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Letter from NZBK re AFB Levy


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Dear Members,

As you may know,  the AFB PMP Management Agency has proposed an increase in levies of 25% for the 2021/22 levy year. NZ Beekeeping supports the PMP’s objectives and does not begrudge paying reasonable levies to fund the PMP. However, on top of last year’s increase for commercial beekeepers, the levy increase is intolerable at a time when beekeepers are struggling to remain financially viable. 

Your Executive are sufficiently concerned at the continual increases in the levy and offer the following suggestions if members and those on our wider mailing list also have concerns.  We have listed here are some aspects of the budget that have not been sufficiently explained so you can make an informed decision regarding the budget. You might like to drop in a submission to the management agency or use the NZB template to send your views. For some, even a 10c per colony levy increase can be a significant amount spread over a number of hives:

A 25% increase in fees is not desirable nor does the proposed budget show anything to say that the increase is necessary or justified. We live in times of constraint and we want the agency to reconsider, for example, the benefit of testing 1,000 honey samples. What is the proposed cost and how many AFB hives has previous testing located?  

The agency has provided insufficient information for anybody to construct a better informed view of the finances. This is despite every year of asking for more detailed information relating to a breakdown of expense categories.

The levy order provides that there should be adequate time for the agency to consult with levy payers with information that would allow greater understanding where money comes from and goes to with the PMP.  This has not happened.  The agency have provided a 16 day consultation time span for beekeeper input and yet allows itself 117 days to consider levy payers views, set and notify the levy rate by the required date of 20 Jan 2021.  This is grossly unfair to the levy payers.

The agency appears to have listed the AFB recognition course and default inspections as an expense to all levy payers, whereas these items are cost recovered items. Adequate financial interpretation should see a reduction of levies in this instance.

The agency have budgeted $170,000 for the next review of the PMP in 2023. NZ Beekeeping welcomes the review as a time to consider if there need to be changes to the management of the PMP.  But we think that the review should be conducted by an independent group of beekeepers and MPI as happened for the last review. It is not appropriate for the management agency that have an obvious conflict of interest to lead the review process.

The agency have built substantial reserves over the years. Any costs associated with the PMP review could be covered by reserves.

Finally, it has become a part of the consultation process of the management agency to include a survey as part of the consultation.  NZBI thinks that the survey is a 'Push Poll' where the participants are led into providing a response that the Agency wants to hear.

Instead, NZBI suggests levy payers present their view as a submission rather than participating in the survey.  For example the rate of the levy is established as a mathematical calculation once the budget is accepted by levy payers. To accept the budget levy payers should be provided estimates based on realistic appraisals of the program costs and expected income. The ‘levy’ is the amount required to balance the books divided by the levy base. For the agency to ask in a survey “Do you agree that the levy rate for 2021/22 should be fixed at $1.70 per colony and $40 per beekeeper?” is a question that cannot be answered until levy payers are provided sufficient information that allows them to do the maths to confirm yes or no that $1.70 per colony and $40 per beekeeper will provide sufficient income to balance the books.
 

Kind regards,
Jane

JANE LORIMER

PRESIDENT

 

New Zealand Beekeeping Incorporated

Email: info@nzbeekeeping.co.nz 

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If it were not for the PMP, AFB would effectively be de-regulated in New Zealand.  Nothing whatsoever could be enforced: no one could be forced to deal with their AFB.  Nothing could be done if AFB is

That doesn't matter. Finding AFB in the honey, means there was AFB in the hives it came from. Regardless of source.   Finding out which beekeepers have excessive amounts of AFB in their hone

Honey testing is not about identifying specific apiaries/sites that are problematic. It is all about identifying beekeepers who have AFB problems. Which sites their hives collected the honey from is i

On 22/09/2020 at 7:24 AM, morporks said:

Dear Members,

As you may know,  the AFB PMP Management Agency has proposed an increase in levies of 25% for the 2021/22 levy year. NZ Beekeeping supports the PMP’s objectives and does not begrudge paying reasonable levies to fund the PMP. However, on top of last year’s increase for commercial beekeepers, the levy increase is intolerable at a time when beekeepers are struggling to remain financially viable. 

