MAKE A SUBMISSION
Let Minister Shaw know you reject his demand to slash farming just to be ‘first’.
A copy of our submission to the Government on proposals to price agricultural greenhouse gas emissions. Use this to help make you own submission if you like. Or make your own. Submissions close on the 18th November. It is vital that every farmer and concerned citizen submits. This tax proposal is still at bureaucratic level so there is every chance of making a difference here. If you have not switched over to FARM membership please do so as that is how you will receive notifications. join at www.farmemissions.co.nz https://environment.govt.nz/news/consultaton-on-government-proposals-to-price-agricultural-greenhouse-gas-emissions/
F.A.R.M.’s proposed measures for non-negotiable “BOTTON LINE”.
Copy of the latest statement from Federated Farmers and Industry Bodies. Note that they are listening and have been forced to respond to our rejection of their HWEN proposals. They have let the industry down with the original HWEN proposal and now they have themselves been shafted by the Government they have learned that if you lie down with dogs you get fleas. Good to see them get a bit of spine albeit belatedly.
Submission by F.A.R.M. (Facts About Ruminant Methane).
We are a group of farmers and scientists seeking to understand the role that ruminant methane plays in the atmosphere. We are concerned with the science and the practical implications of imposing taxes on farmers with livestock.
Background to F.A.R.M.’s position:
The Government’s stated formal position on methane is documented in the Carbon Zero Consultation document where it states under Option 2 of the 3 options it put to New Zealanders that if New Zealand’s short-lived gases were stable it means they would not contribute to any further increase in global temperatures
Ruminant methane emissions from New Zealand’s livestock have been falling steadily since peaking in 2005 because of improved management and are expected to fall further as large areas of land formerly used for sheep and beef are being planted in trees.
The only reason given by the Climate Commission for reducing methane emissions in New Zealand is to offset CO2 emissions.
That the 48% of Greenhouse Gas emissions attributed to agriculture is heavily overstated and inequitable given methane’s short life in the atmosphere and the falling level of emissions from New Zealand agriculture.
F.A.R.M. believes the following measures should be agreed:
That no action to implement measures to tax or limit ruminant emissions be taken until our trading partners and competitors in primary production have agreed to similar restrictions or ruminant methane emissions.
That no taxation or limitation be imposed that reduces New Zealand’s food production in accord with the Paris Agreement Article 2 (b).
That no action to tax or limit ruminant methane be taken because of the inability to reduce New Zealand’s CO2 emissions – a proposal from the Climate Change Commission.
That the New Zealand Government call a meeting of those countries who have significant emissions of ruminant methane with a view to only taking action in concert with them and to a comparative degree.
That a comprehensive, independent cost benefit analysis of any tax or limiting for ruminant methane emissions be undertaken prior to such taxes or impositions being applied.
Questions from Ministry of the Environment with FARM answers:
Question 1: Do you think modifications are required to the proposed farm-level levy system to ensure it delivers sufficient reductions in gross emissions from the agriculture sector? Please explain.
YES. The proposals are too complex, too difficult, administratively expensive and impose unnecessary burdens on farmers. There is no data supplied as to the resulting decrease in temperature that will result. The scheme has been designed primarily to put a price on emissions rather than to reduce them.
Question 2: Are tradeable methane quotas an option the Government should consider further in the
YES. A simple ‘Cap and Trade’ system run by farmers, based on the previous 5 years production, independently audited and based on incentives rather than penalties is possible and far superior to what is proposed.
Question 3: Which option do you prefer for pricing agricultural emissions by 2025 and why?
A farm-level levy system including fertiliser?
A farm-level levy system and fertiliser in the New Zealand Emissions Trading Scheme (NZ ETS)
A processor-level NZ ETS?
NONE. All the proposed systems are unnecessary, cumbersome, too expensive to administer and will apply unmanageable pressure on farmers. No cost benefit analysis linked to temperature reduction has been presented.
Question 4: Do you support the proposed approach for reporting of emissions? Why, and what improvements should be considered?
NO. The reporting process is too complex and the imposition on farmers to comply is too great. The variable nature of emissions from farm to farm, animal to animal and year to year rule out any accurate reporting system that is workable.
Question 5: Do you support the proposed approach to setting levy prices? Why, and what improvements should be considered?
NO. Too complex and cumbersome. Unnecessary and administratively expensive.
Question 6: Do you support the proposed approach to revenue recycling? Why, and what improvements should be considered?
YES, in general. Penalties would need to be too onerous to be effective and would be counter-productive leading to increases in production to offset the loss of net revenue. Incentives only, should be deployed.
Question 7: Do you support the proposed approach for incentive payments to encourage additional emissions reductions? Why, and what improvements should be considered?
YES, in general. Incentives should not be restrictive and leave room for new initiatives and technologies. The use of incentive payments should be expanded as they are more likely to lead to meaningful reductions in emissions than a tax. The incentive payments should be funded by CO2 emitters because it is only to offset CIO2 emissions that the Climate Commission wants methane emission reductions. Foresters are paid to offset CO2 emissions and so should farmers.
Question 8: Do you support the proposed approach for recognising carbon sequestration from riparian plantings and management of indigenous vegetation, both in the short and long term? Why, and what improvements should be considered?
No because they do not recognise all on farm sequestration. All past and present sequestration should be acknowledged including riparian planting, erosion-proofing, covenanted areas, and soil sequestration.
