165 Simons Rd

RD9 Whangarei 0179

094346006 0274795663 robin@farmcarbon.co.nz

I am making this submission on behalf of our members and am available to speak to this submission.

Pastural Farming Climate Research Inc is an incorporated society with over 1300 members. Members of PFCR are concerned with the treatment of livestock biological emissions in the ETS and want them removed on the basis that these emissions do not alter the composition of the atmosphere. No scientific link exists between emissions of enteric methane and an increase in the atmospheric concentration of methane. Furthermore no evidence exists that contradicts the undisputed premise that enteric methane when produced in a steady state does not increase the concentration of methane in the atmosphere. The theory of global warming and the official definition of climate change is that it is caused by human activities which alter the composition of the atmosphere.  Enteric methane produced from steady state does not fit within this definition. Most enteric methane produced in New Zealand is from steady state.

We take exception to this statement by Minister Groser in the forward to the consultation document.

As a signatory to the Kyoto Protocol, New Zealand has an obligation to reduce its emissions to 1990 levels for the period 2008 to 2012 or pay the difference. Following the introduction of the ETS, New Zealand is well on its way to meeting this obligation.

We see this as yet another example of misleading information put out by his Ministry. New Zealand did not commit to reduce its emissions. The 1990 level was the level of gross emissions we produced. The emissions we measure this target against are net emissions. We are well on our way to meeting our obligation under Kyoto because while our gross and net emissions have increased dramatically since 1990, our net emissions of today are lower than our gross emissions of 1990. To say that our obligation is to reduce our emissions to 1990 levels and that we are doing that is untrue. We believe a Minister of the Crown should not be misleading the people of New Zealand in this way.

Consultation Questions

Question 2

We believe the Government should adopt option C

Foresters should be able to choose either compensation or the right to offset; there is no value loss of their land if they can offset so no compensation required.

We also submit that when foresters offset they should be liable for the soil carbon losses that occur when pasture is converted to forestry. If offsetting is to have any environmental integrity the loss of soil carbon, which equates to about one third of the CO2 sequestered by these trees, should be taken into account. Even though soil carbon is not included in the Kyoto Protocol environmental integrity is important and so too is consistency. Certain international units were banned because they did not result from the net removal of any greenhouse gas. So too is the case with offset forestry. Approximately one third of the CO2 they remove does not cause any reduction in the concentration of CO2 in the atmosphere because of soil carbon loss. Consistency and fairness and environmental integrity dictate the soil carbon losses are paid for by the foresters.

Question 1          What do you think of the overall package of amendments the Government is proposing to make to the ETS as outlined in this document?

These are the Govt proposed amendments We are submitting on;

• Provide for a power to delay the entry of emissions from animal livestock and fertiliser use for up to three years if certain criteria are not met, following a review in 2014.

We submit that the words “up to three years” be removed with no limit on how long entry can be delayed.

The reason for this is that if the criteria the Govt has set for the entry of livestock emissions are not met then they should not be included in the ETS regardless of what year it is. There is no reason to set a maximum extension of three years so no limit should be included. In fact there is no logic in having a time limit. This Government proposal is effectively saying that biological emissions should not be in the ETS for these reasons but that after 2018 these reasons are no longer valid. Why would they not be valid after 2018? If they are valid now they will be valid after 2018.

As to the first of the two criteria.

• there are technologies available to reduce these emissions

We submit that this criterion is too vague. It could be said that technologies exist now, The Caygill report said that farmers could reduce emissions by increasing per head production, planting trees and using DCD. The report was incorrect in drawing this conclusion. We will deal with each of these options separately.

DCD

DCD is not available to all. If compliance with the ETS is to remain at processor level then only technologies that can apply throughout NZ can be considered for this test. DCD is not a useful option through out New Zealand. It is also only marginal in some areas of New Zealand and the known harmful effects of burning fossil fuel to spray a chemical on the soil to kill the denitrifying bacteria that are an essential part of the nitrogen cycle, which is undoubtedly the most important cycle for life on this planet, far outweigh the minor and only suggested consequences of nitrous oxide itself.

Forestry

Technologies to reduce emissions must not include the ability to offset emissions by planting trees as this is not a realistic or sound economic proposal for farmers on high value fertile land. It also goes against the intention of the UN not to enact policies that reduce food production. It is also not a technology to reduce emissions, rather it is an offset mechanism only and not a true one at that because the farmer can not offset one activity against another and then account for the balance. The farmer will still have to pay money because of the ETS yet if they have planted trees they only receive NZU’s.  These NZU’s can only be converted to money by the farmer trading them with the inherent liabilities and risks of that.

Increasing per head production

We submit that it is only the ability to reduce emissions greater than 1.3% per year per kg product per year that should trigger this condition being met. Livestock emissions are currently reducing by this amount without an ETS. It also demonstrates how unnecessary it is to use an ETS to reduce emissions. Of course this, option while reducing emissions on an intensity basis usually result in an increase of absolute emissions. Placing extra ETS costs on farmers will promote further increases in absolute emissions as farmers increase production to cover the ETS costs.

On the second of the two criteria

• international competitors are taking sufficient action on their emissions in general.

We submit that this condition is too vague. Who decides what is sufficient and under what criteria? This condition must also define competitors as livestock producers and read that NZ’s biological emissions will not be included in the ETS until our competitors include biological emissions in their carbon reduction scheme.

