It is of huge significance to farmers and some of the specific proposals are causing concern, particularly at a time when there is so much to do on-farm.
The time frames for consultation are extremely short, especially given the amount of change being proposed, the complexity of the issues and the sheer volume of material to understand.
Since it was released DairyNZ’s water quality scientists, policy experts and economists have been working through the details to understand their implications on the environment, dairy farming families and our communities.
There has been a lot to assess because we were not part of the package’s development process. Along with our own analysis the information and comments farmers have provided on how the proposals affect them are vital for our submission and we appreciate the time farmers have taken to share their views with us, make submissions and attend meetings.
In the package there are aspects we support and a number of proposals we have serious concerns about.
Healthy waterways are something we all want and we know we need to do our bit for ourselves, our communities and our consumers.
At the same time we want to ensure policies are grounded in robust science, lead to meaningful outcomes, are practical to implement and have a fair transition time.
Some of the policies build on all the great work many dairy farmers have already been leading on, which we know will make a real difference to water quality.
For example, DairyNZ supports the proposed mandatory farm environment plans as the best way to manage the environment on-farm and to further improve water quality outcomes quickly.
Through our Dairy Tomorrow strategy the dairy sector has already made a commitment for all farmers to have farm plans.
However, we do have some concerns around how the plans will be rolled out under the Essential Freshwater Package.
In principle, we support national standards for winter grazing, another key proposal. Most of the practices the Government wants to see farmers adopt are already part of good management practice for the primary sector. But we would like to see some of the proposed definitions, like pugging, improved.
We support stock exclusion as one of the most effective measures for reducing nutrients, sediment and bacteria entering permanent waterways. Through the Sustainable Dairying: Water Accord dairy farmers have already made significant progress on this issue. Our scientists are reviewing what evidence there is on whether a proposed 5m buffer requirement will be effective.
We are broadly supportive of no further increases in nutrient and sediment loading occurring in over-allocated catchments until regional councils have set limits for their areas. Any increases in loading in these areas might require all farmers to make greater reductions to their footprint in future. Increases are already prohibited for many regions through existing regional rules. In catchments that are not over-allocated we support taking a measured approach.
While we support policies that will protect ecosystem health alongside swimability we don’t support the new nitrogen and phosphorus bottom lines proposed. We don’t consider the new thresholds are scientifically robust or view them as the most effective way to improve waterways.
We are concerned focusing on just nitrogen loss reductions on farms won’t deliver the ecosystem health improvements the community wants to see.
Instead, we would like to see a focus on achieving improvements to ecosystem outcomes in at-risk catchments. At the same time we recognise the need to manage high nitrogen losses across many catchments and believe a focus on improving practices through farm environment plans is the best way to achieve that.
We don’t think an adequate assessment of the economic and social impact of the proposals on farmers and regional communities has been included with the package. We are doing a more robust analysis for our submission and we will share this with dairy farmers once it’s available.
An extension was granted to the original October 17 consultation deadline following pressure from DairyNZ and other agricultural organisations. Submissions can now be made until October 31.
I would really encourage you to make a submission.
The proposals could result in some significant effects on farmers and we have only one chance to make our voices heard.
DairyNZ has developed a submission template you can use. You can also make a submission online.
Thank you for the feedback we have gathered from speaking to farmers and at the farmer meetings and webinars held in September and early October. Much of this will be included in our submission, which we are continuing to refine as we gather more information and analysis.
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Visit dairynz.co.nz/freshwater for the latest information and submission details. If you have any questions you can get in touch with our regional teams. They are happy to talk through any queries and provide support with making a submission.
