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:
2/11/2022
Meeting type:
Ag Sector Leaders Group- Ashburton
MfE/MPI staff:
MPI- Peter Ettema, Fleur Francois Mele Tabukovu, Loretta Dobbs
MfE- Jessica Bensenmann, Cephas Samwini, Angela Christensen
Number of attendees:
1
Al en + Clarke
Agricultural Emissions Pricing Consultation – The Ministry for the Environment and the Ministry for Primary Industries
Date:
2/11/2022
Demographic of attendees (if Ag sector leaders including Deer Industry NZ, FAR, Fed Farmers, Dairy NZ, Beef and Lamb
possible, e.g. farmer, NGO,
Māori, general public):
Prompt
Stakeholder feedback
Emissions reporting
Reporting- Define core pil ars of the pathway. Commercial sector can help the
government to report. Provide consistent avenues of reporting.
Who did attendees think should be
Last thing we need is another silo to send info to. We already send it to 3-4 places
responsible for
reporting and paying
and it is the same info every time. Look at agriculture as a whole and don’t silo it.
for
emissions?
Collectives- How is collective/catchment group work for instance, planting riparian
What feedback did attendees have on
margins on unowned land, recognised?
the
thresholds set for farms to report Emissions- What happens if emissions decrease and we overshoot the targets?
emissions?
There should be a mechanism that is able to wind back pricing as that’s not what’s
What did attendees believe would need required for change to be seen. Price wil go up regardless of performance. If ag
to be in place to
include collectives in does good job, what would that mean for pricing? What is the light at the end of the
the pricing scheme?
tunnel/incentive? It should be a continual y sinking cap. Need to communicate
what the numbers mean. There are ridiculous assumptions made in modelling (ie
increase in deer). Freshwater and biodiversity not included in model ing. Model to
set prices is not good enough.
2
Al en + Clarke
Agricultural Emissions Pricing Consultation – The Ministry for the Environment and the Ministry for Primary Industries
Reporting 2025- Identify clusters to focus on for 2025 then support further
development. Use platforms already created.
Did attendees believe farms will have
The government has taken the proposal and trimmed it to what might be
the
necessary data for reporting by
deliverable by 2025. Agriculture needs to be careful in wanting to develop a perfect
2025?
solution that may ‘bite us’. Need to ask how much can we live with by 2025 and
What feedback did attendees have on
then after that, the building on to it takes place.
registration requirements?
The timeframes are unreasonable when you’re trying to create fundamental
Did attendees raise any concerns
about
change for the future. ‘Harry Clarke and his 9 areas of science’ was referred to and
reporting and payment timing?
it says that the likelihood of landing any of it by 2025 is not happening for us to
have levers.
Did attendees believe there are any
opportunities to improve the proposed
approach to
reporting emissions?
Question:
New/thorny questions asked by
attendees
Answer:
[Duplicate this row as needed]
Pricing, revenue and incentive payments
3
Al en + Clarke
Agricultural Emissions Pricing Consultation – The Ministry for the Environment and the Ministry for Primary Industries
Setting levy prices- Is the purpose of the whole thing to change farmers’
behaviour? If yes, where is the incentive to do that? The whole levy is a
punishment i.e., for livestock types, fertiliser, etc.
The independence of price setting has been removed. Sitting it with the CCC is a
risk.
What
concerns did attendees have
Pricing must be independent from politics (including for ETS and recycling).
around the proposed approach to
Price setting mechanism must include other factors, not just consider them i.e.,
setting levy prices?
social/economic factors. The government is only interested in the trajectory of
Did attendees offer any
improvements meeting the target. Ministers
can consider other factors but don’t have to. Other
to the proposed approach to
setting
factors can be ignored, even in downturns of the economy, etc. You can’t create a
levy prices?
sustainable system by prioritising only one thing. Al factors should be considered.
An unintended consequence of pricing is that it wil lead to the sector disappearing
altogether.
The National Inventory has its own way of calculating emissions and that needs to
be recognised. Pricing mechanism doesn’t work unless the science is rapidly
updated. If the National inventory is set on international standards, we cannot be
hamstrung by it as it may not be updating quick enough.
What feedback did attendees have on
the proposed
revenue recycling
strategy?
There is no independence re: funds administration. Politics must be visually
removed otherwise the rural sector wil not be on side.
What did attendees think about an
advisory board for revenue
Recycling must go back to agriculture, it can not go overseas.
recycling?
4
Al en + Clarke
Agricultural Emissions Pricing Consultation – The Ministry for the Environment and the Ministry for Primary Industries
The situations are dif erent on dif erent classes of land. It seems you are
Indiscriminately picking out certain farm systems and treating them dif erently than
others. Prefer a tax instead of an indiscriminate levy.
What does the government want to achieve? Do they want us to change farming
systems? If so, why not incentivise the people who already are? They are trying to
take money off of farmers to spend on research to help farmers with decision
making but in reality it takes money from farmers and puts it into centralised
groups, and that is not fair. Levy is pushing us down a rabbit hole and there is no
coming back.
Transitional support- The implementation is daunting. We need to know now what
you wil need/want for reporting. It is too hard to do retrospectively (trying to find
What
transitional support did
receipts from a year ago, etc).
attendees say was needed?
Be clear about the direction you want us to go as a whole. Freshwater regs are
What approaches did attendees support pushing us in one direction and HWEN in another.
for
incentivising mitigation practices
or technologies?
Mitigation/technologies- There should be local conversations about mitigations as
all properties are dif erent.
What
mitigation practices or
technologies did attendees think
When/where are tools available? The idea of an EcoPond (as in discussion doc) is
should be
supported by an incentive
expensive. It is $76k to install and costs between $37k-47k each year to operate.
payment?
