Priority – Medium
Security Level – In Confidence
To: Hon Andrew Hoggard, Associate Minister of Agriculture
Hon Mark Patterson, Minister for Rural Communities
From: Susie Wilson, Manager Science, Innovation, Workforce Policy
Training programmes in the primary industries
Date 19 September 2024
Reference
AM24-0861
Purpose
•
This aide-memoire provides you with information and talking points on in-work training
to support your meeting with Hon Louise Upston, Minister for Social Development and
Employment on 26 September 2024, 9:00 am to 10:00 am, in your office.
Background on in-work training in the primary industries
1. In-work training is a way of training new staff or upskil ing existing employees.
It includes informal employer provided training and formal training towards
qualifications. Formal training involves oversight by an accredited private training
enterprise (PTE) or Te Pūkenga through its work-based training subsidiary. Formal
training qualifies for government funding through the Tertiary Education Commission
(TEC).
2. In-work training is critical to the primary sector, especially in regions where provider-
based, or in-person training is unavailable. Some PTEs meet criteria for TEC funding
while others deliver courses paid for by employers, as is common in the wool industry,
for example.
3. The Ministry for Social Development (MSD) funds some programmes that equip young
people, or people on benefits to enter the food and fibre sector as work-ready
employees. These programmes involve pastoral care and equip students with life
skills.
4. Programmes include:
a) Flexi-wage: a wage subsidy for either 24 or 36 weeks to support employers to
take on and train people who do not meet the entry level requirements of the job.
b) Mana in Mahi: Mana in Mahi provides an industry training pathway with wage
subsidies, pastoral support, and client payments. It reduces the number of
people receiving benefits as they move into work over a wide range of industries
with the largest numbers in construction, agriculture, forestry, and fishing.
AM24-0861
Page 1 of 4
18. How can reforms provide for work based training and micro-credentials that can
deliver work-ready trainees in a shorter timeframe?
Minister / Minister’s Office
Seen / Referred
/ / 2024
AM24-0861
Page 4 of 4
B24-0525
3. On 12 August 2024, the Cabinet Expenditure and Regulatory Review Committee
agreed to the proposals of the Gene Technology Policy Decisions paper
[CAB-24-MIN-0296 refers]. This included a proposal to empower Hon Judith Collins
KC, Minister of Science, Innovation and Technology, in consultation with relevant
ministers, to decide on changes to other acts (without separate Cabinet approvals) to
accommodate the Gene Technology Act.
4. Officials have provided the Ministry of Business, Innovation and Employment with
potential amendments to the Biosecurity Act 1993. We are now seeking your
confirmation and approval for these proposed changes.
Implementing the Gene Technology enforcement requires amendments to the
Biosecurity Act 1993
We are using existing systems as much as possible
5. Cabinet has agreed to base the enforcement of the Gene Technology Act on what is
in the Hazardous Substances and New Organisms (HSNO) Act 1996 (the HSNO Act)
for new organisms. The intention was to ensure there is a functional enforcement
regime ready when the new Gene Technology Act is passed.
6. There are several provisions in the Biosecurity Act 1993 that empower MPI to manage
new organisms at the border and within New Zealand. These wil require amendment
if they are to apply to GMOs under the new legislation. Proposed initial amendments
are listed in
Appendix One.
7. Depending on how the Gene Technology Act is drafted and the exact terminology
used, there may be further consequential amendments required. We wil seek further
approvals from you as necessary.
There are some pain points in the current system which could be exacerbated by the
Gene Technology Regime
We understand that Ministers expect interacting systems to be streamlined and efficient
s9(2)(g)(ii)
8.
s9(2)(g)(ii)
9.
Page 2 of 5
B24-0525
10. s9(2)(g)(ii)
This project presents an opportunity to resolve ongoing issues
MPI wil work with the Ministry for the Environment to attempt to resolve these pain points
11. Addressing problems within the current system wil help to meet the Government’s
objective of create an enabling and streamlined environment for using GMOs.
s 9(2)(f)(iv)
14. MPI wil work with the Ministry for the Environment and the Environmental Protection
Authority to scope work that could be done to resolve ongoing interface issues
between the acts. We wil report back to you when there are significant developments.
Next steps
15. You might wish to discuss the opportunity to improve the wider system for managing
new organisms with Hon Penny Simmonds, Minister for the Environment. Officials can
provide talking points, should you choose to do this.
Page 3 of 5
B24-0525
Recommendations
16. It is recommended that you:
a)
Note that Hon Judith Collins KC, Minister of Science, Innovation, and
Technology may approach you to discuss amendments to the Biosecurity Act
1993 as part of the Gene Technology Bil ;
NOTED
b)
Note that the amendments being proposed to the Biosecurity Act 1993 as part
of the Gene Technology Bil mirror the current settings for managing new
organisms, including the interface between the Biosecurity Act 1993 and the
Hazardous Substances and New Organisms (HSNO) Act 1996;
NOTED
c)
Agree to progress the list of indicative amendments to the Biosecurity Act 1993
set out in
Appendix One as part of the Gene Technology Cabinet package;
YES / NO
d)
Note that there are pain points within the current system caused by interactions
between the Biosecurity Act 1993 and the Hazardous Substances and New
Organisms (HSNO) Act 1996;
NOTED
e)
Note that officials wil work with the Ministry for the Environment and the
Environment Protection Authority to scope amendments that could be made to
the HSNO Act to address operational pain points;
NOTED
Page 4 of 5
B24-0525
f)
Note that officials will provide you with further advice on how the wider system
could be improved when there are significant developments.
NOTED
Fiona Duncan
Hon Andrew Hoggard
Director, Regulatory Systems Policy
Minister for Biosecurity
Policy and Trade
/ / 2024
Page 5 of 5
B24-0525
Appendix One: Consequential amendments to the Biosecurity Act 1993
These consequential amendments are based on our understanding of how the Gene
Technology Act wil be drafted. The final wording of the amendments wil depend on the
interface between the two Acts.
Section in Existing provision
Indicative amendment
the
Biosecurity
Act 1993
2
No definition currently in the Act.
Include a definition for “regulated
organism”, or whatever term is used to
describe genetical y modified organisms
(GMOs) that are regulated by the Gene
Technology Act.
2
No definition currently in the Act.
Include a definition for “Gene Technology
Regulator”.
28
A biosecurity inspector must not give a
Amend to include regulated organisms
biosecurity clearance for goods that are or
under the Gene Technology Act and
contain an organism specified in Schedule 2
enable regulated organisms permitted for
of the Hazardous Substances and New
use in containment to be authorised to go
Organisms Act 1996 (the HSNO Act) or for a
to that containment facility (both approved
new organism. However, an inspector can
and non-approved).
give clearance for goods that may involve an
incidentally imported new organism.
Any new organism which is approved for
importation into containment may be al owed
to go to that containment facility.
