Beef+Lamb NZ Submission on the Proposed Canterbury Land and Water Plan
Submission to
Environment Canterbury
Proposed Canterbury Land and Water Regional
Plan
by
Beef + Lamb New Zealand
5 October 2012
Page 1 of 22
Beef+Lamb NZ Submission on the Proposed Canterbury Land and Water Plan
1. Introduction
1.1
Beef + Lamb New Zealand Ltd (B+LNZ) welcomes the opportunity to make a submission on
Proposed Canterbury Land and Water Regional Plan (the Plan)
1.2
B+LNZ is an industry-good body funded under the Commodity Levies Act through a levy
paid by producers on all cattle and sheep slaughtered in New Zealand. Its mission is to
deliver innovative tools and services to support informed decision making and continuous
improvement in market access, product positioning and farming systems.
1.3
B+LNZ is actively engaged in environmental issues that affect the pastoral production
sector.
2. Submission
2.1
Beef +Lamb New Zealand supports the collaborative and integrated approach to water
and land management that Environment Canterbury is developing.
2.2
As a plan prepared under the provisions of the Resource Management Act, the Plan
needs to focus specifically on the achievement of outcomes, and avoid where possible
becoming prescriptive to achieve the aims and objectives of the Plan.
2.3
B+LNZ believes that the Plan should reflect the four well beings – social, cultural, economic
and environmental and reflect the views of the community.
2.4
The Plan must also give effect to the National Policy Statement for Freshwater
Management.
2.5
B+LNZ opposes the use of resource consents for general or minor farm activities and
maintains that these activities should be given ‘permitted activity’ status, particularly where
the nutrient leaching status of a property is low.
2.6
B+LNZ opposes the use of resource consents for farms that exceed the ‘look-up’ table
values, particularly in ‘red zones’ where the values determined are based on broad
assumptions and don not reflect the vast mix of farming operations that may occur on an
individual property.
2.7
B+LNZ also sees duplication in the requirement for resource consents as well as Farm
Environment Plans (FEPs), and submits that land managers be given an option of consents
or FEPs. FEPs on their own will adequately address the issues of concern in a far more
specific way than a resource consent or the multiple consents needed for specific activities
will be able to.
2.8
Farm Environmental Plans provide a much more specific, flexible and outcome focussed
approach to managing water and land management and quality issues in a cohesive and
co-ordinated way. FEPs can manage a range of activities such as stock holding areas, offal
Page 2 of 22
Beef+Lamb NZ Submission on the Proposed Canterbury Land and Water Plan
pits and rubbish holes, farm lanes, silage pits and stock access to the beds of lakes and
rivers or (non-significant) wetlands without recourse to consenting processes.
2.9
This approach has the advantage of reducing the costs, both financial and time, for land
managers and Environment Canterbury. The advantages also include:
•
•
•
•
•
•
A risk based response to issues, with a higher level of response on higher risk land;
Increased effectiveness as measures are tailored to the risks actually present on the
property, with actions agreed on site during and informed discussion, rather than a
desk top exercise isolated from the environment and unable to consider overall
cumulative effects;
Land managers have the opportunity to discuss what they need to achieve, what
they need to do and why, on their farm;
Land managers and regulators are provided with a single reference point for
environmental issues and responses on the particular property;
Multiple inspections (for multiple discharge or land use permits) are incorporated into
the FEP audit;
Voluntary adoption of FEPs will be encouraged where the alternative is multiple
consents.
2.10
B+LNZ requests that all minor farm activities that require consent as controlled or restricted
discretionary activities are to be non-notified.
2.11
B+LNZ requests that additional time be provided for, beyond the 6 months provided for in
the RMA s20A, to achieve the requirements of the rules that require resource consents or
FEPs for activities that are already legally established. A period of 3 years is suggested.
