Submission on the Proposed Bay of Plenty Regional Policy Statement 2010
From
Stuart Morrison
705 Oturoa Road
RD 2 Rotorua 3072
PH 07 3323500
Submission
My submission relates to Part 2.10 Water Quality and Land Use and Part 3 Water Quality
Policies
Proposed Targets Part 3 PolicyWL 3B andWL 6B
The issue of primary concern arises in Policies WL 3B and 6B which relate to the target
where discharge to land or water in the Lake Rotorua catchment can exceed 435 tonnes of
nitrogen only until 2019.
While I understand that the RPS does not deal with how the policy is to be put into effect,
the stating of the target in such specific terms invites comment.
The implications of this for the farmers in the catchment are significant and could severely
affect farmer business viability.
In the absence of clarification as to where these figures come from in the Statement, I
refered to the Lakes Rotorua & Rotoiti Action Plan. Page 7 indicates a figure used in relation
to the 435 tonnes and that is that current (2009) exports from land are estimated at 746
tonnes; so the reduction proposed is 311 tonnes - that is a 42% decrease.
Other communications from the RC suggest for dairying that a 50% reduction of current
inputs is required.
Putting this target in context, the legacy load within the lake contributes 360 tonnes of N
that can be released up to 10 times a year ie up to 3600 tonnes per annum. It can be seen
that with the land based reduction at less than 10% of internal load. A point made by others
is that to suffer the costs mitigation actions and of land use change, without also addressing
the internal load, would be money and effort wasted.
On page 75 of the Statement Paragraph 2.10.3, 2 states “Agricultural discharges of nitrogen
and phosphorus are a significant contributor to reducing water quality in the majority of the
lakes in the Rotorua district”. As far as Lake Rotorua is concerned a particularly significant
contributor has been a growing urban population where in the past sewage discharges have
contributed substantially to the legacy load.
The Proposed Lakes Rotorua & Rotoiti Action Plan 2007 made much of how the lake water
quality would worsen because of agricultural discharges. The lake has not worsened but
improved over the last 5 years; the TLI three year rolling average has gone from 4.9 to 4.7.
This may be because of an over estimation of agricultural losses or an improvement in
sediment loadings (as noted from University of Waikato work). It is my understanding that
nitrogen modeling for Lake Rotorua has been revised and shows a lower contribution from
agricultural discharges than on the 2007 basis. However it appears that the target remains
the same because now the impact of climate change has been factored in, increasing
internal releases and increasing nutrient loads by 25% in future years.
The point I wish to make is that is that there is enough uncertainty about agriculture’s effect
on water quality to justify proceeding without undue haste.
Certainly encourage management change to best practice and reconfiguration of farms to
better sustainability. But to insist on targets that are unachievable in size or time with the
result that businesses are forced out, may result in loss of a valuable industry with an
unknown and perhaps less than planned effect on lake water quality.
The direct public cost in vilifying farmers and forcing them out is minor although the
economic cost of value lost to the community is not. The private cost is massive and
untenable in terms of fairness and natural justice.
Independent industry advisers –for example DairyNZ – have noted that to meet these
reduction targets individual farmers will have business viability severely impacted.
Farmers have continued running their businesses in the most efficient way within the rules
but substantial environmental efforts have been limited because of concern for the future
of farming in the catchment. Since the introduction of Rule 11 and the development of the
Lake Rotorua Action Plan it has been clear that significant reductions in nutrient losses from
land would be required. The difficulty has been in not knowing what the final targets are
likely to be, not having the tools to deal with the problem, and, particularly, not knowing the
impact on the business to the point of not being sure of having a business. In short, there
has been and still is uncertainty of investment.
Not withstanding that, many have had enough faith that good sense will prevail and have
put effort into farming more sustainably with a heightened awareness of downstream
impacts of farming practice. This has come at the direct cost of the mitigation action and/or
the loss of income. Our analysis has shown that this has resulted in lower nutrient losses.
Further progress is being made with a focus on just what targets are likely and substantial
work has been initiated as a Collective around on a solution based outlook as to how we can
significantly reduce our nutrient losses. That is, what we can do and at what cost.
