Cucumbers

Summary of submissions and consultation process

  • In response to the December 2009 consultation document, one submission was received regarding production of cucumbers. That submission was from Horticulture New Zealand (Hort NZ), the industry body representing New Zealand cucumber growers, and was submitted on behalf of growers.  Officials understand that all commercial cucumber-growers in New Zealand are members of Hort NZ.
  • Because of the comprehensive coverage of Hort NZ, and because officials understood it to be the preference of the industry, consultation on the draft activity definition for production of cucumbers was conducted through Hort NZ. Officials provided the draft definition to Hort NZ on 15 March 2010. Hort NZ provided the draft definition to their 12 product group directors representative of all hothouse growers, which is the process that Hort NZ usually follows for consultation. The product group directors are representative of a significant segment of the industry in terms of size and experience. 
  • No submissions specific to production of cucumbers were received in response to the draft activity definition. Hort NZ provided general feedback that it agreed with the draft activity definitions for cucumbers, fresh capsicums and fresh tomatoes, and responded to specific follow –up questions, in relation to the issue of measuring production of cucumbers mentioned below.

Summary of analysis

Input

Officials propose that the activity begin with the input of a cucumber seedling. The activity should not extend upstream beyond this point (for example, to include growing cucumber seedlings from seeds) because cucumber seedlings are a tradable commodity (and are currently traded in New Zealand).

Output/Product

Officials considered whether to measure production of cucumbers by weight or by number of cucumbers. Cucumbers are usually sold on a per cucumber basis. But, in order to take an approach consistent with other activities, in particular fresh capsicums and fresh tomatoes, and to avoid creating an incentive to reduce the size of cucumbers in order to gain additional benefits from allocation, we propose that production of cucumbers be measured by weight. The industry has advised that it will be possible to provide data on a weight basis, by applying a basic calculation from units of cucumbers to tonnes of cucumbers based on average annual yields.

So that the starting point is clearly identifiable, the activity definition specifies that the activity begins when the seedling is transferred from the seedling propagation area to its final growing position. Different growers transfer seedlings into the final growing position at different stages of maturity, but officials and industry agree that the impact of such discrepancies are likely to be negligible because the emissions associated with raising seedlings are relatively minor and that a pragmatic approach is needed.

The activity description specifies it applies to cucumbers grown ‘for commercial purposes’ in order to clarify that non-commercial growers, such as households, are not covered by the definition. Non-commercial growers should not be covered because they are not trade-exposed.

Inclusions/exclusions

Emissions associated with grading, packing, storing and freighting should be excluded because they are not integral to the process of growing cucumbers and this approach is consistent with the approach taken for other activities.

Emissions associated with off-specification/reject production (i.e. cucumbers that do not meet the quality standards for sale) should be included because some off-specification production is unavoidable when undertaking the activity. This is approach is consistent with the approach taken for other activities.

Matter Analysis
The requirement to define each activity by reference to a physical, chemical or biological transformation of inputs into outputs. The activity is described as a biological transformation from inputs to outputs.
The undesirability of activities being defined by reference to the technology employed, the fuel used, the age of the plant, or the quality of the types of feedstock used when the activity is carried out. The proposed activity definition does not reference any technology, fuel, age of plant, or quality of types of feedstocks.
The desirability of defining activities:
  • consistently and equitably across industries.
  • in a way that takes into account the impact that definitions may have on business investment, geographical location, and the structure of activities.
  • in a way that takes into account the potential for intermediate inputs produced when the activity is carried out to be substituted for bought-in inputs.
The proposed activity definition takes in account consistency and equity with other activity definitions, particularly production of fresh capsicums and production of fresh tomatoes, because these are very similar activities. It is also consistent with the approach taken for other activities with respect to off-specification production and associated packing, grading, storing etc.
The proposed activity definition takes into account the potential to impact on business investment, geographical location, and the structure of the activity.
The proposed activity takes into account the potential for intermediate inputs. To avoid including an intermediate input in the activity, the activity input is ‘capsicum seedlings’.  
The desirability of there being no overlap between activity definitions. The proposed activity definition does not overlap with others.
Any other matters the Minister considers relevant, including activity definitions proposed to be used in Australia. No definition for this activity has been developed by Australia.

Recommendation

Officials recommend that you approve the attached activity definition for production of cucumbers.

Last updated: 24 May 2010