2.12
B+LNZ suggests that the requirement for the use of Overseer to calculate nutrient losses is
unnecessary in situations where the amount of fertiliser, particularly N fertiliser, is low, and
stocking rates across the property are also low. In these situations where there is no
likelihood of N loss to water reaching either community-set zone limits, look-up tables or the
20kgN/ha/yr trigger, then a simple nutrient budget or record of fertiliser applied, and a
stock return, on an annual basis, should suffice to meet ECan’s needs.
2.13
B+LNZ recognises that Overseer is only a model and therefore cannot be considered an
accurate measure of nutrient leaching rates. However, it is currently the best tool available
to help manage the issue of deteriorating water quality, and therefore should be used
cautiously whilst supporting its refinement as a tool.
2.14
B+LNZ is concerned about the resourcing currently available to deliver the required number
of overseer nutrient budgets. The industry does not currently have enough qualified
practitioners to be able to deliver the large number of Overseer generated budgets
required. This is particularly so for farmers whose low levels of fertiliser use makes them a
lower priority for completion of Overseer nutrient budgets. A period of 3 years is suggested,
to match the development of Farm Environment Plans.
2.15
B+LNZ is concerned that the proposed definition of land use ‘change’ needs investigation
and refinement to ensure that it does not accidently capture normal good management
practice for rotations of grazing, stock class changes, cropping and the range of existing
farm management practices.
Page 3 of 22
Beef+Lamb NZ Submission on the Proposed Canterbury Land and Water Plan
2.16
B+LNZ also suggests that the definition of change relating to irrigation be either removed in
the expectation that all new irrigation will be required to be efficient and not add to
nutrient loss, or qualified by a requirement for efficiency and good management.
3
Oral Submission
3.1
B+LNZ would welcome the opportunity to be heard in support of this submission.
Contact
For further information please contact:
Victoria Lamb
Beef+Lamb NZ
[email protected]
04 474 0806
Page 4 of 22
Beef+Lamb NZ Submission on the Proposed Canterbury Land and Water Plan
The specific provisions of the
Proposed Plan that my submission
relates to are:
Section & Page
SubNumber
section/Point
(2) My submission is that: (include whether you support or oppose the specific provisions
or wish to have them amended and the reasons for your views.)
Reasons
(3) I seek the following decisions from Environment Canterbury:
(Please give precise details for each provision. The more specific
you can be the easier it will be for the Council to understand your
concerns.)
Section 1: Introduction, Issues & Major Responses
pi and iii
Karanga and Support with
B+LNZ supports the inclusion of the Karanga and
Tauparapara amendment
Tauparapara however, feels that in order to be
inclusive of both Māori and wider New Zealand culture
English translations are needed for both.
Add English translations for the Karanga and
Tauparapara and all other uses of Te reo Māori and
a glossary of Māori words as per the Proposed
Regional Policy Statement.
Oppose/support
(in part or full)
English translations for all Te Reo Māori used in the
plan would assist in ‘weaving’ Ngai Tahu’s values into
the plan and bringing together a better understanding
of both cultural perspectives.
S1 p1-1
1.1.1
Para 2
Support
B+LNZ support the inclusion of the statement that:
“Reliable fresh water supplies are important for
irrigation, hydro-electricity generation and a variety of
manufacturing and industrial processes. All are vital to
the cultural, social and economic well-being of people
and communities in Canterbury and New Zealand.”
B+LNZ submit that the statement is retained and
enhanced to recognise that water is essential for
primary production, whether for stock water, crops or
other activities.
All four well beings - cultural, social economic and
environment, need to be considered.
A secure supply of quality water is paramount for
primary sector and primary support industries.
Page 5 of 22
Beef+Lamb NZ Submission on the Proposed Canterbury Land and Water Plan
The specific provisions of the
Proposed Plan that my submission
relates to are:
Section & Page
SubNumber
section/Point
(2) My submission is that: (include whether you support or oppose the specific provisions
or wish to have them amended and the reasons for your views.)
Oppose/support
(in part or full)
Reasons
(3) I seek the following decisions from Environment Canterbury:
(Please give precise details for each provision. The more specific
you can be the easier it will be for the Council to understand your
concerns.)
