
Offsets from Native
Forests
Document information
Author contact details
Suzi Kerr
Motu Economic and Public Policy Research
suzi.kerr@motu.org.nz
Thomas Carver
Motu Economic and Public Policy Research
tom.carver.nz@gmail.com
Acknowledgements
We would like to thank Air New Zealand for commissioning and providing the core funding for
this work to proceed, and the Aotearoa Foundation and the Tindall Foundation for ongoing
support of Motu Economic and Public Policy Research work. We also appreciate and thank those
who contributed interviews and other input towards this project. These people were: Sean
Bates, Peter Beets, Ollie Belton, David Bergin, Debbie Birch, Fiona Carswell, Roger Cornforth,
Jeffrey Cornwell, Joris de Bres, Trevor Gray, Dayle Hunia, Peter Lough, John McCarthy, Simon
Millar, Tina Ngatai, Thomas Paul, Espen Ronneberg, Nigel Searles, Craig Trotter, Caroline
Wallace, Sean Weaver and Philip Wiles.
Disclaimer
All opinions are those of the authors and we are also responsible for any errors or omissions.
© 2017 Motu Economic and Public Policy Research Trust and the authors. Short extracts, not exceeding
two paragraphs, may be quoted provided clear attribution is given. Motu Working Papers are research
materials circulated by their authors for purposes of information and discussion. They have not
necessarily undergone formal peer review or editorial treatment. ISSN 1176-2667 (Print), ISSN 1177-
9047 (Online).
i
Facilitating Carbon Offsets from Native Forests
Abstract
This note aims to help firms looking to offset their Greenhouse Gas (GHG) emissions. Emissions
reductions from native forestry sequestration are already recognised in the New Zealand
Emissions Trading Scheme (ETS) and it is ‘shovel ready’ to generate native forest offsets. 10,000
Ha of post-1989 native forest land would sequester 65,000 tonnes of CO2-e annually on average
over 50 years, and would be eligible to earn 65,000 NZUs per year under the ETS. Native forestry
also has a wide range of associated environmental, cultural, social and economic co-benefits. It is
certainly possible for more native afforestation to occur at present, and within the existing
policy framework; however, challenges do still exist. These include: a lack of awareness; limited
access to capital; the complexity of the ETS; policy uncertainty; and some specific policy settings.
The New Zealand business community can play an important role in solving these problems.
Businesses can help influence government policy and have the capital and capacity to play a
facilitating role in the market.
JEL codes
Q23, Q55
Keywords
Emissions Trading, Forestry, Native Forestry, Carbon Offsets, New Zealand, Pacific, Environment
Summary haiku
Natives get rewards
Can we make it easier?
Birds and climate win
ii
Facilitating Carbon Offsets from Native Forests
Table of Contents
1 Introduction 1
1.2 Benefits of Native Forestry 5
1.3 The Current State of Native Forestry in the ETS 7
References 29
iii
Facilitating Carbon Offsets from Native Forests
Table of Figures
Figure 1: Native vs. Exotic Forest Land in the ETS (by the Year it Originated) 8
iv
Facilitating Carbon Offsets from Native Forests
1 Introduction
This note aims to help firms looking to offset their Greenhouse Gas (GHG) emissions with native
forestry. Native forestry has a wide range of associated environmental, cultural, social, and
economic co-benefits and the credits it earns have a high degree of environmental integrity.
Emissions reductions from native forestry sequestration are already recognised in the New
Zealand Emissions Trading Scheme (ETS) and it is “shovel ready” to generate native forest
offsets. This paper does not address “new” carbon reduction/removal options (soil carbon,
marine carbon and carbon capture and storage). These face significant scientific and regulatory
challenges. The “new” reduction options are discussed in a companion paper (Meduna 2016).
The ETS was introduced in 2008 as a part of the country’s efforts to meet its Kyoto
Protocol obligations.1 Under the scheme, firms are required to acquire and then surrender New
Zealand Units (NZUs),2 to account for emissions associated with their activities. Currently, firms
must surrender two NZUs for every three tonnes of carbon dioxide equivalent (CO2-e). By 2019,
this will increase to one NZU for every tonne of CO2-e, as the “one-for-two” subsidy is phased
out (Bennett 2016).3 New Zealand is the first, and still the only, country to include forest
landowners as mandatory participants in its ETS. As forests grow, they are eligible to earn NZUs
for the carbon they sequester. Forestry also faces liabilities under the ETS for reductions in
carbon stocks on forestry land, either from harvesting or deforestation.4 The Afforestation Grant
Scheme (AGS) and the Permanent Forest Sink Initiative (PFSI) are two other closely related
policies that landowners can use to obtain finance and NZUs for afforestation efforts.5 For more
detailed information on the ETS, see Karpas and Kerr (2011), (Leining and Kerr 2016), and
(Kerr, Carver, and Dawson Forthcoming).
Establishing new stands of native forestry (i.e. afforestation) has significant potential to
help New Zealand firms meet their ETS commitments, contribute to voluntary programmes that
go beyond New Zealand’s target for corporate social responsibility reasons, and meet sectoral
international commitments such as those under the International Civil Aviation Organization.
