Briefing: Draft Cabinet Paper: Afforestation on
Crown-owned Land
Date submitted: 20 September 2024
Tracking numbers:
Ministry for the Environment: BRF-5344
Ministry for Primary Industries B24-0590
Sub Security level: CLASSIFICATION
MfE priority: Urgent
Actions sought from Ministers
Name and position
Action sought
Response by
Provide feedback on the
To Hon Simon WATTS
draft Cabinet Paper
Minister of Climate Change
Forward this briefing to the
23 September 2024
Hon Todd MCCLAY
Minister of Conservation and
Minister of Forestry
the Minister for Land
information
Actions for Minister’s office staff
Return the signed briefing to the relevant Ministry
Appendices and attachments
Appendix one: draft Cabinet paper
Appendix two: Feedback (verbatim) from agency consultation    Withheld in full under section 9(2)(g)(i) of the Act
Appendix three: Afforestation on Crown-owned Land - Agency Assessment Tables
Key contacts
Position
Name
Cell phone
First contact
Ministry of the Environment
Responsible Manager  Kara Lok
9(2)(a)


General Manager
Mark Vink
021 176 2243
Ministry for Primary Industries
Responsible Manager  Sophia Murphy

9(2)(a)
Director
Alastair Cameron
Minister’s comments
BRF – BRF-5344
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Draft Cabinet Paper: Afforestation on Crown-owned
Land
Purpose
1.  This briefing provides a draft Cabinet paper for your review (Appendix one), reflecting
direction we received at your meeting on 12 September.
2.  The paper seeks Cabinet’s agreement on next steps to partner with the private sector to
afforest Crown-owned land, including:
i
Identifying and progressing legislative changes to facilitate a wider range of
afforestation on Crown-owned land, subject to a report-back to Cabinet 9(2)(f)(iv)

ii  9(2)(g)(i)

3.  We aim to have this paper ready for you to lodge on 10 October, for ECO consideration
on 16 October and Cabinet consideration on 21 October.

4.  This timeline allows you to take a Paper to Cabinet before finalising Emissions
Reduction Plan 2 (ERP2) - as you requested following recent advice (see BRF-
5282/B24-0575 Progressing afforestation on Crown land).
Agency feedback
5.  This briefing also highlights key comments received during agency consultation. A
truncated agency consultation process was undertaken between Tuesday 17 September
and Wednesday 18 September.
6.  Agency feedback has been received from the Department of Conservation; Land
Information New Zealand; the Ministry of Business, Innovation and Employment; Te Puni
Kōkiri; the Public Services Commission, and the Treasury. Agency comments are
summarised in Appendix Two.
7.  Key issues raised during agency feedback include:
9(2)(g)(i)




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9(2)(g)(i)








Next steps
11.  9(2)(g)(i)


12.  Of icials are also continuing to quality assure and refine estimates both of available land,
and of abatement potential. These numbers may be subject to further revision ahead of
lodgement.

13.  The Minister of Climate Change wishes to include this policy, including quantified
estimates of its impact on future abatement, within ERP, as noted in the draft Cabinet
paper. Upcoming advice on ERP2 sufficiency wil  test options for how this policy is
included in Government modelling, and wil  inform text in the final ERP2 Cabinet paper.

14.  Next steps are summarised in Table One below.

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Week commencing  Deliverable
23 September
Feedback on Cabinet paper from Ministers (Monday 23
September)
Update Cabinet paper
Send to Minister’s office for Ministerial consultation (Friday 27
September)
30 September
Ministerial and agency consultation (Tuesday 1 to Tuesday 8
October)
7 October
Update Cabinet paper and discussion document (if required) based
on feedback (Wednesday 9 October)
Lodge (Thursday 10 October)
14 October
Cabinet paper at ECO (Wednesday 16 October)
21 October
Confirmation of ECO decisions from Cabinet (Monday 21 October)

Recommendations
We recommend that you:
a.  agree to provide feedback on the attached draft Cabinet paper to officials by Monday 23
September 2024
Yes | No
b.  agree to forward this briefing to the Minister of Conservation and the Minister for Land
information
Yes | No
Signatures

Mark Vink
Alastair Cameron
General Manager
Director
Ministry for the Environment
Ministry for Primary Industries
20 September 2024
20 September 2024

