29 August 2019
Environmental Protection Authority
Private Bag 63002
Wellington 6140
New Zealand
Submission on application APP203660
To reassess methyl bromide
Introduction
1. The Soil & Health Association of New Zealand Inc. (“Soil & Health”) is a charitable society registered under the Incorporated Societies Act 1908. It is the largest membership organization supporting organic food and farming in New Zealand and is one of the oldest organic organisations in the world, established in 1941. Soil & Health’s objectives are to promote sustainable organic agricultural practices and the principles of good health based on sound nutrition and the maxim: “Healthy soil, healthy food, healthy people”. Its membership is chiefly composed of home gardeners and consumers, organic farmers and growers, secondary producers, retailers and restaurateurs. Soil & Health publishes the bi-monthly ‘Organic NZ’ magazine – New Zealand’s leading organics magazine.
2. Soil & Health makes this submission on the application by Stakeholders in Methyl Bromide Reduction Inc (STIMBR) to reassess methyl bromide a fumigant which among other things is used on export timber and logs.
3. Soil & Health accepts the need for fumigation to meet the phytosanitary needs of New Zealand and other countries, should safer methods of pest control not be effective, and if communities and the broader environment are protected from any adverse effects from the fumigant.
4. The EPA in 2018 allowed the possibility of a reassessment application;
‘Grounds to reassess were granted based on data that evidenced New Zealand’s use of the fumigant has increased from over 400 tonnes a year in 2010, to more than 600 tonnes in 2016. One of the criteria required to be met to meet grounds for reassessment under the Hazardous Substances and New Organisms Act, is a significant change in the quantity of a substance imported into or manufactured in New Zealand.’
5. Soil & Health believe that reassessment criteria was used inappropriately, as that increased use was totally predicted at the last reassessment with conditions of use and the recapture deadline made in that knowledge. It is misleading to use increased use to allow another reassessment to effectively excuse the log export industry out of their environmental and public health responsibilities, when those responsibilities were clearly defined in 2010.
6. Soil & Health submitted to the Environmental Risk Management Authority (ERMA) for the reassessment of methyl bromide in 2010 and has campaigned since to have that fumigant better contained and recaptured or stopped.
7. Those campaigns along with other community, union, and environmental groups have meant that methyl bromide fumigation without recapture is no longer used at log exporting facilities in several ports, notably Nelson, Picton and Wellington. However the problems of worker exposure and release of the atmospheric ozone depleting gas have mostly just shifted north to the ports of Napier, Tauranga, and Marsden Point-Whangarei.
8. This submission writer, later in another role as a Section 274 Party, won an Environment Court case, Envirofume Limited vs Bay of Plenty Regional Council [2017] NZEnv 12. That case, contested for the applicant Envirofume by legal counsel Helen Atkins (Chairperson of the 2010 ERMA methyl bromide re-assessment), exposed further the significant risks of methyl bromide fumigations for the health and safety of workers and nearby communities.
9. The log exporter industry through STIMBR have variously used public funding as in the Primary Growth Partnership (PGP) funding to look at mostly predictably unlikely alternatives to recapturing residual methyl bromide, while obfuscating attempts at log stack trials of existing recapture technology using carbon filters as available from Nordiko.
10. STIMBR supported Draslovka who applied for an alternative fumigant ethanedinitrile (EDN) which the Ministry for Primary Industries (MPI) appear to be taking seriously in negotiations with log importing countries as an alternative to methyl bromide, on the premise that recapture will not be necessary should EDN be approved, as it is not subject to the Montreal Protocol.
11. Soil & Health submitted in opposition to EDN due to the known risks, and the lack of environmental and safety data, and that the applicant and STIMBR’s approach that recapture would not be required, although in Australia, EDN can ONLY be used with scrubbing (a recapture) technology as part of its label use after being assessed by the national regulatory body there, the Australian Pesticides and Veterinary Medicines Authority (APVMA).
12. Soil & Health is concerned that government agencies such as MPI might be looking at the EPA as a rubber-stamping agency for compounds such as EDN with such confidence that they are putting EDN as an option for fumigation to countries including India and China. Soil & Health is concerned that industry’s economic benefits appear to become paramount over the need of worker, community and environmental health in the decision making around fumigants approval and their use.
13. However, the EPA has decided to process this application by STIMBR as a modified reassessment rather than forcing the previous reassessment’s requirement of recapture onto the users of methyl bromide fumigation.
The Tauranga example:
14. While economic considerations are included in the benefits analysis by the EPA, the ability to pay for appropriate safeguards must be included in any analysis, not just the significant earnings the industry generates. All stakeholders including port companies should be part of ensuring the ultimate safety of workers, community and environment.
15. In the Environment Court case, Envirofume Limited vs Bay of Plenty Regional Council [2017] NZEnv 12, it was noted that Port of Tauranga Limited (POTL) was missing in action as such during those proceedings although was the owner and operator of the port where the log fumigation activity under scrutiny was taking place.
16. The community and Soil & Health have long called for dedicated fumigation facilities incorporating recapture technology to be constructed and used, yet POTL continue to discount any such possibility there.
17. Soil & Health points out that POTL has just announced its largest profit ever (end of year June 2019). Increasing 6.7% on last year’s profit of $94.3 million to reach $100.6 million, with log export volumes increasing during that time 12.5% to 7.1 million tonnes. http://www.port-tauranga.co.nz/growth-in-cargo-volumes-contributes-to-increased-profit-for-port-of-tauranga-limited/
While that growth is expected to ease in the short term, POTL is still the country’s largest export log exporter, close to twice its nearest rival Whangarei.
18. Log exports through POTL for the year ending December 2017 were valued at $968,919,331, almost a staggering billion dollars towards a third of New Zealand’s log export value that year of $3,058,737,889 and yet the port company and log exporting interests continue to deny workers, the community and environment the benefits of recapture.
- Safeguards to protect people and the environment are becoming more important and need greater attention as increasing development and presence of toxins including fumigants in the environment become more common.
20. Soil & Health submits that the money is there for fast correction of the shortcomings in facilities and responsible management of log and timber fumigation in New Zealand.
