The notion of an arbitrary "tax" imposed on farmers for on-farm biogenic greenhouse gas emissions was soundly rejected years ago.  The then stated imperative was that any liability had to be directly related to individual farming enterprises. It is therefore somewhat surprising that He Waka Eke Noa ever put forward a Meat Processor-level hybrid levy proposal for consultation with farmers. [Milksolids is much more straightforward!]

While it arguably provides a theoretical basis for a charge, such a levy is incapable of sending any messages about on-farm management systems. There is also a huge issue in relation to dairy cattle. There are around 70% more on-farm dairy cattle than non-dairy with the slaughter accounting for only 63% of the total carcase weight of non-dairy cattle.  That means that emissions calculated on a per Kg of carcase weight basis are 2.7 times more than for non-dairy cattle. For all practical purposes, this renders the proposal incapable of implementation.

In summary, regardless of the issues with cattle, this option is no different from a tax which is antithetical to the whole concept of GHG emissions charges for farming.

    
        Tick to see analysis
 
  Based on 2018 Livestock numbers            
      Number on-farm Enteric CH4 (Kt)      Manure
        		Kg CO2e /head    
      CH4    N2O    
    Dairy cattle*  A 370.80 29.45 0.19    
    Non dairy      B    
    Sheep    
                     
  *The published 544.46, 50.53 and 0.32 have been corrected relative to numbers (A# ÷ B#), in an attempt to apportion milksolid related emissions    
  An estimate of gross liability based of 2018 figures        
  Slaughter statistics Gg Car- case wt Kg CO2e / KgCw    
   KgCW*
    Dairy cattle        
    Non dairy        
    Sheep        
  TOTAL              
 
Under the current arrangements, there is no discount by 2120.
   
  * These are the overall average Carcase weights with the dairy cattle low because of the calf slaughter numbers.    
                     
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  A meat processor levy - the maths don't work  
           
    While the concept of using meat processor information as a basis for assessing GHG emissions levies has some serious issues with relevance vis a vis messaging, the more fundamental issue is the ratio of carcase weight per head of cattle livestock translating to an emissions factor.   
    Explanation
By definition, the emissions calculation for each sector (dairy & non-dairy in this instance) needs to account for 100% of the sector emissions from the carcase weight of slaughtered animals. In this case we can see below that the dairy sector has 70% more cattle than non-dairy, equating to approximately 70% more emissions but it only has 63.5% of the total slaughter carcase weight.  This means that the difference between the emissions per kg of carcase weight for dairy is 2.7 times more than that for non-dairy.

This means that for all practical purposes, this proposal is incapable of implementation without daily arguments about "what is a dairy farm animal and what is not?".

 		 
    As at 30 June 2018 Numbers Slaughtered Ave Kgcw Gross Kt KgCw /hd  
    Dairy cattle  
    Non-dairy  
    Dairy cattle  
    Tick to exclude calf slaughter
 
    Conclusion: for all practical purposes, incapable of delivering on its design imperatives.