A comparison of HSNO Submissions, from Federated Farmers, Methane Science Accord and GE Free. Notably Federated Farmers paid almost no attention to export market access, whereas GE Free was concerned about trade access and for Methane Science Accord market access was a primary concern. Federated Farmers consider access to technology a primary concern. MSA considers new research and market demand for grass fed, phytonutrient dense, pure nature is New Zealand’s greatest opportunity for growth, market access, sustainability and aligns with NZ’s passion for protecting nature.

Request to Delay HSNO: New Zealand’s competitive advantage lies in our clean, grass-fed, non-GMO pastoral systems — delivering premium phytonutrients, omega-3s, and CLA that cannot be easily replicated by industrial GM approaches. Weakening HSNO puts this at risk for marginal or negative gains.
Allowing GMOs or gene-edited products could threaten New Zealand’s agricultural export premiums. Because key markets demand non-GMO verification, introducing GMOs risks losing organic/non-GMO certifications, increasing compliance costs, and undermining NZ’s "clean and green" brand reputation.

In my submission on Gene Tech Bill; I noted that New Zealand farmers are one if not the only farmers in the developed world that do not receive government subsidies, as such they are highly sensitive to market demand. That GMO GE farming in the United States in particular is heavily government subsidised. GMO GE is a lower value product, on average reducing crop value by 15-20% to non-GMO crops and 115%+ less than organic crops…NZ’s proposed Gene Technology Bill sets out no liability framework, no obligations to protect indigenous biodiversity, productive and speciality seeds, nor animal welfare. The bill appears to carve out liability- free framework for gene technologies. There appears no requirement to evaluate long tail risk, no obligations for disclosure and law appears to have been developed with only laboratory processes in mind.

Silver Fern Farms’ decision to kowtow to global emissions agendas is unnecessary and deeply insulting to NZ farmers, the world’s most efficient producers of natural, pasture-fed, low-input food. Instead of championing this which is what consumers actually want, SFF is bowing to corporate-driven demands that misrepresent market realities. UK consumers’ clear rejection of feed additive Bovaer proves there’s no demand for these unnecessary “innovations.” By pandering to these disconnected corporates, SFF are undermining the very advantages that set our farming apart globally.

From previous comments there appears to be a fanciful belief that some significant reduction can be made to livestock methane by the use of a technology such as boluses, vaccines, genetics etc. The public reaction overseas to bovaer coupled with the cost and effort to farmers should tell you that that is not a solution.
You will no doubt be hearing from many scientists telling you they are on the brink of a solution, just a few more millions in research needed. Unfortunately they have been doing that for decades and but their claims never eventuate- only the demand for more funding.

No one has been able to actually translate ruminant methane emissions into warming effect, at least not to a quantum that is measurable or in anything other than a model…
We know full well, and it is not disputed, that grass fed ruminants, as we have in NZ, are only cycling C02 and methane, it is the carbon cycle, it is neutral …

Emerging new biotechnologies (NBTs) or GE technologies are potentially fraught with unintended and off-target effects showing deleterious mutations. Is temperature reductions of millionths of a degree worth the risk?
Methane mitigation Biotechnology tools: Has a risk to benefit analysis been done for these ‘never before used biotechnology tools’? What price do you put on an entire industry that stands to lose everything if these novel biotechnology tools are released and then subsequently found to be unsafe and or unwanted? Are biotech companies held liable if safety concerns arise further down the track? Or will NZ farmers have to pick up the bill for that too?

We suggest that methane emission reduction targets of 24 to 47% were set not because methane emissions need to reduce in order to “stop” global warming (as methane is having a barely measurable impact on global warming, if any) but to actually offset generic CO2 emissions.
… Destruction of Rural Communities Regulatory impacts show that economic growth could slow by $5-12 billion per year between 2020 to 2050 – a loss of around $300 billion. Farming outputs have been modelled to drop by 50 percent from current levels by 2050 – which is both ironic and unpalatable, given that this is the same timeframe that the primary sector was asked to double it's productive capability.

The opening paragraph of your section on agriculture says it is responsible for 51% of this country’s emissions. We then see constant reference to emissions in the sector. But these emissions bear absolutely no relationship to warming. It is now acknowledged that methane is a short-lived gas and does not need to reduce to zero to be warming neutral. But where has it ever been quantified how much warming our livestock cause? How can anyone make a realistic target for methane without this information? Instead, we get targets based on the outdated emissions calculated using the flawed GWP 100 metric. I have known since a 2011 meeting on greenhouse gas metrics I attended, that was presented by IPCC authors, that this metric does not accurately calculate methane’s warming. The IPCC now acknowledges that in the case of stable livestock production, as is the case in New Zealand, it overstates warming by three or four times. So why is the Commission using such outdated metrics?

This is a political issue not a scientific one and has become contentious because of those that either derive income directly or are trying to derive income based on GHG emissions being an issue and are subsequently creating an industry around this. Quite simply if the effect of Methane is shown scientifically to be negated then the logical and honest course is to acknowledge this, move on and search for an actual problem where research and action can achieve a result. Methane is not the actual problem.

The coalition government has a mandate to take the hidden costs out of the productive sector. In this instance it starts with acknowledging the IPCC statement that settings for methane were overstated 3-4 times and the emissions in NZ are not 48%, (or 70% as uttered by Ministry for the Environment only yesterday), but likely of no consequence. An additional requirement is to quantify the warming affect of the methane produced or its longevity in the atmosphere but if the starting point is inaccurate then what will the answer be? …