Hearing Evidence – Brunner - Federated Farmers

More documents

Recommendations

Info

these expenses are sourced locally and relate to labour, contractor and professional fees, bought in feed, and other local services. Using the Southland model as a guide, we estimate that the increase of 5250 cows milked on the West Coast reported in the 2011/2012 year, represents an additional $6,777,500 in farm working expenses, the majority of which directly enters the local economy. Added to the benefits generated on-farm, almost all milk produced on West Coast Farms is processed locally at Westland Milk products, a major employer in the region. In other words, reducing opportunities for farm production, has a directly proportional effect on jobs and opportunities for enterprising West Coasters. Relationship between impacts on farm values and stewardship 25. Methods that undermine farm value, will also undermine the sense of ownership of farms and environmental issues related to them. This is important because voluntary methods and facilitating behavioral change have already proven very valuable in managing nutrient inputs to Brunner and are an aspect of the ethic of stewardship, which the Council is required to ‘have particular regard to’ under section 7 (aa) of the RMA. We think that the following from the section 32 report for the proposed Land and Water Plan, produced at the time of notification fairly reflects the value of voluntary action in improving farm practice in the Lake Brunner catchment: Farm plans had been developed with farmers in the catchment in 2005. These were a non-regulatory approach to improving systems of which some farmers had implemented the recommended best practice. Good work was undertaken by landowners through the installation of fencing and bridging, but unfortunately not everyone participated in this project. With new landowners in the catchment and changes in policy proposed, a review of these plans would provide new opportunities for reducing adverse effects on the environment through current farming practice. This method is seen as a positive approach towards identifying and working with landowners to come up with solutions and timeframes for putting in place best practice systems which not only benefits the landowners, but also has a positive environmental benefit. It is also another opportunity for farmers to demonstrate the value of non-regulatory tools in achieving positive change. 26. Contrary to the submission of Fish and Game discussed at Decision Requested: 9.54, we see farm plans and education as effective in achieving improvements. Widespread support for improved effluent management, stock exclusion and stock crossings to reduce P loss are evidence of the ability of farmers to change once properly equipped with appropriate information. 6
3. The proposed policy framework for the Lake Brunner catchment 3.1 Objective 9.2.1 – To improve the water quality of Lake Brunner by managing the adverse effects of activities in the catchment to reach an average water clarity of 5.3m by 2020, and then maintain or enhance this clarity. 28. In further submissions Federated Farmers opposed the submission from the Department of Conservation to replace water clarity with Trophic Lake Index (TLI) as the key parameter in Objective 9.2.1. The 42A report recommends accepting this submission at Decision Requested: 9.15. 29. We oppose the use of TLI because it makes the policy framework subject to nitrogen (in addition to phosphorous, clarity, and algal biomass), which has been barely addressed at all in the Proposed Regional Land and Water Plan. We therefore fear that the inclusion of TLI as parameter in Objective 9.2.1 creates a lacuna in the plan, and thus creates scope for legal challenge that was not previously present. 30. The information we have suggests that Nitrogen: is not a limiting nutrient in Lake Brunner; is a costly contaminant to regulate or control with any certainty because is readily soluble in water; is unlike phosphorous in that nitrogen loss is more difficult to accurately measure and provide direct regulatory measures to manage; there is scope to reduce nitrogen loss through good practice methods, but some of these measures can be incredibly expensive and have not been trialled in high rainfall environments such as the West Coast; a large proportion of nitrogen loss is to groundwater, and is difficult to observe or measure, and regulators are very reliant on predictive models. 31. Federated Farmers recommends that the Council avoid opening a proverbial ‘can of worms’ and leave water clarity as the key parameter in Objective 9.2. Not only is water clarity simpler to deal with, but it also directly represents that values that the plan change is seeking to protect. As noted in the section 32 report, and repeatedly stated throughout pre-consultation the key issue for Lake Brunner is phosphorous and lake clarity, and this should remain the focus of the plan change. 32. Failing this, we submit that West Coast Regional Council exercise its right to undertake further consultation on the use of TLI as the key parameter in Objective 9.2.1. At no point during the preparation of the plan was TLI discussed as a parameter of interest. It is only with the release of the 42A report, at this very late stage, that we have become aware of it. 33. Federated Farmers notes that the 42A report recommends rejecting submissions requesting reference to nutrients besides phosphorous (at Decision Requested: 9.17, Decision Requested: 9.20) Our comments on the use of TLI at paragraphs 28-32 are also relevant to discussions of other nutrients. 7
Page 1 and 2: BEFORE THE West Coast Regional Coun
Page 3 and 4: 4. Other matters 1. The issue of wa
Page 5: submission, with the comment that C
Page 9 and 10: 3.4 Policy 9.3.5 - To prevent stock
Page 11 and 12: 3.5 Policy 9.3.6 - To reduce the lo
Page 13 and 14: 56. We are relieved to see that the
Page 15: 65. The phrase ‘licence to contam

Hearing Evidence – Brunner - Federated Farmers

You also want an ePaper? Increase the reach of your titles

Delete template?

Save as template?