Agricultural Emissions Pricing Submission

Pricing agricultural emissions

We ask that on behalf of the animals, you please make a submission urgently. You will need to give certain personal information in the initial part of the consultation. Feel free to create your own submission and/or use our information. Either way, we want to make it easy for you to convey your opinions on this matter to the government.

Submission Closes : 18th November 2022

The government is asking for submissions on Pricing Agricultural Emissions and we are keen to see animal farming pay appropriately for the emissions they create. We would also love to see the government rewarding horticultural enterprises and encouraging animal farmers to transition and diversify into growing more plants. Making animal agriculture no longer profitable is an easy way to help this along.
The consultation asks 15 questions, which you do not have to answer. You can simply copy and paste some or all of the following into the General Feedback section, Q15.
Please feel free to have a look at the following responses from us, for some phrases you could use in your submission.
Q1. Answer Yes
We should be working towards a system to manage the total volume of methane, rather than the price. This is to guarantee cuts to gross emissions and a fair pricing mechanism.
The price of emissions should be set by the market, for a fair scheme free from political interference.
Synthetic nitrogen fertiliser should be brought into the ETS to ensure fair pricing.
On-farm sequestration that is closely linked to New Zealand’s Greenhouse Gas Inventory and the ETS, with a farmer-initiative system for adding new types of vegetation.
Native bush should score more highly than exotic pines. Established bush needs to be included as part of the vegetation. We cannot have a system that would reward a landowner for cutting down native bush and planting pines instead. All plant matter should be taken into account.
Q2. Answer Yes
The Government should implement tradeable methane quotas for pricing agricultural emissions as soon as possible, because it is the fairest option for all farmers, will prevent political distortion of the methane price, and will guarantee real reduction in methane emissions.
Tradeable methane quotas are much better than bringing agricultural methane into the ETS. This is because:
The ETS is set up for net emissions reductions, which allows for solutions like forestry offsets. This isn’t the best way to address methane emissions from agriculture.
In New Zealand’s context, with methane from livestock making up 39% of our total national emissions, we need a system that specifically drives gross methane reductions. This is why we want to see Government implement tradeable methane quotas with a reducing cap, which would set maximum emissions and leave the market to decide the price.
The ETS doesn’t match the split gas targets in the Zero Carbon Act, which means it isn’t well-suited to achieving these gross reductions in methane we urgently need.
Q3. A farm-level levy system and fertiliser in the New Zealand Emissions Trading Scheme (NZ ETS)
Synthetic nitrogen fertiliser should enter the NZ ETS (option b), because this is the fairest pricing option available. It will capture all fertiliser emissions across all sectors and incentivise the broadest reduction in use, which is good for the climate, the environment, and the health of our waterways.
Q4. Answer Yes
It needs to be simple, yet effective.
What improvements should be considered? :
More incentives and suggestions to transition towards growing food and fibre plants should be offered to farmers. Reducing livestock numbers and growing more plants should be given priority for grants and support funds etc.
We should not rely on future technology to allow us to continue doing the same thing. We actually need a system change, one which enhances soil production and doesn’t rely on synthetic fertilisers. which are not sustainable.
Q5. Answer No
Biogenic methane breaks down to become carbon dioxide, so although itself is short-lived, it actually ends up adding to the long-term gases. Biogenic methane is something that could be brought under control within a few years by consistent herd reduction across the nation and by more than 15%.
Reducing biogenic methane in the quickest time frame is the best solution to reducing our greenhouse gas emissions overall. Our planet is counting on every country to play its part and NZ should not use its relatively small size as a reason to do nothing.
What improvements should be considered? :
Incentivise transitioning from ruminant livestock towards growing plants for food. NZ manufacturers are crying out for NZ vegetables and legumes to make their products, when it is possible to grow these foods here, it is crazy that companies are forced to buy overseas.
Q6. Answer Yes

The revenue raised should be supporting those who do the right thing. Thereby if it becomes unprofitable for a livestock farmer to continue, they should be looking at how they can change to make it profitable again. That should be by growing plants on their land.

What improvements should be considered? :

There is no land in NZ not capable of supporting plant life, even growing wild meadows for bees should be counted as vegetation offset. All low fertile land should be replanted with natives as far as possible and farmers given credit for this.
All good fertile soils should be used for growing food or fibre plants, with some of this revenue used to supply support and advice for farmers wanting to transition to growing plants. They need expert advice from soil scientists and current horticulturalists on what to grow where according to soil and land type.
Q7. Answer No  
Mitigation technologies are unnecessary. We should be reducing animal numbers and growing more plants. This requires no new skills or technology and can be done right now. Big changes can occur in a few short seasons if we adopt this approach.
Q8. Yes, support both
A system to recognise rigorous and robust sequestration is needed. This must align with New Zealand’s Greenhouse Gas Inventory. The onus should be on farmers and other organisations to prove that their vegetation meets that threshold.
Forestry should not rate as highly as native bush or plants grown for food and fibre.
What improvements should be considered? :
Encourage farmers to grow hemp, all barriers to doing so, should be removed. Hemp is as much like cannabis as a tomato is like an aubergine. They are simply from the same family. Hemp is a fast growing plant with the ability to sequester carbon quickly and efficiently. It has thousands of uses and was widely grown over the northern hemisphere in the 16th century, when its value to humankind was widely recognised. Thanks to oil companies it has been effectively banned in the Western world. It has powerful remediation properties too and could be used to remove excess nitrogen from contaminated soils across Southland.
Q9. Answer Yes
Q10. None of the above
Cabinet must implement pricing for agricultural emissions by 1 January 2025 – we can’t wait any longer for emissions reductions in our worst-polluting sector.
Climate action right now is critical to mitigate the worst effects of global warming for future generations.
Scientists warn that the price of inaction is total biosphere collapse. Currently NZ is one of the worst performers in the OECD, there is no reason for this, given our size, population and amount of bush.
What changes to the system would be required to make it equitable?:
New Zealand has the chance to lead the world with agricultural emissions pricing, like we’ve done in the past on important global issues – but our pricing must be effective to do so.
Incentivise growing more plants, not mitigation technology.
Stop cutting down trees! Grow hemp instead. For many uses of tree fibre, hemp can do a better job.
Q11. Yes
Failure to reduce animal numbers or to grow more plants when these are easily accomplished should be on a user pays system. Levy revenue should be used to encourage diversification and rewilding less fertile lands.
I foresee a “business as usual” approach, with little reduction of actual emissions as farmers buy more ETS credits. Those farms with established bush need to have that taken into account, otherwise they could feel forced to cut it down, in order to grow forestry trees, which will be cut down, so there is no sequestration long-term.
The soil has a massive capacity to store carbon, so this needs to be encouraged, by transitioning support programmes. Farming without inputs needs to be encouraged. I don’t see this anywhere in the current scheme.
Without encouraging looking after the soil, we are dooming future generations to a barren land, if they can even make it through this current climate chaos. Many previous civilisations literally died out due to improper care of the soil. We have the ability to not make the same mistakes.
The Government must undertake deep and genuine engagement with tangata whenua regarding potential impacts on Māori interests of agricultural emissions pricing. This includes consultation on design of specific elements, such as a cap and trade market mechanism for methane. The Crown must honour Te Tiriti o Waitangi throughout both development and implementation.
Q.14. Not answered
Q.15 General Feedback
Reduce livestock numbers
Upskill and support the transition of animal farming towards horticulture
Make it easy for farmers to transition to plant growing
Carbon credits/grants given for all landowners who increase their planted areas
Carbon credits/grants given for all landowners who reduce their livestock numbers year by year.

Other Submissions