We understand that the term ‘emissions in general’ was included deliberately instead of saying biological emissions. The reason given that we should include biological emissions in our ETS even if our competitors don’t, is that biological emissions make up a large proportion of our emissions is not necessarily logical.

What does it matter what proportion of our emissions they make up? We just decide what to include and what not to include in our ETS. Europe’s ETS does not include major emitters so we can do the same for biological emissions.

The Government is also eying up opportunities to align our ETS with the Aussies. Having farmers on both sides of the Tasman treated the same way is essential. The relative contribution of each sector to their national emissions profile is quite irrelevant and in addition biological emissions are not an insignificant contributor to the Australian emission profile, yet they are not included. Once New Zealand farmer’s biological emissions are included in the ETS it could not equitably be aligned with Australia’s scheme. This is because then you would have a NZ farmer who is having exactly the same impact on the atmosphere as an Australian farmer buying carbon credits from the Australian farmer. This is because our ETS deems the NZ farmer to be an emitter whereas the Australian farmer who may be involved in identical farming methods receives carbon credits under the carbon farming initiative because their biological emissions are ignored and certain carbon accounting methodologies which are not available to the NZ farmer, receive credits.

The Caygill panel could only refute the claim of unfairness by saying “The argument that no other country includes biological emissions in its emissions trading scheme ignores the point that these emissions are covered by the target for which New Zealand is accountable, whatever happens elsewhere. This is easily solved; don’t include them in the targets. It would be quite legitimate for NZ to set a target which excludes biological emissions. The other countries that are not including biological emissions in their trading schemes are hardly going to be able to complain.

On the proposal to change the Global Warming Potential of methane from 21 to 25 and nitrous oxide from 310 to 298

We submit that GWP’s are a flawed system and that the UN is actively seeking a replacement metric because they do not work. Until this occurs a flawed metric should not be used in major economic policy, namely the ETS. Using GWP’s is disadvantaging NZ and NZ needs to advocate for a fairer system. In the meantime methane and nitrous oxide do not need to be converted to a ‘carbon dioxide equivalent’ they can easily be reported on an individual gas basis.

We also submit that changing the GWP’s at the whim of a conference creates uncertainty. Any value needs to remain unchanged for a defined period. Farmers need to know what these GWP’s will be without fear of another increase at every conference. These conferences cause enough fear already with the fear that our delegates will get carried away in the moment and handicap our future with an agreement. If we are to have GWP’s the Govt needs to set a clear process in place as to how often and when these GWP’s will be subject to change in our ETS.

• Introduce more explicit powers to enable auctioning of NZUs within an overall cap subject to further consultation on the detailed settings.

• Provide a power for appropriate quantitative restrictions on the use of international units subject to further consultation on details.

Consultation does not mean that the Government will do any more than inform so we do not support this proposal without these details.

We submit that the proposed ETS auctioning process and the ability to set a cap and the ability to limit the purchase of international units should not proceed into legislation until all the criteria are in place.

These changes will fundamentally change the way the ETS works with the Government attempting to pass legislation with out any of the necessary detail in place to gauge the impact this will have.

We also submit that any changes a Minister of Climate Change wants to make to the cap, the amount of units available for auction and the percentage of international units an emitter can purchase must be through legislative change, not regulation.

The reason for this is that any changes will directly affect the market making it not a true market. Any changes need to be considered and consulted on and scrutinised by the public through the parliamentary process. With such changes able to be made by regulation the powers future Ministers will have are too great. There is a real possibility that political motivations will be used to change the fundamentals of the scheme and for example turn it into a cash cow for the Government rather than a tool to save the planet. We saw that at the last election with Party’s pledging to take money paid by emitters and use these to fund expenditure not related to global warming mitigation.

We also submit on the proposal to set a cap on emissions based on international targets or commitments. With no international commitments after 2012 other than conditional targets and if these targets are to directly affect the ETS and our economy then for the sake of certainty and so that business can plan ahead, unconditional targets must be set several years in advance and remain relatively constant.

w www.farmcarbon.co.nz

They are asking for submissions on 4 questions. If you address your submission to these you will have more chance of effecting change. A rant about the inanity of it all might make you feel better and will remind the bureaucrats that read them that we do not like what they are doing but unless it addresses the issues raised in the consultation document it will do no more than that. I suggest address the issues and add disapproving comments in the context of the point you are addressing.

Three of the questions relate to forestry in particular whether the Government should adjust the level of compensation to pre-1990 forest landowners in light of the introduction of offsetting?

I personally think foresters should be able to choose either compensation or the right to offset; they should not receive both.

For livestock farmers the question to answer is;

General

1. 1.       What do you think of the overall package of amendments the Government is proposing to make to the ETS as outlined in this document?

These are the Govt proposed amendments I will be submitting on; What I am submitting (or words that effect) I have underlined.

• Provide for a power to delay the entry of emissions from animal livestock and fertiliser use for up to three years if certain criteria are not met, following a review in 2014.

The Govt needs to change the legislation to be able to do this I will be submitting that the words “up to three years” be removed with no limit on how long entry can be delayed.

