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Document AFB PMP Management Agency latest price report

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Comments anyone re the charges moving forward from the agency as per yesterdays email.

The way I read it our levies are going up considerably.

 

And they intend to charge non compliant beekeepers but no indications on how those charges will work.

 

Management Agency Response to submissions on proposal to replace the American Foulbrood Apiary and Beekeeper Levy with a Hive and Beekeeper Levy

In August 2018, the Management Agency for the National American Foulbrood Pest Management Plan (the Agency) conducted a consultation amongst beekeepers to seek their views about a proposal to increase the American Foulbrood (AFB) Apiary and Beekeeper Levy (referred to as ‘2018 Levy Consultation’). Over 828 submissions were received, and the majority strongly disagreed that the levy should be increased as proposed.

The majority of 2018 Levy Consultation submissions considered that the Agency should not continue to use apiaries as a basis for calculating the levy and proposed a hive levy instead. A significant number of submissions were also concerned that non-compliant beekeepers were not paying the costs of the AFB problem they created.

In response to 2018 Levy Consultation submissions, the Agency revised the proposal to replace the existing apiary and beekeeper levy with a hive and beekeeper levy. The Agency also decided to fund its compliance and enforcement activities through cost recovery charges under section 135 of the Biosecurity Act 1993.

The Agency took the revised proposal back to the beekeeping community for consultation in 2019. The consultation period was for three weeks and opened on 4 March 2019 and closed on 22 March 2019.

477 unique submissions received, of which 466 were from survey respondents. Fourteen letters were sent to the Agency, three of whom were also survey respondents. The consultation findings and detailed description of the consultation process is presented in the companion Consultation Findings report.

The Agency would like to thank submitters for their submissions on the future funding of the elimination of clinical American Foulbrood in New Zealand.

Summary of Agency decisions

Having considered the submissions, the Agency has decided to request the Minister to make a new American Foulbrood – Hive and Beekeeper Levy Order with the maximum rate of levy set at $2.55 per hive and $40 per beekeeper.

The Agency has also decided to charge non-compliant beekeepers to recover fair and reasonable costs of compliance and enforcement actions.

The reasons for these decisions are set out below:

Replace the Apiary and Beekeeper Levy with a Hive and Beekeeper Levy
A narrow majority of submissions considered that the existing apiary and beekeeper levy should be replaced with a hive and beekeeper levy.

Submissions in favour of the replacing the existing apiary and beekeeper levy with a hive and beekeeper levy stated that it more fairly distributed the cost between large and small operations, incentivises smaller apiaries and encourages people to take up hobby beekeeping.

The primary objection stated by submissions against replacing the apiary and beekeeper levy with a hive and beekeeper levy was that it was too easy for beekeepers to under report their true hive numbers.

The Agency noted the concerns expressed about the potential for beekeepers to underreport their hives under a hive levy. However, the Agency was not satisfied that these submissions made the case that the under reporting of hives would be significantly higher than the current under reporting of apiaries and believes this can be mitigated by developing new mechanisms to audit hive declarations. The Agency also considered that submissions in favour of changing to a hive and beekeeper levy made a more compelling case for changing to a hive and beekeeper levy than the submissions against as:

  • A hive and beekeeper levy fairly distributes costs between large and small beekeeping operations,
  • A hive levy incentivises smaller apiaries with a lower disease risk, and
  • Replacing the apiary levy with a hive levy removes the financial incentive for beekeepers not to register all their apiaries, thereby improving the Agency’s ability to monitor and manage American foulbrood.

Setting a maximum levy rate at $40 per beekeeper and $2.55 per hive
A majority of submissions opposed the proposed levy rates. The primary objection was that the proposed levy rates were too high, and beekeepers could not afford to pay them.

The Agency is concerned about the financial hardship that many beekeepers are experiencing. However, the Agency is also concerned that continued underinvestment in AFB elimination has the potential to further erode beekeeper incomes due to hive losses associated with AFB, particularly at a time when AFB may increase as a consequence of the financial pressures that beekeepers are experiencing. The proposed levy rate for 2020/21 and maximum levy rates are approximately $0.65 (proposed) and $1.80 (maximum) per hive above the current levy rate. The Agency considers that the additional levy is justified to reduce the costs associated with losing hives and production to AFB.