Ten thousand hectares of post-1989 native forest land would sequester (and earn NZUs for)
65,000 tonnes of CO2-e annually on average over 50 years, and would be eligible to earn 65,000
NZUs under the ETS.6 There is strong interest among a variety of stakeholders, including
community groups and iwi, in planting more native trees for biodiversity, plantation forestry
diversity, cultural and aesthetic reasons, and for erosion control. The financial returns from
forestry have improved recently: the carbon price has rebounded;7 there is more certainty
around New Zealand’s global commitments with the Paris Agreement;8 and there are other
payments for forestry available.
This note outlines the different options for obtaining credits via carbon sequestration by
native forestry. It also outlines barriers to encouraging more native afforestation and suggests
actions to overcome these. To help understand the issues, we have interviewed a range of
stakeholders, including government officials, scientists, landowners, officials from certain iwi,
and key individuals/organisations involved in native regeneration initiatives.
It is certainly possible for more native afforestation to occur at present, and within the
existing policy framework; however, challenges do still exist. These include: a lack of awareness;
limited access to capital; the complexity of the ETS; policy uncertainty; and some specific policy
settings. The New Zealand business community can play an important role in solving these
problems. Businesses can help influence government policy and have the capital and capacity to
play a facilitating role in the market.
6 Assuming the average carbon sequestration per year over the 50 year “indigenous forest” lookup table from MPI
(Ministry for Primary Industries 2015b). 85,000 hectares represent around1.5% of all planting since 1990, and
around 0.11% of New Zealand farm land (Ministry for the Environment 2016).
7 $17.50 on 14 December 2016. The price of an NZU was as low as $2 in 2013, whilst other eligible units were priced
at less than $1. See https://www.commtrade.co.nz/ for the latest spot price. See Ormsby and Kerr 2015 for a full
treatment of the history of the carbon price in NZ.
8 Although New Zealand’s Intended Nationally Determined Contribution (INDC) is still provisional on access to
international markets and land accounting rules (New Zealand Government 2015).
Facilitating Carbon Offsets from Native Forests
The following tables summarise the key recommendations from our scoping study.
Science Regulatory
Acceptability
Current Options
Strong In ETS
Native Regeneration
Fencing off land near a native seed source and allowing it to
revert to native forest.
Actions:
1. Provide expertise and up-front finance for landowners
in return for credits.
2. Work with researchers and other stakeholders to
compile a shortlist of suitable land for regeneration
efforts.
3. Pursue partnerships with other stakeholders and
options that might deliver other revenue streams (e.g.
honey, government incentives).
Strong In ETS
Planting Native Trees
Plantation or restoration
Actions:
1. Provide expertise and finance for up-front planting
costs.
2. Engage with experts to facilitate research into cheaper
planting options. Encourage these groups to achieve
consensus on key issues.
3. Utilise other incentives where possible.
Options Currently Limited
Strong on Only in ETS if
Riparian Planting
carbon; wider than
Planting native trees along the banks of rivers when they are
water quality 30 metres
fenced. The aim is often to improve water quality.
benefits less
Actions:
clear
1. Identify farmers willing to retire riparian areas wider
than 30 metres. Provide expertise and finance for up-
front planting costs. As this land is already being
retired and fenced, it may prove a cost-effective
option for native afforestation (although this is
unlikely on high-productivity land).
2. Encourage research on the value of making credits
available for narrower riparian planting.
3
Facilitating Carbon Offsets from Native Forests
Policy Uncertainty
1. Encourage the government to clearly articulate its policy intentions for meeting New
Zealand’s Paris commitments.
2. Push for a multi-party consensus on as many of these intentions as possible.
Transparency
Ask the government to make more ETS forestry data available.
Policy Intentions
Clarify policy intentions for agricultural greenhouse gas emissions and Regional Council
decisions around freshwater reform. This will help avoid perverse incentives to intensify or
sustain livestock on land that would otherwise be attractive for native regeneration.
9 MPI could allow challenges to this, perhaps requiring landowners to meet the costs.
10 Clarify uncertainties around the definition of ‘planted indigenous forests’ under the Forests Act 1949, and the
In this paper, we necessarily make some generalisations about native forestry. It’s worth
keeping in mind that there are a diverse range of tree species and modalities for their
establishment/management and there is rarely a single solution. For more detail on native
forestry establishment options see (Davis et al. 2009) and (Bergin 2012b).11
• Environmental
• Biodiversity
• Soil stability
• Carbon storage
• Water quality
• Regulation of flows
• Social
• Aesthetics
• Conservation
• Recreation
• Community engagement
• Cultural
• Fulfilment of kaitiakitanga.
11 Tane’s Tree Trust also has a good technical handbook available here: http://www.tanestrees.org.nz/resource-
centre/publications/.
12 This is covered in detail in other works (e.g., Hall 2016; Bergin 2012a; Ngapuhi 2007; and Davis et al. 2009).
5
Facilitating Carbon Offsets from Native Forests
• Carbon sequestration: Forestry provides an effective means for New Zealand to mitigate its
emissions domestically. This has been made more attractive by the rebound in the carbon
price, and since international units were no longer accepted in the NZ ETS.
