Submissions on the government’s proposals to impose a tax on farm emissions close today.
You can submit here .
This is my submission:
- We oppose the government’s proposals for pricing agricultural emissions
1.3. The Paris Accord agrees: ”to decrease global warming through: . . . Increasing the ability to adapt to the adverse impacts of climate change and foster climate resilience and low greenhouse gas emissions development, in a manner that does not threaten food production.”
1.4 Until there are affordable, practical and safe ways to reduce emissions any costs imposed on farmers will reduce food production and lead to job losses on farms, in businesses that service and support farmers and process their produce; and in the wider communities.
1.5 New Zealand has a well-deserved reputation for producing nutritious and safe food, efficiently with high standards of animal welfare. We have strict requirements about the use of chemicals and drugs. Any tools that reduce emissions must not have any adverse impact on stock, meat quality and nutrient value and human health.
1.6 We oppose the use of the ETS to encourage on-farm emissions reductions. Unless, and until, there are safe measures to reduce emissions it would simply be a tax on production.
1.7 We do not support the pricing of emissions until there are safe measures to reduce them. However, if one is imposed, a farm level system would be less bad than the proposed interim processor level system as a backstop.
1.8 If the government persists in imposing costs, any approach to reducing emissions must maintain the viability of New Zealand’s farming sector and rural communities.
1.9 It must not encourage practices that would lead to poor economic, environmental and social outcomes, for example large scale job losses on farms and rural communities or replacing pastoral farms with pine plantations.
1.10 It must recognise the good work that many farmers and rural communities have already done to mitigate climate change through establishing vegetation and that is fair across all sectors and New Zealand industries and communities.
1.11 The Governments proposal does not do this.
2 He Waka Eke Noa (HWEN) did not have universal support but the government has succeeded in uniting farmers against its proposals.
2.1 The He Wake Eke Noa approach aimed to create a mitigation package that included recognition of technologies used and progress already made, the adoption of mitigating technologies only when they had been proved safe and were readily available, recognition of the agri sector’s contribution to the economy, care for rural communities, recognition of progress against goals and recognition of our competitive position in markets.
2.2 The government’s proposal is primarily focussed on emissions pricing to achieve arbitrary targets that have no relation to what is possible, practical and proven.
2.3 The proposal is overly simplistic, would destroy rural communities and come at a huge economic cost. Taking out 20% of sheep and beef farms would cripple small rural towns and take multi millions of dollars from export earnings.
2.4 Primary industries in general and pastoral industries in particular are fundamental to New Zealand’s economic wellbeing.
2.5 They comprise more than 80 percent of New Zealand’s physical export earning and make up about 50 percent of these total export earnings. There is no other way to pay for all the imports the country needs.
2.6 New Zealand has international commitments to reduce its greenhouse-gas emissions. That does not mean that New Zealand has to be the first country to destroy its most important export-earning industries.
2.7 No other country in the world is considering going down a self-destruction path for mainstream industries that underpin that nation’s fundamental economic well-being. It is not happening and it is not going to happen elsewhere in the world.
2.8 Sabotaging farming, which the government’s proposal would do, would at best have a minimal environmental impact, at worst it will increase global emissions through carbon leakage and degrade New Zealand soil and waterways when pine plantations replace pastoral farms.
3 The government’s proposed emissions accounting system will add unaffordable costs to the dairy sector and have an even worse impact on the deer, sheep and beef sectors.
3.1 The assumption that tools and technologies will be available to assist with reducing or mitigating emissions is putting the green cart well in front of the scientific horses.
3.2 There are no options available now and there is a risk that some proposed tools would impact the quality of meat and milk, and possibly human health.
3.4 Professor Keith Woodford points out:
. . . The problem is that nature’s ruminant nutritional system was designed for a purpose over millions of years by trial and error. That is how evolution works. And nature does not necessarily take kindly when humans want to interfere with the basics of that ruminant system. Change part of the system and there is always a good chance that the overall system will fall apart.
One way or another, the excess hydrogen has to be removed from the rumen. Otherwise, the rumen will turn from a fermentation vat to an acid vat. The animal will not be impressed and will get very sick.
Accordingly, it is not just a case of killing the methanogens. Something else has to take over the job that the methanogens do naturally. If there was an easy solution that was energetically better than producing methane, then nature would in all likelihood have figured that out itself.
So, what are the technologies that humans have been exploring?
One of the most fascinating technologies is to feed some bromoform-releasing seaweed to ruminants. These trials have been going on both in New Zealand and overseas. The bromoforms are particularly good at killing off the methanogens, but unfortunately, they tend to also mess up other parts of the rumen system. Particularly important is the finding in a recent scientific paper that bromoforms pass from the rumen into milk.
Alas, bromoforms are a suspected carcinogen and certainly have the ability to interfere with many human processes. My own assessment is that, despite some ongoing hype, there is close to zero chance of this technology being acceptable to food-safety authorities. Indeed bromoforms, which are similar in their action to chloroform, are already widely banned in foodstuffs.
