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3 June 2015 TO: Ministry for the Environment ON: Climate Change Consultation Contribution BY: Beef + Lamb New Zealand Ltd B+LNZ submission on Climate Change Consultation Contribution June 2015 Introduction 1. Beef + Lamb New Zealand (B+LNZ) 1.1 B+LNZ is an industry-good body funded under the Commodity Levies Act through a levy paid by producers on all cattle and sheep slaughtered in New Zealand. Its mission is to deliver innovative tools and services to support informed decision making and continuous improvement in farming systems, market access and product positioning. 1.2 B+LNZ is actively engaged in environmental issues that affect the pastoral production sector. 1.3 B+LNZ represents sheep and beef farmers in New Zealand. Submission 2. Background 2.1 Beef + Lamb New Zealand (B+LNZ) welcomes the opportunity to make a submission on New Zealand’s Post-2020 Emissions Target. 2.2 Sheep and beef farmers recognise the need for their farming operations and land management to be environmentally friendly and are acting to reduce their environmental footprint, including Greenhouse Gases emissions. New Zealand farmers consider themselves to be stewards of the land for future generations and like all New Zealanders, wish to enjoy their environment and strive to farm in the most sustainable manner possible by managing New Zealand’s air, soil and water resources. 2.3 New Zealand’s pastoral production system draws upon a long heritage in farming and is recognised throughout the world as utilising our natural advantages of water, soil, sunshine and grass. New Zealand pastoral agriculture has forged an international reputation for our productivity, innovation in and adoption of research and technology, and use of sustainable pasture-based production systems over the last 100 years. It is important that we continue to uphold this through utilising and applying the best technology and farming practices that further advance New Zealand’s natural advantages in biological systems and food production. 2.4 They recognise that New Zealand has committed to reducing its GHG emissions to 5% below 1990 levels by 2020 and is working towards a new post-2020 international agreement that will commit New Zealand to future emissions reductions. 2.5 B+LNZ and its farmers recognise there is a need to negotiate a robust package of different initiatives to address New Zealand’s contribution to the mitigation of, and adaption to, climate change. The development of an Intended Nationally Determined Contribution (INDC) is an important starting point for New Zealand as negotiations commence. Ultimately the negotiated package needs to balance scientific, economic, environmental and international relationships, and the final post-2020 target will also need to reflect these elements. 3. Sector Profile 3.1 Amongst Annex 1 countries, New Zealand is unique in being a small contributor in absolute terms and the only ‘developed’ nation that has 46 per cent of its GHG inventory resulting from agricultural emissions. While agricultural emissions are high as a percentage of New Page 2 of 8 B+LNZ submission on Climate Change Consultation Contribution June 2015 Zealand’s total emissions, and New Zealand’s emissions appear high when expressed as per head of population or per capita income (17.6 tCo2-e), this does not take into account the fact that the primary products such as meat and dairy, to which those emissions relate is largely consumed overseas, or the emissions efficiency of that food production compared with other countries. New Zealand is one of the most emissions efficient producers of livestock products. 3.2 Sheep and beef farmers reduced their absolute Greenhouse Gas (GHG) emissions by 19 per cent and their emissions per kilogram of product by 23% between 1990 and 2013 through improved efficiency gains such as better lambing percentages and lamb growth rates. Sheep numbers have reduced from 57.8 million in 1990 to 30.8 million in 2013 whilst still maintaining similar production levels. 3.3 This corresponds to a reduction of about 1.0 percent per year since 1990 and amounts to a reduction of 4.12 million tonnes of carbon equivalent per year while total meat production has increased 5 per cent over the same period to 1.19 million tonnes. The sheep and beef sector now contribute 28 per cent of New Zealand’s total emissions but will continue to improve GHG emissions efficiency and overall productivity through investment in new innovation, science and technology. 30.0000 Emissions intensity kgCO2eq/kg meat 25.0000 20.0000 Beef intensity 15.0000 Sheep intensity 10.0000 intensity 5.0000 0.0000 1990 1992 1994 1996 1998 2000 2002 2004 2006 2008 2010 2012 Page 3 of 8 B+LNZ submission on Climate Change Consultation Contribution June 2015 Absolute Emissions CO2-et/yr 25000000 CO2-et/yr 20000000 15000000 10000000 GHG Beef (CO2-et/yr) GHG Sheep (CO2-et/yr) 5000000 0 GHG Beef+Sheep (CO2-et/yr) 3.4 Agriculture additionally contributes to the reduction in GHGs emissions and to the meeting of the New Zealand’s 2020 target through the application of the domestic ETS to on farm use of energy and fuel. Only livestock emissions are currently excluded from the ETS. 4. Mitigation Potential 4.1 B+LNZ believes that targets for agricultural emissions should not assume the future adoption of as yet unproven technologies. Whilst there are a number of technologies that look promising in their ability to reduce GHG emissions in certain classes of livestock, these are far from being ready to be used on-farm. 4.2 Significant barriers exist before these technologies can be applied on-farm, and many may prove to be insurmountable, when it comes to application under field conditions. These include: • Successful field application of laboratory results, over a range of environments, climates and seasons • Persistence of the mitigation. Some