Member Advisory


Last call for Essential Freshwater submissionsTo all Federated Farmers members 

October 30, 2019

The government's package of Freshwater reform proposals “Action for healthy waterways” consultation period ends tomorrow, 31 October 2019.
It's crucial that Ministers and Ministry officials are made aware of the impact these proposals will have on farming families, businesses and rural communities as final decisions will be made by Cabinet not Parliament.
Federated Farmers has put together a comprehensive submission focusing heavily on the policy wording and broader implications of the proposals.
We recommend you as individual farmers focus on providing an overview of the impacts and investment at farm, family and community level. We also suggest you provide details of any specific on farm actions undertaken to improve environmental outcomes. These good farm stories are not recognised in the proposals, and central government needs to be made aware of them.
There will be no hearings following the close of submissions, so this is your best chance to make your thoughts and concerns known.
The biggest concern we have is the crude, blanket, top down approach being taken to address hugely varied water quality issues that are very site specific. Join us in reminding government that one size does not fit all.

Suggested information to include in submissions

The farm-focused information you provide in your submission will depend on the nature of your farming operation, but could cover:
(a) Whether you support or oppose the specific proposals (you can access a summary of the key proposals on our website by clicking here);
(b) Your investment in environmental mitigation (planting, fencing, investment in infrastructure like bridges, culverts and storage). This could include investment over the past five years, three years, or one year, and/or what you are proposing to invest in the following year. The key is to be clear what timeframe you are covering and the types of investment you are including;
(c) The potential or estimated costs of the proposals on your farm productivity and viability. In particular the estimated costs to your farm as a result of key changes summarised via (a) above, such as increasing stock exclusion setbacks, moving fences out to 5m on average across a farm; alternative wintering of stock needs; actively reducing nitrogen losses and so forth.
•    For example we know that 1km of waterway with 5 metre exclusion of fencing on each side ties up 1 hectare of land – you can use this calculation to work out what you may lose in land area and what that land is worth per/ha

(d) If you feel comfortable doing so, some indication around how these additional costs may impact the profitability or viability of your farming operation. In order to ensure the information you provide is not taken as a total farm cost it is useful to break these down into specific operating and capital costs;
(e) Why you need flexibility in land use, how your land use can change on an annual basis and how you use land use change to manage environmental effects on-farm;
(f) How your on-farm investment, catchment group work, fertiliser application and your farming practices have improved water quality on your farm, in your catchment and in your region:
a. Through on-farm monitoring, regional water quality or catchment water quality data or
b. Where possible use environmental data that is publicly available.

How do I make a submission?

There are a number of ways you can submit:
  1. Use the submission templates we have developed to help guide your thinking and ensure the key points are covered. We have drafted two templates a) farm specific and b) proposal specific. The proposal specific template is based on the complex set of feedback questions MfE are seeking a response to. Please choose the ONE that works best for you. You can access these by clicking here.
  2. Use the online option provided on the Ministry for the Environment website. You can access this by clicking here. Please note this tool asks specific questions, provides a specific format for your responses and is not recommended if you are providing detailed information as suggested above.
  3. Free style – write it your way. As long as the submission is clear as to whether you support or oppose the proposals (or parts thereof), provides some reasoning for your position, has your name and contact details and does not use offensive language, then it will provide important feedback. You can email that directly to
The formal deadline for submissions was Thursday 17 October 2019 at 5pm, but on Federated Farmers' request Minister Parker has agreed that ‘submissions will be accepted until 31 October 2019.

What happens with my submission?

Please be aware that if you make a submission your name and your submission may be published on the MfE website. Unless you clearly specify otherwise in your submission, the Ministry will consider that you have agreed to this. Contents of submissions may be released to the public under the Official Information Act 1982, if requested.
When the consultation period has ended, feedback will be collated and reviewed by officials and an advisory panel. Ministers Parker and O’Connor will then make recommendations to Cabinet (consisting of Labour & NZ First Ministers) who approve the final regulations for freshwater. (Note Parliament has no role)
For more information, please contact your local Federated Farmers provincial executive team, or your Regional Policy Advisor.
Gavin Forrest
GM Policy & Advocacy
Federated Farmers of New Zealand