Federated Farmers Submission on the Canterbury Land and Water Plan
Federated Farmers supports a collaborative approach to water management, the parallel development philosophy embodied in the Canterbury Water Management Strategy (CWMS) and the CWMS targets. We support the inclusion of these approaches in the Proposed Land and Water Regional Plan.
- The objectives should contain a statement explicitly recognising the economic and social values attached to abstracted water.
- The plan needs to explicitly state that it is not only the environment which needs to be managed sustainably but also the ability of people and communities to provide for their social, economic and cultural wellbeing and for their health and safety, consistent with section 5 of the RMA.
- The statement of first and second order priorities for guiding the allocation of water needs to be more clearly placed in the CWMS context of parallel development and achievement of the CWMS targets.
- The plan places undue emphasis on the management of Nitrogen. Nitrogen discharge management has the potential to hugely constrain land use and irrigation development, but it is one of the less likely tools to achieve the desired fresh water outcomes.
- Federated Farmers supports the use of OVERSEER as a farm management tool. However, we are concerned about its use in a regulatory sense. It is useful for estimating trends and progress towards targets, and increasing the understanding of relative property-based nutrient loss, but its lack of precision (plus or minus 20%) means that it is not useful for generating absolute values for compliance purposes.
- Nutrient allocation zones need to be reviewed using a robust (scientifically sound) and transparent process based on criteria which recognise that the Canterbury plains is a highly populated working landscape.
- The non-complying status on land-use change in Red Areas and Lake Zones, combined with the definition of land-use change, has the potential to prevent land-use change and flat-line the regional economy.
- The definition of change in land-use requires amendment so that it is not triggered by changes which are not genuine changes in land-use.
- Greater use of water should be removed as a criterion for defining land-use change because well-managed irrigation enables better management of nutrients by facilitating movement of nutrients into the root zone in a controlled manner, by ensuring an actively growing crop to take-up nutrients when they are applied and by enabling drainage to be minimized.
- The NPS for Freshwater Management requirement to set water quality limits should be wholly met via the community-led development of catchment-based plans. The NPS implementation timeframe envisages such an approach where it states that councils may implement the requirements of the NPS by a programme of time-limited stages, to be fully completed by 31 December 2030.
- Requirement for the surrender of water when consents are transferred will create a disincentive for desirable water transfers, reduce dynamic efficiency and reduce the flow of water to its greatest value use
For more, see the full submission