Monitoring and modelling
- Methyl bromide is a risk well beyond fumigation areas due to drift, inversion layers, and the inability by those responsible to adequately monitor its whereabouts. Boundary monitoring is pointless if at head height, when a fumigant plume passes above it and then descends or drifts into other areas.
22. Air modelling techniques cannot fully give assurances about where and at what concentrations methyl bromide will be once released from containers, log stacks or ships holds. Modelling can at best be a best estimate, but the topography of the fumigation surrounds is continually changing with log or container stacks, ships size and presence, and weather variables, including humidity, temperature of air, objects and ground all obfuscating the best air modelling estimates.
- There is no sure air monitoring possibility, or method for the safe release of methyl bromide in the port and coastal marine area. A previous Environment Court in Nelson noted the possibility for “monitoring devices to miss the most concentrated area of the plume, or even the plume in its entirety, and in fact on four out of seven attempts to sample air quality in Port Nelson during 2003-2004 this had occurred in varying degrees” (Env Court Interim Decision para 50).
24. Soil & Health notes STIMBR’s intent that recapture of fumigant from ships holds be delayed significantly, another 10 years, yet ships’ holds are where the most significant volumes of methyl bromide are used. The communities near the ports of Napier, Tauranga and Mt Maunganui, and Marsden Point (Whangarei port), and potentially elsewhere in New Zealand will be further exposed to the toxicity of methyl bromide, and the damage to the ozone layer will continue.
25. Other port workers, not involved in fumigation but working nearby, may also be exposed to the methyl bromide, particularly when the methyl bromide is released into the atmosphere following fumigation, but also during accidental and spontaneous release, as happens with methyl bromide most years, at most log stack fumigating ports. Log stack fumigations under tarpaulins are subject to strong wind events and accidental tarpaulin puncturing. Both Genera and Envirofume fumigation operators have had log stack tarpaulins rent with spontaneous release of methyl bromide. Dedicated permanent fumigation structures would eliminate the risk of tarpaulin failure.
Worker and community safety
- In the Environment Court decision Envirofume Limited vs Bay of Plenty Regional Council, [2017] NZEnv 12, the court observed the large range of port users that may be exposed inadvertently to the methyl bromide fumigant. [1]
- That Court found significant shortcomings in the current methyl bromide fumigations. EPA and Work Safe requirements are either impractical or are frequently breached.
- Whatever toxic fumigant is used for log, timber and other fumigations, it must be in a dedicated facility with recapture of remnant fumigant, such as is used at Port Nelson. Methyl bromide was linked at that port with the deaths of six men from motor neurone disease. Alternative fumigants such as EDN have their own array of serious health risks. Recapture technology exists but industry individually and collectively has mostly avoided its use for economic reasons.
Ozone depletion
- Continuance of methyl bromide release means further atmospheric ozone depletion, and New Zealand’s intentional breach of responsibility to its Montreal Protocol obligations, where although phytosanitary requirements allow some continued use of methyl bromide, there is an obligation to be reducing its use. ERMA allowed a continuance of damaging release into the atmosphere in 2010 with the knowledge that there would be a significant increase in methyl bromide use.
- Dr Olaf Morgenstern – Programme leader (Climate Variability and Change) NIWA for the writer at the Environment Court outlined the significance of that release in world terms, with New Zealand being the highest user per capita. That should not continue if we are concerned about climate effects and the health of people and environment, or economically if our international, including trading, clean green branding reputation is to be valued.
Health effects.
- Most people acknowledge the very real danger of methyl bromide from both acute and chronic exposures, and both acute and chronic effects. A recent although limited US study recently published in the Journal of Asthmareported a positive association between methyl-bromide concentrations and asthma-related emergency department (ED) visits among youths between the ages of 6 and 18 years in California.
- After adjusting for the presence of other pollutants, humidity, and meteorological conditions, each 0.01-ppb increase in methyl-bromide concentration was associated with a 7.1% (95% CI, 2.9%-10.8%) greater likelihood of an asthma-related ED visit.
- That science will need more work but further shows the need for recapture if real precaution is to be used.
The solution – dedicated containment and recapture.
- Responsibility for dedicated containment and recapture facilities was considered by the Environment Court to require an integrated approach:
[130] Overall, our view is that this matter requires an integrated approach from the Port of Tauranga, the marshalling/stevedoring companies, the forestry industry and the fumigators to adopt an approach for the safe application of methyl bromide and the recapture of all reasonable emissions. This would probably require a dedicated area for fumigation, and may involve a building or other system that seeks to encapsulate and recapture gas. We are not satisfied that the introduction of another company into the Tauranga market is going to bring about those changes. In our view, the advance towards reduction of emissions has seen little progress since the 1990s, and the Court is surprised to see that there is approximately ten times as much methyl bromide being applied in Tauranga as there was in the 1990s.
- Regardless of the possibility of an alternative fumigant, industry including port companies and possibly government need to bite the bullet and install dedicated facilities for fumigations and recapture.
- The ERMA 2010 methyl bromide re-assessment inappropriately and possibly illegally set a very late 2020 date for recapture of that fumigant to meet Montreal Protocol requirements of phasing out methyl bromide emissions. The EPA must now insist on dedicated fumigation facilities and recapture always, if the EPA is to meet its statutory requirements.
- Soil & Health supports the substantive submission of the Combined Trade Unions, and is in general agreement of the fumigation context and need for stronger and certain safety conditions as supplied by the Bay of Plenty Regional Council.
- Soil & Health submits that the evidence as attached and provided by expert witnesses for the writer for the Envirofume Environment Court case be considered by the EPA. That included evidence by an epidemiologist Dr Dave McLean from the Centre for Public Health Research, Dr Olaf Morgenstern – Programme leader (Climate Variability and Change) NIWA, and Jayne Metcalfe an air scientist.
Conclusion.
39. Soil & Health seek that the current application be declined.
40. Should the application be granted, dedicated fumigation facilities and recapture must be required.
41. Soil & Health wish to be heard in support of our submission and welcome any questions of the writer for clarification or further information.