• Water quality: Public concern has grown over the rising level of nutrient run-off into
waterways (Parliamentary Commissioner for the Environment 2015).
• Soil erosion: The “area of steep, erosion-prone grassland that could benefit from
afforestation” is estimated between 0.35 million hectares and 0.6 million hectares (Davis
et al. 2009).
13 See Chapter IV of (Hall 2016) for an attempt to quantify the dollar value of some of these benefits at:
http://pureadvantage.org/news/2016/04/22/our-forest-future/.
14 For details, see: http://www.mpi.govt.nz/funding-and-programmes/forestry/erosion-control-funding-
programme/.
15 Fonterra’s ‘Living Water’ project is being done in partnership with the Department of Conservation.
16 After this 10-year period, the forest land can be registered in the ETS and earn credits from then.
17 Based on the native lookup table, a 5% discount rate and a $20 constant carbon price the NPV of the first 10 years
of carbon credits is $562. Even with a 0% discount rate and a $25 carbon price, the NPV is only $1,005.
Facilitating Carbon Offsets from Native Forests
the same way as in the ETS. Land can only be entered into one of the PFSI or the ETS (Ministry
for Primary Industries 2015a).
Figure 1: Native vs. Exotic Forest Land in the ETS (by the Year it Originated)
40
35
30
25 Native Exotic
'000 Ha
20
15
10
Year of Planting
20 Combinations of these two also exist (e.g. enhancement planting of naturally regenerating land).
Facilitating Carbon Offsets from Native Forests
Regeneration is already eligible to earn credits in the ETS and is an inexpensive way to do
so, albeit a slow one. Moreover, permanent, regenerating native forestry has large co-benefits: it
provides a wide array of social amenities along with cultural as well as environmental benefits
(e.g. biodiversity, erosion reduction, and water quality). David Bergin feels that regeneration is
likely the only practical way to restore native forestry on a large scale (Bergin 2012b). He also
thinks that landowners fear that their land will revert to invasive weeds such as
gorse/blackberry rather than native forestry. This has sometimes happened when farmers tried
to encourage regeneration. David believes that this might be due to lack of good advice,
expertises and time/money to engage in the necessary spraying and pest control.
In some situations, planting can serve as a good complement to regenerating land. It can
function as a seed source (especially for larger broadleaf species), and can also provide a
nursery for regenerating natives. This nursery function can be fulfilled by smaller shrub species
such as manuka that, depending on the site, can be relatively inexpensive to plant compared to
later successional native trees.21
2.1 Opportunity
2.1.1 Cost-benefit
The key costs involved (where necessary) in native regeneration are: fencing, animal pest
control, controlling competing vegetation, weed control, site preparation, and the value of the
land (or the opportunity cost of its current use).22 It is hard to provide a definitive cost for native
regeneration. In some regions it is happening with no human assistance on unutilised land, and
is thus effectively free. In other areas where extensive pest control is needed, there are no seed
sources nearby, and there is competition from other land uses, it may cost a lot more. One study
put the cost of native regeneration at just over $4,000/hectare (Davis et al. 2009).23 This figure
does not include the value of the land.
The value of carbon credits is a key monetary benefit. We estimate the NPV of the first 50
years of carbon credits at around $2,500.24 The money from the carbon credits could be enough
for regeneration to be profitable on low value land – especially when combined with payments
for other environmental services (e.g. erosion control) – or where other non-economic benefits
are realised. It’s also possible that landowners might be able to earn a revenue stream from the
recreation/leisure benefits or by-products (e.g. manuka honey) from their forest land (Hall
2016).
21 David Bergin.
22 David Bergin notes that even where regenerating land may initially revert to brush weeds such as gorse or broom,
many of these sites will eventually succeed to natives over time.
23 Tables 6.2 and 6.3. David Bergin, a co-author of the paper, felt in many cases it could be done more cheaply.
24 Assuming a constant carbon price of $20 and a discount rate of 5% and MPI’s native carbon sequestration lookup
table. With a carbon price of $17.50 and an 8% discount rate this would be around $1,350. With a rising carbon price,
it could be much higher.
9
Facilitating Carbon Offsets from Native Forests
25 The age of the tree species in the forest is determined by treating all trees as if they regenerated in the year that
regeneration began (Ministry for Primary Industries 2015b).
26 Ollie Belton said that in practice it is not possible to register land and claim credits if no tree seedlings are present.
In unfavourable circumstances (e.g. strong pasture competition), this may take years or never happen at all.
27 (Ministry of Agriculture and Forestry 2010) notes that the “Year Zero” of forest establishment can be updated if
circumstances change (e.g. if there is a drought or weed invasion occurs). The examples given refer to older stands of
forest (e.g. regeneration that began in the 1990s) so it is unclear how this process will work with new land.
28 The estimates in Shepherd et al. (2008) for the amount of land that is the least productive, and thus the most likely
to respond to a carbon price, need to be redone.
