SUBMISSION ON SOUTHLAND WATER AND LAND PLAN

Transcription

1 SUBMISSION ON SOUTHLAND WATER AND LAND PLAN To: Southland Water and Land Plan Environment Southland Private Bag 90116, Invercargill 9840 Submission on: Name of Submitter: Address of Submitter: Proposed Southland Water and Land Plan (PSWLP) Ravensdown Limited (Ravensdown) PO Box 1049 CHRISTCHURCH C/- CHC Ltd P O Box Tawa WELLINGTON 5249 Attention: Chris Hansen Phone: Chris@rmaexpert.co.nz 1. The specific provisions of the proposed plan change that Ravensdown s submission relates to are: The Proposed Southland Water and Land Plan as included in the attached submission below. 2. Trade Competition Ravensdown could not gain an advantage in trade competition through this submission. 3. Ravensdown s submission is: Refer to submission points below. The relief sought by Ravensdown are also outlined in the submission points below. 4. Ravensdown wishes to be heard in support of this submission. Ravensdown would be prepared to present a joint case with others that have made similar submissions at a hearing... Chris Hansen Authorised Agent for Ravensdown Limited 1 August 2016

2 Plan Provisions Page Number Submission Oppose/support Reason Issues Issues Soil Page 15 Support Recognises the benefits of fertilisers to the Resources soil resource and plant growth I seek the following decision Ravensdown seeks the reference to the benefits of fertiliser to the soil resource and plant growth to be retained as written. Region wide Objectives Objective 1 Page 22 Support The objective is appropriate and necessary. Ravensdown seeks for Objective 1 to be retained as written. Objective 2 Page 22 support The objective is appropriate and necessary. Ravensdown seeks for Objective 2 to be retained as written. Objective 3 Page 22 Support in part While Ravensdown supports the intent of the objective, it is not clear how the achieving the objective will be measured presumably meeting the targets and limits included in the Plan will meet this objective? Objective 4 Page 22 Support in part While Ravensdown supports the intent of the objective, it questions the use of the term identified and reflected and suggests recognised would be more appropriate. Objective 6 Page 22 Support in part While Ravensdown supports the intent of the objective, the current structure could be improved. Ravensdown seeks for the intent of Objective 3 to be retained, with an indication included that meeting the targets and limits in the Plan will achieve these outcomes. Ravensdown seeks for the intent of Objective 4 to be retained, with the following amendment: Tāngata whenua values and interests are identified and reflected recognised in the management of freshwater and associated ecosystems. Ravensdown seeks for the intent of Objective 6 to be retained, and amended to read: There is no reduction in the quality of freshwater, and water in estuaries and coastal lagoons, by: (a) maintaining the quality of water in waterbodies, estuaries and coastal lagoons, where the water quality it is not degraded; and

3 Objective 7 Page 22 Support in part Ravensdown questions the intent of the objective, as it is not clear how water quality can be over-allocated. Ravensdown considers the objective should refer to the contaminants (nutrients, sediment and pathogens) that can lead to the effects on water quality. Objective 8 Page 22/23 Support in part While Ravensdown supports the intent of the objective, as currently written it is a mix of what is to be achieved (objective) and how it will be achieved (policy). Objective 13 Page 23 Support While Ravensdown supports the intent of the objective, it considers Clause (b) should address significant or cumulative adverse effects. Objective 18 Page 24 Oppose Ravensdown opposes Objective 18 as Good Management Practice (GMP) is a method of achieving a number of the objectives included in the Plan and belongs in the policies and rules. The objectives providing for the sustainable management of the natural and physical resources are already well defined by Objectives (b) improving the quality of water in waterbodies, estuaries and coastal lagoons, that have where it has been degraded by human activities. Ravensdown seeks for the intent of Objective 7 to be retained, and amended to read: Any further over-allocation of freshwater quantity and of contaminants that may affect freshwater quality (including nutrient, sediments and pathogens) is avoided and existing overallocation is phased out in in accordance with timeframes established under Freshwater Management Unit processes. Ravensdown seeks for the intent of Objective 8 to be retained, and re-written to read: The quality of water in aquifers is maintained where it currently meets standards and any freshwater objectives, and is improved where degraded by land use and discharge activities. Ravensdown seeks for the intent of Objective 13 to be retained, with clause (b) amended to read: (b) the discharge of contaminants to land or water that have significant or cumulative adverse effects on human health are avoided Ravensdown seeks for Objective 18 to be deleted as Industry Good Management Practice is a method to achieve the objectives. The objectives providing foe the sustainable management of the natural and physical resources in Southland are already well defined by Objectives By nature, this objective requires that for all activities, environmental management practices are placed above all other

