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For a brighter future: Submission on He Pou a Rangi’s Draft Advice

Along with other NGOs, businesses, communities and individuals, Project Crimson & Trees That Count are thrilled to have had the opportunity to contribute to the Climate Change Commission's development of this important piece of legislation which will protect Aotearoa's health, prosperity and planet.

Increasing native tree cover across Aotearoa

Project Crimson has a 30-year history of preserving and restoring Aotearoa’s indigenous trees. Our efforts are backed by science and driven by aroha. In that time, we have saved pōhutukawa and rātā from extinction, restored neighbourhood reserves and parks, and created outdoor classrooms at schools.

We have accelerated the ability of planters around the country to increase their efforts through our (world-first) native tree marketplace, Trees That Count. Since 2018 Trees That Count has contributed over 660,000 native trees to planting projects, funded by individuals and businesses who want to help make a difference to our unique environment.

We’ve learnt a few things along the way. This document summarises our observations and challenges in native reforestation and highlights the ways in which Government can assist us in bringing about significant positive change. We appreciate the opportunity to provide this input to decision making.


Challenges and observations
  • Economics are driving environmental decisions—landowners need revenue and the economics support pine. Not only does pine provide revenue through harvesting, but it now provides additional revenue through ETS credits.

  • Additional incentives and payments, such as Emissions Trading Scheme credits, should exist where market failure exists. There is no market failure in commercial pine forestry, but there is a significant market failure with planting of natives, yet the financial incentive is to plant pine. Government policy is being driven by international agreements, which are detrimental to our special environment.  The Emissions Trading Scheme is an accounting system that doesn’t account for nature.

  • The economics don’t stack up for natives as they are weighted towards pine. This is encouraging landowners to plant pine because of the return they get. We must change the economics to be in favour of natives. Landowners need an income from native planting and/or regeneration on their land.

  • These decisions are being made by landowners now. These decisions are based on economics and not the environment, yet they will have immediate and ongoing negative effects on the environment. We must urgently change the economics to be in favour of native planting.

  • Significant research has gone into Pinus radiata, yet very little into native trees and their growth and sequestration rates. The inadequate and incorrect look-up tables for natives reflect this. Much more research funding must go into native forestry so that policy reflects the reality of nature.

  • Measurement of progress is limited to the historical constraints around measurement of trees, which has been in hectare blocks and percentage of canopy cover. That doesn’t reflect reality and nature, which grows according to seed source, light source and bird flight. We now have the technology to measure carbon and the other benefits of native trees in much smaller plantings, so policy should also be amended to reflect the measurement capability of contemporary technology.

Actions required by Government

In order to right the balance of incentives and investment that is currently in favour of exotic species towards native forestry, we recommend the Government undertakes the following actions (with urgency).

  1. Recognise the voluntary sector of the ETS is our own domestic policy and must be amended to enhance New Zealand’s unique environment, outside of international agreements that are developed around accounting principles. This means supporting and endorsing the development of a ‘biodiversity credit’ that will:
    • Act as proof of investment into native reforestation and the biodiversity gains that come from that investment
    • Accept this ‘biodiversity credit’ as an inset for landowners against their own emissions profile
    • Require investment into ‘biodiversity credit’ by visitors, migrants and high net-wealth investors to New Zealand
    • Attract investment into scheme, which can be used to pay for/provide an income to landowners who choose to plant natives instead of exotics

  2. Tag the revenue from ETS auctions to evidence-based investment in native forestry. This becomes the revenue stream that funds afforestation and an income to landowners (particularly relevant to Māori and other landowners who are looking at pine as an income stream) via a ‘biodiversity credit’

  3. Increase funding into R&D of native forestry. Pinus radiata and other exotic species have received 40 years of research, whereas native trees and forestry have had comparatively little. We need to know the real sequestration rates of our trees and healthy forests (that are rich in diverse species) and their non-timber values.

  4. Increase incentives into the planting and regeneration of native species as that is where the market failure (and greatest need) exists. We cannot achieve or exceed the Commission’s recommendation to plant 25,000 hectares per year without the appropriate incentives for the actions we want to change.

  5. Prioritise growing of new native forests to provide a long-term store of carbon – we strongly agree that new native forests must be prioritised, but add:
    1. Care and maintenance of old forests must be recognised
    2. Permanent forests must be native forests, or at least long-lived exotics (i.e. not Pinus radiata)


Feedback on specific clauses

Clause 2.2       Principle 7: Leverage co-benefits

“The actions Aotearoa takes to meet emissions budgets and targets should consider the wider benefits, including benefits to health, broader wellbeing and the environment.”

We cannot understate the salience of this point with regard to native trees. Native afforestation is one of the few emissions mitigation strategies with the potential to provide economic benefit; add significant biodiversity gain; improve water and soil health; and drive holistic community well-being. 

The benefits and carbon value of pre-1990 native forests must be reflected in legislation. Domestic credits (i.e. biodiversity credits) should be available to the guardians of these forests.


Clause 3.2       A different, but important, role for forestry

“New permanent native forests absorb carbon more slowly but will continue to do so for centuries until they reach maturity.”

We support the Commission’s current focus on native forestation and would like to see it extended further in terms of promoting native plantations over exotics. Exotic plantations are an historical way of doing things; this report has the potential to cast a new vision in terms of the role of native forestry which can be echoed in the upcoming amendment of the Forestry Act. Exotic plantations are inferior in terms of co-benefits as well as long-term sequestration, and also create a problem in terms of invasive weeds (which the Government is currently spending millions to remove).