29 Thomas Paul and Peter Beets (Scion), felt the NZ LUCAS maps were “on the whole OK”.
Facilitating Carbon Offsets from Native Forests
useful.30 MPI could allow pre-1990 landowners to challenge this on a case-by-case basis, perhaps
requiring landowners to meet the costs.
Reporting burden
Forest land over 100 hectares in the ETS must use the Field Measurement Approach (FMA)31 to
measure its carbon biomass (Ministry for Primary Industries 2015b). Nearly 90% of all native
forest land registered in the ETS is greater than 100 hectares in size, and as such must use the
FMA (Ministry for Primary Industries 2016b). The costs involved with the FMA are a potential
barrier to native forestry joining the ETS. Peter Lough (Manager of Climate Change Operations at
MPI), Craig Trotter (Principal Adviser for Spatial, Forestry and Land Management, Ministry for
Primary Industries), and Ollie Belton agreed that in comparison with exotic plantation forestry,
each measurement plot costs twice as much for regenerating natives. To compensate for this,
MPI requires native forestry to measure half the number of plots.32 However, as the income
stream from regenerating natives is far lower than exotic plantation forestry, it can still be hard
to cover the costs associated with the FMA.33
30 MPI officials (Peter Lough, Craig Trotter); Tane’s Tree Trust group (David Bergin, Debbie Birch, Caroline Wallace
and Joris de Bres); Tindall Foundation (John McCarthy and Trevor Gray); Scion (Thomas Paul and Peter Beets); Simon
Millar and Ollie Belton.
31 For more information on the FMA, see: https://www.mpi.govt.nz/growing-and-producing/forestry/forestry-in-
the-emissions-trading-scheme/using-the-field-measurement-approach/.
32 Using fewer plots reduces the accuracy of the FMA. Both the 100-hectare area and the number of plots are
somewhat arbitrary.
33 Ollie Belton claimed that to make it worthwhile a native forest would need to be at least 200-300 hectares. Fiona
Carswell believed the 100-hectare threshold was set with the financial viability of native regenerating land in mind.
34 Peter Lough, Craig Trotter, Ollie Belton, David Bergin, Thomas Paul, Peter Beets and Fiona Carswell. From the ETS
lookup table guide: “The tables represent the average increase in carbon stocks on a given
hectare of land since the time regeneration first began… [the] tables allow for [the] gradual expansion in vegetation.”
35 A stocking overlay is being considered as part of the ETS review.
36 Only forest land planted after 1989 can enter the ETS. Thus, the most mature native forest land in the scheme can
be little more than 25 years old.
11
Facilitating Carbon Offsets from Native Forests
Provide expertise and up-front finance for landowners in return for credits
This could immediately generate more native reforestation project, even under existing rules.
Barriers to valuable projects include: landowners’ lack of understanding of ETS opportunities,
rules, and risks; their inability either to manage administrative processes or to make small up-
front investments in fencing and pest control.
Eligibility
Recommend the government agree to a “line in the sand” classifying land as either pre-1990 or
post-1989. Pre-1990 landowners could be allowed to challenge this on a case-by-case basis, but
they would have to meet the costs associated with this. This would reduce investor uncertainty
and the burden on landowners. There seems to be broad agreement on this point.
Carbon measurement
Propose lifting the FMA threshold for regenerating native forests. The government has claimed
that the lookup tables and FMA give very similar answers, so the fiscal risk associated with
37This may of course also allow more deforestation of existing native forests. The net effect would be unclear. The
goal should be clarification of rules to avoid unnecessary uncertainty.
38 See: https://data.mfe.govt.nz/layer/2375-lucas-nz-land-use-map-1990-2008-2012-v016/.
Facilitating Carbon Offsets from Native Forests
raising the FMA threshold should be low.39 Lifting the threshold from 100 to 500 hectares would
reduce the existing ETS forest area impacted by the FMA from 87% to 59% and may facilitate
more entry of small regenerating areas.40
Significant trade-offs are involved with this decision and it should not be made without
consulting landowners and the government. One issue is that it will introduce different FMA
thresholds for native and exotic forest land, and thus more complexity to the ETS. Another issue
is that despite a large variability in native sequestration rates, there is currently only one table
for all species, modes of establishment, stocking rates, and regions. This could pose a fiscal risk
to the government and result in some participants earning fewer credits than they would using
the FMA.41 For this reason, some stakeholders, including Ollie Belton, oppose increasing the FMA
threshold for native forest land. Indeed, Peter Lough (Manager of Climate Change Operations at
MPI), informed us that some stakeholders have previously asked for the threshold to be
lowered. Only the government has the data from the FMA to assess the level of the fiscal risk or
how much some landowners may stand to gain or lose. The ETS lookup tables could also be
adjusted.
This will lower the compliance/participation costs for smaller regenerating areas. Officials
will probably wish to consider whether having a different threshold for native forestry may
confuse participants.
39 Native forestry makes up less than 10% of forest land registered in the ETS and earns credits at roughly one third
of the rate of exotic forest land. Allowing native forest land to measure half as many plots when using the FMA also
poses some fiscal risk, especially as naturally regenerating land is unlikely to grow in a uniform manner.