The resources made available to dairy farmers by the involvement of DairyNZ and others
associated with this effort have made it possible to examine closely farm operations and
management systems and start to move to a solution seeking stance. These resources are
not available on an individual basis.
Decision sought : Qualify the stated targets.
Part 2.10.1 page 74 and Part 3 Policy WL 3B
Land Use Change
Meeting a target such as that stated without severely impacting the industry depends on
land use change – the extent of land use change and how soon it occurs. Land use change
will lessen the pressure on farm businesses and I support that it should be encouraged and
facilitated.
Given the impact on individual farmers capital and income that these targets pose, on top of
the losses already suffered from rule 11 and from the knowledge of future reduction
requirements, I support the statement page 74 ending “ … district plans will assist change
to a more beneficial land use”. I support Policy WL 1B Facilitating land – use change which
explains that “ District plans should facilitate this process”.
While it is acknowledged that a forward looking policy is required to find the right solutions
to clean up the lake, careful management of change is surely necessary to avoid
squandering the value built up and present in the current land use activities.
To the extent that assistance is not available to assist with land use change that is required
to reach a target that goes beyond the best management efforts of farmers, then we ask for
more time. More time will allow use of yet to be derived technology that is likely to be
developed given the now national attention on the importance of dealing with the impact of
agricultural activity on the environment.
Part 2.10 and Part 3 Policy WL 5B
Economic Impact
There appears to have been a reluctance to look at the issue from an economic point of
view; where the economic objective can be stated as maintaining or improving economic
wellbeing in an environmentally sustainable way.
In particular, in the Statement absent from the list of principles in Policy WL 5B is any
reference to economic contribution. Economic and social wellbeing remain two of the four
pillars of the RMA that I believe should be given more weight. Economic impact should be
included as one of the principles considered in allocating nutrient discharge levels.
Part 3 Policy WL 9B
Protecting Versatile Soils
Policy WL 9B concerns the protection of versatile land but indicates that “in the Lakes
catchments land use change to achieve reduced nutrient discharges may justify over-riding
this policy”. The development of such land requires considerable investment and it would
be preferable to find ways to improve the environmental sustainability of such land than to
resort too enthusiastically to this policy and squander the investment made and its future
potential contribution.
Conclusion
I accept that there are environmental limits to any natural system and clearly there are
limits to the nutrients the lakes can assimilate.
I agree that as an industry, sustainability efforts need to increase to mitigate or offset the
environmental effects of increased activity and past over use. However, Lake Rotorua has
suffered from the past impact of sewage from a large urban population that has severely
restricted the scope for agricultural production.
I submit that the targets set should have some flexibility. While providing certainty as a fixed
number, in the context of the modeling that the target was derived from and, further, in
relation to the significantly higher internal load, there is clearly margin for error and a range
of values around which judgments and assumptions have been made. Therefore I submit
there is room for flexibility.
To the extent that resources are not available for beneficial land use change then more time
should allowed to reach targets.
The thrust of my submission is about the importance of maintaining financially viable
agricultural activity for the good of farmers and of the community as a vital part of the
region’s economy.
This submission asks that the council give careful consideration to the value of the
productive land in the catchment and consider how it currently provides for and contributes
to the economic, social and cultural wellbeing of farmers and the community.
The economic and social contribution of agriculture is significant and should be maintained
but a level that is that is environmentally sustainable. The challenge is to maintain or
improve the level of economic activity at the same time staying well within the
environmental limits. We all want a cleaner lake, the question becomes how do we achieve
this without unnecessary economic hardship for individuals and loss for the community. In
short let us avoid throwing the baby out with the bathwater.
I believe the answer lies in encouragement and support for a mix of; land use change,
improved environmental sustainability of farm businesses, and an approach to targets that
gives certainty of investment but is flexible enough to allow for change to occur in a way
that gives the best overall result.
Decision Sought
More adequately include statements in Part 2- Water quality and land use, and Part 3Water Quality Policies of the RPS that require that account be taken of the economic, social
and cultural impact of change on agricultural businesses and the flow on impact on the
community.
I wish to be heard in support of my submission
………………………………………………….
February 3, 2011