28A
Any inspector may seize any organism which Amend to include suspected regulated
they have reason to believe may be a new
organisms.
organism.
28B
Section 28 does not apply to organisms
Amend to include regulated organisms
approved under specific sections of the
approved under the relevant sections of the
HSNO Act.
Gene Technology Act.
39
The Director-General may approve a place as Amend to include containment facility
a containment facility if they meet the
standards approved by the Regulator in
requirements of the Biosecurity Act 1993 and accordance with the Gene Technology Act.
the relevant standards under the HSNO Act.
40
In approving a facility or operator, the
Amend to include the convictions under the
Director-General may take certain matters
Gene Technology Act.
into account. These matters include:
(a) a serious or repeated failure to comply in
the past with a duty imposed by the
Biosecurity Act on a facility operator:
(b) a conviction for an offence against the
Biosecurity Act 1993, or the HSNO Act,
among others.
41A
The definition of “ministry-related border
Amend to include the Gene Technology
management function” includes any function, Act.
duty, or power imposed on MPI by or under
any of a series of Acts in relation to the
management of risks associated with the
movement of goods, person, or craft into or
out of New Zealand.
Page 1 of 2
Appendix One
B24-0525
44(2)
The duty to inform does not apply in relation
Amend to include organisms which are in a
to an organism that is seen or otherwise
place where they may be present in
detected in a place where it may lawful y be
accordance with the Gene Technology Act.
present in accordance with an approval given
under the Hazardous Substances and New
Organisms Act 1996.
45
The responsible Minister must not
Amend to include that MPI must not
recommend the making of a notifiable
recommend a regulated organism to be a
organism order under section 45(2) in respect notifiable if it has been released in
of any new organism approved for release in
accordance with the Gene Technology Act
accordance with the HSNO Act unless that
without first consulting with the Regulator.
Minister has first consulted the Environmental
Protection Authority.
126
An authorised inspector may inspect a
Amend to include the standards set by the
transitional facility or containment facility to
relevant section/s of the Gene Technology
confirm that the facility complies with the
Act.
relevant standards.
If a facility does not meet the necessary
requirements, an inspector is empowered to
give directions to remedy the situation.
Page 2 of 2
Appendix One
Priority – Low
Security Level – In Confidence
To: Hon Todd McClay, Minister of Agriculture
Cc: Hon Andrew Hoggard, Minister for Biosecurity
From: Stuart Anderson, Deputy Director-General Biosecurity New Zealand
Update on the Corbicula fluminea Waikato 2023 Response
Date 12 September 2024
Reference
AM24-0877
Purpose
•
This aide-memoire provides an update on the biosecurity response to the detection of
Corbicula fluminea in the Waikato in early May 2023, and specific actions being taken
to protect Lake Ōkataina.
General update on the Corbicula fluminea incursion in the Waikato River
1. In May 2023, Biosecurity New Zealand (BNZ) and its partners established a
biosecurity response to the detection of
Corbicula fluminea (
Corbicula) in the Waikato
River. Since the initial discovery at Bob’s Landing on Lake Karāpiro,
Corbicula has
been confirmed in a 227 kilometre stretch of the river, from Lake Maraetai down to
Tūākau Bridge. Advice from technical experts indicates that it will not be possible to
eradicate
Corbicula from New Zealand.
2. A nationwide surveil ance programme using environmental DNA (eDNA) techniques
and visual surveil ance has not found evidence of
Corbicula in any other water body in
New Zealand. A new surveil ance strategy is currently under development to increase
certainty in this finding.
3. Research to investigate the limiting depths and population densities of
Corbicula has
shown us that this species is well established in the Waikato River. It is present up to
depths of 30 metres on all types of sediments, it can exist below the substrate up to
15 centimetres and has a multigenerational population structure.
4. In addition to being present in the river, it is increasingly found in the infrastructure and
intake ponds of water users who hold consents to take water directly from the Waikato
River. BNZ is working with these consent holders to understand the impacts and
opportunities for reducing these.
5. Transition to a long-term management programme is the best way to ensure
appropriate management of the impacts of
Corbicula. A transition plan is being
developed with regional councils, iwi, major users and others to transition to long-term
management with the aims of:
a) containing
Corbicula to its known range and areas of likely natural spread in the
Waikato River catchment area;
AM24-0877
Page 1 of 3
BNZ assessment of the biosecurity risk to Lake Ōkataina
14. There is good argument that the CAN conditions for Ōkataina and the other Te Arawa
Lakes should be aligned as, on the face of it, they manage the same risk. However,
there is some justification for different conditions at Lake Ōkataina because of the
unique considerations outlined below:
a) unlike any of the other Te Arawa lakes, Lake Ōkataina is the only lake with one
road in and one boat ramp which gives an ability to provide a higher level of
protection by controlling access for regular lake users; and
b) there are unique cultural considerations for Lake Ōkataina, from a Te Arawa
perspective this lake held in higher regard than other lakes in the region.
15. While BNZ surveil ance indicates
Corbicula is only found in the Waikato River, we are
not certain that it is not anywhere else. Given that it is relatively easy to provide a
higher level of protection at Lake Ōkataina than other lakes, in combination with the
unique situation at Lake Ōkataina, we consider these additional protections are
justified.
16. At last week’s meeting with stakeholders a proposal to provide full access to Lake
Ōkataina, while maintaining the current CAN conditions, was broadly supported by all
parties.
Maintaining on-going, full access to Lake Ōkataina
17. A permanent managed access solution for Lake Ōkataina will be put in place by way
of a barrier arm controlled by swipe card, QR code, or PIN number. Access will only
be obtained after washing at an official wash station.
18. Bay of Plenty Regional Council have agreed to take the lead on this project with BNZ
support. Ngāti Tarawhai, Fish & Game, Bay of Plenty Regional Council, and Te Arawa
Lakes Trust have formed a working group to develop options for this access which will
become a permanent solution for Lake Ōkataina. Options will be confirmed in two
weeks’ time.
19. The technology is readily available and used in a variety of settings (such as
controlling remote access to forest blocks) and is likely to be able to be put in place
quickly.
20. The cost of implementing access will be via a cost share arrangement between all
parties, including BNZ.
Minister / Minister’s Office
Seen / Referred
/ / 2024
AM24-0877
Page 3 of 3
Priority – Medium
Security Level – In Confidence
To: Hon Andrew Hoggard, Minister for Biosecurity
From: Stuart Anderson, Deputy Director-General Biosecurity New Zealand
Improving the plant nursery stock import system
Date 12 September 2024
Reference
AM24-0816
Purpose
•
This aide-memoire provides information about Biosecurity New Zealand (BNZ) work to
improve the plant nursery stock import system. We intend to start consulting on this
work this month.
