In our submission to the Climate Change Commission on its draft advice to Government on New Zealand’s emission reduction targets and related issues, we argue for changes to the targets and outline significant concerns.
The submission was made jointly with Deer Industry New Zealand.
The Commission consulted during April and May on its:
- review of the 2050 emissions reduction target
- draft advice on the fourth emissions budget (2036–40)
- review on whether emissions from international shipping and aviation should be included in the 2050 target.
Our response to the review of the 2050 emissions reduction target
The Commission has not made any formal recommendations but there are strong indications they believe there is an argument for increasing the ambition of the targets (that is, reducing emissions faster).
We strongly disagree with this suggestion. Based on the latest scientific understanding around the differing impacts of short- and long-lived gases and other factors, there is a strong case for the methane targets to be reduced.
Chair Kate Acland notes B+LNZ has long argued that the current methane reduction targets are too high and were originally set based on an incorrect application of an IPCC report. “These must be reduced and the new targets need to be based on the principle of ‘no additional warming’.
“This would be a fairer approach that asks long-lived and short-lived greenhouse gas emissions to make the same contribution to addressing climate change. The current methane targets are asking our sector to take a greater share of the emissions reduction burden than others.
“While our farmers recognise they have a role to play in addressing warming, they want to be sure that what they’re being asked to do is fair.”
B+LNZ is therefore pleased that the Government is undertaking a separate review of the methane targets.
The B+LNZ submission also argues that gross reductions of long-lived gas emissions should be encouraged – at present, the carbon dioxide targets can be fully offset with tree plantings but methane must make absolute reductions in emissions.
The impacts of emissions reduction targets disproportionately affect sheep, beef, and deer farmers. The fundamental way the targets are set up to incentivise afforestation (on sheep, beef and deer land) to achieve long-lived emissions reductions while also expecting significant short-lived gas emissions reductions to occur in sheep and beef farming operations is unfair.
It also argues the Paris Agreement’s prioritisation of food security and production should be considered.
New Zealand meeting emissions reduction targets by simply reducing food production is a poor outcome not only for rural communities, regional economies and the overall New Zealand economy, but also a poor outcome for global food security and the atmosphere. New Zealand farmers should be empowered to farm better, not simply forced to farm less.
The Commission had also suggested that New Zealand’s targets could be made more ambitious. They base this argument on flawed modelling of what is possible and a belief that we could better share the burden of reductions with other countries. This was also strongly disputed by B+LNZ, based on the science around warming and issues of equity.
Our response to the draft advice on the fourth emissions budget
Our submission raised significant concerns about the levels of afforestation the Commission proposes to meet the net zero long-lived gas target.
“They have vastly underestimated the impact the proposed levels of planting would have on our sector.
“There is absolutely a place for forestry, and we actively support the integration of trees on farms. However, there needs to be a conversation about how much planting should occur and where,” Acland says.
The Commission’s modelling indicated the fourth emissions budget could be met by 1.43 million hectares of additional forestry (a mixture of new exotic and native plantings) and a reduction in stocking rates per hectare. They estimated this would see a 17 percent reduction in red meat production (relative to 2023 levels) by 2050.
However, B+LNZ’s modelling of the Commission’s projected afforestation and reductions in stocking rates would lead to a 35 percent decline in red meat production by 2050.
“That’s an unacceptable price for our sector to pay – and for New Zealand to pay, given that comes with an associated cumulative $30.8 billion loss in red meat export revenues.”
Our response to including international shipping and aviation in the 2050 target
Our submission argues that including emissions from aviation and shipping in New Zealand’s domestic emissions reduction targets should only be considered when other countries do this.
Including these in our targets now could hinder New Zealand’s ability to competitively export and trade. This is a cost our competitors do not face and will not provide any meaningful outcomes in terms of reducing global emissions and warming impacts.
Related information and next steps
The Commission will review submissions and provide its final advice to Government at the end of the year.
B+LNZ supports the Government’s separate independent review of the targets, currently under way, because this review is underpinned by the principle of adding no additional warming.
The Government will consider both the independent review and the Climate Change Commission’s advice in making its decision about the targets.
Read the full submission on our website here (PDF, 830 KB).