• Patrick Dawkins

DOC’s Treatment a Bitter Pill for Beekeepers

While beekeepers across New Zealand struggle as honey prices sit below the cost of production, many are also facing loss of their best hive sites as the Department of Conservation (DOC) denies beekeeping in certain areas, or forces apiarists from the land with excessive fees. How does the concessions process work, and is DOC showing any sympathy for the plight of the beekeeper?

By Patrick Dawkins

DOC estimates there could be anywhere from 9000 to 18,000 beehives placed on the approximately 8-million hectares of conservation land in New Zealand, with 60 concessions currently in place. While historic data on beekeeping concessions granted is not readily available, those numbers are almost certainly on the decline, with only six new concessions granted in 2022 to October.

New Zealand has a vast conservation estate, managed by the Department of Conservation under the Conservation Act 1987.

The reduction in use of conservation land for beekeeping purposes would not be surprising, given that registered beehive numbers in New Zealand have reduced in each of the last three years in the face of a falling honey market, for both mānuka and non-mānuka varieties. Despite drastically reduced returns to beekeepers DOC has made no adjustment to their charges for beekeeping since concession prices were increased in the mānuka boom years, meaning some beekeepers have walked away from sites. However, even among those who wish to maintain their existing ‘DOC sites’ and attempt to make a go of it, the Department appears increasingly reluctant to allow beekeepers to maintain hive placements, stating concerns of the unknown impact the introduced honey bees could have on native conservation land.

However, in several such areas DOC’s conservation efforts are limited, or none at all according to beekeepers. They say the only effort to maintain access or reduce pests is coming from them, effort that has or will stop when they are removed from the land.

DOC charges beekeepers a wide range of fees for the benefit of placing hives within the conservation estate.

How the Process Works & What is Paid

If a beekeeper wishes to place beehives on any of the conservation land in New Zealand, then a beekeeping concession must first be applied for. Discretion to grant that concession is solely in the hands of DOC and, even if granted, it comes with a long list of conditions. Those conditions include payment of an annual per-hive fee ($30 for non-mānuka sites, $75 for mānuka), as well as an annual “management” fee ($150-$500) and one-off “processing” fee (a minimum of $2065) for each application. On top of that, a successful applicant may also be required to pay extra if they plan to use helicopters to place hives. Stacked on top of that again is the “monitoring fee” charged to beekeepers when DOC audits the hives on concession sites, and charged whether fully compliant or not.

While each concession period previously lasted 10 years, most appear to now be for periods of only three years, after which time the applicant will be required to re-apply and subject to a fresh processing fee, thus increasing the cost to the beekeeper. Processing fees are payable regardless of success or denial of applications.

The number of sites used by each concessionaire, and the number of beehives placed on each site, varies. However, the maximum stocking rate DOC allows for is 40 beehives per site.

As of October, only six concessions applied for in 2022 had been approved.

What Influences DOC’s Decision?

DOC’s actions are governed by the Conservation Act 1987 and (as detailed in To Bee or Not to Bee? this issue) they must strike a balance between a range of factors, of which conservation of the land is top priority.

For beekeeping activities a key consideration is whether the impact of European honeybees, a non-native species, can have adverse effects on the native flora and fauna.

In 2015 DOC’s science team wrote up Beekeeping National Guidelines which heavily influences decisions, while Dr Catherine Beard’s 2016 Honeybees on Public Conservation Lands report to the Department has guided their thinking.

Then, there is the issue of “EMUs”, Ecological Management Units. It’s an acronym some beekeepers are learning about the hard way.

Ecological Management Units

The Aorere Goldfields in Golden Bay were once home to – as the name suggests – extensive goldmining operations in the second half of the 1800s. These days abandoned remnants of those operations remain amongst the scattered native bush of largely kanuka, mānuka and kamahi, which is home to both native and exotic wildlife. Among the introduced species are approximately 100 of Freebees Honey’s honey bee colonies, but not for long it seems.

The Aorere Goldfields area, to the left of photo, in Golden Bay where beekeeper Avner Cain has been given three years to remove his hives by DOC as the land is on the outskirts of an Ecological Management Unit.

