Additional freshwater consultations – low-slope map changes, freshwater farm plans, intensive winter grazing changes, and wetlands.
This page contains information about consultations, announced by the Government in July and August 2021, as part of the Essential Freshwater work programme. Public feedback is being sought on a range of proposed changes and approaches. We’ll keep this page updated.
Update 12 July 2022: these submissions were all closed by October 2021. We’ve published our submissions below – including an additional one on the wetlands regulations that closed 10 July 2022 – and you can still view the resources we created for your information.
The freshwater-related consultations are:
- changes to the stock exclusion low-slope map (closed on 7 October) – see our submission, factsheet and info below
- certified freshwater farm plans (closed on 7 October) – see our submission, factsheet and info below
- changes to the intensive winter grazing rules (closed on 7 October) – see our submission, factsheet, submission template and the info below
- changes to ‘wetland’ definitions and wider settings (closed on 27 October) – see our submission and the info below.
Farmers can provide a submission on any or all of the freshwater consultations.
For information about the earlier consultation about the essential freshwater reforms, see this page: Essential Freshwater Consultation.
Note that B+LNZ is working with DairyNZ and Federated Farmers on ensuring our positions and approaches align across all these consultations.
Submission documents
B+LNZ, DINZ AND NZDFA SUBMISSION ON INTENSIVE WINTER GRAZING (PDF,712KB)
B+LNZ’S SUBMISSION ON THE WETLANDS CONSULTATION OCTOBER 2021 (PDF, 671KB)
B+LNZ’S SUBMISSION ON THE WETLANDS REGULATIONS JULY 2022 (PDF, 506KB)
Proposed changes to the low-slope map for stock exclusion
The Government proposed changes that aimed to address the identified inaccuracies of the low-slope map incorporated in the stock exclusion regulations, and sought feedback on those changes. The changes included:
- use of a new mapping approach
- changing the stock exclusion trigger from a 10 degree slope to a five degree slope
- new requirements around managing stock within freshwater farm plans in some instances
- the introduction of a 500-metre altitude threshold.
While B+LNZ recognises the Government’s efforts and acknowledges the new map is better than the original, it is still flawed and our view is that an alternative approach is needed. This view is in line with other agricultural groups, including Federated Farmers.
Farmers were encouraged to test the revised approach on their farm and provide feedback to the Ministry for the Environment (MfE) and B+LNZ if the low-slope map still wasn’t right – specific examples from farmers will assist our argument for replacing the mapping approach with a slope trigger rule or may point to where regional councils need to have flexibility in applying the rules due to specific regional conditions.
Note that this consultation closed on Thursday 7 October.
You can find out more in the factsheet B+LNZ developed: The Government’s consultation on proposed changes to low-slope map for stock exclusion regulations (PDF, 5.3MB)
For further details, visit MfE’s consultation page on the low-slope map changes.
Freshwater farm plans
The Government consulted on proposals for how freshwater farm planning could become operational across New Zealand. A discussion document set out how a freshwater farm plan could be developed, implemented and audited, and what high-level information could be required in a farm plan. Feedback was sought across all these aspects.
Overall, we still have significant concerns about using farm plans as a compliance tool. While the content in the discussion document generally aligns with many of B+LNZ’s positions and advocacy work aimed at providing practical solutions within the farm planning space, the content is relatively high-level and the devil is always in the detail. We need to see the detailed regulations on the farm plan to be able to make a proper assessment. B+LNZ is very much aligned with DairyNZ and Federated Farmers in these views and we all will be seeking further clarification. We also:
- encouraged farmers to ask for assurances that there will be further opportunity to comment on the proposed regulations once they have been drafted (especially the detail of what goes in a freshwater farm plan)
- suggested that farmers think about what freshwater farm planning would look like from their perspective if all the preferred steps outlined were implemented
- were particularly interested in hearing from farmers with existing regulatory farm planning processes to inform our submission (or to make their own submission).
This consultation closed on Thursday 7 October.
You can find out more in the factsheet B+LNZ developed: The Government’s consultation on freshwater farm plans (PDF, 1.4MB)
Read B+LNZ's submission on the Certified Freshwater Farm Plans Regulations and Stock Exclusion Regulations: Proposed changes to the low slope map (PDF, 3.6MB)
For further details, visit MfE’s consultation page on the freshwater farm plan regulations.
Proposed changes to the intensive winter grazing regulations
The Government also consulted on proposed amendments to the intensive winter grazing regulations. These regulations require farmers who are undertaking intensive winter grazing to comply with certain criteria if they don’t want to apply for a resource consent.
The Government proposed changing some of these criteria based on recommendations from B+LNZ and other stakeholders.
We welcomed the move to more practical management approaches, as shown by the removal of the unworkable pugging depth and sowing date rules. However, we have several areas of remaining concern or comment around:
- the revised 10-degree slope rule for winter grazing
- how the certified freshwater farm plan process relates to winter grazing
- the importance of industry groups being involved in developing the ‘further guidance’ referred to in the discussion document.
This consultation closed on 7 October. You can access detailed information on the MfE website.
You can find out more in the factsheet B+LNZ developed: The Government’s consultation on changes to the intensive winter grazing regulations (PDF, 243KB).
We also provided this template to help farmers write their submission: Consultation on changes to the intensive winter grazing regulations (WORD, 161KB).
Read the B+LNZ, DINZ and NZDFA submission on intensive winter grazing (PDF, 712KB).
Wetlands
In 2021 the Government also proposed some changes to the rules under the National Environmental Standards about what defines a ‘wetland’ and what activities can be undertaken in and around these areas. The proposals to change the definition of a ‘wetland’ can have significant implications for what areas on farms need to be protected and how this is done. Some of the other content proposed isn’t very relevant to sheep and beef farming activities (as it covers things like mineral mining and urban development).
B+LNZ made a submission on:
- The proposed new definition of ‘natural wetland’. This is much clearer but we have some questions around specific details.
- The proposed changes that better enable restoration, maintenance and biosecurity work. We support making these activities easier and will be commenting on aspects such as the need for consistency, recognising the wider values of wetlands (for freshwater health, climate resilience and biodiversity outcomes) and therefore the need for an integrated view across policies.
Our advice was that unless farmers had specific concerns about the proposed changes, they didn’t need to make submissions on this consultation.
Read B+LNZ’s submission on the initial wetlands consultation (PDF, 672KB)
The Government’s proposals were here.
On 31 May 2022 the Government released an exposure draft of proposed changes to the NPS-FM and NES-F that included the new wetland regulations. B+LNZ made a submission on this, noting we still have a number of concerns – primarily relating to:
- how the scale of given wetland is determined, and
- the treatment of ‘induced’ wetlands.
We also asked for further involvement and guidance on the definition of ‘pasture’ and the implementation of these requirements.
Read B+LNZ’s submission on the exposure draft of the wetlands regulations (PDF, 506KB)