4 considerations for management of land use activities and so could have significant economic and social consequences. Region-wide Policies Policy 2 Page 25 Neutral Ravensdown is unaware what the Ngāi Tahu indicators of health are, what process they have gone through, and whether they are to be included in the plan by way of reference. Ravensdown questions the appropriateness of assessing water quality based on these indicators. Policies 4-12 Pages Support in part and amend Ravensdown notes the overall outcomes relating to controlling sediment, nitrogen, phosphorus and microbial contaminants is consistent for all physiographic areas. Ravensdown supports the fact that although the predominant pathway is different in each, no pathway is excluded from any zones. Ravensdown also supports Industry Agreed GMP and Nutrient Management Plans/Farm Management Plans targeting identified risk areas. Ravensdown considers the physiographic characteristics can be identified for particular zone using a schedule rather than a policy and can be grouped for simplicity where similar controls are sought. Ravensdown also notes some rewording is needed as the policies repeats the term Ravensdown seeks for clarification of the appropriateness of the Ngāi Tahu indicators of health to be used in a policy and other provisions in the Plan, and if they are to be used, would seek they be included by way of reference so they can be reviewed for their appropriateness to assess water quality. If they are not to be included by reference, then delete reference to then in the Plan. Ravensdown seeks for the overall intent and approaches included in Policies 4 12 to be retained. Furthermore, Ravensdown seeks Policies 4 12 to be deleted and replaced with the following policies (or similar), with subsequent policies renumbered: Policy 4 Alpine In the Alpine physiographic zone, avoid, remedy or mitigate adverse effects on water quality, by: Controlling land use activities and, Managing the transport of contaminants via overland flow, and Implementing Industry Agreed Good Management Practices, and Prohibiting new dairy farming and new intensive winter grazing, and Not granting resource consents for cultivation, except where the adverse effects are no more than minor.

5 Policy 13 Page 29 Support in part/oppose in part adverse effects on water quality when this is not necessary. While Ravensdown supports the overall intent of the policy, it opposes the intention to protect water quality. The RMA requires the life-supporting capacity of water to be safeguarded, and this is done through maintaining water quality, or improving if degraded. Policy 14 Support in part While Ravensdown supports the intent of the policy, it considers it should be directed to point source discharges as these can be controlled. Policy 5 Old Mataura and Peat Wetlands In the Old Mataura and Peat Wetlands physiographic zones, avoid, remedy or mitigate adverse effects on water quality, by: Controlling land use activities and, Managing the transport of contaminants, and Implementing Industry Agreed Good Management Practices, and Restricting new dairy farming and new intensive winter grazing, except where the adverse effects are no more than minor Policy 6 In all other Physiographic zones, avoid, remedy or mitigate adverse effects on water quality, by: Controlling land use activities and, Managing the transport of contaminants, and Implementing Industry Agreed Good Management Practices. Ravensdown seeks for the intent of Policy 13 to be retained as written, with the following amendment: Manage land use activities and discharges (point source and non-point source) to land and water so that water quality is maintained, or improved where degraded, and the health of humans, domestic animals and aquatic life is protected. Ravensdown seeks for the intent of Policy 14 to be retained, while amending it to read: When considering applications for point-source discharges, P preference will be given to

