The questions you asked us
What are we consulting on?
The amendments to the ETS forestry regulations we are consulting on are:
- the detailed rules and settings for averaging accounting
- technical amendments to simplify the ETS and let us implement new policies.
Our consultation page has more details, including presentations, the discussion document, and background information.
Will the default regional carbon stock tables still be used for non-FMA participants using averaging accounting?
Regional tables for radiata pine will still be used.
I have received a grant scheme for my forest. Can I earn units if I register in the ETS?
Grant funded forests cannot earn units in the ETS during the stand-down period for that forest. A forest can begin earning units once the stand-down period from the grant contract expires. Some forests may also not be registered into the ETS until the expiry of the stand-down period.
If applying to join the ETS recently after a stand-down period has expired, you should notify MPI of the grant funding and which areas received a grant fund.
Under a 5-year age band, would a participant need to account for harvesting at a carbon accounting area (CAA) level, or sub-area level? For example, harvesting the roadline at age 24 and clearfell at age 26 to 28 would mean harvesting in 2 age bands. Are we required to account for changes in carbon with the same stock change methodology that we currently use?
You will continue to have to account for harvesting at a sub-area level under all options. Whether a forest accounts using averaging or stock change depends on what kind of accounting approach it is registered under.
How are existing participants treated if they plant an area that has never had trees (greenfields)? Would they register it at a participant level or CAA level?
Accounting approaches are determined at the CAA level – so if a participant has existing carbon accounting areas registered under the stock change approach, they could plant a new forest, and register it under averaging accounting in its own carbon accounting area.
Will we be able to make changes to the mapping of carbon accounting areas in the future for radiata pine?
Carbon accounting area reconfigurations have been improved in legislation, and the new process to reconfigure carbon accounting areas will come into force on 1 January 2023. This will allow participants to more easily reconfigure carbon accounting areas.
Does the proposed minimum 1 hectare (continuous) sub-area approach apply to pre-1990 as well as post-1989 forests?
Yes, the approach would apply to post-1989 forests and pre-1990 deforestation.
How will the proposed minimum 1 hectare (continuous) sub-area approach apply to permanent forests? Will it interact with the restriction on clear-felling (reducing canopy cover to below 30% in a hectare)?
The proposed approach would apply to permanent forests when accounting for carbon stock change. The penalty for ‘clear-felling’ by reducing canopy cover in any hectare to below 30% is separate from carbon accounting, so sub-area definitions will not affect the enforcement of this penalty.
Would the proposed minimum 1 hectare (continuous) sub-area approach induce a ‘swiss cheese’ style of forestry where small-coup harvesting becomes common, as it would avoid surrender liabilities?
We don’t consider this to be a major risk. The cost of harvesting in this way would likely outweigh benefits for a typical rotational forest in New Zealand. Participants using the Field Measurement Approach would also account for the clearing through having lower carbon stocks for their land.
We will always work to ensure that integrity is maintained through our accounting and would be monitoring our registered forest to ensure that our accounting approach remains accurate.
Who to contact
If you have further questions about the consultation, email firstname.lastname@example.org