BRF-5344

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Hon Simon WATTS
Hon Todd MCCLAY
Minister of Climate Change
Minister of Forestry
Date:
Date:
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Appendix one: Draft Cabinet Paper: Afforestation on
Crown Land

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CLASSIFICATION
Office of the Minister of Climate Change and the Minister of Forestry
ECO - Cabinet Economic Policy Committee
Afforestation on Crown-owned land
Proposal
1.
This paper seeks agreement to proposed next steps for afforestation on Crown-owned
land, including:
1.1
Identifying and progressing legislative changes to facilitate a wider range of
afforestation on Crown-owned land, subject to a report-back to Cabinet
1.2
9(2)(f)(iv)

Relation to government priorities
2.
This proposal relates to the National Party manifesto commitment to “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”. This was also a key action signalled in the second emissions reduction plan
(ERP2) discussion document.
Executive summary
3.
The Crown is a significant landholder in New Zealand, including land which has low
conservation and agricultural value but may be suitable for forestry. We intend to
progress afforestation of this land in partnership with the private sector, with the Crown
providing and retaining ownership of land and the private sector funding planting and
management of new forests.
4.
Increasing afforestation can support two key objectives:
4.1
Securing additional net emissions reductions in the medium-long term, which
contribute towards our domestic and international emissions targets
4.2
Growing the forestry and wood processing sector, spurring economic growth
through jobs and exports
5.
We have identified 9(2)(g)(i)
of Crown-owned land with potential to
be afforested, which is administered by the Department of Conservation and Land
Information New Zealand.
6.
The land identified is a high-level assessment and no individual site assessments have
been undertaken to date. There may be barriers to afforestation on a site-to-site basis,
including ecological suitability, legislative constraints and other barriers that may
reduce the potentially available area.
1
S E N S I T I V E

7.
9(2)(g)(i)

9(2)(f)(iv)

8.
9(2)(f)(iv)


9.
9(2)(g)(i)

11.
Our intention is that as lit le as possible of this new forestry should be registered in the
ETS. This wil  maximise additionality of carbon removals, as well as minimise impacts
on the ETS market.
12.
We intend to include these abatement estimates ERP2, due to be published by the
end of this year.
13.
9(2)(g)(i)

9(2)(f)(iv)

9(2)(f)(iv)

1 9(2)(g)(i)


2
S E N S I T I V E

Background
14.
The forestry and wood-processing sector has great potential to support the
Government’s objectives to grow the economy and exports, add value and lift
productivity. Our forests are highly productive, create significant export earnings and
produce the raw materials our wood processors use to make high-value products.
15.
Forestry and wood processing also have a vital role in meeting New Zealand’s climate
change targets. Forests remove carbon from the atmosphere to reduce our net
emissions and their wood products can be substitutes for more emissions-intensive
products, for example, woody biomass can help businesses transition of  coal.
16.
Native forests remove carbon from the atmosphere more slowly than exotic forests.
However, they are effective long term carbon sinks as they continue to remove and
store carbon for centuries. They also support indigenous biodiversity.
17.
In the National Party Manifesto, and again in the  ERP2  discussion document, the
Government signalled its intention to partner with the private sector to plant trees on
Crown-owned land that is unsuitable for farming and has low conservation value.
18.
Of icials in the Ministry for Primary Industries (MPI), the Ministry for the Environment
(MfE), Department of Conservation (DOC) and Land Information New Zealand (LINZ)
have been investigating this opportunity. This work has refined our understanding of
what Crown-owned land may be available.  However, the analysis to date has been
desktop only and detailed site assessments will be required to refine further the amount
of land available.
19.
The Minister of Climate Change is required to finalise and publish ERP2 by the end of
this year. We intend to include afforestation on Crown-owned land as a key
commitment within that plan. Decisions to progress this work are therefore required
now, to allow us to set out additional detail on the Government’s intentions.
Analysis
Our objectives
20.
The key objectives that guide this programme are to:
20.1  Secure additional net emissions reductions, which contribute towards our
domestic and international emissions targets
20.2  Grow  the forestry and wood processing sector, spurring economic growth
through jobs and exports.
21.
Afforestation can also support biodiversity and freshwater outcomes and improve
adaptation to the impacts of climate change.
22.
The rate and type of af orestation (indigenous, permanent exotic, and production
exotic) that takes place on Crown-owned land wil  affect the extent to which these
various objectives are achieved.
3
S E N S I T I V E

