Contact for service: Lindsay Fung Deer Industry New Zealand P O Box Wellington Phone:

Transcription

1 Southland Water and Land Plan Hearing Statement of Evidence of Richard Cook on behalf of the New Zealand Deer Farmers Association, Southland Branch 12 May 2017 Contact for service: Lindsay Fung Deer Industry New Zealand P O Box Wellington 6143 Phone: Lindsay.Fung@deernz.org

2 Qualifications and experience 1. My name is Richard Cook 2. I hold a Batchelor of Veterinary Science from Massey University 3. I am the Chair of the New Zealand Deer Farmers Association, Southland Branch (NZDFA- Southland), a voluntary organisation representing the interests of deer farmers in the Southland region. Scope of evidence 4. This statement of evidence will cover: An outline of the NZDFA-Southland submission including witness evidence A description of the deer industry in Southland and the region s importance to the industry NZDFA-Southland s response to the Hearing Report (S42A report) recommendations in relation to deer farming. NZDFA-Southland s position on Farm Environmental Management Plans and ongoing collaboration with Environment Southland. Page 2 of 17

3 Outline of the NZDFA-Southland submission Topic Introduction to deer farming in New Zealand and the importance of Southland for the deer industry Comments on the S42A report recommendations: Stock crossing frequency (Rule 70) Winter grazing area 50 ha (Rule 23) Set back distances 20 m (Rule 23 and 25) Capacity to have FEMP completed by 2020 and 2021 to qualify as permitted activity (Rule 20) The Southland Economic Project findings in relation to the Water and Land Plan: Diverse and complex Low inputs few mitigation options Mitigation effectiveness low but reduces profitability greatly Impact of the Water and Land Plan on a large, extensive deer farm (stock exclusion and winter grazing) Impact of the Water and Land Plan on a smaller deer farm (stock exclusion and setbacks) NZDFA-Southland s position on Farm Environmental Management Plans and ongoing collaboration with Environment Southland 1. Use of FEMP supported but requires having the capability to provide advice and assist in developing FEMP takes time 2. What could DFA and DINZ offer to help ES implement FEMP? Speaker Richard Cook (NZDFA- Southland Chair) Lindsay Fung (Deer Industry New Zealand) Simon Wright (Fairlight Station) Andre Cade Richard Cook The deer industry in Southland and the region s importance to the industry 5. The following information is provided in The Southland Economic Project: Agriculture and Forestry, Technical Report (Part B, Chapter 3) which can be accessed at 6. Deer farming is generally located on the Southland Plains or the high country areas in northern and western Southland, as shown in Figure B17. There is a concentration of large farms in the Te Anau Basin and a large number of specialist deer properties occur in and around the Invercargill area. As deer farming is based on annual production of meat and other animal products it shares many similarities with sheep and beef farming. A deer farm can be run as either a specialised deer farm or as a part of a mixed drystock farm. Deer have different seasonal feed requirements to sheep and beef and the three stock types are often seen as complementary, despite the costly investment needed for deer fences. Page 3 of 17

4 Figure B17: Deer farming in Southland 2015 Source: Pearson and Couldrey (2016) 7. In total, it is estimated that deer farming covers around 270,000 hectares of land over 456 properties. 8. Over recent years, an increasing number of large sheep and beef farms in Southland have included deer in their farming mix. Most deer farms (estimated to be over 70%) are now mixed drystock operations typically with sheep and/or beef cattle, but dairy grazing and cropping are also seen. Mixed drystock operations have expanded farmers options for sustained profitability in red meat supply and are an alternative to traditional drystock farming. Deer farms previously tended to be focused on either breeding or finishing but more recently there has been a shift towards both operations on the same farm. 9. Deer farming is a relatively new industry, compared to other pastoral land uses. Southland is the pioneer region internationally for large-scale commercial deer farming. Southland s deer industry currently has the second largest herd and is considered the most advanced deer region in New Zealand, through the provision of high quality genetics, animal specialist support services, transport and processing. 10. The first deer farming licence was issued in Southland in 1970 and the NZ Deer Farmers Association was set up in Initial interest in deer was accentuated by an abundant supply of available stock, through wild deer capture, and the existence of an established wild venison recovery and processing industry. Page 4 of 17

