Funding Review of Live Animal and Germplasm Exports

In December 2006, Biosecurity New Zealand released a discussion paper entitled Funding Review of Live Animal and Germplasm Exports (No: 2006/05) and invited submissions on cost recovery proposals for export services under the Animal Products Act 1999.

The primary purpose of the proposals in the discussion paper was to redistribute fees so that they are more equitable and justifiable, and allocated more closely to those exporters benefiting from the work. The overall level of cost recovery from industry will be slightly higher than in previous years due to existing shortfalls in some areas.

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Contents

Biosecurity New Zealand Discussion Paper No: 2006/05
ISBN No: 0-478-29857-9
ISSN No: 1176-8398

December 2006

Disclaimer

Every effort has been made to ensure the information in this report is accurate.

The Ministry of Agriculture and Forestry (MAF) does not accept any responsibility or liability whatsoever for any error of fact, omission, interpretation or opinion that may be present, however it may have occurred.

The proposals in this paper are for consultation purposes and do not necessarily represent agreed Government policy.

Requests for further copies should be directed to:

Janet Greenwood
Policy Analyst
Policy Directorate
Biosecurity New Zealand
PO Box 2526
WELLINGTON

Email: janet.greenwood@maf.govt.nz
Telephone: 04 894 0425
Facsimile: 04 894 0730

© Crown Copyright – Biosecurity New Zealand

 

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Executive Summary

Biosecurity New Zealand’s Exports Group is responsible for the provision of official assurances to overseas governments. These assurances relate to the zoosanitary certification of all live animals and germplasm, and the phytosanitary certification of forestry, horticultural and arable plant products exported from New Zealand.

This paper presents proposals for the funding of services associated with the export of live animals and germplasm under the Animal Products Act (1999). Biosecurity New Zealand invites submissions on the proposals put forward. The closing date for submissions is Friday 9 February 2007. Any changes to cost recovery mechanisms and charges are intended to take effect from 1 July 2007.

The review takes into account the high-level principles for cost recovery from the Animal Products Act, the Biosecurity Funding Review, and Government guidelines. The review has found that:

  • some exporter groups are significantly subsidising the costs of other exporter groups;
  • there is some under recovery in a few areas; and
  • the current regime is overly complex.

Changes are proposed to:

  • remove the Biosecurity New Zealand export certificate fee;
  • rationalise the current export categories and revise unit fees to more accurately reflect the volume of work for each category;
  • increase the Biosecurity New Zealand hourly charge from $118.13 to $132 (including GST) to offset a minor deficit in revenue; and
  • increase the official assurance fee from $25 to $36 and the mileage rate from $0.54/km to $0.69/km (including GST) to offset a deficit in revenue for export verification activities provided by the New Zealand Food Safety Authority Verification Agency (NZFSA VA).

These changes will result in costs to be recovered from industry of $620,000 for Biosecurity New Zealand and $465,000 for NZFSA VA in 2007/08. This represents a small increase ($37,000) for Biosecurity New Zealand compared to revenue collected in 2005/06, and an increase of $66,500 for NZFSA VA to offset an existing deficit.

The key point of difference is in the funding of new market access work. Three options are presented:

  • Updated status quo (the costs of new market access work are funded by industry through unit fees);
  • New market access work is fully funded by the individual exporter requesting the work;
  • Half of new market access work is funded by the individual exporter requesting the work, with the other half funded by industry through unit fees.

Biosecurity New Zealand’s preferred option is the last one because it will signal the truer costs of market access work to applicants while recognising there is some industry benefit.

Biosecurity New Zealand has met with live animal and germplasm exporters at meetings in Hamilton, Palmerston North and Christchurch. The proposed options for future cost recovery have been developed as a result of these discussions. Biosecurity New Zealand is proposing to meet annually with exporters to assess the efficiency of the system and prioritise future market access work.

 

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1 Background

The purpose of this paper is to present for consideration proposals for the funding of services associated with the export of live animals and germplasm under the Animal Products Act 1999 (the Animal Products Act).

Biosecurity New Zealand invites submissions on the proposals put forward. The closing date for submissions is Friday 9 February 2007.

 

The paper has the following structure:

Section Two explains the role of the Exports Group of Biosecurity New Zealand, sets the context for this funding review, outlines its objectives, and highlights other related projects.

Section Three outlines the principles and methods of cost recovery guiding this review, including the legislative framework within which the Exports Group is operating.

Section Four describes the export services that are subject to the cost recovery proposals in this paper, and the outcomes to which they contribute. This section explains the principles used to determine the nature of the services and explores how these affect the decision around who should pay for them.

Section Five examines the limitations of the current charging mechanism and proposes changes in how the services could be funded.

Section Six outlines the actual and projected costs of providing these services. Proposed changes to existing fees and charges are introduced.

Section Seven presents options for new market access work and the future cost recovery of these services, including the rationale behind each option. Suggestions are made as to how best to give effect to the proposed option for cost recovery.

Section Eight gives guidance to submitters on the consultation process.

Accompanying attachments provide information about the definitions used in this paper, the schedule of existing fees and charges, and calculations and figures used throughout the review.

 

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2 Introduction

2.1 ROLE OF THE EXPORTS GROUP

Biosecurity New Zealand’s Exports Group is responsible for providing official assurances to overseas governments about certain products being exported. Biosecurity New Zealand certifies all live animals and germplasm, forestry, horticultural and arable plant products exported from New Zealand. For example, if the importing country requires an official assurance, the exporter of a horse pays for Biosecurity New Zealand to certify its health status and freedom from unwanted pests and diseases.

2.2 WHY DO THIS REVIEW NOW?

The export of live animals and germplasm is governed by the Animal Products Act, which requires that cost recovery mechanisms and charges be reviewed every three years. Biosecurity New Zealand intends for any changes to cost recovery mechanisms and charges to take effect from 1 July 2007.

2.3 OBJECTIVES OF REVIEW

This review is two-fold, and began with a retrospective analysis of the performance of cost recovery mechanisms and charges. Secondly, Biosecurity New Zealand is looking to clarify and, where possible, simplify cost recovery mechanisms and charges. This will give greater certainty to export industries and will allow the Exports Group to establish better reporting systems that can assist in future planning and reviews. The key objective is to have equitable, efficient, justifiable, and transparent charges for recovering the costs of export services.