6 Policy 15 Pages 29/30 Oppose in part Ravensdown considers the wording of Policy 15 needs to be amended to address several matters: Firstly, Ravensdown considers the policy should focus on maintaining existing good water quality, and improve water quality where degraded, to be consistent with Objective 6 above. Secondly, Ravensdown questions why the water quality in all surface waterbodies and groundwater needs to meet the Drinking Water Standards for NZ 2005, as this is what the policy implies as currently worded. Ravensdown considers this requirement should only apply to surface water bodies where water is taken for municipal or domestic water supply purposes. Thirdly, Ravensdown notes that the ANZECC sediment guidelines are required to be met. The ANZECC sediment guidelines sets trigger values at which point a management response is required, not a threshold that must be met. Policy 16 Page 30 Oppose in part Ravensdown considers the wording of Policy 16 needs to be amended to address several matters: Firstly, Ravensdown considers the policy should focus on managing the adverse effects of farming activities which are discharges to land, rather than direct discharges to water. Ravensdown seeks for Policy 15 to be amended to read: Maintain and or improve water quality by: 4. avoiding controlling discharges to artificial watercourses that will reduce water quality in a river, lake or moidified watercourse beyond the zone of reasonable mixing; so that: 3. water quality meets the Drinking-Water Standards for New Zealand 2005 (revised 2008) in surface water bodies where water is taken for municipal or domestic water supply purposes; and 4. ANZECC sediment guidelines (as shown in Appendix C of this Plan) are met or if not met investigated to assess potential for risk. Ravensdown seeks for Policy 16 to be deleted and replaced with the following (or similar): Minimise the adverse effects of farming activities on water quality in rivers, coastal lakes, lagoons, tidal estuaries, salt marshes and coastal wetlands, and groundwater by:

7 defined, not minimising environmental effects which are not defined. Secondly, Ravensdown opposes the use of strongly discouraging as this is arbitrary and undefined. The RMA provides for Council to control the use of land (s.30(1)(c) for the purpose of the maintenance and enhancement of the quality of water. Thirdly, Ravensdown considers the policy should not list application to be discouraged the RMA presumes a consent application can be applied for any activity, unless it is prohibited. a) Controlling the establishment of new dairy farming and new intensive winter grazing activities; and b) Requiring all farming activities, including existing activities, to either prepare and implement a Farm Management Plan as set out in Appendix N, or be part of an Independently Audited Self- Management scheme approved by the CEO of the Southland Regional Council. Ravensdown seeks for definition of Independently Audited Self-Management be included in the Plan. Ravensdown opposes the focus on close proximity to sensitive waterbodies for new dairy farming close proximity is undefined and arbitrary. This can be managed as part of the Farm Management Plan. Ravensdown considers the policy should be re-written and restructured. Activities that affect water quality and quantity Policy 36 Page 36 Support Ravensdown supports the intent of Policy 36. Consideration of Resource Consent Applications Policy 39 Page 38 Oppose Ravensdown opposes this policy as it is contrary to the Permitted Baseline principle, Ravensdown seeks for the intent of Policy 36 to be retained as written. Ravensdown seeks for Policy 39 to be deleted.