40 Government data may help to pinpoint the right threshold.
41 Forest owners who have planted native stands may be concerned about this. However, as discussed in Section 2,
the ETS lookup tables indicate higher rates of growth than modelled growth of planted natives for the first 25-30
years. Besides, these landowners are likely to be rare, as planting over 100 hectares of native forest would be very
costly.
13
Facilitating Carbon Offsets from Native Forests
methods and in extracting other by-products from the land (Hall 2016).42 There has been very
limited research into establishing “optimal” rotation lengths for different native forest species.
One study modelled harvest rotations of 60-80 years, and 60 years is sometimes mentioned as a
minimum (Steward et al. 2014). David Bergin feels that rotation lengths may need to be
significantly longer than 60 years, especially given the quality of land on which native forestry is
likely to be planted.
Like regeneration, plantation native forestry is already eligible to earn credits in the ETS.
Even when it is not established/managed to resemble a “natural” forest (permanent forest cover
and a diverse set of tree/shrub species), it can still sequester significant levels of carbon and
provide important social, cultural and environmental co-benefits. Moreover, the harvested
timber is likely to be highly valued. It’s thus unsurprising that landowners are considering
plantation native forestry.43
Planting natives for restoration purposes is covered in Section 5.
3.1 Opportunity
3.1.1 Cost-benefit
It’s incredibly difficult to assess the profitability of a stand of native trees that may be harvested
60-100 years in the future. Growth rates, timber quality/prices and the carbon price must all be
predicted.
One recent study has suggested that, under certain circumstances, kauri plantations may
be profitable (Steward 2012). Some researchers doubt this, especially as many of the study’s
assumptions represent the “best case scenario” for native plantation (e.g. “good to very good
site” and growth rates, low to zero cost for land, low establishment costs of around
$4,000/hectare, and high value of final timber product).44 This study doesn’t assume any income
from carbon credits or other ecosystem payments (e.g. nitrogen credits), which could only
improve the prospects for plantation native forestry. However, it is still far from clear that
profitability would be possible under an “average” set of assumptions even with ecosystem
service payments.
As noted earlier, planting native forestry can be expensive; however, just like regenerating
natives, the costs are situationally dependent. Cost estimates for larger native tree species
suitable for timber harvesting (e.g. kauri, tōtara, rimu) range between $5,000-$60,000/hectare,
excluding the cost of the land.45 One study gives an estimate of $24,000-$36,000/hectare (Davis
42 Hall notes that this is in accordance with the Māori notion of interdependence (taupuhipuhi) with the land. Tina
Ngatai (General Manager of Ngati Whakaue Tribal Lands Incorporation), expressed interest in this.
43 Interview with Tina Ngatai.
44 Gerard Horgan expressed doubts about the assumptions used in the study. See:
http://pureadvantage.org/news/2016/06/21/going-native/ for more discussion on this.
45 Ollie Belton provided the low-end cost estimate ($5,000-$10,000 per hectare). He felt some of the higher cost
estimates were appropriate for conservation/restoration planting, but with plantation forestry lower densities could
be used and there would be efficiencies from planting a monoculture. Gerard Steward’s study on Kauri plantation
Facilitating Carbon Offsets from Native Forests
et al. 2009);46 another found that depending on the stocking rate, costs could range from
$5,000-$66,000/hectare (Bergin and Gea 2007).47 The stocking rate has the largest impact on
establishment costs; however, lower stocking rates carry increased risk of seedling failure due to
weed invasion and competition from existing vegetation.48 We will cover the cost of planting
cheaper shrub species (e.g. manuka/kanuka) later as they are not used for timber production.
There is some scope to reduce these costs, some of which are briefly listed below:
• Buying in bulk: Our interviewees felt that the cost of native seedlings could drop if demand
increased and nurseries had confidence in this level of demand. David Bergin (Director,
Environmental Restoration Ltd) believed that a large increase in demand could drop
seedling prices by as much as 30%.
• Nurse crops: Planting nurse crops (or utilising existing vegetation as a nurse crop) could
accelerate the growth of trees and reduce establishment costs.49
• Planting strategies: Research is being done on reducing the cost of planting natives. Some of
these strategies are showing promise. For example, (Davis et al. 2009) estimate that bare-
root seedlings could reduce costs by nearly $9,000/hectare; direct-seeding onto the
ground may be even cheaper (although there are major concerns about its viability on a
large scale (Bergin 2012b)); employing lower stocking rates can reduce costs significantly.
More research is needed on these options as they are still largely unproven and can
involve significant trade-offs (e.g. lower stocking rates increase the chance of weed
invasion and the native planting failing) (Davis et al. 2009) and (Bergin and Gea 2007).
forestry assumes a low establishment cost of around $4,000 per hectare (Steward 2012). David Bergin felt $30,000
per hectare was really the minimum, and that lower cost options using lower planting densities were at risk of failure
from weed invasion. Scientists we interviewed at Scion and Landcare (Peter Beets, Thomas Paul and Fiona Carswell)
generally felt the $20,000-$30,000 per hectare range was a reasonable estimate.
