Photosynthesis

Submitter: Professor Euan G. Mason

Profile: Dr Euan Mason is a Professor at the New Zealand School of Forestry, University of Canterbury, where he teaches silviculture, statistics, modelling, and research methodology. His research interests include forest growth and yield modelling, tree physiology, and silviculture. He has published numerous peer-reviewed articles and a chapter in a textbook relating to climate change and forestry, and has been employed by government ministries and political parties to advise them on climate change issues from time to time. He is a New Zealand citizen, born in Invercargill. He was educated at universities in New Zealand and the United States of America.

Synopsis of submission

I provide a summary of our current state and the role of forestry in helping New Zealand respond appropriately to climate change.

Many proposed changes to the emissions trading scheme (ETS), particularly the idea of splitting credits into sequestered carbon versus avoided emissions with only the latter of any market value, are irrational, will create confusion, will lower confidence in carbon forestry, and will cause us to fail to meet our targets. This will cost the nation potentially billions of dollars in purchases foreign carbon credits of dubious quality, and in lost markets as other countries begin to sanction our lack of action.

Continued expansion of forests, particularly exotic ones, is vital for us to reach our national targets.

Unharvested exotic carbon forests could be assured of ultimate conversion to native by:

a. Carefully selecting sites on which these forests are established,

b. Requiring owners of such forests to place a portion of their carbon credit revenues in an escrow account to pay for any management required for their conversion.

More accurate assessments of sequestration on small woodlots would encourage farmers to establish carbon forests on small portions of their farms and reduce the likelihood of whole-farm conversions to forest that are currently causing such anguish in the agricultural sector.

Our emissions trading scheme ignores those responsible for more than half of our gross GHG emissions.

The “emissions leakage” argument used to exempt most greenhouse gas (GHG) emitters from the ETS does not work, because it requires us to assume that:

a. We are the most greenhouse gas (GHG)-efficient producers of primary products

b. Other countries will not seek lower their GHG emissions;

c. People will continue to purchase goods with a high greenhouse gas footprint as the climate crisis worsens.

Moreover, actual studies of emissions leakage show that it is a negligible problem. Therefore the NZ agricultural sector and other trade-exposed industries, responsible for 57.5% of our gross GHG emissions, should not use the “leakage argument” as a justification for their exemption from purchasing NZUs.

The discussion document suggesting changes to the ETS fails to make the case that forest-based carbon credits threaten reductions in gross GHG emissions by overwhelming the carbon market with cheap credits. This case relies on the assumption that the supply of credits will increase while the demand for credits will remain small. However, making trade-exposed industries and agriculture responsible for their emissions would greatly increase the demand for credits, invalidating the argument that forest-based credits necessarily threaten reductions in gross emissions.

The pathway to lowering gross emissions is to:

a. Require everyone, including farmers and trade-exposed industries to submit credits for the full amount of their greenhouse gas emissions;

b. Allow the price of carbon credits to rise to the point where it is more cost-effective to lower emissions that to purchase offsets;

c. Stop auctioning carbon credits;

d. Stop giving away credits.

The threat of carbon forestry to our high country farming culture can be mitigated by making carbon lookup tables accurate and/or allowing owners of carbon forests < 100 ha in extent to measure actual carbon sequestration in their woodlots. This would encourage farmers to establish their own small woodlots, reducing the incentive to convert whole farms to forest and greatly increasing the profitability of hill country farms.

Background

Aotearoa has so far failed to make substantial progress in its response to climate change, and proposed changes to rules for permanent forest carbon sinks will further undermine progress in meeting our net GHG emission commitments for 2030 and 2050. That our nation is one of the worst greenhouse gas polluters is beyond doubt. Climate Action Tracker provides an assessment of our performance and rates it as highly insufficient (Figure 1).

According to our Ministry for the Environment, Aotearoa emits about 78 million tonnes of CO₂-e annually . These are known as “gross emissions”. In 2018 we emitted 16.9 tonnes of CO₂-e per capita. This level of emissions placed us 16^th worst among all countries[1], and is far above both the Organisation for Economic Cooperation and Development average of 10.83 and the global average of 6.45 tonnes of CO₂-e per capita[2].

Aotearoa has agreed to two international commitments. Firstly, we have agreed to a “Nationally Determined Contribution (NDC) to keep our net GHG emissions at 50% of gross 2005 emission levels between 2021 and 2030. Secondly, and more importantly, we have pledged to get our net emissions down to zero by 2050, with perhaps some exceptions for methane emissions from agriculture.

Recent progress has been made by setting up a Climate Change Commission, providing incentives to purchase electric vehicles, and attempting to negotiate with farming lobbyists. In addition an emissions trading scheme has been set up so that for a bit less than half the country’s emitters there is a price on greenhouse gas emissions. The price recently rose to as high as $85/tonne of CO₂, leading to some investment in carbon (C) forestry, among other things, and some concern from hill country farmers about whole-farm conversions to C forestry. Conversion of whole, mostly hill country farms, has become a political issue, prompting some lobby groups to push for legal constraints on conversions. Typically these concerns are about impacts of whole-farm C forests on hill country farming as a way of life. The farming lobby has been joined by an anti-exotic species lobby that questions what might happen to exotic C forests that remain unharvested and would much prefer to see indigenous species in C forests.

Figure 1 – An assessment of our national performance at climate change mitigation, available on-line at https://climateactiontracker.org/countries/new-zealand/ (Accessed on 14/4/22)

The role of forestry

Creating new forests is the most efficient way we currently know of to extract CO₂ from the atmosphere. Trees absorb solar energy and create sugar from CO₂ and water. Some of the created sugar is used to provide energy for living functions, and some is stored for longer periods in biomass. Typically half the dry-weight biomass in wood is elemental C, and amounts of CO₂ extracted from the atmosphere (“sequestered”) by trees can be calculated by multiplying the mass of stored elemental C by 44/12.

