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Gino de Graaf

AFB Proposed Levy Increase

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21 minutes ago, Gino de Graaf said:

back to the bone, 

 

Quote from proposal, "For effective national control of AFB, apiary sites must be accurately identified and registered" 

increasing the Levy won't encourage compliance. 

 

"Encourage beekeepers an landowners to report unregistered apiaries...." 

What do these apiaries look like?  Neglected ones might be registered while clean looking ones not. 

 

"...and the reported annual incidence of disease has increased by an average of 15% since 2015"

Recently more willingness for beekeeper reporting?  Could some beekeepers report less if they believe that they could be under increased scrutiny? Logic would suggest that if you report more, then you will be looked at.  Even if you are actively eliminating AFB

And, if unregistered sites discovered, the proposal states

"....the Management Agency will ensure that the beekeeper registers the unregistered apiaries..."

Well, that's a great strategy, 

 

If the aim is for beekeepers to become more compliant- the above are contrary suggestions.  If more beekeepers became compliant, without a big increase in Levy could the Agency then move forward with resulting boost in Apiary Registration? 

 

I know, it's easy to complain and poke holes at a proposal and I am trying to think of some ideas to include in the Submission. 

 

 

  

 

I have a simple 80/20 view of AFB. I believe 80% of Beekeepers truly aim at controlling AFB and complying with all rules, but through a multitude of reasons they still get caught in the AFB net.  20% are criminals who knowingly have unregistered sites and keep AFB gear because of a perceived financial benefit from not burning it.

 

Unfortunately in recent times our AFB program has put the 20% in the too hard to prosecute basket, despite the current PMP program having all the required laws to push enforcement.

At the same time the 80% have been left to fend for themselves. There is no branch support, and worse as with increased beekeeper pressure they do not even know their beekeeper neighbours. AP2 numbers in NZ have plummeted and even if you find one they are now prevented from providing constructive advice to people with problems. In fact they can be dismissed if they provide any service outside their contracted audit.

 

Funding is blamed for this reduction of services combined with increased pressure from hive numbers. While this is partially true, a million dollars is still a lot of money for AFB and all the laws exist.

 

So will 4x funding solve all the problems. If I thought yes I would have the cheque written out by lunchtime.

 

Sadly my cheque is not being written for two reasons.

First is beekeeper buyin. Every levy this industry has ever implemented has increased the number of people hiding their hives/honey/apiaries from regulators. There are multiple reasons why this happens, and not always because they are "bad" beekeepers/people, but they come from the 80% group who were actually trying to do the right thing.

 

The second reason is cheque book passing the buck. If you charge people too much they stop being connected to the problem. Beekeepers say "I have paid all this money it is now the AFB managers job or AFB committee job to manage my AFB and everyone else's AFB."  

These are my thoughts ( I am passionate but not an expert.)

I Would like to see more counciling and practical help provided by AP2 staff. Rule change from PMP management required and physically more AP2 staff in total.

PMP need to work on guidelines through the H and S and privacy system to provide full support to branches to hold local inspection/social days to generate buyin.

Have Less focus on big stick auditing for Chinese trading partners, and more on what actually gets grass roots Beekeepers involved.

Restrict any new funding to 2x existing before having to go back to industry and proving systems are working rather than blanket 4 year increase.

The 28 days registration rule needs changing for honey collection sites (makes sense to stay for true pollination) but this might be a 2023 problem as this requires ministerial input.

Cap admin and office based AFB management to say 15% so we know our money is being spent in the field on real world issues.

Actually prosecute someone to prove the wet bus ticket does not exist.

 

time for a coffee before moderators get me for waffling.

 

 

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2 minutes ago, Bushy said:

The second reason is cheque book passing the buck. If you charge people too much they stop being connected to the problem. Beekeepers say "I have paid all this money it is now the AFB managers job or AFB committee job to manage my AFB and everyone else's AFB."  

This is exactly what now happens across the board with our disconnected society. There is no answer. 

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6 minutes ago, Bushy said:

 

I have a simple 80/20 view of AFB. I believe 80% of Beekeepers truly aim at controlling AFB and complying with all rules, but through a multitude of reasons they still get caught in the AFB net.  20% are criminals who knowingly have unregistered sites and keep AFB gear because of a perceived financial benefit from not burning it.

 

Unfortunately in recent times our AFB program has put the 20% in the too hard to prosecute basket, despite the current PMP program having all the required laws to push enforcement.

At the same time the 80% have been left to fend for themselves. There is no branch support, and worse as with increased beekeeper pressure they do not even know their beekeeper neighbours. AP2 numbers in NZ have plummeted and even if you find one they are now prevented from providing constructive advice to people with problems. In fact they can be dismissed if they provide any service outside their contracted audit.

