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EDS submission on ETS reforms questions integrity of agricultural sector’s commitments

21 January 2020

The Environmental Defence Society (EDS) has lodged its submission on amendments proposed to the Climate Change Response (Emissions Trading Reforms) Amendment Bill; specifically those that seek to give effect to aspects of the Primary Sector’s Climate Change Commitment He Waka Eke Noa (and as set out in SOP 413).

EDS is concerned that while other sectors are subject to surrender obligations and required to reduce their emission profiles, neither He Waka Eke Noa nor the draft legislation actually require our largest emitter to reduce biogenic emissions in the short term.

“How New Zealand will meet its 2030 target if the agricultural sector’s obligations over the next 5 years are limited to simply rolling out farm reporting and plans without reference to an interim reductions target is a question the Government must address,” warns EDS CEO Gary Taylor.

“There’s a danger here that come 2025, when the design of a farm-gate system for measuring emissions is due for completion, history will repeat itself and there’ll be a new set of arguments for delay in taking responsibility.

“There is a very real risk that years could pass in the absence of discernible behaviour change across the sector.  But the science suggests we are fast running out of time.  Urgency and ambition are critical.  The ramifications of any delay will be felt across the economy. Why should other businesses shoulder all responsibility, essentially subsidising farmers?

“Stalling is likely to further erode the sector’s social licence to operate, already under pressure because of its opposition to fixing freshwater pollution. We should not underestimate the reputational risk that failing to contribute to domestic and international reduction targets will have in terms of export markets.

“Farmers aren’t so uniquely exposed that they can be expected to simply do nothing until new mitigation technologies emerge, which is the thrust of their proposition.  There is a range of existing farm management practices available now that can achieve significant emission reductions alongside maintaining or indeed increasing financial returns, including stock reductions, changes in feed, and land use change. And a mere 1% per annum reduction through to 2030 isn’t that big an ask.

“We are also extremely surprised at the scant level of detail surrounding the governance arrangements for the steering group responsible for overseeing the sector’s progress towards its limited reporting and plan obligations under the draft legislation.  We would like to better understand its terms of reference, composition, reporting and transparency requirements, and how it will manage conflicts of interest.

“We look forward to appearing before the select committee that is hearing submissions on this matter,” concluded Mr Taylor.

Submission available here