Yours sincerely
Steffan Browning
021 804 223
greeny25@xtra.co.nz
Position: National Councillor
The Soil & Health Association
PO Box 9693,
Marion Square,
Wellington, 6141
Email: advocacy@organicnz.org.nz
Website: www.organicnz.org.nz
[1] https://www.environmentcourt.govt.nz/assets/Documents/Decisions/2017-NZEnvC-012-Envirofume-v-Bay-of-Plenty-Regional-Council.pdf
Submission on application APP203660 To reassess methyl bromide
/in Submissions29 August 2019
Environmental Protection Authority
Private Bag 63002
Wellington 6140
New Zealand
Submission on application APP203660
To reassess methyl bromide
Introduction
1. The Soil & Health Association of New Zealand Inc. (“Soil & Health”) is a charitable society registered under the Incorporated Societies Act 1908. It is the largest membership organization supporting organic food and farming in New Zealand and is one of the oldest organic organisations in the world, established in 1941. Soil & Health’s objectives are to promote sustainable organic agricultural practices and the principles of good health based on sound nutrition and the maxim: “Healthy soil, healthy food, healthy people”. Its membership is chiefly composed of home gardeners and consumers, organic farmers and growers, secondary producers, retailers and restaurateurs. Soil & Health publishes the bi-monthly ‘Organic NZ’ magazine – New Zealand’s leading organics magazine.
2. Soil & Health makes this submission on the application by Stakeholders in Methyl Bromide Reduction Inc (STIMBR) to reassess methyl bromide a fumigant which among other things is used on export timber and logs.
3. Soil & Health accepts the need for fumigation to meet the phytosanitary needs of New Zealand and other countries, should safer methods of pest control not be effective, and if communities and the broader environment are protected from any adverse effects from the fumigant.
4. The EPA in 2018 allowed the possibility of a reassessment application;
‘Grounds to reassess were granted based on data that evidenced New Zealand’s use of the fumigant has increased from over 400 tonnes a year in 2010, to more than 600 tonnes in 2016. One of the criteria required to be met to meet grounds for reassessment under the Hazardous Substances and New Organisms Act, is a significant change in the quantity of a substance imported into or manufactured in New Zealand.’
5. Soil & Health believe that reassessment criteria was used inappropriately, as that increased use was totally predicted at the last reassessment with conditions of use and the recapture deadline made in that knowledge. It is misleading to use increased use to allow another reassessment to effectively excuse the log export industry out of their environmental and public health responsibilities, when those responsibilities were clearly defined in 2010.
6. Soil & Health submitted to the Environmental Risk Management Authority (ERMA) for the reassessment of methyl bromide in 2010 and has campaigned since to have that fumigant better contained and recaptured or stopped.
7. Those campaigns along with other community, union, and environmental groups have meant that methyl bromide fumigation without recapture is no longer used at log exporting facilities in several ports, notably Nelson, Picton and Wellington. However the problems of worker exposure and release of the atmospheric ozone depleting gas have mostly just shifted north to the ports of Napier, Tauranga, and Marsden Point-Whangarei.
8. This submission writer, later in another role as a Section 274 Party, won an Environment Court case, Envirofume Limited vs Bay of Plenty Regional Council [2017] NZEnv 12. That case, contested for the applicant Envirofume by legal counsel Helen Atkins (Chairperson of the 2010 ERMA methyl bromide re-assessment), exposed further the significant risks of methyl bromide fumigations for the health and safety of workers and nearby communities.
9. The log exporter industry through STIMBR have variously used public funding as in the Primary Growth Partnership (PGP) funding to look at mostly predictably unlikely alternatives to recapturing residual methyl bromide, while obfuscating attempts at log stack trials of existing recapture technology using carbon filters as available from Nordiko.
10. STIMBR supported Draslovka who applied for an alternative fumigant ethanedinitrile (EDN) which the Ministry for Primary Industries (MPI) appear to be taking seriously in negotiations with log importing countries as an alternative to methyl bromide, on the premise that recapture will not be necessary should EDN be approved, as it is not subject to the Montreal Protocol.
11. Soil & Health submitted in opposition to EDN due to the known risks, and the lack of environmental and safety data, and that the applicant and STIMBR’s approach that recapture would not be required, although in Australia, EDN can ONLY be used with scrubbing (a recapture) technology as part of its label use after being assessed by the national regulatory body there, the Australian Pesticides and Veterinary Medicines Authority (APVMA).
12. Soil & Health is concerned that government agencies such as MPI might be looking at the EPA as a rubber-stamping agency for compounds such as EDN with such confidence that they are putting EDN as an option for fumigation to countries including India and China. Soil & Health is concerned that industry’s economic benefits appear to become paramount over the need of worker, community and environmental health in the decision making around fumigants approval and their use.
13. However, the EPA has decided to process this application by STIMBR as a modified reassessment rather than forcing the previous reassessment’s requirement of recapture onto the users of methyl bromide fumigation.
The Tauranga example:
14. While economic considerations are included in the benefits analysis by the EPA, the ability to pay for appropriate safeguards must be included in any analysis, not just the significant earnings the industry generates. All stakeholders including port companies should be part of ensuring the ultimate safety of workers, community and environment.
15. In the Environment Court case, Envirofume Limited vs Bay of Plenty Regional Council [2017] NZEnv 12, it was noted that Port of Tauranga Limited (POTL) was missing in action as such during those proceedings although was the owner and operator of the port where the log fumigation activity under scrutiny was taking place.
16. The community and Soil & Health have long called for dedicated fumigation facilities incorporating recapture technology to be constructed and used, yet POTL continue to discount any such possibility there.
17. Soil & Health points out that POTL has just announced its largest profit ever (end of year June 2019). Increasing 6.7% on last year’s profit of $94.3 million to reach $100.6 million, with log export volumes increasing during that time 12.5% to 7.1 million tonnes. http://www.port-tauranga.co.nz/growth-in-cargo-volumes-contributes-to-increased-profit-for-port-of-tauranga-limited/
While that growth is expected to ease in the short term, POTL is still the country’s largest export log exporter, close to twice its nearest rival Whangarei.
18. Log exports through POTL for the year ending December 2017 were valued at $968,919,331, almost a staggering billion dollars towards a third of New Zealand’s log export value that year of $3,058,737,889 and yet the port company and log exporting interests continue to deny workers, the community and environment the benefits of recapture.
