Federated Farmers Submission on the Proposed Southland Water and Land Plan
Water and Land 2020 and Beyond is ES’s response to the Government’s National Policy Statement on Freshwater Management, which requires regional councils to maintain or improve water quality.
In June, ES notified the Proposed Southland Water and Land Plan for public consultation.
Federated Farmers submitted a strong, farmer-informed submission on the Plan. We gained farmer feedback through our four farmers meetings held throughout Southland, our member survey, and directly by members contacting staff and Executive members with questions and concerns.
Our key concerns with the Plan are:
- Physiographic zones – the physiographic zones have not been ground-truthed, there is no mechanism for landowners to review the zone/s their land has been placed in, and it is unnecessary and premature to make some activities ‘non-complying’ based on this risk-based model. Our recommendation is that any reference to physiographics is removed from the Plan;
- Intensive winter grazing – the area restrictions placed on intensive winter grazing do not recognise the practical need to feed livestock all year round, and in Southland stock cannot be grazed extensively over the winter months. Our recommendation is that intensive winter grazing remains a permitted activity, subject to good management practices and some practical set-backs from waterways;
- Stock exclusion from waterways – the exemption for sheep is appropriate, but overall the stock exclusion requirements are unworkable and not practically or economically feasible for extensive farming operations in Southland, or where stock rely on drinking water from waterways.Our recommendation is that the requirements do not apply to farms where the average stocking rate is 5 stock units per hectare or less, or where stock need to access waterways for drinking water;
- Cultivation – Federated Farmers supports set-backs from waterways for cultivation to reduce sedimentation, but disagrees with the extent of those proposed in the Plan. Our recommendation for setbacks is: 3 metres from the outer edge of the bed on land with a slope of less than 8 degrees; and then 1 metre incremental increases on slopes above 8 degrees. We also recommended increasing the 20 degree permitted activity limit for cultivation up to 25 degrees;
- New or extended dairy farming – the non-complying activity statuses for new or extended dairy farming in the Old Mataura and Peat Wetlands physiographic zones are inappropriate. Currently there is not enough known about nutrient loading and whether there are over-allocated catchments within Southland. Our recommendation is to change the discretionary and non-complying activity statuses to ‘restricted discretionary’ so that the resource consent process is transparent and more efficient.
Later this year, ES will call for Further Submissions on the Plan, and in 2017 a hearing will be scheduled to give submitters the opportunity to present their views to the ES hearing panel.
On behalf of our members, Federated Farmers Southland will be fully engaged in this regulatory process, pushing for practical and workable farming rules.