Submission on Proposed Plan Change 5 to the Canterbury Land and Water Regional Plan
Federated Farmers has two significant concerns with the process undertaken by Environment Canterbury during this Proposed Plan Change.
The first relates to the quality and appropriateness of the Proposed Plan Change’s Section 32 report. In particular, Federated Farmers considers the report fails to adequately assess the potential and likely costs of the un-validated Farm Portal proxies within the Proposed Plan Change provisions, as is required under the Resource Management Act (RMA). In short, we do not feel the requirements of Council under section 32 have been met and we ask that a higher level of analysis is undertaken.
Our second significant procedural concern relates to the rushed timeframes for the development of, and submissions on, Plan Change 5.
We do not feel that the adoption of the absolute minimum timeframe provided for under the RMA is appropriate for this large, complex and crucial plan change. A number of key issues material to the practical farm-level implications of the planning proposals are yet to be determined, in particular with regard to both the robustness of the Farm Portal and the proxies contained within it.
We have real concerns that stakeholders will not have sufficient time or opportunity to undertake appropriate user-testing, and this is likely to have serious workability consequences. The modelling proxies, as currently written in the MGM overview report (MGM, 2015b), do not meet the regulatory requirements for a regional plan and will require additional plan amendments. This makes it very difficult for a submitter to have confidence that what they’ve submitted on will reflect the final situation or that the concerns they’ve raised can realistically be addressed prior to implementation of the plan at farm level.
For more, see the submission, further submission, and hearing documents