Submission Form ENVIRONMENT SOUTHLAND WATER AND LAND PLAN - KEY ISSUES FOR SHEEP AND BEEF FARMERS

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1 ENVIRONMENT SOUTHLAND WATER AND LAND PLAN - KEY ISSUES FOR SHEEP AND BEEF FARMERS Submission Form Form 5: Submissions on a Publicly Notified Proposed Policy Statement or Regional Plan under Clause 6 of Schedule 1 of the Resource Management Act 1991 Complete the following Full Name: Nathan James Joyce and Julie Louise Joyce Phone (Hm): Phone (Wk): Postal Address: 236 Kee Road, RD3, Gore Phone (Cell): Postcode: nathanjulie@yrless.co.nz I am not a trade competitor for the purposes of the submission but the variation has a direct impact on my ability to farm. If changes sought in the plan are adopted they may impact on others but I am not in direct trade competition with them. I do wish to be heard in support of this submission.

2 The specific provisions my submission relates to are: My submission is that: State: The decision I would like Environment Southland to make is: Give: whether you support, oppose or wish to amend each provision listed in column 1; and brief reasons for your views. precise details of the outcomes you would like to see for each provision. The more specific you can be the easier it will be for the Council to understand the outcome you seek Physiographic Zone I support that Environment Southland has used physiographic zones to identify risk.

3 Rule 22 - Dairy conversions I support ES on the proposed rule for dairy conversions. We have been sheep/beef farming in Southland for 30+ years on Bedrock/Hill Country. We have always farmed appropriately to the contour of the land and to the heavy soil nature of our property. We have never wintered heavy cattle on our paddocks for the very reason that it would have adverse effects on soil structure, water quality and animal welfare. Please explain why our high standard of farm management practice and consequently the way we will now have to farm in the future, be impacted by rules and regulations being imposed on us that are set up to regulate those who have chosen detrimental ways of farming to produce what they think is greater financial gain.

4 Glossary Intensive Winter Grazing I oppose. The reasons for this are: I propose Sheep should be excluded from the definition and classified as a Permitted Activity. The winter grazing of sheep have not caused the detrimental effect to the water system, of which other farming activities that others pursue, have. No set parameter on stocking rates for sheep. The cost of consent for winter grazing for a sheep farm for an activity that is a requirement for our financial viability is not economically viable for our operation.

5 Rule 23 Intensive Winter Grazing I oppose And Rule 25 Cultivation of Sloping Ground The reasons for this are: A large percentage of hill country farmers don t have the luxury of a high percentage of flat ground to cultivate and get their required crop hectarage. We will run into weed/pest issues having to constantly crop the same areas as well as compaction problems. Apply a 25degree slope policy for cultivating land. Small percentage areas of above 25 degrees should be allowed to be cultivated also for ease of management (eg, a paddock that majority is <25degrees, but has 2% ground area of >30degrees should be permitted). 20m buffer zone for 20degree slope is too long. A significant amount of farmland will be unused, which should be cultivated. Again, this won t be financially viable for our farm operation to not utilise all our productive land. A 4 metre buffer is ample for all situations. Unreasonable to expect all drains to be identified in Intensive Winter grazing. Especially if you have purchased a farm where you don t have any idea where the drains are. Who will pay for this farmer to find all of his drains?

6 Rule 70 - Stock exclusion I support the following: See page 7 of B+LNZ summary for more information Sheep being excluded from the stock exclusion I oppose the following: There being any degree of gradient, when this rule is being imposed for all year round it isn t clear if it is or not. What is the definition of a waterbody? We have stock water dams in the majority of the paddocks. Will ES pay for a reticulated water scheme to go in, if we have to fence off these water bodies? Clarification of the definition of Waterbody needed.

7 Rule 13 Discharge from installed subsurface drainage systems I support/ oppose/ wish to amend (delete as required) The reasons for this are:

8 Appendix N Management Plan Requirements See pages 9-10 of B+LNZ summary for more information I support the following: Completing a simple, annual farm management plan I do not support the following: If you commented on management plan review frequency - what would be a better alternative? If you commented on the start/ finish dates - what would be a better cycle? Nutrient budget for sheep and beef farmers. Must follow farm financial year: 1 July 31 st June If you commented on the frequency of nutrient budget reviews - what would be a better alternative? ES need to state how much a consent will be. We suggest no cost but a penalty system when a direct breach is made on water quality.

9 Rule 20 Farming I oppose. The reasons for this are: What are the reasons for identifying farms that are <20ha with no specific physiographic zone limitation on them, as a permitted farming activity. This means that a farm on Peat Wetlands could intensively graze stock on all 20ha, and cause more damage than what a larger farm on bedrock/hill country does. Appropriate distinctions required that are reasonable and fair. Prior to the ES plan being confirmed and finalised; ES MUST visit EVERY farm in the ES catchment. A farm tour should be conducted ensuring each farm s unique attributes are being considered in the plan not a blanket ban as what is being proposed. Water samples should be taken and discussion surrounding the positive and negative impacts the plan will have on both immediate and future farm viability, both economic and environmental.