Submissions to New Zealand’s biodiversity market consultation agreed that governments alone can not muster enough cash to adequately address biodiversity decline, but there are concerns that credit-based schemes are too immature to be considered.
Writing in a joint submission to the consultation, which opened in July and closed this month, Environmental Defence Society, Pure Advantage, and WWF-NZ critiqued the government’s line of questioning as too narrow, saying other options beyond a biodiversity crediting scheme should be considered.
“A biodiversity credit system may have potential in this country. However, the mechanism is relatively new and evidence of its efficacy overseas is still emerging. More work is required before progressing it further,” it said.
“In that regard, we consider that other options not explored in the discussion document may provide a better, or complementary, solution.”
It raised the idea of a biodiversity incentives scheme that could act as a supplementary measure to address climate change and biodiversity loss.
An incentives scheme could come in the form of providing grants to landowners to cover the cost of establishing nature-positive indigenous forests, and once established, carbon credits accrued through the country’s ETS could come into play and continue to incentivise biodiversity gains.
It said this scheme might be easier to scale than a biodiversity credit scheme and would provide the up-front cash needed to scale up New Zealand’s native afforestation sector.
The joint submission said the government should engage more widely on other options for transformational green financing, while still progressing its investigation into a crediting scheme.
IMPORTANT FEATURE
Minerals and mining industry group Straterra was more receptive to the idea of a biodiversity market in the country, saying it would provide a useful revenue stream for the Department of Conservation.
A crediting system should be primarily project-based, its said, arguing that while outcomes would be based on theory, an approach based on activities and projects would be more practical – emphasising that verification would be critical.
Straterra sees the mining sector involved as being both purchasers and sellers of biodiversity credits, and argued strongly for the case that credits should be used for offsetting purposes.
Its submission said purchased credits could be used under the effects management hierarchy as part of the consent process towards management, mitigation, offsetting, or compensation of environmental impacts.
“This is an important feature of the system to ensure that resources enhance biodiversity in a coordinated and enduring way,” it said.
Additionally, it said mine rehabilitation projects should be open to biodiversity crediting.
However, offsets in the scheme was something the three NGOs vehemently opposed, arguing that biodiversity credits “are not intended to be offsets for damage, but investments in a nature-positive future”.
Similar concerns have been raised about the treatment of environmental offsets in Australia’s proposed nature repair market legislation.
Think-tank the New Zealand Planning Institute (NZPI) also said the use of credits to offset development impacts as part of the resource management processes was not appropriate.
“The outcomes the credits achieve may have no relation to the impact of the activity seeking consent,” its submission said.
“There is also no additionality if credits can be used for offsetting – the offsetting will occur through the consent process regardless of whether this is a biodiversity crediting scheme.”
On the question of outcomes, activities, and projects, NZPI said these three bases were not mutually exclusive.
“We consider that a BCS needs to be driven by overarching outcomes for Aotearoa New Zealand’s indigenous biodiversity, and that these outcomes should be achieved by particular types of activities that support enhancement and protection, and also by specific projects that achieve those outcomes,” it said.
“This type of approach or structure will provide for strong links to the resource management planning system.”
NZPI’s submission went on to say that projects and activities that generate credits must provide permanent biodiversity improvements that must be guaranteed.
It added the country’s resource management system could be used to ensure credits are applied in targeted areas, combined with planning documents identifying objectives, or future end states for biodiversity that credits can be used to achieve at the national, regional, and district level.
STARK
All submissions agreed that the state of biodiversity in New Zealand was declining, and that the government would not be able to come up with the funding required to put a halt to it.
“We cannot just continue to rely on government funding and the goodwill of landowners to solve the biodiversity crisis. Something more is required if this country is to adequately protect, maintain, and restore biodiversity on both public and private land,” Environmental Defence Society, Pure Advantage, and WWF-NZ’s submission said.
NZPI said the statics of the country’s declining biodiversity were “stark” and as much as possible needed to be done to reverse this decline.
“In principle, we support a biodiversity crediting scheme that enables funding for enhancing and protecting indigenous biodiversity,” it said.
The submissions follow initial remarks made about the consultation in July when stakeholders cautiously welcomed the idea of the scheme, but had little faith in the government to deliver it in light of its handling of the ETS.
That government has since been voted out, and it is still unclear what the final makeup of the National and Act coalition government will look like, or whether they will choose to continue pursuing a biodiversity crediting scheme.
By Mark Tilly – mark@carbon-pulse.com
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