5 11. Since its peak of 5,200 farmers and 2.1 million deer in 2002, the deer industry nationally has contracted to 2,100 farmers and 950,000 deer in However, in Southland the industry is more entrenched than in other regions, and is influenced by Landcorp Farming Ltd. s large deer holdings in the Te Anau Basin. Beyond these holdings, the deer farmers that remain are often from the pioneering deer farming families. 12. Southland quickly became the centre of New Zealand s commercial deer transportation and specialist venison processing plants. The deer industry s growth in the region continued with the entry of the large meat processing co-operatives, Alliance Group Ltd and Silver Fern Farms. 13. The deer industry s presence in Southland is disproportionately larger than most other regions and reflects a number of favourable features for deer farming in Southland. Southland s deer industry is the second largest in New Zealand. Roughly 23% of the national deer herd is in Southland (second only to Canterbury at 28%). About 22% of New Zealand s venison production, but around 35% of the venison processing, and 20% of velvet antler production occurs in Southland. 14. Having Landcorp Farming Ltd and other large corporates in the region means Southland also recruits, trains and employs the bulk of the country s deer farm staff and managers. 15. With several deer slaughter operations in the region processing deer from outside of the region, there is proportionally more downstream employment and added value compared with other regions in New Zealand. 16. Southland also leads the country in deer sector servicing, through livestock company representation and large, specialised veterinarian practices. A deer specialist veterinary network is based on practitioners in Southland, and recognised internationally for their skills and services in deer embryo transfer and artificial insemination, as well as providing veterinary supervision of the velvet antler removal programmes. The region is also home to the largest deer specialist transport companies, is the national hub for wild venison recovery via helicopters, and has several major trophy park operations and other links to international hunting clientele that also engage in adventure tourism, fishing and specialised tourism interests. 17. The region is a major contributor to the national high quality deer genetics pool and the January sales period attracts buyers from throughout New Zealand for elite young sires and capital stock breeding hinds. Page 5 of 17

6 Comments on the S42A report recommendations: Stock crossing frequency (Rule 70) 18. NZDFA-Southland appreciates the recognition by Environment Southland of its concerns regarding the expense for permanent deer fencing which remains the default approach to achieve deer exclusion from water bodies as per paragraph (page 555) of the Hearing Report and that the recommendations are now in line with the proposed national stock exclusion regulations. 19. However the draft stock exclusion regulations are currently being discussed amongst industry, regional council and government organisations with regards to developing guidelines for implementation and interpretation. One are that remains unresolved is the stock crossing frequency for deer, cattle or pigs (paragraph , page 560 of the Hearing Report) which is now recommended as: (a) The disturbance of the bed of a lake, river (including an intermittent river), natural wetland, artificial watercourse (other than a stockwater dam or race), modified watercourse, estuary or lagoon by stock and associated discharges through access by stock is a permitted activity provided the following conditions are met: (i)... (ii) (iii) for the purposes of deer, cattle and pigs crossing a water body: 1. the deer, cattle or pigs are being supervised and are actively driven across the water body in one continuous movement; 2. from 1 July 2019, the crossing occurs less frequently than once per week. 20. NZDFA-Southland recognises the need to distinguish between dairy crossings that are daily and over many months, as opposed to intermittent stock movements, with perhaps velvet removal having the most stock movements (perhaps up to 3 a week over a two month period), weaning may also require some frequent stock movement. NZDFA-Southland refers to the Deer Industry New Zealand submission on this matter which is provided in Appendix 1 of this evidence (see section 5, paragraphs 5.1 to 5.8). 21. Unless there are more frequent stock movements for cattle and pigs, NZDFA-Southland cannot think of any standard deer farming activities that would require frequent stock crossings. To the contrary, few stock movements are preferred to reduce stress on deer. NZDFA-Southland would prefer that the recommended Rule 70 (a)(iii)2 from 1 July 2019, the crossing occurs less frequently than once per week be deleted. Winter grazing area 50 ha (Rule 23) 22. NZDFA-Southland notes that the permitted activity threshold for intensive winter grazing is now recommended in the S42A Report as a standard 50 hectares of winter grazing, regardless of farm property size. The rationale for this as given in paragraph (page 283)is that: Some submitters point out that Rule 23 would require some larger farms to Page 6 of 17

