Submission

 Submission on the proposed changes to the Intensive Winter Grazing Regime

The intensive winter grazing regulations have caused headaches for farmers across the country.  Introduced as part of the National Environmental Standard for Freshwater, these regulations set strict standards that farmers carrying out intensive winter grazing are required to meet without obtaining resource consent.

The Government has proposed loosening some of those conditions, which we support.  In particular, Federated Farmers supports the proposal to:

• remove the requirement to re-sow by 1 October in favour of “as soon as practicable”;
• remove the arbitrary limits on pugging in favour of requiring “reasonably practicable steps” to manage pugging;
• amend the definition of “drain” to exclude sub-surface drains;
• change from using a ‘mean’ slope to using a ‘maximum’ slope (with Federated Farmers requested the maximum slope be increased to 15-20 degrees);
• include a new condition protecting critical source areas, provided the protection only extends to landscape features that has a direct pathway for sediment/contaminants to a waterway and excludes subsurface drain; and
• defer the IWG regulations until November 2022.

However, there are still some areas where the intensive winter grazing regulations require further work. Federated Farmers opposed the treatment of subsurface drains as critical source areas. In addition, Federated Farmers sought:

• the ‘area limit’ be adjusted from 50 hectares to 100 hectares (or 10% of the farm, whichever is greater);
• that the FW-FP pathway is clarified and available at scale before consent is necessary;
• the full involvement of primary sector representatives, including Federated Farmers, in the preparation and working groups associated with any Guidance Material on intensive winter grazing;
• a review of the ‘reference period’ to ensure there is no unintended consequences of the area of farm that is used;
• a review of the restricted discretionary consent matters of discretion;
• an amendment of the definition of ‘annual forage crop’ to ensure arable crops are not captured as part of the intensive winter grazing conditions;
• an amendment to the definition of ‘pastoral land use’ to ensure grazing of livestock on arable crops does not limit arable growers under the N Cap.