Calculating agricultural emissions
Released 09 Jun 2010
Regulations for exemptions and thresholds, and methodologies for calculating agricultural emissions
Federated Farmers of New Zealand submits that it continues to oppose the current emissions trading scheme (ETS) introduced in legislation by the previous government and subsequently amended by the current government, and therefore submits that the regulations for exemptions and thresholds, and methodologies for calculating agricultural emissions (the draft regulations) should be abandoned in their entirety.
It is the view of the Federation that biological agricultural emissions from food production should be removed from the Kyoto Protocol and subsequent international climate change agreements. Federated Farmers further considers the inclusion of biological agricultural emissions in the ETS should be postponed far beyond the 2015 entry currently set in the legislation, and that for government to now propose the draft regulations is wholly inappropriate.
Our preference as an organisation remains that there should be no ETS in New Zealand. If New Zealand must have an ETS, then it must not include biological agricultural emissions. If New Zealand must have an ETS and include biological agricultural emissions, then there are a number of requirements the legislation and regulations would need to satisfy before that should occur.
We've seen in recent months the abandonment by Australia and the USA in introducing their own domestic emissions trading schemes and have yet to see other countries take steps to follow the path that New Zealand has. We've seen in response to this absence of ambition elsewhere verbal commitments from ministers here to not bring biological agricultural emissions into the ETS where other countries do not have schemes of their own.
These commitments from ministers must be reflected in legislation to have meaning for farmers. In the meantime, the federation considers these commitments must be reflected in government timetables around the draft regulations as they apply to agriculture.
That the current legislation has timelines for voluntary and later mandatory reporting of biological agricultural emissions from 1 January 2011 and 1 January 2012 respectively is a matter for government to resolve in line with the verbal commitments that have already been made by government ministers to the farming sector.
Another element of concern is the short period of time the federation and other interested parties have been given to comment on draft regulations as complex and involved as those that have been proposed. Greater time should have been allotted for their consideration, especially as they are the first of a series of draft regulations the government has scheduled for the next few years. Perhaps if the draft regulations had been postponed in line with the commitments we have received from ministers, they could have been given more meaningful consideration than the constrained timeline has allowed.
Federated Farmers' primary recommendation is that the draft regulations be abandoned at this time.
Without prejudice to our primary recommendation that the draft regulations be abandoned, the Federation also recommends that:
- That the point of obligation for biological agricultural emissions should rest at the farm-level and not with the processor.
- That the draft regulations should adopt a simpler approach to the calculation of biological agricultural emissions than is currently proposed.
- That the proposed species-level exemptions are appropriate for the species described other than horses.
- That the draft regulations should not exempt biological agricultural emissions from horses.
- That more work is done on the issue of thresholds for live animal exports before confirming an appropriate threshold.
Federated Farmers takes seriously its responsibilities as New Zealand citizens. We know it is vital to use resources efficiently and wisely but we want to ensure that the New Zealand economy, which is primarily anchored by agriculture, continues to prosper.
To download the submission, please click on the PDF below.
For further information, post your comment below or contact Jacob Haronga via 0800 327 646 or click here.
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July 25, 2010 09.07p.m.
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