CA ANZ has responded to the consultation paper by the Ministry for the Environment and Ministry for Primary Industries on pricing agricultural emissions.

Key points from our submission include:

• We broadly support the intention to implement an on-farm levy pricing option. We consider this option preferable to the processor-level pricing option and believe it will provide the best incentive for innovation and emissions reduction activities, ensuring more accountability by farmers. However, we have provided feedback on certain elements of the proposals. 
• The Government will need to continue to educate farmers on their new responsibilities and to provide clear, practical guidance on how to accurately collect and report their emissions. Ongoing collaboration and continued conversation with the agricultural sector will be essential to the success of the system. 
• Attaching a price to agricultural emissions will be cost prohibitive for some farmers who over time may not be able to continue operating. These farmers, their suppliers, service providers and communities will need to be consulted and supported throughout this transition, particularly acknowledging the uncertainty currently being experienced in the sector and the flow-on impacts of the reduction in agricultural production. 
• We support the plan to align emissions pricing with the farm business’s year-end date. This approach would enable greater efficiencies to be gained by more fully aligning the reporting of on-farm emissions with accounting and tax reporting. 
• To achieve the farm-level levy system by 2025, we consider that implementation of the reporting process should utilise existing systems (such as Inland Revenue (IR) systems), and the trusted relationship between farmers and their accountants. 
• In developing the details of the penalties and enforcement regime, we encourage policymakers to consider how best to acknowledge and celebrate best efforts by farmers and deter deliberate misstatement and avoidance. In the long term, the regime will be more successful if good disclosure efforts are recognised.

For more information, visit the consultation homepage.