The reason I submit this is that if the criteria the Govt has set for the entry of livestock emissions are not met then they should not be included in the ETS regardless of what year it is. There is no reason to set a maximum extension of three years so no limit should be included.

The criteria the Govt has set before livestock emissions are included are;

• there are technologies available to reduce these emissions

• international competitors are taking sufficient action on their emissions in general.

A review of the ETS will be held in 2014 as required by ACT in its 2008 coalition agreement with National. It will review how these conditions have been met.

The report of the last review led by David Caygill said that farmers could reduce emissions by increasing per head production, planting trees and using DCD. The next review will likely conclude the same thing so the criteria for assessing whether this condition has been met needs to be set differently.

I will submit that if compliance with the ETS is to remain at processor level then only technologies that can apply throughout NZ can be considered for this test.

That rules out DCD.

I will also submit that the abilityto reduce emissions must be balanced with other impacts such a process may have. For example it may not be advantageous to the environment to burn fossil fuel to spray a chemical onto the soil to kill the soil bacteria responsible for denitrification which is an important part of the nitrogen cycle which is the most important chemical reaction to life on this planet.

Doing the above makes as much sense as blowing up the sun because it causes skin cancer.

I will submit that technologies to reduce emissions must not include the ability to offset emissions by planting trees as this is not a realistic or sound economic proposal for farmers on high value fertile land. It also goes against the intention of the UN not to enact policies that reduce food production. It is also not a technology to reduce emissions, rather it is an offset mechanism only.   

I will submit that it is only the ability to reduce emissions greater than 1.3% per year per kg product that should trigger this condition being met. Livestock emissions do not need to be in the ETS because farmers are currently reducing emissions by this amount without an ETS. Livestock emissions also cause no increase in the concentration of any greenhouse gas when produced in steady state, which is most of New Zealand’s livestock emissions. 

On the second condition

• international competitors are taking sufficient action on their emissions in general.

I will submit that this condition is too vague. Who decides what is sufficient and under what criteria? It must specifically include livestock emissions and that international competitors be defined as livestock producers and that the condition be that NZ’s biological emissions are not included in the ETS until our competitors are subject to the same financial liabilities for their biological emissions.

At the consultation meeting I attended they made a point of saying that this clause used the term general emissions instead of biological emissions deliberately. It is inconceivable that the NZ Govt would handicap its farmers by not requiring our competitors to be paying for their emissions and maybe National is putting in a vague condition to give it an out. The problem is that it may not be a National Minister deciding this; it could be a Green one.

They Govt brings out the same line that Nick Smith used to do that because livestock emissions make up such a large proportion of our emissions compared to other countries we have to include them in our ETS even if other country’s do not submit their farmers to the same impost. I can make no sense of that reasoning at all. What does it matter what proportion of our emissions they make up? We just decide what to include and what not to include in our ETS. Europe’s ETS does not include transport, a major part of their emission profile; in fact no other country does so we can do the same for biological emissions.

The Govt is also eying up opportunities to align our ETS with the Aussies. Having farmers on both sides of the Tasman treated the same way is essential. The relative contribution of each sector to their national emissions profile is quite irrelevant.

The Caygill panel could only refute the claim of unfairness by saying “The argument that no other country includes biological emissions in its emissions trading scheme ignores the point that these emissions are covered by the target for which New Zealand is accountable, whatever happens elsewhere. This is easily solved; don’t include them in the targets. It would be quite legitimate for NZ to set a target which excludes biological emissions. The other countries that are not including biological emissions in their trading schemes are hardly going to be able to complain.

On the issue of livestock emissions they propose changing the Global Warming Potential of methane from 21 to 25 and nitrous oxide from 310 to 298

This is because Kyoto used these GWP’s so they have been set since Kyoto began when in fact they should have been 25 and 298 respectively to match the latest science. This will increase the liability farmers face. I will submit that GWP’s are a flawed system and that the UN is actively seeking a replacement metric. Until this occurs a flawed metric should not be used in major economic policy, namely the ETS.

I will also submit that changing the GWP’s at the whim of a conference creates uncertainty. If we are to use these flawed GWP’s then their value needs to remain unchanged for a defined period. Farmers need to know what these GWP’s will be without fear of another increase at the next conference. There is enough fear created by those things anyway. If we are to have GWP’s the Govt needs to set a clear process in place as to how often and when these GWP’s will be subject to change in our ETS.

The other proposals I will be submitting on are general ones to do with the function of the ETS

• Introduce more explicit powers to enable auctioning of NZUs within an overall cap subject to further consultation on the detailed settings.

This is a significant change to the current ETS. Two problems here.

Auctioning NZU’s changes the fundamentals of the scheme. Currently the Govt gives NZU’s to a forester- the emitter buys the NZU off the forester- the emitter then surrenders the NZU back to the Govt.

It is cash neutral to the Govt.

By auctioning NZU’s the Govt will get involved by cutting out the forester and selling to the emitter. There will be a limit on the number of NZU’s the Govt sells so the foresters will still be able to sell their units. The problem the Govt is trying to solve is that an emitter can buy an international unit from overseas instead of NZU’s from forestry and surrender these. The Govt wants to avoid the flow of money out of the country by auctioning units so that emitters will buy from the Govt instead of overseas. (the price will be the same ). They maintain that this auction process will be income neutral to the Govt because the money they get from the auctions will be equivalent to and just replace the value of these international units that they get now.  The reality is that they can not sell these international units because there is no demand for them they are worthless. The big problem I see is that it will just become a cash cow for the Govt and with future Minister of Climate Change issues able to alter the settings of the ETS by regulation rather than legislation this ETS could become just another tax to raise revenue rather than save the planet.

