The federation acknowledged the conflict the plan presented to it, given the controversial effect of the plan’s nitrogen limitations on dairy versus drystock operators.
Its submission maintained the plan was “divisive”. It had distilled its submission down to concerns in three key areas.
But Waikato Federated Farmers president Chris Lewis said the federation also had concerns over the science used by the Healthy Rivers’ Collaborative Stakeholder Group, on which many of the assumptions and impacts of the plan change would swing.
Even under the group’s own analysis those impacts were likely to be significant, with the 10-year economic impact estimated to cost $193 million a year over its first 10 years in lost income were the plan changes to be implemented immediately.
That included estimates of 1880 jobs lost with only forestry experiencing some small gains in job numbers as trees replaced cows.
“But we are taking the approach that environmental change is happening, like it or not, so let’s make it a process where we can all get the greatest gains.
“We have now had some experience in this, learning what works and what does not in other regions like Manawatu and Canterbury,” Lewis said.
The submission focused on nitrogen allocation, fencing and land use flexibility.
It was “strongly opposed” to the existing nitrogen limitations or nitrogen reference points being placed on landowners. They were based on nitrogen use in 2015-2016, preserving levels for all those other than the top 25% of emitters.
Instead, the federation pushed for a best-practice approach until sub catchment plans were completed, as was being done in Canterbury and using the reference points only as an indicator of which farmers were the highest nitrogen polluters.
The requirement that all land over certain slope levels be fenced was regarded as “inequitable, repressive and unnecessary”.
Lewis said the federation’s preference was instead to see more of a national standardised approach to fencing requirements, based on what the Government proposed in its fresh water regulations earlier this year.
“As it stands regional rules are simply going to be too divisive.”
Thirdly, the land use change rules made it almost impossible to switch from any other land use to dairying and other land use changes were restricted to no more than 15kg of nitrogen a hectare a year in losses.
All three factors culminated in significant extra costs for farmers and the federation pointed to mitigation surveys it did on farms to highlight the expense it pushed onto farmers.
Drystock properties were going to have to spend $300,000-$785,000, depending how the council’s rules on farm environment plans were interpreted.
“Basically, you are looking at drystock operators having to spend about $800 a hectare to meet the regulations.”
The submission urged council to instead focus more on sub catchments within. It wanted to stick with the plan’s intent to make the rivers healthy enough to swim and fish from while enabling farmers to achieve that in ways specific to each sub-catchment’s unique characteristics.
In coming months a scientific report commissioned by Federated Farmers on data used in the collaborative group’s work was due to be completed and peer reviewed before being presented to the council.
“The question was whether we can trust the science behind the CSG’s analysis,” Lewis said.
