Overseer: greenwashing nutrient pollution from intensive agriculture for 20 years

“Overseer” and dairy farming have been in the news a lot lately. ("Govt to assist development of next-gen waterways protection tool", Radio NZ, 11 August 2021, "Hawke's Bay farmers 'frustrated' by review of regulatory tool Overseer", NZ Herald, 11 August 2021 and "Major tool for managing farm pollution gets a fail from reviewers", Stuff, 11 August 2021)

What is Overseer?

According to a Government media release of 11/08/21;

"Overseer and its predecessors have been used for 30 years by many New Zealand (dairy) farmers to estimate nutrient budgets and understand how nutrients are cycled on-farm. Recently, it has been used by a number of Regional Councils as part of their plans and consents to manage nutrient loss to rivers and groundwater.“

An independent expert peer review of Overseer has just been completed and it’s conclusion is that Overseer is not fit for purpose and is unfixable.

The Review conclusion (pages 95 and 96) is;.

"...we do not have confidence that Overseer’s modelled outputs tell us whether changes in farm management reduce or increase the losses of nutrients, or what the magnitude or error of these losses might be."

Why was there an independent expert peer review?

Because the Parliamentary Commissioner for the Environment Simon Upton wrote a report asking for a review in 2018.

What was the original concern of Simon Upton?

Simon Upton said (on page 7);

“This investigation is about Overseer’s fitness for purpose in a regulatory context. Can we be confident that its estimates of nutrient loss provide regional councils with a basis for making regulatory decisions, notwithstanding the simplifications and approximations that are inevitable in having recourse to models?”

Upton was also concerned that privately owned proprietary software was not transparent and neither it’s model structure or results had been independently verified.

So what’s the big issue now this independent peer review has been released?

Well the answer is “No” to Simon Upton’s question; can there be confidence in Overseer’s estimates of nutrient losses when regulating agricultural intensification under the RMA?

However, the Government response is to fudge the issue. In the Beehive media release they down play the peer review conclusion in bullet points.

• Report finds shortcomings in Overseer nutrient management tool
• Overseer will be supported while a next generation of the tool is developed and/or additional tools are made available

Minister for the Environment David Parker states;

“Despite its shortcomings Overseer has been a useful tool to build awareness and influence practices to manage nutrient loss at the farm and catchment level”

Minister for the Environment David Parker is minimising and therefore denying the peer review's conclusion. Parker in an interview with Radio NZ stated that Overseer isn't fatally flawed. Look for my underlining

"The Overseer tool has been used by Regional Councils to estimate what the nutrient pollution coming from a farm into water ways and it turns out there's some problems with it. That doesn't necessarily make it fatally flawed but those problems are significant."

And he states that Overseer can indicate the relative change in nutrient flows after a change of farm practise:

"We need to look at whether its still got really sound utility as a regulatory tool on say on a flat dairy farm on which it probably is quite accurate on and lets face it that's where most of our dairying is on flat land but there are some councils who instead of using it just to measure the relative performance of a change on farm because even if its not accurate as to the absolute number it does give you an indication if you change your practice of things getting better or worse and that's very useful."

What’s wrong with what David Parker is saying?

The peer review gave a black and white answer. Overseer can't give reliable estimates of either relative or absolute nutrient losses from farms. Yet David Parker made a 180 degree contrary statement to Radio NZ that Overseer can usefully estimate relative nutrient losses from farms.

Parker and the Government need to accept that Overseer is fatally flawed. It isn't fit for purpose for regulating agricultural intensification. Parker is treating the issue as shades of grey. There are problems, but these can be addressed, work can be done, and Overseer can be supported and improved.

Parker's assertions completely fly in the face of the peer review's conclusions. I don't see how any sufficiently informed reader of the peer review could possibly see the Government work program and Parker's statements as logical and valid responses to the peer review's conclusion.

So how does this fit in with the context of resource consents and RMA regional plans?

In terms of the regulatory context that Simon Upton was concerned about, I draw three conclusions;

1. Any resource consents that have Overseer conditions - those conditions are now unenforceable on the consent holder.
2. The regional council process that led to the granting of consents for agricultural intensification relied for their conclusion of "adverse effects mitigated" on the inappropriate use of a fatally flawed model.
3. Any regional plan rules (i.e. Manawatu Whanganui Regional Council’s One Plan) where Overseer was used to manage and therefore allow intensification were based again on the inappropriate use of a fatally flawed model.

