It is important for all farmers to make a submission to Parliament on this bill. It is bad for NZ and particularly bad for farmers. Greenpeace and others will be submitting in their thousands and farmers need to stand up for themselves in numbers. Submissions close on 16 July at 5pm.
To make a submission simply write your name, state you are making a submission to the Climate Change Response (Zero Carbon) Amendment Bill.
State whether you wish to appear before the Committee or not(you can appear by phone )
Give your contact details (these will be published with your submission unless you can ask that they are not).
Make your submission which can be as brief or as detailed as you like.
You can submit on the Bill in general terms as it is a bad piece of legislation that will harm NZ and/or you can focus on the methane aspect. Below are some submission points that deal with methane that you may wish to use.
If you need this emailed to you please email me at robin@farmcarbon.co.nz.
To read the Bill click here. http://www.legislation.govt.nz/bill/government/2019/0136/latest/096be8ed81873608.pdf
For a non PDF version click http://www.legislation.govt.nz/bill/government/2019/0136/latest/whole.html#LMS183736
To make a submission click https://www.parliament.nz/en/pb/sc/make-a-submission/document/52SCEN_SCF_BILL_87861/climate-change-response-zero-carbon-amendment-bill
1/ The split gas approach is a welcome if not belated recognition that methane is different to CO2 and this has not been recognized in the past resulting in methane’ impact being overstated and farmers unfairly victimized.
2/The methane targets are unfair because they require more of methane than CO2.
The Ministry for the Environment in its Zero Carbon Bill consultation document state
Option 2. Reducing long-lived greenhouse gas emissions to zero and stabilising our short-lived gases, which would mean our domestic emissions would not contribute to any further increase in global temperatures.
Methane only needs to stabilize to match the contribution of CO2 when it reaches net zero. Methane when stabilized makes the same contribution to global warming as a closed down coal burning power station.
The intent of this Bill by only requiring CO2 to reduce to net zero is to do no more than stabilize the climate. Therefore stabilizing methane by 2050 is all that is required.
Having identified that carbon emissions sourced from CO2 are different and require a different mitigation to carbon emissions sourced from methane, the conclusion must be drawn that carbon (which stands for carbon dioxide equivalent), is not in fact the equivalence unit it is supposed to be. Its adoption was a mistake and it serves no purpose. Because carbon is supposed to be an equivalence unit, one carbon emission is supposed to be the same as another and it is clearly not which makes it no more than a nonsense. Yet this nonsense unit underpins the ETS, Kyoto, Paris agreement and this Bill, and its flaws project to making these policies and agreements nonsensical too.
This Bill requires the carbon budgets to be expressed in terms of CO2 equivalence (carbon) and as carbon is not an equivalence unit, these budgets will be meaningless.
3/ The targets in the Bill are not scientifically based.
The Bill calls for methane to be reduced by 10% by 2030 and by between 24 to 47% by 2050
The targets are not based on what is needed to stop global warming and are no more than visions of what may be achievable as articulated in some reports. These however require every possible eventuality to go as is predicted they might. This is unlikely. The reports also conclude that while such reduction are possible for some farmers they are not for many. Many farmers will be forced out of farming. Emissions have certainly decreased per unit of output and will continue to do so, which along with possible future technologies, could bring about further reductions which will meet some of the reduction possibilities quoted in the reports this Bill relies on for its methane targets, but none of this factors in the likely requirement to lift production to remain profitable, and more importantly feed a growing domestic and international population.
4/ Limiting agricultural animal product production will increase emissions.
Demand for animal products is going to lift exponentially by 2050 as more and more of the world population can afford it. The more of this demand that can be met by the most emissions efficient farmers in the world (NZ) the better. Limiting our ability to meet that increased demand will see more of the production met by less efficient producers.
5/ Methane emitters are being treated unfairly because the 2030 reduction target is not conditional in the same way any CO2 reduction target is
The 2030 target for methane of a reduction of 10% is not matched by any requirement to reduce CO2 by then. Before any reduction requirements are placed on CO2 emissions certain factors must be considered such as scientific advice, available technology and economic circumstances. However the 2030 methane target is not conditional at all. This is unfair, unreasonable, and unworkable.
6/ So much is not known about methane
There is no consensus among NZ climate scientists as to at what level methane should be stabilized in order to achieve certain peak temperature. It is a well regarded scientific point that reducing methane emissions will make no impact on global peak temperatures. This is canvassed well in the Motu report 2016, Cows, Sheep and Science: A Scientific Perspective on Biological Emissions from Agriculture.
Until some consensus is reached the Climate Commission should not have any methane targets imposed upon it other than to require continuing reductions in emissions intensity. The politicians made the mistake of running ahead of the science and adopting the carbon unit (CO2 equivalent) which overstated the impact of methane emissions, despite scientists telling them it was not possible to equate different greenhouse gases this way. This mistake has been devastating for NZ and it is important politicians learn from this and do not make the mistake of running ahead of the science again.
7/ There is no mechanism available to the Government to bring about a reduction in livestock emissions.
The Government should have a realistic policy tool available to reduce livestock emissions before it sets any 2030 target. Until such a policy tool is identified farmers can not have any understanding of how this Bill will affect them. Having decided that methane emissions can not be offset by forestry removals the ETS is no longer an option for methane.
9/ Putting targets in to a Bill and pinning hope on future technology is poor and pointless legislation
Not even some currently known technologies to reduce emissions are available to farmers Farmers are able to reduce nitrous oxide emissions but food safety concerns have made it not available.
It is most likely that food safety will be of increasing importance to consumers in the future and it is less likely that concerns about global warming will match these and allow mitigation at the expense of real and perceived food safety concerns.
Summarised points
The Bill aims to reduce CO2 emissions to net zero which will mean that from that point on CO2 emissions will be fully offset so they do not cause the atmospheric concentration of CO2 to increase any further, so if that is what is being asked of CO2 emitters, why are CH4 emitters being asked to do more?
Not feasible to measure emissions at farm gate but farmers are doing a pretty good job of reducing emissions per kg of production. Methane has been stable and therefore not causing any global warming since 2006 so farmers methane emissions are where CO2 may get to in 2050 if this Bill succeeds.
Targets are not realistic because they do not take in to account growing world demand for our products and our own growing population that will need feeding. They are more hope than anything. They are also not needed because stable methane emissions are doing the same thing to the atmosphere as a closed down coal burning power station.
Not fair or right to require methane emissions to reduce to allow more CO2. Also not scientific with no consensus among scientists that reducing methane will have any impact on peak temperatures.
Paris agreement requires that climate mitigation must not be a threat to food production so any trade off between emissions reduction whereby one gas offsets the other should favour methane over CO2.
Scientists can’t agree, politicians ran ahead of the science when they adopted the carbon unit which has been catastrophic for NZ, don’t make same mistake.
Without any indication as to how the Government plans to achieve this impossible to understand implications.
What you want the Committee to do.
Remove methane requirements and bring in to subsequent legislation once scientists reach some agreement. One thing that they do agree on is that reducing methane emissions should not be considered to offset CO2 emissions.