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Hearing Evidence – Brunner - Federated Farmers

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62. In our submission on Policy 9.3.7, discussed at Decision Requested: 9.38, <strong>Federated</strong><br />

<strong>Farmers</strong> requested an amendment to the explanation to make it clear that the policy is<br />

non-compulsory in nature. The 42A report recommended Council reject this<br />

submission. We maintain that conventional wintering in the catchment may be the only<br />

practicable option for many, for example if market conditions result in shortage of land<br />

for winter grazing elsewhere, or biosecurity issues, (such as Tb) restrict stock<br />

movements.<br />

63. In further submissions, <strong>Federated</strong> <strong>Farmers</strong> responded the submission of the<br />

Department of Conservation (at Decision Requested: 9.37), who sought Rules to<br />

manage winter grazing. <strong>Federated</strong> <strong>Farmers</strong> members fear that ‘rules’ for winter grazing<br />

will result in excessive cost in light of the nature of the problem and concessions<br />

already made by farmers in the <strong>Brunner</strong> catchment. An obvious fear is that rules will<br />

involve requirements for ‘alternative’ wintering practices, such as wintering barns, to<br />

demonstrate reduced phosphorous loss. <strong>Federated</strong> <strong>Farmers</strong> seeks to avoid this<br />

outcome because wintering barns are very costly, and introduce technical complexity<br />

around animal welfare and diet which must be carefully managed. Furthermore,<br />

wintering barns encourage high intensity farming as farmers attempt to recover the<br />

cost, and take advantage of the ability of wintering barns to achieve efficient feed<br />

utilisation, and increase cow numbers on the milking platform. With future policy<br />

responses to stock wintering, the Council is better to avoid prescriptive policy<br />

responses, and focus on good wintering practice, and to ensure that solutions are cost<br />

effective and achieve good environmental outcomes.<br />

4. Other Matters<br />

4.1 Policy 4.3.6 <strong>–</strong> Council will require the use of bridges, culverts, and other<br />

methods where a farmers causes a herd of cattle to cross any river or<br />

permanently flowing creek, at any farm raceway, more than ten times in any<br />

month for herds larger than 500 cattle, or more than 20 times in any month for<br />

herds less than 500 cattle. A crossing is one-way only.<br />

This Policy also applies for dry stock where more than 50 animals cross any<br />

river or permanently flowing creek more than 20 times per month.<br />

63. <strong>Federated</strong> <strong>Farmers</strong> are pleased to see the recommendation to accept our submission<br />

and amend Policy 4.3.6 at Decision Requested: 4.17 of the 42A report. The suggested<br />

changes make sense and make the plan more coherent and easier to understand, and<br />

are fairer because cattle are treated equally with other stock types.<br />

64. <strong>Federated</strong> <strong>Farmers</strong> made further submissions on the submission from Fish and Game<br />

discussed at Decision Requested 4.18. This submission includes a request to extend<br />

controls on stock crossings to any situation where a farmer causes cattle to cross a<br />

‘river or permanently flowing creek’. In response to the submission of Fish and Game, it<br />

is not reasonable or efficient to require that every place where animals might<br />

conceivably cross a stream has a fence or a culvert. We support the 42A report which<br />

recommends the Council reject this submission.<br />

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