What are the environmental organisations saying?

I agree with Greenpeace who said that Overseer had supported dairy conversions and intensification. Overseer was an excuse for allowing too much synthetic nitrogen fertiliser and too many cows to be crammed onto the land, despite worsening freshwater quality and drinking water contamination. Overseer justified the over-application of synthetic nitrogen fertiliser and had been embedded in resource consents.

“From the start, Overseer has been peddled by fertiliser companies as a means to sell more fertiliser – the very thing that is wrecking rivers and driving intensive dairying.”

“That’s no surprise given that Overseer is managed by the fertiliser companies that make a killing off farmers dumping synthetic nitrogen fertiliser onto the land,”

Overseer has been unequivocally unmasked as not just an imperfect tool used inappropriately in the RMA context to justify more intensive horticulture and dairy farming, but as propaganda for environmentally damaging agricultural intensification.

David Parker’s statements and intentions to continue with Overseer with incremental improvements show he is just a cheerleader for agricultural intensification and it’s ensuing adverse nutrient pollution of our freshwater bodies.

Well that sucks. What should be done about it?

I think the environmental NGOs need to get a declaration from the Environment Court that Overseer is unusable in any consenting or planning context. The Government needs to be stopped from propping Overseer up with incremental fudges so it can still act as a fig-leaf of faked mitigation for agricultural intensification.

An appendix on the independent peer review of Overseer

The citation for the independent peer review is Overseer whole-model review Assessment of the model approach, MPI Technical Paper no: 2021/12 Prepared for the Ministry for Primary Industries and the Ministry for the Environment by the Science Advisory Panel ISBN No: 978-1-99-100936-4 (online) ISSN No: 2253-3923 (online)

Here are the relevant conclusions from the independent review.

On page 90 in para 10.2.3 "The limitations of the overarching structure of Overseer notably impair the ability of the model to produce trustworthy absolute or relative predictions (see 10.2.1). These challenges with the overarching model structure are likely to overshadow any appropriately modelled behaviours represented by the model microstructure."

On page 93 "As highlighted in 10.2, Overseer’s structure, data, and behaviour suggest predictions of absolute and relative nutrient losses are likely inaccurate."

On pages 95 and 96 a summary of the panel's findings and conclusion.

"Our core concerns are that Overseer:

• Is a steady state model attempting to simulate a dynamic, continually varying system;
• Uses monthly time-steps;
• Uses average climate data and, therefore, cannot model episodic events, or capture responses to climate variation;
• Does not balance mass;
• Does not account for variation in water and nutrient distribution in the soil profile;
• Does not adequately accommodate deep-rooting plants;
• Focuses on nitrate and omits ammoniacal nitrogen and organic matter dynamics; and
• Lacks consideration of surface water and nutrient transport, as well as critical landscape factors.

As a result of these concerns, we do not have confidence that Overseer’s modelled outputs tell us whether changes in farm management reduce or increase the losses of nutrients, or what the magnitude or error of these losses might be."

Summary of the Climate Change Commission's emissions budgets and policy '2021 Draft Advice for Consultation'

He Pou a Rangi/Climate Change Commission's report 2021 Draft Advice in graphics.

I mentioned the He Pou a Rangi/Climate Change Commission's report 2021 Draft Advice for Consultation" published on 31 January 2021 to my millenial colleague.

She asked if it has infographics?

Yes it does and hopefully they can help assist in providing a summary without anyone having to read either the 188 pages of the advice document or the hundreds of pages of the supporting evidence chapters.

First thing, let's get the citation right. "2021 Draft Advice for Consultation", He Pou a Rangi/Climate Change Commission, 31 January 2021.

It is a draft for public consultation until 14 March 2021. The report recommends three 5-year greenhouse gas emissions budgets to 2035 (and relevant policy) to the Government. To be finalised after submissions by 31 May 2021. The Government has to respond to it by 31 December 2021. So it will take all year.

The report adopts the Zero Carbon Act's approach of having a separate target for biogenic methane. Which is basically all of New Zealand's emissions from pastoral agriculture.

For the 'long-lived' gases (excluding methane from agriculture and waste), they recommend three 5-year emissions budgets out to 2035 and lots of policies to achieve them. The budgets mean a 26% decline in gross gases (excluding methane) and a decline of 36% in net gases (excluding methane) by 2035 from 2018. The ten percent difference being offset by exotic forestry carbon sequestration.

