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Nick Butcher

Our Carbon 2.0 Vision


Tui bird on a flax flower stalk

Forests suck up CO2.


More forests suck up more CO2.


We need more CO2 sucked out of the atmosphere... so we need more forest.


Seems like something that everyone can get behind, right?


Sadly, that’s not always the case. Some people believe that some forests don’t count, even when they’re still growing and sucking up new carbon. We think these forests should count, and that our climate response needs them to count.


We believe that if you can demonstrate that your forest has sucked another tonne of carbon from the atmosphere last year and you commit to protecting that forest in the long term… you should be able to have that sequestered tonne of carbon recognised with a carbon offset - a CarbonCrop Unit.


CarbonCrop Units are:

  • 1 tonne of CO2, as assessed by CarbonCrop’s AI-enabled methodology

  • Removed from the atmosphere within the last 5 years

  • Durably stored in the growing biomass of regenerating native forest

  • With a binding obligation on the landholder to ensure the CO2 stays sequestered for the next 100 years


The argument against this hinges on a test called ‘Additionality’, which says that only activities beyond those already underway should be recognised.


Under the strictest interpretation of Additionality, you only get recognised for something if you weren’t going to do it anyway.

This means:

  • A carbon-farming corporation is incentivised to buy up thousands more hectares of high productivity farmland and plant it out in pines for carbon revenue. This is certainly additional, but that doesn’t mean it’s preferable.

  • Meanwhile, a farmer who retired a hillside in 1970 and has been quietly chipping away at restoring the forest for decades is deemed ‘business as usual’, and isn’t incentivised (or funded) to keep at it, or do anything more, because it’s too hard to tell the difference between what’s new and what they might have done anyway.

  • Another farmer who last year fenced off their river boundary and planted new trees to improve water quality will also see their carbon sequestered not considered additional, because they didn't plant the trees for carbon credits. Without incentives, they're less likely to encourage faster growth of those trees, or plant more. The trees may qualify for the ETS, but they often don't.


The tragedy of this interpretation of Additionality is that it unintentionally discourages potential new restoration activities because it's just too hard to prove what was going to happen anyway vs what was new.

  • Was that forest really going to be harvested otherwise?

  • How much of that new growth is the result of pest control and stock exclusion, vs just the higher rainfall and increased sunshine this year?


Our approach, while different, ultimately achieves Additionality. Sometimes it will recognise carbon that was going to be sequestered by a forest anyway, but the long term commitment to protect that forest, and the incentive to do more, drives the additional response.


Focusing purely on ‘strictly Additional’ sequestration is subjective and unreliable in practice. It increases the cost of monitoring and compliance to the landowner meaning they receive less funds to put into their forest, and it can create perverse incentives that can drive landholders to stop ongoing forest restoration - or even start harvesting.


Edit: Fundamentally our goal is to enable and support the ongoing restoration and protection of native New Zealand forest. Earlier in this process, we found a lot of philosophical alignment but it wasn't clear how to square this with conflicting guidance from a number of international standards. However, with the newly released draft guidance from the Integrity Council for Voluntary Carbon Markets, we see our philosophical position reflected in leading international recommendations, which can be reconciled with what needs to happen to better support and enable native forest restoration. We anticipate amendments to our methodology and process to align and clarify as the ICVCM guidance is finalised in the coming months.


Trying too hard to achieve additionality can - and has - led to anti-additional action. When taking action falls into the “too-hard” basket, we all miss out.

We could be boosting the carbon sucking potential of our regenerating native forests right now. We’re not - or at least, not anywhere near enough. And funding is a critical constraint. Maybe there’s a better way to get this done, but it’s certainly not what we have today. The status quo wastes the potential of our regenerating native forests, and that’s hurting everyone - landholders, businesses looking for better offsets, and the climate and country at large.


We need more, not less. We want to reward more sequestration. More from people who are currently doing nothing and more from those currently doing something. We need as much more as we can get right now.


We choose to reward all ongoing sequestration, because if you try to pick and choose it's very easy to end up with less.


We’ve pioneered something new to deliver more for our native forests, landholders, businesses, and climate. Ultimately we believe this will help protect and improve biodiversity and the climate, and that doing something today is better than waiting for a tomorrow that may never come.


We pledge 100% native offsets, 100% NZ offsets, 100% removal offsets, and 100% transparency.

We invite (not challenge) anyone who can improve on our methodology to deliver better offsets and better forests, at the scale the world needs, to step forward and collaborate with us. We support anything and anyone that will get us there faster.


In that light, here are some summaries of our position and thinking on the latest concerns raised.


Does your approach just rely on goodwill to make the planet better?

Quite the opposite! It rewards things which people have done recently out of their goodwill (and their hope for a better future), ensures they continue, and incentivises more. This uses Incentive Theory… which is a core principle of economics that states (obviously) that incentives are a great way to trigger future action! Our approach simply pays people for delivering what we all want - carbon sucked out of the atmosphere, and locked up in protected forest. We only issue offsets when that happens, which means people only get paid for actually delivering the positive result. We still love and applaud goodwill, but we rely on clear market incentives to make the planet better.


Does CarbonCrop require landowners with regenerating forest to do anything extra in exchange for carbon offsets?

