Federated Farmers Northland province found the overall thrust of Northland Regional Council policy-making was appropriate for dairy, sheep and beef cattle farmers.
In particular, it responded to livestock exclusion rules, setback distance from waterways, farm wastewater storage, wetlands and catchment plans for improving water quality.
It said Northland’s freshwater resources were in a reasonable state and over-allocation and nitrate loadings were not issues.
It complimented the council on its decision to not include nitrate caps in the regional plan.
It also highlighted a council comment from the draft plan, “On the face of it, there is no river water quality issue that justifies high-cost interventions.”
But the federation agreed sedimentary loss and E. coli bacteria levels in Northland’s waterways did need addressing and it argued for targeted intervention, not universal rules.
For example, E. coli sources included livestock, wildfowl and wild animals so livestock exclusion through fencing rules was not going to fix the problems.
In general, the federation agreed with the concept of stock exclusion rather than prescriptive fencing rules, to allow farmers to adopt whole-farm policies using management, natural barriers and perhaps use riparian grazing when needed.
It argued for the use of farm management plans rather than universal rules, to preserve appropriate flexibility and farmer co-operation.
The high cost of deer exclusion fencing and the potential for that to work against deer farming in Northland were highlighted.
Federated Farmers objected to a new requirement that dairy farms with consent to discharge would also need sufficient storage to avoid discharges from May to September.
Such large storage ponds could cost up to $200,000 each, it said.
In its submission, DairyNZ acknowledged the hard work by the council to strike an appropriate balance between economic, social and environmental values.
It had concerns on behalf of dairy farmers in the province regarding proposed new requirements for water-take consents and the speed with which they would be introduced.
The permitted takes would not be adequate for 90% of dairy farms, requiring them to obtain consents for farm dairy shed use.
“This is a significant concern for existing farmers who are practising reasonable use of water to meet food-safety and animal-welfare requirements.
“The permitted activity allowance needs to recognise this reasonable use, particularly where significant investment has been made in farming infrastructure,” DairyNZ said.
Farmers who had been consulted also wanted DairyNZ to point out the inequity of an allocation per property, regardless of size.
That would mean a 4ha orchard could take 10 cubic metres a day as a permitted activity, the same as a 100ha dairy farm.
Beef + Lamb New Zealand also supported the non-regulatory approach evident through encouragement and subsidisation, riparian planting, erosion and sediment control, wetland rehabilitation and livestock exclusion.
It strongly supported the catchment planning approach to freshwater quality, identifying specific values, issues and solutions among the local people.
B+LNZ drew attention to the voluntary farm environment plans throughout the region, being targeted and proactive management of specific risks.
“This approach is more enduring and will be far more effective in addressing environmental issues than blanket and blunt regulatory methods.
“As such, B+LNZ encourages the council to support and endorse voluntary industry farm environment plans as a legitimate and effective way of addressing complex environmental issues.”
Council policy development manager Ben Lee said 250 submissions on the draft plan were received.
A proposal to allow the burning of silage wrap had received a large number of submissions.
Key proposed changes the council had been consulting on included new limits on taking water from rivers, lakes and aquifers, making it easier to get permission for mangrove removal and new stock exclusion rules for rivers, drains, wetlands and lakes.