New forests are called “sinks” for CO₂ because they extract far more CO₂ from the atmosphere than they emit through respiration, but forests do not remain sinks forever. The name “permanent forest sink” can therefore be misleading for those who are unfamiliar with forestry. Eventually forest sinks become simple carbon reservoirs. Those that are repeatedly harvested and re-established typically retain about 60-70% of their maximum C content at harvest in long-term average storage, while unharvested forests eventually reach the point where they are emitting as much CO₂ through respiration and decay of dead biomass as they absorb. Their long-term storage may be punctuated by small- and large-scale disturbances such as wildfires or windthrow that reduce their average long-term storage just as periodic harvesting can reduce average long-term storage.

Establishing new forest sinks to absorb GHGs we emit can only, therefore, be a temporary solution, with additional new forest sinks providing a cheap way to extract our GHG emissions from the atmosphere, achieving net GHG neutrality while we develop ways to reduce our gross GHG emissions to zero. If we wished to rely on forest sinks to achieve GHG neutrality on a permanent basis then we would need an unlimited supply of unforested land on which to establish new forests each year. This fact was clearly recognised by authors of the “Globe” study, a multi-partisan, parliamentary-initiated study designed to explore how Aotearoa could reach GHG net neutrality by 2050 (Vivid_Economics, 2017).

After extensively studying Aotearoa’s GHG-emitting and forestry sectors, the authors of the Globe study stated that in their opinion we could not reach net GHG neutrality by 2050 simply by reducing gross GHG emissions to zero because new technologies had to be developed, and resistance to rapid change would be strong. They recommended that new forest sinks be used to fill the gap between what we wished to achieve by 2050 and what could realistically be achieved by gross GHG emission reductions. This situation is clearly shown in a graph that quantifies the gap in our accounts that we need to fill with sequestration of CO₂ by forest sinks while we reduce our gross emissions to zero (Evison & Mason, Forthcoming) (Figure 2).

Figure 2 – The Globe study’s “Innovative” scenario of gross GHG emission reductions (red), the path Aotearoa has committed itself to for net GHG emissions (green), and the gap in our national C accounts that needs to be filled by forestry (blue dashed line) (Evison & Mason, Forthcoming). The graph and an accompanied analysis of our options will soon be submitted to a peer-reviewed scientific journal.

Reality is a bit more complicated than the situation represented by Figure 2 because we have not consistently planted the same area of new forests in Aotearoa each year. The last large-scale afforestation programme occurred during the 1990s, and many of those forests will be harvested in the 2020s, effectively reducing our carbon storage in forests, and this needs to be taken into account if we wish to genuinely reach net GHG neutrality by 2050. I’ll show that later, but for now let’s consider what factors influence the rate of CO₂ sequestration/hectare and the maximum amounts of CO₂-e storage in new forest sinks.

C sequestration by forests

Three factors overwhelmingly influence both rates on forest sink sequestration and maximum storage in forest reservoirs. These three factors are:

1. The fertility, soils and climate on sites where the forests are established;

2. The species established on those sites; and

3. The ways that forests are managed. We call this management “silviculture”.

Impacts of site are easily illustrated, but are complicated by the fact that, by definition, no forests are currently growing on candidate sites for new sinks. We need to estimate potential productivity by examining the impacts of soils and climate on tree physiology (Figure 3).

Such a map would be subtly different for each tree species, because species differ in their responses to site conditions and pests.

If we ask which sites currently have no forest, and are not prime farmland, i.e.: land use classes 5 and 6, we get a map like that shown in Figure 4.

Rules for the national emissions trading scheme (ETS) specify that forests planted on land that was unforested in 1990 can earn carbon credits called New Zealand Units (NZU). One NZU is meant to represent 1 tonne of CO₂ removed from the atmosphere as trees grow. Land areas larger than 100 ha can be measured at various times and the tonnes of C stored can be estimated. However, if a forest owner’s land area is less than 100 ha then they are required to use default “lookup” table for sequestration. For some species, such as radiata pine, the tables vary with region, but for others there is simply one table. Tables tend to be conservative.

There is one lookup table for all native forests, which is a simple Gompertz yield equation based on data from 52 sites that rises to an asymptote of 445 t CO₂-e/ha assuming no water deficit (Payton et al., 2010). Clearly this table has too low an asymptote for many of the indigenous forests quoted in Table 1, and it was intended to be used for young forests established after 1990. Almost all the 52 sites measured contained manuka, kanuka and/or gorse with a few emergent native hardwoods.

Figure 3 – Megajoules/m² of solar radiation (of which ~50% is photosynthetically active) potentially useable by a species like radiata pine over the 10 years between June 2008 and June 2018 across Aotearoa. This geographical information system layer has approximately 3 million pixels, each representing 9 ha. Green = more productive, and white = unsuitable. Scales are NZTM eastings and northings.

Figure 4 – Areas in land use classes 5 and 6 that are currently unforested, coloured by likely productivity as shown in Figure 3.

Estimates of forest CO₂ sequestration rates and storage per hectare vary widely (Table 1).

Table 1 – Example carbon dioxide sequestration rates and storage by forests in Aotearoa. The first 10 entries were in natural stands, while the other examples were in plantations. In some cases below-ground C was considered while in others it was not.