S1 p1-2
Support
B+LNZ support the inclusion of the statement that:
B+LNZ submit that the statement is retained.
1.2.1
Para 1
“Fresh water is essential for a variety of values and
uses, for example, drinking water and stockwater;
customary uses and food supplies; contact and noncontact recreation; irrigation, hydro-generation,
industrial and other economic activities. We rely on
fresh water for our social, cultural and economic wellbeing and our way of life...”
The statement highlights the importance of the supply
of quality water for primary sector and primary support
industries.
S1 p1-3
1.2.1
Para 1
Support with
amendment
Section 1.2.1 outlines how deteriorating water quality
affects the use of surface water bodies for customary
uses and contact recreation.
Deterioration of surface and groundwater quality can
also affect the use of water to support the economy, in
primary production, processing and support. A secure
supply of quality water is paramount for sustaining
economic uses, including primary production.
B+LNZ suggest the following or similar amendment.
“Deteriorating water quality also affects the use of
surface water bodies and groundwater for
customary uses, and contact recreation and
economic activities including primary industry”.
Page 6 of 22
Beef+Lamb NZ Submission on the Proposed Canterbury Land and Water Plan
The specific provisions of the
Proposed Plan that my submission
relates to are:
Section & Page
SubNumber
section/Point
S1 p1-3
1.2.1
Para 2
(2) My submission is that: (include whether you support or oppose the specific provisions
or wish to have them amended and the reasons for your views.)
Oppose/support
(in part or full)
Reasons
Section 1.2.1 outlines how a drier and warmer climate
will drive additional irrigation competing with hydroelectricity generation but that water storage would be
complementary.
(3) I seek the following decisions from Environment Canterbury:
(Please give precise details for each provision. The more specific
you can be the easier it will be for the Council to understand your
concerns.)
B+LNZ suggests that effects on water quality
outcomes be considered in assessing new activities
and existing uses.
Whilst storage must be considered as an option for
increasing the reliability of supply for water, that this
shouldn’t be done at the detriment of water quality.
Taking water for storage could potentially have an
adverse effect on quality through diminished freshes
and recharge.
In setting up storage schemes and taking water for
storage, water quality must be considered as
important as water quantity.
Providing additional quantity and reliability should not
result in an increase in the need or the cost of
treatment.
Page 7 of 22
Beef+Lamb NZ Submission on the Proposed Canterbury Land and Water Plan
The specific provisions of the
Proposed Plan that my submission
relates to are:
Section & Page
SubNumber
section/Point
(2) My submission is that: (include whether you support or oppose the specific provisions
or wish to have them amended and the reasons for your views.)
Oppose/support
(in part or full)
Reasons
S1 p1-6
Support
Section 1.2.6 states that:
1.2.6
(3) I seek the following decisions from Environment Canterbury:
(Please give precise details for each provision. The more specific
you can be the easier it will be for the Council to understand your
concerns.)
B+LNZ suggests that all existing activities should be
considered in the allocation of natural resources.
“the RMA requires particular consideration to be given
to existing activities in the allocation of natural
resources”.
Over allocation of water quantity and quantity in some
catchments would suggest that this requirement may
not have been given effect to.
B+LNZ is concerned that existing uses (such as stock
drinking water, which is specifically provided for in the
RMA 14(3)(b), continue to need to be protected
against new uses.
Page 8 of 22
Beef+Lamb NZ Submission on the Proposed Canterbury Land and Water Plan
The specific provisions of the
Proposed Plan that my submission
relates to are:
Section & Page
SubNumber
section/Point
(2) My submission is that: (include whether you support or oppose the specific provisions
or wish to have them amended and the reasons for your views.)
Oppose/support
(in part or full)
Reasons
S1 p1-6
Support with
amendment
Section 1.2.6 outlines the RMA requirements related
to existing use rights and the impractically that arises
at consent renewal when there is no alternative to
using the existing infrastructure.
1.2.6
Section 1.2.6 states that “Existing infrastructure
associated with large-scale irrigation and hydroelectricity generation schemes have effects that last
throughout the period that the structure exists for...”
