
Al en + 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 fil ed 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 Al en + Clarke, who wil focus thematic feedback,
but these wil 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 wil 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:
26 October 2022
Meeting type:
In person workshop: Ag Sector Leaders group – Napier;
MfE/MPI staff:
Kara Lok, David Mead, Peter Ettema, Kate Simpson, Warren Gray, Hannah McCoy
Number of attendees:
12
1

Al en + Clarke
Agricultural Emissions Pricing Consultation – The Ministry for the Environment and the Ministry for Primary Industries
Date:
26 October 2022
Demographic of attendees (if Farmers
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
the
thresholds set for farms to report
emissions?
What did attendees believe would need
to be in place to
include collectives in
the pricing scheme?
Did attendees believe farms will have
the
necessary data for reporting by
2025?
2

Al en + Clarke
Agricultural Emissions Pricing Consultation – The Ministry for the Environment and the Ministry for Primary Industries
What feedback did attendees have on
registration requirements?
Did attendees raise any concerns
about
reporting and payment timing?
Did attendees believe there are any
• Land class determines what you can do. Opportunities under the pricing
opportunities to improve the proposed
system are not the same.
approach to
reporting emissions?
• How to include changes from other policies
Question:
New/thorny questions asked by
attendees
Answer:
[Duplicate this row as needed]
Pricing, revenue and incentive payments
• There needs to be an end point. It is hard for there to be influence and
behaviour change without their being an end point for pricing. Including
What
concerns did attendees have
dif erential pricing and benchmarking. At the moment it feels like they wil be
around the proposed approach to
taxed forever.
setting levy prices?
• Ef ective drivers of behaviour change should be mitigations, then policy, and
Did attendees offer any
improvements
then price last. Don’t need to do an emissions tax to incentivise land use
to the proposed approach to
setting
change. Looking at better ways to spend money other than a tax.
levy prices?
• It needs to incentivise the right things.
• The unit the price creates is important- the other factors in the policy result
in this on being a tax on land use class.
3

Al en + Clarke
Agricultural Emissions Pricing Consultation – The Ministry for the Environment and the Ministry for Primary Industries
• There was discussion about pricing per hectare vs per tonne of product. Dry
stock emissions on per hectare basis- more likely to achieve reductions you
want
• When people have an end point- they know they wil be off the hook
• Trying to force the contraction- mitigations are not physically available
• Need to create a goal rather than just being taxed
• Could there be subsector targets or end points?
• There needs to be a pathway to be able to not pay.
• A tax is not an incentive
• Issue with taking money off farmers to only give it back- seems like a
reallocation of funds via bureaucracy. Want recognition for what they do-
What feedback did attendees have on
don’t want handouts.
the proposed
revenue recycling
• Already pay levies etc to B+L etc- why can’t they manage the revenue?
strategy?
• Confidence lost, ceased investment, ceased development—reverse trend of
What did attendees think about an
productivity and create a reliance on the cycle of handouts
advisory board for revenue
• For extensive farmers, this feels like taking money off them that they could
recycling?
use to invest in environmental stuff.
• Don’t want to be taxed just to receive a handout back- creates a tax
What
transitional support did
• Concern around the lack of mitigations for deer. There is also concern about
attendees say was needed?
who is going to invest in mitigations for deer when it is such a small industry.
•
What approaches did attendees support
Opportunities not being uniform- land use class in particular
for
incentivising mitigation practices
• Concern about what the mitigations wil cost- as they know it is required,
or technologies?
what is to stop the suppliers pushing the price up?
• There needs to be the freedom for new technologies to come onboard.
4

Al en + Clarke
Agricultural Emissions Pricing Consultation – The Ministry for the Environment and the Ministry for Primary Industries
What
mitigation practices or
• Discussion about coal burners etc v methane reductions- ability to reduce
technologies did attendees think
carbon emissions is already there. Mitigations for ag are not.
should be
supported by an incentive
• Trying to force the contraction- mitigations are not physically available
payment?
• No mitigations for extensive farms- so taxing and taking away money that
could be spent on other environmental benefits
• Constraints of time and money to make things happen
Question:
• Is there an opportunity to look at benchmarking at a sub sector level?
New/thorny questions asked by
• Is there an option for dif erential pricing?
attendees
[Duplicate this row as needed]
Answer:
Pricing carbon sequestration and nitrogen fertiliser
• Sequestration feels like a token- based on the cost involved to fence etc.
What feedback did attendees have on
• Attendees raised the point that for many hil country farms investing pines is
the proposed approach to
carbon
not effective, and limited abilities to do this.
sequestration?
• Attendees think that the ETS is more effective at increasing afforestation
What
barriers did attendees raise to
on-farm than this programme.
including new categories of
• Cost involved to prove pre additionality outweighs any return that wil be
sequestration in the NZ ETS?
received- as with pest control and fencing as well.
• Sequestration is a distraction from the policy outcomes
• Forests can be a liability- e.g. fires and pests
5

Al en + Clarke
Agricultural Emissions Pricing Consultation – The Ministry for the Environment and the Ministry for Primary Industries
Did attendees have any
concerns
• Compliance costs higher for deer farmers
about bringing
on-farm vegetation into
• Opportunities not equal across land class
a farm-pricing system?
Did attendees prefer
pricing nitrogen
at the farm level or at the processer
level? Why?
Question:
New/thorny questions asked by
attendees
Answer:
[Duplicate this row as needed]
Future enhancements
Did attendees prefer a
tradeable
methane quota? What benefits did they
cite?
• A cap and trade scheme is the least preferred option
What concerns did attendees have
about
tradeable methane quotas?
What concerns did attendees share
about an
interim processer-level
• A cap and trade scheme is the least preferred option
levy?
6

