Submitter details
1. Submitter name
Individual or organisation name
(Required)
Jesse Card
Section 1: What is a biodiversity credit system?
1. Do you support the need for a biodiversity credit system (BCS) for New Zealand?
Please select one item
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Ticked
Yes
Radio button:
Unticked
No
2. Below are two options for using biodiversity credits. Which do you agree with?
Please select one item
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Credits should only be used to recognise positive actions to support biodiversity
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Credits should be used to recognise positive action to support biodiversity, and actions that avoid future decreases in biodiversity
Please explain your answer here.
I believe credits should only be issued in recognition of biodiversity, but that there should be a credit futures market should be part of it to support current action to encourage expanding and adding biodiversity.
3. Which scope do you prefer for a biodiversity credit system?
Please select one item
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Focus on terrestrial (land) environments
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Extend from land to freshwater and estuaries (eg, wetland, estuarine restoration)
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Extend from land and freshwater to coastal marine environments (eg, seagrass restoration)
Please explain your answer here.
I believe the initial focus should be on land and freshwater and expand to estuaries and coastal marine environments over time (phased in over, say, 50 years)
4. Which scope do you prefer for land-based biodiversity credits?
Please select one item
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Ticked
Cover all land types, including both public and private land including whenua Māori
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Unticked
Be limited to certain categories of land, for example, private land (including whenua Māori)
Please explain your answer here.
Maintaining and improving biodiversity is the job of everyone, including goverment and private entitities. THey should all bear both the costs and benefits thereof.
DoC holding a large portion of credits at present would give stability to the credit system as well as a good funding method for maintaining and expanding them.
DoC holding a large portion of credits at present would give stability to the credit system as well as a good funding method for maintaining and expanding them.
5. Which approach do you prefer for a biodiversity credit system?
Please select one item
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Based primarily on outcome
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Unticked
Based primarily on activities
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Based primarily on projects
Please explain your answer here.
I'm quite torn on this, but it might be ameliorated by a credit futures market to split upon.
I think an outcome-based credit would be most accurate in getting the results the credits intend. It might also encourage creative ways to achieve the results that aren't intuitive. On the other hand, it might be easier to game the system and have unintended consequences without frequent tinkering.
I think an outcome-based credit would be most accurate in getting the results the credits intend. It might also encourage creative ways to achieve the results that aren't intuitive. On the other hand, it might be easier to game the system and have unintended consequences without frequent tinkering.
6. Should there also be a requirement for the project or activity to apply for a specified period to generate credits?
Please select one item
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Ticked
Yes
Radio button:
Unticked
No
Please explain your answer here.
Yes. We know even short-term disturbances to ecosystems can have very long-lasting effects.
7. Should biodiversity credits be awarded for increasing legal protection of areas of indigenous biodiversity?
Please select one item
Radio button:
Ticked
Yes
Radio button:
Unticked
No
Please explain your answer here.
Absolutely. QEII should have distinct incentives that can help with maintaining parcels as intended. Without the credits it's too easy for these protected areas to fall victim of their neighbor's actions or inactions.
8. Should biodiversity credits be able to be used to offset development impacts as part of resource management processes, provided they meet the requirements of both the BCS system and regulatory requirements?
Please select one item
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Ticked
Yes
Radio button:
Unticked
No
Please explain your answer here.
I believe offsets are the best way to go. There's little incentive to maintain a market for many other than as a feel-good measure.
However, if they're an offset, I believe we should establish a "ground truth" goal that all development is measured against and must offset to.
For example: The ideal should be a fully biodiverse Aotearoa as it was before human arrival. Including the lost species. Every move away from that should incur an offset. A full offset would be from a fully biodiverse ecosystem for that area to, for example, an industrial area that supports no life.
Everything in between would incur fractional credits. An isolated park that supports limited wildlife, but not natives might only incur a 10th of a credit. If it is fully suitable to support biodiversity, but none is present due to location, isolation, etc, then it is neutral with no cost. A fully biodiverse ecosystem that is close to an undisturbed state would get a full credit.