Land cover	Sequestration t CO₂/ha/year	Storage t CO₂/ha	Below ground?	Reference
Native forest average (from national vegetation survey)		525	No	(Hall, 2001)
Native woody scrub		128	No	(Tate et al., 1997)
Manuka/kanuka shrub, ~25 years	10	238	No	(Scott et al., 2000)
Manuka/kanuka shrub, ~35-55 years		554	No	(Scott et al., 2000)
Manuka/kanuka shrub, 40 year span	7-9		Yes	(Trotter et al., 2005)
Lowland native podocarp-broadleaf forest		1238	No	(Tate et al., 1997)
Mature beech-podocarp forest		1287	No	(Beets, 1980)
Mature beech-podocarp forest		1290	No	(Tate et al., 1997)
Hard beech forest		1172	No	(Tate et al., 1997)
Mountain beech forest		938	No	(Tate et al., 1997)
Kauri, Northland, aged 67, 492 stems/ha	13.8	926		(Kimberley et al., 2014)
Kauri, Fred Cowling Reserve, aged 38, 1402 stems/ha	10.9	413		(Kimberley et al., 2014)
Kauri, Fred Cowling Reserve, aged 51, 11256 stems/ha	12	614		(Kimberley et al., 2014)
Kauri, Fred Cowling Reserve, aged 69, 1325 stems/ha	18.9	1306		(Kimberley et al., 2014)
Kauri, Taranaki, Brooklands Park, aged 50, 630 stems/ha	13.3	663		(Kimberley et al., 2014)
Kauri, Taranaki, Brooklands Park, aged 71, 630 stems/ha	14.5	1027		(Kimberley et al., 2014)
Kauri, Taranaki, Brooklands Park, aged 83, 630 stems/ha	13.4	1116		(Kimberley et al., 2014)
Kauri, Hawkes Bay, aged 48, 1700 stems/ha	20.1	966		(Kimberley et al., 2014)
Kauri, Northland, aged 36, 650 stems/ha	10.9	393		(Kimberley et al., 2014)
Totara, Northland, aged 102, 1225 stems/ha	17.4	1770		(Kimberley et al., 2014)
Totara, Northland, aged 102, 1825 stems/ha	13.3	1357		(Kimberley et al., 2014)
Totara, Northland, aged 58, 816 stems/ha	6.5	376		(Kimberley et al., 2014)
Totara, Hawkes Bay, aged 48, 1975 stems/ha	8	382		(Kimberley et al., 2014)
Totara, Waikato, aged 30, 2831 stems/ha	6.1	182		(Kimberley et al., 2014)
Kahikatea, Waikato, aged 30, 2831 stems/ha	9.6	289		(Kimberley et al., 2014)
Puriri, Bay of Plenty, aged 69, 588 stems/ha	15.2	1046		(Kimberley et al., 2014)
Red Beech, Waikato, aged 16, 738 stems/ha	9.2	147		(Kimberley et al., 2014)
Red Beech, Southland, aged 14, 1579 stems/ha	6.2	87		(Kimberley et al., 2014)
Black beech, Southland, aged 14, 1508 stems/ha	7	98		(Kimberley et al., 2014)
Pasture without grazing		11	Yes	(Ford-Robertson et al., 1999)
Pruned radiata pine on a good site, 400 stems/ha (modelled), average over three 28 year rotations		814	Yes	(Ford-Robertson et al., 1999)
Pruned radiata pine on a poor site, 250 stems/ha (modelled), average over three 28 year rotations		550	Yes	(Ford-Robertson et al., 1999)
Pruned radiata pine, 250 stems/ha to age 28 Central North Island (modelled)	33	918	Yes	(Robertson et al., 2004)
Untended radiata pine, aged 15, 2500 stems/ha, site index=23	38	571	Yes	(Yallop, 2021)
Untended radiata pine, aged 15, 1250 stems/ha, site index=23	34	514	Yes	(Yallop, 2021)
Untended radiata pine, aged 15, 625 stems/ha, site index=23	27	401	Yes	(Yallop, 2021)

Paula Yarur Thys (2021) measured C storage in planted native forest stands on Banks Peninsula, Canterbury up to 59 years after planting, and compared their C storage to those estimated by the lookup table assuming a water deficit (Figure 5). She found that data were highly variable, that they more or less agreed with the lookup table for young stands, but older stands had C storage exceeding that shown in the table. Moreover, a nationwide survey by Beets et al. (2009) demonstrated that many natural stands exceeded the asymptote in the lookup table (Figure 6).

Figure 5 – Measured CO2-e storage (blue triangles) versus age, and the Ministry for Primary Industry’s carbon sequestration lookup table for native forests on dry sites in Canterbury (red line).

Figure 6 – C storage in Aotearoa’s native forests estimated by Beets et al. (2009)

Kimberley et al. (2021) reported some new observations of sequestration rates in plantations of native species, including a number from Kimberley et al. (2014), but some from 2014 appear to be missing from the 2021 graph and so I have added them (Figure 7). Some of the implied sequestration rates they found are quite high for native species, and so this is encouraging. However, as sequestration rates vary also with site and stand management, I asked where their plots were in the landscape and how the stands were managed. Mark Kimberley replied, “They are scattered across the country, more in the North Island than South Island.” He also assured me that full details will be provided when a paper is prepared for peer review. If these plots were repeatedly measured then families of curves might be fitted in order to represent sequestration rates and carbon storage on a wide range of sites and stand management practices. It is difficult to judge how the reported rates might apply across the range of sites available for carbon forestry in the absence of detailed plot information, and repeated measures would provide us with a more realistic appraisal of variation in sequestration rates. For reference, on a roughly average site (site index=32 m in the central North Island) radiata pine planted at 800 stems/ha and then thinned to 500 stems/ha can reach 1000 tonnes CO₂-e/ha in about 25 years.

Figure 7 – Estimates of CO2-e storage in kauri and totara plantations on a range of sites at a range of stems/ha Kimberley et al. (2021) (triangles) and some extra points from Kimberley et al. (2014) (circles). Lines are fitted to the 2021 data.