Background
1. The existing system for importing food and fibre plant nursery stock (whole plants,
tissue culture, budwood) manages risks wel , but needs improving to help sectors
import new varieties and genetics faster and with less cost.
2. Two key initiatives BNZ is taking to improve import efficiency are:
a) cleaning up the plant nursery stock standard by suspending import pathways that
have not been used; and
b) speeding up imports of food and fibre plant nursery stock.
3. Suspending unused import pathways wil let us focus resources on managing actively
traded pathways and opening new priority pathways. BNZ recently finished consulting
on this and is working through matters raised by stakeholders before it is finalised
(refer AM24-0862
Proposed changes to nursery stock import pathways).
4. BNZ now plans to consult on how to speed up imports of food and fibre plant nursery
stock, and reduce costs, while having a more efficient and less complex regulatory
system. BNZ will work closely with stakeholders to ensure that the final solutions give
the broadest possible benefits.
5. The third, longer-term piece of work (yet to start) is a redesign of the plant nursery
stock Import Health Standard (IHS) framework to significantly reduce complexity.
AM24-0816
Page 1 of 6
Current state
6. The current system is complex and nearly 30 years old. It gives two main options for
importing food and fibre plant nursery stock: manage all risk in New Zealand, or
manage some risk offshore.
Manage all risk in New Zealand
7. Most food and fibre plant nursery stock, including most horticultural species of
economic importance to New Zealand, needs Level 3B quarantine in New Zealand.
This is because these plant species may host pests that present a very high risk to
New Zealand’s economy and/or environment:
a) importing into Level 3B quarantine is the main method used to import many food
and fibre plants. Plants in Level 3B quarantine are grown and inspected for
disease symptoms and tested for key high-risk pests;
b) imports can take a long time (12 to 24 months for many plants) and the process
can be expensive. This can stop New Zealand industries accessing new varieties
as quickly as key offshore competitors and can stifle innovation; and
c) the system is highly detailed, complex, and often hard for importers to use. This
is because there is considerable variation in requirements between different
plant species, and standards can be out-of-date and hard to interpret.
Manage some risk offshore
8. There are three ways to manage some risk offshore. All three options remove the
need for Level 3B quarantine in New Zealand, as described in paragraphs 9 to 11:
a) source plants that are grown and tested in high-health offshore facilities
approved by the Ministry for Primary Industries (MPI);
b) obtain assurances from overseas competent authorities for freedom from some
key high-risk pests; and
c) import plants as tissue cultures.
9. Source plants from high-health offshore facilities that are approved by MPI:
a) this is a main method used to import some key food and fibre plants. It utilises
commercial systems which distribute high-health plants around the world. MPI
audits these facilities and identifies how much risk is managed offshore;
b) five offshore facilities currently meet MPI’s requirements and are approved by
MPI. We expect to approve a sixth facility soon;
c) while it costs less than managing all risk in New Zealand, most facilities do not
manage risk from all pests that New Zealand is concerned about. This means
that most plants still need Level 2 or 3A quarantine in New Zealand. It can take
up to three years to complete the combined offshore-onshore import process;
and
d) offshore facilities voluntarily meet the import requirements; BNZ has no means of
enforcement. Imports have been disrupted if facilities become unwil ing, or
unable, to meet the requirements.
AM24-0816
Page 2 of 6
10. Obtain assurances of pest freedom from overseas competent authorities:
a) some food and fibre plants can be imported into Level 2 quarantine if overseas
competent authorities can certify they are free from key pests (for example, as
confirmed by testing or official pest status);
b) it is often not possible to get sufficient assurance of pest freedom from overseas
authorities. This can make it hard, or impossible to import from some countries;
and
c) this option is seldom used for food and fibre plants as it usually applies to those
for which there is little demand to import. It is a main way to import plants for
New Zealand’s ‘green-life’ sector. ‘Green-life’ is plants for people, homes, urban
spaces, and the natural environment.
11. Import plants as tissue cultures:
a) many plants imported as tissue cultures can be cleared when they arrive in
New Zealand, with no quarantine. This is because many pests may be
eliminated from plants by the process of putting them into tissue culture; and
b) this option is also seldom used for food and fibre plants but is a main way to
import plants for New Zealand’s green-life sector.
Options BNZ wil consult on:
12. BNZ wil consult on two change options for food and fibre plant nursery stock. Options
were developed as part of the Plant Germplasm Import Council work programme, with
assistance from industry members.
Change Option 1:
13. Faster quarantine for plants from non-approved sources. A target maximum
quarantine length of nine months in Level 3B for nearly all plants. This will be
supported by more testing for key pests. It would reduce cost and speed up access to
new genetics:
a) for many plants this would reduce quarantine length by between 7 and 15
months. It would allow plants to be released from quarantine within one calendar
year of import and would speed their entry into commercial production.
b) note that in all cases, quarantine lengths in this briefing relate to the period after
plants start growing. In some cases, there is a lag of several weeks between
when plants enter quarantine and when the official quarantine period starts.
14. Less reliance on managing risk offshore. BNZ would only approve offshore facilities
that manage all risk on its behalf – only 1 of 5 approved facilities currently does this.
Other facilities would not be approved, so plants would need Level 3B quarantine (for
the reduced period) as above. BNZ would recognise results of tests from non-
approved facilities, subject to official assurances from overseas competent authorities.
AM24-0816
Page 3 of 6
28. The next steps in the nursery stock improvement work include:
a) doing a similar piece of work to improve imports of green-life plants; and
b) redesigning the framework of the entire plant germplasm import system to
improve efficiency across the board (this is a much more complex piece of work,
which wil take longer to deliver).
29. BNZ will provide another update after consultation on change options described here.
Minister / Minister’s Office
Seen / Referred
/ / 2024
AM24-0816
Page 6 of 6
Appendix One: Summary of key features of each option
AM24-0816
Page 1 of 1
Appendix One
Priority – Low
Security Level – In Confidence
To: Hon Nicola Grigg, Associate Minister of Agriculture
Cc: Hon Andrew Hoggard, Minister for Biosecurity
From: Stuart Anderson, Deputy Director-General Biosecurity New Zealand
Proposed changes to nursery stock import pathways
Date 12 September 2024
Reference
AM24-0862
Purpose
•
This aide-memoire provides information on a proposal by Biosecurity New Zealand
(BNZ) to suspend out of date, unused import pathways and discusses feedback from
a key stakeholder (BLOOMZ NZ Limited (BLOOMZ)).
Key messages
1. s9(2)(g)(ii)
They say it is
hard to comply with, costs too much, and that it takes too long to open new pathways.
2. s9(2)(g)(ii)
. We are working to resolve the above issues,
and to make other improvements to the system:
a) this includes consulting on a proposal to clean up the plant nursery stock import
standard by suspending unused import pathways, many of which have not been
used for over 25 years.