This would be an incentive for the owner to make the small actions to promote biodiversity, turning it into an asset.
This would provide an immediate market where DoC can sell their credits to other users, generating income for DoC to maintain and improve their areas as well as fund grants for private users to improve their own land for biodiversity.
However, if they're an offset, I believe we should establish a "ground truth" goal that all development is measured against and must offset to.
For example: The ideal should be a fully biodiverse Aotearoa as it was before human arrival. Including the lost species. Every move away from that should incur an offset. A full offset would be from a fully biodiverse ecosystem for that area to, for example, an industrial area that supports no life.
Everything in between would incur fractional credits. An isolated park that supports limited wildlife, but not natives might only incur a 10th of a credit. If it is fully suitable to support biodiversity, but none is present due to location, isolation, etc, then it is neutral with no cost. A fully biodiverse ecosystem that is close to an undisturbed state would get a full credit.
This would be an incentive for the owner to make the small actions to promote biodiversity, turning it into an asset.
This would provide an immediate market where DoC can sell their credits to other users, generating income for DoC to maintain and improve their areas as well as fund grants for private users to improve their own land for biodiversity.
Section 2: Why do we need a biodiversity credit system?
9. Do you think a biodiversity credit system will attract investment to support indigenous biodiversity in New Zealand?
Please select one item
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Ticked
Yes
Radio button:
Unticked
No
10. What do you consider the most important outcomes a New Zealand biodiversity credit system should aim for?
Please explain your answer here.
I think the most ideal outcome that the system aims for are:
Large areas in every ecosystem that support all varieties of native biodiversity. These areas should be large and undisturbed enough to provide stable populations of all our species indefinitely. They should be connected by wildlife corridors to allow movement of animals and plants in a relatively safe manner.
All effort should be taken to de-extinct and reestablish native species that have disappeared since the beginning of human habitation.
Large areas in every ecosystem that support all varieties of native biodiversity. These areas should be large and undisturbed enough to provide stable populations of all our species indefinitely. They should be connected by wildlife corridors to allow movement of animals and plants in a relatively safe manner.
All effort should be taken to de-extinct and reestablish native species that have disappeared since the beginning of human habitation.
11. What are the main activities or outcomes that a biodiversity credit system for New Zealand should support?
Please explain your answer here.
The main outcomes should be indefinitely protected contiguous areas of native ecosystems that are protected from predators and pests.
Permanent protected areas like QEII should have significant benefits for the owners to make them attractive. This includes making them financially sustainable to protect from pests and invasives by: rebating rates and giving a financial benefit to pay for trapping or have trapping provided by councils.
Providing high quality ecosystems should have immediate benefits attractive enough to encourage providing more over current disturbed areas. There should be grants and incentives at the beginning to support planting projects, invasives removals, and pest control.
All incentives should be centered around protecting our most endangered species first and expanding outward based on: contiguous area to support growth, wildlife corridors to enhance spread, and quality and variety of biodiverse ecosystems.
Permanent protected areas like QEII should have significant benefits for the owners to make them attractive. This includes making them financially sustainable to protect from pests and invasives by: rebating rates and giving a financial benefit to pay for trapping or have trapping provided by councils.
Providing high quality ecosystems should have immediate benefits attractive enough to encourage providing more over current disturbed areas. There should be grants and incentives at the beginning to support planting projects, invasives removals, and pest control.
All incentives should be centered around protecting our most endangered species first and expanding outward based on: contiguous area to support growth, wildlife corridors to enhance spread, and quality and variety of biodiverse ecosystems.
Section 3: How should we design and implement a biodiversity credit system?
