What If the PMP Ceased to Be?

A participant in the AFB Pest Management Plan Review (2021-2022) said that, for a variety of reasons, the “AFB PMP should be allowed to cease on 1 April 2023.”  

Let’s think about some of the implications of that.  We’re talking about the Minister deciding, based on the issues raised in the review, etc, that the AFB PMP is no longer necessary or desirable.  So the AFB PMP ‘Order’ (it is an Order in Council) is revoked.  And consequently, the (separate Order in Council) levy order would be revoked, as well.

Some Cost Savings

That levy order is calculated ‘by beekeeper’ and partly ‘by hive’ – $40 for being a beekeeper and  $1.35 per hive.  So if you apportion it over, say, a 1000 outfit, let’s say a round number of $2/hive as an on-going, annual cost for the PMP.  (I have used GST excl figures here – add it on if you want to.)

So you’re going to immediately save $2/hive, $2,000 in total.  Now I’m not a commercial beekeeper.  But even back in my day (the late 1990s) the Hive Levy was set somewhere around $1.50/hive, not all that much different, really.  Admittedly, it was for the NBA, the PMP and the industry-wide marketing activities.  And I would think that the gross income/hive might be somewhat greater than it was back then, even acknowledging the (lack of) sales situation for the last few years.  What are some current figures for the cost of maintaining a beehive?  How major/significant is $2/hive?  For it to be a ‘worthwhile cost’, it needs to be shown to provide at least that much value to the bkpr.

Asset Sale?

So we’re going to wind up the PMP…  One of the only real ‘assets’ of the PMP might be the apiary register, and the software that provides access to it.  With no PMP, we don’t need HiveHub anymore, as we would not be recording or tracking or auditing DECAs, etc.  Given the other uses of the database, maybe we could sell it to MPI for their uses?  I would not want to be counting on that money, but who knows?  It could be surprising ‘income’ from the revocation of the PMP.  I’m not exactly sure how it might be paid out to beekeepers, but still it might have a one-off value when the PMP is revoked and the Mgmt Agency is wound down.

Feeding of Antibiotics

One assumption we made even back when the PMP was being developed was that if AFB were to be ‘normalised’, no longer being addressed by either MAF (back in the day) or the PMP (since 1998), one of the first calls would be to allow the feeding of antibiotics to attempt to treat AFB.  That is the case for most of the beekeeping countries of the world, and there have always been some who felt it to be preferable.  It might all depend on how desperate and vocal that “let us feed antibiotics” group might be.  

The PMP order restricts, specifically, the use of drugs to ‘mask, obscure or conceal’ the symptoms of AFB.  But revoking the PMP order does not mean that you *can* then use antibiotic drugs in your hives.  Nope.

If the industry wants to start feeding antibiotics for AFB, it would need to go through seeking approvals through the Animal Products Act processes (if not other aspects, as well).  So the industry would be calling for the (new) addition of an antibiotic (known to have human health implications) to a human food product (eaten by young and old).  Now, I’m not the best one to estimate the effort and costs involved in getting the approval to feed antibiotics to honeybees.  We could argue it is done around the world, but I would still anticipate a long, drawn-out decision-making, that would inevitably be both exhausting and expensive.  OK, so if we want to go the way of drug feeding it would have some sort of a one-off cost, for sure.

But then the on-going costs of feeding drugs.  The cost of the drugs themselves may not be major, and the administration in sugar syrup – neither of those need necessarily be much of a cost.  But back to the previous paragraph.  One might expect, maybe reasonably, that use of an antibiotic in this manner *might* be seen as into the realm of the veterinary profession – I’m sure that *they* would be arguing that.  So the cost might be from minimal to a lot more if vets on the ground get involved/necessary.  And the more involvement/confidence of food security that wins the day dictates the costs.  It may be in the procurement of the antibiotic (most assuredly) and it might even get its (funding) tentacles into the administration.  Again, a cost, but only if we do go down the drug feeding path.

And associated will be costs related to testing for antibiotics.  I’m assuming that is done, at least to some extent, already.  But I would expect it to be strengthened if antibiotics are allowed.