For 'short-lived' gases (agricultural methane plus waste methane), they recommend three separate 5-year emissions budgets to 2035. These represent less ambitious reductions in emissions - minus 16% to 2035 from the 2018 baseline

The summary 5-year budgets are to put Aotearoa on a path to 'net zero carbon' emissions by 2050. Absolute carbon emissions in 2050 will be millions of tonnes but they will be 'offset' to 'net zero' by forests storing carbon. There will be another round of three 5-year budgets for 2035 to 2050 to sort out the exact trajectory.

The forecast emissions pathways show a major decrease in transport emissions, modest decreases in agriculture and industry emissions, and major increases in carbon stored in forests.

The Commission have two emissions 'scenarios' to 2050; optimistic 'tailwind' and pessimistic 'headwind'. Both lead to net zero carbon by 2050.

For electricity generation, coal and oil have to be gone by 2030, gas is to be minimised, and wind generation increased a lot.

For food processing energy, coal is gone by 2035, diesel is squeezed, gas is halved and electricity and biomass generation are increased a lot.

For the dairy sector, methane emissions decrease marginally, milk fat production is stable, stock numbers drop very slightly through efficiency gains for each unit of dry feed. But - the Commission doesn't seem to know if dairying should be in the emissions trading scheme. Their recommendation to the Government is "Review regulatory regimes". This is very vague. A kick-for-touch response.

The whole point of having the Commission as an independent Crown agency is that it can make "free and frank" recommendations about applying politically sensitive policies such as carbon pricing to politically sensitive sectors such as the dairy industry. I find this quite disappointing.

For sheep and beef, methane decreases, meat production increases slightly, stock numbers drop through efficiency gains. But, again, the Commission doesn't seem to know if sheep and beef should be in the emissions trading scheme. They say "Review regulatory regimes". This is again a bit disappointing and a vague kick-for-touch.

Finally, James Shaw had asked the Commission how should Aotearoa's 2030 emission reduction target under the Paris Agreement work?

It's 30% below 2005 levels by 2030. The Commission says the target could be more stringent than the 5-year emissions budgets because credible international carbon credits could be imported. 'Credible' credits, they have to say that to distinguish them from the fake and fraudulent Russian and Ukrainian credits imported from 2013 as noted by the Morgan Foundation.

At the moment, there is no operative international carbon market. It also seems unlikely to happen under the Paris Agreement. The 'net zero by 2050' target incentivises countries to hold on to domestic carbon removals for offsetting their most emission intensive sectors. Any international sales (such as to Aotearoa) would only happen once domestic demand is met. A reliable credible supply of credits seems either unlikely to eventuate or alternatively be extremely expensive.

Dear Federated Famers and Dairy NZ Pasture grazing livestock do not mitigate climate change

Grazed and Confused? How much can grazing livestock help to mitigate climate change? was a research report prepared by the FCRN in 2017.

FCRN’s coordinator and the lead researcher Dr Tara Garnett further explains the argument in a post titled Why eating grass-fed beef isn’t going to help fight climate change hosted by The Conversation.

Here is the video explainer which I dedicate to New Zealand's industrial pastoral agricultural lobby - Federated Famers and Dairy NZ.

Inaction on Agriculture - pastoral agriculture gets feather bedded into the emissions trading scheme

At 4:58 p.m., two minutes before the deadline, I uploaded my submission to the Ministry for the Environment's In Action on Agriculture consultation.

This is about the Government's response to the first report of the Interim Climate Change Committee. The proposal is extremely disappointing. It involves 'feather bedding' New Zealand's pastoral agriculture sector into the emissions trading scheme by giving the public a Hobson's choice of two completely compromised proposals.

First weak option; agriculture joins the emissions trading scheme from 2025 with the weakest obligation possible (i.e. after a free allocation of emissions units equal to 95% of emissions - and at the most complex way possible - at farm level.

Or - the second weak option; the industry runs their own scheme, also based on a free allocation of emissions units equal to 95% of emissions at farm level from 2025.

The Ministry helpfully provides a set of questions submitters have to navigate through. Some of which pre-suppose certain limits to the answers. I have underlined each question and then provided my response.

1. What is the best way to incentivise farmers to reduce on-farm emissions?

I do not agree that this is the correct question to ask. The framing of the question pre-supposes the answer. The more objective, neutral and policy-relevant question is "What are the best policies to reduce emissions from the pastoral agriculture sector?"

