Submissions

Submission On Increasing The Use Of Biofuels In Transport: Consultation On The Sustainable Biofuels Mandate 

The Federation has extensive experience advocating for the interests of our farmer members on climate change, energy, and transport policies. Most recently, we submitted on the Climate Change Commission’s draft advice and evidence reports and on the Ministry of Transport’s Transport Emissions – Pathways to Net Zero by 2050 green paper. In both the draft reports and green paper, an increase in the use of biofuels is assumed by the reports’ authors. 

In 2005 Federated Farmers also submitted to the Ministry of Transport on the Consultation on Encouraging the uptake of biofuels discussion paper. In this submission Federated Farmers expressed concerns at the practicality of such a mandate. Many of these concerns went unaddressed and led to the eventual repeal of the mandate. We are hopeful a potential second scheme to encourage the use of biofuels will be more practical and therefore longer lasting. 

Federated Farmers is committed to the New Zealand agricultural sector achieving a 2050 goal of becoming warming neutral, as is consistent with the 2015 Paris Agreement. Such a goal demands that short-lived flow GHG emissions (biogenic methane) are reduced by about 10% by 2050 and demands that long-lived stock GHG emissions mainly nitrous oxide and carbon dioxide) are reduced to net zero by 2050. 

Increasing the use of biofuels has the potential to reduce New Zealand’s long-lived carbon dioxide emissions and we therefore support policies that increase their use. It is also important that such policies are fit-for-purpose for farmers and rural New Zealanders, who often lack practical alternatives to commercial and personal internal combustion engine (ICE) vehicles. 

The reliability, performance and affordability of the fuels used by our members is important in maintaining both the standard of living in rural areas and maintaining the international competitiveness of the New Zealand agricultural sector. 

The Federation supports the use of biofuels as a means of reducing long-lived carbon dioxide emissions. We do, however, caution that care must be taken to ensure that any mandatory biofuel emissions reduction target does not result in a reduction in fuel quality (particularly in cold climates), a loss in productive farmland or an overly burdensome increase in the cost of fuel. It is therefore a concern that the discussion document expects the Sustainable Biofuel Mandate to increase the cost of diesel by 5.8% and that it lacks detail on the practical considerations of farmers and rural New Zealanders. Many of our members are very large consumers of diesel, which is a critical input in food and fibre production. Farmers and rural New Zealanders will shoulder a disproportionate share of the financial burden of this mandate with no practical alternative. 

We recommend that the Sustainable Biofuels Mandate be examined through the Government’s rural proofing framework. We are concerned that this policy may not have been designed with all rural New Zealanders in mind and as stated by Minister O’Connor when releasing the rural proofing guidance: 
“The Rural Proofing Policy will ensure that when policy-makers sit down to design the rules they take into account the unique factors that affect rural communities such as low populations, isolation, and reliance on the primary sector for employment.”

It is important that unique challenges being faced by rural New Zealanders are acknowledged and considered when developing policy. The rural proofing guidance should not sit dormant but should be prioritised to ensure that central government policy that is designed in Wellington is not only fit-for-purpose for Wellingtonians, but for all New Zealanders.