Submission

Submission on the Draft National Adaptation Plan

INTRODUCTION
Federated Farmers takes a strong interest in climate change policy, both emissions mitigation and climate adaptation. 

New Zealand farmers are very aware of the risks of climate change to their businesses, especially compared to other sectors and industries. 

Federated Farmers requests that MfE notes its submission and points raised. 

Federated Farmers would welcome the opportunity to discuss our submission further with MfE. 

SUMMARY OF RECOMMENDATIONS 
Recommendation 1: That MFE notes Federated Farmers’ submission and points raised. 
Recommendation 2: That the National Adaptation Plan acknowledge that farmers are aware of the effect of climatic events and are acting on this information where possible. 
Recommendation 3: That prior to adopting a National Adaptation plan, another round of public consultation is undertaken. 
Recommendation 4: That the National Adaptation Plan recognise the contribution from farmers in planning for and recovering from adverse weather events. 
Recommendation 5: That careful consideration be given when developing the National Adaptation Plan, that a siloed approach is not supported, and other government policies or regulations do not act in contradiction to this plan. 
Recommendation 6: That clear and equitable processes, early engagement, and alternative options be adopted. 
Recommendation 7: That the National Adaptation Plan aligns its consultation to ensure major legislative reforms to the Resource Management Act, Local Government Act and Civil Defence Emergency Management occur prior to a finalised draft for consultation. 
Recommendation 8: That it is recognised that while there may be economic opportunities in adapting to climate change, there will also be negative economic impacts. 
Recommendation 9: That investment and delivery of rural infrastructure is not further compromised by a lack of funding. 
Recommendation 10: That a just transition framework be applied to retreat, managed or reactive. 
Recommendation 11: That a standardised approach to response and recovery, which includes the rural sector, be adopted. 
Recommendation 12: That the revised Federated Farmers Policy on ‘Government policies incentivising the blanket afforestation of farmland’. be included in the National Adaptation Plan.1 
Recommendation 13: That the Rural Proofing Policy and guidance be embedded in the principles in the National Adaptation Plan. 
Recommendation 14: That MFE implements the Rural Proofing Policy and guidance during the development of this plan. 
Recommendation 15: That the risk to farm and other exotic ecosystems from the enhanced spread, survival, and establishment of invasive species due to climate change be acknowledged in the body of the plan. 
Recommendation 16: That the National Adaptation Plan provides for early intervention support and improved auditing of systems for biosecurity incursion response. 
Recommendation 17: That the Water Availability and Security programme is prioritised, and that greater urgency is shown in addressing regulatory, legislative, and financial barriers that are hampering the improvement of water resilience. 
Recommendation 18: That the Government invest in ensuring the resilience of rural infrastructure networks and invest in ensuring that these networks are reliable. 
Recommendation 19: That the Government invest in building climate resilience and preparedness for rural New Zealand. 
Recommendation 20: That any interventions in the insurance market should be very carefully considered, including costs and benefits.