Submitter details
1. Submitter name
Individual or organisation name
(Required)
Yellow Eyed Penguin Trust
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
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No
Please explain your answer here.
As it currently stands, there is not a straightforward way for companies to invest in/offset carbon emissions. The options are usually direct sponsorship of individual companies/species/habitats etc. which leads to companies/species/habitats missing out on funding due to public perception (charismatic megafauna etc.). This also doesn't usually recognize on the ground work such as pest control, weed work, and plant releasing for example.
The current Emissions Trading Scheme also doesn't necessarily promote conservation, as a lot of native species are slow growing, and may not reach the height requirement. Instead it promotes the planting of fast growing exotics (Pines etc.) which are then felled and transported across the world meaning the carbon taken up by the tree is then in a way released back into the environment through shipping and processing emissions.
The current Emissions Trading Scheme also doesn't necessarily promote conservation, as a lot of native species are slow growing, and may not reach the height requirement. Instead it promotes the planting of fast growing exotics (Pines etc.) which are then felled and transported across the world meaning the carbon taken up by the tree is then in a way released back into the environment through shipping and processing emissions.
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.
Option 2 is best as it promotes future thinking, not just here and now. It could also help offset of companies going electric etc. as these could be argued that they don't currently support biodiversity, but they would potentially avoid future decreases in biodiversity by lowering emissions.
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.
Although it will be harder to include all habitats, all habitats are linked. Terrestrial habitats effect freshwater habitats, which in turn effect marine habitats. Marine habitats are often put in the too hard basket, yet it acts as one of our major carbon sinks,
"The ocean acts as a carbon sink and absorbs about 31% of the CO2 emissions released into the atmosphere according to a study published by NOAA and international partners in Science" - National Centers for Environmental Information.
New Zealand also has a large amount of biodiversity in all habitats, so as a result all habitats should be recognized, and conservation should be promoted in all habitats, not just in easy to reach places.
"The ocean acts as a carbon sink and absorbs about 31% of the CO2 emissions released into the atmosphere according to a study published by NOAA and international partners in Science" - National Centers for Environmental Information.
New Zealand also has a large amount of biodiversity in all habitats, so as a result all habitats should be recognized, and conservation should be promoted in all habitats, not just in easy to reach places.
4. Which scope do you prefer for land-based biodiversity credits?
Please select one item
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Cover all land types, including both public and private land including whenua Māori
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Ticked
Be limited to certain categories of land, for example, private land (including whenua Māori)
Please explain your answer here.
The credit system should be prioritized not on land type but on who manages said land. The credits shouldn't be available to Government affiliated groups, but for NGO's, Charity's, Private land etc. as it needs to be a way for smaller groups to help with funding issues. If for example DOC were able to generate Biodiversity credits; since they manage such a large area of public conservation land, the Credit system would be swamped with Government affiliated credits, devaluing the credits that smaller groups would be relying on.
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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Based primarily on activities
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Based primarily on projects
Please explain your answer here.
Based on Activities and based on Projects, would be preferred as they recognized all the time and effort which goes into conservation. Plant preparation, seed collecting, growing plants, plant releasing, pest control, on the ground species monitoring etc. There are masses of hours which would not be recognized with an Outcome based system. By Activity is preferred because credits would be received faster, which in turn could then be used to fund more on the ground conservation at a much faster rate.
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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Unticked
Yes
Radio button:
Ticked
No
Please explain your answer here.
Conservation takes different lengths of time depending on location. For example, if a groups goal was to plant a certain number of trees, and look after them until a certain height was achieved; a group planting in nice fertile farmland soils would achieve this goal a lot faster than a group planting in sand dunes. It would work best if the credits were issued earlier on, which would help with funding, but there still needs to be a way to enforce the work is actually done, and done to a high standard, and to make sure projects aren't just abandoned as soon as credits were awarded.
7. Should biodiversity credits be awarded for increasing legal protection of areas of indigenous biodiversity?
Please select one item
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Ticked
Yes
Radio button:
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No
Please explain your answer here.
Yes as this promotes the protection of already present areas of indigenous biodiversity, so long as the credits remained with the title holder, unless they wished for the credits to be "donated" to QEII trust for example. This would hopefully help the credits hold their value, for reasons mentioned in Question 4.
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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Unticked
Yes
Radio button:
Ticked
No
Please explain your answer here.
As an offset, credits would promote development companies degrading areas and investing the money elsewhere. If they were to be used to offset development, the offset should be limited to the surrounding area.
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
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No
Please explain your answer here.
More and more companies are trying to appeal to the public by showing they are doing the right thing for nature by offsetting emissions etc. However issues arise when companies begin "greenwashing" and making claims that are false or misleading. A BCS would make a quantifiable resource which companies etc. could then use to appeal to the public with a system which proved the conservation was being done correctly, and right here in New Zealand.
10. What do you consider the most important outcomes a New Zealand biodiversity credit system should aim for?
Please explain your answer here.