46 This is the cost to: purchase the tree stock, prepare the ground, plant the trees and then carry out ongoing weed
control, pest control and site management for the first three to five years. It excludes the cost of the land. This study
assumes a planting density of 4,444 trees per hectare (compared with 1,000 per hectare for pine plantation, which the
study estimated costing $6,000 per hectare). See p. 63 Table 6.2.
47 This study excludes the cost of the land, fencing, and pest control. A stocking rate similar to the Davis report would
imply a cost of around $30,000 per hectare. See p. 33 Table 2.
48 Interview with David Bergin.
49 Interviews with David Bergin and Ollie Belton.
15
Facilitating Carbon Offsets from Native Forests
native tree species (Kimberley, Bergin, and Beets 2014).50 Over a longer period, the
planted native forest will sequester more carbon than the ETS tables suggest; the value of
this later storage will depend on the investor’s discount rate, as illustrated by Table 3, and
also on future carbon prices (a constant $20 price may be conservative). Where a nurse
cover of planted native shrub species are used, these tend to grow faster than regenerating
land and can potentially contribute to early carbon sequestration while inter-planted
native tree species become established (Kimberley, Bergin, and Beets 2014).
• Other potential revenue streams: Manuka honey is frequently mentioned as a potential
revenue stream for native forestry. Some suggest that native forestry could produce other
by-products useful for “pharmaceuticals, nutraceuticals, biofuels, genetic resources” and
more (Hall 2016). However, there is limited information about these other opportunities,
and we are not aware of instances where they have been commercialised in a successful
and ongoing manner.
• AGS: The NPV of the first 10 years of carbon credits from planted native forests is much less
than the $1,300 payment from the AGS. It thus should make sense to utilise this when
possible.
• Payments for other co-benefits: As discussed above.
Table 3: Net Present Value (NPV) of Carbon Storage in Native Forestry Stands by Discount Rate.51
Discount Rate 5% 8% 5% 8%
20 years $1,673 $1,183 $1,065 $753
50 years $2,479 $1,557 $3,244 $1,686
Source: Kimberley, Bergin, and Beets (2014) and Ministry for Primary Industries (2015b).53
There is a significant gap between the carbon value and the cost of establishing plantation
natives. For planting to occur, the value of harvested wood products and ecosystem services
other than carbon must be high enough to cover this gap.
50 The growth rates in this study are based on the average performance across a range of existing small native stands
planted nationwide as surveyed by Tane’s Tree Trust.
51 Assuming a constant carbon price of $20 per tonne.
52 Kauri is one of the fastest native species for sequestering carbon over a 40-80-year period. The annual carbon
sequestration figures are interpolated from the 20, 40 and 60-year figures found in Table 4 of (Kimberley, Bergin, and
Beets 2014), using the growth profile from the ETS lookup table.
53 The growth rates for regenerating natives come from the ETS lookup tables (Ministry for Primary Industries
2015b). The planted Kauri numbers come from the Tane’s Tree Trust work (Kimberley, Bergin, and Beets 2014). As
mentioned before, the growth rates in the Tane’s Tree Trust study are based on the average performance across a
range of existing small native stands planted nationwide.
Facilitating Carbon Offsets from Native Forests
Reporting burden
For native plantation forestry that resembles exotic plantation forestry (monoculture, single-
age, planted at regular intervals), the FMA is relatively easy to comply with. However, for those
seeking to establish multi-species, multi-age, continuous cover native forestry, this will prove
more difficult. It could even be as hard as naturally regenerating native forest land in some
cases.
54 The research finds that planted shrubs (e.g., manuka/kanuka) grow 40% faster than the lookup table would imply
in the first 20 years; however, their growth plateaus very soon after that.
55 For more detail see: https://www.mpi.govt.nz/growing-and-producing/forestry/indigenous-forestry/harvesting-
and-milling-indigenous-timber/.
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Facilitating Carbon Offsets from Native Forests
have provisions to prevent or limit the clearing of native vegetation; this could limit the ability to
harvest a planted indigenous forest.56
Another uncertainty is the future price of timber. Attempting to predict the price of such a
rare and illiquid commodity is not easy. Even the nature of the wood itself is uncertain. The
traditional supply and use of these species by Māori, and in European settlement times, came
from large trees in old growth forests. The timber was likely to be from trees that were
hundreds of years old and comprised mostly heartwood. Preliminary studies of wood properties
from 60-70-year-old kauri/tōtara stands have found that heartwood formation is relatively
slow, and timber from these stands will be predominately sapwood e.g. (Barton and Horgan
1980) and (Steward and Kimberley 2002).57 However, there has been some work that suggests
the properties of this sapwood compare well with those of heartwood and that it may be a
valuable product (Steward and Mckinley 2005).
likely to be able to manage projects that involve multiple actors and revenue streams, and hence
lower costs or increase revenues.
Carbon measurement
Support research that would develop species specific carbon lookup tables and appropriate
“overlays” (e.g. stocking rate, geography). Officials are considering whether to investigate
overlays as a future means of improving ETS carbon accounting.
