Policies & action
New Zealand’s current policies are “Highly insufficient” when compared to modelled domestic pathways. The “Highly insufficient” rating indicates that New Zealand’s policies and action in 2030 are not at all consistent with the Paris Agreement’s 1.5°C temperature limit. If all countries were to follow New Zealand’s approach, warming could reach over 3°C and up to 4°C.
New Zealand will not achieve its NDC with currently implemented policies. The CCC advice to government drew a similar conclusion while including LULUCF in its analysis, noting that New Zealand previously relied on forestry offsets and purchasing offshore mitigation instead of effective climate policies (Climate Change Commission, 2021a).
The CAT finds that following an emissions trajectory based on policy and actions, New Zealand will have emissions of 74 MtCO2e in 2030 (excluding LULUCF), which is 17% higher than 1990 levels. The NDC target equates to 68 MTCO2e in 2030 (excluding LULUCF), which is 5% above 1990 levels.
CAT policies and action projections for New Zealand are based on government sources which project a dip in emissions in 2020 as a result of COVID-19 without a rebound (Ministry for the Environment, 2021c). This policies and action trajectory assumes New Zealand can sustain the low emissions resulting from the COVID-19 pandemic as the economy recovers.
The COVID-19 recovery efforts, if directed appropriately, could provide an unprecedented opportunity to kick-start plans for a low emissions economy in line with the governments 2050 net-zero goal. However, New Zealand, while taking only incremental steps towards a green recovery, has made environmental safeguards optional.
In response to COVID-19, the government swiftly passed new legislation that fast-tracked projects to boost employment and economic recovery (Ministry for the Environment, 2020d). The legislation provides an alternative pathway for projects to bypass the Resource Management Act, but it does provide optional environmental safeguards as the Environmental Protection Agency vets the applications before referral to an expert consenting panel (Ministry for the Environment., 2020). However, the act ought to ensure emissions-intensive projects are not approved. The Act has a ‘sunset clause’ and will be repealed after two years (Ministry for the Environment, 2020d). The independent Climate Change Commission had called for these safeguards on fast-tracked ‘shovel-ready’ projects, in order to guarantee emissions intensive projects would not be approved (Wannan, 2020).
Budget 2020 was the first budget implemented during the COVID-19 pandemic. The Climate Change Commission found that the Budget 2020 did not provide enough investment to meet New Zealand’s climate change goals (Gibson, 2020).
Budget 2021 offered relatively small-scale funding in support for climate related policy, including:
- NZ$300 million has been allocated to the New Zealand Green Investment Finance supporting low carbon technology.
- NZD 67.4m for the Carbon Neutral Government Programme to decarbonise the public sector and lease low emissions vehicles. It includes NZD 19.5m for the State Sector Decarbonisation Fund which plans to replace medium-sized coal boilers in hospitals and schools (Shaw, 2021a).
- NZD 19.7m for the Government to respond to the Climate Change Commission’s advice (New Zealand Government, 2021b).
These amounts directed towards addressing the climate crisis are very little relative to the funds made available to the COVID-19 crisis. The COVID-19 Response and Recovery Fund (CRRF) has an allocated NZD 5.1bn (New Zealand Government, 2021b).
Additionally, although allocating funding to addressing the CCC’s advice is positive, the government is not required to wait for the CCC’s advice to implement climate policies. The CCC has since published its advice and the government intends to release an Emission’s Reduction Plan by December 2021.
The CCC recommended three shrinking emissions budgets over five-year periods to 2035 to support meeting the 2050 targets. However, the CCC’s emissions budgets do not meet the current NDC, let alone be 1.5˚C compatible. The CCC advice to government outlines the policy direction on the first emissions budget and covers all sectors of the economy (Climate Change Commission, 2021a). Lawyers for Climate Action Incorporated (LCANZI) has filed proceedings against the CCC in the High Court, as they assert the CCC’s advice is not compliant with legislation (LCANZI, 2021b). LCANZI argue the emissions budgets are not consistent with the Paris Agreement 1.5°C goal and the accounting methods are inconsistent with the Climate Change Response Act. The NDC makes a logical and mathematical error by using a gross - net approach (please see the forestry and land use section below for further details).