7 obtain resource consent to winter their own stock. This is likely to be the case. However, the ownership of stock does not affect the contaminant loss from an intensive winter grazing operation, so I see little value in regulating on this basis. I consider it appropriate that larger wintering operations where the stock are owned by the landowner receive the same treatment in Rule 23 as those where the stock belong to another party. 23. NZDFA-Southland does not consider the ownership of stock to be the issue but rather that additional stock that is brought in to a farm places increased risk of environmental degradation through intensive winter grazing. This is because there are extra inputs, possibly beyond the natural carrying capacity of the land. 24. By way of contrast, large, extensive farms are lightly stocked across the whole property, but may still require intensively grazing over winter. As a standard practice it should not contribute any more environmental degradation (on a per hectare basis) than a smaller farm that does not bring in any additional stock. The requirement to operate at good management practice is the most cost effective approach to ensuring that winter grazing impacts on water quality are minimised. Requiring these farms to go through a consenting process will do little to improve environmental outcomes, but add cost and divert resources to the administration of the consent (for both the land owner and the council). 25. Simon Wright, a deer farmer from Fairlight Station, will speak to this point using his farm as an example of this issue. 26. NZDFA-Southland considers that the originally drafted proposal that area of winter grazing be restricted to 15 % of land area is much fairer to all land owners and should comfortably cover land owners who do not bring on extra livestock to graze. This approach does not create winners and losers based on land area and more importantly does not penalise large, extensive farms that have overall low stocking rates and lower impacts than smaller, intensive farms. Set back distances of 20 m (Rules 23 and 25) 27. NZDFA-Southland notes that the S42A Report recommends that a vegetated buffer strip of 20 metres is established between the edge of a waterbody and an area of winter grazing or cultivation where there is a slope of 9 degrees or more. This length was determined after discussion with the Council s science team (see paragraph 7.615, page288) which also acknowledged the use of good management practices: Advice has been sought from Council s science team as to the appropriate sizing of setback distances between water bodies and areas of cultivation and winter grazing. The general advice received is that the most effective means of reducing sediment loss from cultivated and winter grazed areas requires a combination of risk assessment prior to the selection of land areas for cultivation and the implementation of GMPs, and needs to include careful and considered location, timing and method of cultivation and or grazing of fodder crops along with implementation of sediment runoff management which should include application of buffers between cultivated areas and streams. This advice is also that while there are a number of GMPs that can be used to mitigate non-point source loss of sediment from cultivation and winter grazing activities, these need to be tailored to the specific situation. Page 7 of 17

8 28. Paragraph (page 290) provides further rationale for 20 m: above 9 degrees, a 20m strip is required (for a permitted activity), but consider that a reduced buffer, down to 5m would be acceptable for steeper slopes, provided that adequate mitigation measures are undertaken such as the application of variable buffer width filter strips defined by GIS and terrain analysis, the use of sediment traps, and the exclusion of cultivation and grazing from swales and ephemeral water ways. 29. It would be useful to understand the rationale for determining that 20 m was an effective width as NZDFA-Southland assumes that buffer strips are only as effective as the amount of vegetated cover on the strips and the intensity of rainfall that then mobilises exposed soil from the grazed or cultivated area and flows into a waterbody. Regardless, it is noted that the council science team also acknowledge the role of good management practices and their use can negate the need for the long distance of a setback. 30. The S42A report also refers to strategic grazing investigated by Pastoral 21. The fact sheet for this work shows that grazing progressively towards the waterbody compared with grazing away from the waterbody provides a 90% reduction in sediment and an 83% reduction in phosphorus. This would suggest that the need for a 20 m setback is not a fixed certainty and that the use of strategic grazing perhaps in conjunction with sediment traps where possible and a reduced setback would result in a better environmental outcome than a simple metric with unclear rationale. Capacity to have FEMP completed by 2020 and 2021 to qualify as permitted activity (Rule 20) 31. The S42A report recommends that farms complete a Farm Environment Management Plan (FEMP) by certain dates to qualify as a permitted activity and that otherwise they would revert to a discretionary activity (paragraph 7.477, page 254): I recommend amending Rule 20 so that FEMPs are staged by FMU, with timeframes aligned with FMU processes and commencing after the pswlp is expected to be operative. This would see very few farms required to prepare their FEMP by 1 May 2019 (Fiordland and the Islands FMU), approximately 1,500 required by 1 May 2020 (Mataura and Aparima FMUs), and the remaining 1,500 to be prepared by 1 May 2021 (Waiau and Oreti FMUs). 32. While it is understandable that alignment with the FMU (limit-setting) processes would be helpful, NZDFA-Southland remains concerned and seriously doubts the ability for 3000 farms to complete FEMPs within four years. These concerns were raised in the original submission and are repeated for emphasis: NZDFA-Southland has concerns that the current availability of farm (environmental management) advisory services for sheep, beef and deer farms is extremely limited and is already in demand in other regions across the country (e.g. Hawkes Bay, Lake Rotorua, Canterbury). Advisory services need to cover both farm environment planning and nutrient management (using OVERSEER to model nutrient losses). Capability in both these areas is further skewed towards dairy farm systems, with sheep and beef systems a distant second and deer systems most poorly represented. As a result it is quite possible that many deer farmers will not have the ability to provide the required Management Plan within the given deadlines and would therefore have to apply for a resource consent as a discretionary activity. Page 8 of 17

