Response 530335962

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1. Submitter name

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CarbonHq

Chapter 2: Expected impact of current NZ ETS

2.1. Do you agree with the assessment of reductions and removals that the NZ ETS is expected to drive in the short, medium and long term?

Please select one item
Yes
No
Unsure
Please explain your answer here
The system simple is not an ETS.
Emitters need to buy the right to the CO2 they emit which will be in the atmosphere in perpetuity.
No amount of forestry will remove co2 in perpetuity and therefore it simply should npt be part of the equation.
To date gross emission remain statistically unchanged since ETS inception

2.2. Do you have any evidence you can share about gross emitter behaviour (sector specific, if possible) in response to NZU prices?

Please write your answer here
Vector has done some work " which I assume is a proxy for many industries.
https://www.vector.co.nz/articles/vector-carbon-abatement-cost-curve
in this it shows that the low hanging fruit has been actioned and the price need to climb about 140 to make abatement cost effective .
In short anything under $140 it is cheaper form them to buy NZU than abate

2.3. Do you have any evidence you can share about land owner and forest investment behaviour in response to NZU prices?

Please write your answer here
The sheer level of registration, the inappropriate mono culture shows a vast mismatch between the NZU yield per hectare and the necessary NZU price to affected emission reduction.

2.4. Do you agree with the summary of the impacts of exotic afforestation?

Please select one item
Yes
No
Unsure
Please explain your answer here
Short term solution for a long term problem, land degradation when replanted, vulnerabilty t pest, disease and fire,

Chapter 3: Driving gross emissions reductions through the NZ ETS

3.1. Do you agree with the case for driving gross emissions reductions through the NZ ETS?

Please select one item
Yes
No
Unsure
Please explain your answer here - In your answer, please provide information on the costs of emissions reductions.
Businesses operate on profitabilty and responsibility to share holders.
They will not (en masse) do the right thing.
Making NZU availability/price scarce/high will naturally make them go the reduction route

3.2. Do you agree with our assessment of the cost impacts of a higher emissions price?

Please select one item
Yes
No
Unsure
Please explain your answer here
The ETS single purpose is to reduce emissions. The govt job is to manage the effect on the poulation: there are any number of methods for stopping a high NZU price affecting those that cannot pay.

3.3. How important do you think it is that we maintain incentives for removals?

Please write your answer here
Unimportant.
We must drive behaviour and process change to get to zero.

Chapter 4: Changes to the NZ ETS would be significant for Māori

4.1. Do you agree with the description of the different interests Māori have in the NZ ETS review?

Please select one item
Yes
No
Unsure
Please explain your answer here
Seem to be clearly ennumerated

4.2. What other interests do you think are important? What has been missed?

Please write your answer here
What has been missed is this is a consultation based on the effectiveness of an ETS.
The business and socio economic costs affecting Mori are an issue better dealt with outside the ETS.
In fact I would argue, removing forestry from the ETS, promoting idiginous planting would disproportionately benefit Maori which surely is a positive

4.3. How should these interests be balanced against one another or prioritised, or both?

Please explain your answer here
The intersts should be separated and dealt with separately.
Gross CO2 emissions need to be reduced.
Forestry needs to be sustainable on every level (ironically needing a lower NZU equivalent to avoid farming degradation).
Socio economic adverse affects are a welfare issue NOT an ETS one

4.4. What opportunities for Māori do you see in the NZ ETS review?

Please write your answer here
Becoming /returning to stewardship of out native forest.
If any, how could these be realised? Please explain your answer here
1. Remove Forestry from ETS.
2 Fixed price (s) for co2 sequestration.
3 Tier the fixed price to discourage pine. encourage native. say $40 pine/tonne , $80 native /tonne

Chapter 5: Objectives and assessment criteria

5.1. Do you agree with the Government’s primary objective for the NZ ETS review to consider whether to prioritise gross emissions reductions in the NZ ETS, while maintaining support for removals?

Please select one item
Agree
Disagree
Unsure
Please explain your answer here
Emission reduction should be the whole story.
Considering forestry is right but has a different driver and answer

5.2. Do you agree that the NZ ETS should support more gross emissions reductions by incentivising the uptake of low-emissions technology, energy efficiency measures, and other abatement opportunities as quickly as real-world supply constraints allow?

Please select one item
Agree
Disagree
Unsure
Please explain your answer here
No. Way too difficult to quantify and qualify.
The ETS need to get prices to a level where companies seek out their own solutions.

5.3. Do you agree that the NZ ETS should drive levels of emissions removals that are sufficient to help meet Aotearoa New Zealand’s climate change goals in the short to medium term and provide a sink for hard-to-abate emissions in the longer term?

Please select one item
Agree
Disagree
Unsure
Please explain your answer here
Better to keep our advances onshore

5.4. Do you agree with the primary assessment criteria and key considerations used to assess options in this consultation?

Please select one item
Agree
Disagree
Unsure

5.5. Are there any additional criteria or considerations that should be taken into account?

Please write your answer here
Simply remember what the ETS is for.
What forestry is for and how it fits NZ

Chapter 6: Options identification and analysis

6.1. Which option do you believe aligns the best with the primary objectives to prioritise gross emissions reductions while maintaining support for removals outlined in chapter 5?

Please select one item
Option 1
Option 2
Option 3
Option 4

6.2. Do you agree with how the options have been assessed with respect to the key considerations outlined in chapter 5?

Please select one item
Agree
Disagree
Unsure

6.3. Of the four options proposed, which one do you prefer?

Please select one item
Option 1
Option 2
Option 3
Option 4
Please explain your answer here
Because I feel it best addresses the disparity of drivers in the space

6.6. Do you agree with the assessment of how the different options might impact Māori?

Please select one item
Agree
Disagree
Unsure