Allen + Clarke
Agricultural Emissions Pricing Consultation – The Ministry for the Environment and the Ministry for Primary Industries
Consultation Event Feedback Template
Instructions:
• One template is to be filled in per consultation event and provided to Allen + Clarke following each consultation event for
inclusion in the overall analysis. In the first instance, the primary audience is Allen + Clarke, who will focus thematic feedback,
but these will also serve as our primary record/notes for each session.
• Use the prompts provided as suggestions to capture as much information as possible. However, you do not have to answer
every prompt, and can vary from the specific question if this will better capture the themes and information provided in the
session.
• Capture as many Q&As as possible in the designated row, and duplicate the row for each new question. If you know that the
question has already come up and been answered similarly, or exists in our FAQs, you can make a call on either not capturing
it or referencing the relevant FAQ.
• Please file here, or email to 9(2)(g)(ii)
if you cannot access the link.
Date:
18 October 2022
Meeting type:
Online - Zoom
MfE/MPI staff:
MFE: Martin Workman; Hemi Smiler; David Mead; Kara Lok; Hamish Slack; Frankie McGirr
MPI: Warren Gray; Hannah McCoy; Oliver Powell; Claudia Gonnelli
Number of attendees:
165 at peak (10:09 am)
1
Allen + Clarke
Agricultural Emissions Pricing Consultation – The Ministry for the Environment and the Ministry for Primary Industries
Date:
18 October 2022
Demographic of attendees (if
General public
possible, e.g. farmer, NGO,
Māori, general public):
Prompt
Stakeholder feedback
Emissions reporting
Who did attendees think should be
responsible for
reporting and paying
for
emissions?
What feedback did attendees have on
There were questions on what constitutes a collective (e.g. would the same owner
the
thresholds set for farms to report with different agricultural inputs count as a collective?)
emissions?
What did attendees believe would need
to be in place to
include collectives in
the pricing scheme?
Did attendees believe farms will have
Wouldn’t it be fairer to measure per hectare? - Govt has considered this, but it
the
necessary data for reporting by
can’t be appropriately done in the timeframe & raises cross sector equity issues -
2025?
Partnership also struggled to find a solution to this.
2
Allen + Clarke
Agricultural Emissions Pricing Consultation – The Ministry for the Environment and the Ministry for Primary Industries
What feedback did attendees have on
In the levy calculation, is "farm area" the total area of the property (ie on the title)
registration requirements?
or is it just the productive farm area?
Did attendees raise any concerns
about
reporting and payment timing?
Did attendees believe there are any
One attendee had a question about how beef breeders and store farmers would
opportunities to improve the proposed report into the system - “Are we expected to weigh on a regular basis or what? If
approach to
reporting emissions?
weighing, how often? How are breeding cows treated?”
Question: Collectives - speak more to the Government’s thinking on starting with
Māori collectives
New/thorny questions asked by
attendees
Answer:
[Duplicate this row as needed]
Due to the ownership structures / particular impacts on Māori - there are complex
decisions to make for wider collectives, but we are looking seriously into this,
particularly as the sector has serious interest.
Pricing, revenue and incentive payments
What
concerns did attendees have
A participant asked: Why is the Government proposing to link the price of
around the proposed approach to
agricultural nitrous oxide emissions to the price of fossil carbon dioxide emissions
setting levy prices?
in the NZ ETS?
Did attendees offer any
improvements
to the proposed approach to
setting
levy prices?
3
Allen + Clarke
Agricultural Emissions Pricing Consultation – The Ministry for the Environment and the Ministry for Primary Industries
What feedback did attendees have on
the proposed
revenue recycling
strategy?
What did attendees think about an
advisory board for revenue
recycling?
Participant asked what happens if the price a farmer could receive on the voluntary
What
transitional support did
carbon market is higher than the incentive payment offered by the government.
attendees say was needed?
Could farmers opt out of the incentive scheme? We said that yes, you could opt
What approaches did attendees support out of the incentive payment, but you can’t opt out of the levy.
for
incentivising mitigation practices
or technologies?
A participant asked what a system might look like where incentive payments aren’t
What
mitigation practices or
just based on adoption of a mitigation (as our material says this could change but
technologies did attendees think
not what it would change to in a more complex system)We said we could
should be
supported by an incentive
recognise the cost of adopting the mitigation and the emissions reduction in a
payment?
detailed system (as opposed to just a flat adoption-based payment).
Question: What is it about sheep and beef that means they are disproportionately
New/thorny questions asked by
targeted?
attendees
[Duplicate this row as needed]
Answer: Less emissions mitigation options available, and lower profit margins
4
Allen + Clarke
Agricultural Emissions Pricing Consultation – The Ministry for the Environment and the Ministry for Primary Industries
Question: A significant number of intensive dairy operations are deeply in debt.
Their ability to pay will also be an issue. It seems like a "grandparenting" approach.
Is the dairy sector being "grandparented" its emissions?
Answer: No - there will be transitional support where it is needed, not just in the
worst affected sectors
A few people raised the issue of soil carbon. We responded that it could be
recognised once we know more about its effects in NZ.
Question” why are we focusing on technological solutions and not on holistic ones
(eg. Regerative agriculture).