12. Of the following principles, which do you consider should be the top four to underpin a New Zealand biodiversity credit system?
| Principle 1 – Permanent or long-term (eg, 25-year) impact 1 Radio button: Checked 1 | Principle 1 – Permanent or long-term (eg, 25-year) impact 2 Radio button: Not checked 2 | Principle 1 – Permanent or long-term (eg, 25-year) impact 3 Radio button: Not checked 3 | Principle 1 – Permanent or long-term (eg, 25-year) impact 4 Radio button: Not checked 4 |
| Principle 2 – Transparent and verifiable claims 1 Radio button: Not checked 1 | Principle 2 – Transparent and verifiable claims 2 Radio button: Not checked 2 | Principle 2 – Transparent and verifiable claims 3 Radio button: Not checked 3 | Principle 2 – Transparent and verifiable claims 4 Radio button: Not checked 4 |
| Principle 3 – Robust, with measures to prevent abuse of the system 1 Radio button: Not checked 1 | Principle 3 – Robust, with measures to prevent abuse of the system 2 Radio button: Not checked 2 | Principle 3 – Robust, with measures to prevent abuse of the system 3 Radio button: Not checked 3 | Principle 3 – Robust, with measures to prevent abuse of the system 4 Radio button: Checked 4 |
| Principle 4 – Reward nature-positive additional activities 1 Radio button: Not checked 1 | Principle 4 – Reward nature-positive additional activities 2 Radio button: Not checked 2 | Principle 4 – Reward nature-positive additional activities 3 Radio button: Checked 3 | Principle 4 – Reward nature-positive additional activities 4 Radio button: Not checked 4 |
| Principle 5 – Complement domestic and international action 1 Radio button: Not checked 1 | Principle 5 – Complement domestic and international action 2 Radio button: Not checked 2 | Principle 5 – Complement domestic and international action 3 Radio button: Not checked 3 | Principle 5 – Complement domestic and international action 4 Radio button: Not checked 4 |
| Principle 6 – No double-counting, and clear rules about the claims that investors can make 1 Radio button: Not checked 1 | Principle 6 – No double-counting, and clear rules about the claims that investors can make 2 Radio button: Not checked 2 | Principle 6 – No double-counting, and clear rules about the claims that investors can make 3 Radio button: Not checked 3 | Principle 6 – No double-counting, and clear rules about the claims that investors can make 4 Radio button: Not checked 4 |
| Principle 7 – Maximise positive impact on biodiversity 1 Radio button: Not checked 1 | Principle 7 – Maximise positive impact on biodiversity 2 Radio button: Checked 2 | Principle 7 – Maximise positive impact on biodiversity 3 Radio button: Not checked 3 | Principle 7 – Maximise positive impact on biodiversity 4 Radio button: Not checked 4 |
Please explain your answer here.
The primary benefit must be nature before anything else. Being attractive to humans should just be a nice side effect.
14. What assurance would you need to participate in a market, either as a landholder looking after biodiversity or as a potential purchaser of a biodiversity credit?
Please explain your answer here.
As a landholder a steady value is nice, if not critical. I think if the credits are granted to the holder of most of New Zealands best and most biodiverse land, Department of Conservation, as expected, that would provide a very steady provider, keeping the price steady.
15. What do you see as the benefits and risks for a biodiversity credit market not being regulated at all?
Please explain your answer here.
Being used as a sham scheme to move money and enrich people without much actual environmental benefit.
16. To have the most impact in attracting people to the market, which component(s) should the Government be involved in?
Please select all that apply
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Project provision
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Quantification of activities or outcomes
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Monitoring measurement and reporting
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Verification of claims
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Operation of the market and registry
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Investing in credits.
Please explain your answer here.
Honestly, there is high trust in New Zealand's government and departments overall. I think the more involvement, the better so long as it's independently operated outside of changing leadership.
17. In which areas of a biodiversity credit system would government involvement be most likely to stifle a market?
Please explain your answer here.
Permanently excluding or including certain parties or price fixing.
The ETS's largest failure is the gifting of credits to certain industries for free or at overly large discounts for too long a period.
Climate change has been a known risk for 7 decades now. It's been a large cultural point of knowledge for the last 3. There is no excuse for not having taken it into account now.
The ETS's largest failure is the gifting of credits to certain industries for free or at overly large discounts for too long a period.
Climate change has been a known risk for 7 decades now. It's been a large cultural point of knowledge for the last 3. There is no excuse for not having taken it into account now.
