Freshwater Consultation 2016

Transcription

1 SUBMISSION TO THE MINISTRY FOR THE ENVIRONMENT on Freshwater Consultation 2016 From Deer Industry New Zealand 22 April 2016

2 1. 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 Next steps for fresh water: Consultation document (MfE publication number: ME 1233). 1.2 New Zealand is the world s largest producer of farmed deer. The main products marketed from deer are venison and deer antler velvet and approximately 95% of products are exported. In the year ending 30 September 2015, deer products were worth $255m in export receipts to New Zealand. 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 producers and processors of venison and velvet. There are roughly 1,800 deer farmers and 16 processing plants that slaughter deer, of which 12 slaughter only deer. 1.5 The DINZ contact for this submission is: Page 2 of 8

3 2. Scope of Submission 2.1 DINZ will confine the submission to the following proposals: Freshwater and our environment: 1.1, 1.2 ( maintain or improve overall water quality) 1.3, 1.4 (MCI as a measure of water quality) 1.8 (stock exclusion from water bodies) Economic use of fresh water: 2.1, 2.2, 2.3 (technical efficiency and good management practice standards) 2.4 (transferring consents to more efficient, higher valued uses) Freshwater funding: 4.1 (freshwater improvement fund) 2.2 Overall DINZ supports the intent of the proposals outlined in the consultation document and the recognition that diffuse pollution sources from intensive farming and urban stormwater requires ongoing focus and a new approach. As such DINZ supports the Government s collaborative approach through the Land and Water Forum (LAWF) and other fora that include a diverse selection of stakeholders. 2.3 DINZ encourages the Government to continue this approach and seek to include smaller industries including the deer industry in further discussions regarding on-farm freshwater management. 2.4 As a smaller industry, deer farmers face more challenges in being able to engage meaningfully at regional and catchment levels. As a result there has been inadequate representation of deer farmers interests and more importantly informing policy makers of deer behaviours, industry-agreed management practices to reduce deer behavioural impacts on the environment and the long association that deer farmers have with environmental initiatives. More often than not it is apparent that policy makers are unaware of how deer are farmed and will then assume that policies and rules that are developed with cattle and sheep in mind can be transposed on to deer farming with little or no modification. 3. Freshwater and our environment 3.1 Proposal 1.1: Amend Objective A2 of the National Policy Statement for Freshwater Management so that it applies within a freshwater management unit, rather than across a region. 3.2 DINZ supports the proposal as is worded, since setting objectives and limits will be determined by communities at the freshwater management unit (FMU) level. Although not directly pertinent to the proposal, DINZ regards the engagement and representativeness of communities within FMUs as extremely important and considers that this has been poorly executed in several regions to date. We recommend that additional guidance be developed for management of FMUs that cross council boundaries. 3.3 Proposal 1.2: Clarify that councils have flexibility to maintain water quality by ensuring water quality stays within an attribute band, where it is specified in the National Page 3 of 8

4 Objectives Framework, or demonstrating that the values chosen for a freshwater management unit are not worse off, where an attribute band is not specified in the National Objectives Framework. 3.4 DINZ supports the proposal. Providing a range within an attribute band will allow a more realistic reflection that water quality attributes are not static over time and may fluctuate despite council policies and adherence to good land management practices. 3.5 Water quality in a catchment may be influenced by long-term groundwater movement such that historic land use may continue to impact on current and future water quality measurements. Legacy groundwater quality may compromise on-farm and other catchment activities and will require sufficient regional council resourcing to determine likely sources of impacts and their magnitude on water quality. DINZ notes that this is an expensive and typically under-resourced activity for most regional councils. 3.6 Proposal 1.3: Require the use of Macroinvertebrate Community Index (MCI) as a measure of water quality in the National Policy Statement for Freshwater Management by making it a mandatory method of monitoring ecosystem health. 3.7 DINZ neither opposes nor supports this proposal but notes that any justification for the introduction of a holistic indicator of (aquatic) ecological health should be scientifically sound and agreed to by relevant Te Mana o te Wai stakeholders. As this proposal was not covered by The Fourth Report of the Land and Water Forum 1 further reference to appropriate fora and consensus would be helpful. Given the ongoing assessment of MCI outlined in proposal 1.4 below, DINZ would not wish to see this as a mandatory method until activity required by proposal 1.4 was completed. 3.8 Proposal 1.4: Work with the Land and Water Forum on the potential benefits of a macroinvertebrate measure for potential inclusion into the National Objectives Framework as an attribute. 3.9 DINZ supports this proposal. As the discussion document states: in its current form the MCI does not lend itself to this (an attribute in the National Objectives Framework). However, we will continue working with the Land and Water Forum and the science community to investigate how measures of macroinvertebrates could be included as an attribute. In the interim, monitoring of macroinvertebrates will provide evidence to support how the MCI might be incorporated Proposal 1.8: Create a national regulation that requires exclusion of dairy cattle (on milking platforms) from water bodies by 1 July 2017, and other stock types at later dates (see table 2) DINZ supports this proposal in concept. DINZ notes that the timeframes are consistent with The Fourth Report of the Land and Water Forum, which provided greater detail and justification for classification of farm types, topography and resulting timeframes. DINZ re-iterates the deer industry position that high costs for deer fencing (typically between $25 30 per metre not including labour and the need 1 Land and Water Forum The Fourth Report of the Land and Water Forum. Page 4 of 8

