SUBMISSION
To
Environment Canterbury
From The Mackenzie Branch of Federated Farmers of NZ
On
Proposed Canterbury Land and Water Regional Plan
Date
5 October 2012
Contact John Murray
Chairman
Mackenzie Branch of Federated Farmers of NZ
The Wolds Station
PO BOX 154
Lake Tekapo 7945
Phone: (03) 6806608
Email: thewolds@farmside.co.nz
We wish to be heard in support of our submission
General Submissions
The Branch supports a collaborative approach to water and nutrient
management with representation from areas such as the Mackenzie Country
which has issues unique to the area. The Branch submits that land owner
involvement and motivation will be crucial to the successful result.
The economic impact of the proposed LWRP will be huge to our members to
over half of our members who do not have a water consent with nutrient limits
attached. Given the public interest in the Mackenzie, the cost of any consent is
likely to run into the hundreds of thousands of dollars for even a small consent
making all but the large, corporate type developments uneconomic. This will
make it hard for the average family property to survive, let alone look after the
biodiversity and other values.
All these plans do is take from us and give nothing in return.
In predicting nitrogen loss, overseer does not allow for a possible decrease in
nitrogen loss from, for example:
 The removal of nitrogen fixing weeds such as gorse, broom and alders
from waterways.
 Fencing of water ways and buffer planting.
 Removal of septic tanks.
 Removal of geese from waterways.
The Branch supports the submission from Federated Farmers of New Zealand.
1.2.3 Issues relating to soil conservation, gravel resources and
biodiversity
Most of the Mackenzie Basin is very low in most major nutrients such
as N, P and S. Most unimproved tussock land has an Olsen phosphate
test of less than eight. If a good vegetative cover is to be maintained
to prevent erosion such nutrients may be needed.
Relief Sought
Add a statement to this effect.
DEFINITIONS
Definition of “ Changed” page 2-5
An increase of more than 10% in the loss of nitrogen is deemed to be
a change in farming activity. If a farm was had a low nitrogen loss of
5 Kg/ Ha/year, it would only be allowed a 0.5 Kg increase but could
go to 20 Kg/Ha/year without any appreciable impact on the
environment, but another farm currently losing 70 Kg/Ha/year of
nitrogen can increase by 7 Kg/Ha/year without the need for a
consent. Also 10% is within the margin of error for overseer.
An increase in lambing by 20% could cause a calculated nitrogen
loss, yet could be achieved by genetic gain with no actual change in
nitrogen loss.
Relief sought
Allow a nitrogen loss of up to 20 Kg per Ha per year until 2017
without the need to obtain consents outside red area where WQ
outcomes are not being met and the Lake zone.
Where a different version of overseer is used which calculates a
higher nitrogen loss with the same inputs, no change is deemed to
have occurred.
Definition of “Hill country”
Support the exclusion of arable land from this land class.
LIVESTOCK EXCLUSION FROM WATER BODIES
Policy 4.26, page 4-7
This policy potentially could exclude stock from much of the high
country. This is unrealistic given that current grazing patterns are
unlikely to change significantly and it is uneconomic to fence off
waterways and all sensitive areas. This would result in a rule in a plan
rendering the land incapable of economic use which is against Sec 85
of the RMA
FARMING
Rule 5.37
Support
Rules 5.39 – 5.51, pages 5-11 – 5.14
Fish farming should be included in the rules. They discharge directly
into water ways but seem to have no rules around their operation or
their expansion. The Mount Cook Salmon Farm on the Tekapo Canal
has expanded hugely lately and has a calculated discharge the
equivalent of many large dairy farms. Why do farmers face tough
rules on expansion when fish farms have no limits on how big they
can get? A case of double standards?
Rule 5.44, page 5-12
A full discretionary consent is unwarranted given that this plan is
about nutrient management. A discretionary consent is usually
publically notified and very expensive. Why should factors such as
landscape and biodiversity revisited when they would have been
looked at when the original water consent was granted. A consent
should not be required where the estimated nitrogen losses would
be low after development. There should be an easy way of getting
nutrient conditions attached to a water consent.
Relief sought
Change rule to:
“5.44
Prior to 1 July 2017, the use of land for a change to an existing farm
activity that does not comply with Condition 1 in Rule 5.42 and is
within an area coloured orange on the Planning Maps is a restricted
discretionary activity. A consent will not be required if the
estimated nitrogen loss is less than 20 Kg/N/Ha/year after the use
of land for a change to an existing farm activity is completed
The CRC will restrict the exercise of discretion to the following
matters:
1. The proposed management practices to avoid or minimise the
discharge of nitrogen, phosphorus, sediment and microbiological
contaminants to water from the use of land;
2. The potential effects of the land use on surface and groundwater
quality, and sources of drinking water;
3. The contribution of nutrients from the proposed activity to the
nutrient allocation status of the management zone.
4. The extent to which the proposed activity will prevent or
compromise the attainment of the environmental outcomes sought
by, or is inconsistent with, the objectives and policies of this Plan
relating to nutrient management and water quality.”
FERTILISER USE
Rules 5.53 and 5.54, page 5-14
Condition 1 is too restrictive. In the high country we apply fertiliser
(usually phosphorous and sulphur) aerially on terrain unsuitable for
ground spreading after winter to avoid losses while plants are not
actively growing. This has to be applied before stocking for lambing
to avoid metabolic disorders when ewes eat superphosphate on
pasture.
Relief sought
Amend Condition 1 to allow aerial application of non-nitrogenous
fertilisers avoiding areas with ponding by 10 m.
Conclusion
The Mackenzie Branch of Federated Farmers thanks Environment
Canterbury for the opportunity to submit on the Proposed Land and
Water Regional Plan