Appendix One provides the background on this
proposal; and
b) this will help us more effectively manage actively traded pathways and let us
focus on opening (or reopening) priority pathways faster.
3. Stakeholders are concerned that we wil never reopen suspended pathways.
Appendix Two describes the themes raised by stakeholder BLOOMZ and how we are
responding.
Appendix Three provides the summary of recommendations from the
BLOOMZ submission:
a) suspension is temporary and not intended as permanent closure;
b) we wil focus on reopening suspended pathways that have been requested by
stakeholders as quickly as possible; and
c) stakeholder concern is understandable. We are looking for dif erent ways to
manage the system to reopen pathways in a timely manner.
AM24-0862
Page 1 of 2
4. We are taking other steps to improve the system including developing options to
speed up the import process of nursery stock (we will consult on these soon) and
planning a longer-term piece of work to redesign the plant nursery stock import
regulatory framework to significantly reduce complexity.
Minister / Minister’s Office
Seen / Referred
/ / 2024
AM24-0862
Page 2 of 2
Appendix One: Background to our proposal to suspend import pathways
Context
1. The existing plant import system manages biosecurity risks well and has allowed
free-flowing imports of some plants for many years. However, it has restricted many
other imports. It needs improving to help industries import plants faster and with less
cost.
2. The first part of Biosecurity New Zealand’s (BNZ’s) work to improve import efficiency
is to clean up the plant nursery stock import health standard by suspending unused,
unmaintained import pathways.
3. The Aotearoa Horticulture Action Plan sets out an agreed aspiration to breed cultivars
that meet future growing needs. That involves ensuring a robust, timely and
cost-effective germplasm import pathway. This is necessary if we are to achieve the
desired outcome of improved access to high quality, pest-free germplasm material in
New Zealand, and increased confidence to invest in breeding programmes.
4. Suspension of pathways may seem counter-intuitive and counter-productive to that
goal. Our experience shows that unused pathways create a distraction from the
pathways that matter.
5. Cleaning up the nursery stock standard by suspending pathways wil help us focus on
maintaining standards that are most important to New Zealand’s plant-based
industries, and which will give the biggest benefits to New Zealand.
6. We consulted on suspending pathways between 18 July and 30 August 2024.
Why did we make the proposal?
5. When we analysed use of the standard, we found that a high proportion of the
standard is unused and has not been maintained for many years:
a) only 24 percent of plants (459 genera) covered by the standard have been
imported in the past 11 years; and
b) remaining plants (1468 genera) haven’t been imported for at least 11 years, and
in most cases not for over 25 years.
6. Biosecurity risk is constantly changing. Standards need regular updates to account for
this. Updating standards is time consuming. Even though most import pathways have
not been used, we need to assess emerging threats and update these pathways if the
standard implies that imports are allowed.
7. Many of the pathways we propose to suspend would need a pest risk review before
they could be used. This is because:
a) standards are based on risk assessments from the 1990s. Most have not been
reviewed to account for changes in biosecurity risk;
AM24-0862
Page 1 of 3
Appendix One
b) many unused pathways may have unmanaged biosecurity risks that we have
identified through the Ministry for Primary Industries’ (MPI) Emerging Risks
System. They may also have unmanaged risks that we do not yet know about
because we haven’t analysed these in many years; and
c) we have not updated most unused pathways to manage these risks. This is
largely because we focus our resources and expertise on ensuring that the
actively used pathways are up to date.
8. We need to be transparent about which pathways are up to date and which are not:
a) the existing standard implies that many pathways are open when, in reality, we
would not allow imports for some because they are out of date;
b) this misleads stakeholders. It can lead to them ordering plants and incurring
significant costs, only to then find that they cannot import the plants; and
c) s 9(2)(h)
9. The proposal to suspend standards does not change the current state of trade, but
instead gives transparency on what can, and can’t, be imported:
a) without suspension of some pathways, we do reactive work to check whether
imports are allowed. This is unplanned, time consuming, and stops us focussing
on priority work that wil give the biggest benefits to New Zealand’s horticulture
sector, and other plant-based industries.
What did we ask stakeholders to provide during consultation?
10. We expected that importers would want to use some pathways proposed for
suspension. We asked the following questions during consultation to understand what
pathways might be in demand, and what impact suspension would have:
a) what impacts wil this proposal have on you?;
b) do you have a viable and valid interest in importing any plants proposed for
suspension?;
c) what is the demand – and opportunities in New Zealand – for plant species that
are proposed for suspension?; and
d) do you have any other relevant information we may have missed while
developing our proposal?
What feedback have we received? 11. Stakeholders have been very engaged with our proposal via email, phone calls and
attendance at information sessions. We received a high number of submissions (24).
Key themes in submissions include:
a) objection to the proposal to suspend unused pathways;
b) lists of plants that stakeholders are interested in and want to import in the future;
c) concerns that suspended pathways wil not be reopened when importers and
industry groups need them;
d) concern about the impact of suspending pathways on growth and productivity of
plant sectors, and goals to double horticulture export values;
e) some support towards changing the system; and
AM24-0862
Page 2 of 3
Appendix One
f)
support for the reformat of the nursery stock standard.
Next steps
12. We are in the process of considering all feedback.
13. We aim to make decisions about the pathways that wil be suspended in late
September. This timeframe may shift if further analysis of options is needed.
AM24-0862
Page 3 of 3
Appendix One
Appendix Two: Our response to the BLOOMZ submission
1. BLOOMZ is a key stakeholder involved in importing plants for planting and their
submission was on behalf of several stakeholder groups with an interest in importing
nursery stock. They raised concerns about our proposal to suspend import pathways
(see BLOOMZ ‘summary of recommendations’ in
Appendix Three). We have
grouped their recommendations into four main themes and respond to each.
Suspension and barriers to trade – BLOOMZ recommendations 3, 4 and 5
2. BLOOMZ commented that many pathways are not used because there are too many
barriers to import. They note that this does not mean people don’t want to import.
They asked us to retain several pathways proposed for suspension and to prioritise
those for review. They also commented that we need faster ways to review standards.
3. We agree there are many barriers to prospective importers under the current standard
and that a lack of trade does not necessarily mean there is no interest in importing:
a) this is why we asked stakeholders to identify pathways of interest to them. We
will keep working with them to better understand their needs for these pathways;
and
b) BLOOMZ identified four plant genera that they and their clients are interested in.
We wil work with them to find out more about these pathways.
4. Once we fully understand the needs, we wil prioritise standards for review and work to
reopen pathways as quickly as possible. We don’t want to unduly restrict trade where
there is a desire to import. But we must ensure biosecurity risk wil be effectively
managed before we allow imports of plants that have never been imported and where
standards are out of date.
5. We already have a substantial pipeline of standards for review. This includes
standards for plants (including banana, cannabis, pear, and pine) and seeds
(including brassica, tomato and maize):
a) we wil need to prioritise re-opening pathways against reviews of those
standards, to ensure that all work we do wil deliver maximum economic, and
other benefits for all of New Zealand.
