Hearing Evidence – Brunner - Federated Farmers

50. In our submission, Federated Farmers sought the inclusion of an explanation to Rule
14 to the effect that: This rule is not intended to prohibit further development, but
requires the applicant to consider methods of reducing potential future phosphorus loss
into Lake Brunner. The 42A report recommended the Council accept this submission
at Decision Requested: 18.1.73. Federated Farmers appreciates this recommendation.
3.7 Rule 72 – Application of fertiliser
51. In submissions, Federated Farmers opposed in part amendments to Rule 72 to only
provide for application of fertiliser as a permitted activity, as part of land development in
the Lake Brunner catchment, if the solubility of the fertiliser is less than 10%. This very
low solubility makes Rule 72 very difficult to apply in the Brunner catchment because
10% is too low a solubility to support the rapid plant growth necessary for successful
land development, and to consolidate sediment. This is unnecessary given that land
development in the Brunner catchment is a discretionary activity under Rule 14.
52. In our submission we requested that provision for higher solubility fertiliser might make
Rule 72 more useful. The staff recommended the Council reject our relief sought at
Decision Requested: 18.5.9.
53. In further submissions, Federated Farmers opposed the submission of the Department
of Conservation, discussed at Decision Requested: 18.5.10, because the imposition of
farm plans across the region would be very difficult to enforce, and would be a severe
administrative burden for the Council, and would seek to address something that is a
non-issue according to water quality in the SOE report. The 42A report recommended
the Council reject this submission.
3.8 Rule – 83 Application of phosphorous fertiliser associated with Rule 14 in the
Lake Brunner catchment
54. In submissions, Federated Farmers sought that Council either removes condition (ii) of
Rule 83 or clarifies:
how the amount of fertiliser is to be defined;
how properties are to be established where boundaries change or lease
agreements are established;
how an annual average will be established in the absence of accurate records;
and;
how an appropriate bench mark period will be established given concerns with
the 2005 – 2010 years
Condition (ii) of Rule 83 is:
The average amount of phosphorous fertiliser applied per property per year is to
be no more than the annual average applied between 2005-2010.
55. No submissions were received in opposition of this submission.
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