Radiata pine sequestration rates can be estimated by using growth and yield models of stem dimensions combined with a carbon estimation model called C_CHANGE (Beets et al., 1999) or by applying individual tree biomass models (Moore, 2010) to stem measurements in tree lists from inventories. Thousands of permanent sample plots are available for the construction of growth and yield models, and thousands of inventory plots are established in Aotearoa’s plantations each year. A small number of very large trees have been assessed for biomass, however, which limits the applicability of C_CHANGE and Moore’s biomass models. Growth and yield measurements of stems are more sparse for other species, and comprehensive biomass data are rarely available.

Lookup tables for exotic species may greatly underestimate actual sequestration and storage. A study undertaken in a 7.5 ha experiment at Rolleston, Canterbury, across a range of stems/ha, combined with destructive harvesting of 476 local trees for biomass estimation showed that the Canterbury lookup table underestimated CO₂ sequestration of radiata pine by up to 63% (Yallop, 2021) (Figure 8). For reference, this site has a very low site index of 23, and site indices over 40 have been recorded in other parts of Aotearoa. A study at the School of Forestry, University of Canterbury, examined how assessed sequestration rates compared with lookup table rates on a wider range of sites and with a wider range of stand management practices and found that lookup tables frequently under-estimated our best estimates of actual sequestration (Nish, 2022).

Figure 8 – C sequestration and storage by radiata pine over 15 years at 2500, 1250, and 625 stems/ha and with two levels of weed competition control: 2 years (N) versus 4 years (H) on a poor site in Canterbury (Site index=23) compared to the Ministry for Primary Industry’s default carbon sequestration lookup table for Canterbury (in purple) (Yallop, 2021).

In summary, forest sequestration rates and carbon storage vary with site quality, species, and stand management. Sequestration rates in highly stocked stands of some native species on highly productive sites might approach 2/3 of those observed in radiata pine stands at lower stockings on average sites, but in many cases sequestration rates and maximum storage of C in native forests appears to be much lower than that achieved by our most rapidly-growing exotics. Moreover, native plantations appear to take longer to reach their highest rates of sequestration. Lookup tables for exotic species may be very conservative, and those for native forests need to be more diverse, reflecting the wide range of sequestration rates and storage values recorded in plots. The lookup table for natives may be roughly right for some shrubs such as manuka & kanuka or young stands of trees, but the level of maximum storage (the asymptote) clearly underestimates what has been observed in some older, high forest stands.

The case for exotic tree species

Many imported species grow and sequester CO₂ much more rapidly than native species within the time frames required to meet our 2050 target. Radiata pine has been chosen as an example for the following reasons (although other species such as dryland eucalypts or redwoods might do the job equally well or even better in some cases):

1) It grows rapidly and sequesters C at a much higher rate than native species. Between 2008 and 2012, our national carbon accounts indicate that radiata pine planted after 1990 sequestered at an average rate of 34 tonnes of CO₂-e/ha/year, and rates might be even higher with silvicultural regimes aimed at maximising value from sequestered carbon credits. By contrast, estimated rates of sequestration for native species are often below 10 tonnes of CO₂-e/ha/year during the years immediately following forest establishment (Scott et al., 2000; Trotter et al., 2005), and the slower development of young native stands would mean that they would take longer to begin effective sequestration. In older indigenous stand higher rates have been reported on some sites, but not at the rates typical of radiata pine. To be fair, studies of native forest sequestration are sparse, as outlined in the previous section, but we can also get an idea of relative sequestration rates by comparing the more numerous reports of growth rates of stems of various species (Pardy et al., 1992; Silvester & McGowan, 1999), and native species often take 3-4 times longer to reach equivalent stem volumes of radiata pine plantations at harvest even at higher stockings.

2) We are experts at producing seedlings for exotic species and they are cheap.

3) Radiata pine will grow on a wide range of sites and we understand how to establish it on diverse sites, despite its sensitivity to shade and frost.

4) Radiata pine is not a high country wilding risk (Ledgard, 2008). It is very intolerant of both shade and frost, and would only seed naturally on moist lowland areas (Dickson et al., 2000) where adjacent land was not intensively grazed (Beneke, 1967; Douglas, 1970; Ledgard, 1994) (which is a relatively rare condition in New Zealand). Our wilding species are commonly other, more hardy imports, such a P. contorta, P. ponderosa, P. nigra and Douglas fir (Ledgard, 1994, 2001; Ledgard, 2008). These wilding risk species should be avoided in carbon forests. Relative to these other species and areas of plantation, radiata pine is only rarely a wilding, and this is on lowland, ungrazed sites.

5) On warm, moist sites (either medium or high productivity categories), exotics can act as a nurse crop for native forest, and the C reservoirs we establish would ultimately change to become native forest so long as seed sources were available in the local vicinity (Figure 9). Understoreys of native vegetation are common in plantations on such sites (Brockerhoff et al., 2003; Ogden et al., 1997). This issue has been much studied by a PhD graduate from the School of forestry named Adam Forbes (Forbes et al., 2015a, 2015b, 2016). In order for native forest to regenerate under pines local native seed sources are essential.

6) Studies suggest that radiata pine will continue to sequester carbon for at least 100 years on some sites (Woollons & Manley, 2012). This means that exotic forests could remain as sinks for some considerable time.

Afforestation with exotics and conversion to native forest

I love our ngahere, and I would be delighted to be able to recommend that all our carbon forests should comprise native species, but unfortunately afforestation with native species is very expensive, and the sequestration rates of native species are not only lower than those of cheap exotics, but they take decades longer to reach appreciable rates even on some of the best sites and at high stockings (Figure 7 and Table 1).

Figure 9 - Forest biomass dynamics after introducing the exotic pine species Pinus radiata to the native species pool. Dynamics are modeled for a site near Christchurch, New Zealand. Species aboveground biomass is cumulative. "Kunzea and Leptospermum" include the early colonizing species K. ericoides and L. scoparium. "Others" include the species Griselinia lit- toralis, Pittosporum eugenioides, Aristotelia serrata, Elaeocarpus hookerianus, Fuchsia ex- corticata, Nothofagus fusca, and N. solandri var. solandri Figure from Hall (2001).