I consider that the proposals are compromised and inadequate responses to the urgent need to reduce agricultural emissions. They are clearly not fit for purpose.

The proposals are so weak in terms of price, scope, timeliness, exceptions, excessive unit allocations, complexity and difficulty of implementation - that they are worse than doing nothing.

The proposals, if implemented, would undermine the role of the yet to be established Independent Climate Commission by predetermining the agricultural emissions targets and 5 year budgets.

I recommend that neither proposal is accepted.

I recommend that pastoral agriculture be entered into the emissions trading scheme at processor level from 2020 with no free allocation of emissions units.

2. Do the pros of pricing emissions at farm level outweigh the cons, compared with processor level, for (a) livestock and (b) fertiliser? Why or why not?

Even the consideration of pricing emissions at farm level is the incorrect framing to apply. Farm level pricing would not be fit for purpose. It is highly problematic in terms of price, scope, timeliness, exceptions, excessive unit allocations, complexity and difficulty of implementation. Processor level pricing is efficient and sends an effective emission price back through the value chain.

3. What are the key building blocks for a workable and effective scheme that prices emissions at farm level?

There are no feasible building blocks for a workable and effective scheme that prices emissions at farm level. The framing of this question is not appropriate as it presupposes the outcome.

The notion of a "workable and effective scheme that prices emissions at farm level" is currently a figment of the imagination.

From the point of view of establishing reasonably effective policy, it has become an unrealistic and unachievable expectation of 'best' policy. In this consultation, it has the role "letting the perfect be the enemy of the good" and being given as a reason to try to implement the most difficult , the most time-consuming and most impractical point of obligation.

4. What should the Government be taking into consideration when choosing between Option 1: pricing emissions at the processor level through the NZ ETS and Option 2: a formal sector-government agreement?

The Government should be considering the interplay of the 2019 'zero carbon bill' debate and of the dogged determination of the pastoral agriculture interests to avoid any regulation of their emissions.

I question the utility of negotiating a detailed ETS/emissions policy agreement with pastoral agriculture sector, when the pastoral agriculture organisations do not accept or agree with the higher level goal - the proposed 2050 methane target in zero carbon bill. How can there be a 'partnership' approach when the partners do not even agree what the methane target is?

Dairy NZ, Federated Farmers, and Beef and Lamb NZ have a uniform and consistent position of opposing any methane target above 'business as usual' incremental changes in efficiency. The only mitigation they will tolerate will be technology-based 'supply side' reductions in intensity in per unit of output. Such technology has been researched at the tax payers expense for about a decade.

In short, their position on New Zealand's 'zero carbon' targets, is that there should be no absolute reduction in methane emissions, no absolute reduction in stock numbers and no changes in land use in the pastoral sector to lower-emission land use.

Given the firmly and repeatedly articulated viewpoint of the pastoral lobby, I was very surprised on 16 July 2019, to read about Ministers Shaw and O'Connor announcing "Consensus reached on reducing agricultural emissions".

This must a different definition of 'consensus' than the one from my dictionary. The Ministers and the pastoral lobby have opposite views on the proposed 2050 methane target in the zero carbon amendment bill. How can a partnership compromise proceed without agreement on the basic methane target?

The tactics of the pastoral agricultural lobbyists are clear; to delay policy timing/implementation by promoting the problematic farm-level obligation and to minimise policy scope by including minimal targets and exceptions/discounts through excessive free allocation of units. Then wait out a period of 'wet bus ticket' compromised and ineffectual policy until it is removed by the next National-led Government.

Todd Muller of the National Party is on record that the next National government will lower the 2050 the methane target (speech to Federated Farmers Taranaki AGM in Stratford on 24 May) and that National will never put pastoral agriculture in the emissions trading scheme (interview with Jack Tame of 'Q & A' on 23 July).

If the proposed 2050 methane target is lowered to about 20% over 30 years (the same as past efficiency gains), as Dairy NZ, Federated Farmers, and Beef and Lamb NZ have submitted, I absolutely question if is there any point adopting either proposal.

Research into mitigation of agricultural emissions

The Productivity Commission (2018) on pages 312 and 313 notes that the Government invests roughly $20 million each year into mitigation research, most of which helped fund three research centres.

1. The Pastoral Greenhouse Gas Research Consortium, set up in 2003.
2. The New Zealand Agricultural Greenhouse Gas Research Centre, established in 2009.
3. The Global Research Alliance on Agricultural Greenhouse Gases (GRA) in 2009.

