From late May to late July, the Government consulted on changes to a range of national direction instruments, which will ultimately affect farmers though regional council plans and other rules.
The consultation is now closed. You can read the submission we made here (PDF,
939 KB).
What was consulted on
The consultation covered national direction instruments across four packages:
- Infrastructure and development
- Primary sector
- Freshwater
- Going for Housing Growth.
Proposals included changes to freshwater policy frameworks that councils use when setting targets, timeframes and rules; and changes to national rules such as stock exclusion, wetlands and water storage.
For further information about what was consulted on, see the ‘More information on the proposals’ section below.
B+LNZ’s views
We are pleased to see what the Government’s options are for addressing some of the RMA regulations that are hugely problematic for sheep and beef farmers.
Across the wide range of topics, B+LNZ’s views are correspondingly wide-ranging. Some of the proposals need to go further to make the regulations fit for purpose, while a few of the proposals need to be pushed back on.
Where you can find out more
- The Ministry for the Environment website.
- B+LNZ held two webinars (on 8 and 10 July) to outline what was proposed, share our views, and gather feedback. View the B+LNZ recorded webinar about RMA National Direction here.
More information on the proposals
Following is the guidance we gave to farmers during this process. See also our submission (PDF,
939 KB).
General information
National direction sets national resource management policy and rules that inform regional and local plans, policy statements and resource consent decisions. It includes national policy statements, national environmental standards, and section 360 regulations.
Regional councils will be required to ‘give effect’ to these national direction instruments. This means the outcome of this work will affect farmers through regional council rules and plans – so it’s important that we influence these to get them right.
This diagram (PDF, 28.5KB) explains what national direction instruments are, and how legislation flows from overarching laws down to on-farm rules.
If B+LNZ can successfully influence the Government at a national level, our sector will be in a much stronger starting position when the regional council plans are drafted.
Because the consultation is wide-ranging and highly technical in places, we’ll focus our efforts on the topics that will have the greatest impact on farmer profitability and productivity. These are:
- National Policy Statement for Freshwater Management/National Environmental Standards for Freshwater Management:
- freshwater management through multiple objectives
- Te Mana o te Wai
- National Objectives Framework
- commercial vegetable growing
- water security and water storage
- wetlands
- fish passage regulations
- synthetic nitrogen fertiliser use
- Stock Exclusion and Wetland Regulations:
- standards for activities such as fencing, irrigation, wetland construction
- wetland management
- grazing intensity definitions
- National Policy Statement for Highly Productive Land.
B+LNZ will also be asking for the Government to consider changes to the National Policy Statement for Indigenous Biodiversity, and in particular, amending the definition of Significant Natural Areas so that it only captures truly significant biodiversity. This is not part of the Government’s current consultation package.
B+LNZ is asking for farmer feedback and practical examples of how the proposals will affect people on the ground.
We’ll be holding two webinars to outline what’s proposed, our views, and to gather your feedback. For information and to register, go to the Events page on our website.
We’ll also be running small focus groups with farmers.
Specific proposals
The Government’s proposals as part of the primary sector package:
- Removing LUC 3 land from the NPS-HPL – meaning this land would not be protected by the NPS from urban development.
- Testing alternative ways to protect additional areas of agricultural land that are important for food and fibre production, and consulting on establishing ‘special agriculture areas’ around key horticulture hubs like Pukekohe and Horowhenua.
Our initial response:
- All sheep and beef land is productive land, regardless of whether it’s intensive or extensive, LUC 1 or LUC 7.
- The importance of sheep and beef land cannot be overlooked or undervalued. Farming classes are interconnected with extensive hill and high-country properties being vital breeding country that supplies more intensive, flat finishing farms throughout multiple regions.
The Government’s proposals as part of the primary sector package:
- Amending the stock exclusion regulations so that non-intensively grazed beef cattle and deer no longer need to be excluded from wetlands that support threatened species.
Our initial response:
- Excluding stock from natural wetlands in non-intensive farming systems is challenging and not cost effective. In some cases, grazing can enhance wetland values by keeping weeds at bay.
- There are challenges with defining ‘non-intensive grazing’. Farm Plans may provide a more flexible and risk-based approach for when stock exclusion from wetlands is appropriate.
The Government’s proposals as part of the freshwater package:
- Adding new objectives to the NPS-FM to rebalance how freshwater is managed. These would not operate as a hierarchy: Safeguard the life-supporting capacity of freshwater and the health of people and communities while enabling communities to provide for their social, cultural, and economic wellbeing, including productive economic opportunities.
- Requiring councils to consider the pace and cost of change, who bears the cost, trade-offs, and the timeframes that change is expected to occur.
- Te Mana o te Wai. The government has proposed multiple options to rebalance Te Mana o te Wai; including removing the concept completely from the NPS-FM, reinstating the 2017 version, and keeping Te Mana o te Wai as a concept but removing the hierarchy of obligations.
- Options to change which water quality attributes (E. coli, nitrogen, sediment etc) should be compulsory or optional for councils to manage and set limits for.
Our initial response:
- This work defining how freshwater is managed is a positive step to better reflect the interests of farmers as well as the rural community, and for recognising the crucial role that water for farming plays in powering New Zealand’s economy.
- Currently the NPS-FM is complex, often impractical and focused on unachievable numeric limits rather than the health of ecosystems.
- Since the release of the Torlesse report commissioned by B+LNZ last year, we’ve made it clear that there needs to be a rethink about how we approach freshwater policy. Rules need to better account for natural processes, better accommodate different land uses and provide more realistic targets and timeframes.
- Suspended fine sediment and E. coli national bottom lines are fundamentally flawed and need to be urgently changed before regional freshwater plans become operative based on trying to achieve them.
- A community-driven, targeted, and risk-based approach is needed. Every river is different and will respond differently to different actions, therefore we do not believe one-size-fits-all national bottom lines are appropriate.
- The farming sector and rural communities need robust, inexpensive and uncomplicated frameworks for freshwater that deliver more reasonable, affordable and enduring outcomes.
The Government’s proposals as part of the freshwater package:
- Consulting on providing new direction to councils through the NPS-FM to address water security as part of climate change resilience.
- Whether to develop new national standards that permit the construction of off-stream water storage.
Our initial response:
- Making it easier to build on-farm water storage is critical to help farmers be more resilient to droughts.
- However, the major barrier is often not building the dam but gaining consents from regional councils for taking water and getting a long consent term to give investment and funding (e.g. from banks) certainty.
The Government’s proposals as part of the freshwater package:
- Clearer and more workable definitions for wetlands by defining ‘induced wetland’ and defining ‘wetland construction’.
- Removing the 50 percent pasture exclusion from the definition of ‘natural inland wetland’ and instead permitting more farming activities to occur in and around wetlands.
- Encouraging wetland construction and edge of field mitigations.
- Removing the requirement for councils to map natural inland wetlands.
Our initial response:
- Any regulatory requirements need to reflect the true risks of contaminant losses and declining biodiversity.
- Induced and constructed wetlands should not be subjected to the same rules as natural wetlands.
- Wetland maintenance activities are integral to ensuring restoration efforts provide ecosystem, sediment and nutrient capture, and other benefits.
- The use of Farm Plans as a tool for managing stock exclusion from natural wetlands may be able to balance costs, pest control and wetland protection.