Submission

Federated Farmers submission to the Draft Air Quality Strategy Otago Regional Council

Federated Farmers appreciates the opportunity to submit to the Otago Regional Council Draft Air Quality Strategy.
We consider the current Air Plan is generally working well, excluding in identified urban and township airsheds where there are issues with chimney emissions during winter heating peaks.
Key Issues
Issue 1: Our communities rely heavily on burning wood and coal to heat our homes
 -We support the focus of this issue, the description of Effects and the way the Desired Outcome has been divided into a Short to Medium and Long Term component.
-We support the proposed short term actions aimed at addressing this issue.
-We support Council focusing on upgrading heating in new homes, and focusing on problem areas as priorities.

Issue 2: Outdoor burning is still common in Otago to remove green waste and diseased material, and to manage pasture
-Federated Farmers agrees with the description of the issues, but ask that the ‘Effect’ is re-written as follows (or words to similar effect): 'Outdoor burning adds to the overall pollution levels in an area. Where the burning is significant, or undertaken in an area where there are existing air quality issues, the resulting smoke that can be a nuisance for residents and visitors'.
- We ask that the desired outcome is tailored to focus on areas with existing identified air quality issues as follows (or words to similar effect): 'Reduce reliance on outdoor burning in areas that have identified air quality issues'. 
-  We ask that Council prioritize the implementation of the Air Strategy to those areas where there is an identified air quality issue.

Issue 3: Some people do not manage their discharges to air properly and this can impact on their neighbours. Earthworks, roads and other land uses can generate dust:
 - Federated Farmers agrees, and we agree that being a ‘good neighbour’ and a responsible farmer includes undertaking practical steps to reduce nuisance and negative impacts on neighbours. However we ask that the ‘Desired Outcome’ for Issue 3 is re-written as follows (or words to similar effect): 'Nuisance from emissions and dust is minimised'. 
- We support Council focusing on tightening up the rules on the use of outdoor fires in our region’s cities and residential areas, where the impact of these fires on human health is likely to be relatively more significant.
-We support Council promoting the desired outcomes of the Air Strategy through each Council’s District Planning processes, so that the methods of achieving those outcomes can be tailored to the issues and challenges within each District.

Issue 4: Chemical spraying is widely used in Otago to manage pests
- We agree with the adverse effects stated in relation to use of chemicals. In our view the impacts of these practices can be significantly reduced, if not entirely managed, through adoption and refinement of good practice.
- We ask that the ‘Desired Outcome’ for Issue 4 is re-written as follows (or words to similar effect):
'Toxic emissions do not cause harm to people and or ecosystems'.