Second Problem

Currently our ETS is a no cap trading scheme. NZU’s are distributed on an intensity basis so farmers will receive NZU’s  covering 90% of their livestock emissions in 2015 or whenever it comes in. They have to purchase the other 10%. If livestock emissions doubled between now and then due to a miracle grass doubling production then farmers would still get 90% of the new level of emissions.

By introducing a cap this will change the scheme from an intensity based scheme to a true cap on trade scheme. Farmers can live better with an intensity scheme than a capped scheme because livestock emissions reduce by 1.4% each year per kg product due to increased productivity but as production increases so too do absolute emissions. If a cap is in place the price will go up as demand increases with no increase in supply

The Government seems to be all over the place with this, on the one hand they lower the demand and therefore carbon price by continuing the transition measures and on the other hand they want to introduce a cap which could dramatically increase the value of units if supply does not increase to match demand.

What the cap will be has not been set, the Govt proposes that the Minister of Climate Change will set the cap each year based on whatever international commitment NZ has.

This is far too loose, it gives tremendous powers to the Minister and with future international commitments unknown the impact of this change to the ETS is unknown.

• Provide a power for appropriate quantitative restrictions on the use of international units subject to further consultation on details.

Again this is all too loose, they propose being able to restrict how many international units an emitter can purchase on a percentage basis. The percentage would be able to be set by the Minister and changed at his whim. By saying that the restrictions will be set based on further consultation shows what a mess the Ministry is in. They need to get this legislation through this year but they have no details ready at this point. Once the legislation is passed to allow the percentage to be set by regulation they propose a consultation process to help set the percentage. I don’t thinks so! Once the Minister has the power to set the percentage of international units an emitter can surrender without going back to the parliament he does not need to listen to anything we say in the consultation process. By saying they will have such a process is just placating us so that we will give him the power to ignore us in the future.

I will submit that the proposed ETS auctioning process and the ability to set a cap and the ability to limit the purchase of international units should not proceed into legislation until all the criteria are in place. I will also submit that any changes a Minister of Climate Change wants to make to the cap, the amount of units available for auction and the percentage of international units an emitter can purchase must be through legislative change, not regulation.

The reason for this is that any changes will directly affect the market making it not a true market. So any changes need to be consulted and scrutinised by the public through the parliamentary process.

What the Govt is trying to do here is get the legislation passed that will allow it to change the ETS using as yet undefined criteria. With undefined criteria, the effect can not be defined and no legislation should be passed if the effect of that legislation can not be determined.

I will also submit that with no international commitments after 2012 other than conditional targets and if the ETS is to be changed in such a way that  these targets directly affect the ETS and our economy then for the sake of certainty and so that business can plan ahead, unconditional targets must be set several years in advance and remain relatively constant.

Certainty is the reason for this; imagine trying to do budgets for a farm purchase or development which is fraught with enough uncertainty re weather and prices so to have a Minister of Climate Change dicking around with the carbon markets as well it would be too much. Remember the Minister is a politician, he is not an expert on these matters, he could really wreak havoc with all the powers they propose giving the Minister.

Well done for reading all that. I hope it made sense.

If you want to send a submission the details are below, and if you want any info to help you you’re your submission email me or ring me.

Cheers Robin

Please send your submission by email to:etsconsultation@climatechange.govt.nz

If you are unable to email your submission then please post it to:

ETS Review Consultation Ministry for the Environment PO Box 10362Wellington 6143

The Government is now consulting on the proposed changes to the ETS. They are holding meetings which start this week, (I have been away for a week so I am sorry for last minute notice, although it has been fairly last minute by the Govt.)

Click here for consultation document consultation document consultation document (PDF, 4.49 MB) This has been published setting out the proposed changes and a number of regional hui and public meetings have been scheduled to discuss the proposed changes.

In the document they say this

the Government supports the entry of agricultural emissions into the scheme only under two conditions:

• there are technologies available to reduce these emissions

• international competitors are taking sufficient action on their emissions in general.

Consistent with this position, the Government proposes to undertake a review, to report in 2014, on whether these conditions have been met.

To enable the results of this review to be implemented, the Government proposes to include the power to defer the entry of these agricultural gases by up to three years. As it is possible that different gases or agricultural activities could have varying levels of opportunities to reduce emissions, it will set up this power to enable the Government to defer obligations for some or all activities.

So it is not cut and dried that they will defer agriculture’s entry for all bio emissions. It is also disconcerting that they put a time limit for the deferral of a maximum of three years should they wish to defer some or all of these livestock emissions; this implies that after three years the Government will throw our farmers to the wolves even if the two conditions are not met. I would think a submission that no maximum is put in place here is in order.

It is also noticelable that the Govt does not see it as important to require competitors to pay for livestock emissions only that they take sufficient action on their emissions in general. (whatever thta means)

The other change which is significant is that the Govt wants to limit the number of international units bought and is proposing limiting the proportion of international units an emitter can surrender and also auctioning NZ Units by the Govt as well as continuing with the free allocation it gives to trade exposed industry and forestry. They say this process will be revenue neutral to the Govt as each additional NZU sold would mean one less international unit of equal value would be surrendered to the Government to meet participants’ obligations.