Your Executive are sufficiently concerned at the continual increases in the levy and offer the following suggestions if members and those on our wider mailing list also have concerns.  We have listed here are some aspects of the budget that have not been sufficiently explained so you can make an informed decision regarding the budget. You might like to drop in a submission to the management agency or use the NZB template to send your views. For some, even a 10c per colony levy increase can be a significant amount spread over a number of hives:

A 25% increase in fees is not desirable nor does the proposed budget show anything to say that the increase is necessary or justified. We live in times of constraint and we want the agency to reconsider, for example, the benefit of testing 1,000 honey samples. What is the proposed cost and how many AFB hives has previous testing located?  

The agency has provided insufficient information for anybody to construct a better informed view of the finances. This is despite every year of asking for more detailed information relating to a breakdown of expense categories.

The levy order provides that there should be adequate time for the agency to consult with levy payers with information that would allow greater understanding where money comes from and goes to with the PMP.  This has not happened.  The agency have provided a 16 day consultation time span for beekeeper input and yet allows itself 117 days to consider levy payers views, set and notify the levy rate by the required date of 20 Jan 2021.  This is grossly unfair to the levy payers.

The agency appears to have listed the AFB recognition course and default inspections as an expense to all levy payers, whereas these items are cost recovered items. Adequate financial interpretation should see a reduction of levies in this instance.

The agency have budgeted $170,000 for the next review of the PMP in 2023. NZ Beekeeping welcomes the review as a time to consider if there need to be changes to the management of the PMP.  But we think that the review should be conducted by an independent group of beekeepers and MPI as happened for the last review. It is not appropriate for the management agency that have an obvious conflict of interest to lead the review process.

The agency have built substantial reserves over the years. Any costs associated with the PMP review could be covered by reserves.

Finally, it has become a part of the consultation process of the management agency to include a survey as part of the consultation.  NZBI thinks that the survey is a 'Push Poll' where the participants are led into providing a response that the Agency wants to hear.

Instead, NZBI suggests levy payers present their view as a submission rather than participating in the survey.  For example the rate of the levy is established as a mathematical calculation once the budget is accepted by levy payers. To accept the budget levy payers should be provided estimates based on realistic appraisals of the program costs and expected income. The ‘levy’ is the amount required to balance the books divided by the levy base. For the agency to ask in a survey “Do you agree that the levy rate for 2021/22 should be fixed at $1.70 per colony and $40 per beekeeper?” is a question that cannot be answered until levy payers are provided sufficient information that allows them to do the maths to confirm yes or no that $1.70 per colony and $40 per beekeeper will provide sufficient income to balance the books.
 

Kind regards,
Jane

JANE LORIMER

PRESIDENT

 

New Zealand Beekeeping Incorporated

Email: info@nzbeekeeping.co.nz 

I have seen empire building before, there will be no end to fee increases and it will not help the people it was supposed to help. Mark these words.

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I am not keen on any levy increases especially at the moment but I am also not keen on my hives picking up any more AFB from neighbouring hives. The testing of 1000 honey samples will be expensive but also hopefully find some of those hidden, unreported AFB hotspots. There are some very large beekeeping\having operations out there that consistently report little or no AFB despite lots of evidence to the contrary. Large-scale Honey testing will identify whether they are being honest or not.

It has always been difficult to identify who has a problem until the problem is so big it can't be hidden or missed. Honey testing will benefit everyone because outbreaks will be identified and controlled a lot quicker than in the past.

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Honey testing only really works when hives are not moved about.   I am aware of a positive test in honey and the hives on the site were not the hives on site when the retail sample was tested.   The Agency in there usual bullying way were not interested.   

I believe that a lot of the proposed testing methods are greatly flawed.   The labs may be able to detected stuff in the samples but unless the taking of samples is done in a scientific way the lab results are useless.