18. Should the Government play a role in focusing market investment towards particular activities and outcomes?
Please select one item
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Ticked
Yes
Radio button:
Unticked
No
If yes, why? Please explain your answer here.
Yes, the government already has good knowledge and connections for establishing the species and ecosystems most at threat and prioritizing them.
19. On a scale of 1, not relevant, to 5, being critical, should a New Zealand biodiversity credit system seek to align with international systems and frameworks?
| Should a New Zealand biodiversity credit system seek to align with international systems and frameworks? 1 - not relevant Radio button: Not checked 1 - not relevant | Should a New Zealand biodiversity credit system seek to align with international systems and frameworks? 2 Radio button: Not checked 2 | Should a New Zealand biodiversity credit system seek to align with international systems and frameworks? 3 Radio button: Checked 3 | Should a New Zealand biodiversity credit system seek to align with international systems and frameworks? 4 Radio button: Not checked 4 | Should a New Zealand biodiversity credit system seek to align with international systems and frameworks? 5 - is critical Radio button: Not checked 5 - is critical |
Please explain your answer here.
New Zealand is in a unique position for having a high level of endemic species and a high chance of recovery due to the late arrival of humans. This may diverge our needs from international systems/frameworks.
20. Should the Government work with private sector providers to pilot biodiversity credit system(s) in different regions, to test the concept?
Please select one item
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Yes
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No
If you support this work, which regions and providers do you suggest? Please explain your answer here.
No, the Government should just make a system and commit fully. Of course it should be willing to accept change and criticism, but pilot programs merely invite criticism, delay, and additional cost. We have delayed long enough!
Section 4: How a biodiversity credit system could complement the wider system
21. What is your preference for how a biodiversity credit system should work alongside the New Zealand Emissions Trading Scheme or voluntary carbon markets?
Please select one item
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Unticked
Little/no interaction: biodiversity credit system focuses purely on biodiversity, and carbon storage benefits are a bonus
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Ticked
Some interaction: biodiversity credits should be recognised alongside carbon benefits on the same land, via both systems, where appropriate
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Unticked
High interaction: rigid biodiversity ‘standards’ are set for nature-generated carbon credits and built into carbon markets, so that investors can have confidence in ‘biodiversity positive’ carbon credits
22. Should a biodiversity credit system complement the resource management system?
Please select one item
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Ticked
Yes
Radio button:
Unticked
No
Please explain your answer here.
Yes, as time is of the essence, we should prioritize the areas most at risk with initial investments.
23. Should a biodiversity credit system support land-use reform?
Please select one item
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Ticked
Yes
Radio button:
Unticked
No
Provide general feedback
Any general feedback on the consultation
Add your comments, ideas, and feedback here
I very much support this idea, but also think that it should be started as a mix of voluntary and compulsory. Similar to the ETS being for largest emitters.
I think that offsets should be required for the most adverse type environments. Ones that actively harm the areas around them: Combustion-based power plants, heavy industry, anything with large emissions of air or water changes. Shortly thereafter it can also include spaces like fully-paved areas that do not support any living things. It should expand those needing offsets to less adverse areas over time. This will provide a metered flow of purchasers to expand as the source of credits also increases.
The ultimate goal in pricing a system would be enough area to support all of Aotearoa's species indefinitely without fear or them going extinct from human activity or human-introduced species. This would include species currently extinct being brought back and reestablished with permanent sustainable populations.
I think that offsets should be required for the most adverse type environments. Ones that actively harm the areas around them: Combustion-based power plants, heavy industry, anything with large emissions of air or water changes. Shortly thereafter it can also include spaces like fully-paved areas that do not support any living things. It should expand those needing offsets to less adverse areas over time. This will provide a metered flow of purchasers to expand as the source of credits also increases.
The ultimate goal in pricing a system would be enough area to support all of Aotearoa's species indefinitely without fear or them going extinct from human activity or human-introduced species. This would include species currently extinct being brought back and reestablished with permanent sustainable populations.