2.4 OTHER RELEVANT PROJECTS

The New Zealand Food Safety Authority (NZFSA)1 is currently reviewing its cost recovery mechanisms and charges under the Animal Products Act. Biosecurity New Zealand is working with NZFSA to ensure that the two cost recovery reviews are aligned.

Included within the scope of this funding review are costs incurred by NZFSA’s Verification Agency (NZFSA VA) for live animal and germplasm exports. Both Biosecurity New Zealand and NZFSA use the same regulatory model to support their official assurance regimes, as both regimes are regulated under the Animal Products Act, although their responsibilities differ. This review does not address the content of their respective official assurance regimes.

2.5 CONSULTATION

The Animal Products Act requires Biosecurity New Zealand to consult with affected parties to develop cost recovery mechanisms that best meet the statutory requirements whilst taking into account the expectations and needs of stakeholders. A reference group drawn from Biosecurity New Zealand, NZFSA, and the recognised agencies for live animals and germplasm (Agriquality New Zealand and Gribbles) has assisted with this funding review.

Biosecurity New Zealand has met with live animal and germplasm exporters at meetings in Hamilton, Palmerston North and Christchurch. The proposed options for future cost recovery have been developed as a result of these discussions.

Following the release of this discussion paper, submissions will be analysed and a final cost recovery proposal will be presented to Government by May 2007, for intended implementation by 1 July 2007.

 

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3 Principles of Cost Recovery

The export of live animals and germplasm is regulated by the Animal Products Act, which defines the criteria that needs to be considered when determining the most appropriate method of cost recovery. Both Government guidelines and the Animal Products Act prescribe that the costs of export certification be fully cost-recovered where appropriate and in accordance with the principles outlined below.

In 2005, the Government also agreed that a set of principles from the ‘Future Funding of Biosecurity Services’ (the Biosecurity Funding Review) be adopted for the assessment of any future changes to the funding of biosecurity services. This review has been guided by these principles and methods of cost recovery, along with the high-level principles of cost recovery identified in the Treasury document Guidelines for Setting Charges in the Public Sector and the Audit Office document Guidelines on Costing and Charging for Public Sector Goods and Services.

3.1 PRINCIPLES OF COST RECOVERY UNDER THE ANIMAL PRODUCTS ACT

The Animal Products Act outlines the following principles for cost recovery that have guided this review:

  • Equity – funding for a particular service should be sourced from the users or beneficiaries of the service at a level commensurate with their use or benefit from the service.
  • Efficiency – costs should generally be allocated and recovered in order to ensure that maximum benefits are delivered at minimum cost.
  • Justifiability – costs should be collected only to meet the reasonable costs (including indirect costs) for the provision or exercise of the relevant function, power, or service.
  • Transparency – costs should be identified and allocated as closely as practicable in relation to tangible service provision for the recovery period in which the service is provided.

3.2 METHODS OF COST RECOVERY UNDER THE ANIMAL PRODUCTS ACT

Section 114 of the Animal Products Act provides wide and flexible options for the recovery of direct and indirect costs. The methods by which costs can be recovered relevant to this review are by way of:

  • fixed fees or charges, or those based on the time involved or a per unit basis;
  • recovery by way of a fee or charge of actual and reasonable costs for undertaking any particular service or function;
  • fees or charges imposed on users of services or third parties;
  • levies; or
  • any combination of the above.

3.3 TREASURY GUIDELINES

According to Treasury guidelines, services can be characterised as public, club or private goods. In practice, there is often no clear delineation between the three categories and a product or service can have elements of all three. The issue is more one of degree with the practical consideration of how costly it is to charge the user of a service. This review adopts the following definitions to help determine the most appropriate source of funding:

  • Public good – A good is considered public when excluding people from its benefits is either difficult or costly, and its use by one person does not detract from its use by another. In practice, pure public goods are very rare. However, many Government-provided services share the characteristics of public goods to some extent. There is a good case for recovering the costs of a public good from the community as a whole by general taxation.
  • Club good – In the case of a club good, people can be excluded from its benefits at low cost (unlike a public good), but its use by one person does not detract from its use by another. The key difference here is that the ability to exclude implies the feasibility of charging for use. Charging club members can be an efficient way of recovering costs.
  • Private good – In the case of a private good, people can be excluded from its benefits at low cost, and its use by one person conflicts with its use by another. There is a strong case for recovering the costs of a private good from those who benefit directly from it.

3.4 BIOSECURITY FUNDING REVIEW (2005)

In 2005, the Government endorsed the results of a major funding review that recommended changes to the ways in which export certification cost recovery is managed. The Biosecurity Funding Review found that funding arrangements must:

  • collect the level of funds required;
  • minimise the costs of compliance and administration;
  • help keep the costs of supply low;
  • be fair; and
  • be consistent with our international obligations.

The Biosecurity Funding Review also prescribed that those required to pay should be able to do at least one of the following:

  • change their behaviour to reduce the costs of the service or the risks that give rise to the need for it over time;
  • assess whether the true benefits of the service at its current levels outweigh its costs on an ongoing basis, and thereby influence its ongoing provision; and/or
  • influence whether the service at its current levels is being provided in the most cost effective manner.

If they are not able to do any of the above, then it follows that Crown funding may be desirable. Based on all of the above, the Biosecurity Funding Review prescribed the full cost recovery of all export certification and export documentation work, including an appropriate share of overhead costs.

 

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4 Services Provided and Proposed Source of Funding

This section details the eight key services that Biosecurity New Zealand’s Exports Group provides and the outcomes to which they contribute. The ability to identify the outcomes is crucial to gaining an understanding of who benefits from the services and who should pay.

4.1 MULTILATERAL STANDARD SETTING

New Zealand’s contribution to the development of multilateral standards is necessary to promote and deliver export products worldwide. The international fora with whom the Exports Group associates include OIE, the OECD, APEC, and the WTO.2

The main activities in this area include:

  • contributing to the development of international standards;
  • clarifying and interpreting multilateral standards and specifications; and
  • undertaking responsibilities required to meet international protocols, such as the Cartagena Protocol.

Given that these activities clearly have public good characteristics, the Biosecurity Funding Review found that the Crown should continue to fund multilateral standard setting.

4.2 POLICY AND TECHNICAL ADVICE

The input of policy and technical advice to export activities should take into account the best interests of New Zealanders as a whole. To maintain the independence of this advice, the Biosecurity Funding Review found that the following activities should continue to be funded by the Crown:

  • providing policy and technical advice to Government policy makers;
  • responding to Official Information Act requests; and
  • responding to parliamentary questions and Ombudsman enquiries.