5 to provide a reticulated drinking water supply) and the intensity of livestock on farm necessitate the approach outlined in The Fourth Report of the Land and Water Forum. The proposal for stock exclusion has considerable acceptance and merit for intensively farmed livestock, however the purpose of stock exclusion preventing further degradation of water quality from livestock may also be achieved by other methods. This is detailed in The Fourth Report of the Land and Water Forum and is consistent with a logical risk-based assessment approach DINZ notes that there are many examples of deer farmers undertaking mitigation measures that are both cost effective and effective in minimising impacts on water quality (e.g. by targeting critical source areas such as wallows and fence pacing, or by constructing wetlands and sediment traps at waterway exit points from the farm). These measures are often more affordable than permanent deer fencing and may offer more effective outcomes than a singular focus on stock exclusion. While not part of the consultation document, it is worth noting that these approaches can be documented and justified in a farm environment plan that takes a risk-based assessment approach to on-farm environmental management such as is covered in the Beef + Lamb New Zealand Land and Environment Plan toolkit (LEP) that is supported by DINZ and approved for use in Canterbury and Hawkes Bay regions DINZ is concerned with potential implementation of enforcement through instant fines. Such an approach would need to be context dependent and based on likely environmental impact. For example 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 2. In this case deer were clearly not excluded from the waterway but have minimal and transient environmental impact on water quality enforcement with punitive fines would be counter to good stock management that results in minimal environmental impact. An approach that combines warning and education, followed by fines is preferable: Instant fines have the potential to consign serious environmental issues to a regulatory tick box exercise only 3.14 As further noted in The Fourth Report of the Land and Water Forum (paragraph 217, recommendation 38, page 54), there are already regions that have effective policies and alternative approaches to stock exclusion or where it is impractical to exclude stock (Westland is provided by way of example). The development of a national regulation for stock exclusion needs to account for these situations. DINZ requests that the appropriate regulatory body that is charged with drafting the national regulation consults closely and meaningfully with affected stakeholders in keeping with the Government s collaborative approach. 2 Focus on Deer newsletter #5, September Sustainable Farming Fund Project 05/ Page 5 of 8