As a taxpayer, I do not begrudge the significant investment of tax that has been invested in researching mitgation technologies for methane and nitrous oxide. I accept that the benefits could help many countries. However, I do not see that research can be a substitute for mitigation for an indefinite time.

I consider that indefinite time has passed and there is a 'quid pro quo' that applies. Given the research funding, and given the past decade-long exemption of agriculture from the ETS, I think it is now unconscionable for pastoral agriculture to be evading emissions reduction policies. I consider this applies whether the evasion of policies is - by seeking a 'zero methane' target or by seeking 95% free allocation of units or by seeking farm-level point of obligation. This just isn't acceptable.

5. As an interim measure, would Option 1: pricing emissions at the processor level through the NZ ETS with recycling of funds raised back to the sector to incentivise emissions reduction or Option 2: a formal Government-industry agreement for reducing emissions be best? Why?

What will be best will be emissions pricing implemented on the basis of standard economics principles such as 'pricing the externality', 'polluter pays', 'finite emissions cap' and 'processor level point of obligation'.

I recommend that pastoral agriculture be entered into the emissions trading scheme at processor level from 2020 with no allocation of emissions units.

6. What additional steps should we be taking to protect relevant iwi/Māori interests, in line with the Treaty of Waitangi?

The Ministry should already have carried out a suitable process of consultation with iwi and hapu. The consultation document does not mention any consultation. I find that unsatisfactory. The Ministry should be taking into account the principles of the Treaty of Waitangi. That requires, at a minimum, consultation. The Productivity Commission 2018 report into the low emissions economy discussed issues affecting iwi and hapu and it is a poor reflection on the consultation document that it doesn't.

7. What barriers or opportunities are there across the broader agriculture sector for reducing agricultural emissions? What could the Government investigate further?

The main barriers to reducing agricultural emissions are the pastoral agricultural lobbyists Dairy NZ, Federated Farmers, and Beef and Lamb NZ and their preferred political party the National Party. Their positions and actions and statements show that they are a generation behind urban New Zealanders (and many farmers) in terms of responding to climate change. They say they accept the science and that it supports their position of no policy and no absolute reduction in emissions. And that they are already the world's most efficient farmers. They are, to coin a term, 'mitigation deniers'.

The Government should investigate "less cows" - which is otherwise known as 'demand side management' or changes in land use (to lower emissions uses).

The ICCC report only mentions the option of change in land use once in it's report. Todd Muller has even embarrassed himself in stating to TV One, to Radio New Zealand that Te Papa is not allowed to mention "less cows" in the context of a exhibition on declining water quality.

8. What impacts do you foresee as a result of the Government’s proposals in the short and the long term?

In the short term the implementation of either proposal will involve almost insurmountable practical difficulties that will result in no practical reduction in greenhouse gas emissions from pastoral agriculture.

Nor will the Government be thanked for it's compromise. It will only earn further scorn from the agriculture sector for 'imposing' an 'impractical' policy on them. There is nothing some agricultural interests like more than criticising governments and bureaucrats for not being 'practical'.

In the long term the implementation of either proposal will be remembered as yet another failed implementation of emissions pricing where the political lobbying of the sector's vested interests prevented effective policy.

New Zealands biogenic methane emissions and the not zero target

In the recently unveiled Zero Carbon Bill, or more correctly, the Climate Change Response (Zero Carbon) Amendment Bill, biogenic methane emissions get a separate and distinctly non-zero emissions reduction target.

What are these methane emissions? I thought I would do some graphical analysis.

First of all - definitions. The draft bill in Section 4 amended (Interpretation) defines biogenic methane as:

"...all methane greenhouse gases produced from the agriculture and waste sectors (as those sectors are defined in the New Zealand Greenhouse Gas Inventory)".

The New Zealand annual greenhouse gas inventory records three sub-categories of methane; methane from enteric rumination, methane from agricultural soils and methane from the waste sector. Waste sector emissions in 2017 were 95% methane, 4.12475 million tonnes and 5% of total gross emissions. That's a significant chunk of New Zealand's GHG emissions.

Why is the waste sector methane included? It's not sourced from agriculture. None of the advocates of the split-gas target, like David Frame or Simon Upton, made any arguments about waste sector methane. Also, the Productivity Commission in it's 2018 report Low Emissions Economy thought waste sector emissions could be feasibly reduced. (See page 451 of their final report; "Waste also represents a major mitigation opportunity.")