New Zealand’s main instrument to reduce greenhouse gas emissions is an Emissions Trading Scheme (NZ-ETS) (Ministry for the Environment, 2019). It is a market-based approach that ensures certain sectors report on and are charged for their emissions. Included sectors are industrial processes, liquid fossil fuels, stationary energy, waste, horticulture, primary industries and industry involved in synthetic greenhouse gases. Since June 2015, the NZ-ETS has transitioned into a domestic-only scheme, and it is not yet clear whether the Government will reopen the NZ-ETS to international units, it certainly aims to limit their use (Ministry for the Environment of New Zealand, 2019).
The government passed the NZ ETS reforms in June 2020. The reform introduces a cap to limit the emissions covered by the ETS, which will decline in accordance with New Zealand’s carbon budgets based on emissions targets (Ministry for the Environment, 2020c). The government set a provisional carbon budget for 2021 to 2025, in lieu of the carbon budget developed by the Climate Change Commission released in 2021 which the government is yet to consider. The CCC lists a number of recommendations to improve the ETS, including changing the ETS unit supply to align with the emissions budget and lower the stockpile (Climate Change Commission, 2021a).
The revised ETS introduced auctioning of New Zealand units (NZUs) which started in 2021, where bidders can bid for units. The proceeds from auctions will be recycled for further emissions reduction in Budget 2022 (Shaw, 2021b). The reform set a price floor at NZ$20 starting in 2021 (Ministry for the Environment, 2020c). To regulate the price of units, the government set up a “cost containment reserve” (CCR) where it releases more units into the market if the price reaches NZ$50, and this will increase 2% a year to reach NZ$54.12 by 2025 (Ministry for the Environment, 2020b).
Other amendments to the ETS include phasing out industrial allocations, LULUCF sector amendments, and details on the inclusion of the agriculture sector by 2025 (Ministry for the Environment, 2020c). See specific sector analysis below for details.
While the ETS is the main market mechanism for reducing emissions, the New Zealand government has also implemented financial incentives such as the Government Investment in Decarbonising Industry Fund (GIDI). GIDI is a government – business partnership to reduce emissions in industrial processes as part of COVID 19 recovery, with a budget of $69m for three years (EECA, 2021).
The government launched the New Zealand Green Investment Finance Ltd (NZGIF) in 2018 (Scale-Up New Zealand, 2019). The purpose of the institution is to catalyse investment in low-emissions initiatives. Investments so far have been directed towards distributed energy ($10m debt facility), energy efficiency ($3.8m in equity), transport ($5.8m hybrid investment and $15m green credit facility) (NZGIF, 2021).
New Zealand's planning laws were a major impediment in preventing high-emitting projects, such as the newly constructed gas-fired power stations in Taranaki. A 2004 amendment to the Resource Management Act inserted clauses stating that a regional council "when making a rule to control the discharge into air of greenhouse gases...must not have regard to the effects of such a discharge on climate change." The same laws apply to the nation's exclusive economic zone legislation. However, this clause was repealed with the Zero Carbon Amendment, and will come into force at the end of 2021, allowing regional councils - who grant most of the consents for high-emitting projects - to first establish policy statements (Parliamentary Counsel Office, 2020).
Electricity generation is a mix of coal, oil, gas and renewables, where hydro power meets a high proportion of demand (Ministry for the Environment, 2020a). Fossil fuels accounted for just 16% of electricity generation in 2018 (Ministry for the Environment, 2020a). Thermal baseload electricity generation is moving to a mix of wind, geothermal, and gas peaking plants, while a number of baseload electricity generation plants are set to be decommissioned (Ministry for the Environment, 2019). The decommissioning of the Stratford Combined Gas Cycle Turbine (380 MW) is expected in 2023, Whirinaki Diesel Peaker (155 MW) in 2024, and Huntly Coal Power station (400 MW) in 2030/31 (Ministry for the Environment, 2019). New Zealand is part of the Powering Past Coal alliance and committed to no further coal for unabated electricity generation by 2030 (Climate Change Commission, 2021a).
In 2018, renewable sources made up 83.3% of electricity generation, a level that has been high in New Zealand for decades, due to its extensive historical hydro generation, along with more recent wind and geothermal plants (International Energy Agency, 2019). Reliance on hydro power creates vulnerabilities in the electricity system as it is subject to rainfall.
