Farm Forestry New Zealand

Carbon measurements that forest owners will have to make

Hamish Levack, New Zealand Tree Grower May 2011.

Join NZFFA »

MAF’s proposal

MAF proposed that five-yearly measurements be mandatory for post-1989 forests of 100 hectares or more and which are registered under the ETS or the Permanent Forest Sink Initiative. On completion of these measurements owners would receive specific look-up yield tables to be used to estimate carbon changes during each five year period.

On the other hand owners of post-1989 forests of less than 100 hectares in area would be obliged to continue to use the current look-up tables. These are less reliable, being based on generalised regional forest data.

Using the field measurement approach you have to:

• Apply to MAF for sample plot location co-ordinates
• Establish permanent sample plots in their forest
• Take measurements at the sample plots
• Submit the measurements to MAF
• Use the participant-specific look-up tables that theyreceive from MAF to calculate forest carbon stocks.

At the same time MAF also introduced new look-up tables. These were for post-1989 indigenous forest harvest residues and for the deforestation of indigenous forest planted after clearing pre-1990 exotic forest.

Backdating and reconciliation

Participants who have previously completed claims using the currently available, regional based, look-up tables would not be allowed to claim back-dated adjustments immediately. A mandatory emissions return covering Commitment Period 1 from 1 January 2008 to 31 December 2012, would have to be submitted between 1 January 2013 and 31 March 2013.

The NZFFA’s submission

The NZFFA made a submission suggesting several improvements. Apart from technical comments on the desirable size, shape, frequency and layout of plots, four main points were made:

1. That the field measurement approach FMA should be designed to double up as a system that can also provide useful management information for forest owners.
   The NZFFA asked that the measurement system coincide with inventory work which is currently doneas part of good forest practice so as to avoid unnecessary work duplication and would minimise costs. For example,it would be much more convenient if FMA plot work could double up as plots for quality control after thinning, mid-rotation inventory and pre-harvest inventory.
   This would require only three measurements over around 30 years instead of the six proposed by MAF.
   The NZFFA pointed out that, if estimates of carbon sequestered or emitted at intermediate times are needed every five years for example, to meet with obligations under the Kyoto Protocol, necessary data could be reliably provided by interpolation. The NZFFA conceded that special inventories may be required before early harvestor in the event of significant catastrophes. By checking satellite photographs MAF could readily verify whether owners had been complying.
2. The FMA should also double-up as a system to help the government increase the reliability of regional yield projections so as to improve national planning regarding transport, industrial and social development.
   Together with the National Forest Descriptionand Farms on Line, the FMA will provide the final component of a national plantation forest inventory which is something that all governments need for planning purposes. The corollary of this is that, as a beneficiary, the government should pay for any forest inventory costs that it obliges a forest owner to make that the forest owner would not normally make.
3. Self assessment is advocated.
   The measurement of carbon and furnishing a five-yearly return was compared with how we do our ordinary tax returns. The NZFFA concluded that MAF should not be dictating exactly how and when plots should be established and measured − one size does not fit all. Educating woodlot owners about minimum field assessment requirements and auditing doubtful returns are valid roles for MAF, but further involvement is unnecessary.
4. Anyone who wishes to be an ‘FMA participant’ should be allowed to be just that.
   In general, although not always, farms will produce higher yielding stands than are depicted by the region-wide look-up tables. This is because these look-up tables have been constructed using data from old state forests which were planted on more difficult sites. The NZFFA pointed out that it would be unfair if someone who owns less than 100 hectares of forest, and knew that the default tables underestimated his carbon, was not permitted to be an FMA participant, whereas his neighbour who owned 100 hectares or more, could be a particiapant.

The result

After pondering our NZFFA submission, and the submissions of other interested parties for several months, MAF announced in March that there would not be any change. All submissions had been ignored. MAF’s unmodified proposals are to become regulations that take force in September.

Should we have expected anything else? Following a round of consultations in 2010 after it issued a parallel proposal about how farmers would be accessed for the agricultural emissions methane and nitrous oxides, a large number of objections were received. They were also all ignored by the government. The government seems to be wasting everybody’s time by pretending to consult.

Hamish Levack is a member of the NZFFA Executive