Submission

Kyoto Protocol to the United Nations Framework Convention on Climate Change

Rural Women New Zealand represents the interests of more than 4000 members from over 300 branches located in rural areas throughout New Zealand. Our organisation works at local, regional and national level to strengthen the social, economic and environmental wellbeing of rural communities.

Rural Women New Zealand:
· agrees that New Zealand has a clear and direct interest in supporting efforts to minimise climate change;
· agrees there are many ways we can reduce emissions;
· agrees that New Zealand can and should put in place a practical programme of domestic policies to reduce net emissions;
· agrees that measures to limit net emissions be implemented in a manner that demonstrates environmental integrity and leadership, while keeping as low as possible the social and economic costs of measures to achieve that.

Rural Women New Zealand:
· notes that the guesstimated 1990 emission level in New Zealand was 73 million tonnes;
· notes that the growth in emission levels from 2008 - 2012 is guesstimated (plus projected increases; less projected reductions) at 30-55 million tonnes;
· notes that the growth in credits from 2008 - 2012 (from forest plantings) is guesstimated at 110 million tonnes;
· agrees that this amount is indeed larger than projected excess emissions, and in fact represents a credit of the order of 55-80 million tonnes;
· notes that this is more than sufficient to meet the objective of reducing net emissions to 1990 levels during the commitment period;
· notes, with surprise, the contrary suggestion that New Zealand will not be able to meet its obligations;
· notes, with further surprise, that while the Government does indeed agree that New Zealand has more sinks than emissions, the Government wishes to sell the credits; and then - in order to account for excess emissions - to buy them back.

Rural Women New Zealand is especially interested in climate change discussions relating to the agricultural sector. Rural Women New Zealand:

· objects to statements in the Climate Change Consultation Paper that we are still (our emphasis) heavily dependent on primary industries (with connotations of a remnant but persistent state). New Zealand is (our emphasis) heavily dependent on primary industries (full stop);
· agrees that data concerning agricultural emissions is highly uncertain;
· agrees that measuring methane emissions from sheep (some sampling work done), dairy cows (some sampling work done) and beef cattle (barely grappled with as yet) presents significant practical difficulties;
· notes therefore that guesstimates of agricultural emissions of 73 million tonnes in 1990 (54% of the total) are highly uncertain and unreliable; and that guesstimates of increases ranging from 0-25 million tonnes during 2008 - 2012 are even more uncertain and unreliable;
· notes that technologies for reducing emissions are still largely at the developmental stage;
· supports continued public good research into rumen biology with twin objectives of reducing methane emissions and improving feed conversion efficiencies;
· agrees that calculations of emission charges would be "problematic" in agriculture;
· rejects any suggestions of imposing carbon taxes by applying "proxy" rates instead;
· agrees that agriculture is a key economic sector; and that the "market based" policy options proposed in this document do indeed place its competitiveness at risk.

In relation to the proposed Climate Protection Bill, we make the following points:

· "the crown will be able to buy and sell on the international market to ensure New Zealand holds sufficient emission units to cover its emissions for the period 2008 - 2012".

New Zealand's carbon credits are estimated to be 55-80 million tonnes in excess of emissions through this period: we see no necessity for this provision.

· the criteria against which domestic policy options will be tested include "environmental integrity, i.e., how effective a policy will be in reducing greenhouse gas emissions globally" (our emphasis).

Rural Women New Zealand recommends that, if the Government is indeed "committed to leadership on this issue as one way to convince others that actions is needed" then the first test of environmental integrity is how effective a policy will be in reducing greenhouse gas emissions domestically.

· the first over-arching issue is presented as "who" is responsible; following on with how should that responsibility be divided up.

Rural Women New Zealand recommends that the first over-arching issue is "what" is our carbon status and "what" is the scope of the task; followed by "what" are the options for moving forward.

The Climate Change Consultation Paper acknowledges the uncertainties, the estimates, the lack of robust data, the difficulties of measurement and monitoring; but then skips right over them in favour of polarising the discussion into whose fault is it and who should pay.

· the Consultation Paper notes that there is already a substantial amount of work underway to address New Zealand emissions and lists a number of policy initiatives.

Rural Women New Zealand supports initiatives to reduce emissions through:
· the National Energy Efficiency and Conservation Strategy
· the upcoming Renewable Energy Strategy;
· the National Waste Minimisation and Management Strategy;
· the proposed New Zealand Transport Strategy;
· public good research; and
· public education

We agree that New Zealand has a track record for the kind of creative thinking that is needed to develop the new technologies needed in these areas; and we agree on the potential for significant new business and export opportunities.

· having noted these initiatives, the Consultation Paper focusses its attention almost exclusively on "market mechanisms".

Rural Women New Zealand rejects this approach. Serious and complex matters require careful and complete attention. The credibility of the Government's aspirations to environmental leadership are seriously undermined by short-circuiting analysis of the full package of domestic policy options in favour, again, of dwelling at length on "who pays".

· the Government has already decided that the objective for 2008 - 2012 should be to limit emissions "in a manner that demonstrates environmental integrity and leadership, while keeping as low as possible the social and economic costs of measures to achieve this".

The Government has also decided that policies "should offer broadly comparable incentives to reduce emissions across different sectors".

This second statement conflicts with the first; and conflicts with criteria separately listed referring to environmental integrity and economic efficiency.

Rural Women New Zealand does not accept, prima facie, that incentives should necessarily be similar across sectors.

· the economic efficiency criteria propose that "maximising benefits and minimising costs to the economy as a whole (our emphasis) is a key consideration".

This section then goes on to repeat the "comparable incentives across sectors" theme.

Again, this second statement is in conflict.

· "Equity": Rural Women New Zealand supports notions of "fairness". We are confident that suggestions of taxing farmers on averaged, approximated extrapolated proxy calculations based on sample bags of hot air will indeed prove to be just that.

The alternative is to deeply offend fundamental principles of citizen taxation.

· "Transaction Costs": Rural Women New Zealand agrees these are an important aspect of economic efficiency.

The proposed superstructure of national and international "market mechanisms" has been mooted in an attempt to force increased progress in emissions reductions. Transaction costs of this strategy must be fully accounted for; and assessed alongside the benefits of directly applying equivalent levels of funding to specific targetted measures (e.g. increased public good funding into rumen biology).

In conclusion, Rural Women New Zealand recommends that Government set aside the rhetoric of national and international market mechanisms for emissions trading and return to first principles. Rural Women New Zealand:

· supports a practical programme of domestic policies to reduce net carbon emissions over the long-term;

· supports continued public good research into reducing agricultural emissions alongside other policy initiatives in the energy, waste and transport sectors;

· notes that projected carbon credits significantly exceed projected carbon emissions during the period 2008 - 2012;

· rejects proposals for a carbon tax on agricultural emissions;

· recommends that the Government does not proceed with ratification of the Kyoto Protocol with its associated convoluted, cumbersome and expensive commitments.

Rural Women New Zealand wishes to be heard on this submission.

Ellen Ramsay
National President
Rural Women New Zealand