Hearing Evidence – Brunner - Federated Farmers

3.2 Policy 9.3.3 – To reduce the amount of phosphorous discharged in the Lake
Brunner catchment.
34. In further submissions, Federated Farmers supported the proposed change to the
wording of this Policy by Fert Research to refine the focus of Policy 9.3.3 to
phosphorous discharged to water, rather than phosphorous applied to land. It is good
to see the staff report recommend this submission is accepted at Decision Requested:
9.19. We also support the submission of Westland Milk Products as discussed at
Decision Requested: 9.21 for the same reasons.
3.3 Policy 9.3.4 – To require discharges of dairy effluent in the Lake Brunner
catchment to be to land rather than directly to water.
35. In our submission, Federated Farmers asked that Council: Carefully consider the actual
costs and benefits of the proposed objectives, polices, and rules. The importance of
balancing costs and benefits is acknowledged at Decision Requested: 9.24.
36. For example, effluent application systems are a technically complex area, and a variety
of problems arise if rules and consents conditions are subject to prescriptive, rather
than outcome-based criteria. Discussions with experts 3 suggest that the use of deferred
irrigation of effluent (storage) is not feasible on the humped and hollowed and high
rainfall land in the Brunner catchment. The pond calculator model for the West Coast
predicts that optimum soil moisture conditions do not persist for long enough to get
FDE onto land fast enough to keep ponds empty, and that it will be very difficult for
farmers to maintain a useful irrigation buffer, even with very large ponds. Furthermore,
Michael’s experience in Southland is that large storage ponds are prone to failure as
clay liners erode and crack, or as synthetic liners are compromised by rising methane
gas from decomposing soil organic matter. Unsuitable design can also lead to severe
problems with odour. Thus, any storage pond must be suitable for the climatic
conditions and designed and constructed to a very high engineering standard,
otherwise a structure intended to achieve certainty and reduced contaminant loss from
the farm system will have the opposite effect, with wasted capital, on-going worry for
farmers, and lack of certainty for the Council the likely result.
37. With effluent systems, Federated Farmers prefers simple systems that achieve certainty
of outcome, and that come at reasonable cost so as to leave farmers with resources to
address other areas of environmental performance. Rushing through with prescriptive
solutions, even as researchers are working to develop effluent systems suitable for
high rainfall environments, is likely to lead to high cost and poor environmental
performance in the long term.
3 Dr Dave Houlbrooke pers comm 9-01-2012
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