Please make a submission to the Climate Commission. To help you
Here is an analysis of the Climate Commission draft report that I did for FARM (Facts About Ruminant Methane)
Points to note in regard to agricultural livestock emissions ruminant methane and nitrous oxide.
The Climate Commission draft report is a missed opportunity to properly redress the numerous and significant mistakes that governments over many years have made about the impact of ruminant methane emissions. FARM recommends the Commission rewrites its report in respect of methane emissions and take a more thorough look at the issue from a first principles approach.
The report makes a positive change from previous reports by taking a split gas approach with methane targets stated in Mt of methane rather than CO2 equivalents, but FARM feels that many of the mistakes that were created by the adoption of the CO2 equivalent system using GWP100 to quantity methane emissions are still prevalent in this report.
The Commission does acknowledge that when methane emissions are stable, as they are now in New Zealand, they do not cause an increase in atmospheric greenhouse effect and the warming that results from it.
The Commission admits 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 acknowledges that methane emissions when stable are not causing further warming but it proposes farmers reduce methane emissions to subsidize CO2 emitters and it proposes that farmers be penalized with a tax if they do not.
What does the Commission propose?
The Commission proposes cuts to biogenic methane of 13.2% by 2030 and 15.9% by 2035. The 2030 target is more than it is mandated to require in the Carbon zero Act of a 10% reduction by 2030.
The 2050 methane target it works to is the Government legislated target of -24 to -47%. The same legislated target for nitrous oxide emission reduction target is 100% by 2050.
The Commission recommends making farmers pay for livestock emissions as the method the Government uses to incentivize these emission reductions.
The Commission believes that animal methane emission reductions of 24% by 2050 are possible without new technology by farmers becoming better farmers than they are now. It believes farmers can achieve more efficiency by reducing stocking rates and inputs for the same level of production they get now.
However 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.
Emission reduction greater than 24% by 2050 will require technology that has not been invented yet and or a significant reduction in the size of the pastoral farming industry.
Why does it propose these targets?
The Commission does not base its recommendations on the science of methane emissions and simply bases its recommendations on the targets set by the Government in the Carbon Zero legislation to reduce methane emissions by at least 10% by 2030 and between 24 and 47% by 2050.
Where do these targets come from originally and how valid are they?
The 10% reduction requirement by 2030 is not based on a scientific need to reduce these emissions but on a report by the Biological Emission Reference Group (BERG) that said that some farmers could reduce emissions by that much with present technology and knowledge. BERG has done farmers a disservice because now farmers are being hit with the stick BERG made.
The Government and the Commission base their 2050 target of -24 to -47 % on figures produced in IPCC pathways that show what combination of emission reductions are consistent with a temperature increase of 1.5 degrees C.
The pathways should not be used to determine a target for methane in the way the Government and the Commission do as according to the IPCC they ‘do not indicate requirements’. They are not based on atmospheric science but on a number of things including tradeoffs that are possible between emissions. ie methane and CO2. They do not indicate that methane emissions need to reduce by that much because the science tells them they are causing global warming, but because they need to be reduced to that level because CO2 emissions cannot be reduced enough quickly enough.
The other main problem is that the Commission and the Government have adopted the IPCC pathway figure as their target for methane for 2050, but have ignored the same IPCC pathway figure for nitrous oxide which is +1 to -26 % and adopted instead a target of -100%. There is no justification for this discrepancy and the Commission needs to explain this inconsistency.
The Commission’s reliance on these IPCC pathways is a reflection of its own lack of knowledge of the science of methane emissions.
What farmers should submit on.
- Farmers should submit that the methane and nitrous oxide emission reduction targets set by the Commission and the Government are unjustified, unscientific and unrealistic and that the report should be rewritten to reflect the science.
- The accepted science is clear that methane emissions that are stable are not causing an increase atmospheric methane. The Commission’s recommendations should reflect this scientific fact.
- The Commission should base its emission reduction targets for methane on science, not IPCC pathways that are not based on atmospheric science and the IPCC states should not be used to determine national requirements. If the science is not robust enough to justify emission reductions there should be no recommended reductions.
- Reducing methane emissions to allow for more CO2 emissions is unfair on farmers.
- That penalizing farmers financially to force them to reduce methane emissions in order to allow more CO2 emissions, as the Commission admits it is proposing, is unfair to farmers. It leads to the unjust vilification of meat and dairy products and product resistance.
- If the Commission wants farmers to reduce methane emissions to subsidise CO2 emitters as it acknowledges it is proposing, it should recommend that farmers are paid to reduce emissions.
- All New Zealand climate policy and domestic and international targets and agreements should be based on a split gas approach with methane separated from long lived gases. The CO2 equivalent system using GWP100 has no scientific integrity and should not be used in any form. The Commission should recommend that the Government supports the removal of the use of the CO2 equivalent system from all legislation, and advocate for its removal from all international agreements. To use a system that attempts to equate a long lived gas with a short lived gas is nonsensical and leads to perverse decisions and outcomes.
- It is great that the report is written using the split gas approach but the point of the split gas approach is to prevent the mistaken assumption being made, that is inherent in the CO2 equivalent system calculated using GWP 100, that all methane emissions are causing an increase in atmospheric methane and thus contributing to further global warming and therefore need to be reduced or offset. There is no advantage in using the split gas approach unless it is recognized that in a New Zealand context most ruminant methane emissions are not causing any increase in atmospheric methane. The Commission needs to ensure its report reflects that scientific reality.
The Climate Commission report in regards to methane is inadequate. It takes us no closer to settling on enduring science based policies and it perpetuates mistakes originating from the disastrous adoption of the CO2 equivalent system calculated using GWP 100. The Commission needs to rewrite the report to ensure these mistakes are removed. FARM also urges the Commission to see the unfairness of its recommendation to make farmers pay if they do not reduce emissions that the Commission states are only required to offset CO2 emissions. FARM also urges the Commission to make clear that its methane reduction targets are not needed to address methane’s impact on global warming, which in most cases is zero, but the inability of CO2 emitters to reduce their emissions.
Submissions can be made at
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