(3) I seek the following decisions from Environment Canterbury:
(Please give precise details for each provision. The more specific
you can be the easier it will be for the Council to understand your
concerns.)
B+LNZ suggests the following or similar amendment
“Existing infrastructure associated with large-scale
irrigation, hydro-electricity generation schemes,
primary and other industries…
And all other consequential amendments.
Large Scale irrigation and hydro-electricity generation
are not the only activities to have invested in
significant infrastructure.
This could be said to be true for other activities also,
and it would be appropriate to recognise these
significant infrastructure investments.
S1 p1-6
1.3.1
Support
B+LNZ supports the collaborative approach, noting
that for key partnerships to work consultation is
paramount. However consultation must be undertaken
and actively engage with all stakeholders, especially
those who will be expected to implement actions
under policies.
B+LNZ request that in undertaking consultation,
measures are taken to ensure it is a balanced
process, and that those that are directly affected or
that will be expected to implement the actions
required to meet objectives / policies are adequately
and actively engaged.
Page 9 of 22
Beef+Lamb NZ Submission on the Proposed Canterbury Land and Water Plan
Section 2: How the plan Works & Definitions
S2 p2-2
2.7
Support
Over
Allocation
S2 p2-2
2.10
Oppose
Definition for
“Changed”
S 2p 2-10
2.9
Definition:
Infrastructure
B+LNZ is recognises that limits have been set, and
the science behind those limits is the best currently
available. Where new science becomes available this
should be integrated into the limit setting.
Ensure that limits have been based on sound,
defensible science that recognises and incorporates
continuous improvement in knowledge.
B+LNZ has concerns with the definition for land use
change.
B+LNZ supports the submission by Federated
Farmers with some amendments:
The definition of land use change is either an increase
in water use for irrigation or an increase in estimated
N loss of greater than 10%.
An increase in water use for irrigation will not
necessarily result in increased drainage or nutrient
discharge if it is well managed. The policy should
focus on reducing nutrient loss to water, as an
outcome, not an output.
The estimation of a 10% increase in N discharge
using Overseer which has an accuracy of plus or
minus 20-30% is problematic.
Support and
amend
The definition for Infrastructure should include water
storage as it is an essential part of irrigation, water
supply and electricity generation infrastructure, and
may not be included in other terms used.
1. Delete increase in water use for irrigation as
a criterion for defining land use change, or
add to the above with a proviso of ‘where
there is no increase in nutrient loss, or where
it is part of an approved irrigation scheme’.
2. Amend the definition so that only genuine
land use change is captured i.e. at a sector
level e.g. sheep to arable, arable to dairy.
Alternatively a way to do this would be by
raising the threshold for the percentage
increase in N loss for defining land use
change and/or by adjusting the periods over
which averaging is done.
3. Further consideration is needed on the use of
Overseer to estimate N discharge in a
compliance context including the lack of
precision, perhaps by increasing the N loss
threshold for defining land use change or
state a range.
B+LNZ suggests the inclusion of water storage in the
definition of infrastructure.
Page 10 of 22
Beef+Lamb NZ Submission on the Proposed Canterbury Land and Water Plan
S 2 p2-11
2.10
S2 p2-12
Definition:
Natural State
water bodies
2.10
Oppose in part
B+LNZ support the contention that that not all rivers,
lakes and natural wetlands within land administered
by DOC are necessarily natural state water bodies.
B+LNZ requests that it is recognised that not all
water bodies within land controlled by DOC will be
natural state water bodies...
Support and
Amend
Schedule 7 uses the term property in terms of the
area that a Farm Environment Plan should cover but
the term property is not defined in section 2.10.
B+LNZ supports the suggestion to include a
definition of property that is consistent with other
planning documents
The term site (as defined in S 2.10) is not appropriate
as an operation could be made up of a number of
sites. Therefore a definition for the term “property” is
needed.
“Property, means any contiguous area of land
held in one, or more than one, ownership that is
utilised as a single operating unit, and may
include one or more titles/ sites.
