Submissions

Marlborough Environment Plan Process

We are currently in the hearing process - this will be spread out across 2018. We will be loading hearing documents and statements here throughout the process 

Key Recommendations:

  • That the Plan is amended to enable the ongoing social, economic and cultural wellbeing of the district through the valued contribution of primary production; and
  • That Council ensure that any resource management decisions are based on sound consideration of economic and social costs to farmers and the wider community; and  
  • That Council review the use of an onerous regulatory approach that will burden primary production with unnecessary constraints; and  
  • That Council commit to a partnership approach of working with landowners, the community and industry to maintain and where necessary, further enhance the region’s natural resources.

General Comments

The primary purpose of the Plan is to provide for the sustainable management of Marlborough’s natural and physical resources, by providing an overview of the resource management issues facing the region, and setting policies and methods to manage its natural and physical resources.

In delivering on this overall purpose the Plan must seek to deliver on all of the four wellbeings in a sustainable manner, including economic and social wellbeings. Currently the economic benefits derived from natural resource use within the Plan is has not been given appropriate recognition. The Plan should provide for natural and physical resource use to achieve economic and social wellbeing, provided that these resources are used in such a way that ensures the potential of these resources are sustained for future generations, and the life-supporting capacity of ecological systems is retained or restored.

Federated Farmers’ view is that a region rich in economic, social and cultural terms is more able to deliver good environmental outcomes. From a farming perspective, economically viable farmers are best placed to afford mitigation, offsetting or investment in environmental ‘least cost’ options. To address these concerns the Plan should recognise and provide for good economic and social outcomes by avoiding the imposition of unnecessary restraints on primary production; specifically providing for the positive aspects of primary production where reasonable and appropriate; explicitly stating the importance of the primary production sector to achieving the desired outcomes.

While the This Plan sets out a narrow and restrictive regulatory approach, lacking any concrete analysis or costings, threatening private property rights and misunderstanding farm practicalities. It has the potential to come at a significant cost to the generosity and good will of the farming community that strives for environmental improvements over generations of farming.

We register our strong opposition to this approach. There are real risks that it will not achieve the desired outcomes of maintaining and improving our physical and natural resources. It is our strong submission that boldness is required from Marlborough District Council moving forward. Council can choose to adopt this Plan as notified, or to make amendments, and follow on with a partnership approach, building on the relationships developed with stakeholders; a much more strategic and enduring partnership approach that will build on the shared values and past partnership programmes, including the Rai Valley and SNA programme.

Acknowledging that resource quality is reasonably good and reasonably stable, we can agree that our first expectation is overall maintenance. In the context of maintaining current state, we support a clear, concise regulatory framework which safeguards bottom lines for water quality, protects us against going backwards, and which prioritises and discourages activities where there are significant adverse effects.

We see a place for continually building a picture of the state and trends within the Marlborough region. We see a place for acknowledging the need for improvements with time frames provided to do so, where there is an evidenced need for improvement. This will be driven and decided by the community discussion around values which will happen through collaborative processes at the catchment level.

We can also agree that we have pressures and hotspots and that these should be prioritised for improvement through collaborative work. It is here that Federated Farmers sees a place for Council to work in partnership with landowners, the community and industry. Improvements will not be driven by onerous regulatory regimes, but by Council investing resources to work collaboratively with communities.

We see a place for continually building a picture of the state and trends within the Marlborough region. We see a place for acknowledging the need for improvements with time frames provided to do so, where there is an evidenced need for improvement. This will be driven and decided by the community discussion around values which will happen through collaborative processes at the catchment level.