New Zealand experienced a dry year in 2019, where wind power could not compensate for the decrease in hydro power, and gas and coal were ramped up to meet the shortfall (Ministry of Business Innovation & Employment, 2020). In 2020, Genesis Energy imported more than one million tonnes of coal from Indonesia to burn at the Huntly coal-fired power station (Bond, 2021) .
One option being explored by government to deal with the issue is pumped hydro storage at Lake Onslow (Ministry of Business Innovation & Employment, 2021a) which would provide fast response for power system flexibility, intermittency back up allowing for more solar and wind, and dry year storage. Accelerating uptake and diversifying renewable energy along with energy efficiency will be key to decarbonising the sector (Climate Analytics, 2021).
New Zealand has set the target of 90% renewable electricity generation by 2025 and 100% renewable electricity by 2035 (Government of New Zealand, 2016; Ministry of Business Innovation & Employment, 2021b)
The Climate Analytics 1.5C National Pathway Explorer found that a Paris Agreement compatible pathway requires New Zealand to be near 100% renewable power by 2030 and phase out coal in the current decade and natural gas by 2032 to 2035 at the latest (Climate Analytics, 2021). Similarly, the CCC recommends a target of 95% to 98% renewable electricity by 2030 to replace the current target of 100% by 2035 (Climate Change Commission, 2021a). It also recommend that coal be phased out of power generation as soon as possible and that this occur under the principles of a Just Transition (Climate Change Commission, 2021a).
The CCC recommendations to government call for a national energy strategy to establish a coordinated approach to support low emissions technologies, and considering: emissions reductions and removals; system reliability and affordability; future energy developments; infrastructure; equitable industry transitions; regional and national economic development planning; supply chains; and workforce and skill needs (Climate Change Commission, 2021a). The CCC recommends a target of 50% of energy consumption to be renewable energy by 2035 including power, process and building heat and transport (Climate Change Commission, 2021a).
In November 2018, the Government banned new offshore oil and gas exploration (Government of New Zealand, 2018). Onshore, the construction of the 100 MW natural gas fired power plant in Taranaki has now been completed and the plant began operations in May 2020 - to be used as backup for peak periods and provide baseload when wind or hydro generation is low (Keith, 2020).
The government is supportive of developing a hydrogen economy (Persico, 2019). Hydrogen can assist in decarbonisation in a number of ways, particularly with respect to the industry sector and heavy freight transport. However, it is important to distinguish between hydrogen produced from renewable energy and hydrogen produced from fossil fuels. Fossil fuel hydrogen causes a substantial amount of emissions and is thus incompatible with a 1.5°C world. The government released a hydrogen vision paper for consultation in 2019 to inform a hydrogen national strategy (New Zealand Government, 2019d). The vision paper suggests that hydrogen produced from fossil fuels may help in a hydrogen transition, but the government finds there is greater opportunity for green hydrogen for domestic use and export, in line with the net-zero goal (New Zealand Government, 2019d).
Most of New Zealand’s existing small-scale hydrogen generation is from natural gas (The Helen Clark Foundation, 2019). Pouakai NZ has approached the government to support a feasibility study on using natural gas, coupled with carbon sequestration, to produce electricity, hydrogen, and fertiliser (Persico, 2018). Even with sequestration, there would be methane emissions during the production and transportation of the gas as well as remaining CO2 emissions. Advocacy groups have called on the New Zealand government to develop guidelines regarding the source of hydrogen production and to only support green hydrogen production (The Helen Clark Foundation, 2019). Such guidelines would support the government’s 100% renewable electricity targets.
Currently, there are very few policies in place that would support the renewable energy targets. The government plans to develop policies to support a Renewable Energy Strategy work programme (Ministry for the Environment, 2019). The government’s projected decline in energy sector emissions is based on the decommissioning of gas plants and replacement with renewables (Ministry for the Environment, 2019). However, in some regions, power distribution companies are now imposing an extra charge on new solar power users, with the High Court indirectly giving the green light to this “solar tax” by ruling against a request from solar companies for a hearing to contest the charge (High Court of New Zealand, 2017).
The government published its Climate Action Plan that sets a deadline for mid-2020 to develop a policy package as part of a renewable energy strategy, including revising the National Policy Statement for Renewable Energy Generation (NPS-REG) and considering the development of National Environmental Standards on renewable energy (New Zealand Government, 2019c).
The Energy Efficiency and Conservation Authority implements efficiency programmes for large energy users, public sector agencies and small to medium businesses (Ministry for the Environment, 2019).