6 4. Economic use of fresh water: 4.1 Proposal 2.1: Require councils to apply technical efficiency standards in catchments that are at, or approaching, full allocation of water. 4.2 DINZ supports this proposal and is encouraged that the Government will coordinate the development of the standards, building on standards that are already being developed by councils and sectors. DINZ supports the proposal as written which defines technical efficiency standards as being applied to water use only. 4.3 Proposal 2.2: Where councils have elected to allocate discharge allowances, require them to apply good management practice standards in catchments that are at, or approaching, full allocation of contaminants. 4.4 DINZ supports the application of good management practices to all land uses in catchments that are approaching or at full allocation of contaminants. It is hoped that good management practice is required of both primary (food) producers and other land users such as urban and industrial entities. 4.5 However the ability to derive numeric limits of discharges when operating at known good management practices is limited and problematical due to the wide range of environments and farming systems within New Zealand. DINZ opposes any attempt to determine farm-specific hard limits for contaminants based on the farm operating at good management practice. The introduction of protocols and standards to measure and monitor water quality and other quantifiable objective measurements would be more appropriate. 4.6 The development of industry-agreed Good Management Practices through Environment Canterbury s Matrix of Good Management Project has highlighted that managing diffuse, non-point source discharges of contaminants to waterbodies is both complex and difficult to quantify at a farm scale. The major modelling tool to estimate nitrogen and phosphorus loss from farms, OVERSEER, is unable to account for many of the good management practices and as a result proxy modelling settings have to be used where possible 4.7 As has been previously mentioned, the use of an on-farm risk-based assessment approach can identify appropriate mitigation methods for each farm. This then allows the farm to choose relevant good management practices (for both point source and diffuse contaminant discharge) and the whole process can be recorded using the Beef + Lamb New Zealand LEP or similar farm environment plan. By utilising LEPs including a formal auditing/verification process, LEP and good management practices can be tailored to each land unit and/or farming system throughout New Zealand. This approach allows flexibility by land managers required to mitigate pollution from a complex ecosystem as well as ongoing improvement. 4.8 Proposal 2.3: Require councils to apply these standards at defined times, for example, at initial limit setting, on consent expiry, and/or on application to permanently transfer consents for water or discharge allowances. 4.9 DINZ considers that technical efficiency standards for water use could reasonably be expected Page 6 of 8

7 to apply at any time and would achieve both productive and environmental benefits. Similarly good management practices would be achievable for most farming businesses Proposal 2.4: Investigate a package of measures to better enable transfers between users so allocated water and discharge allowances can move to higher valued uses DINZ acknowledges that in some circumstances there is benefit and advantages in enabling transfers of water and nutrient discharge allowances. But the mechanisms for transfer require careful consideration and input from a wide range of stakeholders. DINZ wishes to be kept informed of any further work and would be willing to participate in any investigations Allocation and transfer of discharge allowances does require resolution and a national approach to this would remove considerable time and resources for all stakeholders engaged in regional regulatory processes. 5. Freshwater funding 5.1 Proposal 4.1: The Government proposes that eligible projects will need to meet the following criteria: only projects that support users to move to managing within quality and quantity limits will be considered projects will need to demonstrate that they produce environmental benefits projects will be considered if the overall public and private benefits are clearly demonstrated to be greater than the public and private costs irrigation projects will be eligible for funding only commensurate with any environmental benefits that would not be achieved by the funding available from other sources any legal entity will be eligible for funding changes in resource use or other business practices, or installed infrastructure, will all need to be sustainable beyond the length of the project without ongoing Government funding extension programmes will only be funded where there are clearly public benefits and the barriers to success are about adaption and roll out at scale. These projects must continue to meet the initial objectives after the extension funding has stopped if comparable projects achieve similar economic and environmental objectives cost-efficiently, preference will be given to projects that achieve cobenefits, such as improvements in ecosystem health, conservation and climate change government funding should reflect the public benefits of each project and be limited to a maximum of 50 per cent of the cost of any project. Other sources of government funding will not count towards the co-funding requirement. Priority will be given to projects with funding sourced from either business or philanthropic funds, in addition to funding sources from local government Page 7 of 8

8 the minimum government contribution for projects will be $250,000. There will be no maximum contribution. 5.2 DINZ supports the criteria as listed above but considers that projects may still have merit and should be eligible for funding if a sub-set of the criteria is met rather than all of the criteria being required. 5.3 Government activities and funding can greatly assist education and farm management practice change affecting water management and wider environmental stewardship. The implementation of documented on-farm good management practice will likely be the most significant environmental gain for most drystock farming enterprises if this is approached using a risk-based assessment and identification of farm-specific mitigation measures. Farm plans help farmers identify the problem areas on their farm alongside the nutrient inputs and outputs on the property, so any action will start to have a beneficial environmental impact and will be ongoing where there is a requirement to verify actions. 5.4 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. A significant factor in the success is ensuring good independent facilitation from a provider who can bring in relevant science, stakeholders and communities of interest. 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 specialized and multi-disciplined area. 5.5 Resourcing this approach via collaborative (government, local government, industries, businesses) funding would allow more activities such as LEP workshops, development of farm advisors, development of quality assurance systems/programmes. It is important to note that these activities are and will be driven by regulatory requirements rather than commercial market demand (i.e. where there is currently no demand). Page 8 of 8