6. We agree with BLOOMZ that we need faster ways to review standards. Standard
delivery has taken, and continues to take, longer than we would like:
a) we have done a substantial amount of work to improve the speed of standard
delivery. This has seen us deliver standards faster. More improvements are
needed; and
b) a key aim of the recent BNZ organisational efficiency change was to find more
efficiencies in the standard setting area and free up resource to dedicate to
standard delivery. We expect that we wil continue to deliver standards faster as
we embed the new structure and develop new ways of doing things.
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Appendix Two
Impact on international trading partners – BLOOMZ recommendation 2
7. BLOOMZ’s view is that suspending pathways will be seen as a technical barrier to
trade and signal to international trading partners that we are not ‘open for business’.
8. BNZ has considered reactions of trading partners, and we have taken steps to
mitigate negative consequences:
a) overall, we do not expect trading partners to see this as trade restrictive because
our proposal targets import pathways that have not been used for many years.
Trading partners very rarely express interest in using nursery stock pathways.
Import pathway requests nearly always come from New Zealand importers;
b) we were concerned that the proposal could be interpreted incorrectly, so we
have been proactive in liaising with our offshore counterparts. We consulted
through the usual Sanitary and Phytosanitary World Trade Organisation process
(30 July to 12 September) and raised this topic at a recent Asia & Pacific Plant
Protection Commission meeting; and
c) as of 6 September, we have not received any feedback from trading partners.
Reformatting the Import Health Standard – BLOOMZ recommendation 1
9. The nursery stock standard was first issued in 1993. It has been amended many times
since. This has introduced inconsistencies and resulted in a long complex standard
that is hard to follow.
10. We reformatted the standard to make it more user-friendly, and to align with MPI
Requirements and Guidance formatting requirements.
11. Expected efficiency outcomes are that:
a) we wil get fewer questions about how to interpret import requirements. This will
free up resource for us to use elsewhere (for example, to improve the system);
and
b) imported plants are more likely to conform with the standard. This means that
there wil be fewer delays in import, and fewer costs incurred.
12. We consulted on the changed format at the same time as we consulted on suspension
of pathways. Stakeholders overwhelmingly supported the change and saw it as a big
improvement.
13. BLOOMZ agree the reformatting is an improvement. They also commented that they
want to see the requirements in an online database, not a static document.
14. We fully agree that a database wil be easier to use – this is our preferred option:
a) reformatting is a necessary first step to prepare requirements more suited to
entry into a database;
b) BNZ has implemented the first phase of the Product Import and Export
Requirements (PIER) project which includes a database that holds summarised
data of biosecurity regulations. This is accessible through a public website for
industry stakeholders, importers, exporters, and offshore competent authorities;
and
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Appendix Two
c) Ahead of commencing Phase 2 of the PIER project we are assessing alternative
design options. The enhanced design aims to hold more biosecurity regulatory
data and information, with an intuitive website that wil improve user access to
get current and accurate biosecurity regulatory information.
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Appendix Two
Appendix Three: Summary of recommendations from the BLOOMZ submission
1. We submit that the reformatting of import health standard (IHS) should remove any
reference to treatments, and that all import requirements be included in PIER in a new
user-friendly electronic interface.
2. We oppose BNZ’s proposal to suspend numerous IHSs in that it sends a very
destabilising message to our trading partners.
3. We disagree that many IHSs are redundant due to disinterest; rather there have been
numerous barriers to prospective importers so they have not proceeded.
4. In any event we request that several IHS listed on pages 9 and 10 (of the BLOOMZ
submission) are left in place and prioritised for rapid review if necessary.
5. BNZ does not have the capability to review numerous IHSs within a timeframe that is
acceptable to industry. We submit that a radical new approach for IHS development
with early collaboration with industry is the number one priority.
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Appendix Three
Priority – Low
Security Level – In Confidence
To: Hon Andrew Hoggard, Minister for Biosecurity
From: Stuart Anderson, Deputy Director-General Biosecurity
High Pathogenicity Avian Influenza Update
Date 2 September 2024
Reference
AM24-0807
Purpose
•
This aide-memoire updates you on work to prepare New Zealand for a H5N1 Highly
Pathogenic Avian Influenza (HPAI) incursion. It also provides a summary of the
possible implications on free-range producers during an incursion.
International Environment
California cattle infection
1. Three California dairy herds tested positive for HPAI, with clinical signs beginning 23
August to 25 August. It is not yet clear how these herds became infected – if it was
from another spil over event or is the same HPAI H5N1 variant that’s spread from
Texas. No human cases have been confirmed in relation to this event.
2. Animal movement is being tracked and evaluated. The affected dairies have been
placed under quarantine on the authority of California Department of Public Health’s
State Veterinarian, and enhanced biosecurity measures are in place. Sick cows are
isolated and are being treated at the dairies; and healthy cows have been cleared to
continue shipping milk for pasteurization.
Other international HPAI updates
3. In Australia, no further cases of HPAI have been detected since 24 June. As a result,
housing orders and movement controls are easing.
4. In Malaysia, ten human cases of H5N1 bird flu have been recorded so far this year,
four since July. One teenage female died. No evidence of human-to-human
transmission has been reported in association with any of these cases.
5. Europe is starting to see incursions as Autumn approaches. France and Poland both
had incursions mid- to late- August, after having none since January and February,
respectively.
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Priority – Low
Security Level – In Confidence
To: Hon Andrew Hoggard, Minister for Biosecurity
From: Stuart Anderson, Deputy Director-General Biosecurity New Zealand
Meeting with Minister Patterson and Rob Phil ips 11 September
2024
Date 10 September 2024
Reference
AM24-0825
Purpose
•
This aide-memoire supports your meeting with Hon Mark Patterson, Associate
Minister of Agriculture, and Rob Phil ips on 11 September 2024 at 3:15 pm to 3:45 pm.
•
Rob Phil ips wil likely be joined by Peter Scott and Ross Ivey.
•
The need for increased funding for the control of wilding trees wil be a key point of
discussion.
•
You wil be supported by Sherman Smith, Manager National Wilding Conifer Control
Programme and John Walsh, Director Pest management from Biosecurity
New Zealand.
•
Further background information can be found in:
o
AM24-0899
Progress and Milestones for the Wilding Conifer Programme on
funding progress on funding progress; and
o
AM24-0518
Funding options for the National Wilding Conifer Control Programme
Key issues to be raised:
1. Current funding for wilding conifer control is inadequate to maintain the gains made to
date. Continuing to defer control work results in compounding costs.
2. Unlike most established pests, there is a chance of successfully eliminating wilding
conifers if urgent action is taken.