4.3 EXPORT STANDARDS AND SYSTEMS

These activities provide the basis for trade by safeguarding the assurances required by foreign governments. The main activities in this area include:

  • developing and implementing operational standards and guidance for industry (such as the Biosecurity New Zealand Official Assurance Programme);
  • clarifying and interpreting export standards and specifications;
  • reviewing the effectiveness of standards and systems; and
  • managing incidents and responding to events.

There are a number of such standards that are applicable across the different export industries operating in the live animal and germplasm area. However, the benefits of many of these activities can be attributed to different export industries. Once a standard is developed for a product there are no means to prevent exporters benefiting from its existence, but if it only relates to part of the wider industry it is only of value to exporters of that product. Some form of industry funding therefore seems desirable.

4.4 MARKET ACCESS MAINTENANCE

Maintaining market access serves to promote and deliver export products worldwide and involves bilateral negotiations for access when the importing country’s requirements change.

The main activities in this area include:

  • negotiating technical market access conditions and specifications, where the Exports Group has been notified of a change by overseas authorities; and
  • maintaining access, as overseas market access requirements change over time.

Market access maintenance tends to be of direct benefit to a particular exporter or industry and its use by one exporter does not detract from its use by another. However, capability for the activity is of benefit to all exporters and it is not practical to charge each exporter for every piece of work undertaken. Consequently, some form of industry funding seems desirable.

4.4.1 Export of domestic cats and dogs to Australia3

MAF and the Department of Agriculture, Fisheries and Forestry – Australia (DAFF) have negotiated a regime for the trade of domestic cats and dogs between New Zealand and Australia. Rather than MAF authorised persons providing official assurances, MAF approves local veterinarians to issue export certificates. Maintaining this regime only benefits exporters of domestic cats and dogs to Australia, and so should ideally be funded by such exporters.

4.5 NEW MARKET ACCESS

Under section 60 of the Animal Products Act, any requirements of the importing country may be identified and notified to facilitate the export of live animals or germplasm. These requirements are known as overseas market access requirements. Once the requirements are notified, they can be used by any registered exporter to export that type of live animal or germplasm to that country.

The Exports Group incurs costs for developing new market access requirements arising from:

  • negotiating with overseas government authorities;
  • developing new protocols to export particular products to particular countries, at the request of an exporter;
  • notifying exporters of the new protocols; and
  • changing current protocols to facilitate trade, at the request of an exporter.

Determining who should pay for negotiating market access for a new entrant is problematic. There are clear issues around how equitable it is for the first entrant to an industry to bear the establishment costs of negotiating market access for the new product. It can be argued on the one hand that the costs only arise because the new entrant is seeking to export, but on the other hand there is a strong case for sharing the costs among exporters that enter the market later.

The Biosecurity Funding Review recommends that MAF should seek contributions from each industry to fund new market access work in return for involving them in what work is being done. If the work is driven by the needs of exporters, then they are well placed to make choices about the value of the work to them.

4.6 OFFICIAL ASSURANCES

Official assurances are the means by which the New Zealand Government assures a foreign government that the exported product complies with their import requirements. Official assurances are normally provided in the form of export certificates. The matters to be included in the certificate are specified by the importing country and differ between products.

The main activities in this area are carried out by NZFSA VA and include:

  • providing verification services (as recognised persons); and
  • issuing official assurances (as authorised persons).

Section 63 of the Animal Products Act provides that the Director-General need not issue an official assurance unless satisfied that it meets the requirements of the importing country. NZFSA VA provides verification services that include inspecting live animals and germplasm at the port and ensuring that the required vaccinations and treatments to allow their export have been administered, in accordance with the requirements of the importing country.

Exporters sending products to overseas countries with requirements for official certification seek the service of provision of official assurances. The costs of this are determined by the nature and volume of requests and also by the standards imposed by foreign governments. The Biosecurity Funding Review suggests that exporters are well-placed to decide whether they want any certification services, taking into account the costs and benefits they receive. They should therefore be funded by the individual exporter that directly benefits from the issuing of an official assurance.

4.7 NEGOTIATING EQUIVALENCES

Under the WTO Sanitary and Phytosanitary Agreement, sanitary and phytosanitary measures can be accepted as equivalent if the exporting country objectively demonstrates to the importing country that its measures achieve the same level of protection. The main activities in this area include negotiating requests for alternative measures to known overseas market access requirements.

As they are usually done at the request of an exporter and are usually specific to a particular export consignment, it would seem reasonable that negotiating equivalences to overseas market access requirements should be funded by the individual exporter.

4.8 RECOGNITIONS AND APPROVALS

The main activities in this area include:

  • recognising persons and agencies (e.g. Agriquality New Zealand and Gribbles) to conduct fieldwork that substantiates the statements required in official assurances;
  • revoking recognitions and approvals when necessary;
  • providing the administrative systems for recognitions and approvals;
  • reviewing the systems and applications; and
  • approving germplasm centres under the Biosecurity New Zealand Official Assurance Programme.

These activities are provided directly to the exporter or recognised agency and it would therefore seem reasonable that they fund the associated costs.

4.9 PROPOSED SOURCE OF FUNDING

Table 1 summarises the proposed funding source for each service that is adopted throughout the remainder of the paper.

Table 1: Summary of who appears most appropriate to pay for each service

  Crown funded Industry funded Individually funded
Multilateral standard setting √    
Policy and technical advice √    
Export standards and systems   √  
Market access maintenance   √  
New market access   √  
Official assurances     √
Negotiating equivalences     √
Recognitions and approvals     √

 

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5 Proposed Charging Mechanisms

This section explores the limitations of the current regime and presents the proposed charging mechanisms for each service. Proposed changes to the actual fees and charges are detailed in Sections 6 and 7.

5.1 CURRENT COST RECOVERY REGIME

Figure 1 illustrates the current model of funding for the services detailed in Section 4. The first two services, multilateral standards and policy and technical advice, are Crown funded and therefore not discussed in the remainder of this paper.

Figure 1: Model of current funding for services related to the export of live animals and germplasm

Model of current funding for services related to the export of live animals and germplasm

Exporters of live animals and germplasm currently pay -

To Biosecurity New Zealand:

  • an export certificate fee of $50.18; and
  • a unit fee (e.g. $12.35 per dog exported); and
  • an hourly charge for negotiating equivalences of $118.13.4

To NZFSA VA:

  • an official assurance fee of $25; and
  • an hourly charge of $96.10 for verification activities.