The methane from enteric rumination, from agricultural soils and from the waste sector and the total biogenic methane look like this.

The total biogenic methane emissions in 2017 was 40.34134 million tonnes. It's a crude point so here's a crude pie graph to make it, 40 million tonnes of biogenic methane is half of gross emissions (excluding landuse and forestry).

40 million tonnes of biogenic methane is more than twice the quantity of net emissions (including landuse and forestry). Net emissions are 41% of biogenic methane emissions.

This line graph shows how the biogenic methane emissions compare to gross and net emissions over the 1990 to 2017 period. In the early 1990s, biogenic methane emissions exceeded net emissions.

The amount of biogenic methane emissions exceeds all emissions attributed to the agricultural sector. So the 'split' gross target, in carbon dioxide equivalents, is less than a counterfactual target where all agricultural sector emissions are excluded.

For context, here is my preferred graph of all New Zealand's greenhouse gas emissions by sector.

This next graph below shows actual emissions and the split gas targets; biogenic methane to 10% less by 2030, and to either 24% to 47% less than 2017 by 2050.

Net emissions in carbon dioxide equivalents, after taking out methane, go to...well..zero of course in 2050. I have assumed that carbon sequestration from the land use and forestry sector is the same in 2050 as it was in 2017.

Note that from 1990 to 1995, the net emissions were less than the 2050 net zero carbon dioxide target. In other words, under the net zero split gas carbon dioxide/methane targets definition, New Zealand's greenhouse gas emissions were negative. Can anyone credibly argue that New Zealand's greenhouse gas emissions in the early 1990s were 'net zero'?

Now this final graph shows the targets scaled up to include gross emissions as well as net. Gross emissions must decline at the same rate as net emissions. As the difference between them is the carbon sequestration from land use and forests.

The key point here is that if the sequestration in 2050 is about 23 million tonnes (the same as in 2017) then the New Zealand 'net zero' target for gross emissions, is 50 million tonnes. That's still a heck of a lot of emissions.

The net zero/split gas target is not nearly as stringent as all the pundits seem to think. It is hard not to conclude that the waste sector methane has been moved to the less stringent methane target in order to make the carbon dioxide target larger in 2050 and therefore easier to achieve. This, unfortunately, seems to be another example of New Zealand's favourite climate change practice; achieving targets by creative accounting instead of reducing emissions.

Kevin Anderson on Irelands agriculture a lesson for New Zealand as well

While recently in Ireland Kevin Anderson also gave an interview to John Gibbons of the Irish website called Think or Swim.

The interview was recorded on Vimeo and is not on You Tube.

I am highlighting the first six minutes, because Anderson provides some direct answers to questions about giving agriculture special treatment such as leaving the sector out of emissions reduction policy. I would say that John Gibbons the interviewer is running domestic Irish narratives past Anderson. These narratives of inaction ("we are efficient", "we are too small", "the world needs food") are exactly the same in New Zealand. And Anderson's answers are just as relevant to New Zealand as Ireland.

These quotes start with the time in the interview and then the speaker.

2:11 John Gibbons. "Many politicians in Ireland, for example for the agricultural sector, would feel that we are a small country and we are recovering from the recession, so climate change is something we can deal with in 20 years time".

2:28 Kevin Anderson. "It completely misunderstands the science. It is the emissions that we put in the atmosphere now that matter. What really matters from the science perspective for temperature is the total quantity of carbon dioxide we put in the atmosphere; the carbon budget".

3:22 Kevin Anderson. "Ireland is a small part of the problem. Every part of the world is a small part of the problem. We hear that from every sector, the aviation sector says that, shipping says that, UK says this...You can divide the 100% of all emissions into any small numbers you want to. Using that as an argument is very false and very misleading".

3:58 John Gibbons. "A large portion of our emissions are attributable to the agriculture sector and under Food Harvest 2020 and Foodwise 2025 the Irish Government is undertaking a really large scale expansion of our ruminant-based agriculture. Their argument is that we can do it more efficiently than for example than the Brazilians who are clearing rainforest for beef and dairy. Is that a reasonable argument?"

4:30 Kevin Anderson. "From a climate change perspective it is clearly is not a reasonable argument. I am sure that any one who is making that argument is aware of the science, You cannot hold those arguments and keep to the commitments signed up for in Paris. The climate does not care about efficiency it only cares about absolute levels of emissions".