Commercial partnership approach to afforestation
23.
We intend to progress this afforestation through partnership with the private sector.
Available Crown-owned land wil  be selected and offered up, while the private sector
wil  fund the planting and management of the new forests. We intend that the Crown
wil  retain ownership of the land.
24.
9(2)(g)(i)

9(2)(f)(iv)

4
S E N S I T I V E

Assessment of available Crown-owned land
32.
We have initially identified up to around 9(2)(g)(i)ha of Crown-owned land with potential
to explore for af orestation, which is administered by DOC and LINZ.
33.
9(2)(g)(i)

36.
9(2)(f)(iv)

37.
9(2)(g)(i)

38.
We, along with the Ministers responsible for potentially impacted legislation, will report
back to Cabinet with specific proposals 9(2)(f)(iv)
. This will allow for
us, in consultation with Ministers responsible for potentially impacted legislation, to
consider the opportunities and risks of dif erent options for legislative reform, and to
have been informed by the feedback from the private sector in response to initial
offerings on Crown-owned land.
39.
9(2)(g)(i)

2 9(2)(g)(i)

5
S E N S I T I V E

9(2)(g)(i)

41.
9(2)(f)(iv), 9(2)(j)

9(2)(g)(i)

6
S E N S I T I V E

9(2)(g)(i)

49.
In line with our objective “to secure additional net emissions reductions”, our intention
is that as lit le as possible of this new forestry should be registered in the ETS. This
wil  maximise additionality of carbon removals, as well as minimise impacts on the ETS
market, but may pose challenges around commercial viability of planting.
50.
9(2)(g)(i)

Cost-of-living Implications
51.
To come
Financial Implications
52.
To come
Legislative Implications
53.
9(2)(f)(iv)

ther legislative changes wil  also be necessary to facilitate
afforestation on Crown-owned land, and we wil  report back to Cabinet 9(2)(f)(iv)
with details on these.
Impact Analysis
Regulatory Impact Statement
54.
To come
Climate Implications of Policy Assessment
55.
To come
Population Implications
56.
To come
Human Rights
57.
The proposals in this paper are consistent with the New Zealand Bil  of Rights Act 1990
and the Human Rights Act 1993.
Use of external Resources
7
S E N S I T I V E

58.
No external resources were used in the preparation of this paper.
Consultation
59.
The following agencies have been consulted: Ministry of Business, Innovation and
Employment; Department of Conservation; Land Information New Zealand; Of ice for
Māori Crown Relations – Te Arawhiti; Te Puni Kōkiri; the Public Services Commission;
The Treasury; and the Department of the Prime Minister and Cabinet.
Treasury Agency comment
60.
9(2)(g)(i)
61.
9(2)(g)(i)
Communications
62.
To come
Proactive Release
63.
To come
Recommendations
The Ministers recommend that the Committee:
1
9(2)(g)(i)

3
Agree that, to maximise additionality of carbon removals and minimise impacts on the
ETS market, as little as possible of this new forestry should be registered in the ETS
4
Direct Ministers, with the Minister of Conservation and the Minister for Land
Information, to identify what legislative changes are necessary to facilitate afforestation
on Crown-owned land, and report-back to Cabinet 9(2)(f)(iv)

5
9(2)(f)(iv)

6
9(2)(g)(i)

8
S E N S I T I V E

7
9(2)(g)(i)

9(2)(f)(iv)

11
9(2)(f)(iv), 9(2)(j)

9
S E N S I T I V E

Appendix Three: Afforestation on Crown-owned Land - Agency Assessment Tables
The purpose of this document is to compare the diﬀerent aﬀorestation parameters between Crown-owned Land
9(2)(j)

Commentary
Aﬀorestation opportunities
•  Interest from lease holders for native regeneration
•  Greater opportunity for natural regeneration of native forests in areas bordering existing  •  General y road accessible .
•  General y accessible (i.e., part of farm system)
native forest- adjacent seed sources.
•  Production forestry and native forestry aligned with overal