Industrial processes and product use (mainly iron, steel and aluminium production) are responsible for around 6% of New Zealand’s total emissions excluding LULUCF. The main GHGs directly emitted by industry are CO2 (two thirds of emissions), followed by hydrofluorocarbons (HFCs). Following the ratification of the Kigali Amendment in October 2019, New Zealand will begin phasing down HFCs in 2020 and cut usage by 85% by 2036 (New Zealand Government, 2019b; Parliamentary Counsel Office, 2019).
The CCC calls for the Emissions Reduction Plan to outline a plan to decarbonise the industry sector including supporting innovation to decarbonise hard to abate sectors and a high NZ ETS price signal to accelerate industry players to switch to low emissions fuels and energy efficient measures (Climate Change Commission, 2021a). The CCC also suggests measures to reduce HFCs such as import restrictions, improving industry practice to reduce HFCs leakage and supporting a business and consumer switch to alternative options (Climate Change Commission, 2021a)
The government currently has a target to reduce industrial emissions by at least 1% a year between 2017 and 2022, with a particular focus on process heat. Based on the latest historical industry data, industry emissions increased 1% from 2017 to 2018, and dropped 1% between 2018 and 2019 (Ministry for the Environment, 2021a). According to the Productivity Commission, the achievement of this target would be difficult as emissions-intensive industries have been freely allocated the majority of their NZU requirements to support their international competitiveness and prevent leakage of production and emissions offshore (New Zealand Productivity Commission, 2017, 2018). Amendments to the NZ ETS include phasing out industrial allocation from 2021 to 2030 (Ministry for the Environment, 2020c). However, the gradual phase out will still allow these companies to continue emitting to a degree at the expense of the state, until 2030.
New Zealand will prohibit new coal boilers in manufacturing and production by 31 December 2021 (Woods, Parker, & Shaw, 2021). The government is also considering banning new fossil fuel boilers, if economically viable alternatives exist, and the phase out of existing coal boilers by 2037 (Woods et al., 2021). The CCC recommends ensuring no further coal boilers are installed and phasing out the existing boilers (Climate Change Commission, 2021a).
The Government Investment in Decarbonising Industry Fund (GIDI) is a government – business collaborative effort to lower emissions in the industry sector as part of COVID-19 recovery (EECA, 2021). The fund has $69m for co-investment grants over three years. In round one, 14 companies will receive $22.88m in co-funding which are estimated to abate 3 MtCO2e during the lifespan of the projects (Woods et al., 2021).
Dairy and coal industries lobbied the government during COVID-19 to exempt the coal production industry from lockdown, and coal production for domestic use was allowed to continue as it was deemed necessary for food production (Frykberg, 2020). The dairy industry uses a large portion of coal consumption, accounting for 71% of industrial use, and 25% of total coal consumption in New Zealand, coming in second only to electricity generation (27%) in 2019 (Ministry of Business Innovation & Employment., 2019). Some dairy producers have pledged to reduce coal usage and not build further coal boilers, or use renewables/ biomass in some instances (Frykberg, 2020). The country’s largest dairy company, Fonterra, one of the biggest coal users, has now committed to phasing out coal boilers by 2037, the same date recommended by the Climate Change Commission (Piddock, 2021).
Transport is the second largest source of emissions in New Zealand (Ministry for the Environment, 2021a). Transport emissions are the result of heavy reliance on fossil fuels, poor fuel economy of cars, road freight reliance, low density living, and transport planning based on car use (Ministry of Transport, 2021a). Light vehicles are responsible for the highest share of transport emissions at 67%, and 23% is the result of heavy vehicles (Ministry of Transport, 2021a). New Zealand has the fifth highest CO2 road transport emissions per capita out of the OECD countries (Ministry of Transport, 2021a).
Projections indicate transport emissions dipped in 2020, and will rebound but to below 2019 levels, followed by a slow decline from 2024 onwards assuming increasing EV uptake (Ministry for the Environment, 2021c; Ministry of Transport, 2021a).
Current transport policies include road user charge exemptions for low emissions vehicles, increased investment in walking, cycling, public transport, and rail freight (Ministry of Transport, 2021a). In 2021, the government introduced exhaust emissions standards for new and used vehicles entering the fleet depending on fuel type and vehicle weight (NZTA, 2021).
