April 20, 2020
Environment Select Committee
Dear Select Committee Members
As the select committee deliberates, recent comments in the media has prompted us at 50 Shades of Green to write again to share the concerns we have for the hill country sector and the proliferation of farms being sold to blanket plant in exotic trees as a means of managing climate change.
The comments referred to “the privilege and responsibility of managing the primary sector to carry on operating while the country manages its response to Covid19”.
Pertinently now, and because of Covid19, it brings into stark reality the need to ensure there are restrictions on exotic forestry offsets. As New Zealanders are increasingly appreciating, no matter what their political persuasion, this is the industry that is going to bring New Zealand back through this dreadful economy situation we are in.
It will be much more difficult if our key asset at the top of the supply chain, hill country farms are blanket planted in exotic forestry.
Of particular concern, in the proposed Emissions Trading Scheme bill before you all at the moment, there is no clear mechanism for limiting exotic plantings. Effectively this means, no present or future Government has a tool to manage land use or to prevent a barrage of more hill country farms being taken out of the supply chain. We are deeply concerned about the lack of a mechanism, because as you know the bill also proposes to lift the cap on the carbon price. As soon as this happens, we expect to see an acceleration in the conversion of land into exotic forestry. This is what has been modelled by the Parliamentary Commissioner for the Environment in their report on Farms, Forests and Fossil Fuels last year. The Climate Change Commission in their submission to the select committee identified the lack of a mechanism as a flaw in the current Bill.
As we know if the beginning of the supply chain is hollowed out there would be massive downstream impacts on the industry, jobs that rely on the sector, New Zealand’s export earning potential, and the nation.
Fundamentally, allowing exotic offsetting is not going to achieve what we want, nor is it what the ETS is designed to do. The intention of the ETS is to provide a price mechanism to change behaviour at source, but it does the opposite, it allows emitters of carbon to abdicate their responsibility to reduce emissions.
As acknowledged by the government the planting of exotics is at best a short term reprieve, the long tail however, is the potential of an environmental disaster, social destruction of many communities, and is economically unsound, planned out of policy that as far we can see has had no comprehensive analysis of the impacts on the three pillars; social, economic and environmental outcomes.[1]
We all understand about the end destination, but it’s all about the path we take. We have presented our views before, that current policy is fraught with delivering unintended consequences. We think New Zealanders deserve a more durable solution to managing climate change, not policy that basically is a tax by stealth, delivering little benefit other than to those investors who hear the governments message. The coalition seem blissfully unaware of the message the investor sector both domestically and internally are hearing loud and clear. That is, the guaranteed floor price of carbon, signalling the price is going to go to $50, add in that averaging with no liability to repay the first 18 years of credits. Investors can line their pockets for 18 years and walk away. We say look in the rear vision mirror before we get further down that track and have a look at what is going to be left behind.
We believe there should, at the very least be a mechanism in that bill to provide a restriction limiting the allowable area of new exotic plantings, if any at all.
[1] Not to mention, where will replacement export receipts come from
Thank you for taking time to share these insights, and apologies for not replying sooner to this comment.
G
It is my view we need to bring into this discussion the rules that govern how GHGs and sinks are accounted for. Politicians and ministry officials have not been clear on were the information on GHGs and sinks has come from leaving the public and media to make the assumption it must be based on science. It isn’t it is based on the international carbon accounting rules known as the “Marrackech accord”. These rules were written by politicians not scientists who were clearly looking for a way round the carbon caps they knew were coming. This lead to some judicious cherry picking of the science so as to allow for emissions to be measured as a net figure – emissions minus sinks. Very convenient for politicians in a country with a growing population that is piling on 150,000 more cars on its roads a year but grows trees very well. We should be telling politicians they could be facing some very hard questions if the media ever found out what the cherry picking did to the scientific merit of forestry sinks. Tree growth would first have to overcome the loss of abedo (reflectivity) and lower soil carbon levels relative to the pastural system the forestry replaced to start to become effective. In short it doesn’t work as well as politicians would have us believe. A tricky question in a country were the price of fuel is so politically sensitive.