The Climate Change Commission was formed in November 2019 to set the country’s climate targets which were legislated under the Climate Change Response (Zero Carbon) Amendment Act.

In February 2019 the Commission released its draft advice paper to the government with recommendations on how New Zealand, including the dairy sector, could reduce its emissions.

You can read the submission that Jersey Advantage has made on behalf of its members, below.
To view the Commission’s draft advice report click here.

Jersey Advantage Submission - in response to Climate Change Commission draft advice to government

This submission is made on behalf of farmer advocacy group Jersey Advantage in response to the Climate Change Commission’s draft advice paper to Government.

 Jersey Advantage and our farmer members from around New Zealand are broadly supportive of the paper’s intent to provide recommendations to mitigate Climate Change. Dairy farmers are already making positive changes on farm including:

• Improving herd and farm efficiency through better feed management and genetic improvement. This is the reason that dairy greenhouse gas emissions only doubled between 1990-2014 while cow numbers increased three times during the same period.

• More efficient use of nitrogen fertiliser with the support of proof of placement technology.

• Use of low-N feeds and crops.

• Use of low-N sires.

• Planting marginal land in trees.

 In particular, we are supportive of the following themes from the advice paper:

• We welcome the acknowledgment that methane should be treated differently from other long-lived gasses and does not need to decrease to net zero.

• We agree with the commission that to meet targets there will need to be significant and accelerated investment in R&D and extension services.

• We agree with the commission that Rural Broadband should be resourced and prioritised so that farmers have access to data and information to support decision-making.

• We support the use of He Waka Eke Noa in creating a farm-level pricing mechanism for agricultural emissions.

• We agree that, to meet our New Zealand commitments, all sections of the New Zealand economy will need to engage and make changes. We believe that broadly speaking, the balance between the different industries is about right.

• We agree that New Zealand can’t meet its obligations by just planting more trees. We need to reduce our overall use of carbon-generating fuels as well.

• We agree that the current incentives for planting commercial forests need adjusting in favour of more native forests. If the current projection of 1.1 million hectares of pines by 2030 materialises, this will have a devastating impact on the economies of many rural communities.  Native forests will have less economic impact as it is envisaged they will largely be planted on unproductive land such as gullies and steep slopes rather than whole farms being converted.

•  And, we agree that smaller woodland areas like shelter belts and riparian plantings need to be recognised as mitigation assets.

However, we have concerns around some of the recommendations for the dairy industry as outlined below:

We do not support an increase to the legislated 10% reduction by 2030.

Recent research showed that New Zealand dairy farmers have the world’s lowest carbon footprint – at half the emissions of other international producers1.

It is paramount that the productivity and profitability of our industry is not compromised in reaching our greenhouse gas targets, opening the door for less efficient producers with significantly higher emissions to fill the void in world markets.

The Commission has not considered how some of the options to reduce emissions are practically implemented on-farm, and we believe further assessment is necessary to understand the economic impact of meeting the emission budgets on the dairy sector.

Dairy farmers are already taking practical steps to reduce their emissions further. It is critical that targets are consistent to give farmers the confidence to invest in change on farm.

We do not support any wholesale reduction in dairy cow numbers.

New Zealand farmers operate under a variety of systems with a variety of stocking rates. A blanket reduction in stock numbers would see farms already running at optimum levels penalised and productivity impacted.

In particular, low input farmers running largely pasture based systems with optimal stocking rates would be disproportionately impacted if a blanket reduction in stocking rate was used. With reduced stocking rates these farms would have more supplement to harvest in seasonal peaks to maintain pasture quality. That in turn will have implications for harvest costs, CO2 emissions from additional vehicle use, and additional infrastructure required to store feed. It will ultimately impact farm profitability and land value if a farm is legislated to be perpetually under stocked.

We would welcome more clarity around how the modelled 15% reduction figure could be achieved, what proportion of this reduction would come from land use change, and what proportion would come from a reduction in dairy cow numbers versus other stock classes within the agricultural sector.

We do not support the use of cows per hectare as a measure of stocking rate.

Liveweight per hectare is a better measure to gauge a farms efficiency and model emissions. There is a significant difference in the liveweight of New Zealand dairy cows. Mature cows commonly range in liveweight from 375kg to 650kg, so to treat all cows the same is nonsensical.