Currently, revenue recovered from Biosecurity New Zealand’s export certificate fees and unit fees is used to cover the costs of activities around export systems and standards, market access maintenance, and new market access. This can result in:

  • revenue raised from one group being used to subsidise the costs of other groups; and
  • new market access work being undertaken without strong justification.

Biosecurity New Zealand’s revenue and costs for each category of live animal and germplasm exports over the last two years is summarised in Appendix 2.

Under the current regime, exporters of cats and dogs are providing considerably more revenue than the cost of market access work for that sector. In 2005/06, Biosecurity New Zealand collected $207,000 in revenue for the export of cats and dogs, against costs of $79,000 for that sector. This is clearly not equitable or justifiable.

In contrast, Biosecurity New Zealand’s Exports Group is spending substantially more time on market access work for the semen and embryos sectors than is being funded by those exporters. For example, in 2005/06, Biosecurity New Zealand collected only $8,000 in revenue for the export of embryos, against costs of $55,000 for that sector.

5.2 PROPOSED CHARGING MECHANISMS

It is important that the charging mechanism is not overly complex, so as to avoid unnecessary administration costs. It would seem prudent, therefore, that the costs of recording auditable information should not outweigh the benefits of providing the service. It is proposed that charges should be structured using the existing combination of fixed annual charges, fixed fees, and hourly charges, but revised to more accurately reflect the current situation.

Table 2 summarises the proposed source of funding for each service, followed by a description of how this differs from the current regime. For example, where it is proposed that services are funded by industry, the costs would be recovered directly from exporters by way of a unit fee that relates to their category of export. The source of funding for new market access is subject to the options presented in Section 7.

Table 2: Summary of the proposed source of funding for each service

  Crown funded Industry funded Individually funded
Multilateral standard setting Crown funding    
Policy and technical advice Crown funding    
Export standards and systems   Unit fee  
Market access maintenance   Unit fee  
New market access   Unit fee and/or hourly charge (subject to the options in Section 7)
Official assurances     Hourly charge, unit fee, and official assurance fee
Negotiating equivalences     Hourly charge
Recognitions and approvals     Hourly charge

Export standards and systems / Market access maintenance - It is proposed that the costs of providing these services be funded by industry through unit fees that more accurately reflect the volume of work for each category of export.

New market access - Three options for this are provided in Section 7. Biosecurity New Zealand proposes that half of the actual work in developing new market access be funded by the individual exporter requesting the work through an hourly charge, and the remaining costs to be recovered from industry through revised unit fees.

Official assurances – Under the current system, individual exporters pay one hourly charge rate and three types of fixed fees for this service:

  • An hourly charge for verification activities provided by NZFSA VA. It is proposed to retain this charge at the current rate of $96.10.
  • An official assurance fee for services provided by NZFSA VA. It is proposed to retain this fee, although at an increased level as outlined in Section 6.2.
  • An export certificate fee for services provided by Biosecurity New Zealand. Charging export certificate fees for each animal in a small consignment can penalise the small exporter, and does not provide for the costs of services to be shared equitably or at a level commensurate with usage. It is proposed to remove this certificate fee.
  • A unit fee for services provided by Biosecurity New Zealand for live animal and germplasm exports. Changes in the volume and categories of exports over the last three years highlight the need to rationalise current categories. For example, there have been no exports of finches in the last three years, and so it is proposed to remove this category.

Table 3 shows the existing and proposed export categories. The minimum number of categories has been maintained to accommodate the scope and scale of the various live animal and germplasm exports. Where it is proposed that a category be removed (for example, other aviary birds), these costs will be recovered from unit fees in the “all other” category. The “all other” category is for all live animal and germplasm exports not included in the other established categories, and is designed to capture the costs of services to low volume exports across a wide range of species.

Table 3: Proposed changes to live animal and germplasm export categories

Current categories Proposed categories
Cats and dogs Cats and dogs (including semen)
Sheep for slaughter  
Other livestock and bloodstock Livestock (only bovine, caprine, cervine, ovine, and porcine)
  Bloodstock (only equine)
Semen Semen (only equine, bovine, caprine, cervine, and ovine)
Embryos and ova Embryos and ova (only equine, bovine, caprine, cervine, and ovine)
Day old chicks (including hatching eggs) Day old chicks and hatching eggs (only poultry and ducklings)
Finches  
  Ferrets
Other aviary birds  
Queen bees Queen bees, bumble bees, and packaged bees
Bees other than queen bees  
Zoo animals – large shipment  
Zoo animals – small shipment  
Other animals not specified above (including small mammals, ratites, and their eggs) All other

Negotiating equivalences - The costs of negotiating equivalences are direct and vary on a time basis. It is proposed that negotiating equivalences should continue to be recovered by an hourly charge for actual services provided to the individual exporter. It is proposed to retain this charge, although at an increased level as outlined in Section 6.1.

Recognitions and approvals - It is proposed that the costs of providing these services to the individual exporter or agency continue to be funded through an hourly charge at an increased level as outlined in Section 6.1.

 

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6 Cost of Providing Services

This section details the costs of the services that Biosecurity New Zealand and NZFSA VA provide for the export of live animals and germplasm. Proposed changes to existing fees and charges are introduced. All revenue and costs throughout this paper include GST.

Biosecurity New Zealand is unaware of any major changes to the live animal and germplasm export industry. Therefore, the assumption is made that the volume of exports is likely to remain stable over the next three years and the projected budgets for 2007/08 are expected to remain the same as for 2006/07.

6.1 TOTAL ANNUAL COST AND PROJECTED OPERATING BUDGET – BIOSECURITY NEW ZEALAND

The total annual cost of services that Biosecurity New Zealand provides for the export of live animals and germplasm is budgeted at $619,000 for 2006/07. The Exports Group received additional Crown funding for multilateral standard setting and providing policy and technical advice of $47,000 in 2006/07.

Table 4 shows the total actual and projected costs of providing these services. These include the indirect costs associated with management, support services, and overhead costs that include travel, equipment, accommodation and communications. The Exports Group does not currently have a mechanism to separate the costs of activities related to export standards and systems, market access maintenance, and new market access.