9 If deer farmers need to apply for resource consent, due to the lack of advisory services to prepare Management Plans, there is potential for those farmers to be faced with uncertainty, delays and more onerous requirements, but not necessarily more effective environmental management outcomes. Currently in the Manawatu, DairyNZ estimates it costs dairy farmers $5,000 to apply for a consent that includes the equivalent of a Management Plan. It is unlikely that this cost would be any cheaper in Southland a point acknowledged in the Section 32 Evaluation Report. 33. NZDFA-Southland does not oppose the requirement to have FEMPs and acknowledges their value to formally record good management practices appropriate to the particular risks onfarm. But it strongly disagrees with an outcome that could see many deer farmers have to undertake a costly consenting process due to a lack of advisor capability and capacity which is beyond the control of deer farmers and NZDFA-Southland. 34. Other than a greater understanding of nutrient management, NZDFA-Southland considers that deer farming activities as a whole will not greatly change under the Water and Land Plan. This is because generally deer farming is a low input, low (nutrient) output production system, albeit with specific considerations for deer behaviour. Deer Industry New Zealand Environmental Policy Manager Lindsay Fung will expand on this. 35. It is therefore hard to see what benefit will be derived (either environmentally or administratively for the council) by placing unrealistic timeframes for deer farmers to develop FEMPs or revert to a consent. NZDFA-Southland s position on Farm Environmental Management Plans and ongoing collaboration with Environment Southland 36. Given the retrenchment of deer farming in the region, NZDFA-Southland is acutely aware of land use change in Southland over recent years and how intensification of agriculture has impacted on water quality in the region s waterbodies and therefore understands that farming in today s context is quite different to that of ten or twenty years ago. Environmental stewardship is now a co-requisite with the production of food from the land and good management practices that reflect this are an expected minimum requirement. 37. Accordingly NZDFA-Southland acknowledges the valuable role that FEMPs will play in recording farmers identified good management practices and as means for verification of actions. Because the FEMP is intended to identify environmental risks within the context of the farm land, climate and stock management, it represents the most cost-effective method to focus actions on the greatest environmental risks for that farm. 38. NZDFA-Southland supports the use of FEMPs and notes that these are also required or proposed for other regions that have significant intensive farming activities (Canterbury, Waikato and parts of Bay of Plenty). The issue of a lack of deer farm advisory capability is therefore very real and likely to require some years to develop to a level and quantity that could cover the estimate 450 properties that farm deer. Page 9 of 17

10 39. In acknowledging the role of FEMPs for the Southland Water and Land Plan but also the concerning lack of capability for deer farm advisory services (in both Southland and nationally), NZDFA-Southland repeats its offer to work constructively with Environment Southland to identify good management practices for deer farmers and discuss how capability for FEMP development can be accelerated in Southland. As a small, voluntaryfunded organisation it has limited resources but has a long and extensive corporate knowledge and awareness of deer farming within the region and will look to assist the council where it can in these matters. 40. NZDFA-Southland has recently collaborated with Environment Southland on the Southland Economic Project and also collaborates closely with DINZ, the national levy-funded industrygood organisation and will request its assistance where this is appropriate and achievable in order to develop or possibly implement FEMPs for deer farmers. Already DINZ is looking to develop a national environmental management code of practice and Environment Southland has been invited to be part of an editorial review team. 41. NZDFA-Southland thanks the commissioners for hearing our concerns. Page 10 of 17

