Submission

Proposed National Environmental Standard for the Outdoor Storage of Tyres

Federated Farmers welcomes this opportunity to submit on the National Environmental Standard for the Outdoor Storage of Tyres. We acknowledge any submissions made by individual members of Federated Farmers.

EXECUTIVE SUMMARY

  • Federated Farmers is strongly supportive of appropriate measures which discourage tyre dumping and inappropriate stockpiling of tyres.
  • The proposed 200m3 limit will inadvertently capture 10-15% of farms across New Zealand or more, with some regions such as Southland, Otago, Mackenzie and Wairarapa having higher proportions of affected farmers than other regions. A 360m3 limit would still have significant impacts in many regions.
  • Federated Farmers strongly recommend that the outdoor storage of tyres for the purposes of silage preparation and storage activity is granted blanket exemption from the conditions contained within the NES.
  • Providing that the proposed blanket exemption for silage preparation and storage activities is granted, Federated Farmers support the proposed 200m3 permitted limit for the outdoor storage of tyres for other activities and similarly, the Discretionary activity status for volumes greater than 200m3 for other activities.
  • Federated Farmers strongly recommend that the recommended exclusion of tyres used for silage preparation and storage and the 200m3 permitted limit for other activities to be set as a true National Standard, unable to be amended by District Councils.
  • Federated Farmers is keen to be included in further discussions on this NES and other measures which will discourage tyre dumping and inappropriate stockpiling and encourage safe and economical disposal options.

For more information please see the full submission