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Cover brief: Opportunities to afforesting Crown land
Purpose
1. You are meeting on Tuesday 6 August 2024 to discuss progressing work to recognise
and reward afforestation on Crown land.
2. Officials have prepared the attached A3 (
Appendix 1) to support this discussion. The A3
outlines:
• an initial estimate of the Crown land available for afforestation
• how different mechanisms for funding and incentivising afforestation perform against
a range of potential objectives Ministers may have for this work.
3. We are seeking your direction on how you want to progress this work in line with your
key objectives.
Afforestation on Crown land – the opportunity
4. Afforestation on Crown land is a key priority for your Government, as highlighted in the
draft discussion document for the second Emissions Reduction Plan. It supports the
National Party manifesto commitment1, and provides an opportunity to deliver in the
following pillars of the climate strategy:
• credible markets to support the climate transition
• nature-based solutions address climate change.
2. There are broader objectives that afforestation on Crown land may serve. As set out in
the attached A3, your objectives may be supported differently depending on the
mechanisms chosen to progress afforestation on Crown land.
How much land?
5. As indicated in the attached A3, there are different preliminary estimates of how much
Crown land might be available for afforestation. A top end estimate is 638,000 ha.
6. All estimates to date have been desk-based. While they provide an upper end to the
amount of land that might be available, further work is needed to assess the potential
suitability of using the land identified for afforestation purposes. They also do not provide
an assessment of ability to register in the New Zealand Emissions Trading Scheme (NZ
ETS). A range of characteristics are likely to affect suitability, including land quality,
location (e.g., proximity to population centres) and relevant legislation (which may need
amendment).
1 “Partner with the private sector to plant trees including opportunities for native afforestation on Crown
land (excluding National Parks) that is unsuitable for farming and has low conservation value.”
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7. By applying a set of suitability criteria over existing spatial data, land-holding agencies
will be able to provide you with a more accurate quantification of the amount of land
available for afforestation.
How afforestation on Crown land can support across your Ministerial portfolios
8. The Government currently manages Crown land for a range of purposes and has
legislated options for what it does with this land. A policy to afforest Crown land will need
to reflect the different portfolio interests as well as consider the costs and risks.
9. In the
Climate Change portfolio, afforestation on Crown land could reduce the costs of
achieving emissions targets and/or provide additional net reductions towards the
emissions budgets, our future Nationally Determined Contributions (NDCs), and our
2050 net zero long-lived gases target.
10. In the
Conservation portfolio, native afforestation could support broader portfolio
objectives such as supporting biodiversity and attracting investment in high value
conservation areas. Investing in exotic afforestation would not achieve the same
conservation objectives 9(2)(f)(iv)
11. In the
Land Information portfolio 9(2)(f)(iv)
12. In the
Forestry portfolio afforestation on Crown land can support all four roles
the
Government sees for the forestry and wood processing sector (economic growth and
exports, delivering cost-effective low-emission products, land use resilience, and
sequestration towards New Zealand’s emissions targets). It can also support further
investment opportunities for the private sector to plant new forests on land not suited for
other productive uses.
Different mechanisms to incentivise afforestation will support different objectives
13. You have choices of which mechanism(s) you want to use to incentivise afforestation on
Crown land, depending on your objectives. The NZ ETS is currently the only regulated
market that incentives carbon sequestration. DOC land is the only Crown land that can
currently be legally included in the NZ ETS. Including additional afforestation in the NZ
ETS will likely increase the supply of least-cost NZUs to the market within the existing
cap. This means it will have no impact over the longer term on net emissions. It would
also not provide additional abatement towards our future NDCs, nor offset the long-lived
gases from agriculture which sit outside of the NZ ETS and form part of our net zero
2050 target.2
2 The NZ ETS cap is based on our domestic emissions budget, not our NDCs. Any NZUs issued to
forestry participants in the NZ ETS for sequestration of 1 tonne of CO2 generate revenue by being sold
to an emitter to be surrendered for an emission of 1 tonne of CO2. Therefore, forestry in the NZ ETS is
a net zero activity that supports meeting the domestic emissions budgets. 9(2)(g)(i)
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14. Non-ETS mechanisms (e.g., voluntary carbon market, biodiversity credits market, or
public-private partnerships) could contribute towards future NDCs and the 2050 target
but in some cases require the development of new finance mechanisms, which will take
time. The voluntary carbon market exists but is relatively small and fragmented, 9(2)(f)(iv)
Progressing afforestation on Crown land
15. Officials from MfE, DOC, LINZ and MPI are available to support Ministers to progress
this work and the further decisions that would be needed to achieve afforestation on
Crown land.
16. We have identified some key starter questions that could form the basis of a cross-
agency work programme. These are:
i
How much Crown land is suitable for afforestation and could be practically made
available now?
ii
What could be done now, using existing levers to enable additional afforestation on
the land identified in question i?
iii
What policy development, legislative or policy changes are needed to increase
afforestation on different types of Crown land?
17. We consider questions i and ii would need to be answered before officials could provide
full advice on question iii. There would also be other practical questions or wider
implications you may wish to consider, including any individual portfolio impacts that
responsible Ministers would need to be briefed on.
18. We can report back to you, subject to your direction and decisions, with more detail on a
proposed cross-agency work programme, including how this work links to related work to
deliver on the Government’s climate priorities.
Implications of this advice
19. This advice does not present any immediate risks, Te Tiriti issues, legal issues, or
financial, regulatory or legislative implications, although these might arise depending on
your decisions about options to progress. For example, making land available for carbon
removals would reduce the flexibility of land use over time and have Treaty Settlement
implications.
20. Any implications of progressing work on afforestation on Crown land would be identified
through ongoing advice.
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Next steps
21. The meeting on 6 August is an opportunity for you to discuss and agree on your
objectives for work on afforesting Crown land and the role you want it to play in the
broader climate strategy.
22. Subject to your direction, officials can provide further advice on the work that would be
required across agencies, and how this could relate to other relevant work underway.
Recommendations
We recommend that you:
a.
Note the attached A3 to support your conversation
b.
Note there is a high level of public interest in this work
c.
Note that the mechanisms available to fund and incentivise afforestation will perform
differently depending on your objectives, as set out in the attached A3
d.
Direct officials during your 6 August meeting on the key objectives that you expect to
drive forward work on afforestation on Crown land
Yes | No
e.
Direct officials to report back to you on a cross-agency work programme to support you
to deliver on this work in line with your signalled objectives
Yes | No
Signatures
Mark Vink
Amanda Moran
General Manager
Head of Strategy, Policy and Ministerials
Markets, Climate Mitigation and
Organisational Effectiveness
Resource Efficiency
1/08/2024
1/08/2024
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Alastair Cameron
Ruth Isaac
Director
Deputy Director-General
Primary Sector Policy
Policy & Regulatory Services
1/08/2024
1/08/2024
Hon Todd McCLAY
Hon Simon WATTS
Minister of Forestry
Minister of Climate Change
Date
Date
Hon Tama POTAKA
Hon Chris PENK
Minister of Conservation
Minister for Land Information
Date
Date
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Appendix 1: A3 presentation of opportunities
associated with afforesting Crown land
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