Federated Farmers of New Zealand Submission for Healthy Rivers Plan Change 1
In regard to this submission, Federated Farmers has engaged in a considerable amount of consultation with its members with interests in the Waikato Region. Federated Farmers represents members who engage in a broad range of land use activities in the region. These include Dairy, Sheep and Beef, Arable and Horticulture. The Proposed Plan Change needs to provide for the needs of all of the people of the region who engage in all of these activities.
Federated Farmers submitted that it is concerning that the Proposed Plan Change is being progressed with insufficient regard being paid to the development of the Region’s response to the NPSFM framework and that the Waikato Regional Policy Statement is not given effect to by the Proposed Plan Change. We also submitted that there are issues in the proposed PC1 with the CSG process, the section 32 evaluation, and the lack of acknowledgment of the significant economic impacts both on farmers and the communities they live in.
As a principle position Federated Farmers considers that all normal farming activities in rural areas should be permitted activities and believes that it should be possible to undertake normal farming activities without having to obtain a resource consent. Federated Farmers is particularly concerned at the potential for substantial compliance costs when the provisions in it come to be put into effect. The Federation is aware of many cases where the costs of obtaining consent for a normal farming activity outweighs the cost of undertaking the activity, in some cases by several multiples
Summary of the three key issues with the Proposed Plan Change
Federated Farmers is strongly opposed to the allocation of nutrient discharge allowances. Principally this is because there is no fair and equitable way in which this can be done. It is considered that issues arising from the over-allocation of nutrients can generally be addressed in the interim in ways other than allocation, such as the implementation of good management practices, with more detailed proposals developed at a later stage through a sub-catchment, freshwater management unit based assessment, and implemented at that time through a sub-catchment plan change (such as the approach in some other regions). It is considered that the Proposed Plan Change needs to ensure the Nitrogen Reference Point is to be used solely for the purpose of determining those land users who need to reduce their nutrient discharges, and for setting flexibility limits, as discussed below.
Federated Farmers considers that the requirements for the fencing off of water bodies set out in the Proposed Plan Change are inequitable, repressive, unnecessary, and that they will not satisfactorily address the water quality issues that the Region is facing. Instead, Federated Farmers considers that the policy proposals for excluding stock from waterways set out in the Government’s recently announced Clean Water Package 2017 should be implemented as an interim measure, and more detailed proposals developed as appropriate to the particular sub-catchment later, through a freshwater management unit based assessment, and implemented then through a sub-catchment based plan change.
Flexibility of Land Use
Federated Farmers is very concerned at the extent to which the Proposal locks rural production land users into their present land uses. This is because of the rapid changes in agriculture that are taking place at the moment. It is considered that land users should be able to modify their production systems within their present general land uses as a permitted activity, with the proviso that nitrogen discharge does not exceed 15kgN/ha across the production unit as a whole, and that an exemption from the general nutrient discharge restrictions should be applied in the case of vegetable production, as is the case in Auckland. For example, a sheep and beef farmer should be able to alter the ratio between sheep and beef, and also have the flexibility to grow some fodder crops without needing to obtain resource consent, while where a change of land use is involved, such as conversions from forestry to sheep and beef, or from sheep and beef to dairying a resource consenting regime is appropriate, with the Council retaining control over the amount of nutrient that can be discharged.