Submissions on the Carbon Zero Bill close tomorrow.
The Bill as it stands is deeply flawed.
It will impose enormous economic costs on the country; severely decrease New Zealand’s export income and GDP; and destroy rural communities.
It will at best have a tiny impact on global emissions and at worst will increase them as food production losses here are replaced by increases from less efficient producers in other countries.
The more submissions pointing our flaws and suggesting better alternatives, the better the chance of effecting change.
You can make submissions here.
Federated Farmers’ submission is here.
Alliance Group’s submission is here.
Mine follows, you’re welcome to use any or all of it in making your own one.
Comments on the Climate Change Response (Zero Carbon) Bill
- 1. If we accept the science on climate change we must apply the best science in response to it.
Forestry is a short-term band aid on fossil fuel emissions.
Pine trees are not a long-term solution to meeting our emissions targets. Allowing pine forests to be used as carbon sinks will not encourage the behaviour change required to reduce emissions
Forestry should be used to offset biological emissions not fossil fuels.
Farmers should be able to claim full offsets for all available carbon sinks.
The point of obligation has to be on-farm to achieve behaviour change
Allowing farmers to off-set biological emissions with trees provides them with the incentive plant more.
The Methane targets in the Bill are impractical, without serious reductions to stocking rates (and damaging the NZ GDP). There currently exist no technologies that can meet these reductions as alternatives to reducing stocking rate.
Gene editing should be permitted in New Zealand as a tool to reduce methane emissions and genetic modification should be researched to determine if it has a place in reducing emissions.
- 2. If we are following the Paris Accord in reducing our emissions we must follow the Paris Accord in ensuring that carbon sinks do not come at the expense of food production.
Subsidies for planting trees and lower hurdles for foreigners buying farmland to convert to forestry than those who would continue farming are turning productive farmland into forests.
The right tree in the right place is not forests on farmland well suited to raising stock or crops.
If our response is to be sustainable it must be sustainable in the full sense – not just environmentally but economically and socially too.
Turning productive farmland into forestry is already reducing jobs in, and taking people from, rural communities. It is neither economically nor socially sustainable.
Nor is it environmentally beneficial: Environment Commissioner Simon Upton’s report Farms, Forests and Fossil Fuels, found that forests could be used to offset biological emissions but not carbon emissions from fossil fuels.
- 3. If we are thinking globally and acting locally we must take into account the impact of anything we do not just on New Zealand’s emissions but global emissions.
Food insecurity is one of the possible impacts of climate change.
New Zealand feeds 40 million people and leads the world in doing it efficiently.
Even DEFRA (the UK’s equivalent of MPI) says that it is better for the environment for people there to eat imported lamb from New Zealand than local produce:
Policies which lead to less food being produced here might lower New Zealand’s emissions but will increase global emissions as less efficient food production is increased in other countries.
Policies which incentivise forestry over farming are in direct contradiction to the Paris Accord. That includes lower hurdles for foreigners seeking to buy farmland for forestry than those who would farm it.
The One Billion Trees programme has not thought past the first 30 years, when high harvesting costs and high carbon prices will be a disincentive to harvest. That will leave a “Green Elephant” – many thousands of hectares of trees that return no harvest value and no carbon value for their owners, and no economic benefit to New Zealand.
Replacing pastoral land with exotic forests in the name of reducing net emissions risks severely impacting this country’s GDP.
Allowing the carbon price to “drift” upward from $25/tonne will create severe distortions in investment markets. The carbon price as it relates to forest sinks should be capped/regulated to prevent these distortions in the market.
The forest harvesting business should have the same environmental standards imposed on it as pastoral farming does.
The right tree in the right place, off setting emissions in the right way is forestry on land not best-suited to farming and off setting biological emissions not fossil fuel emissions.
- 5. If we are to take climate change seriously we need the knowledge to make the right choices.
Recycling is promoted as better for the environment, but if the environmental impact of transporting and processing is taken into account, is it really better than sending waste to landfills?
Running electric cars emit no emissions and hybrid cars emit lower ones than petrol and diesel vehicles. But if the entire life cycle of the vehicles and their components including mining the lithium and other minerals for batteries and then disposing of them are taken into account, which is better?
- New Zealand’s response to climate change must be based on the best science.
- The Carbon Zero Bill must follow the Paris Accord’s recognition that climate change mitigation is not at the expense of food production.
- All impacts of the Carbon Zero BIll must be sustainable in the full sense – environmentally, economically and socially.
- The definition in the Bill of “net emissions” only allows for land-use change and forestry. The definition of net emissions in the Bill should be amended to allow for “other forms of sequestration” including regeneration of native bush, smaller scale permanent plantings or soil sequestration.”.
- Forestry must not be used to offset fossil fuel emissions.
- Farmers must be permitted to offset biological emissions with forestry.
- There should be no tax on biological emissions
- Gene editing should be permitted in New Zealand as a tool to reduce methane emissions and research into genetic modification should be permitted to determine if it has a place in reducing emissions.