AFB Spores

The testing of honey for the presence of large numbers of AFB spores might not change significantly.  Even with the feeding of antibiotics, I’m expecting our markets are not going to want to *reduce* testing requirements with the revocation of the PMP.  On the contrary, whether drugs are fed or not, I would have no real reason to expect tests to either be deemed unnecessary or made less expensive.

European Foulbrood

And then imagine an outbreak of European foulbrood.  EFB would again increase the calls for “let us treat with antibiotics, like the Australians”.  But given that the industry turned its back on the control of AFB, I’m not sure how sympathetic the government response might be.  Remember, too – we don’t have a Government Industry Agreement in place – I’d put my money on no response to an intrusion, and maybe no other changes as we would come to grips with it.

But let’s move on, as this next section has little chance of making it into a cost:benefit analysis, but should still be considered.  That is, when the PMP is analysed for its cost to benefit, it compares the ‘with PMP’ to ‘without PMP’.  And the ‘without PMP’ will provide some sort of estimate of the possible rates of AFB increase.  It gets assumed based on past experience, current numbers and realistic expectations.  But you can be assured that each of the modeling assumptions is identified.  In our original cost:benefit, the Massey Uni agricultural economist that did the analysis by necessity listed each of the variable figures that were included.  Incidentally, this analysis compared (1) no PMP to (2) an inspection/destruction system (which is what was available before the PMP, but no longer is an option) (3) feeding antibiotics and (4) fumigation and sterilisation.  It is certainly fun to play with the numbers on this analysis!

But the issue I want to raise runs deeper than the numbers…  

Deregulated AFB

If the PMP is revoked, it all goes.  AFB would no longer be ‘managed’ as a pest/disease.  There would be no (legislatively) compelling reason to look for AFB (but do factor in the need to get AFB testing for sales).  Nothing to make you destroy it if you find it.

If AFB gets out of control, you’d have several new options to exit the industry.  You could sell your AFB hives on TradeMe if you could (cf., ‘there’s one born every minute’)  – nothing to stop you from doing that, if the PMP is gone.  Or you could just walk away from the hives if you find AFB.  That might be a conscious choice for small or medium sized beekeeping operations.  And nothing much could be done about it.  Spot the nearby abandoned/neglected apiary that might be the detonation point of the area’s AFB outbreak?  Nothing much that could be done about it.  No powers for anyone to enter the property, to inspect the hives, to destroy any found with AFB.  Without the powers of the PMP, NZ’s beekeeping industry would revert to the pre-1906 days.  Fair enough, we don’t have so many box-hive beekeepers as they did then, but we have a hell of a lot more people with beehives…

But let’s take that a step further.  I do think there will be a potential for the intentional spread of AFB.  Don’t like your beekeeping neighbour, and want the area to yourself?  Give them a plastering of AFB.  Unhappy at what someone on Facebook said to you?  Keep a few boxes of scaly frames to throw over the fence to their apiary.  At one time, I would have discounted such behaviour as highly unlikely and not really much of a possibility.  I admit to having to rethink that one.  I’ve heard that the word ‘spiking’ is used to refer to the practice.  It saddens me very much to know that there is a word for it…  Well, no PMP and can become a ‘legal’ practice, for any reason a disgruntled beekeeper chooses to weaponise AFB…

PMP Review

OK.  There is no spreadsheet here, no statement of assumptions or comparisons of scenarios.  I’ve just identified a few of the factors that might/could come into play with the revocation of the Pest Management Plan.  “AFB PMP should be allowed to cease on 1 April 2023”, indeed.  I would like to hope that the Minister cares more about the beekeeping industry than that submission would indicate.

Soon, the review of the PMP will enter Round 3.  And with that round, a cost:benefit analysis for the current PMP will be released.  I’m looking forward to second-guessing it – changing the numbers to see what impact *my* assumptions might have.  And realising that the regulatory control of AFB is both necessary and desirable.  Even in times when the PMP is not reducing AFB levels, it provides an underlying value to beekeeping that stretches back to why beekeepers first supported the first Apiaries Act in the early 1900s.