The second feed additive that has generated considerable hype is a chemical called 3-NOP. This has been developed through to early-stage commerciality by Dutch firm DSM with the trade name Bovaer.
This technology appears to be much safer than bromoforms and does reduce methane production in feedlot situations for dairy and beef cattle. However, the evidence to date is that it does not work under pastoral conditions because it needs to be evenly distributed throughout the feed. . . .
3.5 There is not yet anything that can safely reduce methane emissions in stock and there are very real questions about food safety with what is being trialled.
3.6 We must not risk our hard-earned reputation for safe food in an attempt to reduce emissions.
4 Relying on forestry to make the ETS work is a temporary band-aid. It does not address the carbon problem and it is creating an artificial market that incentivises planting trees on good pastoral land.
4.1 This increases the risk of fires, provides shelter for pests which threaten native species and carry diseases which could infect farm animals; takes up large amounts of water which compromises waterways and water life and would be hard to reverse.
4.2 It also takes jobs from farms and the local community and reduces export income.
4.3 The government’s approach to emissions accounting is inequitable by proposing to levy farmers for methane emissions but not give any credit for the sequestration from on-farm vegetation.
4.4 Unless farms are able to offset emission through sequestration, some will become unviable and the damaging conversion from farmland to forestry will be exacerbated.
4.5 A broader range of sequestration is critical to achieving a balance in the system that will make it work for both extensive and intensive farmers. If the government insists on levying farmers it must adopt the HWEN recommendations and recognise a broad range of vegetation categories.
4.6 The government’s excuses exluding on-farm sequestration on the basis of the complexity of measuring sequestration. That is wrong.
4.7 Hyperspectral photography using LIDAR technology is available to measure both biomass and species composition of vegetation over a large scale. This technology could be adapted to measure vegetation to account for sequestration.
4.8 If the government insists on levying farmers for emissions based on hypothetical models it must accept sequestration credits based on accepted and standardised measurement.
5 We oppose the Government’s proposal for taxing emissions altogether and its proposal for price setting through the Climate Change Commission.
5.1 If the government does impose costs on emissions, the agricultural sector must be represented on any body that sets prices to ensure it is fair and manageable.
5.2 The CCC’s brief to reduce GHG emissions is a conflict of interest with price setting that could risk it using agriculture to cross-subsidise a wider reduction in warming
5.3 Criteria that must be taken into account when setting the price must include equity, economic impacts and what other countries, in particular those with which we compete in exports.
5.4 Agriculture’s contribution to reducing emission must not be the expense of any of our major exporting sectors and rural communities.
6 We oppose linking the price of nitrous oxide to the carbon price.
6.1 Linking nitrous oxide and CO2 reduction targets doesn’t make sense if there are different targets for them.
6.2 If the nitrous oxide price is linked to the carbon price and the carbon price rises rapidly this will become a significant cost to farms and their profitability.
7 We have grave concerns about the impacts the government’s proposal will have on on production, income and costs on farms, rural communities and the wider economy.
7.2 During the ag-sag of the 1980s it was feared farmers would be driven from their farms in their thousands. Some did lose their land but the worst impacts were further downstream in the businesses which serviced and supplied them, schools, and provincial towns. Farmers retrenched and businesses and service providers they used to frequent had too few alternative customers and clients.
7.3 The impact the government’s emissions reduction proposal would have would be far worse for job losses and business failures.
7.4 The modelling shows that a very cautious approach needs to be taken to pricing and the government must recalculate the methane targets.
7.5 High targets require a higher price with the proposed system. No other country is planning to put a price on agricultural emissions. It is foolhardy to sabotage the agricultural sector and the whole New Zealand economy for no benefit except being able to claim a first.
7.6 The government’s claim that customers will take emissions into account and pay more for produce if the country’s agricultural emissions is unproven.
7.7 Until and unless there are affordable, practical and safe tools for reducing emissions, the country’s emissions might reduce but the emissions per animal and therefore per kilo of milk and meat won’t.
8 The government’s proposal will have a disproportionate impact on sheep, beef and deer farmers.
8.1 The impact will be even worse if there is not proper recognition of sequestration.
8.2 No single sector should disproportionately carry the burden of meeting New Zealand’s targets.
9 If a levy is imposed, if must be at a level that delivers only on the scheme’s intended purpose and not to collect excess funds or charge farmers more than absolutely necessary.
9.2 The use of any revenue collected must be under farmer control and they must have the say on how it is used for reinvesting into agriculture for example for research or supporting the uptake of technology.
10 We oppose the processor levy backstop.
10.1 This is inequitable because it would only be imposed on those who slaughter stock.
10.2 A processor levy would treat the best, most efficient producers the same as the worst and least efficient with no reward or incentive for improving on-farm practices.
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