mitigations have proven to be transitory, lasting only a very short time, making application in extensive pastoral systems for sheep and beef cattle unsuccessful. • Any mitigation that involves chemicals or additives of any sort must be cleared for use in the food chain, involving not only domestic regulatory approvals, but also through the international CODEX regulatory process. Examples to date include the withdrawal of the very effective nitrous oxide reducing product DCD following residues being detected in the food chain, for which there are no recognised limits either domestically or internationally, rather than there being any risk associated with the product’s use. • New products and trials of new products must negotiate the labyrinthine processes of the Environmental Protection Agency and the HSNO Act. This can take many months or even years, even for low risk activities or products. • New products or techniques must first be extensively tested to determine that there are no adverse side-effects. Page 4 of 8 B+LNZ submission on Climate Change Consultation Contribution June 2015 • New management techniques must be tested to determine if there are other impacts of concern, for example, feeding of some methane and nitrous oxide reducing forages is likely to adversely affect water quality and soil structure. • Animal welfare must also be considered in the development of new products or management techniques, for trials and for long term application. • New Zealand’s small market place means that costs of development and commercialisation may be too high to make products economic to produce and market. 4.3 Many promising products and techniques are developed in testing, but very few of them survive the journey to market. Current estimates are that it will be at least 10 years and probably longer, before any of the promising leads currently being researched will become available for use on farm. 4.4 Once there are practical mitigations available, that are cost effective and efficient, do not have unintended consequences, and are acceptable within regulatory frameworks and in the market place, then New Zealand farmers and farmers world-wide will be able to actively contribute to the reduction of GHGs. But until that time it is unreasonable to expect the sector to reduce emissions significantly, as this will only be able to be achieved through reductions in animal numbers and products. 5. Sector Initiatives 5.1 While there are a few tools available to the sector, this should not be taken as the sector being inactive in this area. Considerable financial investment has been made into research and development of tools internationally and domestically, to assist in the reduction of biological emissions. On- farm practice: What’s changed between 1990 and 2012? Beef • More finishing cattle and reduction in breeding cow herd. • Increased use of dairy origin livestock for beef finishing. • Better feeding and management of animals. Sheep • Increased genetic merit of sheep for growth and reproduction, and increased use of pregnancy scanning. • Increased hogget mating • Improved pasture production quality, resulting in faster growth. • Optimised stocking rate to fit pasture Effect on productivity farm • Faster growth rates, increased weight of finished animals and of kg meat/ha. • • • Increased lamb weights at slaughter Increased kg meat/ha Increased lambing percentage; greater number of offspring per ewe carried. Net effect on emissions intensity • Greater proportion of feed going into meat production, rather than maintenance. • Reduced ewe population needed to produce equivalent amount of lamb meat at slaughter. Page 5 of 8 B+LNZ submission on Climate Change Consultation Contribution June 2015 growth. 5.2 B+LNZ helps fund: The Pastoral Greenhouse Gas Research Consortium ( PGgRC) to develop a range of mitigation options some of which are showing promising results. These include: • Breeding low-CH4 emitting ruminants • Identifying low-GHG feeds • Developing a vaccine to reduce ruminant CH4 emissions • Identifying inhibitors that reduce ruminant CH4 emissions • Extension and enabling technologies. A Primary Growth Partnership (PGP) project Managing GHG Emissions is underway, aiming to develop: • A network of certified GHG consultants; • An accurate and verifiable tool for accounting GHG reductions. This project is still in the early stages; • A framework to support farmers to understanding their GHG emissions and options for GHG mitigation while meeting other farm business objectives. 5.3 In addition, wider agricultural industry science and technology programmes have co-benefits for GHG emissions reductions: • The Pastoral 21 II project aims to implement new farm systems integrating proven component concepts to increase profitability from production while reducing the environmental footprint. Analysis of the results has shown there is a positive relationship between reducing N-leaching and reducing on farm nitrous oxide emissions. • B+LNZ has continued rolling out its land and environment plans (LEPs) to sheep and beef farmers. Over the past year more than 600 farmers have attended LEP workshops. • During 2012-13 B+LNZ ran 33 workshops and 11 hui throughout New Zealand on climate change technology transfer for sheep and beef farmers. 5.4 B+LNZ is also involved in global sustainability initiatives such as the Global Research Alliance on Agricultural Greenhouse Gases, the Meat Product Environmental Footprint (PEF) pilot, and the Livestock Environmental Assessment and Performance (LEAP) Partnership. 5.5 Life Cycle Analyses have been completed for both lamb and beef in New Zealand to establish their carbon footprint. A Life Cycle Analysis for a water footprint has also been completed. 6. Emissions Leakage 6.1 Given that global demand for animal proteins will continue to grow, any New Zealand commitments that reduce agricultural production in this country will undoubtedly result in that production moving to other, less emissions efficient countries. 