Promoting and helping to fund, Land to Sea conservation. Trying to reduce/halt the decline of Endemic Flora and Fauna, through all conservation means. The system should not promote the planting of exotic trees, or the early abandonment of projects. Ideally the ultimate outcome would see all remaining endemic flora and fauna, in all environments, return to pre-human numbers, and all remaining habitats protected from degradation, and regenerated back to pre-human states.
11. What are the main activities or outcomes that a biodiversity credit system for New Zealand should support?
Please explain your answer here.
Planting endemic natives, including all the work that goes into this (seed collecting, growing the plants, planting the plants, weed control, releasing). Pest control including all work that goes into this (calibrating, cleaning, setting, clearing, checking). Endemic species work including all work that goes into this (rearing, rehabilitation, intervention, monitoring). It should promote activities which help return endemic biodiversity to healthier levels (IUCN least concern if possible), and should promote halting the degradation of all habitats.
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: Not checked 1 | Principle 1 – Permanent or long-term (eg, 25-year) impact 2 Radio button: 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: Checked 1 | Principle 7 – Maximise positive impact on biodiversity 2 Radio button: Not 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 system should be designed to have a positive impact on endemic biodiversity. It should be permanent/long term to prevent abandonment and ensure conservation is completed to a high standard. It should reward all nature positive activities, as true conservation includes all core jobs (weedwork, pest control, plant releasing, etc.) not just species work. The system should be robust and unable to be abused, which would promote investment into the credit system.
13. Have we missed any other important principles?
Please explain your answer here.
Principle 7 should focus on ENDEMIC biodiversity, which would stop credits being used for conservation work which primarily benefited exotic species such as deer, trout, exotic passerines for example. It would also prevent the planting of fast growing exotic plant species.
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.
The funds generated would need to significantly outweigh the costs needed to earn the credits (reporting, data collecting, evidence gathering etc.)
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.
There are few benefits to an unregulated system and many risks. Primarily the complete collapse of the system due to abuse, devaluation, and the withdrawing of investors. If there is no way to prove a credit was earned honestly, no company which truly cared about the environment would want to invest in the scheme. Also if the market was swamped with "false" credits the price per credit would drop meaning the benefit to conservation would be lost.
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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Unticked
Project provision
Checkbox:
Unticked
Quantification of activities or outcomes
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Unticked
Monitoring measurement and reporting
Checkbox:
Ticked
Verification of claims
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Ticked
Operation of the market and registry
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Investing in credits.
Please explain your answer here.
The actual system would need to be government affiliated to prevent abuse and to ensure the system was verifiable, if it were not, investors would be wary to invest in the system.
17. In which areas of a biodiversity credit system would government involvement be most likely to stifle a market?
Please explain your answer here.
Quantification of activities/outcomes, monitoring/ measuring. This is because there are more conservation activities going on in New Zealand, than there are Government staff. This means that when all these different groups started trying to prove their work, a bottleneck would be created causing delays and lags in processing time.
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
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No
If yes, why? Please explain your answer here.
Yes the investment should focus on protecting endemic flora/fauna/geographic areas. But the system should not rule out protecting all endemic species (using threat classifications). This is because through protecting one species through trapping, habitat regeneration etc. many other species will benefit.
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: 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: 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.
Biodiversity practices in New Zealand differ from those over seas, therefore credits should be aligned with New Zealand based conservation practices.
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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Ticked
Yes
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No
If you support this work, which regions and providers do you suggest? Please explain your answer here.
There needs to be a broad selection of Regions and Providers, as different regions/providers face different issues.
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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Ticked
Little/no interaction: biodiversity credit system focuses purely on biodiversity, and carbon storage benefits are a bonus
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Unticked
Some interaction: biodiversity credits should be recognised alongside carbon benefits on the same land, via both systems, where appropriate
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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.
These credits should recognize the hard work that goes into conservation, not just planting monocultures of exotic plants. The ETS already covers plantations. Investors should have the option to buy into a scheme which is primarily conservation focused.
22. Should a biodiversity credit system complement the resource management system?
Please select one item
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Unticked
Yes
Radio button:
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No
Please explain your answer here.
Significant Natural Areas and endangered species should definitely be included, but not at the expense of less significant areas/less threatened species. As biodiversity is all connected, the conservation of all habitats and species should be promoted. The system should focus on Endemic species, if it were to be species specific.
23. Should a biodiversity credit system support land-use reform?
Please select one item
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Yes
Radio button:
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No
Please explain your answer here.
So long as the permanent native forest was PERMAMENT, and was not torn down in the future. As erosion-prone land is generally found at the top of catchments, this would also promote the planting of native trees to stabilize the soil, which would lead to cleaner/less sediment polluted waterways.
Provide general feedback
Any general feedback on the consultation
Add your comments, ideas, and feedback here
There is a definite gap in the market for this credit system. During the most recent DOC community fund round, the total dollar value of all applications came out to be $77 million for a fund which has a maximum budget of $9.2 million, a deficit of $67.8 million. If even a quarter of that deficit could be earned through a BCS it would almost double the amount of funding which is available through the community fund.