Update on the essential freshwater consultations

While we’ve welcomed some of the proposed changes to the essential freshwater programme, we’ve been reviewing the consultation discussion documents and will soon be providing more detailed advice and guidance on making a submission. In the meantime, here’s an update.

What’s being consulted on

The Government is consulting on two aspects of the essential freshwater programme. They are seeking feedback on:

• proposed changes to the low-slope map in the stock exclusion rules, and
• the implementation and transition into the new freshwater farm plan system (including the content of plans, what outcomes could be achieved and how plans could be certified, audited and amended). 
• The two consultations are running separately but have the same timeframes. Farmers can provide feedback on one or both consultations by Sunday 12 September.
• See our initial reaction to the proposals in this media release. 

What B+LNZ is doing

We’ve been analysing the proposals in detail and will provide more insights via factsheets, available in the next couple of weeks.

We’re also working on detailed submissions to the two consultations, on behalf of sheep and beef farmers and following input from key stakeholders such as the B+LNZ Environment Reference Group. We intend to publish our submissions before the consultation closes so farmers can read them before making their own submission, if they choose to. 

Our advice to date on the low-slope map and freshwater farm plan proposals 

In terms of the proposed changes to the low slope map within the stock exclusion rules:

• The proposed changes are largely good news for farmers. The stock exclusion trigger has been changed from a 10-degree slope to a 5-degree slope (noting that farmers will still need to describe how they’re managing stock around waterways on 5- to 10-degree slopes), and an altitude limit has been introduced. 
• Thanks to everyone who provided feedback at the end of last year about the map’s inaccuracies – it made a real difference and the proposed changes are a direct result of this input. 
• We strongly suggest that farmers test the revised approach on their farm and provide feedback to MfE and B+LNZ if it is still not right. Specific examples from farmers may point to where regional councils need to have flexibility in applying the rules due to specific regional conditions. 
• There are areas we’ll be seeking changes on, and we’ll be spelling those out in our factsheet and submission.

In terms of the proposed freshwater farm planning, we’re still working our way through the large volume of complex information, but here are our high-level views so far: 

• We believe it’s good to have some clarity on the Government’s expectations. The proposal sets out what all parts of the process are and what each person in the chain has to do. 
• We have been advocating for plans be able to be completed by farmers, or as part of industry assurance programmes. The Government appears to have responded to some of our initial concerns.
• However, while the proposals contain a huge volume of information, we don’t yet have the detail of what needs to be included in farm plans. This is vital for us to make a proper assessment of what’s being proposed and we’re seeking clarity on when we will see and be able to comment on actual draft regulations. 
• We recommend that, because the proposals are high-level and the detail of what needs to be included in a farm plan will be included in guidance, anyone making a submission should ask for a further round of consultation on the regulations. 
• We believe farmers who have done a regulatory-based farm plan can make a real difference to this consultation by sharing their experiences – what went well, what could have been done better, what costs were incurred, challenges encountered, any ideas for how to minimise likely costs. 
• Our advice is that you don’t have to answer the questions exactly as set out in the consultation documents. Instead, you can comment on what it would be like from your perspective if all the preferred points were implemented. 
• We continue to share farmers’ concerns about how prescriptive the plans will end up being, the costs associated with certification and auditing, and the extent to which farmers’ personal or business information will become publicly discoverable. We will be making these points strongly in our submission.

What next

Keep an eye out for more detailed analysis in our factsheets, which we’ll be publishing in the next couple of weeks – we’ll email all our farmers about these and they’ll be available on a dedicated webpage. 

MfE and MPI are also running webinars you can tune into to find out more. Note that you need to register, and any questions must be sent through in advance (you can’t ask questions during the webinar). There’s more info and the relevant links in our recent Facebook post. 

We understand it’s a busy time of year for farmers so we don’t currently plan to run our own events relating to this consultation. However, we’ll reconsider this if required. 

We’ll also keep you updated about the detailed submissions we’ll be making. We’ll be looking to publish these submissions before the consultation closes, to provide another opportunity for farmers to draw on our advice in their own submissions. 

Timeline