Summary of submissions
Newsletter from the Pastural Farming Climate Research team.
5 December 2010
There were 61 submissions received by MAF during the consultation process to determine the emission factors for agriculture’s reporting of carbon emissions.
Some points of interest
Species exemption
MAF proposed exempting Llama, alpaca, ostrich, emus. horses and ruminants other than cattle, sheep, goats and deer,(eg bison etc)
Some submitters argued Llama and alpaca contributed the same quantity of emissions as egg production and if egg production was included so too should llama and alpaca.
All submitters who commented on species exemption were opposed to horses being exempt. Fairness was the reason given by most for including horses. (we submitted horse emissions were as harmless as cattle emissions and carbon neutral; but that it was unfair not to ping horses if cattle were being held liable for emissions that do not exist)
MAF ignored all these submissions. They argued that llama and alpaca were too small to worry about (same size as eggs remember but they are including them). They intend exempting horses and they argued it would be too difficult to get the money out of the horse people because not many horses get slaughtered. We submitted horse owners should pay a levy like dog owners do and that would not be difficult. However MAF despite giving the impression they wanted industry feedback were petty determined to just set up a scheme that was easy rather than fair whereby the processors of meat and milk and eggs would just send them cheques.
Wool and velvet
In a similar vein to above all emissions attributed to these are to be reported as a liability on the meat production of the animal. Less work for MAF this way because they don’t have to worry about getting money off the wool processors. A bit unfair on meat but good for the wool industry, especially merino wool because they keep wethers which can roam the hills freely for years and not have to pay for their maintenance emissions Good on them I say.
Split emissions factor at slaughter
MAF proposed there be two emission factors for each slaughtered animal. One for each animal and one for each kg carcass weight. Most submitters opposed this because it encouraged bigger carcass weights which were not efficient to produce. In most cases the most efficiently produced animal which has attained a slaughter weight younger than a less efficiently produced animal will subsidise the less efficiently produced animal. MAF ignored these concerns.
Lambing percentage
MAF proposed the emission factors are based on a lambing percentage of 1. The national average is 1.1. Any lambing percentage they use is going to be difficult because farmers with a higher lambing percentage will subsidise those with a lower percentage. As a result of the submission received the lambing percentage has been raised to 1.1
Different sheep breeds and farmers from different regions could apply for a unique emission factor if they are significantly different to the average. However it is only the processor that can apply for this and the regulations for this have not been invented yet.
Bobby calf emissions
MAF asked for submissions on whether the carbon liability of a bobby calf should be charged against the calf at the calf’s slaughter or be added to the production milk.
Under the ETS an animal is assigned the maintenance emissions of its mother for the 12 months in which it was born. It then has added to that its emissions produced while it is growing to mature weight. From then on its emissions produced for its maintenance are assigned to its progeny. Emissions produced for milk production are assigned to the milk production and the dairy company collects that money for the Government.
This system works for most animals that are grown for meat or milk but it does not work for bobby calves which are killed at 4 days of age. (or sooner with bobby calf prices as they are)The problem is that a bobby calf will have a carbon liability which will negate most of the value of the calf.
The options were to either keep the emissions with the calf or put them onto the production milk.
We submitted that the calf should be liable because it would make the calf worth almost nothing and kill off the bobby calf industry and cost NZ exports and this would be the first industry killed off by John Key’s ETS. (we didn’t really want this, we were just making a point)
MAF must have agreed with us that this ETS will destroy the bobby calf industry and have decided to add the bobby calf emissions to the production milk which has the effect of increasing the carbon loading on milk.
NZ starts voluntary reporting using the emission factors decided upon next month in preparation for mandatory reporting and then full entry into the ETS. There are some points about these emission factors that demonstrate the folly in them. The review of the ETS next year is the place to air these. We will be working hard to drive home the inconsistencies and discrepancies and the nonsense they continually spew about livestock emissions.
This is the link to the Ministry of Bullshit summary of submissions if you would like more detail.
http://www.maf.govt.nz/climatechange/agriculture/SummarySubmissions.pdf
For the emission factor sthemselves see our website post.