Clause 3.3       Avoid pushing the burden to future generations

“Build a long-term carbon sink large enough to offset residual long-lived gas emissions without ongoing land use conversion. This means starting now to grow new native forests on relatively less productive land...”

In order to successfully begin this process it is vital that the Government incentivises the planting or regeneration of such land. Landowners facing difficult decisions about land use cannot be expected to prioritise carbon sequestration initiatives without financial support or return benefit of some kind; they also need to be assured that the scheme is durable over subsequent administrative changes.


Clause 3.8.7    Forestry

“The rate that we can plant or revert native forest would likely be limited by nursery capacity, pest control and fencing.”

We strongly support the need for native forestation best practice. Proper preparation and maintenance (e.g. Forest Management Plans) will be vital to the success of any forest establishment or regeneration scheme. It is, however, short-sighted to see this as a limitation on planting; it is an opportunity to develop an entire industry that can play a vital role in Aotearoa’s future. Seed collection, propagation, planting, fencing, pest control, maintenance: all these activities belong to an inter-related economy that can grow and thrive when properly supported. This requires not simply an injection of funding from the Government, but oversight from an independent body that understands the nuances of the industries and has extant relationships with the stakeholders involved. 

Further, it is data on future plantings and guaranteed orders that will support the native nursery sector to expand and upskill in order to meet future planting requirements. This requires a new procurement system to be established, not direct funding by government into selected nurseries. Best practice principles and eco-sourcing must be maintained.


Clause 3.8.7    Forestry

            “Our path assumes that no further native deforestation occurs after 2025.” 

It is essential that legislative measures to protect existing native forests, which currently enjoy little to no protection under the Forestry Act, are put in place. Providing for an extensive native planting programme on one hand and removing existing trees (particularly large trees with high carbon sequestration potential) on the other is counter-productive at best. Ideally, Aotearoa would implement a model which incorporates protection of existing healthy heritage forests, regeneration of degraded native forests, planting of new protected forests and planting of new livelihood native forests (for appropriate harvesting rather than clear felling) which maximise economic benefit to local communities. [1]


Clause 3.8.7    Forestry

“Timber can displace emissions intensive materials such as steel and cement in buildings. This reduces embodied emissions and can lock up carbon for several decades.”

We support a methodology that creates value-add products in Aotearoa instead of carbon intensive commodities that also require offshore shipping. Once the raw product from commercial logging (i.e. pine) has left our shores, we cannot know that carbon is retained within it.

Further, we support amendments to the Forestry Act to create a viable and profitable industry around sustainable growth, harvesting and use of native forestry.

Clause 5.7       Impacts of land use change on communities

“...we have heard through our engagement about concerns that the speed and potential extent of afforestation could have negative impacts on rural communities and provincial centres that are reliant on the food and fibre industry for employment.”

Afforestation policy carried out via a Non-Governmental Organisation with the social license to operate in these communities has the potential to mitigate many of these concerns. Trees That Count currently operates in many of these communities and is aware of their concerns: and also their desire to contribute positively. We are confident that an approach combining the establishment of a new industry and protection of existing incomes is possible.

We support the recognition of community plantings in domestic policy, given that every native tree sequesters carbon and has many other benefits to nature and our natural capital.


Clause 5.7.1    Exotic forestry

“Native afforestation could be incentivised by extending grant schemes such as One Billion Trees or by developing ecosystem services payment schemes that could reward the other environmental benefits of native forests.”     

We suggest that there are more innovative approaches available to maximise return on investment than a straightforward injection of Government funding such as One Billion Trees. A successful scheme will involve many strata of society [2]. Trees That Count has proven the ability of a delivery partner to leverage investment into exceptional results. We are also very supportive of and indeed, are currently developing a ‘Biodiversity Credit’ scheme to incentivise and reward native forestry.


Clause 5.8       Environmental impacts

“...native forests in Aotearoa host hundreds of threatened species and thousands of species…”

The significance of the positive impacts of native forests for biodiversity cannot be overstated. The dire and immediate need for investment into native forestry and our natural capital have been well articulated by the Aotearoa Circle.


Clause 6.1.4    Manage forests to provide a long-term carbon sink

“The additional carbon removed by small areas of permanent vegetation on farms is not currently recognised in target accounting, although it is in the national greenhouse gas inventory. Ongoing technology developments, however, may make it more possible to robustly estimate emissions from these areas in future.”

Trees That Count and Tāne’s Tree Trust have the body of data (via the TTC marketplace) and scientific ability to carry out consequential research in this area. With studies pointing to the benefit of initiatives such as micro-forestation, we believe it is vital to accurately capture the contribution of smaller-scale plantings to wider emissions efforts. It is wise in terms of risk mitigation to focus on and capture data from a larger quantity of small-scale plantings rather than leaving a large planting in one section of the country vulnerable to risks such as drought or fire. We also believe this is salient to incentivising everyday New Zealanders in moving toward emissions reduction—as with our COVID-19 strategy, the small efforts of the many need to be recognised.



[1] De Sacco, Hardwick, et al. “Ten golden rules for reforestation to optimize carbon sequestration, biodiversity recovery and livelihood benefits”. Global Change Biology, 2021;00:1-21.

[2] De Sacco, Hardwick, et al. “Ten golden rules for reforestation to optimize carbon sequestration, biodiversity recovery and livelihood benefits”. Global Change Biology, 2021;00:1-21.