COTTON AUSTRALIA LIMITED

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UNFCCC Taskforce Department of the Prime Minister and Cabinet One National Circuit Barton ACT 2600 27 April 2015 Dear Taskforce Members, Cotton Australia welcomes the opportunity to make a brief submission to the Setting Australia s post-2020 target for greenhouse gas emissions Issue Paper. Cotton Australia is the key representative body for Australia s cotton growing industry. The cotton industry is an integral part of the Australian economy, worth over $2 billion in export earnings and employing up to 10,000 people. The industry s vision is: Australian cotton, carefully grown, naturally world s best. Cotton Australia works with industry to achieve this vision by providing a policy and advocacy role, research direction, stewardship and building our farmer s capacity in their own communities. We are proud of our efforts to ensure an efficient and sustainable cotton industry. Our mybmp is a voluntary farm and environmental management system which provides self-assessment mechanisms, practical tools and auditing processes to ensure that Australian cotton is produced with in line with best practice. Cotton Australia is a member of the National Farmers Federation (NFF). The NFF has provided its own submission behalf of members, and we wish to express our support for the key points put forward in the NFF response. These are reiterated below. We have also provided expanded detail in regards to the potential R&D opportunities that could ensure the industry s contribution to future emissions reduction efforts. Policy principles for establishing Australia s post 2020 target In developing Australia s post-2020 emissions reduction targets, Cotton Australia would reiterate the important points made by the NFF and urge the taskforce to consider the following principles: Australia s emissions reduction commitments must not undermine our trade exposed economy. Australia s emissions reduction commitments should be considered from a whole of economy perspective, and not be banded by sector. Australia s emissions reduction commitment should recognise the difference between the variability associated with the natural carbon cycle of agricultural

systems and emissions that result from fossil fuel use and other industrial activities. An emissions intensity approach to agriculture will supports the continued growth of our sector while reducing our emissions footprint. Mitigation and sequestration efforts Australian cotton farmers continue to reduce greenhouse gas emissions and improve the land s ability to store more carbon through practices and innovations including: Maximising the efficiency of major inputs used in cotton growing such as energy and nitrogen, including by: optimising irrigation pump performance, using fuelefficient farm machinery Using alternative sources of nitrogen, e.g. the use of legume rotation crops which fix nitrogen in the soil Implementing other practices to improve soil health including using controlled traffic and minimum-tillage systems Further minimising machinery operations (and therefore fuel use) of spraying (through industry-wide use of herbicide tolerant cotton), and in picking (through broadscale changes in picking machinery used which eliminates a number of energy-dependent handling procedures) Using renewable and alternative energy sources and fuels eg solar panels to power irrigation pumps, and biofuels Conserving and managing areas of native vegetation and riparian areas on farm, which are valuable carbon stores. These practices also contribute to developing landscapes that are more resilient to the impacts of drought and climate variability. The current efforts of the Australian cotton industry in delivering environmental outcomes, including greenhouse gas emissions reduction and sequestration, are captured in the industry s first Sustainability Report 2014, available here: http://www.crdc.com.au/publications/australian-grown-cotton-sustainability-report The primary efforts reported are in relation to: energy and nitrogen use efficiency, soil carbon management practices and representing a whole cotton farm carbon footprint. Which policies should be considered to achieve Australia s post-2020 target? Cotton Australia supports the NFF view that that the Government must maintain its policy focus on voluntary climate policy initiatives that enable the Australian agriculture sector to make a contribution to emissions reduction efforts. Continued and sustained investment in research and development (R&D) is key to driving the improvement of the carbon efficiency of our farming systems and enabling the agriculture sector to contribute to emissions reduction. The development of costeffective emissions reduction technologies and practices that also improve productivity or efficiency on farm will be most effective. Attachment 1 provides detail around cotton industry R&D opportunities that will ensure the industry can contribute to future

emissions reduction efforts. This builds on a base of effort and research, development and extension. Which policies should not be considered to achieve Australia s post-2020 target? Policies that reduce the competitiveness of Australian farmers or inhibit the ability of the sector to grow and take advantages of the export opportunities available to them are not supported by Cotton Australia. Cotton Australia does not support the reintroduction of a carbon tax or economy wide emissions trading scheme. Modelling undertaken by agriculture industries on the impacts of the carbon tax showed that a typical cotton farm businesses would incur total annual cost increases of 2.1 percent, producing a reduction in farm net income of 5.5 percent at year five (assuming a $20/tonne price of carbon). Cotton Australia welcomes future opportunities to engage with Government on Australia s post 2020 emissions reduction target efforts. Please do not hesitate to contact me on 02 9669 5222 or at angelab@cotton.org.au to discuss our submission in more detail. Yours faithfully Angela Bradburn Policy Officer, Cotton Australia