 

A AP2 poping past to take samples will never be a scientific method  

 

 

 

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34 minutes ago, morporks said:

The Agency in there usual bullying way

 

is this really a specific AP2 that you have locally or is this from the AP1 who you have upset? Your location is given as New Zealand and that's ok, I don't want to know. But it is a problem that not everyone gets on with everyone else..

 

From my experience, we had another AP2 come in to the area following a outbreak from his area and the guy was hopelessly disorganised and opinionated. Wasted a lot of time (my time and his own) and found nothing and was sufficiently useless for me to write a letter of complaint. Whereas our local AP2 is 'gold' being sensible, diplomatic and pretty organised. Yesbut would have an issue with his spelling and grammar, but AP2 are just people and they come in all kinds.... 

Looks like I'm really spoilt here..

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When Byron Taylor talked at a meeting about three years ago, I asked the question about how much honey was tested for AFB, and he replied 150/year. Those samples were taken from supermarket shelves, and so from large commercials, and he said a number of the samples had high levels of ABF spores - some from companies who had not reported AFB for years. 150 sample over 1 million hives is nowhere near a suitable sample size from any statistical standpoint. The test will help flush out hidden AFB spreaders. Some may see that at draconian, but I see it as science doing it's job for beekeepers.

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On 22/09/2020 at 7:24 AM, morporks said:

Dear Members,

As you may know,  the AFB PMP Management Agency has proposed an increase in levies of 25% for the 2021/22 levy year. NZ Beekeeping supports the PMP’s objectives and does not begrudge paying reasonable levies to fund the PMP. However, on top of last year’s increase for commercial beekeepers, the levy increase is intolerable at a time when beekeepers are struggling to remain financially viable. 

Your Executive are sufficiently concerned at the continual increases in the levy and offer the following suggestions if members and those on our wider mailing list also have concerns.  We have listed here are some aspects of the budget that have not been sufficiently explained so you can make an informed decision regarding the budget. You might like to drop in a submission to the management agency or use the NZB template to send your views. For some, even a 10c per colony levy increase can be a significant amount spread over a number of hives:

A 25% increase in fees is not desirable nor does the proposed budget show anything to say that the increase is necessary or justified. We live in times of constraint and we want the agency to reconsider, for example, the benefit of testing 1,000 honey samples. What is the proposed cost and how many AFB hives has previous testing located?  

The agency has provided insufficient information for anybody to construct a better informed view of the finances. This is despite every year of asking for more detailed information relating to a breakdown of expense categories.

The levy order provides that there should be adequate time for the agency to consult with levy payers with information that would allow greater understanding where money comes from and goes to with the PMP.  This has not happened.  The agency have provided a 16 day consultation time span for beekeeper input and yet allows itself 117 days to consider levy payers views, set and notify the levy rate by the required date of 20 Jan 2021.  This is grossly unfair to the levy payers.

The agency appears to have listed the AFB recognition course and default inspections as an expense to all levy payers, whereas these items are cost recovered items. Adequate financial interpretation should see a reduction of levies in this instance.

The agency have budgeted $170,000 for the next review of the PMP in 2023. NZ Beekeeping welcomes the review as a time to consider if there need to be changes to the management of the PMP.  But we think that the review should be conducted by an independent group of beekeepers and MPI as happened for the last review. It is not appropriate for the management agency that have an obvious conflict of interest to lead the review process.

The agency have built substantial reserves over the years. Any costs associated with the PMP review could be covered by reserves.

Finally, it has become a part of the consultation process of the management agency to include a survey as part of the consultation.  NZBI thinks that the survey is a 'Push Poll' where the participants are led into providing a response that the Agency wants to hear.

Instead, NZBI suggests levy payers present their view as a submission rather than participating in the survey.  For example the rate of the levy is established as a mathematical calculation once the budget is accepted by levy payers. To accept the budget levy payers should be provided estimates based on realistic appraisals of the program costs and expected income. The ‘levy’ is the amount required to balance the books divided by the levy base. For the agency to ask in a survey “Do you agree that the levy rate for 2021/22 should be fixed at $1.70 per colony and $40 per beekeeper?” is a question that cannot be answered until levy payers are provided sufficient information that allows them to do the maths to confirm yes or no that $1.70 per colony and $40 per beekeeper will provide sufficient income to balance the books.
 

