Federated Farmers of New Zealand Submission to Environment Canterbury on Proposed Variation 2 to the Proposed Canterbury Land and Water Regional Plan – Section 13 Ashburton
One of the key issues in this plan variation is the approach to the allocation of N discharge and the various undesired outcomes and inequities which flow from this.
In the Upper Plains, it is prohibited for the N loss calculation to increase above the N baseline. This has the effect of preventing any intensification, would limit productive potential in the area and would likely have adverse effects on land values and equity in farmland.
This approach is inherently unfair because it ‘grand-parents’ N discharge to existing land-use within the Upper Plains area, disadvantaging those with lower N baselines compared with those having higher N baselines. It also disadvantages the Upper Plains land users compared with other land users in the catchment who have greater flexibility, including the ability to intensify, as part of an irrigation scheme or as an individual up to an N discharge of 27 kg/ha/year.
There are also inequities within the lower plains, for example between existing dairy farmers who are required to reduce their N discharge by 45% by 2035, regardless of their starting point GMP benchmark, compared with others who will be allowed to intensify up to 27 kg/ha/year (a 45% reduction for anyone discharging 49 kg/ha/year, or less, will require them to reduce to a discharge less than 27 kg/ha/year).
A preferred approach would be to apply a consistent and more equitable N discharge allocation regime across the entire Hinds Plains area (over a suitable timeframe).
The Land and Water Partnership (LWP) is currently working towards a combined primary sector approach to N discharge allocation and will reach agreement on such an approach by 24 October 2014. When agreement is reached, it would make sense to incorporate it into Proposed Variation 2. The hope is that it will be consistently used throughout Canterbury (and throughout New Zealand).
The approach being developed will begin with the adoption of good management practice, based on the Matrix of Good Management (MGM) benchmarks, and will move over time to an allocation based on the productive potential and physical characteristics of land (soil type, climate and topography – essentially the MGM criteria without land use). This would result in greater equity among land users. This approach would be implemented in a staged manner, based on the platform of MGM benchmarks which will apply from 2017.
Therefore, Federated Farmers asks that the LWP approach is introduced in 2017 based on a starting point of GMP, which is required at that time by the Proposed Variation 2.
The first deviation from the proposed plan would occur in 2020, the time at which the first percentage reductions by dairy and dairy support would be required under Variation 2.
Please see the submission, further submission, and evidence for more information