Of course the whole scheme is supposed to be revenue neutral which makes a lie of Russel Norman’s repeated bleating that farmers are being subsidised by taxpayers.

The Government wishes to consult on the following questions:

1. What do you think of the overall package of amendments the Government is proposing to make to the ETS as outlined in the consultation document?
2. Should the Government adjust the level of compensation to pre-1990 forest landowners in light of the introduction of offsetting?
3. If the Government was to adjust the level of compensation, which of the three options for adjusting the second tranche of allocation, as outlined in this document, do you prefer and why?
1. a full removal of the second tranche of pre-1990 compensation for all eligible landowners
2. a reduction of the second tranche of pre-1990 compensation for all eligible landowners
3. a removal of the second tranche of pre-1990 compensation only for those landowners who take up offsetting.
4. If a reduction of the second tranche is your preferred option (option 3b) what do you consider the most desirable way to do this and why?

Responding to the consultation

You can send your submission by email to: etsconsultation@climatechange.govt.nz
or post to:

ETS Review Consultation
Ministry for the Environment
PO Box 10362
Wellington 6143

The closing date for submissions is 5pm Friday 11 May 2012.

About submissions

The Ministry for the Environment may publish all or part of any written submission on the Government’s climate change website. We will consider you to have consented to such publishing by making a submission, unless you clearly specify otherwise in your submission.

The content of submissions is subject to the Official Information Act 1982. Copies of submissions sent to us will normally be released in response to an Official Information Act request from a member of the public. If you object to the release of any information contained in your submission, please clearly state this in your submission, including which part(s) you consider should be withheld, together with the reason(s) for withholding the information. We will take into account all such objections when responding to requests for copies of, and information on, submissions to this document.

If you do not wish your name and any identifying details in your submission to be released in response to a request, please clearly state this in your submission. At your request, we will make your submission anonymous before it is published on the climate change website. However, please note that the Ministry for the Environment will not be able to withhold any information if doing so would contravene the requirements of the Official Information Act.

Hui and public meetings

I can’t make the Whangarei meeting as I will be in Christchurch and so I may be able to attend the Christchurch one for a part of it, although I think there will only be limited participation by public and the best way to get your message across is by submission. Having said that I do encourage any one with a gripe on this issue to go along and say your piece. It doesn’t hurt to tell them again and again that livestock emissions do not alter the composition of the atmosphere.

Also that there should be no maximum on the three year delay for agricultural bio emissions because these emissions are quite harmless and Tim Groser does not possess one piece of evidence to say otherwise.

I think he should be questioned on why he i sprepared to allow a scheme where NZ farmers are the only one’s in the world facing a cost on these harmless emissions.

I will try to get a copy of my submission out to you as soon as I can so that if you want you can use it for information to help with your own submissions.

All the best Robin

Word is that he is not so keen to renew Kyoto but instead sign us up to the other option agreed at Durban which is to sign up to a treaty which will have legal force by 2020.

Either way we are in trouble. We can not meet either commitment. Our emissions increase every year, all the politicians can do and are doing is to adopt short term measures to encourage the planting of trees and fudging the figures using net and gross emission figures at different times to give the impression that these forestry removals are achieving something when in fact they are not. They will not save us from the financial burden of these international agreements.

And the last thing the politicians do is set ridiculous targets without any plan whatsoever as to how to achieve them. The strategy seems to be that targets set way in the future give the impression we are doing something when in fact we are not and more importantly they do not scare the voters. The other advantage of distant future targets is that the politicians know that they won’t be in power in 2025 or 2050 so the fact that these targets won’t be met will not be their problem. It will be ours though because there will be financial consequences; we will be the ones paying the penalties incurred under agreements with legal force signed on our behalf by Tim Groser. He needs to be reminded that actions he takes for short term political expediency will cost us dearly in the future.

I have expressed my displeasure to him that we are all now paying for the actions of a previous National government which signed Kyoto and that one mistake could be forgivable but not two.

John Key is keen for NZ to sign up to a second commitment period but his understanding of the implications of this are on a par with those of Keisha Castle Hughes and Lucy Lawless so  Tim Groser should be able to talk him out of that if he chooses, although Groser did say this in Durban which is a little worrying.

New Zealand is calling for a “Kyoto plus” deal in which the U.S., China, India and other big greenhouse-gas emitters give stronger assurances that they will live up to their voluntary pledges to curb emissions by 2020, Groser, said in an interview in Durban.

Countries that are considering whether to stay in Kyoto need such guarantees to politically justify a decision to remain in the pact, Groser said.

Well China, India and other big emitters have given that assurance and the Europeans have committed to another Kyoto. So what will Tim do?  I told him I could think of no patriotic NZer who would want NZ to sign up to binding commitments with financial penalties attached in return for others just giving assurances on voluntary pledges with no financial penalties for not meeting them.  I will let you know when I get a response.

