Response 142171545

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1. What is your name?

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Simon Papps

Emissions pricing

30. Do you agree the treatment of forestry in the NZ ETS should not result in a delay, or reduction of effort, in reducing gross emissions in other sectors of the economy?

Please select one item
Yes
No
Forestry can only ever be a temporary stop-gap, there is not an unlimited supply of land.

31. What are your views on the options presented above to constrain forestry inside the NZ ETS?

Against. The CCC is attempting to create a planned economy which does not work because there are too many unknowns. The Government does not apply restrictions on the amount of dairy or high intensity pastoral land, even though these land uses have more detrimental outcomes. Why is forestry different? If the ETS is functioning properly, the most appropriate level of forestry will be found to mitigate emissions.
What unintended consequences do we need to consider to ensure we do not unnecessarily restrict forest planting?
Any hypothetical restriction will cause a rush on afforestation in what may be inappropriate places rather than a considered response. Once the restriction is in effect, the option of reducing emissions from more afforestation is lost.

Moving Aotearoa to a circular economy

46. How would you define the bioeconomy and what should be in scope of a bioeconomy agenda?

What opportunities do you see in the bioeconomy for Aotearoa?
NZ is very good at growing fibre quickly which can be used from everything to power generation to long-lived structural products.

47. What should a circular economy strategy for Aotearoa include?

Please select one item
Yes
No

Forestry

106. Do you think we should look to forestry to provide a buffer in case other sectors of the economy under-deliver reductions, or to increase the ambition of our future international commitments?

Please select one item
Yes
No
If the ETS is working properly, the price will determine the most appropriate level of afforestation.
NZ should not be looking to purchase overseas credits to fulfill its obligations.

107. What do you think the Government could do to support new employment and enable employment transitions in rural communities affected by land-use change into forestry?

Nothing. Forestry actually generates more jobs per ha. More holistic forest systems require considerable tending and pest management, which will require local labour.

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

The default native forest ETS lookup tables are probably conservative. R&D into how to grow native species faster.

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?

Government tend to be inept at picking winners. All of the above can work but the paucity of historic research into these options was an oversight. Given the lack of time, people are going to have to make their own judgement calls.
a. Do you think limits are needed, for example, on different permanent exotic forest systems, and their location or management? Why or why not?
No. Restrictions and rules will almost certainly cause unintended consequences. The market is currently acting rationally, selecting steep and remote marginal pastoral land for afforestation.
b. What policies are needed to seize the opportunities associated with forestry while managing any negative impacts?
The Forestry NES already applies rules which have to be followed to minimise negative outcomes.
Forests, and native in particular, provide additional ecosystem services and public good in terms of water quality and biodiversity that are currently not compensated for. If these were recognised, there would likely be more native tree planting.

110. If we used more wood and wood residues from our forests to replace high-emitting products and energy sources, would you support more afforestation? Why or why not?

Please select one item
Yes
No
Why or why not?
Concrete and steel generate huge amount of GHG gases. Wood is net positive. Multi-storey building can be built out of wood. NZ could be come a forestry hub of excellence, especially as many other countries' forests are under considerable threat from climate change.

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
Very little. Forestry already has a National Environmental Standard which has been agreed by all stakeholders. Councils and Governments often act on behalf of vested interests, who are not always acting in the best interests of the environment.
The government should set the rules for the ETS and stick to them. Forestry has been affected every few years with large rule changes which detrimentally affects business confidence.
b. The private sector in influencing the location and scale of afforestation?
The price of carbon will determine the role of the private sector together with the industry's perception on whether the Government will change the rules again.

112. Pests are a risk to carbon sequestration and storage in new, regenerating and existing forest. How could the Government support pest control/management?

Recognition of carbon biomass increases in existing forest from pest control. R&D into more automated approaches to pest control. Gene editing of pest populations hold the most promise but is currently banned under NZ legislation.

114. Are there any other views you wish to share in relation to forestry?

Assuming a blanket average age of 16 years in new post-89 radiata forest is naïve. Biomass will play an increasing role in NZ's future which may result in very short rotations. Conversely, there is no recognition of forest owners storing additional biomass from increasing rotation length in any forest.