The Ministry for Primary Industries called for submissions on proposed changes to forestry settings in the New Zealand Emissions Trading Scheme.

CA ANZ continues to be an advocate for, and supporter of, a just transition to a net zero economy. As a professional body, CA ANZ seeks to advocate in the public good on policy areas that impact our members, the accounting profession and the public.

After consultation with our members working in the relevant sectors, we consider that Option 2 would be the ideal option. We do not support either Option 1 or Option 3b. We consider that Option 3a would be fairer for exotic forest owners who made business decisions under previous policy settings but believe that it should be adopted only if any exceptions are subject to very strict conditions and robust approval criteria.  

We understand that exotic forestry can be used for continuous cover while native forests are yet to mature and that exotic forestry is already being used for erosion control. On the other hand we note that in practice forest owners who may seek to transition from exotic to native forest would incur large costs both to pay back carbon credits and to manage the transition, a significant disincentive to transition.

As noted above, we consider that any exceptions allowed under Option 3a, if it were adopted, would need to be very tightly controlled to prevent ongoing and widespread use of exotic forestry. Under this option the inclusion of exotic forests would need to be by very limited exception only. 

Regardless of which option is chosen, limits should be placed on the use of all permanent exotic forests registered after 1989 as permanent forests. We note that the current proposals only apply to forests registered from 2023 onwards.