8 and matters to be considered when assessing the receiving environment. Effects that are associated with permitted activities are deemed to be appropriate, and should not be revisited when the consent authority decides it wants to. Policy 40 Page 38 Oppose in part Ravensdown opposes the inclusion of Clause 6 which is vague, inappropriate and unnecessary. The clause could apply to any unrelated resource consent and seems to address historical non-compliance which is irrelevant to determining the duration of a consent. Ravensdown also has questions regarding the intent of Clause 7 which creates uncertainty. Policy 41 Page 38 Support While Ravensdown supports a risk based approach with a proportionate response and requirements, it considers the term magnitude is uncertain, and would prefer the term significance which is consistent with the terminology used in the RMA. Policy 42 Page 38 Support in part Ravensdown considers Policy 42 addresses resource management issues associated with the take and use of water, and not discharges (which may include contaminants). Freshwater Management Unit Process Policies Policy 45 Page 40 Support Ravensdown supports the clarity that the FMU policies and rules will take precedence over the policies and rules in the proposed plan. However, Ravensdown considers the heading does not reflect the text of the Ravensdown seeks for Clause 6 in Policy 40 to be deleted, and Clause 7 be either re-written to remove any uncertainty, or deleted. Ravensdown seeks for the intent of Policy 41 to be retained, while replacing the term magnitude with the term significance. Ravensdown seeks for the intent of Policy 42 to be retained, while amending the policy to clarify it applies to the take and use of water, and not discharge. Ravensdown seeks for Policy 45 to be retained as written, while changing the policy heading to read: Priority of FMU Objectives and Policies.

9 policy (there are no references to rules), and should refer to objectives and policies. Policy 46 Page 40 Oppose Ravensdown considers this policy does not add value to the Plan, and is unnecessary this information could be included in a Schedule if considered necessary. Policy 47 Page 41 Support Ravensdown supports the intent of Policy 47. Discharge Rules Rule 5 Page 43 Support in part Ravensdown notes that Rule 5 does not apply where a discharge is provided for elsewhere in the Plan as fertiliser application is provided for in Rule 14, it is exempt from this rule. Ravensdown supports Rule 5 on this basis. Notwithstanding this support, Ravensdown questions how this rule might apply to nonpoint source discharges and as previously noted, a reasonable mixing zone cannot be easily applied to such discharges. Rule 7 Page 43 Amend Ravensdown considers any discharge to a surface waterbody is covered by Rules 5 and 6, and therefore Rule 7 should apply to groundwater. The plan should be clear to aid in interpretation and implementation. Rule 14 Page 46 Support in part Ravensdown supports the intent of Rule 14, and the permitted activity status of the rule. Ravensdown notes Rule 14(a)(iii)(2) refers to identified significant indigenous biodiversity sites. Ravensdown understands these sites are to be identified and included in district plans. Ravensdown questions the appropriateness of including this matter as a Ravensdown seeks for Policy 46 to be deleted the information could be added as a Schedule. Ravensdown seeks for Policy 47 to be retained as written. Ravensdown seeks the intent of Rule 5 to be retained on the basis that fertiliser application to land where it may enter a surface waterbody is provided for elsewhere in the Plan. Ravensdown seeks clarification on how Rule 5 might apply to a non-point source discharges where a reasonable mixing zone cannot be easily applied to such discharges. Ravensdown seeks for Rule 7 to be amended to read: Rule 7 - Other d Discharges to groundwater Except as provided for elsewhere in the Plan, the discharge of any contaminant or water into groundwater is a discretionary activity. Ravensdown seeks for the intent and permitted activity status of Rule 14 be retained. Ravensdown also seeks the following amendments to Rule 14: i. Either delete the term identified significant indigenous biodiversity site from Clause (a)(iii)(2); or ii. Amend Clause (a)(iii)(2) to read (or similar:

10 resource user has to reference another planning document to determine if such a site is affected, and many sites will not include water. Ravensdown considers either the term is deleted, or is amended to refer only to significant biodiversity sites that include surface water. Ravensdown understands that the rule intends to discourage the use of fertilisers directly to water or in close proximity to water. However, it is suggested that a Discretionary activity status can be applied to achieve these aims. Ravensdown also considers non-compliance with any of the permitted activity conditions of Rule 14 should be provided for as a restricted discretionary activity, with Council restricting its discretion to the matters contained in the condition not met. Rule 15 Page 46 Support in part While Ravensdown supports the intent of and permitted activity status in Rule 15 (a), it considers the activity status for (b) is more appropriate as a Restricted Discretionary status with Council restricting its discretion to matters included in the condition not met, and the activity status of (c) should be discretionary. Land Use Rules Rule 20 Pages 49/50 Support in part While Ravensdown supports the overall intent of Rule 20, it has the following concerns/comments: or within 10 metres of a wetland boundary or any identified significant indigenous biodiversity site that includes surface water. iii. Add a new Rule 14A: The discharge of fertiliser in circumstances where fertiliser may enter water that does not meet the conditions of Rule 14 is a restricted discretionary activity. Council will restrict its discretion to the matters included in the permitted activity condition not met. Ravensdown seeks the intent and activity status in Rule 15(a) to be retained, and: seeks the activity status of Rule 15 (b) be amended to Restricted Discretionary Activity with Council restricting its discretion to the matters included in the conditions(s) not met; and the activity status of Rule 15 (c) be amended to discretionary activity status. While Ravensdown supports the overall intent of Rule 20, and seeks the permitted activity status for farming activities on a landholding <20ha to be retained, it seeks Rule 20 to be deleted and

11 Firstly, Ravensdown considers the current rule structure is confusing and needs to be separated into several rules to assist with user readability and Council s implementation. Secondly, Ravensdown supports permitted activity status for farming activities on a landholding <20ha. Thirdly, Ravensdown considers the rules should refer to a Farm Management Plan, and amend Appendix N accordingly. Fourthly, Ravensdown considers noncompliance with rules 20(e),(f),(g) & (h) should be a restricted discretionary activity with Council restricting its discretion to the requirement for a Farm Management Plan and the benefits of the activity, as opposed to a discretionary activity, as the matters of relevance relate to not preparing a FMP or IASM. This also this applies to farming activities other than dairy farming or winter grazing and so a less restrictive consent status is appropriate. replaced with the following new rule structure to read (or similar): New Rule 20A The use of land for a farming activity on a landholding that is less than 20 hectares is a permitted activity. Rule 20B The use of land for a farming activity, other than dairy farming of cows or intensive winter grazing, is a permitted activity; i) Until 30 May 2018 in the Oxidising, Riverine or Peat Wetlands Physiographic Zones ii) Until 30 May 2019 in the Central Plains, Bedrock/Hill Country or Gleyed Physiographic Zones iii) Until 30 May 2020 in the Old Mataura or Lignite-Marine Terraces Physiographic Zones Rule 20C From: a) 30 May 2018 in the Oxidising, Riverine or Peat Wetlands Physiographic Zones, or b) 30 May 2019 in the Central Plains, Bedrock/Hill Country or Gleyed Physiographic Zones, or: c) 30 May 2020 in the Old Mataura or Lignite-Marine Terraces Physiographic Zones: the use of land for a farming activity, other than dairy farming of cows or intensive winter grazing,

12 is a permitted activity, provided the following condition is met: (i) a Farm Management Plan is prepared and implemented in accordance with Appendix N, including mitigations relevant to the farming type being undertaken and relevant physiographic zone, and provided to the Southland Regional Council upon request, or the farming activity and the property on which the activity is undertaken is subject to an Independently Audited Self- Management scheme approved by the CEO of the Southland Regional Council. Rule 20D From: a) 30 May 2018 in the Oxidising, Riverine or Peat Wetlands Physiographic Zones, or b) 30 May 2019 in the Central Plains, Bedrock/Hill Country or Gleyed Physiographic Zones, or: c) 30 May 2020 in the Old Mataura or Lignite-Marine Terraces Physiographic Zones: The use of land for a farming activity, other than dairy farming of cows or intensive winter grazing, that does not comply with the condition of Rule 20C or Rule 20E is a restricted discretionary activity. The Southland Regional Council will restrict the exercise of its discretion to the following matters: 1. Content of the Farm Management Plan. 2. The potential benefits of the activity to the community and the environment.