B+LNZ does not agree with the proposed definition for
Reliability of Supply.
B+LNZ suggest the following amendment:
Definition:
Property
S2 p2-13
2.10
Definition:
Reliability of
Supply
Amend
B+LNZ objects to the assertion that reliability of
supply is only relevant to irrigators. Reliability of
supply and the ability of the supply to meet demands
is relevant for all water users, not just irrigators.
“means, in relation to irrigation, the ability of the
water supply to meet demand from one or more
abstractors, when operating within the flow and
allocation regime or the allocation limits.”
Reliability of supply is essential for stock drinking
water, with significant implications for animal welfare
in the event of failure of supply.
Page 11 of 22
Beef+Lamb NZ Submission on the Proposed Canterbury Land and Water Plan
Section 3: Objectives
S3 p3-1
3.12
Objectives
Support
B+LNZ supports objective 3.12 in providing a
sustainable source of high quality water. Good quality
water is essential for the viability of primary industries.
Retain
S3 p3-1
3.22
Objectives
Clarification
B+LNZ requests clarification on what is meant by
“good practice” as this term is not defined in the
glossary. Who is to define good practice, how it is to
be measured and how will it reflect changes over time
with new knowledge and tools?
Clarification of the term good practice. Good practice
needs to be directed by industry, based on proven
methods and allow for innovation.
Page 12 of 22
Beef+Lamb NZ Submission on the Proposed Canterbury Land and Water Plan
Section 4: Policies
S4, p4-7
4.26
Support and
Amend
Livestock
exclusion
from
waterbodies
There will situations where intensively farmed
livestock, or cattle and deer will need to cross river
beds in situations where culverts and bridges are not
feasible e.g. hill and high country properties. Provision
for these circumstances is needed.
B+LNZ suggests that this section include the aims,
and recognise that total exclusion may not be
appropriate in some cases. These could be identified
and addressed through inclusion in a Farm
Environment Plan.
Stock access for biosecurity purposes e.g. weed
control, or fire risk reduction, is also needed.
In some environments grazing is required to maintain
the current state e.g. high country.
S4 p4-7
4.31
Nutrient
discharges
Support and
amend.
B+LNZ agrees that collaboratively set water quality
outcomes in the form of limits need to be achieved.
Substantial and enduring reduction in N loss
associated with land use change, should be the norm,
however provision for exceptional circumstances may
be needed.
Provide for exceptional circumstances where
substantial and enduring nutrient loss reduction may
not be appropriate e.g. where water quality or
environmental benefits exceed the gains from
reduced nutrient loss.
It should also be ensured that the science used as the
basis for limits, zones and to aid in decision making
should be based on technically sound information.
Page 13 of 22
Beef+Lamb NZ Submission on the Proposed Canterbury Land and Water Plan
S4 p4-9
4.32
Policies
Support and
Amend
The policy should include the possibility of an B+LNZ suggests the following amendment worded,
alternative mechanism, without decreasing the need or something similar
“...where there is no industry articulated good
to achieve water quality outcomes.
industry practice nitrogen discharge limit or credible
alternative method for a particular industry sector
Substantial and enduring reduction in N loss should
included in this Plan after prior 1 July 2017 then all
not be a prerequisite for gaining land use consent.
There is no good reason to prevent the continuation of farming activities in that industry sector will be
productive land use and the benefits that flow from it if required to obtain a resource consent to continue the
farming activity...”
there is no net increase in estimated N discharge.
Reduction should be encouraged in these
And all other consequential amendments.
circumstances.
S4, p4-9
4.37
Support and
Amend
B+LNZ believes flexibility is essential in managing
limits and suggest alternative wording.
B+LNZ requests that the following amendment be
made: All activities shall achieve the water quality
limits, including nutrient load limit and nutrient
allowances for the catchment in Sections 6-15 of this
Plan
S4, p4-10
4.42
Support and
Amend
B+LNZ suggests a longer period be used to determine
natural lake levels in order to capture the full range of
natural variations. Climate change may have affected
these lakes or some of the longer climate oscillations
e.g. 70 years.