3. Additional funding up front for the next three years then ongoing stable funding for the
next ten years is required to break the back of the problem.
4. Long-term solutions for ongoing funding, such as levying beneficiaries and
exacerbators through a National Pest Management Plan, should be considered.
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Appendix One: Biographies
Rob Phillips
- Recently named as the facilitator for the
Upper Clutha Wilding Tree Group.
- Co-Chair of New Zealand’s Biological
Heritage National Science Challenge.
- Has a long history working in sustainable
land and water management and
biodiversity.
- Has held senior leadership positions at
regional councils, most recently as Chief
Executive of Environment Southland
2012 to 2022.
- Was a member of the (now disbanded)
Biosecurity Ministerial Advisory
Committee from 2013 to 2018.
Peter Scott
- Chair of Environment Canterbury and
Council or for South
Canterbury/Ōtuhituhi.
- Member of the Canterbury Mayoral
Forum, the South Island Regional
Councils, and the Local Government
New Zealand Regional Sector Group.
- Previous leadership roles include Chief
Executive of Opuha Water, a director of
Horticulture New Zealand, and a director
of Irrigation New Zealand.
Ross Ivey
- Manager Glenntanner Station, a merino
farm at the head of Lake Pukaki
- Chairman of the Wilding Free Mackenzie
Trust
- You met with Ross when visiting the
Mackenzie on 10 July 2024.
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Appendix One
Priority – Low
Security Level – In Confidence
To: Hon Andrew Hoggard, Minister for Biosecurity
From: Stuart Anderson, Deputy Director-General Biosecurity New Zealand
Progress and Milestones for the Wilding Conifer Programme
Date 10 September 2024
Reference
AM24-0899
Purpose
•
This aide-memoire updates you on the progress and milestones for the Wilding
Conifer Programme (the Programme).
What progress can be made with the current funding
1. Ministry for Primary Industries (MPI) Baseline funding of $10 mil ion and expected
partner contributions of $2.8 mil ion for 2024 to 2025 wil see operational control in
nine regions across approximately 130,000 hectares.
2. The current approach is to carry out the highest priority maintenance work on as many
areas previously controlled as possible to protect the gains from investment to date.
3. At present, around $23.7 mil ion of due or overdue maintenance control work across
953,000 hectares (actual area of control wil be less) is being deferred as a result of
insufficient funding this year and last financial year.
4. Ongoing investment at current levels in the Programme wil result in the Programme
losing ground, and decisions wil need to be made about which large areas are left
that wil not receive follow-up treatments.
5. Work in the Godley management unit in the Mackenzie has been prioritised to enable
the second half of the management unit to be completed and transitioned back to
landowners.
What are the key milestones and/or where are the points where BNZ will assess
progress to determine how the Programme is tracking
Milestones reached:
6. Based on current infestation data and reporting on operations, BNZ knows that around
70 percent of the total known national infestation has been controlled at least once.
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7. At the end of each financial year, the Programme reviews the status of each
management unit and prioritises where control efforts should be focused for the
coming year based on urgency of control, strategic gains (for example, removing
particular seed sources) and using agreed spread risk criteria.
Ongoing monitoring and reporting of control delivered:
8. Councils provide financial and operational reporting to BNZ monthly. This data is
captured in the wilding conifer information system, a Geographic Information System
(GIS) based mapping and data entry platform.
9. BNZ tracks operations progress against the funding allocated and areas planned to be
controlled in the year, and this is reported to the Programme Governance Group
quarterly.
10. BNZ has developed a standardised national post-control audit protocol to assess
effectiveness of ground control operations with a continuous improvement focus. This
wil be rolled out this year.
11. Tracking of progress and any risks/issues are discussed at bimonthly meetings with
councils.
Ongoing monitoring of spread and infestations:
12. National infestation data was collated in 2016 and updated again in 2018, providing
baseline understanding of the location and density of infestations. Since then, a
significant amount of control has taken place, and an update is scheduled to be
carried out this financial year. This wil be informed in part by satellite-based deep
learning (AI) mapping of conifers carried out by the programme in 2022/23.
13. Updating our infestation data wil also inform the ongoing prioritisation of areas for
control.
Assessing progress:
14. The Programme undertakes two-yearly independent evaluations against key
programme indicators (effectiveness of control, alignment of policy and regulations,
social licence, partnership model, health and safety, and data and information). The
next evaluation wil be carried out this financial year, as it was deferred by a year to
better align with the end of the four-year Jobs for Nature funding allocation.
15. Cost Benefit Analyses were undertaken in 2018 and 2022 to assess the impact of
investment options against the status quo.
16. The latest Cost Benefit Analysis in 2022 provides forecasts of milestones that would
be achieved under specific funding scenarios.
17. While these forecasts are now out of date, BNZ does not intend to complete similar
analysis again at this time. Under current funding the focus is on maintaining the work
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done to date and this means the Programme is essentially seeking to mitigate decline,
rather than moving forward towards the outcomes of the strategy.
Options for conversations that the Minister can have to assist in scoping other
sources of funding
18. BNZ understands you have accepted an invitation from the Wilding Pine Network and
the South Marlborough Landscape Restoration Trust to view the Branch Leatham
infestation and attend a workshop with other stakeholders and leaders on future
funding solutions for wilding control on 9 October. This wil be an opportunity to
discuss business and philanthropy options with leaders/specialists.
s 9(2)(f)(iv)
21. A joined-up approach between all current partner agencies could see the collective
Programme funding increased and add weight to engagement with other potential
funders (such as power generators).
What more can be done with International Visitor Conservation and Tourism Level
(IVL) funding
22. Any IVL funding has the potential to significantly increase the amount of control that
can be done this year, and thereby reduce future costs from deferred control or
maintenance. The largely fixed cost of administering the coordinated national control
programme is already met within baseline funding.
23. In 2023 to 2024, $7.051 million of IVL funding for wilding conifer control operations
essentially doubled the operational control budget and enabled an additional
143,900 hectares of control to be carried out.
24. BNZ anticipates that areas of high priority deferred maintenance that protects public
conservation land and contributes to wider programme objectives would be the
primary focus for control by IVL funds, should they become available.
s 9(2)(g)(i)
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s 9(2)(g)(i)
Concise back pocket lines of what BNZ are doing right now in the programme and
some key deliverables planned in the short term
Suggested high level talking points
27. The National Wilding Conifer Control Programme has delivered substantial progress
on pushing back wilding infestations and is well-placed to achieve its outcomes,
subject to adequate consistent resourcing.
28. The Programme continues to provide good value through its collaborative model and
the skil ed industry that has been developed and strong participation from partners.
29. Beneficiaries from wilding control delivered to date include users for water for
hydroelectricity generation and irrigation, the tourism sector dependent on iconic
unique landscapes, and large landholders including managers of Crown-held land.
