B+LNZ provided a submission jointly with Deer Industry New Zealand (DINZ) to the Ministry for the Environment as part of consultation on the exposure draft of the NPSIB legislation. Real-world examples from farmers and a report from an independent environmental consultant were important features of the submission.
B+LNZ chief executive Sam McIvor says the criteria relating to SNAs are a critical flaw. “The possibility of all areas of native biodiversity being captured will cause uncertainty, significantly erode farmer confidence and likely result in impacts on farmer wellbeing.
“Farmers have undertaken a huge amount of work on their land to protect and enhance native biodiversity and real momentum has built through farmers and catchment groups improving biodiversity outcomes over recent years.
“We have real concerns that the legislation wording as it stands will slow this momentum and farmers could become disengaged from the Government’s goals for biodiversity. That will lead to worse outcomes all round.
“SNAs have the potential to seriously impact what farmers can do on their land and with huge swathes of farmland covered in native biodiversity – the area of native vegetation on sheep and beef farmland is second only to New Zealand’s conservation estate – this has enormous ramifications for our industry.
“We have significant concerns about the policy around existing use, which is currently unclear in the legislation. The NPSIB must clearly articulate the ability for existing pastoral use to continue and provide for flexibility within farming systems in relation to existing use.
“Farmers are justifiably concerned about the very real prospect they’ll inadvertently be penalised for their hard work planting and protecting areas of native biodiversity when they’re no longer able to make decisions about the ongoing use of those areas.”
McIvor says it’s critical that landowners are involved from the start in the SNA identification process, and that SNAs are ground-truthed before being included in planning maps.
He says the burden of cost could fall on individual landowners and small communities, which is at odds with encouraging the maintenance of indigenous biodiversity. “Landowners should be incentivised, not penalised for this.”
In its submission, B+LNZ and DINZ sought for only the ‘most’ or ‘truly’ significant areas of indigenous biodiversity to be captured as an SNA and noted that while the supporting material stated this was the intent, the detail in the legislation didn’t match this and was much wider.
McIvor also notes that the policy as proposed doesn’t integrate well with other policies affecting land use and farming, such as climate and freshwater policy, and doesn’t promote the integrated management of biodiversity within farming systems.
“We’ve been saying this for some time – environmental policies need to be considered as an interconnected whole. The Government’s piecemeal approach will compromise the intended outcomes.
“Farmers understand their complex farming systems and how an action taken in one area can have an impact elsewhere. We need legislation that acknowledges that complexity and interconnectedness, rather than tying farmers up in trying to meet a raft of separate requirements.”
McIvor says that B+LNZ’s work to raise awareness of farmer concerns about the biodiversity legislation, in particular SNAs, will continue.
The submission and supporting documents are available on the B+LNZ website:
- NPSIB exposure draft submission July 2022 (PDF, 92KB)
- Review of SNA criteria by Element Environmental (PDF, 344 KB)
- B+LNZ and DINZ’s submission 14 March 2020 (PDF, 6MB)
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