20. Soil & Health submits that the money is there for fast correction of the shortcomings in facilities and responsible management of log and timber fumigation in New Zealand.
Monitoring and modelling
22. Air modelling techniques cannot fully give assurances about where and at what concentrations methyl bromide will be once released from containers, log stacks or ships holds. Modelling can at best be a best estimate, but the topography of the fumigation surrounds is continually changing with log or container stacks, ships size and presence, and weather variables, including humidity, temperature of air, objects and ground all obfuscating the best air modelling estimates.
24. Soil & Health notes STIMBR’s intent that recapture of fumigant from ships holds be delayed significantly, another 10 years, yet ships’ holds are where the most significant volumes of methyl bromide are used. The communities near the ports of Napier, Tauranga and Mt Maunganui, and Marsden Point (Whangarei port), and potentially elsewhere in New Zealand will be further exposed to the toxicity of methyl bromide, and the damage to the ozone layer will continue.
25. Other port workers, not involved in fumigation but working nearby, may also be exposed to the methyl bromide, particularly when the methyl bromide is released into the atmosphere following fumigation, but also during accidental and spontaneous release, as happens with methyl bromide most years, at most log stack fumigating ports. Log stack fumigations under tarpaulins are subject to strong wind events and accidental tarpaulin puncturing. Both Genera and Envirofume fumigation operators have had log stack tarpaulins rent with spontaneous release of methyl bromide. Dedicated permanent fumigation structures would eliminate the risk of tarpaulin failure.
Worker and community safety
Ozone depletion
Health effects.
The solution – dedicated containment and recapture.
[130] Overall, our view is that this matter requires an integrated approach from the Port of Tauranga, the marshalling/stevedoring companies, the forestry industry and the fumigators to adopt an approach for the safe application of methyl bromide and the recapture of all reasonable emissions. This would probably require a dedicated area for fumigation, and may involve a building or other system that seeks to encapsulate and recapture gas. We are not satisfied that the introduction of another company into the Tauranga market is going to bring about those changes. In our view, the advance towards reduction of emissions has seen little progress since the 1990s, and the Court is surprised to see that there is approximately ten times as much methyl bromide being applied in Tauranga as there was in the 1990s.
Conclusion.
39. Soil & Health seek that the current application be declined.
40. Should the application be granted, dedicated fumigation facilities and recapture must be required.
41. Soil & Health wish to be heard in support of our submission and welcome any questions of the writer for clarification or further information.
Yours sincerely
Steffan Browning
021 804 223
greeny25@xtra.co.nz
Position: National Councillor
The Soil & Health Association
PO Box 9693,
Marion Square,
Wellington, 6141
Email: advocacy@organicnz.org.nz
Website: www.organicnz.org.nz
[1] https://www.environmentcourt.govt.nz/assets/Documents/Decisions/2017-NZEnvC-012-Envirofume-v-Bay-of-Plenty-Regional-Council.pdf
GE-free Tasmania a shining example for NZ
/in GE, Media Releases09 August 2019
The Soil & Health Association congratulates the Tasmanian government for extending its ban on genetically engineered organisms for another 10 years, until 2029.
“Tasmanian producers see clear benefits of being GE-free, enjoying a good reputation and access to markets,” said Jodie Bruning, Councillor for Soil & Health.
“We urge the New Zealand government to also implement a ban on the outdoor use of GE, to strengthen our clean and green brand.”
“People here and worldwide are demanding safe, healthy, ethical, GE-free and organic food. We can produce this and benefit economically, environmentally and, socially.”
GE-free organic production will help build healthy soils, and clean up waterways, and it is part of the solution to climate change, according to Soil & Health.
Many local authorities and primary producers around Aotearoa New Zealand recognise the benefits of a GE-free status, and several councils have either outdoor GE bans or precautionary policies.
New Zealand and Tasmania both have the advantage of sea borders which can help us remain GE-free in the environment.
The GE ban in Tasmania has been widely supported, including by primary producers such as orchardists, pastoral farmers and beekeepers.
[ENDS]
MEDIA CONTACT:
Jodie Bruning
National Council, Soil & Health Association
027 505 0808
jodie@organicnz.org.nz
2019 AGM of the Soil & Health Association
/in Association Meetings and EventsRead the minutes of our 2019 Annual General Meeting.
Submission on Climate Change Response (Zero Carbon) Amendment Bill
/in SubmissionsINTRODUCTION
The Soil & Health Association of New Zealand is the largest membership organisation supporting organic food and farming in New Zealand and one of the oldest organic organisations in the world, established in 1941. The Association receives no government or other official support, nor is it sponsored or supported by any commercial organisation, political party, religion or other vested interest.
With every year that passes the vision of Soil and Health of an organic New Zealand becomes more relevant, more imperative, and in fact, more mainstream. The maxim of the organisation is “Oranga nuku – Oranga kai – Oranga tāngata, Healthy Soil – Healthy Food – Healthy People”. This extends into the sphere of climate change, as healthy, living soil is potentially the most important carbon sink our planet has. For planetary health (and therefore our own health) not only must we stop the burning of fossil fuels, but we must change our actions so as to sequester the existing carbon from the air into soil and biomass. Organic and regenerative[1] production methods, which maximise the accumulation of soil organic matter, are key to sequestering atmospheric carbon and keeping global warming within 1.5ºC.
BACKGROUND SCIENCE
This section is aimed not at outlining the climate crisis, which the Bill recognises, but at highlighting the key role that organic and regenerative agriculture can play in ameliorating climate outcomes.
The degradation of soils from unsustainable “conventional” agriculture has released billions of tons of carbon into the atmosphere[2]. It is estimated that the world’s cultivated soils have lost between 50 and 70 percent of their original carbon stock[3]. Conventional agricultural methods, such as the use of chemical biocides and fertilisers, heavy mechanical tillage, mono-cropping and overgrazing, have killed or rendered ineffective a multitude of living organisms within soils, leading to the oxidation of soil organic carbon and its release in gaseous forms. Although classed as “conventional” and therefore normal, these methods of agriculture are new, having arisen only since the “Green Revolution” after the Second World War. In 2019 we have enough evidence that these new ways cannot be continued if we are to survive.