11 Appendix 1: Deer Industry New Zealand submission to The Ministry for the Environment on Clean Water 2017 SUBMISSION TO THE MINISTRY FOR THE ENVIRONMENT on Clean Water 2017 From Deer Industry New Zealand 28 April 2017 Contact for this submission: Lindsay Fung Environmental Policy Manager Deer Industry New Zealand P O Box Wellington 6143 Phone: Lindsay.Fung@deernz.org Page 11 of 17

12 DINZ submission on Clean Water 2017 Contents 1. Introduction Scope of Submission Funding to improve fresh water Keeping stock out of our waterways start date, definitions and riparian buffers Keeping stock out of our waterways stock crossings Keeping stock out of our waterways stock exclusion plan Conclusions Introduction 1.1 Deer Industry New Zealand (DINZ) welcomes the opportunity to make a submission to The Ministry for the Environment (MfE) in response to the consultation document Clean Water (MfE publication number: ME 1293). 1.2 New Zealand has the world s largest modern farmed deer industry. The main products marketed from deer farming (with 95% of these products exported) are venison and deer antler velvet. In the year ending 30 September 2016, deer products were worth $245m in export receipts to New Zealand. It is estimated that 75% of deer farmers also actively farm sheep and/or cattle. 1.3 DINZ is a levy funded industry-good body established by the Deer Industry New Zealand Regulations 2004 under the Primary Products Marketing Act DINZ s functions (under regulation 5(1)) include the following: to promote and assist the development of the deer industry in New Zealand; to monitor, and from time to time report on, the economics and efficiency of all components of the deer industry; and to report from time to time to the Minister and to the Minister of Foreign Affairs and Trade on movements of costs and prices or other factors likely to affect the economic stability of the deer industry. 1.4 DINZ s levy payers are the producers and processors of venison and velvet antler. Venison levies are shared equally each between producers and processor exporters. There are roughly 1,800 deer farmers and 16 processing plants that slaughter deer, of which 12 slaughter only deer. Page 12 of 17

13 DINZ submission on Clean Water Scope of Submission 2.1 DINZ will confine this submission to the following topics: Funding to improve fresh water (page 22) Keeping stock out of our waterways (page 25) 2.2 DINZ supports the broad aim to set ambitious but possible targets for swimmable rivers and lakes as well as enabling mechanisms through provision of better water quality information, amending the National Policy Statement for Freshwater Management (NPS-FM), co-funding community activity, and excluding stock from waterways where practical and effective. As with the previous consultation document (Next steps for fresh water: Consultation document, 2016), DINZ is supportive of the Government s collaborative approach through the Land and Water Forum (LAWF) and other fora that include a diverse selection of stakeholders. 2.3 As deer farming shares many issues and areas of environmental risk with other livestock farming systems, DINZ also supports submissions from industry bodies representing other livestock species farming where these are consistent with deer farming and deer behaviour management. As such DINZ supports submissions from Beef + Lamb New Zealand and Federated Farmers of New Zealand in relation to Amendments to the NPS-FM as follows: The status of water valued for economic wellbeing and for food production is considered alongside other significant values (human and ecosystem health). The swimmable target being applicable only to where this is a value for the waterbody and the need to recognise that this may also involve water ways that are below 4 th order (the current threshold for the swimmable target). In doing so it also should be acknowledged that supporting community catchment initiatives to maintain or improve water quality is an effective approach and that the provision of localised water quality information is fundamental to enable this. 3. Funding to improve fresh water 3.1 DINZ considers that the eligibility criteria that set a minimum request for funding of $200,000 and limits these funds to unreasonably cover a maximum of 50% of the total project cost, sets a distinctly high threshold that discourages small organisations and community-led projects. 3.2 In our earlier 2016 submission, DINZ stated that Government activities and funding can greatly assist education and farm management practice change affecting water management and wider environmental stewardship There are good examples of community-led catchment groups throughout the country that have resulted in agreed actions with the aim of improving environmental outcomes and meeting regional council policy requirements... Funding for more groups in catchments that are seeking to improve degraded water quality would accelerate their formation and allow these groups to secure services from what is a currently small group of facilitators in this Page 13 of 17

