Response 315870063

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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
Radio button: Ticked Yes
Radio button: Unticked No

2. Below are two options for using biodiversity credits. Which do you agree with?

Please select one item
Radio button: Unticked Credits should only be used to recognise positive actions to support biodiversity
Radio button: Ticked Credits should be used to recognise positive action to support biodiversity, and actions that avoid future decreases in biodiversity

3. Which scope do you prefer for a biodiversity credit system?

Please select one item
Radio button: Unticked Focus on terrestrial (land) environments
Radio button: Ticked Extend from land to freshwater and estuaries (eg, wetland, estuarine restoration)
Radio button: Unticked Extend from land and freshwater to coastal marine environments (eg, seagrass restoration)
Please explain your answer here.
Initial focus of scheme should start with land based only until management and audit mechanisms are established and proven, then scope coule expand to include freshwater environments.

4. Which scope do you prefer for land-based biodiversity credits?

Please select one item
Radio button: Ticked Cover all land types, including both public and private land including whenua Māori
Radio button: Unticked Be limited to certain categories of land, for example, private land (including whenua Māori)

5. Which approach do you prefer for a biodiversity credit system?

Please select one item
Radio button: Ticked Based primarily on outcome
Radio button: Unticked Based primarily on activities
Radio button: Unticked Based primarily on projects
Please explain your answer here.
While outcomes are ultimately best, there may be a need for some selective project or activity based credits to prevent the scheme targeting easy outcomes only.

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
Radio button: Ticked Yes
Radio button: Unticked No

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

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
Radio button: Ticked Yes
Radio button: Unticked No

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
Radio button: 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.
Gradual expansion of areas of Native Flora and wetlands, further protected by the removal of introduced Fauna.

11. What are the main activities or outcomes that a biodiversity credit system for New Zealand should support?

Please explain your answer here.
Native plant restoration including wetland restoration.
Fencing of these areas, along with enhanced predator and browsing animal control.
Development of technology to support the scaling up of activities including planting, pest control and monitoring without adding massive costs for human participation.

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: 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: Not 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: Not 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: 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

13. Have we missed any other important principles?

Please explain your answer here.
Commitment to ongoing support and enhancement of the environment that the credits are based on.

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.
N/A

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.
The prime benefit of an unregulated market is likely to be the low entry cost for participants.
This is offset by the difficulty in maintaining integrity of the credits and avoiding greenwashing and milking of the scheme.

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
Checkbox: Unticked Project provision
Checkbox: Ticked Quantification of activities or outcomes
Checkbox: Unticked Monitoring measurement and reporting
Checkbox: Ticked Verification of claims
Checkbox: Ticked Operation of the market and registry
Checkbox: Ticked Investing in credits.

17. In which areas of a biodiversity credit system would government involvement be most likely to stifle a market?

Please explain your answer here.
By adding too many steps into the application process, plus much government involvement in ongoing monitoring and reporting could easily become over burdening.
Emphasis of Te Tiriti ahead of pure science could dissuade non Maori entities from partticipating.
The government role here could be to support the development of technology such as AI to allow participants to provided standardised assessments for reporting purposes.

18. Should the Government play a role in focusing market investment towards particular activities and outcomes?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No
If yes, why? Please explain your answer here.
A scheme such as this should have a set of strategic outcomes over a long period of time. To support this would require some specific activities and outcome in the near term which could be gradually added to over time to achieved the longer term strategy.

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: Not checked 3 Should a New Zealand biodiversity credit system seek to align with international systems and frameworks? 4 Radio button: 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

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
Radio button: Ticked Yes
Radio button: Unticked No
If you support this work, which regions and providers do you suggest? Please explain your answer here.
Setting up a small number of pilot projects or activities would enable both the market operators and government to refine the approach.
Ideal regions would be one or two near or in major urban centres, one or two in farming heartland (preferably with high habitat loss), and one or two in tourism areas.

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
Radio button: Unticked Little/no interaction: biodiversity credit system focuses purely on biodiversity, and carbon storage benefits are a bonus
Radio button: Ticked Some interaction: biodiversity credits should be recognised alongside carbon benefits on the same land, via both systems, where appropriate
Radio button: 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
Please explain your answer here.
If it could be achieved without significant administrative overhead, a targeted complementary mechanism between ETS and BCS for protective (such as planting of natives on erosion prone land) activity, could help expedite outcomes for both carbon and biodiversity.

22. Should a biodiversity credit system complement the resource management system?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No

23. Should a biodiversity credit system support land-use reform?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No

Provide general feedback

Any general feedback on the consultation

Add your comments, ideas, and feedback here
Whatever final form a BCS takes, it is key that administrative overhead for applicants as well as the Government are kept to a minimum, so that every dollar invested goes directly to biodiversity. This could be assisted by the investment in enhanced Information Technology in the application process as well as ongoing management processes.