This costs more than to just pay a tax. Why would you do it? Mitigation tools
cannot be economical y detrimental to implement or farmers wil pull the pin as it is
not affordable.
New/thorny questions asked by
Question:
attendees
5
Al en + Clarke
Agricultural Emissions Pricing Consultation – The Ministry for the Environment and the Ministry for Primary Industries
[Duplicate this row as needed]
Answer:
Pricing carbon sequestration and nitrogen fertiliser
Sequestration- It is not hard to document, use a drone to map for sequestration.
What feedback did attendees have on
How is science being used? You can’t cherry pick to suit agenda and that’s what is
the proposed approach to
carbon
being done. Natural cycles are important. I.e., the sequestration of carbon and
sequestration?
saying its too hard. Recognising people have done good work is important,
currently the system doesn’t recognise hard work such as planting etc. The design
What
barriers did attendees raise to
doesn’t complement the opportunity at hand.
including new categories of
sequestration in the NZ ETS?
Looking forward is important as there are always improvements to be made.
Maintaining market access is key. We don’t see tools going forward to be able to
Did attendees have any
concerns
make improvements/progress. Sheep/beef/deer are being hammered but they
about bringing
on-farm vegetation into have the land for sequestration, dairy does not. Sequestration is not as hard to
a farm-pricing system?
manage as what is being said, this is a major issue.
Did attendees prefer
pricing nitrogen
at the farm level or at the processer
level? Why?
New/thorny questions asked by
Question:
attendees
[Duplicate this row as needed]
Answer:
6
Al en + Clarke
Agricultural Emissions Pricing Consultation – The Ministry for the Environment and the Ministry for Primary Industries
Future enhancements
Did attendees prefer a
tradeable
methane quota? What benefits did they
cite?
What concerns did attendees have
about
tradeable methane quotas?
What concerns did attendees share
about an
interim processer-level
levy?
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
7
Al en + Clarke
Agricultural Emissions Pricing Consultation – The Ministry for the Environment and the Ministry for Primary Industries
A lot of concern around MPI and MfE operating in silos. There are demands from
government that something is done but other legislation in place contradicts that
i.e. Fit For Purpose says to move to horticultural production yet ECan’s PC7 says
that we can’t increase vege production.
Everything in agriculture is fragmented and working in silos. If we do ‘x’ with one
thing, we need to understand how that affects the whole system i.e. agricultural
communities, water quality. Compared at a global level, NZ ag is doing really well
so why are we being penalised?
The ETS and HWEN are not in isolation, they are all interconnected. Land use
How did attendees believe the system
change is an option for mitigating but that is taken out of our hands.
would
impact them?
The system doesn’t recognise the efficiency of agriculture that has grown over
What
support did attendees believe wil generations. There is a fear international y of NZ getting it wrong and that there wil
be needed?
be repercussions for other countries if those governments also follow suit.
Land use changes all the time due to markets. We need the flexibility to change
farming systems. Not a system that declines that opportunity.
Rate of change is unsettling given the multitude of plans. There are impacts on
wellbeing of communities.
Concerned about the balance of farmers and the government shifting. Particularly
around merino wool and how benefits are calculated. Same with beef. Are we
talking about reducing emissions or making change on farm? Wil we get the
results we’re looking for?
8
Al en + Clarke
Agricultural Emissions Pricing Consultation – The Ministry for the Environment and the Ministry for Primary Industries
Forestry is reducing groundwater by 30%. OIO has the ability to invest in that. The
OIO is allowing land to go to forestry so farms are going away. Settings around the
ETS, et are driving this behaviour.
It is important to look at the big picture. How wil this affect our
communities/country/globe? What does it all mean on the ground?
There is a real risk that this wil pick off the smaller industry first such as deer as
we don’t have the big numbers to carry on. There is not great data on deer to see
what they produce as they won’t go into the chambers for data collection. Other
What impact did attendees think the
industry falls away as a result.
pricing scheme wil have on their
communities?
This could be the last generation of arable farmers. For new farmers coming in
with increasing tax, why would they?
How can
rural communities be
supported?
In 1980s we could increase production to succeed. Now the only way to deal with
this proposal is to decrease stock production. I then have to ask How do I increase
per head performance to pay the bil s? We are doing good there already and I’m
not sure how we add more per head and stil meet the needs of biodiversity,
freshwater, landscape values, etc. When things (legislation) contradict how do you
mange? You need to link freshwater with climate change. We wil only be good at
succeeding if we are in control of our destiny. If we are not, things wil not be good.
In the high country, if we decrease stock, then we wil need to increase plants (tree
growth) but that also leads to fires (i.e. L Ohau fires a couple of years ago) due to
wildings and that also has unintended consequences.
Did attendees share specific
impacts
The law around the Treaty must be applied consistently. Matauranga Māori is
for Māori?
knowledge held by everyone in their own place. It is not a one size fits all solution.
9
Al en + Clarke
Agricultural Emissions Pricing Consultation – The Ministry for the Environment and the Ministry for Primary Industries
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?
2030 review- Stuff needs to be in place so that build-ons to the system wil happen.
Legislative pathways are key to move the system on.
What did attendees think should be
included in the post-implementation
The ability to review is important, including the mitigations. Ground truthing the
review in 2030?
model and getting the assumptions right is key.
What feedback did attendees have on
the proposed approach to
monitoring
and verification?
Auditing- Be efficient. The IR never audits us. Why is there so much auditing?
Did attendees support a
government-
run or third-party verification system?
Why?
10
Al en + Clarke
Agricultural Emissions Pricing Consultation – The Ministry for the Environment and the Ministry for Primary Industries
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
Did attendees have
any other
feedback on the proposals?
Question:
New/thorny questions asked by
attendees
Answer:
[Duplicate this row as needed]
11