Freebees Honey is owned by Avner Cain, who is the sole operator of about 300 hives and who says he followed the traditional path of “beekeeper, manager and then owner”, taking over the business in 2020.

Essential to the sustainability of Freebees Honey is the mānuka honey gathered from the Goldfields sites, but Cain says following renewal of his application this year, he has been given three years to get the hives off because they fall within an EMU.

“It’s my only profitable honey. The rest is lucky to cover costs. Loosing those sites makes my business no longer viable,” Cain says.

“I finally got to business ownership and then three years in and I might be out of business. It is really hurtful.”

EMUs make up about a third of public conservation land, and thus more than 2.5-million hectares. They are areas deemed to be of high conservation value by DOC using Zonation software and “in-house experts”.

In the instance of the Aorere Goldfields, Cain’s apiaries sit inside the Parapara Ridge EMU, which DOC describes as “altitudinal sequence from hard-beech through hard-silver beech to silver-beech forest on mix of argillite, schist and mudstone”. DOC’s warning to Cain stated “no expectation of continued operations in these ecologically sensitive areas” due to “potential adverse effects of introduced bees to areas of high ecological importance”.

The Golden Bay beekeeper is aware the issues of land conservation and honey bees is one far bigger than he can shape and says he is grateful to receive three years concession at least, but something still doesn’t seem right.

Avner Cain, owner of Freebees Honey in Golden Bay, says he has seen no evidence that DOC has fully considered the specifics of his concession to place hives application, despite paying $3112 just to “process” the application.

“My sites are not in the beech forest but on the border of the EMU, where it’s low growing mānuka, poor soil, the area has been heavily gold mined, burned several times and they even diverted a river. It has goats, pigs, hares, wasps, you name it. It is nothing like a pristine environment.

“The wasps will create way more damage to the beech forest than any bees. If I lose a swarm it will die within a year due to varroa. My few hives on the outskirts will have very little impact.”

Hives have been on the sites since 2006 and have never been known to collect beech honey dew, according to Cain, who has been working them since 2013.

In the 10 years Cain has kept bees in the area, he is not aware of any work DOC has done to control introduced species or improve the land. Conversely, Cain has maintained track access to hives and controlled wasps at his own expense.

His high level of frustration at DOC’s decision and resulting limited communications comes at the across-the-board nature of the Department’s plans.

“If someone has an established business inside an EMU, DOC should look into it closely and actually consider what is on the line,” Cain says.

The dispersal of the approximately 8-million hectares of conservation estate in New Zealand overseen by DOC, with land classified as Ecological Management Units in dark blue.

“There should be case-by-case decisions made, not one sweeping change which means a lot of beekeepers will lose their hive sites.”

DOC’s Confused Approach

While the Beekeeping National Guidelines which help inform DOC’s decisions specifically encourage beehives “not to be placed in or near EMUs”, national permissions advisor Bryn Shepherd says there is no sweeping rule.

“DOC currently does not have any policy to cancel or ‘wind up’ active beehives concessions in or near EMUs,” Shepherd says.

“However, on expiry of those concessions, should a new concession activity be submitted to continue that activity, DOC will (in line with the Beekeeping Guidelines) assess the suitability of allowing this activity to continue in or near EMUs. Due to the specifics of each application, DOC has not made a blanket ‘rule’ to automatically decline beehives in or near EMUs.”

That view contrasts with written reply to an applicant, from DOC, which states “The Department is currently in the process of phasing out the granting of beehive concessions that are within or nearby Ecological Management Units”.

A Lot of Fees & Little to Show for It

Regardless of DOC’s mixed-messages around their handling of EMUs, Shepherd says that “for beehive concessions, a DOC science advisor is also assigned to assess the suitability of the specific application”.

For Cain and his hopes of a more understanding review of his beekeeping operations, there has been no evidence his application has been individually assessed.

“They didn’t cite any information to me. There is no report, no background data or research. There is no reasoning. They have just decided EMU areas are not having honey bees anymore,” Cain says.

“I wouldn’t believe they did a report. Otherwise, I want to see it.”