Answer: We answered citing MPI work in commissioning studies to assess the
impact of regerative agriculture in NZ
Pricing carbon sequestration and nitrogen fertiliser
What feedback did attendees have on
A participant asked if biodiversity planting would be incentivised. There were a lot
the proposed approach to
carbon
of questions about sequestration. This included concerns about fairness eg with
sequestration?
shelter belts already planted on farm; and concerns that wide swathes of farm land
What
barriers did attendees raise to
would be incentivised to convert to carbon farming. We said that government
including new categories of
wants to make sure biodiversity is incentivised & is looking into how this can be
sequestration in the NZ ETS?
folded in to recognition of sequestration.
5
Allen + Clarke
Agricultural Emissions Pricing Consultation – The Ministry for the Environment and the Ministry for Primary Industries
Did attendees have any
concerns about bringing
on-farm vegetation into
a farm-pricing system?
Did attendees prefer
pricing nitrogen at the farm level or at the processer
level? Why?
Question: How will biostimulants with little to no N content be treated? - not
answered
New/thorny questions asked by
attendees
[Duplicate this row as needed]
Answer:
Future enhancements
Did attendees prefer a
tradeable
methane quota? What benefits did they
cite?
One participant asked what the agriculture sector didn’t like about this option.
What concerns did attendees have
about
tradeable methane quotas?
What concerns did attendees share
A participant asked if implementation could instead be delayed long enough to
about an
interim processer-level
implement a farm level system. We said that emissions have to be priced in 2025
levy?
by law.
6
Allen + Clarke
Agricultural Emissions Pricing Consultation – The Ministry for the Environment and the Ministry for Primary Industries
What
alternatives to an interim
processer-level levy did attendees
share?
Question:
New/thorny questions asked by
attendees
Answer:
[Duplicate this row as needed]
Impacts and support
One participant asked if transitional support would include purchase and set aside
of land where farms are no longer economic.
How did attendees believe the system
would
impact them?
Concern that they would be penalised when they are already low emissions /
reducing emissions and this would remove their ability to make future reductions.
What
support did attendees believe will
be needed?
If there isn’t anything a farm can practicably do to reduce emissions, they will just
face a cost The participant’s example was a “low emissions” beef operation that
already had 40% native forest coverage on the land block.
What impact did attendees think the
pricing scheme will have on their
Food security / decrease in production was brought up repeatedly - the Paris
communities?
Accord was quoted a couple of times. People questioned the rationale for the
How can
rural communities be
proposal and the certainty that markets are requesting sustainable products.
supported?
7
Allen + Clarke
Agricultural Emissions Pricing Consultation – The Ministry for the Environment and the Ministry for Primary Industries
Did attendees share specific
impacts
Some Maori-owned land (participant cited their whanau land) has always had
for Māori?
indigenous vegetation and so the majority predates the 2008 timeframe. The
participant was concerned that the timeframe could accidentally incentivise
How did attendees think the
Crown
removal of this vegetation. They asked if there was a way to measure the natural
should
protect relevant
iwi and Māori
regeneration occurring since 2008 within the land area and calculate based on that
interests?
figure.
Question: How can I know if I support the proposal if I don’t know the impact (from
price and cap) on my farm?
New/thorny questions asked by
attendees
Answer: There will be further consultation on the regulations where the price will
[Duplicate this row as needed]
be set. Likely to have certainty in 2024 - it is also important there is progress to our
targets
Question: Can you comment on unintended consequences of disproportionate
economic effect on sheep and beef leading to change in land use to carbon
forestry with exotic conifers, which will irreparably damage multi-use food and
fibre-producing land with high landscape and biodiversity values currently being
maintained by low intensity grazing.
Answer: We want to provide incentives that prevent this kind of thing - e.g. for
native afforestation and biodiversity.
8
Allen + Clarke
Agricultural Emissions Pricing Consultation – The Ministry for the Environment and the Ministry for Primary Industries
One participant asked for more information regarding the modelling, and why the
Government’s is different from HWEN’s. Answer: the government’s one has more
granular details.
Implementation, verification, compliance and enforcement
What feedback did attendees have on
Participant asked how farmers would assured consistency in price setting
the proposed
governance structure?
approach if they have no direct input, and cited concerns about stability /
What did attendees think should be
politicisation of the approach between governments if the sector didn’t have a
included in the post-implementation
formal role. We answered this question by noting that the price would be set in
review in 2030?
regulation and there would be consultation with the sector at that stage.
What feedback did attendees have on
the proposed approach to
monitoring
and verification?
One participant asked how mitigations would be audited.
Did attendees support a
government-
run or third-party verification system?
Why?
Who did attendees believe should
fund the
administration of the scheme?
Did attendees have feedback on the
proposed approach to
cost-recovery?
New/thorny questions asked by
Question:
attendees
9
Allen + Clarke
Agricultural Emissions Pricing Consultation – The Ministry for the Environment and the Ministry for Primary Industries
[Duplicate this row as needed]
Answer:
Other/General
A participant wanted to know if the calculator would be incorporated into or aligned
Did attendees have
any other
with Overseer.
feedback on the proposals?
A participant wanted to know why the Govt didn’t adopt all 9 proposed principles
for reducing ag emissions from the CCC.
Question:
New/thorny questions asked by
attendees
Answer:
[Duplicate this row as needed]
10