Charge non-compliant beekeepers to recover the costs of compliance and enforcement actions
A majority of submissions agreed that the Management Agency should charge non-compliant beekeepers to recover the costs of compliance and enforcement actions.

Submissions in favour of charging non-compliant beekeepers to recover the costs of compliance and enforcement actions stated that they believed that non-compliant beekeepers are the most responsible for the AFB problem and they supported strong penalties to deter non-compliance.

The primary reason given by submissions opposing charging non-compliant beekeepers to recover the cost of compliance and enforcement actions was that they believed the penalties were too severe, would encourage non-compliance and underreporting in order to avoid penalties.

Under the National American Foulbrood Pest Management Plan beekeepers are responsible for the costs of eliminating AFB from their beehives. Cost recovery is intended to recover the costs of the additional AFB control activities required to manage the consequences of non-compliant beekeepers’ behaviour. The Agency believes it would be unfair to expect compliant levy payers to fund these actions from the levy and has therefore decided to recover the costs of compliance and enforcement actions from non-compliant beekeepers.

The analysis of submissions and the Management Agency’s response can be found on the levy webpage or by selecting the links below:

 

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Yes

It was a surprise to me also

After seeing this my plan is  to hunker down with only enough Hives so as to be able to spring back up in numbers when required.
My guess is that this will be a common approach in the commercial sector

 

  • Agree 4

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I had no clue what way it would go, except it was clear that something was going to happen. So, I was waiting with a feeling of trepidation. At this point I think the pendulum may have gone too far the other way now, but we may have been lucky given some of the suggestions... In the past I've been critical of the management agency, but many of their latest emails have promoted things I said were missing and so I feel suddenly I'm dealing with a different 'person' how that is even possible I don't know. One key issue is charging noncompliant beekeepers costs. I don't know what the means either, hopefully they wont go to the other extreme. But it seems like a good move and if the mere threat of action produces greater compliance that is a good thing. My preference would be that unregistered hives and/or apiaries are confiscated; on the spot and charged for use of trucks to get them moved out. Another thing I like is that they will bring more stuff inhouse instead of being done through Asure Quality. I've nothing against AQ, but the budgets and accounts of the Management Agency are unintelligible to mere mortals and it would be great if the financial reporting was only spun once instead of twice. Given all the handwringing and upheavel in this area I think it would be good to run with this for a couple or 3 years and give them a decent chance at turning around their performance. So my 'vote' is that we give them a second chance on a blank sheet of paper.

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I hope the per hive cost is a lot lower than the maximum !

 

  • Agree 2

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Posted (edited)
2 hours ago, fieldbee said:

And they intend to charge non compliant beekeepers but no indications on how those charges will work

 

I have already seen some of that in action so can answer at least to some extent.

 

Beekeepers who do not file their paperwork to demonstrate that their hives have been checked by a DECA holder are sent reminder notices. Eventually if there is no response, an AP2 is sent to do the check, and the cost of that is billed to the beekeeper.

 

Some will see this as unfair, because there are 2 kinds of non compliant beekeepers. There are those who just don't like "big brother" and do not file paperwork as a matter of principle. The other type are those who just made an innocent mistake.

 

However the purpose of the current regime is to get away from the situation of years ago, when beekeepers were just trusted to check their hives for AFB, some beekeepers had limited experience, could not recognise the disease, and not much was done about that. So now, the idea is to have people trained (become DECA holders), and that people who are untrained have their hives checked by someone who is.

 

IE, every hive in NZ is checked by a trained person at least one time each year. So people who do not furnish the paperwork to show that has been done, now have it done for them, at their expense.

 

In my view, the goal of eradicating AFB has got no show, unless the above is enforced, at a minimum. So although I sympathise with people who just forgot to file paperwork, i am in support of the general idea, it HAS to happen.

 

 

Edited by Alastair
  • Agree 2

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