We require their forest to sequester carbon, and for them to commit to protecting that forest for the next 100 years, and make up for any reversals, and we monitor and track that carbon to ensure it’s only counted once. Also, with access to incentives to sequester more carbon, it’s safe to assume landowners will increase their activities - that’s how incentive markets work! We just monitor and verify; we leave the ‘how’ up to them. For every new tonne of carbon their forest sequesters, they’ll get another offset issued.


Does your approach always meet the strictest interpretation of ‘additionality’?

No. Nor, in practice, do many offsets issued under international standards. The strict interpretation of additionality says that offsets can only be issued for carbon sequestered through new actions that go beyond what’s already being done. This results in confusion and uncertainty, and ironically leads to less action - though it might save some money. We think we’re past the point of trying to find the cheapest path, and that the pragmatic solution is to pay for all recent forest sequestration and protection. Doing this in a transparent way can’t help but drive additional investment in forest restoration and protection, and hence drive additional carbon sequestration enabled by the offsets. Additionality achieved.




Is there anything that you’re doing which does align with the strict interpretation of guidelines?

Yes - everything else! We present a detailed overview of how our approach aligns with the Ministry for Environment guidelines here. Even additionality is rarely a ‘yes’ or ‘no’ answer in practice, and this is true across many projects internationally - we’re just unusually open about the fact. Because of this transparency, you can be sure our offsets are 100% New Zealand, 100% native and 100% removal offsets.


Do these international standards guarantee additionality and all the other guidelines are met - do their offsets always meet the grade?

Not even close. Independent evaluations say they’re often not additional, or real, or many of the other ‘guidelines’, summarised. Some of the most widely adopted methodologies from the past have, with the benefit of hindsight, been shown to largely result in no impact.


Is the industry trying to improve?

Yes, but it’s slow, and there are vested interest groups who benefit from the status quo. The climate needs us to do more today, not wait while “leaders” continue to quibble.


What will your approach deliver?

Better offsets, better forests, more open participation and transparency.


Buyers want offsets that represent a verifiable tonne of carbon removed from the atmosphere, that are traceable back to the date and source of removal, and that support biodiversity.


By making it worthwhile for people to choose restoring and protecting regenerating native forest, we can scale a response to biodiversity enrichment and climate change mitigation, faster.


What’s the worst that could happen if this approach catches on?

Some people who are restoring and protecting forests will get paid with carbon offsets, when they might have done it for free. Is this really a bad thing if it results in more native forest, sequestering more carbon and improving our wildlife habitats?


Is there anyone else who takes this approach?

Yes, though usually in a more complicated or narrow form.


Some examples, all of which are used to support voluntary offset claims in New Zealand, include:

  • The NZ Emissions Trading Scheme, including PFSI (Permanent Forest Sink Initiative) registered areas, award carbon for all ongoing sequestration in a forest, regardless of whether that forest was ‘already growing’ when the registration happened. No strict additionality requirement. We fully support the ETS - and help our landholders register in it wherever possible. Unfortunately, it excludes forest that may have started growing prior to 1990 - even where that forest can still store more carbon - and most of this forest is native.

  • Various ‘CarbonZero’ farming certifications also routinely recognise sequestration in exactly the same way as we do for the purposes of on-farm offsets (sometimes called ‘insets’) - you may have seen claims that insets are ‘different’, but we believe they’re not. They use the same approach to additionality (more on this in a post shortly!)

  • Finally, many international standards for forest carbon offsets routinely recognise sequestration in exactly the manner we do - they just usually force the landholder through more hoops, such as claiming the forest was going to be harvested otherwise. Enormous numbers of these claims have been proven questionable in practice, and this just misses the point of encouraging more carbon sequestered.


Why not just wait for the NZ Emissions Trading Scheme to deliver incentives for Pre-1990 native forest?

‘Wait’ is the key word here. We’d love it if the NZ ETS formalised what we’re trying to do - can they do it today please?!! But people with existing forests have been waiting for a solution for a long time, and every year that goes by is another opportunity lost. Climate change isn’t waiting for us to get our ducks perfectly quacking in a settled row, so we’re choosing to act now instead of waiting for tomorrow. The result will be finance enabled to support more regenerating forest and less carbon in the atmosphere. We think that’s what’s needed.


We think these are critical issues to build clarity and alignment across the voluntary offset industry. While you might see this presented as a ‘settled issue’, the status quo is far from settled and is leading to huge lost opportunities to boost forest restoration and climate change mitigation. We want to make it better, and we’d love you to be part of that journey. You can find more about what we’re doing in our earlier response and our FAQs.


And again, what is a CarbonCrop unit, specifically? What does that mean?

CarbonCrop Units are:

  • 1 tonne of CO2, as assessed by CarbonCrop’s AI-enabled methodology.

  • Removed from the atmosphere within the last 5 years.

  • Durably stored in the growing biomass of regenerating native forest

  • Regardless of the initial establishment date of that forest

  • With a binding obligation on the landholder to ensure the CO2 stays sequestered for the next 100 years.

Our method of recognising carbon sequestration means:

  • We can increase restoration and preservation of regenerating native forest across New Zealand, at scale.

  • Businesses purchasing offsets have a domestic, traceable, carbon offset option for carbon removed from the atmosphere, as an alternative to current international offsets which might not actually remove any carbon from the atmosphere at all.

Landholders are directly incentivised to do more to increase carbon sequestration in their existing forest.

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