Kind regards,
Jane

JANE LORIMER

PRESIDENT

 

New Zealand Beekeeping Incorporated

Email: info@nzbeekeeping.co.nz 

Need to have more beekeepers out there inspecting each area not wasting money on testing 1000 samples, it's not going to do much is it?

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3 hours ago, Sailabee said:

The test will help flush out hidden AFB spreaders. Some may see that at draconian, but I see it as science doing it's job for beekeepers.

 

I agree @Sailabee provided that samples from beekeepers that return a positive for AFB are properly followed up on. There is little point in doing the testing without putting some serious time and resources into followup (including prosecution).

 

18 minutes ago, Maru Hoani said:

Need to have more beekeepers out there inspecting each area not wasting money on testing 1000 samples, it's not going to do much is it?

 

I don't think this needs to be about trying to exhaustively test samples from every different beekeeper. If the testing is done and an example is made of a few flagrant rule breakers then more will fall into line because they know they are more likely to get caught out. 

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A lab test of a sample of honey that has AFB material only shows that it has AFB material in it. Nothing more

If its a DNA test it only shows that is contains DNA.  Does the DNA test show that the material is capable of causing and infection ?  Does heating AFB material above 160 destroy that AFB DNA? Did the DNA come from the foundation wax or wax sprayed onto plastic frames?  There are many question that need to be asked before the positive DNA test can be used to say a Beekeeper has a problem.

 

 

The PMP requires only  one inspection per year for clinical symptoms of AFB.  There is no requirement to inspect your hives when removing the honey.   It is therefore quit possible to extract AFB infected honey from a hive which may be picked up in the testing.   This does not mean you are non compliant as long as you have done your yearly inspection and have some traceability.

 

The size of the batch and how many hives per batch is important.  There are many small sellers of honey in various stores, super markets, one line etc.  Some of the batches could be 100kgs  which may have only come off 3 hives. 

 

Maybe the neighboring beekeeper  had a AFB hive robbed out by the hives with the honey sample with AFB material in it

 

My point is that there are too many questions/possibility about the  AFB testing of honey sample to make claims that a positive sample means the beekeeper in non compliant with the AFB PMP

 

It mealy says it contains AFB Material

 

      

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13 hours ago, Maru Hoani said:

Need to have more beekeepers out there inspecting each area not wasting money on testing 1000 samples, it's not going to do much is it?

trouble is beekeepers are not cheap and not accurate. beeks are human.

lab tests can help a lot. they are a tool which needs to be used the right way.

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17 hours ago, Sailabee said:

Those samples were taken from supermarket shelves, and so from large commercials,

keep in mind that testing only works with those that sell their own honey.

many brands are made up of a lot of different beeks honey. eg it can be 30 different beeks honey in that jar. which one had the afb ?

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10 hours ago, tristan said:

keep in mind that testing only works with those that sell their own honey.

many brands are made up of a lot of different beeks honey. eg it can be 30 different beeks honey in that jar. which one had the afb ?

Again, hives are not going to be destroyed because of a positive test.  It would only alert the agency to better target the inspections that will happen.

 

18 hours ago, morporks said:

My point is that there are too many questions/possibility about the  AFB testing of honey sample to make claims that a positive sample means the beekeeper in non compliant with the AFB PMP

A positive honey sample from a packer will not be the basis burning hives, and it is malicious to imply that .  The testing will be used to better target inspections that might follow. 

 

Arguing about how the results came to be is sort of interesting, but beside the real intention - improving tools and procedures to identify elements that have and do lead to the spread of AFB...

 

I have a hard time understanding the mindset, seemingly encouraging beekeepers to stay just barely on the right side of the line of what could be deemed 'illegal', then challenging the agency to make the determination of which side of the line the beekeeper is on.

 

My children used to do similar in the car's back seat: "She put her hand on my side!" "No I didn't. I had it as close to the middle as I could, but still on my side!  You can't get me for that!".