Investment Uncertainty
Recommend the government attempt to remove any remaining uncertainty in the Forests Act
around how the definition of a ‘planted indigenous forest’ interacts with other parts of the Act
and with trees that naturally regenerate. This could be done by amending the interpretation
section of the Forest Act (1949) to make it explicit that regenerating vegetation within a planted
native forest won’t prevent a landowner harvesting it58 and to make it clear that when a native
forest is harvested and replanted it is still classified as a planted indigenous forest. Work also
needs to be done to ensure that regional RMA plans align with the Forest Act (1949). This policy
would increase investor certainty.
58One way to do this would be to amend the definition so that the status of ‘planted indigenous forest’ extends to the
whole planted area, as opposed to just the planted trees.
59 For example, the Taranaki Region Council (TRC) riparian management programme has been in place since 1996.
See: https://www.trc.govt.nz/environment/freshwater/riparian-management/. This TRC scheme has resulted in the
planting of 2,138 kilometres of stream bank with over 3.9 million native plants. Now, 64% of stream banks are
vegetated where planting is recommended (Dairy NZ 2016).
60 Fiona Carswell (Chief Scientist, Landcare Research) had reservations.
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Facilitating Carbon Offsets from Native Forests
Most of the water quality benefits may come from fencing off waterways from stock (Parkyn
2004).
Momentum is building on this issue, with the central government announcing last year
plans to exclude milking dairy cattle “from water bodies by 1 July 2017” ( Ministry for the
Environment 2016).61 While this won’t mandate riparian vegetation, Dairy NZ has a voluntary
“water accord” that calls for “riparian planting… where it would provide a water quality benefit”
(Dairy NZ 2016).62 However, much of this riparian planting will not be eligible to earn carbon
credits as it won’t be over 30 metres wide, which is the minimum width required to meet the
definition for a forest under the ETS (Ministry of Agriculture and Forestry 2009).63
4.1 Opportunity
4.1.1 Cost-benefit
The costs and benefits are similar to those laid out in 3.3 and 3.4 (depending on whether the
riparian margin is planted or if natural regeneration occurs). A key difference is that the cost of
planting might be significantly lower. Many of these margins are being fenced (as a result of
rules or voluntary actions) to exclude stock. This means that the opportunity cost of this land is
essentially zero as it has no productive value, and there is no additional fencing cost. Based on
these factors, (Daigneault, Eppink, and Lee 2016) estimate the cost of planting manuka to be
$1,000/hectare and regeneration to be $0/Ha. However, the costs may be higher in some cases.
There are also a number of financial incentives available specifically to those planting in
riparian buffer zones. In 2013, the government introduced a tax break for planting riparian
margins on farmland.64 Some councils are also trying to reduce the cost for farmers. For
example, the Taranaki Regional Council “contracts nurseries to supply native plants to farmers
at cost”.65
61 Dairy support, beef, and deer will be phased in between 2020 and 2030. Pigs are included in the July 2017
deadline. As of February 2017, dairy cattle are excluded from 96% of waterways on dairy farms (see:
https://www.dairynz.co.nz/environment/in-your-region/sustainable-dairying-water-accord/).
62 The original water accord can be found here: http://www.dairynz.co.nz/environment/in-your-region/sustainable-
dairying-water-accord/. Dairy NZ has also produced regional planting guides and a riparian planner tool which can be
found here: http://www.dairynz.co.nz/environment/waterways/.
63 Forest land must have (or be able to obtain) “average crown-cover width of at least 30 metres” (Ministry of
Agriculture and Forestry 2010).
64 “Riparian plantings by farmers will now be able to be deducted as an operational expense rather than being
classified as capital expenditure”. For detail see: https://www.beehive.govt.nz/release/tax-reform-encourages-
conservation-planting.
65 For more detail, see: https://www.trc.govt.nz/environment/freshwater/riparian-management/.
Facilitating Carbon Offsets from Native Forests
involved by “between 2:1 and 20:1.” 66 Their work estimated the “optimal width of the buffer” to
be between 17 and 30 metres, depending on the set of assumptions used.67
A challenge for researchers is to differentiate between the benefits of stock exclusion and
vegetation on the riparian margin.68 (Parkyn 2004) notes that around 80% of the benefits in
nitrogen, phosphorus, and sediment come from fencing alone. The findings of (Daigneault,
Eppink, and Lee 2016) tend to support this: they find that a five-metre buffer reduces nitrogen
leaching and phosphorus loss by 50% and sediment loss by 80%. They also find no improvement
in nitrogen, phosphorus, or sediment loss from planting natives vs. regeneration.
Fiona Carswell (Chief Scientist, Landcare Research) also had reservations about the
purported level of co-benefits associated with riparian vegetation – especially biodiversity, since
native insect/plant diversity increases with planting but so too do predator densities. She felt
fencing was a more cost-effective way to improve water quality.69
It therefore seems that any decision to engage in riparian planting/regeneration for
carbon offsetting purposes should be independent from the purported benefits of riparian
planting on water quality. The decision should be taken on the same basis as for any other piece
of land (e.g. comparing the costs with the benefits we can confidently ascribe to native forestry).