Most of our imported, exotic forest plantation species are pioneer species, intolerant of shade, and although they can be regenerated under a canopy, the canopy needs to be exceptionally sparse before any appreciable amount of regeneration to occur. Figure 10 shows how sparse the canopy was after an attempt at continuous cover forestry with radiata pine in the foothills of Canterbury.

It therefore makes sense to consider the option of planting exotics in permanent C forests and then converting them to native forests once the exotics have completed their task of filling the gap in our national C accounts that is critical over the next few decades.

Establishment of native species in some areas of our exotic plantation forests occurs with no intervention as a transition from mostly exotic weeds in young stands to increasingly native species in old stands (Brockerhoff et al., 2003; Ogden et al., 1997), but as noted by Forbes & Norton (2021), this process is not guaranteed to occur in all stands. Proximity to seed sources, extent of small scale disturbance, lack of a moisture deficit and fertility may all promote an indigenous understorey (Figure 11).

Figure 10 – An attempt at continuous cover forest regeneration using radiata pine at Woodside Forest, Canterbury. Natural regeneration was achieved when the overstorey canopy had been reduced enough through harvesting to allow a light-demanding species to prosper.

Figure 11 – A radiata pine stand in Maramarua Forest was a nurse crop for a vigorous native understorey on the lower slopes where fertility was high (left), but lacked an understorey on a less fertile hill top (right).

Figure 12 – Regeneration of native understorey under a mixed species overstorey at Milnthorpe Park, Golden Bay. Much of the regeneration is natural, but in some cases podocarps have been deliberately planted.

Figure 13 – Natural regeneration and planted natives under an exotic plantation (Credit: Dr Adam Forbes)

Figure 14 – A canopy gap in a highly stocked radiata pine plantation created to initiate natural regeneration (Credit: Dr Adam Forbes)

Figure 15 – Regeneration in a created canopy gap (Credit: Dr Adam Forbes)

Figure 16 – A mixed stand of exotics and a vigorous native understorey (Credit: Dr Adam Forbes)

Figure 17 – Native plants growing under a radiata pine stand (Credit: Jeff Tombleson)

Figure 18 – Native plants growing under a mature radiata pine overstorey at low elevation in the Bay of Plenty

There are several examples of stands in transition from exotic species to native species (Forbes et al., 2015a, 2015b, 2016). In some cases these stands required intervention, such as the creation of gaps, or even direct planting of native species. Moreover, pest control and long-term monitoring are vital.

For examples of where native forest regeneration under exotics has been initiated, see Figures 12-15. Figures 16-18 show examples where native vegetation has naturally regenerated under exotic canopies. Figure 19, from Brockerhoff et al. (2001), shows general trends in composition under repeatedly harvested pine canopies on warm, wet sites.

Figure 19 – Trends in biodiversity in repeatedly harvested radiata pine plantations on warm, wet sites (Brockerhoff et al., 2001)

Regeneration under gorse suggests that in some instances species composition may not be the same as that in stands that would have regenerated under native pioneer species such as manuka and kanuka, according to Forbes & Norton (2021).

Forbes & Norton (2021) recommend adaptive management in order to ensure that the transition takes place, and also outline research that is required should we choose this path.

In summary, transitioning from rapidly-growing exotic C forests to slower-growing indigenous ones is feasible on some, but not all, sites. Warm, wet, fertile sites close to native seed sources are the best prospects, and research is required to more clearly identify where such an approach may be successful. There should be no such thing as “plant and leave” in any C forest, either exotic or native, and monitoring combined with adaptive management and in some cases a commitment to active intervention to meet long-term objectives should be mandatory. Pest control is vital in all C forests, whether exotic or native.

Filling the gap in our national C accounts

The proper role of forests in mitigating climate change is to act as sinks while we change our emissions behaviour, thus implementing a planting programme to sequester, on an annual basis, the gap shown in the blue triangle of Figure 2. We have developed software to perform a national estate-level simulation of sequestration resulting from various planting programmes, assuming that the planting was equally likely to be in any of the LUC classes 6 and 7 areas that were “Kyoto compliant” as shown in Figure 4. In previous versions of this analysis we assumed that the last period of rapid new forest establishment, during the 1990s, was more or less on a long-term average trajectory, with periods of emission at times of harvests followed by periods of sequestration by re-established crops. However, this assumption is a bit unrealistic because the period of rapid expansion in our plantation forest estate lasted little more than a decade, and it was followed by a long period with almost no new afforestation. The effect of this planting programme, compared to required sequestration is shown in Figure 20.

Figure 20 – The effect of new plantation forest establishment on annual emissions (negative) or sequestration (positive) are shown in red, while the triangle initially estimated as required annual sequestration is shown in blue. Scenario 1 is where we wish to get to GHG neutrality by 1990

The consequence of our planting during the 1990s are that the actual requirement on an annual basis is somewhat more complicated (Figure 21).

Figure 21 – The blue triangle (Figure 2) of required annual sequestration to reach GHG neutrality by 2050 is somewhat more complicated after taking into account impacts of new forest establishment between 1990 and 2021

As harvest ages of radiata pine plantations are often between 25 and 30 years after planting, a period of rapid afforestation during the 1990s followed by little new forest planting since creates a deep deficit in our accounts during the 2020s that is difficult to fill with new planting. Even radiata pine takes 4-5 years to appreciably begin to sequester CO₂, and so the best we can do is devise a planting programme that is reasonably realistic to sequester the amount required between 2022 and 2082, while allowing for some initial swapping of amounts between adjacent decades (Figure 22). The structural regime that fills the gap in our accounts would require about 2.16 million ha of new forest, with a planting programme is shown in Figure 23.