B+LNZ suggest a much longer period than 5 years
be used
S4 p4-11
4.49
Support and
amend
All water takes need to be considered for their
potential impacts.
Amend to allow a fair assessment of all applications
for takes outside the Groundwater Allocation Zones.
S4 p4-12
4.61
Policies
Support and
amend
Water user groups should have flexibility to manage
water within the group, provided nutrient leaching
rates are not increased overall.
Amend to allow flexibility to manage allocations
subject to meeting nutrient discharge allocations.
S4 p4-13
4.71
Support and
amend
Transfers may assist with reduction in over allocation
but are unlikely to be the only tool needed.
Amend to recognise that other tools may also be
needed to reduce over allocation.
Page 14 of 22
Beef+Lamb NZ Submission on the Proposed Canterbury Land and Water Plan
S4 p4-13
4.75
Support and
amend
B+LNZ suggest that 2 years may not be long enough
for giving effect as large infrastructure projects can
take longer to get underway.
Suggest that a period of 5 years could be included in
some consents.
S4 p4-13
4.76
Support with
amendment
Short terms for consents may discourage investment
in efficient infrastructure. Provision could be made for
longer periods where infrastructure was reducing
discharges or more efficient, leading to improvements
B+LNZ requests that provision for longer consent
durations be made, where there is improvement in
water quality or efficiency in use.
Consent
duration,
Lapse
Periods and
Giving Effect
to Water
Permits
Page 15 of 22
Beef+Lamb NZ Submission on the Proposed Canterbury Land and Water Plan
Section 5: Region Wide Rules
S5 p5-6
5.21, 5.22,
Support
5.23, 5.24
B+LNZ supports these rules, particularly the nonnotification provisions.
Retain, with current non-notification provisions.
S5 p5-8
5.27 (3)
Support with
amendment
B+LNZ suggest this section be amended.
S5 p5-9
5.29 (2)
Support and
amend
This provides for biosecurity operations including the
control of animal pests e.g goat culls.
S5 p5-9
5.29 (5)
(c)
(f)
Support and
amend
This amendment provides for high water tables in
some areas, particularly hill and high country.
5.27 (3) to read:
The discharge does not have any adverse effect
on water takes or other users of water, or take
place at the same time as an abstraction activity
is occurring:is not
(a) ….
The discharge is only of dead animals or animal
parts produced on the site where the pit is located,
or the activity is carried out under the control of
the regional council or a crown agency.
(c) “The discharge does not occur … groundwater
level’ or the site is at least 250 m from the nearest
potable water abstraction point or spring fed
lowland river.
Provision is needed for one-off situations.
(f) to any naturally formed limestone rock.
A new rule is needed to address for one-off disposal
where it is not possible to comply with generic
permitted activity rules.
S5 p5-10
5.33, 5.34
Support
B+LNZ supports the provision for a permitted activity
for the discharge of solid animal waste and vegetative
material, but believes a definition of animal waste is
needed.
Retain these rules, and add a definition for solid
animal waste in Section 2.
Page 16 of 22
Beef+Lamb NZ Submission on the Proposed Canterbury Land and Water Plan
S5 p5-10
5.35
Support with
amendment
B+LNZ suggest amendments to the definition of stock
holding area to better reflect reality.
Stock holding areas should be permitted activities, if
and managed through Farm Environment Plans if
needed.
Stock holding area: means an area of land in which
the construction of the holding area or stocking
density precludes maintenance of pasture or
vegetative groundcover, and is used for confining
livestock for more than 30 days 24 hour in any 12
month period or for more than 10 consecutive 24
hour days at any time. For the avoidance of doubt,
this definition includes;,dairy yards, feedpads and
wintering pads, and farm raceways used for feeding
or containing stock for extended periods of time.
stock holding purposes during milking
It is also suggested that stock holding areas be
made permitted activities when the surface
preparations, design, or stock type result in a lower
level of environmental risk compared to what would
otherwise occur, for example:
• When location and stocking density are such
that the overall environmental risk is
significantly reduced compared to other
practically available outcomes;
• When used to contain deer;
• When it creates a more sustainable outcome
than would otherwise occur.