30. Alongside operations and the other workstreams, Biosecurity New Zealand (BNZ) is
working with partners on ways to further boost resourcing to complete more
maintenance control and remove seed sources.
31. There is a focus on continuous improvement of wilding management. Key work
streams continuing include supporting policy improvements around afforestation and
carbon credits; maintaining up to date data on infestations and spread; researching
ways to slow reinfestation and trials of new control technologies.
Current focus 2024 to 2025
32. The current operational focus for Crown funding through the National Wilding Conifer
Control Programme is on delivering the highest priority maintenance control, to protect
the land where the Programme has previously funded control.
33. In the 2024 to 2025 year, the Programme plans to deliver control operations in
394 operational areas.
34. As well as delivering effective wilding control operations, the Programme is improving
wilding management through policy, good practice, research, data management and
engagement work.
35. Other key work streams include supporting policy improvements around afforestation
and carbon credits, updating essential data on infestations, assessing where grazing
can slow reinfestation, and removal of legacy seed sources such as shelterbelts.
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Control progress in 2023 to 2024:
36. Last financial year (2023 to 2024) the Programme achieved removal of all coning trees
in another four management units (MUs), bringing the number of management units in
the maintenance stage to 21 (of 49 total MUs). In these areas substantial control
operations will not be needed again until scheduled maintenance in around three
years.
a) several MUs have partial areas that are sufficiently controlled that transition
planning can begin; and
b) 20 MUs stil have significant seed sources and there are areas where the
Programme is not yet active, where spread continues unchecked.
Minister / Minister’s Office
Seen / Referred
/ / 2024
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B24-0564
Summary of engagement activities
4. Engagement has been undertaken with a range of stakeholders. MPI has supported
engagements with primary industry stakeholders throughout the review. The next
stage is testing preliminary findings and options with the Sector Reference Group. MPI
wil work with MfR officials to further understand what the implications are for the
ACVM Act, and MPI, in particular.
5. To date, the review team have largely engaged with agencies separately. MPI sees
benefit in MfR engaging with agencies collectively to enable efficient sharing of
information and agencies’ views. We wil continue to work closely with MfR and our
colleagues at the Ministry for the Environment and Environmental Protection Authority
(EPA).
Issues analysis workstream
6. The MfR briefing notes the important distinction between issues raised by parties and
the work needed to verify claims raised during the engagement process. MPI supports
this view and will work with the review team to verify and address any issues without
sharing the specific details of the submitters.
7. A high-level issues summary is provided in Appendix A of the MfR briefing. MPI has
not yet provided detailed feedback on these issues. We are keen to understand if the
implications affect the ACVM and/or the Hazardous Substances and New Organisms
Act 1996 (the HSNO Act), so that we can target our advice effectively.
Economic analysis workstream
8. MPI agrees that the relative size of the New Zealand market is a factor in what
products are made available by manufacturers here. Other countries, such as
Australia and Canada, have similar experiences. With respect to managing risks
through other mechanisms, MPI is not aware of any non-regulatory initiatives that are
managing risks relevant to the ACVM Act.
9. Analysis in the economic workstream is set out in Appendix B of the MfR briefing. MPI
notes this is early analysis, and we are in the process of working with the review team
to provide primary industries data. We understand MfR wil seek a third-party to
conduct part of their economic analysis to inform the review, which wil likely be
conducted under a very short timeframe and at a high level.
Options analysis workstream
10. The review team has developed an initial set of criteria to analyse options (in
Appendix C to the MfR briefing). We consider these criteria are useful and wil help the
Regulatory Impact Analysis (RIA) stage.
11. MPI looks forward to providing feedback on potential options and wil keep you
advised as appropriate.
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Meeting with Horticulture New Zealand on
26 September 2024
Purpose
1. This note gives you information about your meeting with Horticulture New Zealand
(HortNZ) on 26 September 2024. Talking points for the meeting are in Appendix 1.
Context for meeting
2. You are meeting with HortNZ from 11am – 11.30am on Thursday 26 September.
Officials from the Ministry for the Environment and Ministry for Primary Industries will
also attend the meeting.
3. The proposed agenda is to discuss two topics:
a. a permitted activity for commercial vegetable growing (CVG)
b. enabling the supply of fresh fruit and vegetables as a matter of national
significance.
4. We will provide separate advice to Freshwater Ministers, prior to the meeting, that will
seek scope decisions on CVG and water storage. These topics will then be included in
the Cabinet paper seeking agreement to undertake targeted engagement on freshwater
proposals.
Key messages for meeting
5. We suggest that you use your meeting with HortNZ as an opportunity to:
a. express support for growers, noting that the Government wants New Zealanders
to be able to access fresh fruit and vegetables at a reasonable price
b. affirm the Government’s commitments to enable vegetable growing, particularly
in catchments that are not overallocated, and permit crop rotation
c. note the challenges with these objectives are primarily to do with resource
allocation
d. indicate that you are working through the policy issues.
6. The above key messages are reflected in the talking points in Appendix 1. There are
additional points on the Regional Infrastructure Fund if this topic comes up.
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Context on commercial vegetable growing
7. CVG is a relatively intensive land use. CVG activities risk discharges of sediment and
nutrients to the environment. Nitrogen discharges are the most significant risk for CVG,
because of high nitrogen fertiliser use and challenges in mitigating nitrogen losses.
8. CVG’s need for nitrogen discharge allocation is in tension with allocation to other
resource users, and the need to reduce nitrogen discharges to improve water quality.
9. CVG production needs to expand to meet demand from projected population growth.
New Zealand's population is forecast to grow 8 per cent between 2023 and 2033.
10. The relevant Government commitments are to:
a. amend the RMA to make it easier to consent new infrastructure including
renewable energy, allow farmers to farm, get more houses built, and enhance
primary sector including fish and aquaculture, forestry, pastoral, horticulture and
mining; and
b. remove the need for growers to obtain a resource consent to grow food or rotate
crops within a catchment.
11. Information as requested (by Hon Hoggard’s office) on three topics is set out below.
Summary of HortNZ correspondence on permitted activity for CVG
12. HortNZ wants CVG urgently made a permitted activity. In summary, its views1 are that:
a. permitted activity status would apply to existing CVG and expansion of CVG
b. an NES would need to prevail over regional council rules, for national
consistency
c. permitted activity status for CVG operations over 5 ha would be subject to
conditions managed through freshwater farm plans
d. the use of land and associated discharges for CVG would be a restricted
discretionary activity if the use did not comply with the permitted activity
conditions
e. requiring consents for CVG expansion in catchments with nitrogen attributes
below the bottom lines is unlikely to be effective, as significant reductions in
nitrogen losses could not be achieved without reducing vegetable production
1 HortNZ’s views are here summarised from a number of documents, including: Letter to Ministers
Simmonds, McClay, and Grigg on permitted activity status for commercial vegetable production, dated
19 March 2024; HortNZ submission on Targeted changes to the RMA, dated 5 April 2024; HortNZ
Position Paper on National Direction for Vegetables, dated July 2024.