Table 4: Operating and projected budgets for services provided by Biosecurity New Zealand for the export of live animals and germplasm

Service Actual costs
2005/06		 Actual budget
2006/07		 Projected budget
2007/08
Export standards and systems;
Market access maintenance;
and New market access		 $577,883 $608,706 $599,319
Negotiating equivalences $8,505 $8,505 $8,505
Recognitions and approvals5 $2,080 $2,080 $11,467
Total $588,468 $619,291 $619,291
 
Export billable hours6 4,032 4,704 4,704
Hourly rate required $146 $132 $132

Biosecurity New Zealand export services are currently being provided at a rate which results in a deficit of $16,000. It is proposed that the hourly charge for negotiating equivalences should be increased from $118.13 to $132. This hourly charge would also be used as the rate for charging for some or all of the costs of new market access, depending on the options outlined in Section 7.The overall cost of the proposed changes to the live animal and germplasm industry is shown in Appendix 4. The proposed changes would result in a small overall increase in Biosecurity New Zealand costs to industry of $37,000, although these costs would be redistributed to align more closely with the actual costs of export services to each category.

6.2 TOTAL ANNUAL COST AND PROJECTED OPERATING BUDGET – NZFSA VA

The total annual cost of official assurance services that NZFSA VA provides for the export of live animals and germplasm is budgeted at $465,000 for 2006/07. Table 5 shows the total actual and projected costs of providing these services.Table 5: Operating and projected budgets for official assurance services provided by NZFSA VA for the export of live animals and germplasm 7

  Actual costs
2005/06		 Actual budget
2006/07		 Projected budget
2007/08
Total $569,3898 $464,672 $464,672
Official assurance fee @ $25 = $147,100 @ $25 = $145,050 @ $36 = $208,800
AWEC fee @ $24 = $141,144 @ $24 = $138,312 @ $24 = $138,312
Mileage @ 54c/km = $9,028 @ 54c/km = $9,028 @ 69c/km = $11,813
Subtotal $297,272 $292,390 $358,925
       
Balance $272,117 $172,282 $105,747
Export billable hours 1,086 1,100 1,100
Hourly rate required $250.57 $156.62 $96.13

The hourly rate for import verification activities is currently $96.10. For consistency, and in recognising that there are exporters who are often involved in both exports and imports, it is proposed to leave the hourly rate for the verification of live animal and germplasm exports at $96.10. It is proposed to recover the shortfall through an increase in the official assurance fee from $25 to $36, and an increase in mileage from $0.54/km to $0.69/km.

NZFSA VA export services are currently being provided at a rate which results in a deficit of $66,500. The proposed changes in costs for NZFSA VA services would result in an overall increase in costs to industry for this amount only.

 

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7 Options for New Market Access Work

Three options for recovering the costs of services related to new market access work covering the export of live animals and germplasm are outlined below. 9 The rationale behind each option is explored, and the proposed option is analysed in terms of equity, efficiency, justifiability, and transparency. These options are in addition to the proposed changes to fees and charges outlined in Sections 5.2, 6.1 and 6.2. All fees and charges include GST.

The three options are:

  • Updated status quo (the costs of new market access work are funded by industry through unit fees);
  • New market access work is fully funded by the individual exporter requesting the work;
  • Half of new market access work is funded by the individual exporter requesting the work, with the other half funded by industry through unit fees.

These options are not proposed to apply to the unit fee for cats and dogs, which is proposed to be $25 (including GST). This would cover the cost of export standards and systems, market access maintenance, and new market access. Separating this category from the options applicable to other categories is more equitable, as it reduces the risk of cat and dog exporters continuing to pay for the development of new market access for other industries.

7.1 PROPOSED OPTIONS

Table 6 shows the proposed unit fees for each option. Calculations for determining the unit fees are provided in Appendix 5.

Table 6: Proposed unit fees under each option

Proposed category Option 1
Updatedstatus quo
Unit fee required		 Option 2
New market access fully funded by exporter
Unit fee required		 Option 3
Half of new market access funded by exporter
Unit fee required
Cats and dogs (including semen) / animal or straw $25.00 $25.00 $25.00
Livestock (only bovine, caprine, cervine, ovine, and porcine) / animal $3.50 $1.75 $2.60
Cattle (per additional animal) over and above a consignment size of 4,000 animals per exporter $1.00 $1.00 $1.00
Sheep (per additional animal) over and above a consignment size of 5,000 animals per exporter $1.00 $1.00 $1.00
Bloodstock (only equine) / animal $6.85 $3.45 $5.15
Semen (only equine, bovine, caprine, cervine, and ovine) / straw $0.17 $0.08 $0.13
Embryos and ova (only equine, bovine, caprine, cervine, and ovine) / embryo or straw $10.20 $5.10 $7.60
Day old chicks and hatching eggs (only poultry and ducklings) / chick or egg $0.0025 $0.0013 $0.0019
Ferrets / animal $4.15 $2.10 $3.10
Queen bees and bumble bees / unit and package bees / per kilogram $1.50 $0.75 $1.10
All other / unit $24.65 $4.95 $4.95

For each option, it is proposed that a reduced unit fee be introduced for export consignments of over 4,000 cattle and 5,000 sheep. This recognises economies of scale and minimises the chance of excess revenue being recovered from very large consignments.

7.2 OPTION ONE – UPDATED STATUS QUO

Under this option, the cost of developing new market access would be funded by industry through the revised unit fees shown in Table 6. The current system is simple to administer and easy to enforce. However, revenue recovered from different export categories may subsidise other export categories, depending on actual export volumes.

7.3 OPTION TWO – NEW MARKET ACCESS WORK FULLY FUNDED BY THE INDIVIDUAL EXPORTER

Under this option all new market access work (excluding that for cats and dogs) would be fully funded by the individual exporter requesting the new protocol. The costs would be recovered directly through the proposed hourly charge of $132.

This option is the furthest removed from the current situation. It has the advantage that the requesting exporter pays for the service that they directly benefit from, which encourages them to request work that will result in valued and meaningful exports. This is efficient because it potentially avoids protocols being requested in areas of export where there is not a strong likelihood for a market to be established.

However, this option brings with it a high degree of uncertainty. It is difficult for the Exports Group to forecast the costs of new market access work. This could create a disincentive for exporters to seek new protocols as the costs could be more substantial and ongoing than initially predicted. It also has the disadvantage that only the first (requesting) exporter pays and the other exporters can all potentially use that export certificate. There would be a minor increase in administration costs.

