Federated Farmers of New Zealand Submission to Environment Canterbury on Proposed Variation 3 to the Proposed Canterbury Land and Water Regional Plan – Section 15 – Waitaki and South Coastal Canterbury
Nutrient Management Provisions of Variation 3
Before making detailed submissions on the specific provisions in Variation 3, Federated Farmers wishes to make an over-arching submission about some major issues regarding incorporation of the N Allocation framework agreed by the Nitrogen Allocation Reference Group, and the extent to which Variation 3 now delivers on the intentions of that group.
Nitrogen Allocation Reference Group (NARG)
Variation 3 applies to the area known as Waitaki and South Coastal Canterbury. As part of the process of setting water quality limits for that area, and following a consultation process, the Lower Waitaki South Coastal Canterbury Zone Committee developed draft N load limits and a draft N allocation framework and published these in a draft addendum to its Zone Implementation Programme (ZIP Addendum).
A large number of farmers protested to the Zone Committee about the process and timeframe for developing the ZIP Addendum, and about the inequity between high and low N emitters in the N allocation framework.
The Zone Committee and Environment Canterbury responded by setting aside the original proposal for N allocation and enabling the establishment of a Nitrogen Allocation Reference Group (NARG) to work towards reaching consensus on a nitrogen allocation framework.
The group was established from the local community and included a broad range of farming interests. The group was able to work through its competing interests and arrive at a consensus position, referred to here as the NARG Allocation Framework.
Consensus position on N allocation
The NARG Allocation Framework contains flexibility caps for low N dischargers, to enable them a degree of flexibility to change land use in response to market and physical conditions, and maximum caps based on soil type, particularly focused on high N emitters, to be achieved over time to improve the performance of high emitting activities.
Concerns about Variation 3 in its current form
Federated Farmers has concerns about Proposed Variation 3, particularly its incorporation of the NARG Allocation Framework and the extent to which it now delivers on the intentions of the NARG.
Specific concerns include:
- The plan does not take account of updated soil information (correction of an error in S-map) which substantially affects the appropriateness/achievability of numbers in the plan, particularly the maximum caps. There are also issues with how N discharge has been modelled for some soils (e.g. poorly drained and poorly drained light) compared with how it will be estimated on-farm using Overseer.
- The plan is inconsistent with the ZIP Addendum and the Section 32 Report particularly with regard to its lack of ability to accommodate new information, including new versions of Overseer and updates of good management practice. The ZIP Addendum envisaged a ‘live document’.
- The combined effect of soil mapping errors, modelling issues and lack of ability to adjust to new versions of Overseer mean that the Maximum caps specified in the plan may be unachievable and that the flexibility caps may not allow effective flexibility for low N dischargers. As a result, the proposed plan, in its current form, is based on erroneous data, and does not give effect to the intentions of the N Allocation Reference Group or to key aspects of the ZIP Addendum.
Therefore, Federated Farmers opposes the nutrient management provisions of Variation 3 including Policies 15.4.1 – 15.4.17, Rules 15.5.1 – 15.5.14 and Tables 15 (m) – 15 (p).
See the full submission, further submission, and evidence for more information