These are the consultation questions the Climate Commission is asking you to comment on.
FARM is only submitting on questions that are relevant to our purpose of advocating for the truth about livestock emissions of methane.
If you want more information about each question there is a summary of points available on each question in the consultation document here https://ccc-production-media.s3.ap-southeast-2.amazonaws.com/public/evidence/advice-report-DRAFT-1ST-FEB/ADVICE/CCC-ADVICE-TO-GOVT-31-JAN-2021-word.docx
Ahead of each question is an explainer and a summary of points, so it is easy to get to grips with what they are proposing as it relates to each question. Or you can read the report in detail in order to work out what you want to say.
We have put a response that we will base our submission on for your guidance.
To submit you can do it by posting a letter, filling in your response to questions on line, or downloading a saved document such as this one. Details of how to do this are here. https://www.climatecommission.govt.nz/get-involved/consultation/
You can also just write your own submission in any format you like and submit it as a saved document as above. We do recommend that if you do that, then as well as that you respond to some of the questions as well, as they will be collating those to gauge support for their proposal and publishing how many submitters supported or opposed their position on each question. We need as many submitters as possible to oppose the many bad things the Commission is proposing.
MOst of my activities now are with FARM (Facts About Ruminant Methane ) If you want to join FARM you can do so on www.farmemissions.co.nz
These are the questions, with our suggested responses for you to work off.
| Consultation question 1
Principles to guide our advice |
| Do you support the principles we have used to guide our analysis? Is there anything we should change, and why? |
Principle 1: The Commission should be more independent and not simply align with legislated targets. By doing so it serves little purpose.
Principle 5 The Commission should not be concerned with existing inequities, as these exist due to political influence over society. The Commission has no mandate to provide advice on this. The Commission should limit itself to ensure that its advice does not create inequity nor inflict harm on New Zealanders.
Principle 6 No official climate records record any increase in drought, flooding, forest fires and storms and in fact they record a decrease, so the Commission should not be focused on increasing climate resilience because it appears that a warmer world is more benign in terms of climate. Climate related deaths worldwide have declined by 99% over the last 100 years which indicates the climate is more benign and human resilience has increased with progress in any case, and will continue to do so. If global temperatures are kept below 2 degrees there is not expected to be any catastrophic global warming so it seems pointless to try and reduce emissions and increase resilience. Only one of those actions is needed.
Principle 7 should include the wider benefits but with all perceived wider costs analyzed against them so a trade off can be decided.
| Consultation question 2
Emissions budget levels |
| Do you support budget recommendation 1? Is there anything we should change, and why? |
The second and third budgets should be increased substantially. The decrease in available carbon is far too rapid and will cause immense personal hardship to New Zealand families. The impact of Covid 19 must be recognized too and it must be acknowledged that New Zealand families are not as financially resilient as they were to withstand the costs of these carbon budgets.
| Consultation question 3
Break down of emissions budget |
| Do you support our proposed break down of emissions budgets between gross long-lived gases, biogenic methane and carbon removals from forestry? Is there anything we should change, and why? |
No. The reduction in methane emissions is not justified in any way.
Methane emissions from livestock in particular when stable, as they are in New Zealand, do not cause any increase in atmospheric methane. It is only activities that cause an increase in atmospheric greenhouse gas that can be blamed for causing further temperature increases.
| Consultation question 4
Limit on offshore mitigation for emissions budgets |
| Do you support budget recommendation 4? Is there anything we should change, and why? |
FARM is not submitting on this.
| Consultation question 5
Cross-party support for emissions budget |
| Do you support enabling recommendation 1? Is there anything we should change, and why? |
Yes, there should be no methane reduction targets set without cross party support especially.
| Consultation question 6
Coordinate efforts to address climate change across Government |
| Do you support enabling recommendation 2? Is there anything we should change, and why? |
FARM is not submitting on this.
| Consultation question 7
Genuine, active and enduring partnership with iwi/Māori |
| Do you support enabling recommendation 3? Is there anything we should change, and why? |
FARM is not submitting on this.
| Consultation question 8
Central and local government working in partnership |
| Do you support enabling recommendation 4? Is there anything we should change, and why? |
FARM is not submitting on this
| Consultation question 9
Establish processes for incorporating the views of all New Zealanders |
| Do you support enabling recommendation 5? Is there anything we should change, and why? |
FARM supports this.
| Consultation questions 10 & 11
Locking in net zero |
| Do you support our approach to focus on decarbonising sources of long-lived gas emissions where possible? Is there anything we should change?