7.4 OPTION THREE – HALF OF NEW MARKET ACCESS WORK FUNDED BY THE INDIVIDUAL EXPORTER

Under this option half the cost of new market access work (excluding that for cats and dogs) would be funded by the individual exporter requesting the new protocol. This would be recovered directly from individual exporters at an hourly charge of $66 (which is half the total proposed hourly charge of $132). The remaining portion of new access work to be funded by the relevant industry group is included in the revised unit fees shown in Table 6.

This option seems more efficient than the status quo in that it helps to discourage speculative requests for new market access that are unlikely to result in any exports. There is currently no mechanism or incentive for this to occur. While exporters would incur some of the direct costs for developing new protocols, it is potentially more equitable because all exporters of that commodity would share part of the costs of developing a new protocol, compared to only the requesting exporter in option two. As in option two, there would be increased administration costs under this option due to the higher use of invoicing.

This seems the most equitable and justifiable option, without being overly complex or inefficient. As it aims to be more cost efficient and customer driven, this is the preferred option by Biosecurity New Zealand. It recognises the value of New Zealand exports, and gives exporters the opportunity to change their behaviour to reduce the costs of the services or the risks that give rise to the need for it over time.

7.5 HOW BEST TO GIVE EFFECT TO THE PROPOSAL

The Animal Products Act provides that where costs are to be recovered, the cost recovery should be empowered through regulations, giving greater transparency and certainty to all stakeholders. It is intended that the proposed changes in this discussion paper be combined with those from the NZFSA review, and result in fully revised regulations which would be entitled the Animal Products (Fees, Charges, and Levies) Regulations 2007.

The Biosecurity Funding Review suggests that exporters requesting new market access arrangements are well placed to make choices about the value of the work to them. It further recommends that if cost recovery is sought from a particular group of exporters, they should in return be involved in determining the priorities for this work.

It is proposed that the Exports Group will meet with exporters of live animals and germplasm on an annual basis. This would provide exporters the opportunity to work with Biosecurity New Zealand’s Exports Group in prioritising future work for the services that they fund, either individually or as an industry.

7.6 BUSINESS COMPLIANCE COSTS

Biosecurity New Zealand does not anticipate any marked change in compliance costs for exporters of live animals and germplasm. The services subject to this review are already being cost recovered using a similar charging mechanism to that proposed, with the key difference being a redistribution of the fees across industry groups.

 

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8 Notes for submitters

We welcome submissions from all interested parties on any aspect of the proposed cost recovery charges and mechanisms presented in this document.

Submissions are public information and may be the subject of requests under the Official Information Act 1982. If you consider that any or all of the information in your submission should be treated as confidential or commercially sensitive, please state this clearly in your submission. Any decision to withhold information under the Official Information Act may be reviewed by the Ombudsman.

8.1 KEY ISSUES BIOSECURITY NEW ZEALAND SEEKS COMMENT ON

The key issues that Biosecurity New Zealand seeks comment on are:

  • What are your views on the proposed removal of the Biosecurity New Zealand export certificate fee?
  • What are your views on new market access work being partially or fully funded by the individual exporter requesting the work?
  • What are your thoughts on the proposed export categories?
  • What do you think would be an effective way for exporters to work with Biosecurity New Zealand in prioritising the services that are funded by the proposed unit fees?
  • Any other issues you may like to comment on.

8.2 REQUIREMENTS FOR SUBMISSIONS

Submitters are asked to include the following information in their submissions:

  • the title of this discussion document;
  • your name and title;
  • your organisation’s name (if applicable);
  • your address and contact details (e.g. phone, fax and email); and
  • the number(s) of the sections you are commenting on.

8.3 CLOSING DATE FOR SUBMISSIONS

All submissions must be received by Biosecurity New Zealand no later than 5pm on Friday 9 February 2007. Please address submissions to:

Janet Greenwood
Policy Analyst
Policy Directorate
Biosecurity New Zealand
PO Box 2526
WELLINGTON

Email: janet.greenwood@maf.govt.nz
Facsimile: 04 894 0730

8.4 PROCESS FOLLOWING RECEIPT OF SUBMISSIONS

The next stage in the review will be to analyse all submissions and prepare a final cost recovery proposal to submit to Government. A document summarising the submissions will be made public and distributed to each submitter. It is intended that new regulations will be developed in conjunction with NZFSA’s proposed changes under the Animal Products Act for implementation by 1 July 2007.

 

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Appendix 1: Definitions

Approvals – Confirmation by the regulator that the person or agency satisfactorily meets the legal requirements. It does not cover requirements for export approvals (these are ‘official assurances’) or any matters concerned with the appointment of statutory powers or delegations.

Authorised person – A person employed by MAF, and authorised pursuant to section 65 of the Animal Products Act, to issue official assurances. Authorised persons may also be recognised where they are required to undertake pre-export preparation of live animals and germplasm.

Biosecurity New Zealand – The department of the Ministry of Agriculture and Forestry (MAF) that fulfils the role as lead agency in New Zealand’s biosecurity system.

Certification – Procedure by which official written or equivalent assurance is given that live animal or germplasm exports conform to requirements.

Direct cost – The portion of cost that is directly expended in providing a good or service. The cost can be traced to a given output in an economically feasible manner.

Equivalence – Equivalence to an importing country’s requirement may be requested where it can be shown on technical grounds that the requirement can be met by alternative means.

Export certificate – A certificate setting out the conditions agreed by New Zealand and the importing country to be met when exporting live animals or germplasm. Once the certificate is completed, signed and stamped by an authorised person, it becomes an official assurance.

Exports Group – The group within MAF Biosecurity New Zealand responsible for the development and negotiation of export certification procedures for live animals and germplasm, plants, and forestry.

Fee – A charge to an individual for a particular good or service.

Germplasm – Includes semen, embryos, ova, eggs, and broodcomb of bees.

Indirect cost – the portion of cost that is indirectly expended in providing a good or service. The cost cannot be traced to a given output in an economically feasible manner. Indirect costs can also be referred to as ‘overheads’.

Live animals – Any member of the animal kingdom. This includes any mammal, bird, finfish, shellfish, reptile, amphibian, insect, or invertebrate, but does not include human beings.

MAF – New Zealand Ministry of Agriculture and Forestry.

