Hearing Evidence – Brunner - Federated Farmers

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Department of Conservation Change fencing distance from the waterway from 1 metre to 3 metres. Decision Requested: 18.1.56 10 Implement Policy 9.3.5 region-wide - Decision Requested: 9.29 41. We see the relief sought by the above submitters as unnecessary and unreasonable in consideration of the overall broad judgement of likely environmental benefits against economic and social cost to farmers and the wider community. We therefore support the recommendations in the 42A report to reject these submissions. 42. In regard to requests to extend the 1 metre buffer within the Lake Brunner catchment up to 10 metres, or to extend stock access provisions for Lake Brunner to the remainder of the region, we note that: Very substantial areas of land will be lost to production, for little environmental improvement in terms of the actual state or health of the receiving water body. Due to the potential loss of land and social and economic effects that might arise if the Council were to accept further submissions, we question the recommendation in the 42A report at Decision Requested: 9.30 to reject our submission on possible costs of Policy 9.3.5; outside the Brunner catchment, water quality is good or getting better in all surface water bodies, which suggests that increased regulatory intervention is not necessary; compared to other parts of New Zealand, West Coast farms are relatively smaller and with lower stocking rates; stock exclusion can be very difficult to achieve on dry stock properties where a permanent 7 wire fence is required to stop stock, land may be steep with numerous intersecting streams and ephemeral watercourses, and where farmers often rely on natural flowing water for stockwater. Dry stock properties are also generally farmed less intensively than dairy farms, with lower densities of animals that can impact on creeks; pest plants are a major problem on ungrazed land on the West Coast, and this will be no different in riparian areas. Controlling these, or managing an effective transition to native vegetation often results in much higher costs than building a permanent fence in the first place; stock exclusion can result in lack of access to maintain creek beds, which will result in enhanced flood risks.
3.5 Policy 9.3.6 – To reduce the loss of phosphorous to Lake Brunner associated with the intensification of land, by managing phosphate fertiliser use in the catchment so that no net increases in annual use occurs per property. 43. As notified, Policy 9.3.6 will likely create problems with equity between farmers and unnecessary complexity as phosphorous fertilizer (P) use on farm land in Brunner is be pegged to past levels (grandparenting). Federated Farmers are particularly concerned about the phrase ‘so that no net increases in annual use occurs per property’, at the end of the Policy. 44. Work undertaken in the Taupo catchment 4 has found that grandparenting results in farms with historically high nutrient use finding it much cheaper to cap at current levels than farmers who have not. This study found that reducing nitrogen leaching on the more intensive farm could cost between $3.41 and $14.70 per kilogram. For the less intensive farm the cost was between $52 and $84 per kilogram. These figures apply to caps on nitrogen, but the implications for caps on P use are very similar. 45. Grandparenting has particularly serious implications for farms that have used debt to grow their business. Farms that are able to demonstrate a historic pattern of relatively high P-use will be able to provide certainty to lenders that they can continue to farm profitably, while farms that have used relatively low levels of P (and low environmental impact) will not and will suffer substantially both in terms of reduced bankable value (but not debt) and reduced access to credit. 46. With grandparenting, development may still be possible, but will be very costly, because extensive investigative work, farm plan preparation, and monitoring will be required to demonstrate a net increase in phosphorous-loss, and there is no evidence that this will make any difference to the lake or is even necessary from an environmental point of view. 48. Policy 9.3.6 is also inconsistent with subsequent methods which confine limitations on phosphorous use to land developed since 1st January 2011. This is confusing because the intent of the council (the policy) is not consistent with specified actions (i.e. rules). 49. In further submissions we support the submission of Fert Research on Policy 9.3.6, which is discussed at Decision Requested: 9.36 of the 42A report. We see the change recommended by staff as an improvement to Policy 9.3.6 that increases clarity and focuses the policy on land development, rather than ‘intensification’, which could apply to virtually any increased use of fertiliser over historic levels. 3.6 Rule 14 – Humping and hollowing, flipping, v-blading, or contouring in the Lake Brunner catchment 4 Review of Implications of nutrient caps on New Zealand’s agriculture. N Hoogaveen. Completed April 2006 [Online] http://www.fertresearch.org.nz/research/research-results/completed-research 11
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Hearing Evidence – Brunner - Federated Farmers

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