According to soil scientists, at current rates of soil destruction (i.e. decarbonisation, erosion, desertification, chemical pollution), within 50 years we will not only suffer further serious damage to public health due to a qualitatively degraded food supply, but we will literally no longer have enough arable topsoil to feed ourselves[4]. Without protecting and regenerating our arable soils and grazing lands, it will be impossible to feed the world adequately and keep global warming below 1.5ºC.
So we come back to the key focus of the Soil and Health Association: how to grow food in such a way that soil, human and overall planetary health are supported? There is a growing body of research and many examples, from within NZ[5] and from overseas[6], showing how to manage land profitably to meet human needs, while sequestering carbon. These carbon farming methods have been largely ignored as we scramble for solutions to the global climate catastrophe that faces us. For too long, the focus of NZ government has been on offsetting carbon emissions from conventional agriculture by purchasing overseas carbon credits, or planting monocultures of pine trees to sequester carbon within NZ. Of course, we are all in favour of planting more trees, however this does to some extent detract from the opportunities that exist in pastoral, silvopastoral and arable systems. NZ needs to move more urgently in the direction of changing agriculture through appropriate policy and regulation, rather than avoiding the necessary change to appease strong vested interests or maintain lucrative but unsustainable export industries.
OUR POINTS ON THE BILL ITSELF
There are several positive things about the Bill which we wish to tautoko:
Having said this, we believe the Bill has not gone far enough. To limit warming to 1.5ºC, New Zealand has a limit on our total remaining greenhouse gas emissions. Our pathway to net-zero must stay below this limit. The Intergovernmental Panel on Climate Change says this pathway requires carbon emissions to halve by 2030 and reach zero before 2050. Aotearoa New Zealand has the tools to achieve deep emission reductions in the next decade, as long as we have the legislation to back them.
We want this Bill to ensure an emissions pathway that limits our contribution to warming to no more than 1.5ºC. The Climate Commission must ensure we are on the right path, acknowledging New Zealand’s historical emissions. The Bill in its current state will not ensure our contribution to limiting warming to 1.5ºC.
Therefore we wish to propose the following revisions to strengthen its effectiveness:
The Soil & Health Association of New Zealand wishes to speak to its submission.
NZ EXAMPLES OF ORGANIC AND REGENERATIVE FARMS
Biofarm, Palmerston North https://www.facebook.com/pg/BiofarmOrganic/
Bostock’s Organic Free Range Chicken, Hastings https://bostocksorganic.co.nz/
Field to Feast Organics, Christchurch http://www.canterburyorganic.org.nz/field-to-feast-organics/
Grow Together Farm, Rotorua https://www.growtogetherfarm.co.nz/
Harts Creek Farm, Canterbury, http://www.hartscreekfarm.co.nz/
Kotare Village, Wairoa http://kotarevillage.org.nz/regenerative-agriculture/
Lawson’s True Earth, Hastings https://trueearth.co.nz/
Lux Organics, Rotorua https://www.luxorganics.co.nz/
Mangarara Station, “The Family Farm”, Hawkes Bay https://www.mangarara.co.nz/
Milmore Downs, North Canterbury http://www.milmoredowns.co.nz/
Puramahoi Fields, Takaka https://www.puramahoifields.com/
Pikiroa Farm, Te Awamutu
Rainer Ramharter, Lincoln, Canterbury https://www.facebook.com/Ramharter-Organic-Farm-575814699192206/
Six Toed Fox Organics, Tauranga https://www.sixtoedfoxorganics.co.nz/
Spring Collective Organics, South Canterbury https://www.facebook.com/springcollectiveorganics/
Winiata Dairy Farm, Rotorua winiatat@farmside.co.nz, 07 333 2139.
[1] As coined and defined by the Rodale Institute https://rodaleinstitute.org/
[2] https://www.onpasture.com/wp-content/uploads/2017/10/Lal-Soil-carbon-sequestration-to-mitigate-climate-change.pdf
[3] https://e360.yale.edu/features/soil_as_carbon_storehouse_new_weapon_in_climate_fight
[4] https://regenerationinternational.org/why-regenerative-agriculture/?fbclid=IwAR219PNjLCveGhUgdavaefaXNVjrB4DJfik2NN441hwf-lURgj9zkaCjkS0
[5] See the end of this document for a list of organic and regenerative NZ farms.
[6] Toensmeier, E. 2016. The Carbon Farming Solution – A Global Tookit of Perennial Crops and Regenerative Agriculture Practices for Climate Change Mitigation and Food Security. Chelsea Green Publishing, Vermont, U.S.A.
Submission on Dairy Industry Restructuring Act 2001 review
/in SubmissionsIntroduction
1. The Soil & Health Association of New Zealand Inc. (“Soil & Health”) thanks the Ministry for Primary Industries for the opportunity to comment on the Dairy Industry Restructuring Act 2001 (“DIRA”) review and specifically the ‘Review of the Dairy Industry Restructuring Act 2001 and its impact on the dairy industry’ Discussion Document (“Discussion Document”).
2. Soil & Health is an incorporated society, with charitable status, supporting organic food production established in 1941. It is the largest membership organization supporting organic food and farming practices in New Zealand and is one of the eldest present-day organic organisations in the world. Soil & Health’s objectives are to promote sustainable organic agricultural practices and the principles of good health. Its membership is chiefly composed of home gardeners and consumers, organic farmers and growers, secondary producers, retailers and restaurateurs. Soil & Health publishes the bimonthly ‘Organic NZ’ magazine – New Zealand’s leading organics magazine.
3. Soil & Health has concerns about a lack of government support for dairy farmers to transition to higher premium organic milk production. We consider that the Government should recognize the economic and environmental benefits of organic milk production for New Zealand; these include higher returns for farmers and less environmental degradation. The changes we therefore seek from the DIRA review are that:
a) Fonterra must be obligated to collect all certified organic milk and in transition to certified organic milk; and
b) Fonterra must be obligated to pay any Fonterra organic milk supplier a minimum of 25% premium above the annual farm gate price, irrespective of location or availability of processing capacity.
Submission
4. Soil & Health understand that the DIRA was enacted in 2001 to facilitate the formation of Fonterra to drive the New Zealand dairy industry’s economic performance in global dairy markets, and to regulate its dominance domestically, for the long-term interests of New Zealand dairy farmers, consumers and the wider economy. However, we consider that this strong focus on economic growth has come at the expense of the environment.