 

Funding is blamed for this reduction of services combined with increased pressure from hive numbers. While this is partially true, a million dollars is still a lot of money for AFB and all the laws exist.

 

So will 4x funding solve all the problems. If I thought yes I would have the cheque written out by lunchtime.

 

Sadly my cheque is not being written for two reasons.

First is beekeeper buyin. Every levy this industry has ever implemented has increased the number of people hiding their hives/honey/apiaries from regulators. There are multiple reasons why this happens, and not always because they are "bad" beekeepers/people, but they come from the 80% group who were actually trying to do the right thing.

 

The second reason is cheque book passing the buck. If you charge people too much they stop being connected to the problem. Beekeepers say "I have paid all this money it is now the AFB managers job or AFB committee job to manage my AFB and everyone else's AFB."  

These are my thoughts ( I am passionate but not an expert.)

I Would like to see more counciling and practical help provided by AP2 staff. Rule change from PMP management required and physically more AP2 staff in total.

PMP need to work on guidelines through the H and S and privacy system to provide full support to branches to hold local inspection/social days to generate buyin.

Have Less focus on big stick auditing for Chinese trading partners, and more on what actually gets grass roots Beekeepers involved.

Restrict any new funding to 2x existing before having to go back to industry and proving systems are working rather than blanket 4 year increase.

The 28 days registration rule needs changing for honey collection sites (makes sense to stay for true pollination) but this might be a 2023 problem as this requires ministerial input.

Cap admin and office based AFB management to say 15% so we know our money is being spent in the field on real world issues.

Actually prosecute someone to prove the wet bus ticket does not exist.

 

time for a coffee before moderators get me for waffling.

 

 

 

Loved what you are saying!

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When does a split become a hive that needs registering.

What if you combine two hives .

Is it 30 days with a hive to become an apiary.

If I take a couple of nucs to a friends to mate and they are there for two months is that an apiary now .

Is there a document on line somewhere with all the fine print .

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26 minutes ago, kaihoka said:

When does a split become a hive that needs registering.

What if you combine two hives .

Is it 30 days with a hive to become an apiary.

If I take a couple of nucs to a friends to mate and they are there for two months is that an apiary now .

Is there a document on line somewhere with all the fine print .

 

The actual number of hives or splits is not important. The site you have your splits and your friends site are both apiaries, and that is what you register. I've a fixed geographic location. Don't go down the track of worrying about 28 day rule. It was put there to help with short term pollination. It has now been hyjacked for Manuka producers to avoid levies when they jump to three different sites over a three month period.

 

Sorry not very good at links (need the kids to help) but go to:

legislation.govt.nz 

search for "Biosecurity (National American Foulbrood Pest Management Plan) order in council 1998.  This is the original document. There were some changes made in a 2003 update.

 

You can also find various documents and reports at AFB.org, but some of them have been sanitised for easier reading.

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Wow I need to correct myself. I have mentioned 28 day rule a few times, yet everyone else is correct. It is 30 days before registration of an apiary. For pollination this makes sence. For Manuka it does not.

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5 hours ago, Bushy said:

Every levy this industry has ever implemented...

 

What other Levies were these? 

 

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On 24/07/2018 at 1:31 AM, john berry said:

  Unregistered sites  are a problem but there are plenty of  registered  beekeepers who are just as bad or worse. I think the proposed increase is unnecessary and unjustifiable mainly because the current  System while better than nothing is outdated.  We will soon have far better tools for identifying  afb ln   Honey  samples   Which will allow for  far better targeting and should actually reduce costs.mpi  is responsible for prosecutions and is not willing to do so just as they are not willing to follow up on honey coming from unregistered  apairies. Until we get new laws or they in enforce  The laws we have no amount of new funding will change things.   Charging competent beekeepers more will not improve things, identifying and dealing with incompetent beekeepers will.

 

Just to reiterate John's comment here.

 

With the ability to test honey for AFB combined with an effective tracing mechanism (via harvest declarations) the ability to identify source contamination will be a far more effective means of tackling AFB. In my submission I have repeatedly made the point that it is beekeepers who find AFB not compliance personnel! If we have extractors/packers testing for AFB to meet their own compliance standards as well, this will help immeasurably.  

 

I see the AFB management agency's function as twofold, education and monitoring. I don't for one moment believe the agency has 'teeth'.  If 38% of flyover hives are unregistered then it's high time these apiaries were dealt with. I make no apologies for firmly being in the seek and destroy camp.  How the AFB Management agency can in all conscience suggest that a massive increase in levied costs to beekeepers will miraculously resolve the issue is farcical.

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I hope you have all taken the time to put in a sumission - I have.

