Hearing Evidence – Brunner - Federated Farmers

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of the proposed rules in section 9 of the proposed plan. Again the SOE report is helpful 1 : 16. Finally we would like to add that the Council have not determined the relationship between land practices and critical waterbody phosphorus concentrations at which significant adverse effects occur, as noted in the submission of Fert Research discussed at Decision Requested 9.19. There are a range of phenomena, not related to agricultural activities, that might contribute to the changing state of Brunner, including discharges associated with land slips and erosion, and septic tank discharges from settlements on the shores of the lake. 17. To conclude this section, Federated Farmers do not accept that stringent controls on phosphorous use are necessary, particularly in light of farmer acceptance of good management practices to achieve improved management of nutrients and better farm efficiency. Levels of dissolved reactive phosphorous (phosphorous that is available for utilisation by algae) are stabilised or in decline, and there is no proven link between land use practices and the supposedly declining state of the lake. 2. The economic and social implications for Lake Brunner farmers and the wider region. 18. In our submission at section 6.6, Federated Farmers requested that Council fully consider the financial implications to farming businesses in the Lake Brunner Catchment, as required by the RMA, under the proposed Lake Brunner Special Area provisions. At Decision Requested: 9.5 the 42A report recommended accepting this 1 West Coast State of Environment Report 2011. Page 41. ‘Lake Brunner DRP 1992 – 2011 4
submission, with the comment that Council is sensitive to the fact that some of the provisions within the Plan will result in financial implications on Lake Brunner landowners. 19. At Decision Requested: 9.6 the 42A report recommends the Council accept in part our submission and insert a non-notification clause in Rules 83 and 84, which will make the plan more efficient to administer. This is appreciated, but Federated Farmers also ask that the Council consider not applying resource consents fees on consents required under new provisions for the initial three years of the plans life, in recognition of the benefits to the wider community and the costs to the individual farmers. This is a fair point in light of the lack of evidence of a causal link between agricultural activities and changes to the state of the Lake as described in part 1. 20. Federated Farmers has included some comments on economic and social effects to assist Council decisions. The information that follows is relevant to all decisions that potentially affect land value and ability to farm profitably, particularly within more sensitive areas such as the Brunner Catchment as acknowledged at Decision Requested: 9.18. 21. Our submission notes that restrictive plan provisions can undermine farm values, and stifle economic activity. Economic effects on the wider community and implications for the ‘ethic of stewardship’ are also relevant. These concerns link to the purpose of the RMA described in section 5, and the ‘efficiency and effectiveness’ tests specified in section 32. Implications for farm value 22. We have invited Dave Becker, a local real estate agent experienced in rural sales, to comment on the relationship between saleability or value of properties and the developing response of the Council to water quality in Lake Brunner. We think Dave has insights that will be helpful to the Council and will ask him to talk about this aspect of our evidence at the hearing. Economic and social implications for the wider community 23. In addition to adverse effects on individual farm businesses, limiting farm production, either directly through nutrient limits, or indirectly through the creation of uncertainty or disincentives to investment, will reduce economic and social benefits to the community that would otherwise result. 24. For example the model Southland dairy model farm, a 579 cow farm, showed farm working expenses for the 2010/2011 year of $746,935, or $1290 per cow. 2 Most of 2 There is no model available for the West Coast, but we think these figures are representative. Model farms are compiled from figures averaged across a number of ‘monitor farms’ in the region. The source for these figures is Farm Monitoring Report 2011 – Pastoral Monitoring: Southland Dairy. [Online] http://www.mpi.govt.nz/newsresources/publications?title=farm%20monitoring%20report 5
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Hearing Evidence – Brunner - Federated Farmers

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