Response ID ANON-SYE4-4CMM-P
Submitted to Pricing agricultural emissions
Submitted on 2022-11-03 17:14:41
Submitter details
1 Submitter name
Individual or organisation name:
Armer Farms N.I. Ltd
2 Are you submitting as an individual or on behalf of an organisation?
Organisation
3 What is your contact email address?
Email:
9(2)(a)
4 Which region are you in?
Select your region:
Bay of Plenty | Te Moana-a-Toi
5 Please choose any you are associated with:
Business
Other: please specify here:
Section 1: About this consultation
Section 2: Background and context
Read section two – HTML format
Section 3: The Government’s proposed policy designs
Read section three - HTML format
1 Do you think modifications are required to the proposed farm-level levy system to ensure it delivers sufficient reductions in gross emissions
from the agriculture sector?
Yes
Please explain your answer here:
Go straight to processor hybrid. Will be far more simple, especially for dairy farmers.
2 Are tradeable methane quotas an option the Government should consider further in the future?
Yes
Why? Please explain your answer here:
Yes, i think this has done well in the Lake Taupo catchment which had a cap & trade approach. The downside is this will completely destroy Sheep & beef
as it will come down to 'who's most profitable'. Which will be dairy farming by a long shot.
3 Which option do you prefer for pricing agricultural emissions by 2025?
A processor-level NZ ETS
Why? Please explain your answer here:
For dairy famers, this will be far more simple and cost effective. The farm level levy will create serious administrative burden and be one more piece of
compliance we don't want to do. Milk & meat produced is directly from feed grown on farm and feed eaten is directly correlated to methane produced.
Simple.
Read section three continued - HTML format
4 Do you support the proposed approach for reporting of emissions?
Yes
Why? Please explain your answer here:
I am broadly supportive of this. The systems need to go back to energy systems and link back to feed eaten. I have particular concern where generic
things such as cow numbers are used. Different dairy systems have different breed and different sized animals that eat different amounts. It cannot be a
one size fits all and needs to recognise positive things such as early culling.
What improvements should be considered? :
Dairy, on the whole would be very easy to be run simply from a processor hybrid option.
5 Do you support the proposed approach to setting levy prices?
No
Why? Please explain your answer here:
I do not support the Climate Change Commission being the only source of advice
for the minister when setting the levy price, and the criteria for price setting being solely based on the sector’s progress towards emissions targets. The
combination of these factors fails to account for sector circumstance, and what price is needed to drive change whilst maintaining a profitable sector and
vibrant rural communities.
What improvements should be considered? :
Decision makers should use the He Waka Eke Noa Partnership proposed pricing
criteria when setting the levy price, which include progress towards emissions targets; availability and cost of mitigations; social, cultural, and economic
impact on farmers, regional communities, and Māori agribusiness; available scientific, mātauranga Māori, and economic information; emissions leakage
from production moving offshore and impacts on food security. Industry needs a seat at the table when making decisions on levy price.
Read section three continued - HTML format
6 Do you support the proposed approach to revenue recycling?
Yes
Why? Please explain your answer here:
Revenue earned from the sector should be spent on the sector to help us improve. We are the backbone of the country and we need support to improve.
What improvements should be considered? :
7 Do you support the proposed approach for incentive payments to encourage additional emissions reductions?
No
Why? Please explain your answer here:
I dont support the rebate. It sounds like it is too focused on cow numbers from reading the mitigation technology as opposed to feed eaten. Further, it
also sounds liek grandparenting. All we are doing is rewarding the poorest performers to improve,.
What improvements should be considered? :
The Government should fully adopt the sector’s He Waka Eke Noa proposal and
include the incentive payment as an offset of the farm-gate price.
Read section three continued - HTML format
8 Do you support the proposed approach for recognising carbon sequestration from riparian plantings and management of indigenous
vegetation, both in the short and long term?
No, none of the above
Why? Please explain your answer here:
It is completely unacceptable that the government has significantly reduced the scope of vegetation recognised and quantity of sequestration rewarded.
This limits farmers ability to offset their emissions price and manage their farm businesses. The proposed categories do not provide adequate recognition
for sequestration given the cost of active management of indigenous vegetation
What improvements should be considered? :
I strongly believes that all original vegetation categories proposed by the
He Waka Eke Noa Partnership (shelterbelts, riparian, active management of indigenous vegetation, indigenous vegetation, scattered exotics, perennial
cropland) should be included in the scheme. If the Government is going to impose a levy on all emissions on-farm then it should recognise all the
sequestration that takes place too, as per the sector’s proposal. In principle, having on-farm vegetation shifting to the NZETS could work. However, the
government needs to provide certainty
and commitment on the pathway to shift sequestration (from all HWEN proposed categories) intothe NZETS.
Read section three continued - HTML format
9 Do you support the introduction of an interim processor-level levy in 2025 if the farm-level system is not ready?
Yes
Please explain your answer here. If you selected no, what alternative would you propose to ensure agricultural emissions pricing starts in 2025?:
The Government needs to be held accountable for its own delivery. He Waka Eke Noa
highlighted that the creation and implementation of an interim processor levy would increase the compliance, cost, and complexity for farmers. The
interim processor levy would be counterproductive for the overall goal of a simple cost-effective scheme.
Section 4: Impacts
Read section four - HTML format
10 Do you think the proposed system for pricing agricultural emissions is equitable, both within the agriculture sector and across other
sectors, and across Aotearoa New Zealand generally?
None of the above
Why? Please explain your answer here:
: Government’s proposal will lead to increased forestation of productive land and a reduction
in NZ’s overall earnings. DairyNZ is worried about the impact on rural communities, with job losses and decreased economic activity in the rural areas.
DairyNZ is concerned that the government’s proposal will have a substantial impact on the mental health of people in the rural sector.
What changes to the system would be required to make it equitable?:
11 In principle, do you think the agricultural sector should pay for any shortfall in its emissions reductions?
No
Please explain your answer here. If you selected yes, do you think using levy revenue would be an appropriate mechanism for this?:
All revenue should be used for the sector to achieve environmental outcomes. Using levy
fund to pay for a shortfall will reduce the amount of funding available for emissions reductions programs, leaving the sector worse off in the long term
and making it harder to achieve targets.
12 What impacts or implications do you foresee as a result of each of the Government’s proposals in the short and the long term?
Write your answer here :
less agriculture, less export receipts.
13 What steps should the Crown be taking to protect relevant iwi and Māori interests, in line with Te Tiriti o Waitangi?
Write your answer here:
none?
How should the Crown support Māori landowners, farmers and growers in a pricing system?:
Section 6: Audit, verification and compliance
Read section six - HTML format
14 Do you support the proposed approach for verification, compliance and enforcement?
Yes
Why? Please explain your answer here:
What improvements should be considered? :
Provide general feedback
15 Do you have any other priority issues that you would like to share on the Government’s proposals for addressing agricultural emissions?
Add your comments, ideas, and feedback here.:
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