5. We strongly agree with the Discussion Document that, along with economic benefits of the growth of the dairy industry, there have been negative effects on our environment. Such effects include increased greenhouse gas emissions, nitrate leaching, and the expansion of dairy into increasingly marginal land areas. We are pleased to see this acknowledged in the Discussion Document.
6. We share concerns highlighted in the Discussion Document that the DIRA has been encouraging uneconomic and environmentally unsustainable milk production inevitably preventing Fonterra from transitioning to higher value-add processing activities such as organic dairy.
7. It is well known that New Zealand’s freshwater is in a dire state, with a staggering 62% of monitored waterways being unsafe for swimming, and a big factor in this is nitrogen pollution from the increasing intensification of agriculture. The Ministry for the Environment says New Zealand has recently experienced one of the world’s highest rates of agricultural intensification.
8. There is also growing concern about the public health impacts of highdensity livestock production – especially for dairy farming. There are health concerns as nitrate levels in drinking water increase.
9. Nitrogen pollution comes from cow urine and synthetic nitrogen fertilizer diffusing through soils and pasture root zones, so simply planting stream banks and fencing off streams cannot solve this issue.
10. Our concerns are that Fonterra’s focus on economic value growth, primarily from greater volume of commodity production, have made it more difficult for dairy farmers to transition to organic dairy production, and therefore to more environmentally friendly methods of dairy farming.
11. Going organic is part of the solution to fixing polluted fresh waterways in New Zealand. Organic dairy farming involves no synthetic nitrogen fertilizers, lower stock numbers, more biodiversity, and grass-fed cows with no GE feed or palm kernel supplements. Organic farming methods improve the soil biology and soil structure, which means better water retention and less nutrient leaching. Organic and biological farmers make use of natural fertilizers including legumes, instead of soluble artificial nitrogen fertilizers that are more prone to leaching.
12. Organic dairying also has higher animal health outcomes and lower intensity. Some of the profit making of organic dairying and their ability to remain profitable with less volume is because of the reduced veterinary costs because of the reduced animal health issues.
13. Studies have found that a low-input system with fewer cows per hectare and no synthetic nitrogen fertilizer produces the most milk per cow per year. This research also confirms that the low input system is the best environmental performer, the least financially risky, and is most profitable when milk-price payouts are low (Basset-mens C, Ledgard S and Boyes M (2009). Eco-efficiency of intensification scenarios for milk).
14. We support the DIRA in that it is legislation enabling a cooperative and protective approach to market access for many farmers, controlling farmgate milk price to some degree, and because it exists it allows for what could be a legislative environmental gamechanger for dairy in New Zealand.
15. The DIRA however has allowed Fonterra to treat organic farmers poorly over time, including reducing the organic pickup area for paying the organic premium, meaning no premium, even for some of the organic pioneers that helped get the organic dairying underway, because they were beyond the ‘organic hub’. Only when it has suited Fonterra did they reinstate some parts of Taranaki and Manawatu, but overall there has been limited encouragement for new organic transitions beyond its organic hub.
16. Fonterra have made it more difficult to have certified organic dairy farmers in parts of New Zealand away from their prescribed hubs. We understand this has been done for efficiencies however at the same time has resulted in organic dairy growing better outside of Fonterra in New Zealand.
17. Fonterra established its organic programme in 2002 following three years of research and the sector grew strongly. At its peak in 2011, there were 127 dairy farms supplying Fonterra with organic milk. Fonterra had a review and changed its organic policy in the same year. This opened the door to commercial opportunities for new players to fill the supply vacuum. The Organic Dairy Hub Cooperative which is now the third largest supplier of organic milk in New Zealand was incorporated in 2015. Fonterra, Open Country Dairy, Organic Dairy Hub and Marphona Farms which operates Green Valley Dairies, are now the four main suppliers of organic milk in New Zealand (OANZ 2016 Organic Market Report).
18. Consumers worldwide are demanding safe, healthy and more environmentally friendly food, and are prepared to pay for high quality, GEfree, organic dairy products. New Zealand is well placed to provide discerning consumers with an expanding range of organic dairy products to meet their demands, particularly in Asia. The 2018 Organic Market report found that global organic dairy market is currently estimated to be worth about US$17b with a compound annual growth rate of 8% during 2009 to 2016. By 2022 the sector is projected to be worth US$25b the value of organic milk powder being an important contributor (OANZ 2018 Organic Market Report).
19. If Fonterra are obligated to pay farmers the premium for organic milk everywhere, then the co-op will be motivated to process more of the milk
into organic products and do better at marketing the same. DIRA needs to be amended to make it obligatory for Fonterra to be picking up certified organic milk and in transition to certified organic and be paying the premium for it.
Soil & Health’s recommendations
20. Soil & Health considers that government intervention is required to incentivize more sustainable and organic methods of farming. We consider that a shift towards organic farming practices is needed to protect and enhance our environment and our economy.
21. Soil & Health therefore seek that the legislation require that Fonterra must collect all certified organic milk and in transition to certified organic Fonterra milk and pay a 25% premium above the annual farm gate price for it, irrespective of location or availability of processing capacity.
22. Other changes Soil & Health seek are that the DIRA open entry requirements are repealed. As one of the key mechanisms that has facilitated the growth of this industry Soil & Health strongly recommends that the open entry provision be completely removed. For completeness we recommend that open exit be retained so that Fonterra cannot impose any restrictions on farmers who wish to leave Fonterra.
23. Further, with regards to Terms of Supply, Soil & Health recommends that the DIRA be clarified to ensure that Fonterra can provide financial incentives and disincentives to farmers who are performing above or below any element of Fonterra’s Terms of Supply or standards. Being able to use financial incentives and disincentives should include, but not be limited to, issues associated with environment, emissions and animal welfare standards.
Author: Mischa Davis
Position: Policy Advisor
The Soil & Health Association
PO Box 9693,
Marion Square,
Wellington, 6141
Email: advocacy@organicnz.org.nz
Website: www.organicnz.org.nz
Law change can support organic dairy and revitalise waterways
/in Farming, Media Releases, OrganicsSoil & Health want Fonterra to collect all certified and in transition to organic Fonterra milk and to pay a premium for it, irrespective of locality.