The Ministry of Transport has a discussion paper seeking consultation for emissions reduction policies in the transport sector (Ministry of Transport, 2021a). The 2021 Budget allocates $302 million to incentivise the uptake of low-emissions vehicles (New Zealand Government, 2021b). New Zealand has introduced a clean car package, including new rebates for EV and plug-in hybrids, EV chargers are available every 75kms on most state highways, a low emissions transport fund to invest in charging networks, plans for an EV leadership group, and proposed Sustainable Biofuels Mandate to transition the switch to EVs (New Zealand Government, 2021c).
New Zealand has committed to a clean car standard with the aim for progressively lower CO2 emissions annually (New Zealand Government, 2021c). The CO2 emissions standard - the very first such standard in the country - applies to imported new and used light vehicles and will commence in 2021. There are funds allocated for the up keep of the rail transport network (New Zealand Government, 2021b). The Government’s ‘electric vehicle first’ policy received $42 million for the leasing of low emissions vehicles across the public sector (Shaw, 2021a).
The government has an EV target for the government vehicle fleet to be emissions free by 2025/26 (New Zealand Government, 2021a). In 2016, the government announced its Electric Vehicles Programme aimed to encourage the uptake of electric vehicles (EVs), with a target of going from around 3,800 EVs in 2017 to 64,000 EVs registered in New Zealand by the end of 2021 (Government of New Zealand, 2016). By April 2021, New Zealand was far from meeting the target with 26,723 EVs registered (Ministry of Transport, 2021b). To reach decarbonisation of the road transportation sector globally, the last combustion engine vehicle must be sold before 2035.
The CCC recommends banning imports and manufacturing of internal combustion engines by 2030 or 2035 latest. It calls for an emissions efficiency standard for light vehicles and for the government to accelerate the uptake of EVs (Climate Change Commission, 2021a). The policies announced to date are far from meeting this recommendation.
New Zealand lacks any strong policy to reduce emissions in the sector. The agriculture sector represents around half of the country’s emissions (excl. LULUCF).
Despite its huge contribution to GHG emissions, the agriculture sector is exempt from the NZ-ETS reforms, and this exemption will likely remain until 2025, with no cap on total emissions, and hence no quantitative constraint on the overall level of emissions by the NZ-ETS (Ministry for the Environment, 2020c). When agriculture is brought into the ETS, there will be 95% free allocation, where the sector can apply for free allocation of emissions units (Ministry for the Environment, 2019). The farmers will be exempt from 95% of emissions charges, i.e., they are required to meet the costs of only 5% of their emissions.
The government, primary industry organisations, with Māori, plan to develop legislated milestones for farm planning, emissions, and reporting, in addition to a farm pricing mechanism (Ministry for the Environment, 2020c). The Climate Change Commission will review the progress in 2022, and if the legislated milestones are deemed insufficient the sector will be brought into the ETS in 2022 (Ministry for the Environment, 2020c).
Policies and action projections indicate agriculture emissions will decline by 2 MtCO2e from 2021 to 2030. The government suggests emissions will decline due to several reasons: a decline in agricultural land use, particularly dairy cow, beef, and sheep populations; the One Billion Trees program and changes to the ETS which support afforestation; changes to farm management practices and the National Policy Statement for Freshwater Management; and reductions in emission intensity of farming due to animal productivity improvements and on-farm efficiency (Ministry for the Environment, 2019). It is not clear why the government indicates agriculture emissions will be impacted by LULUCF policies (e.g., One Billion Trees).
Modelling conducted in the context of the long-term target options, shows the importance of reducing agriculture emissions as a mitigation policy: a report by the Parliamentary Commissioner for the Environment concluded that holding New Zealand’s livestock methane steady at 2016 levels would cause additional warming of 10–20% above current levels by 2050 and that if New Zealand wished to ensure that methane from livestock caused no additional contribution to warming beyond the current level, emissions would need to be reduced by at least 10–22% below 2016 levels by 2050, and 20–27% by 2100 (Parliamentary Commissioner for the Environment, 2018).
Independent submissions, in the context of the long-term target consultations, confirm the need to reduce methane and other non-CO2 emissions in parallel to reducing CO2 emissions to be consistent with achieving the Paris Agreement goals at the national level in New Zealand (Hare, Schleussner, Schaeffer, & Nauels, 2018). An IPCC report confirms this finding and concludes that pathways that limit global warming to 1.5°C with no or limited overshoot involve deep reductions in emissions of methane (35% or more below 2010 levels) by 2050 (IPCC, 2018).
