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Te hau mārohi ki anamata: Transitioning to a low-emissions and climate-resilient future

Our parent organisation, Project Crimson Trust, recently welcomed the opportunity to make a submission on the forestry segment of the Government's Draft Emissions Reduction Plan. Read it below.

Executive Summary

The Draft Emissions Reduction Plan envisages that the best decisions for future generations will positively influence not only emissions and climate outcomes, but “the wellbeing of New Zealanders”. We wholeheartedly support this approach. Because our work is centred on native trees, we wish to specifically address the Forestry section of the Plan and submit that greater emphasis on native forests is the only way to ensure that broader objectives (biodiversity, wellbeing, cultural enhancement) are met alongside carbon sequestration.

If the Government truly wishes to make the best decisions for future generations, native forestry must be prioritised and incentivised over exotic planting. 

We believe this can best be achieved as follows:

  • incentivising native planting for landowners
  • embracing native forests as living, growing and productive entities
  • enabling private sector climate and biodiversity action


Incentivising native planting for landowners

DERP 108: What’s needed to make it more economically viable to establish and maintain native forest through planting or regeneration on private land? 

As an organisation with oversight of more than 1,000 native afforestation and reforestation projects around Aotearoa New Zealand, we know the demand for native planting, including on private land, to be incredibly high. Each year hundreds of landowners apply for funded native trees through our Trees That Count programme; each year we are limited only by the funding we generate in meeting this demand.

Landowners are more than willing to plant native trees rather than pine when the Government makes the numbers stack up for them. With exotics such as P. radiata currently more economically viable than native trees for large-scale planting efforts, we are simply not encouraging responsible use of land. The Report notes that there are currently “limited commercial returns” for native forestry; this is a vital lever to shift for incentivising change (p119).

We welcome the package of changes outlined that aims to “bring down the cost of planting native forests, improve economic return, address supply chain barriers, develop sustainable models to incentivise afforestation and improve planting success”, and suggest that if the focus of Emissions Reduction really is on the holistic wellbeing of future generations, prioritising this work is vital (p120). We would question why the investigation of permanent exotic forests is currently prioritised as an earlier deliverable (end of 2022) than the package for native forests (end of 2023). 

As a purchaser of more than 250,000 native trees nationwide each year (and growing rapidly), we would welcome consultation from the Government on its review of investment and regulation for the native nursery sector (p119). 


Embrace native forests as living entities

DERP 109: What kinds of forests and forestry systems, for example long-rotation alternative exotic species, continuous canopy harvest, exotic to native transition, should the Government encourage and why? 

Firstly, we note that the science does not currently back exotic to native transition forestry and would suggest that further research needs to be undertaken before any significant investment in this methodology is progressed.

While we acknowledge the significance of Crown and covenanted native forest reserves, we also believe that continuous canopy native forestry has a significant role to play in making the economics stack up for native trees. We strongly support research into continuous cover and nature-based forestry systems: this is urgently needed to increase our knowledge of native forests’ biodiversity, sequestration abilities, water and soil quality, rongoā and other non-timber values (the significance of which cannot be under-emphasised).

Building communities, job opportunities and products around native forests with a view to long-term return enables the possibility of supporting entire rural communities via domestic production. Weaving native forests back into these areas is vital to restore the relationship between people and whenua, and to help communities thrive economically.


Enabling private sector climate and biodiversity action

DERP 111: What role do you think should be played by: a. central and local governments in influencing the location and scale of afforestation through policies such as the resource management system, ETS and investment b. the private sector in influencing the location and scale of afforestation? Please provide reasons for your answer. 

Government must act to prioritise and incentivise native forestry over exotic forestry. This should be reflected in the structure of Te Uru Rākau—New Zealand Forest Service. Policy needs to move away from short-term, siloed thinking about carbon sequestration into a nature-based model that halts biodiversity loss, builds adaptation resistance, delivers abundant co-benefits, and ultimately scales up long-term carbon sinks. We see it as a Government mandate to make native tree planting the most accessible, cost-effective and attractive option for all New Zealanders exploring forestry opportunities, whether this be via the Resource Management Act, Emissions Trading Scheme, National Policy Statement on Indigenous Biodiversity, or other policy levers.

The Report makes it clear, though, that Government policy alone cannot successfully achieve a positive emissions (or even low emissions) future for Aotearoa. We agree that there is a significant role for the private sector to play in creating a very real impact for native forestry. Our programme Trees That Count is a particularly successful example of harnessing private investment into native forestry. Having received more than $2 million in private sector funding for native tree planting in 2021 alone, we know that building a framework to unite corporate support into native forestry is possible, and we are poised to upscale this model further through investment opportunities in large-scale, high-impact new native forest projects. 

We would welcome Government schemes that reward corporates and SMEs (including offshore investors) for making real, sustainable impact for Aotearoa’s native forests, helping disincentivise global carbon investment schemes that deliver no positive impacts for Aotearoa New Zealand. We are working towards measurement mechanisms that will eventually enable a financial return for investment in our biodiversity, and hope that the Government will move quickly to develop the policy framework that supports this scheme and enables a highly visible, measurable reward for corporates and business leaders looking to enhance their business sustainability impact.