We wish to ensure that the cyclical nature of farm emissions of methane is recognized in any emission pricing scheme and that a whole farm system approach is adopted when quantifying any impact livestock on New Zealand farms may have on global temperatures. No farmer should have to pay for emissions which do not alter the composition of the atmosphere nor any activity which does not increase global temperatures.

We the undersigned demand of the Government, He Waka Eke Noa, Dairy NZ, Beef and Lamb and Federated Farmers that any farm emission pricing scheme must adhere to the following principles and meet these requirements:

#   The CO2 equivalent system must not be used to quantify or measure emissions. It has no scientific credibility.

#   Any farm emission measuring system must recognize the cyclical nature of farm emissions and be in real greenhouse gases i.e. methane and nitrous oxide.

#   All emissions must be measured and accurate to that farm and verifiable within a set certainty range as yet to be determined

#   It must be acknowledged that emissions of ruminant methane that are stable are not causing any emission of any greenhouse gas which is increasing the atmospheric concentration of methane.

#   It must be acknowledged that the main reason to reduce methane emissions according to the Climate Commission is to offset CO2 emissions.

#   The only pricing mechanism to encourage reductions in ruminant methane on a farm with stable methane emissions must recognize that farmers are being required to subsidise CO2 emitters and that such encouragement be in the form of a payment made to that farmer

#   The only pricing mechanism that will require payment from farmers for methane emissions will be for farms with increasing methane emissions above a 2017 base rate on conditions set out in this petition.

#   The IPCC pathway scenario that has been adopted for methane of a reduction of 24 -47 % must be used for nitrous oxide as well. This calls for nitrous oxide emissions to be between +1 and -26% by 2050

#   That any costs placed on farmers must be equivalent to or less than the quantified benefits that will accrue to farmers by the expected reduction in global warming. These costs and benefits must be independently verified.

#   There will be no requirement for farmers to pay for emissions of methane above the base rate until there is substantial refutation of evidence, published in the refereed scientific literature that states that water vapour dominates methane in concentration and absorbency to a degree that renders methane incapable of impacting temperature to any significant degree.

#   Actions must be consistent with Article 2b of the Paris Accord and must not result in carbon leakage.

Farmers must be credited with any of the following that apply to their farm:

*   Maintaining soil carbon rates higher than alternative land use e.g. forestry.

*   Any increasing soil carbon identified on that farm

*   Carbon stocks in base pasture and other vegetation

*   All removals of CO2 from increases in vegetation stocks above a base rate.

*   The methane reduction impact of producing transpiration from farm pasture contributing to the production of the OH radical which breaks down methane.

*   Any global cooling impact that can be established from the finding by CERN that amines produced by ruminant farming cause the formation of planet cooling clouds.  

*   All livestock emissions associated with animal by-products used for biofuel, eg tallow