14 DINZ submission on Clean Water 2017 specialized and multi-disciplined area (see paragraphs of the DINZ 22 April 2016 submission). 3.3 DINZ considers that the partnership funding model is a very robust approach but the reality of having to provide a minimum of $200,000 from non-freshwater Improvement Fund sources is unaffordable and in our view unreasonable for a small organisation or individual community catchment groups. 3.4 Future funding rounds for the Freshwater Improvement Fund could be more inclusive by reducing the minimum request for funding level to a more attainable $100,000. It is notable that the examples of government investment provided in the map on page 24 of the consultation document are between $55,000 - $140,000 for Community Environment Fund projects and $39,000 - $181,000 for DOC Community Fund projects. 4. Keeping stock out of our waterways start date, definitions and riparian buffers 4.1 The proposed starting date of 1 July 2017 for excluding dairy cattle and pigs from water bodies while not directly impacting on deer farming appears to be overly ambitious. DINZ considers that once all consultation has been fully considered and requirements for stock exclusion are finalised, a more reasonable starting date would be six months following a government decision and announcement of the requirements. While DINZ originally supported the starting date in the earlier consultation stage (22 April 2016), time frames are now considerably reduced and may not result in effective and positive engagement with landowners, which in turn may have flow on impacts to uptake for beef cattle and deer farmers as they are phased in to meet the requirements. 4.2 Definitions of lakes, natural wetlands and permanently flowing as stated on page 28. We refer back to the Fourth Report of the Land and Water Forum s Recommendation 37 that provides further clarity for defining a natural wetland. 4.3 DINZ welcomes ongoing discussion as to how to pragmatically define the above terms to allow land owners to have certainty in their obligations and an understanding of the Page 14 of 17

15 DINZ submission on Clean Water 2017 effectiveness of these obligations in maintaining or improving water quality. 4.4 DINZ notes that a riparian buffer would in many cases be desirable and beneficial when used in conjunction with stock exclusion but does not agree that this equates to best management practice as a blanket assumption. Any requirement from a regional council to combine riparian buffers with stock exclusion would be better determined by considering farm-specific management and circumstances with local catchment water quality issues. This allows factors such as ongoing riparian buffer management (which may require stock grazing to control weeds), logistic capabilities and priority of water quality targets (reduced E. coli and sediment from stock exclusion, or in stream temperature control and shading for biodiversity from riparian buffers). 5. Keeping stock out of our waterways stock crossings 5.1 Proposal (page 28): Stock crossings. Cattle, deer and pigs are able to enter water bodies for the purpose of crossing from one side to the other as long as they are being supervised and are actively driven across the water body in one continuous movement, where this occurs less frequently than once per week. Stock crossings used once or more per week, must be bridged or culverted by 1 July DINZ supports the intention of the proposal but seeks further amendment to distinguish between: Prolonged river crossings (particularly if there are large numbers of livestock) that are frequent and over a long period (and therefore would justify being bridged or culverted), and Crossings that are of short duration (and where stock move quickly across the water body and do not linger) and occur over short periods in the year. 5.3 As the text is currently worded, the sentence Stock crossings used once or more per week, must be bridged or culverted by 1 July 2019 could be interpreted as requiring all stock crossing to be bridged or culverted unless the inference is that this is on an ongoing basis. 5.4 DINZ considers this is not the intent of the text which should consider both the frequency (number of crossings per day/week/month) of stock crossing at any particular location as well as the intensity of the crossing (number of animals per crossing event, duration of animals in or near the water). 5.5 DINZ refers back to its submission on Freshwater Consultation 2016 (22 April 2016), page 5, paragraph 3.13: a mob of 400 deer crossing the Waimea Stream in Southland (when being moved from one paddock to another) have been timed at three minutes to cross. During that time and for four minutes after crossing, water quality guidelines (Australian and New Zealand Guidelines for Fresh and Marine Water Quality October 2000) for Escherichia coli and Dissolved Reactive Phosphorus were exceeded, but over the course of a day these increases were negligible. The conclusion reached in this small on-farm project was that deer quickly crossing have little influence on overall water quality primarily due to the short time spent crossing. 5.6 Other than moving between paddocks, management of farmed deer does not involve numerous stock movements over an extended season such as would occur for dairy cows during the milking season. However there are times when deer movements Page 15 of 17

