Submissions

Federated Farmers Submission on the Clean Water Consultation Document

The Clean Water consultation document contains a number of proposals, some of which Federated Farmers is supportive of, some of which it is strongly opposed to. 

We have number of concerns with what is currently proposed. We are of the view that the proposal as is contained within the Clean Water document may result in substantial costs to councils and as such have proposed an alternative approach. Councils in conjunction with their local communities should be required to undertake and assessment, using slope or some other threshold, to determine whether their existing rules for stock access to waterways are robust and fit for purpose. If this review determined that they are, then the regulation shouldn’t apply to that region. If this review determines that they are not then,  councils should put in place a work programme which sets out either whether the waterways will be subject to catchment based forms of actions, along with how these will be supported (e.g. Landcare Trust type approach); or whether the waterways should be subject to a National Stock Exclusion requirement. 

Federated Farmers is supportive of the introduction of the new national value for ‘swimming’. However, we do not support that this value only be applied to 4th order or larger rivers or lakes with shorelines on average greater than 1.5km, as we are of the view that this approach captures waterways which are not valued for swimming and misses out waterways which are. We are of the very firm view that Regional Councils in conjunction with the communities should identify which waterways and where on those waterways swimming occurs. Then only those waterways at those locations should be subject to the new national value of ‘swimmablity’. 

Federated Farmers is also very supportive of the requirement to provide better quality information as to whether a waterway is ‘swimmable’ or not. However, in our view this information needs to be linked to the location, time of year and flow at which the likes of swimming occurs. In addition it is our view that there should be a requirement to provide robust and fit for purpose information on all facets of water management. In our experience, communities are often being asked to make complex and hard water management decisions based upon ‘skinny’ data and a huge reliance upon modelling. While we acknowledge that for some aspects of water management there will be the need for good quality models, however, to inform such models and to eventually move away from such a reliance upon such models, we urge the government to invest in science. 

For more information, see the full submission