5:28 Kevin Anderson. "If we are really concerned about feeding the world then you would measure greenhouse gases in terms of nutrition or calories. What units of carbon dioxide per useful calorie do you produce? You would almost certainly have to move away from types of agriculture you have now that have innately high emission to other forms of agriculture that have much lower emissions of greenhouse gases per unit of output."

Kevin Anderson interviewed by John Gibbons on 16 March 2016 on Vimeo.

N.B. Yes Ireland really does have agricultural policies called Food Harvest 2020 and Foodwise 2025 and yes these are all about expanding production just like the New Zealand Government's Business Growth Agenda.

NZ greenhouse gas emissions march steadily onwards and upwards to 2030

A previous post was about an inaugural press release from the new Minister for Climate Change Paula Bennett.

From a public relations point of view Bennett's release aimed to sow and spread and cultivate 'talking points' that support the Government's preferred climate policy narrative. Which is of course that:

New Zealand is doing enough on reducing anthropogenic greenhouse gas emissions. New Zealand complies with its climate target obligations (via 'carbon credits') under the Kyoto Protocol and the UNFCCC. New Zealand has a moderated balanced emissions trading scheme and is doing research on agriculture and helping out in the Pacific and 'punching above our weight' in the international negotiations. All in all New Zealand is doing enough about climate change!

However, New Zealand (irrespective of who was in Government) has historically always sought to use loopholes to comply with emission reduction targets.

So for the talking point "We are meeting our obligations", the reality is "we used creative carbon accounting to obscure the fact that gross and net emissions of greenhouse gases have increased by 21% and 42% since 1990 respectively".

One of the reports referred to by Paula Bennett was the Second Biennial Report to the UNFCCC. This included a spreadsheet of data on projected New Zealand emissions until 2030. So of course I had to create a graph of it.

The creative commons license is CC BY-SA 4.0

I used the R programming language and the script is available on the Wikimedia Commons page. Anyone is free to use the graph, it is licensed under the Creative Commons Attribution-Share Alike 4.0 International licence, via Wikimedia Commons

Categorising the emissions by sectors of the economy makes it very clear that pastoral agriculture by far and away contributes more than any other sector. Emissions from agriculture are twice as large as the second largest sector, energy. I added the projected growth of each industry sector by percent since 1990; agriculture, + 22%; energy, + 19%; transport + 60%; industry + 101%; waste, + 4%.

The upward emissions trend is in stark contrast to the Ministry for the Environment's web page on how New Zealand is meeting the 2020 emissions reduction target.

An all-sectors NZETS should include agriculture

Gareth notes that Nick Smith has confirmed that agriculture will be unlikely to enter the New Zealand Emissions Trading Scheme.

"Hon Dr Nick Smith... explained the recent decision to indefinitely delay bringing agriculture into the scheme, stating the technology to do so practically does not yet exist"

Nick Smith yet again gets away with a soundbite of spin that is contradicted by the orthodox economic rationale for having an all-sectors all-units and all-gases international emissions trading scheme for greenhouse gases.

Just for the sake of argument, let's ignore the Sustainability Council's work on agricultural emissions reduction and assume that Dr Smith is correct that there are no practical technologies that will enable the agricultural sector to reduce emissions.

Let's go back to basics. Why do we even have emissions trading including all greenhouse gases across all sectors and across national borders?

The whole point is so that 'cheaper emissions reductions' can, in the short to medium term, largely carry the can for 'expensive emissions reductions', in meeting emissions limits or caps.

In economics speak, a sector of an economy with 'expensive emissions reductions' options is more or less just the same as a sector without practical technologies to enable reductions of emissions. Agriculture, for example, according to Nick Smith!

To paraphrase from another Nick, Lord Stern, in a well-functioning "deep and liquid" market for emissions permits, emitters with expensive mitigation options become buyers of permits and purchase permits from emitters with cheaper mitigation.

The role of the all-gases ETS, is to provide a wider variety of cheaper markets for emissions reductions, than would be the case in a single-gas ETS (such as a ruminant methane ETS, if there was one).

So the role of the emitting industries with fewer mitigation options (or more costly options) is to provide a flow of funds to reward those industries that have the cheaper emissions reduction options!

Logically, the lack of immediate practical mitigation technology in any one sector, is not a valid reason for leaving a sector out of an all-gases ETS.