Perceptions of MAF's regulatory impact on the grain and seed industry
3 Introduction
Project context
Purpose of outside-in reviews
An outside-in review collects information on how MAF's activities impact on external stakeholders and how the agency is experienced by both users of its services, and the general public. Essentially, these reviews aim to uncover stakeholders' perceptions of MAF and report on what stakeholders and service users think of the organisation's performance.
The demand for more user-focused design and delivery of government services is pushing government agencies in many developed countries to be more responsive to changes in customer demand and to involve customers in service design and delivery. The State Services Commission (SSC) has indicated that developing a greater understanding of New Zealanders' experience of state services is critical to enhancing their accessibility, responsiveness and effectiveness. Outside-in reviews are consistent with this focus on understanding New Zealanders' experiences of state services.
Reviewing the grain and seed industry
The grain and seed industry was selected for this review for a number of reasons.
First, it is an industry with great potential. New Zealand is a leader in producing for the world seed market and in the near future production is expected to increase steadily. Vegetable seed exports have been consistently visible in the growth export category in the arable industry for the past 10 years and now total $38 million (for the year ended 31 March 2007)1. Vegetable seed crops also provide very high export returns on a per-hectare basis.
The export seed industry is of particular interest to this review, but, due to crop rotation cycles and the impact that these have on growers' profits, it is difficult to examine seeds in isolation from grain production. For this reason, both grains and seeds were selected for the review, with a focus on the seed industry where practical.
A detailed profile of the grain and seed industry is included in Appendix 2.
Secondly, selecting the grain and seed industry for this review also offered the opportunity to identify challenges and barriers for this industry which may also be applicable to other primary sector industries in New Zealand. This is particularly the case with industries like the grain and seed industry that have high levels of innovation potential. For example, a considerable amount of research and development is currently going into developing ryegrasses containing novel endophytes.2
Finally, the grain and seed industry is also relatively small, well integrated under peak industry groups and geographically contained. This allowed the use of a case study approach and ensured reasonable coverage of different segments of the industry.
Interviewees
Interviewees ranged from owner-operator growers to employees of large grain and seed companies with operations spanning all aspects of grain and seed production. Company interviews were conducted with a range of individuals in senior roles, including owners, and individuals in operational administration roles. All interviewed grain and seed company employees were involved with importing and exporting seed to various degrees.
All interviewees were male and their experience in the industry ranged from 15-40 years. The majority of interviewees had a lengthy history in New Zealand, though a few of the grain and seed companies were affiliated or owned by large international seed companies.
Project objective
The objective of this outside-in review is to gather and analyse opinions on the quality of MAF-related compliance requirements and the impact of those requirements on the grain and seed industry. This review analyses how MAF is experienced by service users and provides a qualitative understanding of the impact of MAF's regulatory activities on the industry.
Research questions
The broad research questions for this review are:
- What is the form and scale of MAF-related compliance costs on the grain and seed industry, as viewed by stakeholders?
- What are the impacts and relative significance of the way that MAF implements, interprets and enforces these regulations, as viewed by stakeholders?
- What is the monetary value that MAF-related compliance costs take from the end product, as viewed by stakeholders?
- What is the perception of the grain and seed industry on MAF's performance of its regulatory activities?
- What is the perception of the grain and seed industry on the performance of MAF compared to other regulators?
- What does the grain and seed industry consider are the barriers to increasing seed exports?
- What does the grain and seed industry consider are the issues facing the export seed sector both currently and in the near future?
Perceptions
The opinions gathered through this review may differ to those held by MAF, and may, in some cases, be incorrect. However, it is acknowledged that these findings will provide MAF with a better understanding of how the Ministry, and the impacts of its regulations, are perceived by the industry. In this regard, it is also recognised that these findings are an opportunity to examine how and why these perceptions have come about and to consider what, if any, response is required.
Scope
Definition of the grain and seed industry
For the purpose of this review, only those grain and seed crops subject to the Commodity Levy Act (Arable Crops) are included. These crops are wheat, barley, oats, maize, pulses, herbage seeds, vegetable seeds, brassicas seeds and borage seeds. Other arable crops such as process vegetables have been excluded.
Definition of compliance requirements
Compliance requirements include the processes businesses must undertake to comply with MAF administered requirements under legislation, for example, the Commodity Levy Act and Biosecurity Act.
For the purpose of this review, the scope of compliance requirements includes those associated with: commodity levy orders; becoming or maintaining status as a MAF approved independent verification agency, recognised organisation, facility operator or recognised treatment supplier; and importing into New Zealand.
A detailed list of MAF's compliance requirements used in the interviews is provided in Appendix 3.
Definition of compliance costs
For the purpose of this review, the scope of compliance costs includes the costs associated with complying with those MAF administered requirements under legislation outlined in Definition of compliance requirements on the previous page.
Exclusions from scope
Excluded from the scope of this review are recommendations for regulatory amendments, specific proposals for business process changes at MAF and food safety-related issues.
Approach
Extent of engagement
This review spans the extent of the grain and seed industry's interactions with MAF. The interactions are extensive, ranging across all aspects of grain and seed production and marketing including import (regulatory, border security, storage and post entry quarantine), production (certification, phytosanitary, post inspection product security, seed quality management, arable monitoring and statistics), and export (international plant protection, plant market access, OECD representation, international seed testing).
Method
This review followed a case study approach with interactive interviewing used to collect information for analysis. Interactive interviewing was chosen as it diminishes the response burden on interviewees, and allows for a more in-depth discussion.
Most interviews were conducted at the interviewee's workplace. Interviewees were selected from the New Zealand Grain and Seed Trade Association's (NZGSTA) membership list, which the Association estimates covers 95 percent of the grain and seed industry, and from other known sources. Interviews were conducted by a MAF staff member and an external research contractor.
A total of 18 interviews were conducted. Four interviews were conducted in the North Island and 14 in the Canterbury region. Two interviews were conducted with grain and seed industry representative groups. North Island interviews took place in February 2008 and South Island interviews in April 2008.
Reliance on third-party information
The analysis and conclusions of this review are based entirely on opinions and perceptions of MAF as expressed by interviewees. The information collected from interviewees has not been audited or verified in any way. Information included in the findings report has however been supplemented with commentary from MAF staff and from a workshop held with the NZGSTA in June 2008.
1 Situation and Outlook for New Zealand Agriculture and Forestry - MAF August 2007 p45.
2 Endophytes are a naturally occurring fungus that lives within the plant and is only visible under a microscope. Endophytes affect animal health and performance and also protect plants from a range of insects and environmental conditions. Research and development seeks to utilise the beneficial elements of endophytes.
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