 

I don't believe that the honest beekeeper, who register their sites, should be penalized. The money could be gathered from fining those with unregistered sites - the more hives on that particular site the heavier the fine.

 

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I still can't get my head around this cluster (bad word) why will jacking up the costs make the dirt bags that don't confirm now tow the line ???

We are always getting phone calls about dirt bags that don't look after there hives it got so bad last year that we now offer rent a hive deal something I don't like but if people want a hive I want them to be ones I know are being looked after.

If these dirt bags are not checking there hives not answering to there customers you can be sure they are not paying apary leveys.

I've given up calling assure about it as it looks like I'm going on so I now get the owners to call some of the hives I've had calls about have been dead for over a year.

This is happening in everyone's back door ether commercial or hobby beeks.

There is the ability to spot fine non confirmers under the current system it's not necessary as they said to take people to court and costs associated with this.

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What really annoys is the number of abandoned apiaries around,and what are our authorities doing about it.Absolutely NOTHING.

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I'm trying to work on a submission but am finding myself getting more than a little frustrated with the reasoning provided in the proposed plan for the increased funding.

 

A couple of examples:

 

1) Quote: “The AFB NPMP is due for review in 2023. The expected one-off cost of completing a thorough review is $250,000. “

 

From the evidence supplied with the proposed levy changes it is clear that the current plan is not working how it was intended, both from disease elimination and management/implementation perspectives. Surely the best course of action is therefore to fast-track the review of the AFB NPMP and, on completion of the review, decide what resources (levies) need to be in place to carry a new plan forward.
 

2: A quote from the plans FAQs: 

Why is more funding required to support overseas market access?

“Overseas markets are now requiring proof that honey bee products are sourced from apiaries that comply with AFB Pest Management Plan rules”... 

 

If overseas markets are requiring this proof then surely it needs to be supplied by the beekeeper/company exporting the product to ensure this happens? If overseas markets require these standards to be met then this provides an ideal opportunity for the AFB management agency to piggyback on the results of compulsory testing by producers and exporters and identify potential problem beekeepers/areas this way. If anything, it provides a very real opportunity for the Agency to save money rather than spend nearly $1,500,000 more on manual surveillance by AP2s and random honey sample testing. 

 

3: From the FAQ: Why isn't a hive levy proposed?

"However, the Management Agency’s operating costs rise in proportion to the number of beekeepers and apiaries registered, not the number of hives registered – so the levy that funds this should reflect the same format."

 

This is a circular argument as the levies are collected based on the number of beekeepers and apiaries registered, not hive numbers. If the current system used hive numbers rather than apiaries the exact same argument could be used to stay with using hive numbers rather than switching to apiaries...

 

"For example, if we see a significant rise in non-commercial beekeepers each with only a few hives, a small hive levy won’t cover the cost of registering those beekeepers and their apiaries. This means that larger commercials paying higher levies are subsidising these beekeepers, and reduced funding is available for disease management."
 

I am interested in the maths on this one. Say for example we have a hive-based levy of $1 per hive. The total income from 1 commercial beekeeper with an apiary of 50 hives would be $70 ($20 beekeeper levy plus $50 from the hives). If those 50 hives were spread amongst 10 different hobby beekeepers the total income would be $250... I understand the cost of registering 10 beekeepers and apiaries will be a little more than just 1 (data-input time etc) but is that difference really this big? 

 

I would strongly support a shift to a hive-based levy system. I run small apiaries because I firmly believe it is better for the health of my bees. For example, on a farm capable of sustaining 50 beehives, I would rather spread those 50 hives around the farm in apiaries of 8-10 hives than plonk all 50 in one apiary. I believe this is a much healthier model for the hives. Less competition in a small space, less time to fly to available forage etc. An apiary-based levy system penalises me for this. I am currently okay with absorbing that but at $50 per apiary this would get quite expensive.

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Quote

 A quote from the plans FAQs: 

Why is more funding required to support overseas market access?

“Overseas markets are now requiring proof that honey bee products are sourced from apiaries that comply with AFB Pest Management Plan rules”... 

 

I would like to see the proof of this.

and would like to know why overseas markets would even care.

Edited by frazzledfozzle
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Maybe that's geek speak for no antibiotic residue

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59 minutes ago, yesbut said:

Maybe that's geek speak for no antibiotic residue

 

Dont think it could be because in NZ antibiotics are illegal. That simplifies that argument. And saves us at least $250,000... ?

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Hallo Otto! 

 

Yes with you on this.  

If Agency needs us to comply to meet market access conditions- then increasing the Levy will push more apiaries into the dark= more non compliance.