PAMU forestry strategy
•  Open to novel forest types- alt exotics, mixed species
plantings
Aﬀorestation barriers
•  9(2)(f)(iv)

•  9(2)(f)(iv)

•  Not ‘Crown Land’

•  Agreement from State-Owned Enterprise (stil  needs to be

•  Some areas are remote, which makes access more diﬃcult for ongoing forest
investigated)

management



•  Leaseholders’ decision (under lease agreements both the Crown and the
leaseholder would need to consent to aﬀorestation on a Crown pastoral lease)
Other considerations
•  Ngāi Tahu and potential y Te Tau Ihu iwi consultation required (South Island)
•  Signiﬁcant natural areas (e.g. indigenous shrub/grasslands)
•  Opportunity costs
•  SNA’s- high tussock
•  Some areas are remote, which makes access more diﬃcult

•  Opportunity costs for more proﬁtable grazing leases
•  Some existing users/concession holders

•  In some areas there are restoration groups interested in supporting native aﬀorestation
projects
•  Iwi consultation required

•  Short term – (~1 year for minor leg change) native enhanced regeneration
•  Enhanced regeneration
•  Production, native, mixed, transition, agroforestry.
Potential forest types
•  Long term (~2 years for any major leg change) – al  types
•  Native aﬀorestation

•  If suitable for exotics- production forestry
•  VCM (limited current opportunities)
•  Production forestry
Potential funding
•  Voluntary Carbon Markets (VCM) (limited current opportunities)
•  Biodiversity credits (not available)
•  VCM (limited current opportunities)
opportunities outside the
•  Biodiversity credits (not available)
•  Philanthropy (not tested)
•  Biodiversity credits (not available)
ETS
•  Philanthropy (not tested)
•  Alt models (recreation/ non timber forest products/ tourism) (not tested)
•  Philanthropy (not tested)
•  Alt models (recreation/ non timber forest products/ tourism) (not tested)

Alt models (recreation/ non timber forest products/
tourism) (not tested)
Timeframes to trees in
Long (regen)
Long (regen)
Medium-Long if planting exotics
ground + abatement
Long (planting indigenous)
Long (planting indigenous)
Short: 1-2 years, Medium: 3-
5 years, Long: 6+
Pros/ Cons

Pros: Ministers and many lease holding farmers are in support of native
Pros: opportunity to support biodiversity outcomes on DOC estate (if native). If funding/
Pros: Proven commercial models, Pāmu open to al  forest types,
regeneration on their land. If funding/ management is sustainable for 80+ years,
management is sustainable for 80+ years, could be big sequestration win in long term.
quicker sequestration with exotics. More latitude to try novel
could be big sequestration win in long term.

forestry types.

Cons: No commercial business models at scale, very long-term implementation and

Cons: No commercial business models at scale, very long term implementation and
abatement timelines. Remote areas make regular management interventions diﬃcult.
Cons: navigating SOE dynamics and leaseholders under PAMU.
abatement timelines. Aﬀorestation needs to be negotiated 1:1 with leaseholders.

Social licence chal enges with production forestry.

General comments
Natives only in short term on crown pastoral lease land. Implementation could
Natives only in short term. Implementation could happen in the medium term but abatement  9(2)(g)(i)

happen in the medium term but abatement would be long term due to the speed of  would be long term due to the speed of native regeneration and planting.

native regeneration and planting.


9(2)(f)(iv)

9(2)(f)(iv)



Beyond no commercial model planting natives faces long standing barriers: (seedling supply,

long-term management capacity, survival rates)

Beyond no commercial model planting natives faces long standing barriers: (seedling
supply, long-term management capacity, survival rates)

Other considerations on aﬀorestation methods and forest management
•  Al  types of forest management wil  need active management which carries a cost.
•  There may be alternative models for aﬀorestation on Crown land that have not been identiﬁed by oﬃcials.
•  Enhanced native regeneration could start quickly, however it may not be until 2045-2050 until signiﬁcant abatement begins to occur due to the slow speed at establishing cover with natives. It could take 25+ years to even establish the total area identiﬁed for native aﬀorestation. Must
have podocarp seed sources for higher sequestration.
•  9(2)(f)(iv)

Document Outline