Our good friends at Climate Realists have sent out this link to the MAF consultation process
ALL FARMERS SHOULD MAKE A SUBMISSION
Submissions close June 9
The consultation process is to address how agricultural emissions are going to be calculated.
Apart from the obvious that livestock emissions are climate neutral and should not be calculated in the first place the problem is that as an industry farmers need to have a say in how emissions are calculated even though we do not agree that they should be calculated at all.
This is because they are designing the rules of the game and if farmers do not submit what they want, the rules will be written without them.
Some of the issues they are asking for submissions on are as follows.
What animals should be included or excluded? The proposal is to exempt horses, llamas, alpacas, ostrich, emus and ruminants other than cattle, sheep, goats, & deer. (bison are an example of an exempted ruminant)
I don’t see why horses and bison and all the rest should be exempt. They just want to make a simple system where farmers pay for milk processed and meat processed. It is hard for them to collect the money off horse owners they say. We should not allow them to make it easy. If they want to persist with this nonsense let’s make it as complicated as it needs to be to be fair. Horses fart methane so why should they get off just because the Govt want to make it simple. Horse owners could pay a fee each year like dog owners do. The horse racing industry is big bucks, gets a lot of Government money thanks to Winston so let them pay.
The process of deciding which animals to includ needs to be fair. It is more important that it is fair than it is easy, and that is why all animals should be included no matter how difficult it is. In that vane I submit that all ruminants and hind gut animals like horses should be included if they are responsible for an increase in the concentration of greenhouse gas in the atmosphere. Ruminants and horses that do not do this should be exempted. That is ruminants on farms which have not increased production since the previous year. The ruminants on those properties that have increased production should still be exempted unless they are the ones responsible for that increase. This leaves the ruminants that are not exempted being livestock on farms that were responsible for an increase in livestock production.
This would be terribly complicated and problematic but it is immoral to do anything else. Livestock emissions from farms that have not increased production do not increase the concentration of CH4 in the atmosphere. This is because they remove as much CH4 from the atmosphere as they produce. To calculate their emissions as if they are increasing the concentration of methane in the atmosphere when they are not has no basis in science, economics, law, or natural justice. These ruminants should therefore be exempt.
Dairy. The proposed methodology is that a cow will be responsible for emissions that produce milk over its lifetime, and at its slaughter the emissions associated with live weight gain for the first two years of its life to maturity will be accounted for and it will also be responsible for the maintenance, gestation and lactation milk produced by its mother in the year it was born.
This is designed to prevent double calculating. Eg in reality a cow emits each year for maintenance, calf growth and milk production. Each year the milk emissions will be clipped at the dairy factory, maintenance and gestation requirements of that cow will go to its calf which will be accounted for at that calves slaughter either as a mature cow itself or a mature beef animal or as a bobby calf.
The bobby calf issue has problems and they are calling for submissions on options to calculate the emissions of a bobby calf. The two options are
Option 1 account for emissions at the bobby’s slaughter.
The problem with this is that this could make the calf valueless as there could be $70-$100 worth of CO2 emissions at $25 per tonne. (all the emissions created by the maintenance and gestation requirements of its mother for that year.) This could lead to a lot of blunt trauma injuries to bobby calves & the Govt don’t want that because they will miss out on the money.
Option 2 account for these emissions in the milk production component instead.
The problem with this is that the farmer whose calves are reared will be disadvantaged compared to a farmer who bobbies most of their calves. This is because the calves that are reared attract a CO2 charge and this will reflect in the price rearers want to pay. The farmer will effectively pay for these emissions in reduced values as well as having to pay the emissions for the bobby calves of other farmers in their milk levies. .
Wool. The proposal is to forget wool and put all emissions to the meat. This would make it easier for them as they would not have to collect money off the wool sellers. Five percent of a sheep’s emissions are produced for wool growth. The problem they are grappling with is that Merino sheep are bred for wool. (about 5 % of sheep are Merino) The wethers are kept for years and so will not pay their fair share (good on them I say). A mature female sheep or cow is deemed to produce offspring each year and its maintenance emissions for that year are put against that offspring. Wethers will be walking around producing wool for the country but not lambs and so their maintenance emissions will not be able to be accounted for. If they put the maintenance emissions against a mature merino wether at slaughter for every year it has lived it might be more economical to shoot it at home. I don’t know how old merino wethers are kept to calculate that. Sheep farmers might want to have a say on this.
Producers or importers of nitrogen fertiliser have to pay for the nitrogen content of the fertiliser.
I submit that these emissions should not also be accounted for in animal production. At present a kg of milk solid or meat has assumed against it a component for N2O emissions. This N2O is sourced from mostly natural sources and artificial sources. The emission factor for milk and meat production must not include nitrogen that is sourced artificially. To do so is to double dip.
It is proposed that milk emissions are calculated with an emission factor of 8.2.
That means 8.2 tonnes of CO2e per tonne milk solid I don’t know how this is calculated but it needs to be investigated.
There are two emission factors , per animal and per kg
For a steer the emission factor per animal is 1.48 tonnes CO2e per animal and 10.8 tonnes CO2e per tonne of carcass weight. This is to try and reflect the efficiency of producing more carcass weight per animal
A 250 kg steer would attract emissions thus.
1.48 tonnes CO2e
Plus 10.8 tonnes CO2e per tonne of carcass =2.7 tonnes CO2e plus1.48 tonnes = a total of 4.18 tonnes CO2e
A 300 kg steer would be 4.72 tonnes CO2e
1.48 tonnes plus 3.24 tonnes (10.8 x 300)
The heavier steer has a lower emission per kg than a lighter one. 15.7 kgs versus 16.72
This part seems fair seems fair however Neil Henderson points out this using lambs as an example;
No account is made for growth rate. Two farmers may kill their lambs at the same weight but one farmer achieves this in 120 days, the other takes 150. Both will pay the same ETS charge, but the second farmer’s lambs will have been producing emissions from the maintenance component of its rations for an extra 30 days.
Also he says in regard to lambing percentage
Not allowing for lambing percent is going to have a very significant negative impact on those with a high lambing percent. Someone producing 150% of lambs, at the same weight as a farmer producing only 100% will pay an extra fifty per cent costs but that is way more than the extra feed consumed by his ewes.
The point of the scheme as far as the Govt is concerned is to try and fleece farmers as easily as they can. It is all worked on averages and while there is some recognition of efficiency there are problems.
Click the link and the submission form is at the back. It is a big document but it is relatively straight forward. It asks questions eg which option for bobby calves.
I suggest you submit on livestock exemptions. (you can cut and paste mine if you like) And then scroll through it and express an opinion where you have an interest, eg Merino sheep, nitrogen fertiliser.
I know only idiots and fools believe livestock emissions alter the composition of the atmosphere and part of me says we should not dignify this MAF consultation process. But if we don’t we can’t complain when they decide how to calculate these emissions. Most of what they propose makes sense (apart from the premise that livestock emission should be calculated) but there are problems
Exemptions for horse’s bison,
Have a go, make your point now or for ever hold your peace (about how they are calculated anyway, if you don’t make a submisiosn you can still complain about the injustice of the tax just not how it is calculated)