Tentative analyses suggest that as little as 1 million hectares of unharvested exotic forests might be required.

A similar analysis for unharvested native C forests is difficult to perform in detail until we get a clearer idea of impacts of species, site quality and stand management on sequestration rates, but tentative analyses using current data suggest that the area required would be at least double the area required for structural regimes of radiata pine to do the job, and possibly much more. Moreover, native species take much longer than rapidly-growing exotic species to begin to sequester large amounts of CO₂, and so we would need extremely large areas established during the next decade in order to make any worthwhile impact on our 2050 GHG neutrality target. This disadvantage is even more problematic for native species that are regenerated naturally. We shall do an analysis in detail once plot locations providing estimates of native forest C sequestration are publicly revealed.

Figure 22 – Sequestration from a proposed planting programme on “Kyoto compliant” LUC classes 6 and 7 land of a structural regime for radiata pine (brown) versus the gap in our national carbon accounts after accounting for 1990-2021 plantings (blue)

Figure 23 – New exotic forest planting programme for to fill the gap in our national C accounts

Such a programme is feasible, but not necessarily on all the land shown in Figure 4. Many areas are too remote, too erosion-prone, or too small to make harvesting environmentally safe and worthwhile. This is particularly true of Maori tribal lands and hill-country farmland whose profitability could be greatly enhanced by carbon forestry. Permanent carbon forests are a much better solution for those areas. Moreover, the area of unharvested carbon forest required to fill the gap in our carbon accounts would be much smaller, because exotic species typically continue to sequester CO₂ at a rapid rate for many decades after typical rotation ages for wood harvests.

Costs of afforestation

Costs of new forest planting vary with species, seedling type, sites, site management activities, and stems/ha established.

The cheapest option is likely to be radiata pine, as seedling costs are usually 50 cents per tree, 800 to 1000 stems/ha is typical, planting stock is usually bare-rooted, and trees grow rapidly enough that management of weeds is not required for long. Eucalypts are a bit more expensive, because although bare-root seedling technology has been developed for eucalypts, they are most often delivered as containerised stock, at up to $1/plant in bulk. Planting into pasture is inexpensive, with often as little as a year of spot weed control often required for effective survival after planting and rapid initial growth. Under such circumstances plantation establishment can cost less than $1500/ha, but this can rise if control of high densities of woody weeds, soil cultivation, or fertilisation are required.

Adam Forbes (2022) conducted a survey of native forest restoration costs. Plants are generally delivered as containerised stock and costs ranged from $0.6-10 per plant. Overall costs per hectare varied widely, but averaged just over $7000/ha. Many forestry consultants regards this average as a low estimate. Bare-root seedling systems were developed for many native species by the Forest Service, but these technologies are rarely used today. Technology for seed collection and storage requires more development, and there appears to be scope to make establishment of native plants much more efficient.

The flawed ”emissions leakage” argument

The “emissions leakage” argument states that if we reduce GHG emissions in New Zealand by lowering production of GHG emitting industries then this will result in an increase in global emissions because production will increase in other, less GHG-efficient producers in other countries. Three critical assumptions of this argument are questionable.

a. The assumption that we are the most GHG-efficient producers is sometimes supported by New Zealand studies and widely trumpeted in New Zealand media, but studies elsewhere do not necessarily agree. For instance, Wirsinius et al. (2020) identify Denmark, France, Germany, Netherlands, Spain, and Sweden as countries that have lower CO₂-e emissions per kilogram of milk than New Zealand does.

b. The assumption that other countries will not seek to reduce emissions and simply allow expansions of their GHG emitting sectors if we reduce ours is also questionable. As the climate crisis deepens people will become increasingly reluctant to purchase products that have a high GHG emission footprints, and governments are likely to place restrictions on those products, such as border carbon adjustments (Branger & Quirion, 2014).

c. The assumption that international trading partners will ignore our GHG pollution is unlikely to be tenable as the climate crisis worsens.

Some analysts suggest that leakage may be absent or even negative with technology spillovers, and in a meta study of carbon leakage ratio (the increase in GHG emissions elsewhere divided by the reductions in a country with stringent GHG reduction policies) rates of leakage were found to be relatively modest, from 5-25% (Branger & Quirion, 2014). This means that reductions in GHG emissions from New Zealand’s agricultural sector would still be beneficial for the environment.

Response to questions in chapter 2 of the discussion document

I agree that we ultimately need to reduce gross GHG emissions to near zero. Forests can only be temporary carbon sinks, allowing us time to make other changes that will reduce gross emissions. However, as shown by the Globe study (Vivid_Economics, 2017), we cannot reduce our gross emissions rapidly enough to meet our 2050 net GHG zero target, and exotic carbon forests are vital tools for filling the gap in our accounts, as shown above. Native forests are too expensive, take too long to establish, and also sequester CO₂ much more slowly than exotic forests, hence greatly reducing their cost:effectiveness as a means to fill the gap in our national carbon accounts.

I do not agree with the assessment of the threat posed by exotic carbon forests to our gross emission reduction objective. Writers of the discussion document assume that the supply of NZUs will increase while the demand for them remains small, while overlooking the requirement for us to greatly increase the demand for NZUs.

Using the flawed “leakage argument” as an excuse, we exempt agriculture, which emits 49% of our national gross GHG emissions (MfE, 2023), as well as gifting 6.5 million NZUs (8.5% of our total gross emissions) to trade exposed industries. If these polluting sectors were required to purchase NZUs then the demand would greatly increase, and the impact of forest-based credits on the NZU price would be much less. Moreover, changes to the assessment of sequestration on small woodlots less than 100 ha would further reduce the impact.

