New Zealand Climate Change Commission 2021 Draft Advice for Consultation

First and foremost, the Federation is pleased the draft report does not ignore, but also does not fixate, on agricultural emissions. The public discourse in New Zealand for decades has been that ‘agriculture is the number one issue and only farmers need to take climate action’, but the draft report has moved on from that rhetoric. Our farming members are up to the challenge of playing their part in tackling climate change, but what is defined as their part must be proportional with warming. 

Federated Farmers is also pleased to see that the report helpfully acknowledges the cutting-edge nature of the New Zealand agriculture sector while also setting a very high bar for farmers and requiring that good farmers become great, and that great farmers become even better. While tackling climate change demands ongoing GHG reductions, the very high standard to which many New Zealand farmers already farm to must be recognised in domestic policy. This recognition is critical to ensure that domestic policy is consistent with the Paris Agreement and its stated recognition of the importance of food production. 

Federated Farmers is concerned that many of the recommendations appear to be underpinned by modelling that in turn was informed by overly optimistic data. We would welcome being proven incorrect, but the draft report appears to avoid making difficult decisions on sensitive topics by drawing on modelling that shows that it is possible to ‘have your climate action cake and eat it too’. It is very risky to base long term climate plans on modelling that may not reflect reality rather than making difficult decisions. This concern is particularly pressing when modelling is used that does not acknowledge the differing nature of farming systems used throughout New Zealand, and when all information informing this modelling is not publicly available. 

The Federation does not consider it reasonable to assume that productivity improvements increased at a linear rate from 1990 to the present. Much of these productivity improvements are the result of the removal of market distorting policies in the mid-1980s and the biological nature of farming systems means that as farmers approach fixed biological limits, a steep diminishing productivity return on investment will result (even for the most cutting-edge farmers). 

While the exact assumptions used to inform the modelling are not available as of the writing of this submission, the 2018 Biological Emissions Reference Group (BERG) report is referenced. Federated Farmers was a member of the BERG and we are concerned that, as was the case for the Zero Carbon Bill, the report may be being misused to inform important work without taking proper care to note the many critical caveats contained within the report. 

Many of our members are alarmed at the deleterious impact the blanket afforestation of productive sheep and beef farms with pine forests is having on the wellbeing of their communities. Much of this blanket afforestation is driven by the allure of valuable emission units from forestry, while planting restrictions under the National Environmental Standard for Plantation Forestry drives it away from marginal land towards productive farms.  This afforestation is already having an impact on many rural communities along the east coast of the North Island, with the recent spike in forestry resulting in less local economic activity. Our members have already seen jobs lost and rural schools close and there is a fear that as a result of ‘carbon farming’ large amounts of productive land will be lost long term for a short-term climate accounting gain, with no beneficial behaviour change resulting, and rural communities being blanketed in increasingly fire- prone pine trees. The community, employment and economic implications of blanket afforestation will be even greater when the sole or key driver is carbon farming where it is highly likely the forest will never be harvested (and therefore no pruning or thinning activities will occur). 

Federated Farmers supports the Climate Change Commission's recommendation under Time-Critical Necessary Action 4(c) that the Government ensure the Rural Broadband Initiative is resourced and prioritised to achieve its 2023 target. Rural connectivity is desperately poor in many parts of the country. Our Rural Connectivity Survey 2020 report reveals the poor state of rural telecommunications, specifically around 2/3 of farmers across the country endure download speeds that would struggle to support most modern-day online services let alone farm productivity improvements like precision agriculture. Another aspect to emerge from our analysis of rural connectivity is that the completion of the second stage of the Rural Broadband Initiative may not be enough in itself. Our analysis suggests the issue of improving rural connectivity is increasingly less one of pushing broadband into ever more remote places, and instead one of closing the gaps in existing coverage and improving what access there is for many farmers. 

We strongly disagree with the terms of reference given to the Commission to carry out its review of the role of biogenic methane reduction. The issues in the terms of reference of this review are representative of the issues that exist in New Zealand when framing the question ’what is the appropriate role of biogenic methane reductions in limiting atmospheric warming’. In order to not distort least cost mitigation pathways, biogenic methane reductions should be warming equivalent to the reductions asked of long-lived emissions. If net- zero long lived emissions and a reduction in biogenic methane warming equivalent to this target will not achieve the goal of limiting warming to 1.5 degrees, then it is the date set for achieving warming neutrality that should be re-examined, not simply the target for biogenic methane. 

As currently framed, methane emitting industries are being asked to do much more than other sectors in order to make up for a lack of action in reducing these other gases. Federated Farmers do not agree with this approach and are concerned that if targets to reduce long-lived emissions are not achieved in the future, methane emitting sectors will be than asked to do even more to make up for this lack of action in reducing long-lived emissions.
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