“While we generally support the ambition of the proposals for cleaner freshwater the planned river quality limits are excessively tight and exceed current limits already consented by regional councils.
“These limits are likely to result in substantial economic costs to the meat processing sector without resulting in substantially improving environmental outcomes.
“The meat processing industry is the country’s largest manufacturing sector and employs approximately 25,000 people, the vast majority in regional New Zealand, so these proposals will have a significant impact on rural communities,” he said.
Many processing plants’ wastewater treatment systems have also been significantly upgraded in recent years, often at considerable expense.
The sector wants the Government to reassess the proposed dissolved inorganic nitrogen and dissolved reactive phosphorous national bottom lines.
“We generally support setting instream limits for DIN and DRP – clear bottom lines will provide business with greater certainty.
“However, these should be science-based, recognise the diversity of unique ecosystems and natural variation and reflect the local conditions of that waterway.
“The proposed DRP limit is unlikely to achieve better environmental outcomes while imposing significant economic costs.
“We do not believe that most processors will be able to meet the proposed DRP limit.
“The national limits need to be reassessed to ensure they are based on a scientific understanding of the environmental impact on waterways and lead to appropriate water quality without inflicting unnecessary damage on NZ’s regional economy.”
In a number of cases the water quality upstream of processing plants already exceeds or is very close to the proposed limits.
“We are concerned our sector will be paying more than our fair share to fix water quality issues caused by others.”
The association opposes the moratorium on farm land use change.
“This discriminates against farms which are already operating within environmental limits.
“Our processors and exporters have an interest in both ensuring supply of livestock is maintained as well as that livestock is produced in an environmentally sustainable way to meet increasing customer demands for sustainable food.
“One of the cornerstones of NZ’s productive, world-class farming systems has been flexible land use as farmers innovate and rapidly shift production according to market signals and regulatory requirements.
“This will prevent farmers from maximising their production within environmental limits. Farms that meet environmental limits should be able to farm flexibly.
“Any decline in farming will have a knock-on effect with reduced processing and eventually the closure of processing plants in regional towns where meat processors are often the largest employer.
“The economic and social impacts of the freshwater proposals cannot be underestimated,” Ritchie said.
