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:
9 November 2022
Meeting type:
Iwi/Māori hui - in person
MfE/MPI staff:
Julie Collins, Raniera Bassett, Waitai Petera, Kate Simpson, Warren Gray, Oliver Powell, Angela
Christensen, Margie Wheeler, Troy Para, Malcolm Welsh
Number of attendees:
19 (including govt)
1
Al en + Clarke
Agricultural Emissions Pricing Consultation – The Ministry for the Environment and the Ministry for Primary Industries
Date:
9 November 2022
Demographic of attendees (if Iwi/Māori
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?
• Implementation could devalue Tiriti settlements, create inflationary pressure
What feedback did attendees have on
- some thought an exemption would be appropriate
the
thresholds set for farms to report
• Distrust of processors to pass on the value associated with incentives
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
Participant was against the 1 Jan 2025 start date as it doesn’t line up with any
2025?
farmers’ operating years. They wanted a 1 July start date.
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
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
What
concerns did attendees have
around the proposed approach to
• A participant noted that when the margins are narrow, paying the levy wil be
setting levy prices?
a big enough problem that it doesn’t matter if it’s coming back via RR
Did attendees offer any
improvements
• Distrust of Ministers setting prices
to the proposed approach to
setting
levy prices?
3
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
revenue recycling
strategy?
What did attendees think about an
advisory board for revenue
recycling?
What
transitional support did
attendees say was needed?
What approaches did attendees support
for
incentivising mitigation practices
• Participants saw limited options for mitigations in the immediate future,
or technologies?
besides sequestration. There was also scepticism about future solutions
having the predicted benefits. One participant said they wanted ‘natural
What
mitigation practices or
solutions to natural problems’
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
4
Al en + Clarke
Agricultural Emissions Pricing Consultation – The Ministry for the Environment and the Ministry for Primary Industries
• The offset associated with additionality is not enough - especial y when
there is no recognition of sequestration in P90 forest. They don’t line up with
the historical reality - a lot of land was felled before 1990 and the vast
What feedback did attendees have on
majority of indigenous forest is new on that land (and stil has a lot of
the proposed approach to
carbon
growing to do)
sequestration?
o 6.5 tonnes of sequestration annually according to Ngā Whenua
What
barriers did attendees raise to
Rāhui, govt is giving credit for 0.5t
including new categories of
• There was concern that if we rely too heavily on permanent sequestration
sequestration in the NZ ETS?
this wil limit options for generations and permanently alter the land
Did attendees have any
concerns
• The contract system is too complicated - farmers just want one system,
about bringing
on-farm vegetation into
sequestration needs to offset the levy directly.
a farm-pricing system?
• Significant concern about mass pine plantation - Mass pine plantation
(acidic) is costly to water supply - especial y in the north when it’s dry for 8
months of the year. Leaches into groundwater
•
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]
5
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?
Opposition to the ETS backstop - they wanted certainty about the system as soon
What
alternatives to an interim
as possible.
processer-level levy did attendees
share?
Question:
New/thorny questions asked by
attendees
Answer:
[Duplicate this row as needed]
Impacts and support
How did attendees believe the system
• Participants questioned why they have to abide by a government timeframe
would
impact them?
when govt hasn’t tried to engage on their terms. They were concerned
6
Al en + Clarke
Agricultural Emissions Pricing Consultation – The Ministry for the Environment and the Ministry for Primary Industries
What
support did attendees believe wil
about the time allowed for submissions and haven’t had the time or
be needed?
information to fully assess the impacts of their whenua.
• Bull farmers don’t have eligible sequestration (because the forest is part of
the paddock)
• If we do everything we can [to limit emissions], and nobody else does
anything, we wil be worse off for no reason
What impact did attendees think the
• A participant wanted central government to step out of their affairs and
pricing scheme wil have on their
provide the resource to do what’s needed - determined by the whānau /
communities?
community
How can
rural communities be
• What does a 10% reduction look like in terms of animals, product, value,
supported?
jobs? Have you considered the knock-on effects?
• Most of the sheep & beef farms that wil go out of business wil be Māori -
much of this is due to the profile of the land. A disproportionate amount of
whenua Māori is already in forest and under the proposed policy it wil be
Did attendees share specific
impacts
hard to argue with putting more into carbon forestry as it’s more profitable.
for Māori?
• The calculations we are using are Westernised models, and a lot of the
focus has been on Western solutions
How did attendees think the
Crown
should
protect relevant
iwi and Māori
• The idea of an exemption was raised multiple times
interests?
• Māori wil continue to manage the land in accordance with their values, but
if Treaty settlements lose value they wil want to talk to the Min of Treaty
Settlements. Whenua Māori should have been the model of best practice.
• A hit to agriculture [and its economic contribution] is also a hit to essential
services that Māori need the most
7
Al en + Clarke
Agricultural Emissions Pricing Consultation – The Ministry for the Environment and the Ministry for Primary Industries
•
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?
• In policy development with HWEN, Iwi/Māori weren’t at the table - FOMA
What did attendees think should be
were & they don’t represent iwi, PSGEs do
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?
8
Al en + Clarke
Agricultural Emissions Pricing Consultation – The Ministry for the Environment and the Ministry for Primary Industries
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
• A participant wanted assurance that this change was going to lead to a
premium on their products, and said that participants in ‘zero carbon’
marketing programmes are yet to see any financial benefit be passed on to
them.
• Coming to a consultation event is a day off work, so Govt is not hearing
adequately from mana whenua and ahi kā. Time doesn’t matter if the
resource isn’t there
Did attendees have
any other
• Peat is not in the ETS but emits 2% (of farming emissions or total?) - if it did
feedback on the proposals?
go in that would real y hurt iwi/hapū. Participant cited their work with
NZAGRC (sp?) that re-wetting areas of peat land could offset 60% of
agricultural emissions
• There is already a lot of external pressure, e.g. from banks who won’t lend
to groups who can’t quantify their carbon footprint. There was a perception
that it was unjust that these groups could profit from emissions historically,
then ‘find their moral compass’ and punish iwi/Māori groups who have been
denied the opportunity to develop their land.
9
Al en + Clarke
Agricultural Emissions Pricing Consultation – The Ministry for the Environment and the Ministry for Primary Industries
• An economic system has been imposed on Māori that is counter to how
Māori operate. Treaty settlements are a small fraction of what has been lost.
This makes Māori effectively “beneficiaries/dependants on our own land”
General comments about government engagement and processes
These were a major topic of discussion - including:
• Government has had months to prepare for this consultation and hasn’t
given communities enough time to respond - even if there was more time, it
doesn’t matter because participating in engagement events means taking
time off, and writing a detailed submission is a big effort. Participants said to
do the analysis on impacts and respond adequately they would need 6
months and be resourced to do it
• Not feeling represented by Māori He Waka Eke Noa partners - they saw
PSGEs as the appropriate representatives
• Criticism of ‘panic’ decision making without working with the affected
communities
• Communication about what we are doing not getting to interested parties
• Concern that they had little say in the systems already in place e.g. ETS
obligations
Question:
New/thorny questions asked by
attendees
Answer:
[Duplicate this row as needed]
10
Al en + Clarke
Agricultural Emissions Pricing Consultation – The Ministry for the Environment and the Ministry for Primary Industries
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