I personally think that politicians should not be allowed to commit NZ to international agreements without consulting us. That is what I asked for. I also asked that any future agreements do not include livestock emissions on the basis that they are harmless. Tim Groser has as much as acknowledged to me that the current approach to livestock emissions is not appropriate. He actually said that “NZ advocates for an appropriate approach to agricultural emissions in the next agreement” I take that to mean that the current approach is not appropriate, otherwise why would NZ be advocating for it? Is there any other way to take his statement? If there isn’t then such an admission is promising. More than we ever got from Nick Smith.

I hope you all have a lovely Easter

Robin

I would again like to welcome all the new members who have joined up since the last newsletter (about 170 new members).This is a reflection of our growing membership and the fact that it has been 2 months since the last newsletter which is not ideal.

In my defence I took some time off over Christmas and since coming back I have had to devote quite a lot of time to getting our admin up to speed. While all the cheques and new members are fantastic and appreciated, at the moment it is me loading all the information into our database so this eats into my available time.

I am currently still working on getting the members only page on the website up to speed so you can log in and see what is happening with the membership and the money raised so far. I don’t want to put it in this newsletter because it goes out through our website and once Google get hold of it we can’t delete the information from the web even if it is deleted off our own page. I’ll let you know when that is running.

Timeline for initiating action on the study is June; I hope to have sufficient funds raised to set the ball rolling. Ultimately we need to have it finished by 2014 when the next ETS review takes place and before we get a Labour /Green government.

The issue of what the study seeks to do is important. What we don’t want is to do the study and have one press release from another group dismissing it as irrelevant etc. As an example I have had a meeting with a group I hoped would be interested in helping set the terms of reference and assist overseeing the study. They are not interested at this stage but I am hopeful they will rethink this. The point made by them was valid in that what the study asks and answers is vital. They also said that everyone knows that the atmospheric concentration of methane does not increase from livestock emissions of a steady state so we don’t need to prove that. (Although I have never heard that group publicly say that and it would be interesting to hear Dr Smith acknowledge this) This group argues that without livestock replacing atmospheric methane, the methane levels will drop and so too will the greenhouse effect. Therefore they argue that livestock are responsible for global warming. I can see why they think this and this argument might sound logical to them but its logic evaporates when it is put in the context that they are arguing that an emission which maintains the concentration of a greenhouse gas (enteric methane) has exactly the same global warming effect as an emission which increases it (fossil sourced emissions).

Of course it can’t, they are quite wrong and for proof of that you only have to consider that if all our emissions just maintained the concentration of greenhouse gas and did not increase it then there would be no global warming industry because there would be no problem.  An activity which does not alter the composition of the atmosphere is also outside the definition of an anthropogenic global warming activity. I said to this group that until the definition is changed by the UN , there was no need to include atmospherically neutral emissions. Hopefully t hey will mull over this point.

This group is an influential farming group and it would undermine our study should they make a statement that undermines our study when asked to comment on our study regardless of whether there was any merit in their argument. We really want them and other groups involved at least in an advisory role before we frame the study, so that the right question is asked and answered. I am confident this can happen.

In the meantime keep the membership growing, if you have neighbours or friends and you want information sent to them or you want some info yourself to pass on to others let me know. I will be at the Northland fieldays in Dargaville for a couple of days in the rural marquis so drop in and say hi if you are passing by.

The Broadcasting Standards Authority has once again declined a complaint I lodged against TV One news for an item screened about the Australian carbon tax.

In it the news reader said “Australia is following NZ’s lead on reducing pollution by unveiling a new carbon tax scheme “

My complaint was that the term polluters and pollution are an inaccurate description of carbon emissions and someone who emits them. The most obvious reason of course being that carbon dioxide is not a pollutant and that carbon is in fact a theoretical unit, it is not real and therefore can not pollute anything. I also said it was insulting and offensive to emitters and used by people due either to ignorance or the desire to insult and offend. News readers I said should not be in either category.

Anyway the BSA state that “it is common and acceptable for news reports to employ informal or simplified language of this nature in order to convey matters of science to the average viewer in a manner that will be easily understood. We do not consider that the scientific differences between pollution and emissions would have misled viewers.”

There is so much wrong with this decision it is difficult to know where to start so I won’t other than to say misleading viewers is not acceptable and the BSA excuse about simplified terminology is nonsense. In general terms the BSA which is supposed to maintain standards of accuracy amongst others is in fact part of a society that is condoning the distorting of truth.

I find this unacceptable and I will continue to complain whenever I hear this term used by a news reader.  Bad things happen when good people do nothing. If we do nothing the children of today will know nothing other than CO2 is a pollutant and a cow belching is a polluter. If we want a society that respects honesty and truth and detests propaganda we must complain each and every time the term is used by news readers. Politicians can be as ignorant and as offensive as they like so you can’t complain when they say it but you can when news readers state it as a matter of fact, and I encourage you to do it.

Paul Henry got nailed for using the term retarded which is an accurate description of someone who is mentally slow according to the dictionary. The BSA nailed him because they said it was offensive. Polluter is an offensive term but they don’t give a damn about that. They are very selective and nothing more than a puppet of the PC mentality.  They are not upholding standards; they are assisting with the lowering of our broadcasting standards by allowing CO2 to be called a pollutant. Paul Henry called their decision against him “a ridiculous decision by ridiculous people”; I think he said it well.