These matters could be addressed through a Farm
Environment Plan
Page 17 of 22
Beef+Lamb NZ Submission on the Proposed Canterbury Land and Water Plan
S5 p5-11
5.37, 5.38
Support with
amendment
B+LNZ consider that silage pits should be a permitted
activity, and may result in favouring one type of stored
feed over another for little or no environmental gain. It
is unreasonable to require a consent for all silage pits
regardless of location or design.
Amend rule 5.37 (2) For example- ‘ The volume of
any silage pit or stockpile greater than 20m3 and is
not sited: (a) within 20 m of a surface waterbody, the
boundary of the site subject landholding, a bore, or
the Coastal Marine Area.
Silage pits should also be located a sufficient
distance away from boundaries, dwellings or other
places where people congregate.
S5 p5-11
5.39
Oppose
B+LNZ believe that for many farms, their use of
nitrogen fertiliser and the stocking policies mean that
N loss will be under or well under the 20kgN/ha/yr.
These properties should not have to complete
Overseer budgets, rather an annual report N fertiliser
application and stocking policy should all that is
needed. Significant changes to N loss will be covered
by the definition of ‘change’
Provide for properties where N loss is not an issue to
provide an annual report of fertiliser volume and
stocking policy, instead of Overseer.
S5 p5-12
5.42
Support with
amendment
The rule is supported as it provides for land use
change, but the definition of ‘change’ needs to be
amended – see definitions.
Retain with amended definition of ‘change’.
S5 p5-12
5.43
Oppose
Reduce to a controlled activity.
S5 p5-13
5.44
Oppose
In N underallocated zones the threshold for change
does not need to be so high. A controlled activity
would allow monitoring of discharge levels and ensure
that nutrient discharge was at acceptable levels for
the activity.
B+LNZ suggest that while provision needs to be made
to reject an application if zones are at risk or not
meeting water quality outcomes, discretionary
restricted should be a sufficient level over control.
Amend activity status to discretionary restricted.
Page 18 of 22
Beef+Lamb NZ Submission on the Proposed Canterbury Land and Water Plan
S5 p5-13
5.45
Oppose
Change in land use needs to be a real change and
measured against water quality outcomes for the
catchment.
Amend the activity status from non-complying to
discretionary. Require a Farm Environment Plan to
manage specific issues.
S5 p5-13
5.46
Support and
Amend
The overall approach is supported however as noted
in earlier sections, the requirement for Overseer
should have a trigger point to avoid unnecessary work
by farmers and ECan
Include a threshold for N application below which a
simple record of N applied, and stocking rate is
provided to ECan. Changes in either to be assessed
by ECan to determine if an Overseer budget is
required or the threshold is reached or not.
Optionally, a Farm Environment Plan could be used
to manage low N use/leaching properties. This could
be a trigger for a more permissive approach to
consent requirements.
S5 p5-13
5.47
Support and
amend
This proposed level of oversight is not required or can
better be managed through the use of Farm
Environment Plans
Amend the activity status from restricted
discretionary to controlled.
S5 p5-13
5.48
Support and
amend
The proposed activity level is greater than needed,
and issues can be better managed through Farm
Environment Plans
Amend the activity status from discretionary to
restricted discretionary.
S5 p5-13
5.49
Support and
amend
The use of a non-complying activity is not appropriate B+LNZ request that the activity status been changed
and that a discretionary activity status should be used from non-complying to discretionary.
instead. Issues can be adequately managed through a
Farm Environment Plan.
S5 p5-14
5.52
Support
Retain
S5 p5-14
5.53
Support
Retain
S5 p5-14
5.54
Support and
amend
The issues are known so should be identifiable and
manageable.
Change activity status from discretionary to
restricted discretionary.