Do you support our approach to focus on growing new native forests to create a long-lived source of carbon removals? Is there anything we should change, and why? |
FARM will be submitting that offsetting emissions with forestry could lead to productive food producing land being converted to forestry and this will have consequences and is in possible contravention of article 2 of the Paris Agreement, to reduce emissions in a way that does not threaten food production.
| Consultation questions 12
Our path to meeting the budgets |
| Do you support the overall path that we have proposed to meet the first three budgets? Is there anything we should change, and why? |
FARM will submit that there should be no policy that encourages land use change from livestock agriculture in to exotic forestry.
| Consultation questions 13
An equitable, inclusive and well-planned climate transition |
| Do you support the package of recommendations and actions we have proposed to increase the likelihood of an equitable, inclusive and well-planned climate transition? Is there anything we should change, and why? |
FARM will not be submitting on this.
| Consultation question 14
Transport |
| Do you support the package of recommendations and actions for the transport sector? Is there anything we should change, and why? |
FARM will not be submitting on this
| Consultation question 15
Heat, industry and power sectors |
| Do you support the package of recommendations and actions for the heat, industry and power sectors? Is there anything we should change, and why? |
FARM will not be submitting on this
| Consultation question 16
Agriculture |
| Do you support the package of recommendations and actions for the agriculture sector? Is there anything we should change, and why? |
There should be no pricing of agricultural livestock emissions. The Commission states that the methane reductions of the scale it proposes are only necessary to offset CO2 emissions which cannot be reduced quickly enough. In other words it proposes farmers reduce methane emissions to subsidize CO2 emitters.
If there is a legitimate scientific case to offset CO2 emissions with methane reductions, and this is questionable, then farmers should be paid to reduce emissions, not fined with taxes for not doing so. It is deeply concerning that the Commission advocates penalizing farmers if they do not reduce methane emissions so that CO2 emitters can continue to emit at a rate that is too high.
| Consultation question 17
Forestry |
| Do you support the package of recommendations and actions for the forestry sector? Is there anything we should change, and why? |
FARM will be submitting that the benefits of planting exotic forestry are overstated as soil carbon losses, albedo changes and forestry emissions of methane absorbing gases which cause increases in atmospheric methane, are not taken in to account adequately.
| Consultation question 18
Waste |
| Do you support the package of recommendations and actions for the waste sector? Is there anything we should change, and why? |
FARM will not be submitting on this.
| Consultation question 19
Multisector strategy |
| Do you support the package of recommendations and actions to create a multisector strategy? Is there anything we should change, and why? |
FARM will not be submitting on this.
| Consultation question 20
Rules for measuring progress |
| Do you agree with Budget recommendation 5? Is there anything we should change, any why? |
FARM supports point five
To Encourage the Government to develop methods for tracking emissions and removals by sources and sinks not yet included in the country’s domestic or international target accounting, such as organic soils and biomass (including small lots of trees and regenerating vegetation), with a view to allowing them to be included in future target accounting.
| Consultation question 21
Nationally Determined Contribution (NDC) |
| Do you support our assessment of the country’s NDC?
Do you support our NDC recommendation? |
FARM will submit that the NDC should be reduced to take in to account the fact that our emissions profile with such a large component of methane, overstates our global impact on temperatures. Now that this has finally been recognised by the Government it should revisit all targets set under the misperception that our impact on global temperatures was higher.
| Consultation question 22
Form of the NDC |
| Do you support our recommendations on the form of the NDC? |
FARM does not support the Commission’s recommendation. There should be no use of CO2 equivalents based on GWP100. The science is clear that short lived gases cannot be equated to long lived gases. It is not scientifically possible to equate a gas which accumulates in the atmosphere with one that does not. There is no justification for the use of this discredited system and there is no defense for it still being used now that the science has been acknowledged. The adoption of the CO2 equivalent system was a mistake that has had huge ramifications for farmers and for New Zealand. All reference and use of it in Government policy, domestic and international targets and agreements must be expunged. Farmers should not have to suffer because of the incompetence of those who made the mistake and adopted this system.
| Consultation question 23
Reporting on and meeting the NDC |
| Do you support our recommendations on reporting on and meeting the NDC? Is there anything we should change, and why? |
FARM will not be submitting on this.
| Consultation question 24
Biogenic methane |
| Do you support our assessment of the possible required reductions in biogenic methane emissions? |
FARM does not support this assessment because the methane reduction requirements are not based on science and what the Commission overlooks is that for improving farm practices and efficiencies to do more than reduce emission intensity (emissions per kg product), as they have to date, and also reduce absolute emissions, this will require a limit or cap on farm production, otherwise the efficiency gains farmers make will just go in to more production and absolute emissions will not reduce. Farm efficiency gains so far have been significant and will continue, but farmers will not be able to convert those gains in to increased output, as they have been doing up until now and will have to be as profitable in thirty years’ time off the same production they do now. This is not feasible.