What Evidence is Required for ETS Applications? (2022)

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Te Uru Rākau - The New Zealand Forest Service can require significant evidence for ETS applications. Applications for land into the NZ ETS are never guaranteed as it is at the discretion of MPI to approve. 

The basics of the evidence required for an ETS application centres around meeting the Eligibility Requirements for Land in the ETS.  Different application types require different levels of evidence to prove the status of the land. The best approach is to provide MPI with as much evidence as possible to confirm your forest's eligibility in line with the ETS Evidence Guidelines.

 Key evidence for ETS applications relates to two areas that we breakdown in this article:

  1. Evidence that proves the land was not forested on 1 January 1990.
  2. Evidence that proves the location and age of trees at establishment / emergence.

Land Status at 1 January 1990 (Carbon Credit Cut-off)

Firstly, to be eligible for carbon credits, applicants must prove that the land was not forested on 1 January 1990 (Post 1989 forest land).

Historic aerial imagery is the best resource available to prove land status at this time.

There are publicly available Aerial Imagery Resources, which are the same resources available to MPI. Retrolens has the largest public database of historic imagery, with councils often having imagery of their own.

Historical photos in some areas may not be available for the exact date required as the coverage and timing of photos varies greatly across New Zealand. Most historic imagery is in black and white, and taken at high altitudes so is often blurry. Usually, they have no scale or direction and can be at partially oblique angles, this makes locating and mapping areas challenging. 

Private landowners often have historic aerial imagery of their own that is not available to MPI. When submitting these along with the application to ensure they are date stamped if possible, this can help prove the land's ETS eligibility on 1 January 1990.

Clearance of scattered areas of native forest for farmland was common practice during the 1980s and ’90s. Landowners must be aware of this as it is a common cause of parts of ETS applications being declined.

Land Status at Establishment / Emergence

Planted native forest and natural regeneration may not be visible from satellite imagery for the first 5 years, therefore more precise evidence is required for ETS applications to be accepted in this timeframe. It is not required that forests be registered within the first 5 years, but carbon credits can only be claimed back to the last Mandatory Emissions Return Period (MERP). The current MERP started in 2018 and ends on 31 December 2022.

Evidence that proves the location and age of trees can be in many forms. Visual evidence is the most effective way, but non-visual documentation also helps to confirm planted forests or regeneration.

Visual evidence can include photos and videos from hand-held cameras or drones. Ensure photos and videos are clear, of a high resolution, and cover the entire application area. Ensure photos and videos are date-stamped and that GPS tags are enabled. Drone videos must include a download of the flight path to prove the coverage of an area. 

It may not be possible to get good evidence for every tree, especially in young trees, so ensure good even coverage that shows the boundaries of the forest and proves there are no significant gaps.

Non-Visual evidence for planted native forests can include documentation such as; GPS Boundary walk data, seedling orders for species and tree numbers, and planting invoices.


How ETS Evidence is assessed

Each piece of supporting evidence provided to MPI is assessed alongside all other available information. The goal is to build a picture of land-use change over time and prove the date of establishment or emergence, as well as the species and density of the forest.

Firstly the trick is to look at historic imagery on both sides of 1990 and see if any land is ineligible because it appears to be in forest on 1 January 1990. MPI is unlikely to give the ‘benefit of the doubt’ on marginal or unclear applications and it is the landowners' responsibility to prove its ETS eligibility.

By providing visual and non-visual evidence, MPI can see the density and location of the trees as well as identify the species, date of establishment, and the boundaries of the forest.

MPI no longer offers a preliminary assessment of land eligibility for the ETS. Applications cannot be accepted until after establishment. For these reasons, significant due diligence must be carried out before an establishment project begins, otherwise, the forest may never have the potential to earn carbon credits.


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