MAF Biosecurity New Zealand website – http://www.biosecurity.govt.nz (offsite link to www.biosecurity.govt.nz)

Official assurances – Certificates signed by the New Zealand Government for the purpose of assuring a foreign government about the product being exported. In the context of live animal and germplasm exports these include, but are not limited to, statements regarding New Zealand’s animal health status and the residency, isolation, health, testing, treatment and inspection status of the exported commodity. The form of an official assurance is usually an export certificate.

Official Veterinarian – This is the terminology that appears on many export certificates and is used by the OIE for a veterinarian authorised to perform animal health inspections. Veterinarians authorised or accredited under the Animal Products Act can be called ‘official veterinarians’. However, only authorised persons may issue official assurances.

Recognised person – A person recognised by MAF, pursuant to Section 103 of the Animal Products Act, to undertake the verification or other specialised function or activity of live animals and germplasm (prior to 2005, these were defined as ‘accredited persons’).

Standard – A regulatory requirement, generally of a technical nature.

Verification – The application of methods, procedures, tests and other checks by recognised persons to confirm that the product for export complies with regulatory requirements and statements on the official assurance.

 

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Appendix 2: Revenue and costs by export category

The following table shows the revenue that Biosecurity New Zealand collected from unit fees and export certificate fees over the last two financial years. Biosecurity New Zealand’s costs for each export category are shown for the same period. These costs were derived from the actual time (including overheads) spent on export standards and systems, maintaining market access, and developing new market access requirements.

  2004-2005 2005-2006
Category Revenue collected Biosecurity New Zealand cost Revenue collected Biosecurity New Zealand cost
Cats and dogs $194,624 $116,594 $206,996 $79,307
Livestock $228,829 $142,841 $206,962 $234,951
Semen $81,409 $124,403 $72,451 $109,876
Embryos $10,601 $54,711 $8,204 $54,915
Day old chicks $40,705 $17,143 $41,474 $27,358
Other aviary birds $1,400 $12,492 $508 $11,589
Queen bees, kg of other bees $11,001 $44,042 $10,569 $29,117
Zoo animals $6,259 $5,334 $164 $3,902
Other $14,102 $33,875 $14,389 $26,869
Total $588,930 $551,435 $561,717 $577,884

 

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Appendix 3: Existing fees and charges

The following table summarises the existing fees and charges relevant to this funding review. The existing fees and charges are set in the Animal Products (Fees, Charges, and Levies) Regulations 2002. These can be found on the following website: www.biosecurity.govt.nz/commercial-exports/animal-exports/fees (offsite link to www.biosecurity.govt.nz)

Fee or charge Fees/charges (including GST)
Hourly rate for MAF Accredited Vets (per hour)
- For each 15 min block in final part-hour		 96.10
24.05
Where MAF employee or officer is required to travel (per km) 0.54
Issue of an official assurance under section 63 of the Act 25.00
Reissue of an official assurance under section 64(2) of the Act, if replacement assurance demanded by importing country (maximum fee) 1,000
Hourly rate for equivalence/dispensation work
- For each 15 min block in final part-hour		 118.13
29.55
Fixed fee per export certificate 50.18
Unit fee for cats/dogs 12.35
Unit fee for sheep for slaughter 0.05
Unit fee for other livestock and bloodstock 3.85
Unit fee for semen (per straw) 0.10
Unit fee for embryos (per embryo) 1.43
Unit fee for day old chicks (including hatching eggs) 0.002
Unit fee for finches 0.21
Unit fee for other aviary birds 1.04
Unit fee for queen bees (per queen bee) 0.43
Bees other than queen bees (per kg) 0.43
Large shipment fee for zoo animals (total weight 150kg or more) 798.75
Small shipment fee for zoo animals (total weight under 150kg) 270.00
Unit fee for other animals (incl. small mammals, ratites and their eggs) 2.80

 

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Appendix 4: Comparison of current and proposed costs to industry

The following table compares the current costs of Biosecurity New Zealand export services to industry to the proposed costs to industry. Due to only having incomplete information for 2006/07, the current costs of export services are based on the actual figures from 2005/06.

Category Cost to industry 2005/06 Cost to industry 2007/08
Cats and dogs (including semen) / unit $206,996 $103,963
Livestock (only bovine, caprine, cervine, ovine, and porcine) / unit $206,962  $180,402
Bloodstock (equine) / unit $20,911
Semen (only equine, bovine, caprine, cervine, and ovine) $72,451 $123,988
Embryos and ova (only equine, bovine, caprine, cervine, and ovine) $8,204 $58,005
Day old chicks and hatching eggs / unit $41,474 $23,531
Other aviary birds $508 $0
Ferrets / unit $0 $13,279
Queen bees and bumble bees) / unit and packaged bees / kg $10,569 $38,734
Zoo animals $164 $0
Other $14,389 $36,506
Total $561,717 $599,319

Note: It is proposed to create a new category for “ferrets” in 2007/08. The costs for this category of exports in 2005/06 are captured in the “other” category for that year.

 

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Appendix 5: Calculations for cost recovery options

Export Billable HoursThe following table illustrates the method used to calculate Biosecurity New Zealand’s export billable hours.

  2005/06 2006/07 2007/08
Number of hours per person 1792 1792 1792
Number of staff 3 3.5 3.5
Total hours 5376 6272 6272
Less overhead time 1344 1568 1568
Total 4032 4704 4704

Contract staff were used to fill a permanent staff vacancy in 2005/06 and are not included in the calculation of hours for that year. The staff vacancy was filled in 2005/06 and the small budget increase for 2006/07 reflects that.

Options Methodology

The unit fee calculations for the three options are presented in the tables below. The number of live animal and germplasm exports was calculated for the revised categories for 2005/06. These numbers were then used to calculate the projected costs for 2007/08.

The total projected costs for 2007/08 were based on the average actual time spent (including overheads) on export standards and systems, market access maintenance, and new market access for the years 2004-2006.

The projected cost for these three services was set at $103,963 for cats and dogs. The balance of the total costs for 2007/08 to be recovered from the remaining export categories ($495,356) was pro-rated across the categories, according to the estimated time spent on each category.

The mechanism used by Biosecurity New Zealand for capturing time spent on various activities does not currently allow the Exports Group to calculate exactly how much time is spent on developing new market access. According to best estimates, however, the time spent by the Exports Group in developing new market access is estimated to be 50 percent of the total time spent on market access services. The remaining 50 percent is spent on export standards and systems and market access maintenance.

