New Levy Proposal

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 in the documents here:

Levy proposal documents

 

Previous levy consultation

Access to the July 2018 AFB levy consultation can be found here.

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