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f. a more comprehensive alternative to an NES would be a National Policy
Statement for Horticulture, accompanied by a short-term RMA amendment to
make CVG a permitted activity while the replacement to the RMA is developed.
13.
9(2)(g)(i)
We
need to know more about the baseline for intensity, location, and adoption of good
management practices.
14. We will be providing further advice to Ministers McClay and Hoggard on potential
approaches to meet your objectives for CVG.
Update on Specified Vegetable Growing Area policy
15. The Specified Vegetable Growing Area (SVGA) policy was quashed in December 2023.
16. The SVGA policy attempted to address the tension between CVG and meeting
environmental outcomes in areas of intensive CVG within Pukekohe and Horowhenua. It
required regional councils to consider a trade-off between a national need (for domestic
supply of fresh vegetables) and a regional need (to achieve water quality outcomes).
17. The policy was effectively never implemented, because the relevant regional councils
(Auckland/Waikato for Pukekohe and Horizons for Horowhenua) are yet to notify
regional planning instruments that implement the NPS-FM.
18. Before the SVGA policy was quashed, clause 3.33 and the NPS-FM Appendix 5:
a. required regional councils to have regard to the importance of the contribution of
the SVGA to the domestic supply of fresh vegetables and maintaining food
security for New Zealanders; and
b. allowed councils to set a target attribute state below the national bottom line, if
the baseline state of specified nitrogen-related attributes was below the bottom
line and achieving the national bottom line would compromise the matters in (i)
above; and
c. required regional councils to not exempt vegetable growers from requirements
(eg, limits) aimed at achieving at target attribute states; and
d. expired 10 years after commencement (ie, 2030) or earlier if an NES came into
force that applied to the SVGA.
19. In 2022, Muaūpoko Tribal Authority Inc and Te Rūnanga o Raukawa Inc sought judicial
review of the policy. After the High Court dismissed the application for review, the
appellants appealed the decision to the Court of Appeal. The Court of Appeal held that
the Minister for the Environment had not undertaken sufficient engagement, given the
significance of Lake Horowhenua to iwi/Māori and the historical complacency of the
Crown in permitting degradation of the lake. On this basis, the Court of Appeal quashed
the policy from the NPS-FM in December 2023.
20. Although HortNZ supports a revised SVGA policy in the NPS-FM, it would prefer other
policy solutions that more directly enable the sector (eg, permitted activity status).
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Relevant context from regional councils/regional plans
21. Regional councils have been reporting to the Minister for the Environment on how they
provide for vegetable production through land and water plans. Key themes are:
a. councils seek more flexibility to provide for and expand vegetable production
b. some councils see merit in SVGA arrangements in their regions, and Tasman
District Council also seeks a similar provision for fruit growing.
22. Regions that produce a significant proportion of New Zealand’s CVG already have, or
are establishing, nitrogen discharge rules. In these regions it will be the most challenging
to develop an NES for CVG. Elsewhere the land use and discharges associated with
CVG are, for the most part, permitted activities – although regional councils may develop
more stringent rules to address water quality issues.
Canterbury
23. Rules for vegetable growing are operative and growers will have applied for resource
consent. Nitrogen discharges are allocated at a property scale, with progressive
reductions from the baseline loss rate over time. The plan allows CVG nitrogen
discharges to be calculated over a baseline 'area' for an entire operation, and enables
crop rotation within nitrogen management zones.
Horizons
24. Nitrogen discharges are allocated to land based on land use capability, and progressive
reductions from the baseline loss rate are required over time. Plan Change 2 intends to
provide for baseline nitrogen allocation to CVG operations using a baseline area, and
allow alternatives to Overseer for calculating nitrogen discharges.
Waikato
25. Plan Change 1 has been underway since 2012. It intends to provide a resource consent
pathway for existing CVG, and for limited CVG expansion in some sub-catchments.
Hawke's Bay
26. Plan Change 9 has been underway since 2012. It intends to permit existing CVG, but
require resource consent for expansion.
Environment Court decisions pending
27. Decisions on the Horizons, Waikato, and Hawke's Bay plan changes are expected in late
2024/early 2025.
Other matters that may come up in your discussion
Review of approval pathways for products used by growers
28. Following increasing concerns from the sector about the time it takes to process
applications, the Ministry for Regulation is reviewing regulatory regimes that provide
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approval pathways for products used by growers. The Ministry for the Environment is
also considering amendments to improve processing times for hazardous substances.
29. If a substance for use on farms is deemed hazardous, as are most pesticides and
related products, an approval is required under the Hazardous Substances and New
Organisms Act 1996 before that substance can be imported or manufactured.
Agricultural compounds also require registration under the Agricultural Compounds and
Veterinary Medicines Act 1997.
Next steps
30. We will shortly provide advice to Freshwater Ministers seeking agreement on options to
take to engagement on amending the NPS-FM and other freshwater national direction.
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Appendix 1: Talking points
Freshwater policy
• The Government wants New Zealanders to be able to access fresh fruit and vegetables
for a reasonable price. The Government is open to the idea of enabling the supply of
fresh fruit and vegetables as a matter of national significance. This will need to be
worked through during the ongoing programme of RMA system changes.
• The resource management system comes with some issues and chal enges. As you’ve
noted in correspondence, the main challenge for horticulture is the allocation of rights to
discharge nutrients.
• The Government is exploring ways to enable vegetable growing, particularly in
catchments that are not overallocated, and permit crop rotation. In doing this, it will be
important to make sure any effects don’t make the environment significantly worse off.
• We’re interested in your thoughts on how to make commercial vegetable growing a
permitted activity, including the potential role for freshwater farm plans (FW-FPs).
• Work is currently underway to improve the FW-FP system, with the intention to have any
changes finalised by mid-2025. Objectives of the review are to make the system more
cost-effective and practical and to recognise the good things that farmers and growers
are already doing.
• The scope of proposed changes to freshwater management is being considered, as part
of the national direction work programme. You will hear from us in the coming months
once we have approval from Cabinet to proceed. It is expected that new national
direction will in place by mid-2025.
Regional Infrastructure Fund
• The Regional Infrastructure Fund is a $1.2 billion capital investment fund that aims to
build infrastructure for growth and resilience in our regions.
• Because the RIF is primarily a capital fund, funding support will be provided through a
mix of loan and equity investments, and grants will only be available in very limited
cases.
• The RIF will look for investment and co-investment projects that support the priorities of
the regions themselves.
• RIF investment priorities include food production infrastructure and water storage
projects.
• I encourage businesses, iwi, council and community groups in our regions to take
advantage of the Regional Infrastructure Fund to build infrastructure for growth and
resilience in their regions.
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