Beef + Lamb New Zealand (B+LNZ) and DairyNZ support freshwater farm plans, in principle, however clarity is needed on how the rules fit with broader regional and catchment planning and consenting, and opportunities for industry assurance programmes and catchment collectives.
Requested changes are outlined in the organisations’ submissions, now available online. The government’s consultation on proposals for the design of freshwater farm plans and stock exclusion regulations (changes to the low-slope map) close on Thursday, October 7.
“Our concerns include how freshwater farm plans will be used and rolled out, the role of existing farm plans, certification and auditing, how farm plans relate to regional plans and sensitivities on what happens with the data,” said DairyNZ strategy and investment leader – responsible dairy, Dr David Burger.
“The plan’s purpose and relationship with regional rules needs greater clarity. Our view is that freshwater farm plans should take all farmers to good practice. Where further reductions are needed to support freshwater objectives, that’s the role of regional limit setting processes.”
Both B+LNZ and DairyNZ support freshwater farm plans to improve water quality.
Nearly half of all dairy farms have comprehensive, auditable Farm Environment Plans, prepared with a qualified advisor. Half of all sheep and beef farmers also have farm plans.
Four years ago, the dairy sector committed in its Dairy Tomorrow strategy for all dairy farms to have a plan by 2025 – progress is well on track to achieve that. B+LNZ committed in their Environment Strategy launched in 2018 in working toward all farmers having an industry farm plan by 2025.
B+LNZ chief executive Sam McIvor says there are concerns about farm plans as a compliance tool.
“Farmers need to be directly involved in developing farm plans to build understanding and ownership. There is a strong risk certified freshwater farm plans will be overly prescriptive and will lose their value to farmers – that would be a massive lost opportunity. We also have concerns about the costs farmers will face,” said Mr McIvor.
“Farmers have already invested significantly in farm plans and we ask that this investment is not lost, or compromised.”
DairyNZ and B+LNZ don’t want the rules to fundamentally change the role of farm plans.
“Freshwater farm plans need to be practical, active and focused on on-farm risks. The rules currently written could inadvertently undermine some core benefits of farm environment planning,” said Mr McIvor.
DairyNZ and B+LNZ ask Government to work closely with sector bodies as it develops the rules.
“What is currently proposed is relatively high-level. We need to comment on the detail, including guidance material and the role of existing farm plans and certification/auditing, to understand the relationship of freshwater farm plans and regional planning requirements,” said Dr Burger.
“Government must work with the primary sector to ensure the rules are practical and workable on the ground – and achieve the right environmental outcomes.”
DairyNZ says freshwater farm plans are an effective tool to achieve freshwater quality outcomes – but must be alongside regional and catchment planning and consenting, and other national environmental standards. Clarity is needed between the two approaches.
For example, DairyNZ and B+LNZ believe effects of winter grazing can be managed through a freshwater farm plan, rather than permitted activity conditions or resource consent.
In addition, B+LNZ acknowledges the new low-slope map for stock exclusion is generally better than the original but concerns do remain. “We would like to see more discretion given to regional councils for flexibility, in order to better achieve results in diverse farming landscapes,” said Mr McIvor.
Farmers are urged to get submissions in before the consultation closes on 7 October.
B+LNZ’s draft submission is online to help inform farmers’ own submissions – read B+LNZ's submission here.
DairyNZ has published its key concerns and the full submission. Farmers are encouraged to use these documents for their own submission. Visit: Farm Environment Plans - DairyNZ
For more information, please contact DairyNZ’s Vanessa Feaver on 027 836 6295 or B+LNZ’s Katie Jans on 027 838 6353.