6.2 If that overseas production is more emissions intensive than New Zealand agriculture then bold commitments to ambitious targets for New Zealand (whether or not they are achieved) Page 6 of 8 B+LNZ submission on Climate Change Consultation Contribution June 2015 will have come at a great cost not only to New Zealanders’ standards of living, but also to the effort to reduce global emissions. 6.3 If it has a genuine ambition to mitigate climate change, then New Zealand should not accept any policy that will predictably result in the relocation of emissions intensive industries such as agriculture to overseas jurisdictions where they will not be regulated. 7. Sector Contribution to Meeting New Zealand’s 2020 target and Beyond 7.1 Climate change policy measures introduced internationally need to be realistic about a comprehensive international response to food production related emissions and the timeframes over which such a response might occur. 7.2 When negotiating international measures, New Zealand cannot ignore its unique emissions profile, including the economic reliance on exporting food and the already high proportion of energy production that is renewable. Policies and targets that might produce reasonable emissions reductions at reasonable cost in other developed economies, could, if applied in New Zealand have both a negative effect on global emissions and an intolerable economic cost. 7.3 Given the variability of emissions profiles between countries, demands for similar emissions reduction targets should be paired with a requirement for parity in the costs of emissions reduction. By taking this approach New Zealand can more easily ensure that it is doing its fair share – but in its own way. 7.4 The sector believes the New Zealand Government should work towards a new international climate change agreement for post-2020 that provides for the unique characteristics of New Zealand’s emissions profile through separate treatment of GHG emissions from biological systems and food production. A case for securing alternative treatment of agricultural emissions is established and/or supported by: • The United Nations Framework Convention on Climate Change which established the principles on which climate efforts and actions are to be based, and which explicitly recognises the importance of food production. Article 2 stressed that stabilisation of atmospheric concentrations of greenhouse gases should be “achieved within a timeframe sufficient to allow ecosystems to adapt naturally to climate change, to ensure that food production is not threatened, and enable economic development in a sustainable manner”; • The need for affordable and nutritious food production to expand significantly to support the expanding global population. The global population is forecast to rise to 9 billion people by 2050. Estimates are that global food production will need to increase by 60% by 2050 to meet demand. Increased food production should occur in the most emissions efficient systems, in order to ensure a global reduction in GHGs. • The desirability and equity of developing countries taking on emissions reduction commitments or actions to a far greater degree given the central role agriculture plays in their national inventories and economies. The World Economic Forum states, ‘significant benefits can come from switching agricultural production to more carbon efficient locations. The potential abatement of carbon dioxide equivalent was found to be 178 million tons if the location of agriculture is optimised’. As sheep and beef farming in New Zealand operates very efficiently, optimising location means more production in New Zealand over the longer term and definitely not incentives to decrease production; Page 7 of 8 B+LNZ submission on Climate Change Consultation Contribution June 2015 • The linkage between increased agricultural productivity in regions with comparative environmental efficiency for agricultural production and decreasing pressure on deforestation to meet food demand. 7.5 New Zealand should also know the rules before final post-2020 targets are set, this can be accommodated in the conditionality rules attached to the post-2020 target. This is especially important when rules related to Land Use and Land Use Change from Deforestation have such a significant effect on New Zealand’s future net emissions. There is a strong likelihood that these rules will have a direct effect on the agricultural sectors. 7.6 There is a case for New Zealand to take a lead on securing alternative treatment to agricultural emissions internationally. This is in the best interests of not only New Zealand but all other countries if agricultural emissions are to be reduced from the food production sectors over the longer-term. New Zealand’s post-2020 target, negotiating platform and agreed end package needs to reflect this if we are to make a real contribution to agricultural emissions mitigation and reducing global carbon emissions. 7.7 B+LNZ believes that the adoption of an absolute emissions target for New Zealand that excludes livestock emissions and a commitment to develop an alternative policy framework detailing how agriculture will be treated at a later date, but no later than 2020 is required and includes: • developed countries make comparable efforts to those of New Zealand; • advanced and major emitting developing countries take action fully commensurate with their respective capabilities; • there is an effective set of rules for land use, land-use change and forestry (LULUCF); and • there is access to trading of international carbon units. Contact For any queries relating to this submission please contact: Victoria Lamb Senior Environmental Policy Advisor Beef + Lamb New Zealand [email protected] Tel: 04 474 0806 Page 8 of 8