Roses

Summary of submissions and consultation process

In response to the December 2009 consultation document, three growers provided submissions regarding production of roses. Submissions were also received from the New Zealand Flower Growers Association (NZFGA) and the New Zealand Export Growers Orchid Association.

Officials made considerable efforts to identify and provide information to all rose-growers for the purposes of consultation on the draft activity definition. This was challenging because not all rose growers in New Zealand belong to the industry association. In fact, for flower growers in general, only a minority of growers belong to an industry association. Further, the industry association was not willing to provide officials with a list of its members or of other flower-growers. The draft activity definition was sent for consultation to the growers and industry groups that made submissions on the December 2009 consultation document as well as other growers that officials were able to identify through those submissions and conversations with growers. Officials believe the draft definition reached a large majority of rose growers.

Submissions received in response to the draft activity definition, as well as views gathered through conversations with growers, were taken into account in developing the activity definition for production of roses attached in Appendix Two.

Summary of analysis

Input

Officials propose that the activity begin with the input of a rose plant in its final growing position. The activity should not extend upstream beyond this point (for example, to include growing rose bushes from cuttings) because rose plants are a tradable commodity (and are currently traded in New Zealand) and because a single rose plant is usually used to produce several crops of roses.

So that the starting point is clearly identifiable, the activity definition specifies that the activity begins when the rose plant is transferred from its propagation area to its final growing position.

Output/Product

Officials propose that the output should be cut flowering rose stems, as this most clearly identifies the end point of the activity. No substantially different description was suggested in submissions. As industry practice is to measure production in stems, this approach is clearly understood by growers and puts no additional burden on them.

The activity description specifies it applies to roses 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

Officials consider that emissions from some cool-storage should be included because it is integral to the process of producing cut roses (all roses require some initial cool-storage to prevent early collapse, for approximately 24 hours). Emissions associated with all other storing, as well as grading, packing and freighting, should be excluded because they are not integral to the process of producing cut roses and this approach is consistent with the approach taken for other activities.

Emissions associated with off-specification/reject production (i.e. roses 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:
  1. consistently and equitably across industries.
  2. in a way that takes into account the impact that definitions may have on business investment, geographical location, and the structure of activities.
  3. 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 cucumbers, production of fresh capsicums and production of fresh tomatoes, because these are somewhat similar activities.

Where appropriate, 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 ‘rose plants’.  
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 cut roses.

Last updated: 2 July 2010