We are on a slippery slope when we allow this sort of misinformation to go unchallenged. As I blogged recently Tim Groser in Durban told the world our emissions had reduced when in fact they have increased. The BSA might say he is using simplified language when he described our increasing emissions as decreasing. I say can it be anything other than dishonest to describe something that is increasing as “decreasing”?  And should a NZ Government Minister be doing that?

The Treasury in the budget this year said that under Kyoto NZ had agreed to reduce our net average emissions to 1990 levels. This is not true; we agreed to increase our net average emissions to no more than our 1990 gross emission level. They are deliberately misleading the people of NZ in the 2011 Budget by saying Kyoto is about reducing emissions when it is in fact only about limiting the increase. This is the NZ Treasury and this is the NZ Budget, deception should not be a part of either yet they do it. I have complained to them but so far to no avail. I might revisit it in the New Year.

I will sign off now for Christmas. New members continue to join every day. I intend taking a couple of weeks off to work on my orchard and take a break for few days. There is much to do when I get back including getting some pressure onto this Government not to sign up to a second round Kyoto if it includes harmless biological emissions.

Merry Christmas everyone, Paul Henry said it best and I think we have to realise that there are a lot of ridiculous people making ridiculous decisions; especially in the area of livestock emissions. They will be far from my mind this holiday season. I will be able to do this because I believe that ridiculous people will always be found out in the end. Let’s take comfort in that and drink to that!  Merry Christmas.

Talk about shoot yourself in the foot. Groser is supposed to be negotiating for NZ not against us.

Details are still skethchy and I hope I have got this wrong but if what I have read is true I can’t think of  a worse outcome for NZ and I can’t think why Groser would do this to NZ.

With our emissions increasing and forestry offsetting starting in 2013 I can see this costing us all a lot of money. The ETS is bad enough but at least most of that money stays in NZ. This deal Groser may have agreed to will see money going from the hands of a NZer to overseas interests.

With a government not actually  formed yet is it appropriate for Groser who is effectively only acting for a caretaker government to sign away NZ’s future prosperity with a deal that no one in NZ has given him authority to do?

However our very own Tim Groser is leading a sickening display in Durban all by himself.

Tim Groser in Durban

“Having accepted a responsibility target under the Kyoto Protocol CP1 we are on track to meet our commitments and no matter what the outcome here in Durban New Zealand’s mitigation efforts will continue post-2012.”

The only reason we accepted this target is because it was a cheat target. Our net and gross emissions are way up on 1990 and increasing each year, but because we set our target using gross emissions and we meet it with net emissions we are sweet. In other words we report NZ’s emissions status including emissions and forestry removals during the commitment period but we ignore all the forestry removals in 1990 to make it look like we are achieving something even though we are not.

“New Zealand faces a real challenge with half of our emissions coming from agriculture but we have implemented an all sectors and all gases emissions trading system which is a first for a developed country and we are already seeing the benefits of reduced domestic emission levels.”

Bullshit! Groser is effectively lying to the world here. The reduced emission levels he talks about are not real reductions as our emissions continue to track up each year.  Our domestic emission levels have not reduced at all they are just lower than what was projected.  If there is any industry where you can call increasing emissions reduced emissions it is the global warming industry. An industry with almost no integrity at all. Even these so called reduced emissions have everything to do with bad projections and nothing to do with the ETS as Groser claims. This from the MOE explaining why our emissions are below projected levels.

The largest change was to projected emissions from agriculture. This is because the methodology used to calculate agricultural emissions for the national greenhouse gas inventory has changed.  An improved methodology based from the latest science research shows emissions from New Zealand livestock excreta is lower than previously estimated.

It has nothing to do with the ETS as Tim claims. Groser is one of our smarter Ministers and for him to spin this bullshit to the world is disappointing and embarrassing. Our livestock might be producing less effluent but our Government is making up for that by producing more.

“We need to be able to go back to our own people,, whether we live in France or New Zealand,  and say we aren’t the only people doing something. You will not carry public opinion if the debate is ‘you are the only idiots doing anything.’”

Is Tim Groser admitting we are the only idiots doing something?

New Zealand is calling for a “Kyoto plus” deal in which the U.S., China, India and other big greenhouse-gas emitters give stronger assurances that they will live up to their voluntary pledges to curb emissions by 2020, Groser, said in an interview in Durban.

Countries that are considering whether to stay in Kyoto need such guarantees to politically justify a decision to remain in the pact, Groser said.

If Tim Groser is saying he is happy for NZ to sign up to a second round Kyoto which will have binding obligations as long as other countries promise to meet voluntary targets then he needs to get a new job. It was a National Government that signed up to Kyoto in the first place, are they going to repeat the folly?

Hard to take Groser seriously here, while what he is saying to please the world is untrue for the reasons I have said I also believe when he talks of wanting another Kyoto he is being disingenuous. This is because NZ has amended the ETS legislation to allow offsetting from 2013, which means when a forest is cut down it can be replanted somewhere else.

The credits earned by offset forest are not valid under Kyoto, the rest of the world do not see these as genuine carbon credits so they can not be used to offset any post Kyoto liability. NZ would not allow offsetting if it believed it was going to have to meet future international liabilities so I think Groser is being dishonest with the people of NZ and the world.