13 Rule 21 Page 50 Oppose in part While Ravensdown supports the permitted activity status of Rule 21, it opposes limits being placed on inputs to farming systems, including to cow numbers. Controlling inputs removes the opportunity for innovative solutions and flexibility in land use. The RMA is an effects based statute and any controls should address the farm system losses which may give rise to adverse effects. Ravensdown considers that the rule should refer to a Farm Management Plan. Rule 20E Despite any other rule contained in this Plan, from 30 May 2018 the use of land for the farming of sheep, deer or beef on a landholding that is between 20 hectares and 100 hectares in area is a permitted activity, provided the following condition is met: (i) a Farm Management Plan is prepared and implemented in accordance with Appendix N, but excluding part 4 (Nutrient Budget), which includes mitigations relevant to the farming type being undertaken and relevant physiographic zone, and provided to the Southland Regional Council upon request, or the farming activity and the property on which the activity is undertaken is subject to an Independently Audited Self- Management scheme approved by the CEO of the Southland Regional Council. Ravensdown seeks the permitted activity status of Rule 21 be retained, while amending the rule to read: (a) the dairy platform has a discharge consent for agricultural effluent that specifies a maximum number of cows controls nutrient losses from the effluent management system in accordance with (b); and Delete (b); Amend (c) to (b) which reads: (c) (b) a Farm Management Plan is prepared and implemented in accordance with Appendix N, which includes ing the mitigations relevant to the farming type being undertaken and relevant physiographic zone, and

14 Rule 22 Page 50 Support in part Ravensdown has proposed a new Policy 16 above, and if Council accepts those amendments, amendments may be required to Rule 22 to be consistent with the new policy. Ravensdown seeks for the rule to refer to a Farm Management Plan. Ravensdown considers discretionary activity status is appropriate for new or expanded dairy farming. While Ravensdown supports the intent of Condition (g), there may be research farms that are able to meet the permitted activity standards and should not be required to gain a RDA consent. Furthermore, as these provided to Environment Southland upon request, or the farming activity and property the landholding on which the activity is undertaken is listed on the Environment Southland Register of subject to an Independently Audited Self-Management scheme approved by the CEO of the Southland Regional Council Participants; and a Farm Management Plan is prepared and implemented in accordance with Appendix N which includes mitigations relevant to the farming type being undertaken and relevant physiographic zone, or the farming activity and the property on which the activity is undertaken is subject to an Independently Audited Self- Management scheme approved by the CEO of the Southland Regional Council. Ravensdown seeks for Rule 22 to be reviewed and amended as appropriate to be consistent with the new Policy 16 requested above. Ravensdown supports the discretionary activity status for new or expanded dairy farming and seeks it to be retained. Ravensdown seeks Rule 22 to be amended to refer to a Farm Management Plan. Ravensdown seeks Condition (g) to be amended by clarifying that it does not apply to farms that meet the permitted activity standards of Rule 22, and changing the activity status to controlled activity.

15 Rule 23 Page 52 Support in part/oppose in part farms are providing a public benefit, Ravensdown considers a controlled activity status is more appropriate. While Ravensdown supports permitted activity for intensive winter grazing, it wishes to raise the following matters: Firstly, Ravensdown considers Clause (b) condition (ix) is inappropriate as any large rainfall event, or greater, is likely to cause this condition to be not complied with regardless if conditions (i) to (viii) are complied with. Ravensdown considers this condition can be deleted, as all mitigations possible to the landowner to ensure that winter grazing occurs as per industry agreed GMP will be addressed in the Farm Management Plan required under condition (b)(i). Ravensdown considers the current rule structure is confusing and should be separated into several rules to assist with user readability and Council implementation (as sought by Ravensdown with Rule 20 above). In relation to Rule 23(c) matter of discretion 3, Ravensdown cannot see the mechanism by which council will assess the quantum of any reductions of nitrogen, phosphorus, sediment and microbial contaminants required, or the timing of these reductions, or more specifically, if these reductions are even required to gain consent for the proposed activity. There seems to be a Ravensdown seeks the permitted activity status of Rule 23 to be retained. Ravensdown seeks the following amendments to Rule 23: Delete Part (b) condition (ix); Separate Rule 23 into several rules similar to the suggested restructure of Rule 20 above; Delete Part (c) matter of discretion 3.

