Now's the time for agriculture to play its part

Submissions on including agriculture in the Emissions Trading Scheme close on Tuesday 13th August.

We’ve put together this submission guide to help you have your say.

Have your say now 


Right now, our elected members are deciding on how to reform the Emissions Trading Scheme (ETS) – one of our key tools used to help reduce climate pollution. They will be debating when to include climate pollution from agriculture.

We know the agriculture sector lobbyists are making their voices heard and pushing for a voluntary model where agricultural emissions wouldn’t face a price for their climate pollution until 2025 at least. 

If they get what they’re asking for, we’ll see further delays to ensuring that all sectors of our economy contribute to addressing the climate crisis.  

Can you make a submission and help us encourage a system that rewards those farmers, and encourages all farmers to follow their lead?

We’ve put together the submission guide below to help.

make your submission online now 


How to make a submission:

You can make a submission on the ETS by either completing the Ministry for the Environment’s online submission survey or by sending an email to agriculture.emissions@mfe.govt.nz.

If using Ministry for the Environments online submission from:

  • Add your name, region and email,

  • If submitting for yourself, select ‘individual’ under Submitter Types,

  • Answer the questions outlined in the submission form. You can answer as many or as few as you like. We’ve put together some suggested points to make, to help make it as easy as possible for you.

make your submission online by Tuesday 13 august 

If emailing your submission directly: 

  • Start by introducing yourself. Personal stories and perspectives will help make your submission more unique, and therefore give it more weight.

  • Explain why you care about climate change, how you will be impacted by climate change and why the Emissions Trading Scheme is so important to get right (hint: it’s NZ’s tool to incentivise polluters to reduce their emissions, by putting a price on climate pollution – that’s important, because where polluters don’t pay, the rest of us do).

  • Answer the key questions the consultation is seeking input on. To help, we’ve put together some points below that you could include in your submission, to help strengthen the ETS.


Email your submissions to agriculture.emissions@mfe.govt.nz by 5pm on Tuesday 13th of August.


Emissions Trading Scheme Submission Guide

The guide below follows the questions that the Ministry for the Environment is consulting on.

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

  • A clearly signalled requirement to pay for all types of greenhouse gas emissions by entering the Emissions Trading Scheme as soon as possible.
  • Supporting farmers to identify the best way to reduce on-farm emissions.
  • Working with rural communities and processing companies like milk and meat processors to ensure they encourage their suppliers (farmers) to make environmental improvements.

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?

  • Farm level pricing is necessary to ensure there are financial incentives on individual farms to reduce their emissions – especially for biological emissions from animals. Processor level pricing could be used as an interim step as this is simpler to implement.
  • Farmers want control over what happens on their own farms, and that’s fair enough. Farm level pricing is the best way to ensure farmers who make environmentally good changes directly see the rewards of that. But the most important thing is to put a price signal in place urgently.

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

  • Better tools for measuring farm level emissions; and a clear and certain regulatory framework.

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 primarily guided by the need for regulatory certainty and consistency of treatment with other commercial sectors. Option 1 is therefore preferable. Option 2 is insufficient to achieve emissions reduction goals, and inconsistent with best-practice approach to regulatory design. Option 1 is needed to ensure Zero Carbon Bill requirements can be met once this is enacted.

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?

  • Option 1 is preferable as this provides a clearer transition towards including agriculture in the ETS and better long term alignment with the Zero Carbon Bill.

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

  • Te Arawhiti should be involved in considering necessary measures to address Treaty interests, ensuring that these uphold the Crown’s obligations without prejudicing our climate change response.

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

  • The biggest barrier to reducing agriculture emissions is political will. We need a clear commitment so that agriculture sector participants have the right incentives to improve their practices and reduce emissions.
  • Many farmers are already making progress. Others need to be incentivised to follow their lead, and processors need to be incentivised to work with their suppliers to reduce emissions.

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

  • The key impact sought is a reduction in methane and NO2 emissions, which is one of the most significant steps we can take to reduce the impact of global warming and avoid a climate crisis. This is essential so that NZ contributes to global action, with the ultimate goal of protecting our primary sector for generations to come from the impacts of more frequent and stronger droughts, floods, storms, and fires.

9. Do you have any other comments on the Government’s proposals for addressing agricultural emissions?

  • We urge the Government to take meaningful and significant steps to bring agriculture into our climate change response framework, to even the playing field with all other sectors of the economy. Legislation needs to be introduced this term to price agricultural emissions. A voluntary accord is insufficient.

10. Additional questions on free allocation of emissions units (A – D)

  • Free allocation can be a useful mechanism for easing the transition to emissions pricing for key sectors but should be phased out over time to ensure price signals drive meaningful reductions in emissions.