As outlined above, small woodlots are required to use lookup tables for calculating C sequestration that in the case of exotic species often greatly underestimate C actually sequestered in woodlots. This motivates people to purchase whole farms in order to establish larger C forests, driving up land values in the hill country and threatening hill country communities based on pastoralism. Returns from pastoralism in our hill country are small, and so large-scale conversions to forest do not threaten our economy, but they do threaten hill-country culture. If farmers could earn more from small C woodlots then whole-farm conversions would be less frequent, farms with small woodlots would be more profitable, and the ETS would become more popular in these communities.

So, we need much more new forest than we currently have in order to get to our 2050 net zero target, and instead of regarding forests as a threat we should welcome their contribution, we can and should afforest differently, though, encouraging small woodlots on farms, with ultimate conversion to native forest as a long-term objective. More realistic estimates of sequestration rates in small woodlots and also entry into the ETS of agriculture and trade-exposed industries would get us there.

Response to questions in chapter 3 of the discussion document

The Globe study (Vivid_Economics, 2017) made it clear that we need removals of CO₂ with forest sinks in order to meet our 2050 target.

Response to questions in chapter 5 of the discussion document

Both gross emission reductions and GHG removals are important, because new forests are only temporary sinks, and ultimately reducing emissions is the only sustainable option. However, we can’t immediately get to zero gross emissions and our 2050 target must be partly met by removals. Currently it is often cheaper to pay for removals than make reductions, but that is with 57.5% of emitters not participating in the ETS and small woodlots poorly rewarded for sequestration.

Response to chapter 6 of the discussion document

The status quo is not working well. Most of our emitters aren’t even in the ETS, auctioned credits are essentially fraudulent, sector lobby groups have far too much political influence, and the price of credits fluctuates to the point where most money is made via speculation in the ETS rather than by actually helping to mitigate climate change.

Option 1 is partly sound. The government should not auction credits.

Option 2 is deeply flawed. The last time we allowed emitters to purchase international credits our NZU price dropped to $3, and people still hoarded them because international credits were available for as little at 10 cents each. This policy created the credit hoarding problem we now face. Moreover, in the unlikely event that purchased international credits were not fraudulent, we would be paying other people to make changes in emission behaviour that ultimately we will have to make ourselves.

Option 3 would distort an already deeply distorted ETS. We already pay polluters to pollute by giving them free allocations or auctioning credits at low prices, when really the only people awarded credits should be those sequestering C. Credits that do not represent anyone cleaning up GHG emissions are the largest threat to our ETS market and credit price (See appendix 2). Credits for reduction activities should not exist. The reward for reducing pollution should be that the former polluter no longer has to purchase credits.

Option 4 is fundamentally irrational. The government proposes to allow people who purchased fraudulent credits or who were simply gifted fraudulent credits due to an irrational fear of leakage to sell their right to pollute while those actually removing pollution from the atmosphere would face a hugely restricted market and lower credit price. This is fundamentally unfair.

The government’s suggested changes to policy are potentially damaging over-reactions that are unsupported by what we currently know about sequestration rates of native & exotic forests and the potential to convert exotic C forests to native forests after they have served their purpose as rapid carbon sinks. They have already sent shivers through the forestry sector and undermined attempts to create forests to fill a well-known gap in our national C accounts, meaning that we may face billions of dollars in foreign credit purchases in future without changing our behaviour substantially.

Response to chapter 7 of the discussion document

7.1 Should co-benefits be recognised in the value or quantity of carbon credits awarded for afforestation?

Making a change such as this would further distort the ETS, and the idea of “greenhouse gas neutrality”, so vital to the credit market, would become even less tenable. By all means put more money into increasing indigenous biodiversity, but don’t pretend that it sequesters more C than it actually does.

7.3 Should a wider range of removals be recognised?

All verifiable C sinks should be included in the ETS.

Comments on C forestry

Whole-farm conversions

It has been suggested that whole-farm conversions to carbon forests are a threat to vital export industries, but this is not so. This would be true if conversions were of dairy farms, but almost all carbon forests are established on hill country farms, usually land use capability classes 5 or 6, and on such land farming makes very small returns on investments even in good years. We need to recognise that such conversions are not threatening our economy, but instead they are perceived as a threat to a way of life. They are a social problem, not an economic one.

We should therefore seek to enable farmers to establish carbon forests on small portions of their farms.

Under-estimates of sequestration rates in MPI’s lookup tables provide an incentive for whole-farm conversions because areas of C forest greater than 100 ha allow land owners to avoid using low lookup table rates. It is therefore vital that lookup tables for all species be made more accurate across a range of species, sites, and stand management activities. An alternative would be to develop cheap assessment strategies, such as LiDAR, to rapidly assess biomass in small woodlots so that farmers might gain the full value of the carbon they sequester. This change would make small C forest woodlots on small portions of farms more financially viable.

Given weaknesses of the underlying assumptions and results from empirical studies, use of the leakage argument in New Zealand as a justification for doing nothing in some sectors cannot be justified.

Exotic versus native species

As outlined above, exotic species generally sequester at much more rapid rates than native forests on the same sites, given similar management, and exotics are currently far cheaper to plant than native forests. Natural regeneration of native forests is feasible but usually takes far too long to be of use during the critical stage when we require forests sinks to fill the gap in our carbon accounts.

If we proposed to fill the gap in our national C accounts with unharvested exotics we would probably need as little as 1 million ha of new forest. Instead of restricting species choice to slower, more expensive native carbon sinks, the government could reduce the likelihood of unwanted outcomes by requiring that all “permanent forest carbon sink” establishment proposals, for both native and exotic forests, be accompanied by a comprehensive plan, outlining:

1. The long-term future envisioned for the forest

2. A monitoring plan

3. An adaptive management plan

4. A plan for pest control

5. A plan for financial support of stand management and required research

The plan should be a binding agreement between land owners and the crown. The requirement for approved management plans for harvesting of native forests on private land is a precedent for this kind of policy.