Update just through from Durban

Groser might have just got us in a whole lot of trouble because the latest is that the USA has surprisingly agreed to come into an agreement which is a road map towards binding targets. There is a suggestion that Kyoto might be extended because of this which means NZ is in trouble because we will have to pay. This is because our net emissions have already increased to 1990 gross emission level so from 2013 or 2014 as they continue to track upwards we will be facing a deficit which will be increased when offset foresty plantings start.We will have to start buying international units from other countries.

Tim Groser has said he is happy for NZ to meet binding targets as long as other countries try to meet voluntary targets. These binding targets will cost us money, the voluntary targets will cost other countries nothing. The day $1 is paid offshore to meet our Kyoto liability is the day this Government has gone a step too far in this idiocy. Let it be a day they are never forgiven for.

This is great because it is giving us an opportunity to get our message about these emissions out there. Act has a fairly strong rural influence on the list and on the Board so they are pushing Brash on this issue.

This is what he said at the Party launch

Indeed, there’s a strong argument that biological emissions don’t add to greenhouse gases at all: every unit of carbon emitted by pastures, crops and animals was first absorbed from the atmosphere.

As far as I know he is the only party leader saying this

I did send Claire an email asking her where did she think the carbon came from, and suggested a school science book might help her  and I also told her that the billions of dollars Norman claims are being spent on subsidies to emitters don’t exist, and that he was basing his economic policy on cancelling these non existent subsidies.

I haven’t heard back.

The interesting thing is that lots of the comments she got on the website agreed with Brash, which means our message is getting out there. Brash might be the only part leader to have studied this subject but the others might have to look at it now which will be good for our cause.

To see article and comments click here

We have had more success getting mainstream with a radio interview I did with Larry Williams on Newstalk ZB.

The focus was on election spending and Larry was interviewing me about Labour’s claim that it is going to get $800m from farmers to fund its R & D policy.

The problem with the ETS is that few understand it, including most journalists, and that is why the journalists don’t challenge Phil Goff on his claim. I explained to Larry and the listeners that when farmers have to pay for their emissions they will have to buy things called NZ Units from someone like a forester. The forester is given these NZ Units by the Govt on the basis of one NZU for every tonne of CO2 they are supposed to have sequestered. The foresters will get the $800m off the farmers, it does not go to the Government.

The Govt gives out these NZ Units at no cost to them or the taxpayer. There is no limit to how many they give out, as the ETS is a cap and trade scheme without the cap. If they want more NZ Units they just go to the photocopier and print more.

What most people don’t seem to understand is that until livestock emissions are brought into the ETS there is no cost to these emissions, so farmers are not being subsidised by the taxpayer. It is like saying that from 2015 every time someone crosses the road they will have to pay a $1 to the Govt as a tax. Until 2015 no one has to pay anything, the fact that no one is paying now does not constitute a subsidy because the liability does not exist yet.

I wasn’t able to explain our main argument about the harmless nature of livestock emissions because that was not the focus of the interview, but Larry did read pre interview a 2500 word outline I wrote explaining everything from the mechanism of the ETS, Kyoto, the harmless nature of bio emissions and more. So I am hopeful he will contact me in future about these issues if they come up.

Not normal to comment on general politics as I am sure we have all political party’s supported by our membership, but I will have a go without upsetting everyone.

Labour and the Greens have virtually declared war on farmers with Goff’s ETS scheme expected to cost farmers 30 to 50 % of net income and the Labour Green lots’ water policy another $50000 per year I believe.

National has signalled it may delay agriculture’s entry of bio emissions into the ETS further. This is nonsense, they should be removed. Farmers need certainty like any business, Nick Smith said this when justifying leaving agriculture in the ETS, yet now he has switched from promoting certainty to promoting uncertainty for 3 more years at least. If he is too scared to remove bio emissions now with National high in the polls, can you imagine how scared they will be when the next review occurs in 2014 and National is seeking an unlikely 3^rd term, scary stuff.

That is why what we are doing is so important, if National survive this election we have 3 years to change their mind and get livestock emissions entry to the ETS not delayed but removed. Our study will help that. Once Labour get back in, and they will one day, our job will be harder. Having said that I still find it incredulous that National is so timid on this, they know what we say about the science is right. Leighton Smith said on his radio the other day that any Nelson voters who voted for Nick Smith were not welcome as his listeners. It was a little tongue in cheek but underlining it was an honest feeling that Smith has and is doing NZ incredible harm. Mind you why is his boss letting him?

I received a phone call from Feilding, apparently  the new National candidate there is on record rubbishing the ETS for the scam that it is. Any farmers in the area might want to go to the next candidates meeting and ask him some curly questions.

NZ First want to dump the ETS. This is a bit rich considering it was only because of the support they gave to Helen Clark in the dying days of her government, that we got an ETS. I think it was a trade Peters did so as not to get fired for lying.

The Conservatives want to dump the ETS and so does ACT. ACT is the only one of these two likely to be able to achieve anything, thanks to a cup of tea in Epsom. I have been feeding Don Nicholson information, he is their Primary Industry spokesman, and he and the other farmers on the list (including me) are pretty determined to get bio emissions removed from the ETS permanently.

Having said all that, we don’t only want a political resolution, we want a scientific one to achieve the certainty that no political party will play cat and mouse with farm bio emissions ever again. The fund raising is going well. Lots of interest.