Question 9: Do you support the introduction of an interim processor-level levy in 2025 if the farm- level system is not ready? If not, what alternative would you propose to ensure agricultural emissions pricing starts in 2025?
NO. The start date of any new scheme should be pushed out until an effective scheme is available. Adopt a simple ‘Cap and trade’ approach as suggested.
Question 10: Do you think the proposed systems for pricing agricultural emissions is equitable, both within the agriculture sector, and across other sectors, and across New Zealand generally? Why and what changes to the system would be required to make it equitable?
NO. The only given reason for reducing methane emissions is to offset CO2 emissions. Requiring farmers to pay to subsidise CO2 emitters is grossly unfair. Foresters get paid to offset CO2 emissions and so should farmers. The proposed system is unnecessarily burdensome on farming and is counter to the Paris Accord Article 2 (b). The proposed system should remove penalties and only use incentives. What is proposed is totally out of balance with the very minor effects of methane in the atmosphere. Farming should not have to carry any burden on account of the Government’s inability to restrict CO2 emissions as suggested by the Climate Change Commission.
Question 11: In principle, do you think the agricultural sector should pay for any shortfall in its emissions reductions? If so, do you think using levy revenue would be an appropriate mechanism for this?
NO. A ‘Cap in Trade’ system with sensible limits would remove the need for this proposal.
Question 12: What impacts or implications do you foresee as a result of each of the Government’s proposals in the short and long term?
No effect on rising temperatures. An unnecessary, complex and expensive burden placed on farmers adding to the already heavy financial and mental pressure they face. A faster transition from farming of pastoral land to trees, most of which will never be harvested, devastating rural communities, reducing export earnings and creating decades of visual pollution and ruined landscapes.
Question 13: What steps should the Crown be taking to protect relevant iwi and Māori interests, in line with Te Tiriti o Waitangi? How should the Crown support Māori landowners, farmers and growers in a pricing system?
Ruminant methane emissions are ‘colour blind’ and there is no requirement under the Treaty for Māori land owners to be treated differently from non-Māori land owners. Any such separate treatment suggested is divisive and unnecessary. As Treaty partners Māori land owners face the same obligations as all other land owners and so should face the same imposition. The Crown’s obligations to protect its citizens is an obligation on all citizens equally. If Māori farmer’s interests need protecting, so do those of all farmers. It is an abhorrent view that Māori farmers need different treatment because of their race.
Question 14: Do you support the proposed approach for verification, compliance and enforcement? Why, and what improvements should be considered?
No. We support the use of random audits but any farmer involved in an audit should be paid for their time and given professional assistance at no charge to comply.
Question 15: Do you have any other priority issues that you would like to share on the Government’s proposals for addressing agricultural emissions?
YES. New Zealand should not impose any restrictions or taxation until there is absolute proof that other countries with ruminant emissions are taking comparable steps to reduce their ruminant methane emissions.
New Zealand should take the initiative and bring together countries dealing with ruminant emissions to ratify a joint approach.
Making farmers respond is a short timeframe at the busiest time of the year on farms is grossly unfair. The Minister should use his discretion under the legislation to extend the time for discussion and submission into the autumn of next year.
Any farm reporting scheme should operate on a farm season approach rather than a calendar year and be on a 3 year rolling average.
No farmer should have to pay for emissions that are not causing any further warming. Farmers are ready to step up and be part of a scheme that recognises that livestock emissions of methane in New Zealand are effectively at net zero now and not causing further temperature increases, that reducing methane is for the purpose of offsetting CO2 emissions in the same way forestry does and one that is based on a whole farm system approach with recognition for all on farm sequestration.
Robin Grieve – Chairman F.A.R.M.
Owen Jennings – Manager F.A.R.M.
Joint Sector Statement on Ag Emissions Pricing (For your Information)
This week the leaders of DairyNZ, Beef+Lamb NZ, and Federated Farmers met in Christchurch to discuss emissions pricing and to establish common positions between our three organisations so we can move forward together and advocate strongly on behalf of farmers.
A united voice on emissions pricing is the best way to ensure positive policy outcomes for farmers. It was a productive discussion and all three organisations have agreed on the following core principles that we will all be raising directly with the Government on your behalf:
The current methane targets are wrong and need to be reviewed. Any target should be science-based, not political, and look to prevent additional warming.
The methane price should be set at the minimum level needed and be fixed for a five-year period to give farmers certainty.
Any levy revenue must be ringfenced and only be used for the administration of the system, investment in R&D, or go back to farmers as incentives. Administration costs must be minimised.
The future price should be set by the Minister on the advice of an independent oversight board appointed by all He Waka Eke Noa partners.
The system must incentivise farmers to uptake technology and adopt good farming practices that will reduce global emissions.
All sequestration that can be measured and is additive should be counted. We stand by what was proposed by the He Waka Eke Noa partnership on sequestration.
Farmers should be able to form collectives to measure, manage, and report their emissions in an efficient way.
Farmers who don’t have access to mitigations or sequestration should be able to apply for temporary levy relief if the viability of their business is threatened.
We will not accept emissions leakage. The way to prevent that happening is by getting the targets, price, sequestration, incentives, and other settings right.
Our organisations are all united in our determination to get the best possible outcome we can and will continue to work closely together as we advocate for farmers. Individual organisations will continue to raise sector specific issues.