The CCC recommends many policies for the agriculture sector, including: setting a pricing mechanism for agriculture emissions as legislated for 2022; supporting famers to implement changes, including fewer cows on farms; removing barriers for low emissions technology; facilitate market acceptability of proven low emissions food; and investment in, for example, research and development and supporting systems and infrastructure for low emissions technology (Climate Change Commission, 2021a).
New Zealand has relied on forests planted in the 1990s rather than effective climate policy, and the carbon removal benefits of the forests are diminishing (Climate Change Commission, 2021a). The LULUCF sector has historically represented a big carbon sink that offsets, on average, 40% of gross GHG emissions between 1990–2017 (average -29 MtCO2e yearly). New Zealand’s reliance on LULUCF to meet its NDC target has increased 13% to 35% since last year. Emissions reductions from emissions intensive sectors should be a focus, rather than reliance on the uncertain LULUCF sector.
New Zealand’s “Kyoto forests”—largely exotic pine plantations planted in the early 1990s—are due to be harvested in the next few years. The platform Global Forest Watch evaluated a loss in tree cover of 1,290kha from 2001 to 2020, equivalent to a 11% decrease in tree cover since 2000, whereas tree coverage gain over the same period was 710kha (Global Forest Watch, 2021).
Scenarios modelled by the New Zealand Institute for Economic Research require the LULUCF sector to increase the carbon sink to -50 MtCO2e by 2050 in the zero net emissions scenario (New Zealand Institute of Economic Research, 2018). New Zealand’s harvested forestry area would need to increase by 140% from 2018 levels (New Zealand Institute of Economic Research, 2018).
New Zealand has faced criticism over its LULUCF carbon accounting methodology. Plantation forests have a pattern of sinking carbon during tree growth and releasing carbon when harvested. New Zealand’s LULUCF accounting methodology has been criticised by LCANZI which finds that masking real emissions defies the Zero Carbon Amendment Act, which it argues would require a standard land based accounting approach (LCANZI, 2021b).
New Zealand uses a “modified activity-based” accounting method for the NZ ETS and NDC. Rather than recording emissions and removals as they occur, this method averages out the removals and emissions from plantation forests by disregarding emissions that will be outweighed by removals as forests are harvested.
Using this method can be misleading. For example, the proposed emissions budget for New Zealand by the CCC uses the “modified activity-based” method and presents net emission figures for the past three decades as much higher than compared to figures when recording emissions and removals as they occur, although the overall historical net emissions do not change (LCANZI, 2021b). This accounting method has implications for the NZ ETS, the NDC and emissions budgets proposed by the CCC compatibility with the global 1.5°C goal. The modified activity-based method is misleading which impacts the NZ ETS, NDC, and emissions budgets proposed by the CCC. LCANZI argues that the Climate Change Response (Zero Carbon) Amendment Act 2019 requires the CCC to follow UNFCCC accounting practises (LCANZI, 2021b). It is currently taking the CCC to the High Court over its use of this method.
The NZ ETS reforms introduced average accounting, allowing some exemptions for adverse events such as fires, allowing forests to offset deforestation by planting elsewhere, and delaying some forestry changes (Ministry for the Environment, 2020c). The ETS allows foresters the option of using averaging to receive carbon credits for sequestration until they reach average carbon storage over the plantation harvest cycle, which raises questions around the certainty of the accounting methodology introduced, especially when the levels of removals will be central to New Zealand’s strategy in reaching the net-zero target in 2050. The other option available is to receive more credits as the forest grows and pay credits back after the harvest.
The Government has a policy to plant one billion trees by 2030 (Ministry for the Environment, 2019). The Government has so far reported having planted close to 150 Million Trees as of May 2020 since the programme started, with 88% comprised of exotic species (Te Uru Rakau - Forestry New Zealand, 2020). However, the report also identifies the difficulties of providing the appropriate incentives to achieve a sustainable and substantial increase in afforestation activities.
The CCC recommends developing a national programme to encourage reversion and new native forests; policies to reduce reliance of forest sinks and impacts of afforestation; manage pests; flexibility for Māori-collectives; and increase of carbon stocks (Climate Change Commission, 2021a).