Submission

Federated Farmers Submission for “Action for Healthy Waterways” documents: discussion document, draft NPS, proposed NES and draft stock exclusion regulation

Federated Farmers welcomes the opportunity to submit on Essential Freshwater: Action for healthy waterways. We support the goal of maintaining freshwater quality and improved management. However, we are concerned with the process, content and implications of some of the Essential Freshwater proposals.

We agree that more action is required to improve the health of our waterways. However, we consider the size and the nature of New Zealand’s freshwater quality problems and challenges has been overstated. For this reason the proposed solution is disproportionate to the “problem” it seeks to solve. Priority concerns include the one-size fits all regulatory approach, short consultation timeframes, inadequate transitioning periods, and the costly and often unjustified impacts that will follow. There are a number of proposals outlined in the discussion document that we support with amendments, oppose with amendments and others that we oppose.

Key elements that Federated Farmers proposes significant amendments to:

The proposed consultation process as outlined under “Next Steps” on the Ministry for the Environment’s website. The timeframes for finalisation of the proposals need to be sufficient to enable further meaningful consultation with and input from key stakeholders, such as industry, Iwi and regional councils, on the development of the final documents.
The interim regulation of farm intensification. This requires resource consent for land-use change. Consent will not be given if there is any increase in contaminant loss above the 2017/2018 farm year. We propose that only contaminants of issue should be targeted in the catchment, with movement allowed for any contaminants in a catchment that are below an agreed level.
Stock exclusion requirements. We oppose the suggested five metre set-backs. Instead the focus should on keeping livestock out of lowland waterways (below 5 degree slope), implemented through Farm Environment Plans. Farmers should not be forced to re-locate any existing riparian fences. We also oppose the mandatory stock exclusion from Wetlands, as these are best managed through FEPs and local planning processes.
The restrictions on hill country cropping and feedlots. We support the industry standards of Good Management Practice, such as cropping on slope less than 20 degrees and 5m setback from waterways. These standards would be supplemented by other good management practices such as strip grazing, protecting critical sources areas and farm plan commitments.
Certified Fresh Water Farm Plans. We propose Farm Environment Plans that are targeted, meaningful to the farmer, and ‘living documents’; not locked in at a point in time. If a current FEP meets council rules, it should in interim be exempt from the need to be certified. We support the more realistic implementation timeframes proposed in the Regulatory Impact Statement.

Federated Farmers strongly opposes:

The proposed new limits in the NPS for nitrogen, phosphorus and sediment. These are not scientifically robust or costed, are unlikely to be practically achievable in all places or lead to the environmental outcomes sought.
The proposed requirement for councils to not adversely impact the generation capacity, storage and operational flexibility of large hydro-electricity schemes. This will have a considerable impact on all other water users in the catchment. focused

Our Submission

Our full submission comprises of the main submission document which is comprised of our general submission and specific submissions where we provide specific feedback and suggested amendments on specific provisions/components of the documents out for consultation, and 6 appendices. These are available on this page for you to read further.