66 Their work based their cost-benefit analysis on four benefits: greenhouse gas mitigation, nitrogen leaching,
phosphorus loss, and sediment loss; and four costs: fencing, alternative water supply, afforestation, and opportunity
cost of the land. They also considered biodiversity benefits, but didn’t include them in their cost-benefit analysis.
67 This width is for either side of the waterway.
68 Very little current research differentiates between the benefits of fencing and riparian vegetation. We heard this
from several interviewees (Fiona Carswell, Chief Scientist at Landcare Research; Thomas Paul and Peter Beets, both of
Scion).
69 Fiona mentioned that grass was just as effective as trees for sedimentation, whilst the scientific research has not
yet settled this issue for nitrogen/phosphorus run-off. David Bergin noted that even densely planted native riparian
zones can have quite open bare ground beneath due to dense shade from canopy and wondered how that influenced
the performance of grass vs. native trees/shrubs.
70 227,000km of this is on sheep/beef farms, 36,500km is in plantation forestry and 32,000km on dairy farms.
71 10% of this is from dairy and 73% from sheep/beef farming. The research does not consider afforestation along
riparian zones on forestry land.
72 Taking the average sequestration rate of 6.5 tCO2e/yr from the native forestry lookup table. This figure would be
as low as 1.2 MtCO2e in the first couple of years, and above 20 MtCO2e between 12-25 years.
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Facilitating Carbon Offsets from Native Forests
73 It seems that this could be easily resolved by changing the forest definition in the ETS to apply only to
reforestation, not deforestation.
74 Although depending on the outcome of the ETS review and the Paris rules, there is some chance the government
may be willing to do this with other rule settings (e.g., averaging). This update may not be possible because 1990
satellite imagery of sufficient accuracy does not exist.
Facilitating Carbon Offsets from Native Forests
75 Although it’s worth noting that many native tree species naturally form monocultures on selected sites, especially
after man-made or natural disturbances.
23
Facilitating Carbon Offsets from Native Forests
The benefits from this approach are similar to those from regenerating native forest (3.3),
except that some of those benefits may accrue more rapidly.76 The costs can vary greatly,
depending on the type of planting. Debbie Birch (Director, Ngāti Awa Group Holdings Ltd) put
the cost of planting manuka at low stocking rates at $2,500-$3,000/hectare during our meeting
with Tane’s Tree Trust.77 The paper by (Daigneault, Eppink, and Lee 2016) placed the cost of
manuka at $1,000/hectare; however, it didn’t include fencing costs. The work by (Davis et al.
2009) placed the cost of manuka/kanuka at around $25,000/hectare. Ollie Belton and David
Bergin both put the cost of establishing “mixed” forests with larger broadleaf species in the
$20,000-$40,000/hectare range, while the (Davis et al. 2009) work placed the cost at
$40,000/hectare. It’s worth noting that these estimates may not be comparing apples with
apples. The higher cost estimates from (Davis et al. 2009), David Bergin, and Ollie Belton include
site prep, all planting costs, weed control for three to five years after planting, and a relatively
high stocking rate. For the lower cost estimates, however, we could find no detail behind their
numbers.
As these forests tend to be more diverse and not planted at regular intervals, the costs
involved with using the FMA will be high (for stands of over 100 hectares). Many actors planting
these types of forests have broader goals than just carbon (e.g. restoration, biodiversity). In
some cases, this will lead to the establishment of vegetation that does not sequester large
amounts of carbon (e.g. tussock) so may not be valuable as a source of credits.78
Other factors could reduce the attractiveness of this approach: The supply of honey is
expanding rapidly and there are concerns about quality, which may depress the price; a
“stocking rate” overlay to carbon measurement tables could be considered as part of the ETS
review. This might affect this sort of planting, due to the low stocking rate often employed in
honey production.
80 Correspondence with David Bergin (December, 2016). For more detail see (Davis et al. 2009).
81 Some activities to increase carbon biomass on pre-1990 land were eligible to earn credits under the previous
Kyoto rules (UNFCCC 2002).
82 For example, see Ekos: http://www.ekos.org.nz/rarakau---nz.html.
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Facilitating Carbon Offsets from Native Forests
83 For more detail on this see (Karpas and Kerr 2011), (Ormsby and Kerr 2015), (Leining and Kerr 2016) and (Kerr,
Carver, and Dawson Forthcoming).
84 Interviews with David Bergin and Ollie Belton and Tane’s Tree Trust group.
Facilitating Carbon Offsets from Native Forests
Conservation, which has received an application to contract out the carbon credits from its
land.85
85 Conversation with Jeffrey Cornwell, Director of Planning and Support, Science and Policy Group at the Department
of Conservation.
86 We have heard that the Climate Change Act has a privacy provision.
87 The AGS promotes new planting by giving a $1,300/hectare grant to smaller (5-300 hectare) forests. The
landowner receives the grant once the forest is established, and in exchange the Crown gets the carbon credits for the
first ten years. See: https://www.mpi.govt.nz/funding-and-programmes/forestry/afforestation-grant-scheme/.
27
Facilitating Carbon Offsets from Native Forests
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33