Attachment 1: Cotton industry R&D opportunities Background Government support for research, development and extension (RD&E) in emissions reduction and sequestration in agriculture is highly important to ensure the sector can manage in a carbon constrained economy, and contribute to emissions reduction efforts. RD&E has been a fundamental driver of the Australian cotton industry s success, and ability to remain productive, competitive and environmentally sustainable. The industry has sustained a solid RD&E effort in climate science and greenhouse gas mitigation/sequestration which has aimed to: o Ensure growers can manage climate variability and climate change o Understand the sources and sinks for carbon emissions on farm and in landscapes, and management practices to mitigate emissions, enhance sequestration o Develop practice guidelines, support and tools for growers to minimise emissions and maximise sequestration opportunities on farm, and to understand government policies and opportunities to participate in carbon markets. The cotton industry is also driving an effort to improve farm and industry-wide reporting on our carbon footprint, as part of broader sustainability reporting. This organised RD&E effort has worked with government policies and programs aimed at addressing climate change and emissions reductions in primary industries, e.g. the Climate Change Research Program and recent Carbon Farming Futures program. These government programs (competitive grants) have been fundamental to driving the carbon/climate RD&E effort in the cotton industry within the last decade. This has been important particularly given the volatility of the industry s production (reflecting climate conditions) and therefore available RD&E budget. The industry currently has projects under the Filling the Research Gap, Action on the Ground and Extension and Outreach. They have enabled the industry to fill key gaps in knowledge and understanding, harness capacity to address demonstration and knowledge extension needs and determine future directions. Most recent work undertaken via these projects has delivered important outcomes e.g.: o More detailed understanding of emissions in the cotton farming system, and the impact of management practices. This has been supported by local trials. o Industry emissions factors which had fed in to the national inventory calculations o Contributed to the development of a cotton method under the Emissions Reduction Fund focused on enhancing nitrogen fertiliser use efficiency o Built capacity of the industry s extension team in carbon farming policy (via face to face training and webinars, and enabled the industry to developed a technical carbon farming extension specialist and drive information campaigns). o Collaboration with other industries Importantly, this new work and knowledge is being fed into the industry s primary platforms for delivering information to cotton growers our extension team and industry Best Management Practices program (online farm and environmental management system). Future opportunities Broadacre farming systems like cotton are complex, open, biological systems and emissions sequestration monitoring and management is detailed and expensive. Whilst a body of work exists, there is still more RD&E required. The industry has a strong focus on maximising production efficiencies and managing for landscape health (soil, water and vegetation). These efforts make business sense but also reduce emissions and enhance sequestration. Some areas of future RD&E opportunities are summarised below: 1 P a g e

Reducing emissions from nitrogen fertilisers: o Further understanding of emissions sources and interaction with other inputs e.g. water. Local work is also important given the difference of the Australian systems and context compared to published literature, which often underpins national inventory calculations (e.g. northern hemisphere examples). o managing nitrous oxide losses in the irrigation network (including channels and storages) research is indicating this is a potential mitigation opportunity o the potential for rapidly re-using N enriched irrigation water to minimise loss o investigating natural regulators of the denitrification process (eg exploring whether altering the soil chemistry reduces denitrification and subsequent emissions) o accumulating soil carbon and the relationship with N2O/N2 emissions by region o the use of soil mapping & variable rate nutrient application to improve nitrogen fertiliser use efficiency o nutrient cycling in the field under climate change scenarios o promoting the use of seasonal forecasts to assist with irrigation scheduling and nitrogen applications o overcoming constraints to wider commercial use of enhanced efficiency fertilisers o development of clear regional benchmarks Driving uptake of existing knowledge and best practice through smart extension. There are still significant opportunities to drive production efficiencies through extending existing knowledge (e.g. optimising fertiliser use and energy efficiency as two main GHG sources and areas for further gains). Farmers are busy, inundated with information and making more and more complex decisions. We require simple, fast information support and tools that can be integrated into business operations. The industry already has developed some tools to help farmers these require refinement, and support for trialling and implementation. E.g.: o apps, calculators (carbon, energy), fertiliser budgets o predictive tools (e.g. N losses and integrating also economic cost/benefits) o case studies o facilitating engagement/delivery by key agents (e.g. private advisory sector) An effective process for engaging farmers may include: profiling emissions on farm to identify losses/sequestration opportunities (and economic benefits) using a calculator/tool and providing key mitigation/sequestration management actions Designing and piloting renewable energy projects eg solar panels to power irrigation pumps, battery storage, regional energy solutions (e.g. exploring different energy mixes), biofuels Recognising the carbon sequestration of riparian ecosystems as a special case in the Emissions Reduction Fund (areas of riparian and native vegetation hold significant carbon stores on cotton farms) Government facilitating a pilot use of ERF methods to help overcome participation challenges. Further, Government could consider working with industry to ensure mybmp accredited cotton farms are recognised for their emissions reductions and sequestration efforts. The industry has a strong focus on mybmp and grower participation. The program includes modules which ensure growers monitor and manage for their emissions reductions/sequestration on farm (Energy and Input Efficiency, Soil Health and Natural Assets). Growers implementing best practice could be recognised under government direct action policies, and therefore able to access a financial incentive. This would also ensure emissions are managed across the whole farm. Government ensuring appropriate coordination between relevant program/policy areas (e.g. emissions reduction and energy productivity; energy efficiency and water use efficiency) 2 P a g e