Al en + 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
• At the moment, participants are worried about the cost of the system,
leading to financial insecurity and uncertainty with budgeting. Participants
are finding it dif icult to have the confidence to invest anything extra.
• Currently, environmentally focused farmers are putting the breaks on what
they are doing as they are not sure what the end goal is.
How did attendees believe the system
• Concern about compounding impacts of other policies- the broader picture
would
impact them?
of other govt proposals. Some of these are very costly- i.e. fencing
waterways
What
support did attendees believe wil
•
be needed?
Major concerns with destroying confidence in investment
• It is money they have to find over the liability.
• Discussion about why we do this when the risk is so high- what is the
sacrifice for?
• Market access- wil this result in competitive advantage? Wil it give trade
benefits?
• How to get maximum profitability from what you’re doing
7

Al en + Clarke
Agricultural Emissions Pricing Consultation – The Ministry for the Environment and the Ministry for Primary Industries
• Concern about the public perception of hand outs to farmers
• How can they manage when there is no mitigations
• There is nowhere enough extension support
• There wil need to be support to help the bottom 20% keep up
• Big concerns about rural communities- i.e. the ability for schools to be able
to stay open.
• If extensive farming goes, this will af ect all rural communities
• A lot of jobs have been created in small towns servicing new equipment etc
in small towns, which doesn’t happen with forestry. Concern that with this
pricing, the only option wil be
• Lots of discussion about maintaining the incentive for future generations to
consider farming.
What impact did attendees think the
• Need to have buy in from all parts of the country
pricing scheme wil have on their
• Farmers and growers want to be valued as a contributor to the country.
communities?
• Stil to be in a position where people are doing the right thing- so that the
How can
rural communities be
top 20% can carry everyone else. Relying on everyone showing up is
supported?
unrealistic- i.e. with catchment groups lots of farmers aren’t showing up.
• The farmers noted that they are high profit leaders. Farmers with lower
margins probably have a lot more fear.
• The future vision for NZ- what does GHG pricing, FWFP and biodiversity
look like? Is it possible to achieve everything at once?
• Need to understand what the impacts to broader NZ wil look like.
• There is no focus on the inter-generational impacts
• Thinks the messaging from urban folk has been unfair and blames farmers
• Heaps of concern about conversion to pine
• If 25% goes- whole small towns will go
8

Al en + Clarke
Agricultural Emissions Pricing Consultation – The Ministry for the Environment and the Ministry for Primary Industries
• Heaps of services and jobs are reliant on farming- if you pull the base down
the entire pyramid falls down
• These impacts on small rural communities/ school populations are already
being seen/ felt- concerns about how this pricing scheme wil compound
this.
• Concerns about the impacts on employment/ attractiveness of the industry
Did attendees share specific
impacts
for Māori?
How did attendees think the
Crown
should
protect relevant
iwi and Māori
interests?
Question:
New/thorny questions asked by
attendees
Answer:
[Duplicate this row as needed]
Implementation, verification, compliance and enforcement
What feedback did attendees have on
the proposed
governance structure?
• MPI not a trusted support system- there has to be a culture/ mindset change
What did attendees think should be
for extension etc to work
included in the post-implementation
review in 2030?
9

Al en + Clarke
Agricultural Emissions Pricing Consultation – The Ministry for the Environment and the Ministry for Primary Industries
What feedback did attendees have on
the proposed approach to
monitoring
and verification?
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?
Question:
New/thorny questions asked by
attendees
Answer:
[Duplicate this row as needed]
Other/General
Future vision/ end goal
Did attendees have
any other
•
feedback on the proposals?
Key theme of the meeting was what the end goal is- and the need to focus
on this end goal as wel as the journey.
• Missing a future vision of what NZ looks like
10

Al en + Clarke
Agricultural Emissions Pricing Consultation – The Ministry for the Environment and the Ministry for Primary Industries
• It’s about the uptake- not so much the what, it’s the how- how do we get
there.
Concerns with HWEN Partnership
• Not sure how much mandate HWEN has- these face to face meetings with
farmers didn’t happen
• During HWEN consultation, farmers were led to believe knowing their
numbers was the end goal
• The use of the ETS as a threat
• Farmer reference group didn’t have the information behind them until after
the consultation- farmers were not armed with the knowledge to go through
consultation
• Didn’t have the proper information so couldn’t give an opinion- consultation
was not backed by information on impact
• Lots of reference to the Paris Accord and food production
Path dependence
• Discussion about path dependence for HWEN Partnership- they thought it
was ETS or farm pricing and they wanted to stay at the table
• There is really tight deadlines for government- wanted to note that decisions
can be reversed and please don’t stick to something that isn’t feasible.
• Trust is lacking
11

Al en + Clarke
Agricultural Emissions Pricing Consultation – The Ministry for the Environment and the Ministry for Primary Industries
• Concern about political inertia
Legislated targets
• Is it all about the targets? Or is it about an ideal outcome?
• What is the process for setting the targets?
Question:
New/thorny questions asked by
attendees
Answer:
[Duplicate this row as needed]
12