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:
09/11/2022
Meeting type:
In-person consultation discussing the NES-PF and the emissions pricing scheme
MfE/MPI staff:
MfE: Hemi Smiler, Hamish Slack, Emma Tauti; MPI: Fleur Francois, Mele Tabukova; Te Uru Rakau:
Elizabeth Heeg
Number of attendees:
12
1
Al en + Clarke
Agricultural Emissions Pricing Consultation – The Ministry for the Environment and the Ministry for Primary Industries
Date:
09/11/2022
Demographic of attendees (if MfE, MPI and Te Uru Rakau, Māori agribusiness and policy
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?
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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?
Ngai Tahu Farming is deeply involved in the whenua of the land. Whanau need to
benefit from the land, and improvement of the land and are a significant driver the
Did attendees believe there are any
way Ngai Tahu farm. For Ngai Tahu Farming, water is a significant issue, as well
opportunities to improve the proposed as ad nitrogen inputs and regenerative structures are being put in place and are
approach to
reporting emissions?
already a management focus. Those programmes take at least 7 years. Time
frames for change on farm need to be taken into consideration when setting up the
levy.
New/thorny questions asked by
Question: Price setting can have an environmental outcome, but at some point,
attendees
there needs to be an acceptance on the percentage of the number of farms that
are no longer viable. How is the emissions levy going to manage this?
Answer:
Pricing, revenue and incentive payments
What
concerns did attendees have
around the proposed approach to
On price setting, from Ngai Tahu Farming’s perspective, it is concerning that
setting levy prices?
Minister’s would be setting price and it is heavily reliant on the government on the
day. Political agenda may not fit into the long-term agenda. Is there a way that an
Did attendees offer any
improvements enduring governance structure with experts, Māori representatives and
to the proposed approach to
setting
representatives of sectors can be created. They may need sign off from Minsters.
levy prices?
Feel that with Ministers sign off they feel like that there is a loss of control of the
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Al en + Clarke
Agricultural Emissions Pricing Consultation – The Ministry for the Environment and the Ministry for Primary Industries
price. Want more than consultation, want active contribution. Ministers receiving
advice would be recorded and there is no way to walk back from the conversation.
The consistency of pricing is an issue and political aspirations may add to the
cyclical nature of the pricing. We would like context and what a sensible frequency
for review of the pricing.
What feedback did attendees have on
Ngai Tahu Farming were interested in how we take the revenue back into
the proposed
revenue recycling
incentivisation. It is dif icult to do both R&D and sequestration payments together
strategy?
with incentive payments. Ngai Tahu Farming are concerned there wil not be
What did attendees think about an
enough funds to incentivise mitigations. They are also concerned that there may
advisory board for revenue
be a hierarchy of incentivisation. While revenue from Māori wil also be
recycling?
ringfencing, there is no definition of where the money is fed back into.
Ngai Tahu Farming have an interest in nitrate and carbon dioxide mitigations. In
What
transitional support did
particular, coatings on fertilisers and evaluating plant available nitrogen with
attendees say was needed?
cameras on trucks to distribute nitrogen more efficiently. There is less volatility
What approaches did attendees support from the gases from these mitigations as well as the use of liquid fertilisers. How
for
incentivising mitigation practices can these mitigations initiatives be included in the approved mitigations list?
or technologies?
Do we get certified initiatives for reductions? The levy proposal is framed that
What
mitigation practices or
emissions wil not be as high, and if you provide evidence of implementation then
technologies did attendees think
you get a further reduction on your levy bil . You get the benefit of the reduction
should be
supported by an incentive
and an additional rebate. The incentive rebate wil be from the payment of the
payment?
levy. The cost of the incentive wil be part of the regulations and wil be consulted
on later in the process.
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Al en + Clarke
Agricultural Emissions Pricing Consultation – The Ministry for the Environment and the Ministry for Primary Industries
Ngai Tahu Farming have an ambition of 10% gas reductions year on year. They
have had a large drop over the last 24 months and hoping by year 3 the changes
wil be pulled across the farming system.
New/thorny questions asked by
Question: With farming being seasonal and cyclical, what would happen post
attendees
2030? The pricing is looking very daunting. Is there an option to divert levy during
poor farming years like tax or enabling quantitative easing (income equalisation).
