Submission to Select Committee reviewing the bill
July 2019
Fundamental Recommendation
That the 2050 target in the legislation be defined in terms of ‘net’ methane emissions rather than ‘gross’ methane emissions.
Proposed Amendment
That all references to biogenic methane emissions in Clause 5O be deleted.
In particular the current proposed clause 5O
5O Target for 2050
(1) The target for emissions reduction (the 2050 target) requires that—
(a) net emissions of greenhouse gases in a calendar year, other than biogenic methane, are zero by the calendar year beginning on 1 January 2050 and for each subsequent calendar year; and
(b) gross emissions of biogenic methane in a calendar year—
(i) are 10% less than 2017 emissions by the calendar year beginning on 1 January 2030; and
(ii) are at least 24% to 47% less than 2017 emissions by the calendar year beginning on 1 January 2050 and for each subsequent calendar year.
(2) In this section, 2017 emissions means the gross emissions of biogenic methane for the calendar year beginning on 1 January 2017.
Should be amended to
5O Target for 2050
(1) The target for emissions reduction (the 2050 target) requires that—
(a) net emissions of greenhouse gases in a calendar year, other than biogenic methane, are zero by the calendar year beginning on 1 January 2050 and for each subsequent calendar year; and
(b) gross emissions of biogenic methane in a calendar year—
(i) are 10% less than 2017 emissions by the calendar year beginning on 1 January 2030; and
(ii) are at least 24% to 47% less than 2017 emissions by the calendar year beginning on 1 January 2050 and for each subsequent calendar year.
(2) In this section, 2017 emissions means the gross emissions of biogenic methane for the calendar year beginning on 1 January 2017.
So that it reads:
5O Target for 2050
The target for emissions reduction (the 2050 target) requires that net emissions of greenhouse gases in a calendar year are zero by the calendar year beginning on 1 January 2050 and for each subsequent calendar year.
It will also be unnecessary to define ‘biogenic methane’ in Section 4(1).
Short Justification
There is no need to separate biogenic methane from other emissions (including non-biogenic (thermogenic) methane).
It penalises farming unnecessarily;
It involves arbitrary targets;
It overachieves the stated aim of the proposed legislation, and
It makes the legislation and its implementation overly complicated;
Background
Methane is a greenhouse gas which contributes to global warming. It is unusual in that its half-life is relatively short – 10 to 12 years – which means that (biogenic) methane being emitted in 2019 while the legislation is being passed will make virtually no contribution to global warming by the target date of the legislation (2050).
This is because of the nature of the methane cycle. The breakdown from livestock methane is, in effect, to nothing. Its carbon came from atmospheric carbon-dioxide converted into grass, eaten, ruminated, belched and as methane breaks down, eventually returned to atmospheric carbon-dioxide, completing the cycle.
This is already happening. Gross methane emissions from livestock have been stable for about four decades. As a consequence, for some time net livestock emissions – that is, current gross emissions offset by past emissions breaking down – have been near zero; sometimes slightly positive, sometimes slightly negative.
(The methane cloud generated from New Zealand livestock emissions is about 13MTs (million tonnes) of methane. In 2017, around 1.1MTs of it broke down into atmospheric carbon-dioxide. Meanwhile our livestock belched another 1.1MTs – almost exactly the same as the breakdown tonnage.)
Measuring, as the proposed legislation currently does, biogenic methane emissions in gross terms and ignoring the offsetting breakdown of past biogenic methane emissions does not make sense in terms of the purpose of the bill while also complicating its implementation.
Longer Justification: It Penalises Farming Unnecessarily
The farm sector may reasonably ask why other sectors are entitled to use offsets to their emissions while farmers are not. For instance, a motorist using petrol which emits carbon dioxide is permitted to use carbon sinks (such as trees) to offset her or his contribution to global warming.
Farming is also penalised compared to industry sources of non-biogenic (thermogenic) methane, which in the proposed legislation is treated in net terms. Why the legislation makes the distinction is unclear.
It is not at all evident – fair or wise – that the farm sector should be asked to bear a higher share of the burden of New Zealand’s campaign to eliminate net greenhouse gas emissions.
Longer Justification: It Involves Arbitrary Targets
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Leaving aside whether it is a good principle to include specific quantitative targets in legislation (and the rather odd phrase ‘ at least 24% to 47%’, for the significance of last two words is unclear) the targets are, at best, guesstimates and contestable. They assume certain scientific advances which may, or may not, come to pass.
It would seem unwise – if not heroic – to project scientific achievements three decades out, let alone to also legislate any such projection.
Longer Justification: It Overachieves the Stated Aim of the Proposed Legislation
The purpose of the amendment is zero carbon emissions by 2050. The effect of the legislation, if successful, will result in negative net emissions for New Zealand by that date.
The reason is that emissions which are not biogenic methane will be in balance, but biogenic methane’s contribution will be negative, so that, overall, net emissions will be negative.
If the real purpose of the proposed amendment is that New Zealand should be a negative contributor by 2050, that purpose should be made clear, perhaps by replacing the ‘zero’ in the bill’s title by ‘negative’.
Longer Justification: It Makes the Legislation and Its Implementation Overly Complicated
The legislation is long and complicated which adds to the difficulty of implementation. The proposed amendment deletes ten unnecessary and complicating lines.
Moreover, by focusing on net emissions for all greenhouse gases rather than treating some GHGs differently from others, the proposed target is more understandable.
Conclusion
The recommended change makes the legislation more coherent and the implementation of the amendment’s intention simpler.
It does not exempt biogenic methane from the exercise. Insofar as livestock emissions can be reduced, they will make the overall target easier. But any reduction needs to be approached in the light of the application of scientific developments. They will, no doubt, be carefully monitored by proposed Climate Change Commission.
There is nothing in the submission which denies the urgency and importance of the world limiting climate change by reducing the warming effects from greenhouse gas emissions.
References
The underlying technical paper is
New Zealand’s Methane Cloud
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