If we filled the gap with periodically harvested exotics we would need about 1.75 million ha of new forest, and the future of that forest would be to provide extra value to our economy via increased exports of wood products. We should, however, be mindful that not all sites are suitable for production forestry with exotics, and these new forests should only be permitted in suitable land, where harvesting and re-establishment will not pose a risk of erosion and slash movement during cyclones.

Estimates of the area required to fill the gap with native species, allowing for the types of land available, are problematic because we cannot simply say native species might ultimately sequester at half the rate of our fastest growing exotics, therefore we need twice the area, because native trees take a long time to establish, and our target year for greenhouse gas neutrality is only 27 years away. A very conservative estimate suggests that we might need approximately 3 million ha of planted, unharvested native forest on hill country land to fill the gap. This option would be extremely expensive and the required area may be even greater than our optimistic projections.

Some alternative proposals

It is clear that with appropriate planning we can record our current trajectories and plan required pathways to get to our 2050 target and beyond (for instance see Figure 21 above). At present we are doing far too little to address climate change because:

1. we give away or auction too many fraudulent credits;

2. more than half of our GHG emitters do not have to pay for polluting;

3. our lookup tables of sequestration rates for species, sites and silvicultural management are extremely inaccurate for small woodlots. We therefore incentivise mainly large blocks of C forest and deny farmers the opportunity to profit fully from small blocks of trees while they continue to farm;

4. we use a highly questionable rationale to continue polluting that we call “leakage” despite the fact that it is based on faulty assumptions and that international evidence suggests it is not a serious problem even for leakage to third world countries that have few, if any, international climate change mitigation commitments;

5. we make knee-jerk changes to the ETS that further complicate it and often water down the effectiveness of the scheme, resulting in wild fluctuations in credit prices.

The most obvious improvements in the ETS, consistent with its original intent, would be to:

1. stop creating fraudulent credits and auctioning them;

2. stop giving credits away for allowed pollution under the highly questionable justification of “leakage”;

3. bring all greenhouse gas emitters into the scheme on an equal basis;

4. enable realistic rewards for sequestration with woodlots < 100 ha;

5. require C foresters to lodge a plan for the long-term future of their C forests, and if necessary, set aside funding to pay for future management.

Such measures would greatly restrict the supply of NZUs while increasing demand, providing an incentive for people to reduce emissions rather than purchase credits.

Appendix 1: Research required

Several avenues for research can improve our knowledge and allow us to make better policy decisions:

1. We need to be able to predict with more certainty where exotic species can act as effective nurse crops, and also to understand where this might happen naturally, and where more costly intervention is required to make it happen.

2. We need much better estimates of how rates of C sequestration are influenced by species choice, sites and silviculture for both exotic and native species, and lookup tables need to be more realistic.

3. We need to work to make growth of native seedlings in nurseries more efficient, and to improve survival and growth after planting them.

4. We need to more clearly delineate sites where debris flows after harvesting will be a problem, and implement technologies to ensure that they do not occur.

Appendix 2: Why auctioned and gifted credits are irrational

In a well-functioning emissions trading scheme, polluters would have to submit credits in order to be allowed to pollute, and they would purchase credits from those who cleaned up their pollution. So if the cost of cleaning was higher than the cost of reducing pollution in the first place then they'd choose to reduce emissions. Either way the atmosphere would not receive any more GHGs and purchasers of carbon credits could rightly call themselves "greenhouse gas neutral".

However, that's not what's happening. If a polluter reduces their pollution then they can sell credits gifted to them for their “allowed” pollution because of an irrational fear of “leakage”, or that they have purchased in an auction where fraudulent credits are simply made from thin air and don’t represent anyone cleaning up the atmosphere. They also assert that purchasers of their credits can claim to be "greenhouse gas neutral". They are wrong.

There are many ways to explain why they are wrong. You could use stories, mathematics, graphs or even children's blocks. Let's use the latter.

Blocks below represent levels of greenhouse gas in the atmosphere and levels planned to be emitted by two polluters.

Figure 1

Then polluter 2 opts to no longer pollute and has grandfathered carbon credits for sale. Polluter 1 purchases those credits and is allowed to pollute. The result is more greenhouse gas in the atmosphere, as shown below. Polluter 1 clearly cannot claim to be "greenhouse gas neutral".

Figure 2

So, what kinds of credits can confer greenhouse gas neutrality on a purchaser? Let's reach for the blocks again. In this case, we have the atmosphere, a potential polluter and someone who will take greenhouse gas from the atmosphere (maybe using new trees, a scrubber, or perhaps by seeding the ocean with iron to promote plankton); a sequesterer.

Figure 3

The sequesterer receives carbon credits for removing greenhouse gasses from the atmosphere. They are purchased by the polluter, who then goes ahead and pollutes, but the amount of pollution is exactly equal to the amount of sequestration and so the result is shown below:

Figure 4

Clearly, the atmosphere gains no new greenhouse gas and the polluter can now claim to be greenhouse gas neutral.

It is generally much cheaper to do nothing than to extract greenhouse gasses from the atmosphere. If we allow people to sell carbon credits for simply reducing outputs of greenhouse gas, we effectively pay them for nothing because their reward for reducing emissions should be that they no longer have to purchase credits.

Our current scheme is essentially irrational with respect to gifted and auctioned credits.

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[1] https://en.wikipedia.org/wiki/List_of_countries_by_greenhouse_gas_emissions_per_person

[2] https://www.climatewatchdata.org/ghg-

emissions?breakBy=regions&calculation=PER_CAPITA&end_year=2018&regions=G20%2CWORLD%2COECD&start_year=1990

Photosynthesis

Thursday, April 18, 2024

Submission on the proposed Fast Track Approvals Bill, 2024

Thursday, August 10, 2023

Submission on the proposed redesign of the Emissions Trading Scheme, 2023

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