Page 19 of 22
Beef+Lamb NZ Submission on the Proposed Canterbury Land and Water Plan
S5 p5-23
5.97
Support and
amend
Activity level can be reduced.
Change activity status from non-complying to
discretionary
S5 p 5-24
5.102, 5-103
Support and
amend
Some parts of Canterbury are not in a Groundwater
Allocation Zone. The activity level is too high.
Change activity status from non-complying to
discretionary.
S5 p5-27
5.115
Support and
amend
Maintenance of structures cannot be carried out at a
distance from the structures, particularly if structures
are located close to each other.
Amend to allow maintenance of structures.
S5 p5-30
5.133
Support and
amend
The concept of excluding from the beds of rivers to
prevent damage is supported. However the current
wording about ‘temporary access’ appears to relate to
lowland or plains rivers, not the rivers and streams or
the type of farming found on hill and high country. The
current description prevents a range of stock from
crossing a river. This is particularly an issue in hill and
high country where bridges or culverts are not
practical, and the frequency of crossing is low. With
respect to the exclusion of intensively farmed stock,
how stock are farmed once they have crossed a river
is not an issue that affects the river bed. Many sheep
and beef farms include some areas of irrigated land
amongst a mix of extensively farmed dry land stock,
arable cropping and forestry.
Provisions for stock of any type to cross rivers, lakes
or wetlands in certain circumstances are required as
a permitted activity where bridges or culverts are not
feasible.
Alternatively, these matters could readily be
addressed in a Farm Environment Plan.
S5 p5-30
5-134
Support and
amend
Not every spring fed plains river will justify a prohibited Differentiate between significant and not significant
activity rule. The significant areas should be identified areas, through mapping or other suitable method.
and mapped.
Page 20 of 22
Beef+Lamb NZ Submission on the Proposed Canterbury Land and Water Plan
S5 p5-30
5-135
Support and
amend
S5 p5-30
5-136
Support with
amendments
S5 p5-32
5-143,5.146
5.147 –
5.154
Support
S5 p5-33
Oppose
Only ecologically significant wetlands should be
included.
Condition 3(b) relates to areas of ‘bare ground’. The
description does not differentiate between naturally
occurring bare ground, patches of which whilst small,
are common and occur naturally on hill and high
country, and bare ground arising from stock activity.
Refer to ‘ecologically significant’ wetlands in the rule.
Some of the conditions are unsuitable for hill and high
country farms. E.g 20 m crossing width, formed lanes
or tracks – rather they would create far more
disturbance.
Amend to provide for extensive pastoral situations,
or manage through Farm Environment Plans.
Amend condition 3(b) to clarify that it relates to bare
ground arising from significant stock activity.
Retain
B+LNZ supports the submission of NZ Federated
Farmers in relation to these sections.
Refer to Federated Farmers submission for
suggested changes.
One option to address these Hill and High country
issues could be the optional use of a Farm
Environment Plan to address permitted and
consented activities in a unified and connected way.
Page 21 of 22
Beef+Lamb NZ Submission on the Proposed Canterbury Land and Water Plan
Sch 7 p1613
Schedule 7
Para 1
Schedule 7 states that “A Farm Environment Plan
shall be prepared by a person with the appropriate
professional qualifications.” B+LNZ would like
clarification as to what is meant by "appropriate
professional qualifications.”
Clarify what the expectation is for "appropriate
professional qualifications.”
Alternatively provide for suitably experienced persons,
which would allow B+LNZ’s Land and Environment
Plans (Level 2) to be used by farmers to prepare their
own plans, which are then agreed to by ECan, with
appropriate auditing as ECan requires.
As noted elsewhere, Overseer may not be required
on many properties and an alternative threshold
could be used to identify the circumstances where
Overseer would be required.
It is also suggests that a definition for the term
“property” is required as it is not included in section
2.10.
Suggest that ‘appropriate experience’ would be more
appropriate.
“Property, means any contiguous area of land
held in one, or more than one, ownership that is
utilised as a single operating unit, and may
include one or more titles/ sites.
Page 22 of 22