
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:
2nd November 2022
Meeting type:
Online workshop with ENGOs
MfE/MPI staff:
Warren Gray (MPI)
Kara Lok; Hannah Steans; Martin Workman; David Mead; Lauren Blackwel ; Cephas Samwini (MfE)
Glen Lauder (independent facilitator)
Number of attendees:
9(2)(a) (Oxfam Aotearoa)
1

Al en + Clarke
Agricultural Emissions Pricing Consultation – The Ministry for the Environment and the Ministry for Primary Industries
Date:
2nd November 2022
9(2)(a)
(ECO)
9(2)(a)
(Freshwater Ecology and Ag)
9(2)(a) (Environmental Defence Society)
9(2)(a)
(Climate Justice Taranaki)
Demographic of attendees (if ENGOs
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?
2

Al en + Clarke
Agricultural Emissions Pricing Consultation – The Ministry for the Environment and the Ministry for Primary Industries
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?
What feedback did attendees have on
registration requirements?
Did attendees raise any concerns
about
reporting and payment timing?
Did attendees believe there are any
opportunities to improve the proposed
approach to
reporting emissions?
Question:
Looks like public service is depending on ENGOs to questions the assumptions
put forward by the agriculture sector (this concern was widely shares by the
New/thorny questions asked by
group). They expressed their frustration with the actions and progress being made.
attendees
Of icials must consider the interests of all players not only farmers and the
agricultural sector. They want to hear push back from officials about assumptions
[Duplicate this row as needed]
on profitability, rural communities etc
Answer:
3

Al en + Clarke
Agricultural Emissions Pricing Consultation – The Ministry for the Environment and the Ministry for Primary Industries
Pricing, revenue and incentive payments
• What is the point of political administration of levies in the system?
• Methane should be administered as a cap and trade as it is a very harmful
gas in terms of its warming effect. Even Though it is short lived, methane
What
concerns did attendees have
should therefore be priority.
around the proposed approach to
• Why then was the methane cap and trade proposal scrapped
setting levy prices?
• The reference to the 2017 baseline implies grandparenting, but if
Did attendees offer any
improvements
grandparenting is done, it should be for a very short time period.
to the proposed approach to
setting
• Fertiliser charges are better placed on processor
levy prices?
• Who pays for shortfall is the targets are not met? what are the amounts? As
is stands the taxpayer may need to foot the bil for the possible liability
• Amounts given to farmers as incentives for technology uptake to reduce
emissions rather should be geared towards reductions in stock numbers
What feedback did attendees have on
the proposed
revenue recycling
strategy?
What did attendees think about an
advisory board for revenue
recycling?
What
transitional support did
attendees say was needed?
4

Al en + Clarke
Agricultural Emissions Pricing Consultation – The Ministry for the Environment and the Ministry for Primary Industries
What approaches did attendees support
for
incentivising mitigation practices
or technologies?
What
mitigation practices or
technologies did attendees think
should be
supported by an incentive
payment?
Question:
New/thorny questions asked by
attendees
Answer:
[Duplicate this row as needed]
Pricing carbon sequestration and nitrogen fertiliser
What feedback did attendees have on
the proposed approach to
carbon
sequestration? What
barriers did attendees raise to
including new categories of
sequestration in the NZ ETS?
Did attendees have any
concerns
about bringing
on-farm vegetation into
a farm-pricing system?
5

Al en + Clarke
Agricultural Emissions Pricing Consultation – The Ministry for the Environment and the Ministry for Primary Industries
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
The level of ambition reflected in the price setting does not seem to be high
enough. Is there an opportunity to not just achieve the emissions targets but to
exceed them given the urgency of the climate impact. Targets leave room for
higher ambitions on methane exceeding the expectations is legitimate.
Did attendees prefer a
tradeable
methane quota? What benefits did they The fixation on discounting the impact of methane is worrying, even though it is
short-lived it is more potent than the long lived gases
cite?
We would like to see New Zealand do more in methane emissions in alignment
What concerns did attendees have
with the methane pledge to which New Zealand is a signatory.
about
tradeable methane quotas?
We should not tether to Kyoto and Paris but focus on biodiversity and carbon/
climate benefits from secure native regenerative forests.
Pest and weed control to promote indigenous biodiversity
Look out for perverse incentives leading to more intensifications in order to meet
the financial burden of the levy
6

Al en + Clarke
Agricultural Emissions Pricing Consultation – The Ministry for the Environment and the Ministry for Primary Industries
Farmers are paid to adopt abatement – how is that fair to other in the society /
economy
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
• Sheep and beef farmers are aggrieved because they are considering
How did attendees believe the system
vertical equity rather than horizontal equity – 95% discount is a significant
subsidy that disadvantages producers abroad
would
impact them?
• What wil the amount needed for purchasing offshore offsets be – our $3
What
support did attendees believe wil
bil ion at 95%? What are the wealth transfer values
be needed?
• Cost of the status quo – Other sectors of the economy paying for
agricultural emission, Cost of in action, Fiscal risk to the tax payer al need
to be considered
7

Al en + Clarke
Agricultural Emissions Pricing Consultation – The Ministry for the Environment and the Ministry for Primary Industries
• What proportion of emissions reductions can be achieved from land use
change and transition has been part of the advice.
What impact did attendees think the
pricing scheme wil have on their
communities?
How can
rural communities be
supported?
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?
8

Al en + Clarke
Agricultural Emissions Pricing Consultation – The Ministry for the Environment and the Ministry for Primary Industries
What did attendees think should be
included in the post-implementation
review in 2030?
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
Did attendees have
any other
Diversifying away from inefficient animal protein production in favour of alternatives
feedback on the proposals?
eg oat milk
9

Al en + Clarke
Agricultural Emissions Pricing Consultation – The Ministry for the Environment and the Ministry for Primary Industries
How is the leakage analysis determined? – does it account for things like border
tarif s etc. How relevant is it in this context
Of icials must be wary of the risk of the use of the leakage analysis for political
reasons to promote the position of the agricultural sector.
Al ocation definition implies grandparenting.
What figures are we looking at to buy offset abroad
The deadline for submissions is the same for a number of other policy proposals
so might be an effort at the end to get a submission in on time.
Question:
New/thorny questions asked by
attendees
Answer:
[Duplicate this row as needed]
10