“We want to see the Government better commit to organic dairy production and therefore more sustainable farming practices,” says Soil & Health National Council member and former Green Party MP, Steffan Browning.
“We consider that a shift towards organic farming practices is needed to protect and enhance our environment and our economy.”
The Ministry for Primary Industries is undertaking a comprehensive review of the Dairy Industry Restructuring Act which includes looking at incentives or disincentives for the dairy industry to transition to higher-value dairy production and processing that global consumers seek for a premium, and more sustainable environmental practices on and off-farm.
Soil & Health has submitted to the MPI review.
There is growing public concern about the environmental impacts from intensive dairy farming, especially in relation to water quality and human health. Certified organic dairy farming however prohibits the use of synthetic nitrogen fertilizer, has lower stock numbers, more biodiversity, higher animal health outcomes, grass-fed cows with no GE feed or palm kernel supplements, and is generally less intensive than conventional dairy farming.
Consumers worldwide are demanding safe, healthy and more environmentally friendly food, and are prepared to pay
for high quality, GE-free, organic dairy products. The 2018 OANZ Organic Market report found that the global organic dairy market is currently estimated to be worth about US$17b. By 2022 the sector is projected to be worth US$25b, the value of organic milk powder being an important contributor.
To meet the demand, Soil & Health says that government intervention is required to incentivize more organic dairy farming.
“Overall there has been limited encouragement for new organic transitions,” says Browning.
“To help farmers make the transition to organics, we would like to see the legislation require that Fonterra collect all certified organic and in transition to certified organic milk and pay a premium above the annual farm gate price for it, irrespective of location or availability of processing capacity.”
ENDS
Media contact
Steffan Browning
Soil & Health National Councillor
021804223
Christmas comes early for the Organic Sector
/in Food, Health, Organics“This is an amazing Christmas present for the organic community and we’re delighted”, says Bailey Peryman, Co-Chairperson for the Soil & Health Association, welcoming the Government’s announcement to progress with a national standard for organic production next year.
“People want clean, safe food, and are increasingly turning to organic foods and products but it’s difficult to be sure that they really are organic. This legislation can provide certainty to everyone and build a clear definition of what the word ‘organic’ actually means.”
The national standard also opens a constructive forum for discussing the differences in practices across New Zealand. We recognise that there are a small number of organic practices and inputs that are currently certified that other producers might consider harmful for stock and the environment. It is critical that we focus on the qualitative outcomes for people – providing clear information about what is in our food and accurate labelling to guide families in making good food choices.
New Zealand is presented with a great opportunity to learn from the failures of organic regulation overseas. Primarily, that regulation needs to be managed by producers and consumers to maintain the integrity of organics within the standard.
Soil & Health has a long history of campaigning for these standards. It cautions that the adoption of a single National Organic Standard is holistic and must not disadvantage small growers and local markets.
“Many of our members are small-scale organic growers and producers who only sell their products locally, direct to their consumers and choose not to become certified due to the costs and effort involved. While all relevant businesses should comply with a new National Organic Standard, the framework of regulation needs to be proportional so not to unfairly disadvantage anyone” says Peryman.
“We are looking forward to working with Government and the sector to draft legislation which ensures that the oversight and integrity of organics is being upheld for the benefit of all”.
Bailey Peryman
Co-Chair, Soil & Health Association
021 122 7638
bailey@organicnz.org.nz
advocacy@organicnz.org.nz
Photo: iStock ID:184813025
Where’s our food from? Better labelling a step forward
/in Food, Media ReleasesThe blindfold will finally be lifted when it comes to buying food, but the Soil & Health Association says consumers need even greater transparency.
Soil & Health welcomes the passing into law of the Consumers’ Right to Know (Country of Origin of Food) Bill. The Bill, which requires food to carry country of origin labelling, passed with near unanimous support last night in Parliament. While footwear and clothing must be identified where they’re from, until now country of origin of food labelling has only been voluntary in New Zealand.
The Bill was a first introduced in 2016 by former MP, and now Soil & Health National Council member, Steffan Browning, as a Green Party Member’s bill.
“Transparent food labelling is fundamental in allowing people to make informed choices. Mandatory country of origin labelling is a step towards allowing consumers to do this,” says Steffan Browning.
The Bill however only applies to single ingredient foods such as fresh fruit, meat, fish and vegetables and Soil & Health says foods of multiple origins should be labelled too. This requirement could be brought in later through the setting of Fair Trading Act regulations.
“The Bill is a building block to more comprehensive food labelling requirements,” says Browning.
Soil & Health is also concerned that several single origin foods have been excluded from the Bill, including flour, oils, nuts and seeds.
“We particularly want flours and grains included, as most of the soy and maize products from the US are genetically modified. It’s absolutely necessary we have GE food labelling, but in that absence of enforcement we should at the very least be able to choose what country maize and soy products are from,” says Browning.
There has been widespread support for country of origin labelling. A survey conducted last year by Consumer NZ and Horticulture NZ found that 71% of Kiwis want mandatory country of origin labelling and 65% said they looked for country of origin labelling when they were shopping.
“There are many reasons why consumers want to know which country their food comes from. Some want to avoid GE food, food with pesticide residues, or food coming from countries with poor labour conditions or environmental and animal welfare standards,” says Browning.
Soil & Health has been campaigning for mandatory country of origin labelling for over a decade, since the government opted out of joining Australia in mandating country of origin labelling under the Food Standards Code on the grounds it would be an impediment to trade.
[ENDS]
Media contact:
Steffan Browning
021804223
Community Support for a GE-free Coastal Marine Area in Northland
/in GEMedia release: Soil & Health Association of NZ
30 October 2018
Usually associated with land-based farming, the Soil & Health Association is now wading into the coastal marine area in its latest bid towards an Organic Aotearoa New Zealand.
A precautionary approach is needed to any genetically engineered (genetically modified) organisms that may be trialed or used commercially in the Coastal Marine Area (CMA), says Soil & Health.
