Update 23 September 2021: you can now view below our factsheet on the proposed changes to the intensive winter grazing regulations. Also available below is B+LNZ’s draft submission on the low-slope map for stock exclusion and freshwater farm plans – we’re making this available to farmers before the consultation closes on 7 October (note closing date has changed again from 26 September) so you can draw on our work for your own submission if you like.
The freshwater-related consultations are:
- changes to the stock exclusion low-slope map (closes 7 October) – see our submission, factsheet and info below
- certified freshwater farm plans (closes 7 October) – see our submission, factsheet and info below
- changes to the intensive winter grazing rules (closes 7 October) – see our factsheet and the info below
- changes to ‘wetland’ definitions and wider settings (closes 27 October) – more info below and read the Government’s proposals here.
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.
- This document is a draft and B+LNZ may make minor changes – we wanted to provide it early enough for farmers making their own submissions.
- B+LNZ is coordinating with DairyNZ and Federated Farmers on submissions and at a high level our positions are aligned.
- We will publish our submissions on the proposed changes to the intensive winter grazing regulations and on wetlands, but this is unlikely to be before those consultations close. If you want guidance, check out the factsheet on intensive winter grazing or the information below on wetlands.
|Proposed changes to the low-slope map for stock exclusion|
|Freshwater farm plans|
|Proposed changes to the intensive winter grazing regulations|
|How to make a submission|
Proposed changes to the low-slope map for stock exclusion
The Government has proposed changes that aim to address the identified inaccuracies of the low-slope map incorporated in the stock exclusion regulations, and is now seeking feedback on those changes. The changes include:
- 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 are 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 isn’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 now closes on Thursday 7 October.
You can find out more in the factsheet B+LNZ has 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 is consulting on proposals for how freshwater farm planning could become operational across New Zealand. A discussion document sets 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 is being 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 are also:
- encouraging 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)
- suggesting that farmers think about what freshwater farm planning would look like from their perspective if all the preferred steps outlined were implemented
- particularly interested in hearing from farmers with existing regulatory farm planning processes to inform our submission (or to make their own submission).
This consultation now closes on Thursday 7 October.
You can find out more in the factsheet B+LNZ has developed: The Government’s consultation on freshwater farm plans (PDF, 1.4MB)
For further details, visit MfE’s consultation page on the freshwater farm plan regulations.
Proposed changes to the intensive winter grazing regulations
The Government is also consulting 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 is proposing to change some of these criteria based on recommendations from B+LNZ and other stakeholders.
We welcome 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 closes on 7 October. You can access detailed information on the MfE website.
You can find out more in the factsheet B+LNZ has developed: The Government’s consultation on changes to the intensive winter grazing regulations (PDF, 243KB).
The Government is also proposing 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 will be making 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 is that unless farmers have specific concerns about the proposed changes, they don’t need to make submissions on this consultation. We’ll soon provide more detail on our submission – keep an eye on e-diaries.
How to make a submission
There’s detailed information in each discussion document on how to make a submission. In summary:
- it will need to be sent to the Ministry for the Environment through their consultation hub or,
- you can write your own submission (note that uploading a file of this in the consultation hub is preferred, and there are some requirements around what to include if you provide a written submission and around what format to use if you send your submission by email).
Remember to explain your reasons for any feedback you provide and include supporting evidence where appropriate.
You can also contact B+LNZ with feedback or if you need further support. Email firstname.lastname@example.org