In the case of a declined application, DOC may share a Decision Support Document which typically include input from a decision maker, a science advisor, a community ranger who engages with local Māori, and a permissions advisor who drafts the document, according to Shepherd. In the instance of Freebees Honey and Cain, his application has technically been approved, for three years at least.

DOC’s reasoning for not providing more information to all beekeepers applying for concessions is not for lack of resources. Cain says his processing fee alone was first estimated at the “standard” rate of $2682, before being invoiced $5177.50. When this fee was questioned DOC claimed “an error when processing” and it was re-invoiced at $3112.50.

It is unclear how many beekeepers, or concession applicants more generally, may have been overcharged because of such errors.

DOC collected $9.4million in concession fees for activities on the conservation estate in the year to 30 June 2022, but did not detail beekeeping among the 15 accounting categories. Activities as varied as skiing, boating, vehicle access and filming were all categorised, but data specific to beekeeping is not publicly available.

Beekeeper Frustration Widespread

Cain and his Freebees Honey business are far from alone in their plight to maintain access to ‘DOC-sites’, as they are known in beekeeping circles.

Further south in Blackball on the West Coast, Glasson Apiaries owner Gary Glasson says he has given up all six of the DOC sites they once held, in the wake of increasing fees and overbearing bureaucracy.

Gary Glasson, owner of Glasson Apiaries on the West Coast, is one beekeeper who wants nothing more to do with DOC after dealings became "too onerous and more and more expensive".

“I let them go because it was all becoming too much of a pain really. Too onerous. More and more expensive,” Glasson says.

He spent 10 years undertaking pest control for a local wildlife trust, including serving on its board, but gave that up when it became clear DOC was not valuing his contribution to the conservation estate and continuing to charge a range of concession fees.

“I went to DOC and talked about offsetting the hive sites with that work, like mines do. I was told ‘no, no we need the money for other things’. So, I decided to stop doing all that work,” Glasson says.

Another beekeeper, speaking under condition of anonymity due to their ongoing use of DOC sites, says they have been dealing with the Department for decades and describes an “arrogant, dictatorial and unapproachable corporate culture” and a “faceless bureaucracy that wants to destroy our livelihood”.

Will They Listen to Anyone?

So what recourse do beekeepers have in the face of an unapproachable and seemingly unconcerned public department?

DOC claims to “work with Apiculture New Zealand to make sure processes are well connected with the industry, and beekeepers are kept informed,” via their website.

Apiculture New Zealand (ApiNZ) has approached DOC requesting it review fees for beehive concessionaires, noting difficulties with the honey market both nationally and internationally. However, there has been no action towards change from DOC, with Shepherd admitting that a review started in 2021 has been “temporally delayed” and “work is ongoing”.

ApiNZ chief executive Karin Kos describes dealings with DOC as “frustrating” due to the inertia in communications and decision making, or complete lack of, but says the Department has been made aware of the struggles of the honey industry and they are continuing to press for change.

It appears DOC is not listening to the beekeepers on the ground or the industry body representing them. So, Cain went directly to his local member of Parliament, who also happens to be the Minister for Primary industries, Damien O’Connor, but his plight was not taken up with any authority.

Damien O'Connor, Minister for Primary Industries, has passed a beekeeper's concerns at having hives disallowed from DOC land to the Conservation Minister, who in turn has passed the matter back to DOC's operations team.

“The Minister said that because it is a conservation matter, he would forward my letter to the Minister of Conservation. All they said was they would carry out the due process. I really hope they will reconsider the decision,” Cain says.

Just a few years into his hard-earned climb to business ownership, Cain says DOC’s unjust ruling might soon end the dream.

“They told me to prepare to lose those sites in three years, but there is no equivalent mānuka site I can shift the hives to. When I bought the business, I bought it thinking that was my mānuka area, to go along with a kānuka area, another of rata. Three areas and I can't afford to lose my most valuable, completely unexpectedly. If I knew I was soon going to lose the mānuka sites, I might not have bought it.

“I will be very upset if I lose this concession. It seems so unfair. There is no justice behind it at all.”

Unfair and unjust in the beekeeper’s eyes, but is anyone of consequence listening?


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