16 DINZ submission on Clean Water 2017 can be frequent and over shorter time frames. One example would be velvet antler removal that typically occurs over a two month period (October November) where small groups of stags are moved to a deer shed, antlers are removed and the deer are returned to the paddock. Stock may be moved up to three times a week over this period. Other occasions for stock movement include Tb testing, sending stock for slaughter and vaccinating or drenching these are typically annual events. 5.7 An alternative to the current wording that captures the intent is as follows: Cattle, deer and pigs are able to enter water bodies for the purpose of crossing from one side to the other as long as they are being supervised and are actively driven across the water body in one continuous movement, where this occurs less frequently than once per week on average. Stock crossings used once on average weekly, or more frequently per week, must be bridged or culverted by 1 July DINZ would encourage more collaborative discussions with other interest groups to determine appropriate criteria for requiring bridging or culverting and that these are in relation to expected risks and magnitude of the risks to water quality. 6. Keeping stock out of our waterways stock exclusion plan 6.1 Proposal (page 29): Alternative option. Where a land owner is unable to meet the requirements set out above (e.g. due to significant practical constraints), they may apply to the relevant regional council for permission to instead develop a stock exclusion plan. This must set out where and when stock will be excluded from water bodies on their land, and where complete stock exclusion is not feasible, what alternative mitigations will be undertaken to manage the environmental impacts of stock access to water bodies. This could be standalone or form part of a wider farm environment plan or land environment plan and must be approved in writing by the regional council. 6.2 DINZ supports this proposal as a means of demonstrating when the benefits of excluding stock from waterways can be achieved through more cost effective methods or where there is little benefit to be gained from excluding stock based on current management practices, stocking rates and local climate conditions and water quality state. DINZ has previously submitted that exclusion of deer from waterbodies is currently only possible through the use of permanent fencing which is more costly for deer than for other livestock species. 6.3 We submit that the stock exclusion plan, where this is not already included in a regional council-required farm environment plan (or equivalent), should be: Relatively easy to develop by the farmer/owner without the need for a farm consultant. An administratively simple and non-costly procedure for the relevant regional council to approve in writing. Not require disproportionate expense and time to inspect or verify (or take on the role of a quasi-consent). 6.4 In the supporting document to the Clean Water publication, Appendix 5 Draft RIS Stock Exclusion, paragraph 112 (page 24) states: In limited cases, stock exclusion Page 16 of 17

17 DINZ submission on Clean Water 2017 may be impractical and not justified by environmental benefits (for example, where paddocks are intersected by many waterways and stocking density is very low, as on some West Coast farms). DINZ also notes that the Fourth Report of the Land And Water Forum s Recommendation 38 also acknowledges these circumstances: 6.5 We observe that the nature of deer farming in hill and high country can fit this description where stock exclusion is impractical and the enormous costs required for exclusion through fencing cannot be justified as there are negligible environmental adverse consequences. Recommendation 38 has clear precedence in deer farming locations, further emphasising that slope class as a proxy for stocking rate will have some limitations. We also note that in land areas outside the farm boundary it is estimated that some 250,000 wild deer also roam freely with no discernible impact on water quality at its headwater sources. 6.6 Further clarification of alternative mitigations could include current farm management practices if the result is that water quality does not show deterioration from current levels. This may be a particular feature for West Coast deer farms that are not intensively stocked and experience high rainfall in catchments with water quality at acceptable levels. 7. Conclusions 7.1 DINZ supports the broad aim to set ambitious but possible targets for swimmable rivers and lakes as well as enabling mechanisms through provision of better water quality information, amending the National Policy Statement for Freshwater Management (NPS-FM), co-funding community activity, and excluding stock from waterways where practical and effective. 7.2 DINZ is supportive of the Government s collaborative approach through the Land and Water Forum (LAWF) and other fora that include a diverse selection of stakeholders. 7.3 Better access to the Freshwater Improvement Funds for small industries and community catchment groups is requested through lowering the level of required cofunding. 7.4 Excluding stock from waterways where practical and effective is supported although DINZ requests more clarification of definitions, stock crossing and stock exclusion plan criteria. DINZ welcomes ongoing collaboration in developing guidance for stock exclusion issues. Page 17 of 17