The Association is therefore encouraging the Northland Regional Council to adopt precautionary provisions for GMOs in the Proposed Regional Plan for Northland, and is presenting its case to the Council today. (Soil & Health’s submission can be viewed at https://soilandhealth.org.nz/submissions/submission-on-proposed-regional-plan-for-northland/)
“We want to ensure that the Council adequately protects growers and producers in Northland from the significant adverse effects posed by GMO use,” says Soil & Health co-chair Bailey Peryman.
The Proposed Regional Plan for Northland as currently drafted fails to regulate GMOs in the CMA, despite the Northland Regional Policy Statement placing an obligation on the Council to take a precautionary approach to GMOs in the region.
“We call on the Northland Regional Council to follow the lead of Auckland Council which has already adopted precautionary provisions and banned the outdoor release of GMOs in the CMA via the Auckland Unitary Plan,” says Peryman.
GMOs in the CMA could threaten the economic sustainability of a wide range of activities that benefit from having GE-free status. This includes organic and non-organic primary producers in the Northland Region, including oyster farmers, and any growers who collect seaweed from the coastline for fertiliser.
“Organic certification standards prohibit the use of any input containing GMO material. A certified organic farm could be contaminated by GMOs in the CMA by using seaweed harvested from the coastline. The composting of seaweed is a popular form of natural fertiliser for crops for many organic farmers. Any GE contamination from seaweed would mean having to stop harvesting seaweed for fertiliser use or otherwise risk losing their organic certification.”
“Aquaculture is a growing industry in New Zealand with exports to nearly 80 countries and our seafood regarded as some of the best in the world. Markets around the world don’t want seafood products that are contaminated with GMOs,” says Peryman.
“All New Zealand fish and shellfish products currently enjoy GE-free status. But contamination of kai moana by GMOs could mean the loss of the premium that the GE-free status and reputation attracts.”
“New Zealand has already seen several GE field trials breach the conditions of approval,” says Peryman. “GMOs in the CMA run additional risks due to the fluid nature of the marine environment, making buffering and containment impossible. We have to also expect that activities in the CMA can cross into terrestrial and freshwater ecosystems.”
If GMOs were released into the Northland CMA it would no longer be regarded as a GE-free region. This could affect the marketing of products within New Zealand and internationally, and premium returns.
The latest OANZ Organic Market Report 2018 reaffirms that the growth in New Zealand organic production and exports is very strong, reflecting global trends. It makes sense economically and environmentally to protect and encourage organic primary production.
ENDS
Media contact
Bailey Peryman
021 1227 638
EPA must reassess glyphosate and neonics
/in Media ReleasesWednesday 17 October 2018
PRESS RELEASE FOR IMMEDIATE RELEASE
The Soil & Health Association is calling for an enquiry into the independence of New Zealand’s Environmental Protection Authority (EPA), following the EPA’s announcement of priority chemical reassessments for possible bans or new controls.
“While Soil & Health welcomes the reassessment list, there is a glaring omission of two notable harmful chemicals. We want them added to the list, and we want an inquiry into the processes and decision-making that has led to this,” says Soil & Health co-chair Bailey Peryman.
The chemicals that should be on the list for reassessment are:
Both are heavily used in New Zealand, meaning most people have some exposure to them.
“The EPA must add them to the list and urgently conduct robust independent reassessments of them.”
“To give the community trust in the regulatory system, Soil & Health calls on the EPA to adopt a precautionary and proactive approach around glyphosate-based herbicides like Roundup, instead of its apparent economics-first approach that favours the agrichemical industry over the environment and people’s health.”
“For true environmental protection, the EPA should follow the EU Commission recommendations, which are to minimise glyphosate use in public places such as parks, playgrounds and gardens, and to scrutinise its use as a pre-harvest spray on a number of crops.”
“Christchurch City Council has shown that a transition to glyphosate-free public spaces is possible, and in New Zealand and internationally, organic farmers successfully manage crops without the need for glyphosate herbicides or the bee-killing neonicotinoids, improving environmental, worker, and food safety outcomes.”
“Consumers’ interest in food grown free from synthetic pesticides is rapidly growing both here in Aotearoa and internationally.”
Media contact:
Bailey Peryman
021 122 7638
ADDITIONAL INFORMATION
In March 2015, the International Agency for Research on Cancer (IARC) issued a report labelling glyphosate a “probable carcinogen”. Europe has since come out strongly against the use of both glyphosate and neonicotinoids. Recently in a landmark court case in the US, Monsanto was found to be misleading consumers about the safety of its flagship product, Roundup – the primary ingredient of which is glyphosate.
Following the IARC finding, the NZ EPA and the Ministry for Primary Industries (MPI), contrary to a Ministry of Health recommendation not to, did a poor review of that finding, essentially using flawed science guidelines and data provided by industry. Some industry-supplied glyphosate research has been shown to be ghost-written by Monsanto.
“In Australia, following a Four Corners TV showing of the Poison Papers last week, exposing how Monsanto influences regulators, the Federal Opposition there is calling for an inquiry into the funding and independence of its APVMA (Agricultural Products Veterinary Medicines Authority), the equivalent of New Zealand’s MPI agrichemical products arm and our EPA.”
New Zealand regulators need to be investigated for the same reasons, according to Soil & Health.
Using its new Flexible Reassessment Categorisation Screening Tool (FRCaST), theoretically based on risk to people and the environment, the EPA said it would prioritise 40 chemicals from an initial list of more than 700, most of them used in agriculture although some are also used around the home. However, questions of the effectiveness of the screening tool FRCaST also need to be asked.
“The two international regulatory bodies chosen by the NZ EPA to peer review FRCaST were the National Industrial Chemicals Notifications and Assessment Scheme (NICNAS) in Australia and Health Canada (HC) / Environment and Climate Change Canada (ECCC) which also saw limitations in the EPA approach and sought for New Zealand to have greater alignment with Australia and Canada, neither great examples of the precautionary approach.”
“The NZ EPA has generally used the US EPA and the European Food Safety Authority (EFSA) for risk assessment guidance. They all have been heavily influenced by the agrichemical industry. EFSA, following significant criticism, has since been actively improving its independence and transparency, reducing their exposure to industry.”
Soil & Health believes that neonicotinoids and glyphosate should be phased out quickly.