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ForestX Comment

With submissions being called in relation to both the new carbon legislation and associated regulations here is a summary of the submission we have made, aimed at building confidence in the carbon regime:

One source of truth - most land owners find the system complex, while it may need to be so, finding and applying the rules could be easier: is it possible to move to a single manual and decision support tool that can be relied upon to always be up-to-date, including warnings on pending changes?

Irrefutable status of existing registration - we have had to deal with some irate land owners that didn't know they were part of the ETS as pre-1990 participants: is it possible that if a property is in the ETS this status is recorded on the certificate of title without fail and the record include the type of registration?

Pre-approval - much time is wasted with land owners speculating whether their land will be approved as eligible for registration in the ETS: for all likely land, probably Land Use Classes 7 and 8, is MPI able to make an initial assessment of whether it is likely to be approved for registration with this information being searchable on a public database?

Improved data - much time is wasted speculating on likely sequestration levels, the highest quality data is held within the ETS system at great expense to participants: could the MPI publish summaries of this data at a district level with it being searchable on a public database?

Political transparency - ultimately the carbon price is a political as opposed to market price similar to interest rates but unlike interest rates central government does not provide price guidance as an indicator of its policy thrust: would the government consider an annual policy statement as to policy direction and project expected price levels in commitment to the stated direction?

Commutability - a potentially separate system for agriculture has left a level of confusion as to an appropriate path for forestry: could this be soothed by opening a discussion on the basis on which NZUs can be used within the agricultural emissions system?

You can make your own submission through the MPI website.