Federated Farmers has sent the following to members:
The government’s package of Freshwater reform proposals “Action for healthy waterways” consultation period ends 31 October 2019.
Farmers are understandably concerned about the impact of these proposals on their farms, families and communities, and we know you want advice around how to meaningfully submit on these proposals.
Federated Farmers will be entering a full submission on the proposals, and we are working with other industry bodies to ensure we are singing from the same sheet. We will be focusing heavily on the policy wording and broader implications of the proposals.
We recommend you as individual farmers focus on providing an overview of the impacts and investment at farm, family and community level. We also suggest you provide details of any specific on farm actions undertaken to improve environmental outcomes. These good farm stories are not recognised in the proposals, and central government needs to be made aware of them.
We know this is a big ask at a busy time of year, but unfortunately, at this stage, this is the only chance to influence this regulation. (We have requested the opportunity to provide input into further drafts but this is not guaranteed.)
The process government is following is not the usual consultation process. In this instance, timeframes are wholly inadequate, particularly given there are three major legal propositions (the draft National Policy Statement for Freshwater Management, the proposed National Environmental Standard for Freshwater, and the draft Stock Exclusion section 360 Regulations) all released simultaneously as part of this package. Typically, each one of these should have had a 6-8 week consultation period.
Once submissions are in, a panel handpicked by government will summarise submissions and advise MfE and the Minister what they recommend. From there, Cabinet will make a decision. There are no hearings, no Parliamentary debates or readings, and no opportunity for those most affected to look at any amended proposals. It is most likely that the next time we see these documents they will be regulations that are in force.
The Government has stated on several occasions that this is just a discussion document. On that basis, Federated Farmers will be continuing to ask the Government for a further round of consultation on any changes made to the legal documents (NPS, NES and s360 regulations) following submissions. The acceptance of this approach would be more consistent with their promise to be an open and transparent decision-maker, however, there are no guarantees that this plea will be accepted.
Remember what you may consider to be a silent protest by not engaging, will be taken by the Government as support for the proposals, or at least a lack of opposition.
The biggest concern we have is the crude, blanket, top down approach being taken to address hugely varied water quality issues that are very site specific. Join us in reminding government that one size does not fit all.
Suggested information to include in submissions
The farm-focused information you provide in your submission will depend on the nature of your farming operation, but could cover:
(a) Whether you support or oppose the specific proposals (you can access a summary of the key proposals on our website by clicking here);
(b) Your investment in environmental mitigation (planting, fencing, investment in infrastructure like bridges, culverts and storage). This could include investment over the past five years, three years, or one year, and/or what you are proposing to invest in the following year. The key is to be clear what timeframe you are covering and the types of investment you are including;
(c) The potential or estimated costs of the proposals on your farm productivity and viability. In particular the estimated costs to your farm as a result of key changes summarised via (a) above, such as increasing stock exclusion setbacks, moving fences out to 5m on average across a farm; alternative wintering of stock needs; actively reducing nitrogen losses and so forth.
- For example we know that 1km of waterway with 5 metre exclusion of fencing on each side ties up 1 hectare of land – you can use this calculation to work out what you may lose in land area and what that land is worth per/ha
(d) If you feel comfortable doing so, some indication around how these additional costs may impact the profitability or viability of your farming operation. In order to ensure the information you provide is not taken as a total farm cost it is useful to break these down into specific operating and capital costs;
(e) Why you need flexibility in land use, how your land use can change on an annual basis and how you use land use change to manage environmental effects on-farm;
(f) How your on-farm investment, catchment group work, fertiliser application and your farming practices have improved water quality on your farm, in your catchment and in your region:
- Through on-farm monitoring, regional water quality or catchment water quality data or https://www.lawa.org.nz
- Where possible use environmental data that is publicly available.
How do I make a submission?
There are a number of ways you can submit:
- Use the submission templates we have developed to help guide your thinking and ensure the key points are covered. We have drafted two templates a) farm specific and b) proposal specific. The proposal specific template is based on the complex set of feedback questions MfE are seeking a response to. Please choose the ONE that works best for you. You can access these by clicking here.
- Use the online option provided on the Ministry for the Environment website. You can access this by clicking here. Please note this tool asks specific questions, provides a specific format for your responses and is not recommended if you are providing detailed information as suggested above.
- Free style – write it your way. As long as the submission is clear as to whether you support or oppose the proposals (or parts thereof), provides some reasoning for your position, has your name and contact details and does not use offensive language, then it will provide important feedback. You can email that directly to email@example.com
The formal deadline for submissions was Thursday 17 October 2019 at 5pm, but on Federated Farmers’ request Minister Parker has agreed that ‘submissions will be accepted until 31 October 2019.
What happens with my submission?
Please be aware that if you make a submission the information and your name may be published on the MfE website. Unless you clearly specify otherwise in your submission, the Ministry will consider that you have agreed to this. Contents of submissions may be released to the public under the Official Information Act 1982, if requested.
When the consultation period has ended, feedback will be collated and reviewed by officials and an advisory panel. Ministers Parker and O’Connor will then make recommendations to Cabinet (consisting of Labour & NZ First Ministers) who approve the final regulations for freshwater. (Note Parliament has no role)
For more information, please contact your local Federated Farmers provincial executive team, or your Regional Policy Advisor.
- Kim Reilly, Federated Farmers South Island Policy Manager
This article is free to view because it is a topic of high importance. This article was published in Dairy Exporter magazine. For less than $10/month, you can receive this detailed information to help improve performance within your business. nzfarmlife.co.nz/
Supporting New Zealand journalism.