Answer: This has been raised and would be helpful to be included in submissions.
Pricing carbon sequestration and nitrogen fertiliser
Ngai Tahu Farming are spending a lot of money planting trees, as shelter belts as
well as under pivots. It is hard that all that work is not recognised. These shelter
What feedback did attendees have on
plantings also have an animal welfare component as they require shelter plantings
the proposed approach to
carbon
for health purposes. So, there are multiple drivers for recognition of increasing
sequestration?
plantings.
What
barriers did attendees raise to
Ngai Tahu Farming hold pastoral lease land which has substantial reforested
including new categories of
vegetation. As mana whenua of that catchment, who gets attribution of that
sequestration in the NZ ETS?
afforestation?
Did attendees have any
concerns
Where there is active retreat and enabled regrowth wil this count towards
about bringing
on-farm vegetation into sequestration? Ngai Tahu Farming are actively removing beef cattle from high
a farm-pricing system?
country farmland.
How can we recognise using geospatial technology to recognise the plantings on
farm, particularly corridor plantings. Ngai Tahu Farming are spending half mil ion
each year and how does that footprint get recognised. They want NZ to be a
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Al en + Clarke
Agricultural Emissions Pricing Consultation – The Ministry for the Environment and the Ministry for Primary Industries
leader and providing sequestration on farm. They are trying to get zero carbon
beef with mapping of plantings under 5m.
Did attendees prefer
pricing nitrogen
at the farm level or at the processer
level? Why?
Question: How can the emission pricing system recognise sequestration of small
New/thorny questions asked by
plantings using geospatial technology to recognise the plantings on farm,
attendees
particularly corridor plantings. They are spending half mil ion each year and how
does that footprint get recognised.
Answer:
Future enhancements
Did attendees prefer a
tradeable
methane quota? What benefits did they
cite?
No
What concerns did attendees have
about
tradeable methane quotas?
What concerns did attendees share
Ngai Tahu felt that using the processor level levy is catering to those that have not
about an
interim processer-level
made improvements and not supporting those that have already started
levy?
implementing changes and does not support the use of the processor level levy.
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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: The costs of reducing the farms emissions are significant costs and the
New/thorny questions asked by
value of paying the levy vs investment is not necessarily equal. There needs to be
attendees
an acknowledgement across the dif erent programmes of how the solution can
help results across multiple levels even though the costs of the implementing
mitigations is costing more than paying the levy.
Answer: This is something we are trying to avoid.
Impacts and support
How did attendees believe the system
By the time solutions are commercialised they wil be too late to implement before
would
impact them?
the start date and the cost of implementation wil be high. Therefore, the reduction
of stock numbers is the only way to reduce emissions to the targets. There wil
What
support did attendees believe wil also be a knock-on effect on our processors what does that do to the underlying
be needed?
value of those entities stranding assets.
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?
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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
70% are the urban vote, so do Ministers serve the rural sector that underpins the
the proposed
governance structure?
economy and export sector. What are the unintended consequences of
What did attendees think should be
mismanagement? Feel enduring governance would provide clear structure over
included in the post-implementation
time to set the price. Don’t want the price going up and down determined by the
review in 2030?
voting direction.
What feedback did attendees have on
Ngai Tahu are concerned that if the CME function of the pricing system is put with
the proposed approach to
monitoring
Councils there wil be an issue with resourcing as they may not have the capacity
and verification?
and manpower to provide the function.
Did attendees support a
government-
run or third-party verification system?
Why?
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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
The Ngai Tahu farming attendees suggested that MfE and MPI should initiate a
feedback on the proposals?
conversation with rununga sooner rather than later to discuss the emissions pricing
scheme.
Question: Do you sense that there wil be any changes as a result of feedback
from the consultation?
New/thorny questions asked by
Answer: We don’t want to speculate where ministers are going to end up. There is
attendees
scope to influence the shape and direction of the mechanisms and what
businesses need for regulatory certainty. Changes with the ETS might give a
flavour of what changes may be seen. CCC providing advice to Ministers that
would show transparency in the processes. How can we support investment in
areas that have the most potential. We are not doing this in a vacuum, and we wil
most likely need to come back to talk about these points.
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Al en + Clarke
Agricultural Emissions Pricing Consultation – The Ministry for the Environment and the Ministry for Primary Industries
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