The release of the Essential Freshwater Report, ‘Action for Healthy Waterways’ will undoubtable add further turbulence to an already stormy torrent of proposed Central Government policy effecting Regional Councils and land based industries.
The report’s stated intention is to ‘stop the further degradation of New Zealand’s Freshwater resources and start making immediate improvements so that water quality is materially improving within 5 years’. The reference to immediacy is no idle threat, with Regional Councils being expected to comply with many of the proposals by June 2020.
No one can argue with the intent of the report, and few would negate the importance of prioritising our greatest natural resource, however the scope and likely implications of the report will be a topic of much discussion in the coming weeks and months.
The report scope encompasses everything from storm water to drinking water, vegetable growing and most obviously, farming. The incorporation of the report’s recommendations into current National Policy Statements on Freshwater Management, National Environmental Standards for Freshwater, Sources of Drinking Water, Storm Water, and section 360 regulations clearly spells out the Government’s intention to direct and regulate local activities to a much greater exent than has occurred in the past.
The implications for Regional Councils are significant, with proposed mandatory bottom lines being enforced for contaminants such as nitrogen, phosphorus and sediment, in an environment where fewer that half of councils have yet to give full effect the current National Policy Statement on Freshwater Management. This brings into question their capacity to deal with the scope and speed of the proposed changes, as has rightly been highlighted by the Freshwater Leaders Group.
The proposed rule changes would see a complete restriction on the draining of wetlands, mandatory recording of wetlands at a regional level and the compelled protection of existing wetlands. Regulations around stock exclusion will also expand to include all waterways greater than 1 meter wide on flat to gently rolling land (the definition of rolling land is still being discussed) and mandatory Farm Environment Plans which will be required to detail and plan for the fencing of further waterways less than 1m in width.
Waterways will also need to be fenced in areas where stocking rates exceed 14 stock units per hectare at a farm scale or 18 stock units per hectare at a paddock level. The means of determining these thresholds will potentially have huge implications for rotational grazing systems, especially in the typical ‘autumn clean up’ scenario where cows are used to remove rank pasture and improve pasture quality.
Intensive winter grazing will require a resource consent if the cropped area exceeds a certain size or proportion of the total farmed area and if any of the yet to be developed ‘National Standards’ can not be met.
However in a regional context by the far the most ominous of all the proposed new rules is one that would limit the intensification of land use, as by 2025 it is envisioned that regional plans will prevent intensification, identified as increased stock carrying capacity of land through increased fertiliser use, stocking rates or irrigation, unless evidence can be provided that the intensification will not result in increased pollution.
For a region where extensive land use is the norm, and where we are currently being encouraged to retire our marginal land and focus on improving the better classes, this limitation has the potential to stall farm productivity gains. The proposals suggest that a change from beef and sheep grazing to dairy support would require a resource consent. The intensification rule also captures cropping and proposes that farms only be permitted to crop the same area customarily cropped within the last five years. Vegetable growers are similarly captured, with extending vegetable and arable cropping areas also coming under the requirement to apply for resource consent.
The implications of such a limitation will leave many farmers and growers feeling frustrated and possibly angry, as it fails to recognise the fact that farming intensity changes with farm business maturity, and the family lifecycle of those on the land.
To lock a farming operation at a single point of time is ill-conceived and fails to provide the adaptability which has enabled farmers to increase their efficiency off an ever lower physical footprint for the last few decades.
The point must be made however, that this report is presented as a discussion document, albeit one from which major players such as the levy bodies and Federated Farmers where excluded, and as such we now have the opportunity to contribute submissions and help shape the regulations in their final form.
There is no doubt that many in the farming community will be fed up with submitting on what feels like an ever increasing mountain of regulations, however we know that this document was drawn from a select group of handpicked individuals, and to have any chance of giving it some balance, our voices must be added to it.
Kerry Worsnop, East Coast Farmer