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Just to clarify something else about this.

 

My understanding from a presentation I went to about this, is that beekeepers who are found to have excessive AFB in their honey, but are found to have been declaring AFB finds in their hives so therefore actively dealing with the problem, may not be targeted for inspection.

 

But beekeepers who have excessive AFB in their honey but are declaring little or no AFB in their hives will be looked at. Because they may not be dealing with it or even recognising it.

 

The reasoning is that over the last couple of years, several outfits have been found that had massive AFB issues, we are talking of hundreds of hives. And they had declared virtually no AFB. They were only found after considerable costs had been accrued by nearby beekeepers forcing them to complain.

 

The thought is there may be other outfits in a similarly bad situation, and if they can be identified before they cause widespread outbreaks and cost their neighbours large amounts of stress and money, that must be a good thing.

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Alistair

 

A way to think about it is would you be happy being stop by the police and questioned every time you walked down the road because you look dodgy, but when  in fact you are not breaking any law

The reason you look dodgy is because your neigbour thinks anybody who drives a red ute must be breaking the law.

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2 hours ago, morporks said:

Alistair

 

A way to think about it is would you be happy being stop by the police and questioned every time you walked down the road because you look dodgy, but when  in fact you are not breaking any law

The reason you look dodgy is because your neigbour thinks anybody who drives a red ute must be breaking the law.

 

I think the analogy is more about police stopping a red truck weaving on the road, and breath testing - the signs are there to give cause for suspicion, so test to see if you are correct. Loosing a large part of your income because of a neighbouring beek, and confidence that you are finding AFB has had a terrible effect on many over the years. Some of the really large commercials have very few staff members with a DECA, so many hives are inspected by those trained within the company, so rather than meeting the required standard to pass the exam, they do as best as they can depending on the teaching capabilities of the staffer who trained them. All hobby hives are inspected by a DECA holder - although mostly with probably far fewer hive hours of experience.

 

Edited by Sailabee
Disjointed sentence.
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Well said Sailabee and in my view that is a fair assessment.

 

And Morporks I do see your point, and thank you for stating it so politely 👍.

 

But as per Sailabee, a whole lot of AFB in somebody's honey does amount to just cause to check things out. Remember it may not be you that is targeted, it may be that new beekeeper moved right next to you, can't recognise AFB or doesn't want to, and your levy money will be used to protect you and your livelihood from him.

 

It could be that somebody get's their back up cos they got inspected. But at some point with some beekeepers a level of compulsion is necessary to get the job done and protect others. But best I can tell, the overwhelming majority of beekeepers see the value. Might complain about the levy, but do see the need for the program.

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22 hours ago, tristan said:

30 different beeks honey in that jar. which one had the afb ?

30 may be a bit high, but packers know whos honey goes into what batch and what jars come from those batches. So if some is found then all those beeks from that batch perhaps may be notified.

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9 hours ago, morporks said:

Alistair

 

A way to think about it is would you be happy being stop by the police and questioned every time you walked down the road because you look dodgy, but when  in fact you are not breaking any law

The reason you look dodgy is because your neigbour thinks anybody who drives a red ute must be breaking the law.

But you drive down a road with a hidden speed camera to just catch the speeders, but everyone is checked but only the guilty speeders are spoken to.

You can have the same arguments around any auditing, "its what's inspected, not what's expected" that is how you find the guilty.

Morporks you seem to have an issue with having honey tested,?

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11 hours ago, NickWallingford said:

Again, hives are not going to be destroyed because of a positive test.  It would only alert the agency to better target the inspections that will happen.

never said it was.

point was which beek do you look at when it comes back positive.

8 minutes ago, Dennis Crowley said:

30 may be a bit high, but packers know whos honey goes into what batch and what jars come from those batches. So if some is found then all those beeks from that batch perhaps may be notified.

30 is not all that high.

yes all beeks are recorded so they can notify all, but its rather expensive to go looking at all beeks involved.

a bit different if there was a trend like the same beeks name poping up with different positive batches. that can narrow the field somewhat.

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