Use of cows/hectare as a metric will incentivise farmers towards fewer but bigger cows fed at higher intakes, which will be counterproductive to achieving a reduction in farm emissions.

It is imperative that the Commission clarifies this point as a priority with much discussion in the industry already centering around stocking rates and stock size.

Further to this, there are numerous studies both in New Zealand and internationally that highlight the efficiency of Jersey genetics which are more commonly associated with cows around liveweights of 375-425kg. The Jersey breed is estimated to produce 9-13% more kilograms of milksolids per kilogram of dry matter eaten, and around 20-30% more kilograms of milksolids per kilogram of liveweight2,3,4,5.

We do not support the use of generic information in any farm-level pricing mechanisms as is currently being used in He Waka Eke Noa modelling.

He Waka Eke Noa has been tasked with establishing a means of calculating greenhouse gas emissions on farm in order to establish a pricing mechanism. In order to incentivise the right farmer behaviour to achieve the agriculture sector’s emissions targets the methodology needs to accurately estimate actual farm emissions, and be able to detect changes in emissions as a result of farmers’ mitigation efforts.

The current models used in Overseer and the Fonterra Farm Environment Reports use the following methodology:

1. Calculates the ME and therefore the kg DM/ha required for the herd’s milk production (kg MS/ha)

2. Calculates the ME and therefore the kg DM/ha required for maintenance and pregnancy

3. Adds these figures to determine the total DM intake of the animals on the farm (kg DM/ha). This figure becomes the basis for the methane component of the emissions due to the relationship between methane produced and feed eaten.

There are several issues with this methodology. Firstly step 1 (calculation of ME and therefore kg DM/ha required for production) uses a generic figure in the conversion of MJ ME to kg DM.

DairyNZ’s own data highlights that there is a difference in the MJ ME required to produce every kg MS based on the breed of the animal. The DairyNZ figures below show that a Friesian herd producing 1,000kgMS/ha will require 6.5% more MJ ME (at 11 MJ ME/kg DM) than a Jersey herd. These differences will be further exacerbated when genetic merit of an animal is factored in.

Secondly, the Fonterra model uses a generic regional liveweight figure in the calculation of step 2 (calculation of ME and therefore the kg DM/ha required for maintenance and pregnancy). This effectively penalises herds of low average liveweight and rewards herds of high average liveweight by over and under estimating (respectively) the ME and therefore the kg DM requirement.

The Overseer model is more accurate and uses breed, stock class and the number of animals per hectare to calculate the kg liveweight per hectare. However, given the breadth of what is considered a ‘crossbred’ cow for example – effectively anything from J15/F1 - F15/J1 – there is still potential to have a significant variance between actual and modeled liveweight.

The kg DM figures from step 1 and step 2 are added together to calculate the total DM intake of the animals in kg DM/ha. This figure becomes the basis for the greenhouse gas calculation as there is a direct relationship between methane produced and forage eaten.

However, both research and experience, tell us that the efficiency of converting dry matter into milk solids varies significantly both within and between herds based on genetic merit (e.g. Production Worth), breed, and management factors. The more efficient herds require less total dry matter, and therefore produce less emissions, to produce the same amount of milk compared with less efficient herds. Any modeling of greenhouse gas emissions at a farm level must accurately capture these factors.

Thank you for your consideration of our submission.

———

 References

1. DairyNZ website,  https://www.dairynz.co.nz/news/research-shows-nz-dairy-the-world-s-most-emissions-efficient/

2. Grainger C, Goddard M: A review of the effects of dairy breed on feed conversion efficiency – an opportunity lost. Animal Production in Australia (2004) 25: 77-80

3. Kristensen T, Jenson C, Ostergaard s et al. Feeding, production and efficiency of Holstein-Friesian, Jersey and mixed breed lactating dairy cows in commercial Danish herds. Science Direct 15-12-2017

4. Prendiville R, Pierce K, Buckley F. An evaluation of production efficiencies among lactating Holstein-Friesian, Jersey and Jersey cross Holstein-Friesian cows at pasture. J Dairy Sci. (2009) 92:6176-6185

5. Sneddon N, Lopez-Villalobos N, Baudracco J. Efficiency, cheese yield and carbon emissions of Holstein-Friesian, Jersey and crossbred cows: an overview. Proc. NZ Soc. An. Prod. (2011) 71:214-218