I think, that the big increase to 50 allows for this, the expectation by Agency of a sudden reduction of apiaries will result in reduced returns- though at 50 the Agency will still win.  Even if  half of all registered apiaries disappear. 

 

The RMP audit costs 200-300 odd an hour.  So any extra 'data' inputting of say 30 minutes for those extra sites will 'cost' a lot, (not saying the Agency charges this) 

Like I said earlier, the 'charge out rate' of management has got so high that getting those feet on ground to check on sites is just is not cost effective @ 200- 300 an hour. 

We are paying for people on so many levels that it's become a very high building.

And when those management feet are not on the ground, well they start reacting/creating more compliance to justify the system/jobs.  Compared to other honey producing nations, we have got a lot compliance.  And our compliance can only be audited by one company.   The same one who create the rules. 

 

 

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Does the government have any input into this? Should we not all be writing to Jacinda, or our local MPs demanding that they step in?

 

there has been so many valid comments made in this thread that we have the ammunition for correspondence. 

 

(I’ve filled out the survey)

Edited by CHCHPaul
Mistake

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We should all write to Damien O'Çonner He is the person who will sign off the recommendations of the pmp board, 

Mind you I doubt we will have any joy with him because we are all a bunch of cowboys anyway, that is unless you are one of apinz's pet corperates. 

 

 

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13 hours ago, frazzledfozzle said:

 

I would like to see the proof of this.

and would like to know why overseas markets would even care.

 

It’s a cop out. If you cite science you can be challenged, while pointing to ‘markets’ has just the right amount of plausibility but with nothing that can challenged.

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I’ve just read through the latest email. So.... they want an extra 75k to collect the extra levies??! I can’t see how it costs so much more to add  to the invoice we already get. 

I agree they do need to get stronger in surveillance and need more money to do so.

I see no mention of detector dogs?. Why not ??? They are a useful tool in the elimination of sub clinical cases. Imagine an ap2 that could also run a dog through the hives. Or if afb is found then the dogs automatically get called in to check the storage sheds. If the beek didn’t recognise the afb in the field imagine how much is in the shed !! 

I’m going to work out what the increases mean to me but I can see apiaries getting combined. 

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1 hour ago, nikki watts said:

I’m going to work out what the increases mean to me but I can see apiaries getting combined. 

I can see invoices getting binned.

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On 25/07/2018 at 5:23 PM, Gino de Graaf said:

I saw that you can ask questions to the Agency. 

So I did. As below.  Will let you know the response- if I get one. 

 

Good morning, 
 
A few question regarding the Proposed Levy. 
 
Did the Agency seek a Government contribution to help off set the large increase in the Levy?
 
Who will be upgrading the Apiweb? 
Did the Agency seek other quotes/estimates for this work?  
Will the new system use Google Maps?  (if so, realise Google will increase the cost of this service- it might be cheaper at first but they will reap return)
There needs to be a clear cost to this upgrade- not an expected cost- 
 
Did the Agency consider any other Proposals?
 
If I choose not to register my sites, what are my consequences? Please be clear of the process. I want to know how a non compliant beekeeper will be managed. 
 
 

 

Got the response today.  Below. 

 

In answer to your questions:

 

National Pest Management Plans under the Biosecurity Act enable industry to take responsibility for funding  and managing pests and diseases.

 

The Management Agency has yet to initiate the procurement process to replace ApiWeb. These will be done using an open competitive RFI and RFP process to ensure that the best value for levy payers funds is achieved. The cost estimates will be confirmed at the conclusion of the procurement process.

 

The ApiWeb replacement will include Google Map type functionality. (Note we may use Google Maps or a competing product depending on features and costs).

 

Under the proposed levy that Management Agency will have sufficient resources to encourage landowners and beekeepers to report suspected unregistered apiaries and to investigate all reports.

  • Where an unregistered apiary is detected and we can identify the beekeeper, the beekeeper will be required to register that apiary and any other unregistered apiaries (and pay the levy). Should the Management Agency detect another unregistered apiary owned by the same beekeeper within another 12 months the DECA will be automatically revoked for a minimum of 12 months, and they will be required to pay another DECA Holder to conduct a Certificate of Inspection in the spring. Should they fail to do this the Management Agency will conduct the Certificate of Inspection and recover the costs from the beekeeper.
  • Where an unregistered apiary is detected and we cannot identify the beekeeper within 30 days, the Management Agency will burn the apiary as per the process specified in the National Pest Management Plan.

 

Regards,

 

Clifton

 

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Just now, Gino de Graaf said:

open competitive RFI and RFP process

 

What does this mean?

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23 hours ago, Otto said:

I would rather spread those 50 hives around the farm in apiaries of 8-10 hives than plonk all 50 in one apiary.

This is exactly my method and concern also

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