The category “all other” is characterised by a higher ratio of new market access work to export standards and systems and market access maintenance. This split is estimated to be 80:20 and has been taken into account when developing Options Two and Three.

The unit fees for each option were calculated by dividing the total costs to be recovered in each category by the projected number of live animal and germplasm exports for 2007/08. For simplicity Swedish rounding was used, where appropriate, to generate the final unit fee options presented in Table 5.

In order to ensure that over recovery does not occur for very large consignments of livestock, a reduced fee of $1 was introduced for each animal over and above a consignment size of 4,000 for cattle and 5,000 for sheep. This was calculated by modelling the actual consignment sizes for 2004/05 and 2005/06 against the proposed unit fees.

Option 1          
Proposed Category Costs estimated 2007/8 Export standards and systems, market access maintenance and new market access

(via unit fee)		 New market access

(via hourly rate)		 Number of exports Unit fee required
Cats and dogs (including semen) / animal or straw $103,963 $103,963 $0 4,173 $24.91
           
Livestock (only bovine, caprine, cervine, ovine, and porcine) / animal $180,402 $180,402 $0 51,806 $3.48
Cattle (per additional animal) over and above a consignment size of 4,000 animals per exporter         $1.00
Sheep (per additional animal) over and above a consignment size of 5,000 animals per exporter         $1.00
Bloodstock (only equine) / animal $20,911 $20,911 $0 3,051 $6.85
Semen (only equine, bovine, caprine, cervine, and ovine) / straw $123,988 $123,988 $0 738,322 $0.17
Embryos and ova (only equine, bovine, caprine, cervine, and ovine) / embryo or straw $58,005 $58,005 $0 5,676 $10.22
Day old chicks and hatching eggs (only poultry and ducklings) / chick or egg $23,531 $23,531 $0 9,350,000 $0.0025
Ferrets / animal $13,279 $13,279 $0 3,202 $4.15
Queen bees and bumble bees / unit and packaged bees / kg $38,734 $38,734 $0 25,875 $1.50
All other / unit $36,506 $36,506 $0 1,482 $24.63
Sub total excluding cats and dogs $495,356 $495,356 $0    
Total $599,319 $599,319 $0 10,183,587  

 

Option 2          
Proposed Category Costs estimated 2007/8 Export standards and systems, market access maintenance and new market access

(via unit fee)		 New market access

(via hourly rate)		 Number of exports Unit fee required
Cats and dogs (including semen) / animal or straw $103,963 $103,963 $0 4,173 $24.91
           
Livestock (only bovine, caprine, cervine, ovine, and porcine) / animal $180,402 $90,201 $90,201 51,806 $1.74
Cattle (per additional animal) over and above a consignment size of 4,000 animals per exporter         $1.00
Sheep (per additional animal) over and above a consignment size of 5,000 animals per exporter         $1.00
Bloodstock (only equine) / animal $20,911 $10,455 $10,455 3,051 $3.43
Semen (only equine, bovine, caprine, cervine, and ovine) / straw $123,988 $61,994 $61,994 738,322 $0.08
Embryos and ova (only equine, bovine, caprine, cervine, and ovine) / embryo or straw $58,005 $29,003 $29,003 5,676 $5.11
Day old chicks and hatching eggs (only poultry and ducklings) / chick or egg $23,531 $11,766 $11,766 9,350,000 $0.0013
Ferrets / animal $13,279 $6,640 $6,640 3,202 $2.07
Queen bees and bumble bees / unit and packaged bees / kg $38,734 $19,367 $19,367 25,875 $0.75
All other / unit $36,506 $7,301 $29,205 1,482 $4.93
Sub total excluding cats and dogs $495,356 $236,726 $258,630    
Total $599,319 $340,689 $258,630 10,183,587  

 

Option 3          
Proposed Category Costs estimated 2007/8 Export standards and systems, market access maintenance and new market access (via unit fee) New market access (via hourly rate) Number of exports Unit fee required
Cats and dogs (including semen) / animal or straw $103,963 $103,963 $0 4,173 $24.91
           
Livestock (only bovine, caprine, cervine, ovine, and porcine) / animal $180,402 $135,301 $45,101 51,806 $2.61
Cattle (per additional animal) over and above a consignment size of 4,000 animals per exporter         $1.00
Sheep (per additional animal) over and above a consignment size of 5,000 animals per exporter         $1.00
Bloodstock (only equine) / animal $20,911 $15,683 $5,228 3,051 $5.14
Semen (only equine, bovine, caprine, cervine, and ovine) / straw $123,988 $92,991 $30,997 738,322 $0.13
Embryos and ova (only equine, bovine, caprine, cervine, and ovine) / embryo or straw $58,005 $43,504 $14,501 5,676 $7.66
Day old chicks and hatching eggs (only poultry and ducklings) / chick or egg $23,531 $17,648 $5,883 9,350,000 $0.0019
Ferrets / animal $13,279 $9,959 $3,320 3,202 $3.11
Queen bees and bumble bees / unit and packaged bees / kg $38,734 $29,050 $9,684 25,875 $1.12
All other / unit $36,506 $7,301 $29,205 1,482 $4.93
Sub total excluding cats and dogs $495,356 $351,437 $143,919    
Total $599,319 $455,400 $143,919 10,183,587  

 

1 Biosecurity New Zealand and NZFSA are both part of the Ministry of Agriculture and Forestry (MAF).

2 OIE = Office International des Epizooties; OECD = Organisation for Economic Co-operation and Development; APEC = Asia Pacific Economic Cooperation; WTO = World Trade Organisation.

3 Note that assistance dogs (e.g. guide dogs) are exempt from all charges under current regulations.

4 Existing fees and charges are outlined in Appendix 3.

5 The increase in budgeted costs for recognitions and approvals for 2007/08 takes into account revenue for approving germplasm centres, which has not historically been recovered.

6 Calculations for the Export Group’s billable hours are included in Appendix 5.

7 NZFSA VA issues an animal welfare export certificate (AWEC) for a fee of $24. This is outside the scope of this review as it does not fall under the Animal Products Act.

8 Costs were uncharacteristically higher in 2005/06 due to building and renovation expenses.

9 Where new market access work is to be funded either partially or in full by individual exporters, Biosecurity New Zealand cannot hold any information related to this work confidentially.

Page last updated: 2 July 2010