16 presumption that reductions of contaminants will be needed. Ravensdown presumes that this will be assessed using an OVERSEER nutrient budget (NB)? The NB only estimates nitrogen losses, and, to a lesser extent, phosphorus losses at a farm level and at the block level. This will only be of relevance if the entire area for winter grazing is entered in an OVERSEER nutrient budget as one block but in reality the area used for winter grazing may only be a small portion of a land management unit. Furthermore, an OVERSEER nutrient budget does not estimate sediment and microbial contamination losses. Ravensdown seeks that this matter of discretion is deleted. Ravensdown also addresses issues with the definition of Winter Grazing below. Land Contamination Rule 46 Page 69 Support in part Ravensdown notes that Rule 46(a)(ii) requires that a discharge does not breech ANZEEC Freshwater quality standards. Glossary Ravensdown considers that if the reference to ANZEC 80 % and 90% values is directed to those elements and compounds listed in Table 3.4.1, Trigger values for toxicants at alternative levels of protection, page3.4-5 then that should be clearly stated. That said, the ANZEEC guidelines apply a trigger value for investigation. Ravensdown seeks for Rule 46 (a) (ii) to be amended as follows: (ii) the discharge does not result in a breach of the Trigger values for toxicants, presented in Table in the Australia and New Zealand Guidelines for Fresh and Marine Water Quality (ANZECC) 2000

17 Agricultural effluent Agricultural effluent storage Page 107 Support in part Ravensdown supports the intent of the definition, but considers the definition should apply to animal effluent to be consistent with other regional plans. Ravensdown notes the following examples from other regional plans all use the term Animal Effluent : Greater Wellington Regional Council definition (pnrp): Dry or wet, liquid, solid or semi-solid, treated or untreated faeces and urine from animals other than humans, including associated process water, washdown water, contaminants and sludge. ECAN Land and Water Regional Plan definition: Animal effluent means faeces and urine from animals other than humans, including associated process water, washdown water, contaminants and sludge excluding solid animal waste. Horizons one plan definition means faeces and urine from animals other than humans, including associated process water, washdown water, contaminants and sludge, excluding poultry farm litter* or pig farm litter*. Page 107 Support in part Ravensdown considers a consequential amendment is required to the definition due to the requested amendment to the definition of agricultural effluent above. Ravensdown seeks that the intent of the definition of agricultural effluent be retained, with the following amendment: Agricultural Animal effluent Effluent that is derived from livestock farming, but excludes excreta from individual animals, fertiliser application and non-point source discharges from normal farming practices. Ravensdown seeks that the definition of Agricultural effluent storage be amended as follows: Agricultural Animal effluent storage

18 Certified Nutrient Management Advisor Page 107 Request Ravensdown considers there is a need to introduce a new definition for Certified Nutrient Management Adviser. The Nutrient Management Adviser Certification Programme was developed with the aim of building and upholding a transparent set of industry standards for nutrient management advisers to meet, so that they provide nationally consistent advice of the highest standard to farmers. The qualifications for Certified Nutrient Management Advisers was introduced under the Transforming the Dairy Value Chain Primary Growth Partnership funded by DairyNZ and the Ministry for Primary Industries, with support of members of an Advisory Group established for the purpose. This Advisory Group which included regional councils, central government, primary industry groups, universities and Fish and Game endorsed and supported development of the programme. The certification programme is administered by a Management Board comprising members of New Zealand Institute Primary Industry Managers, Dairy Industry and Fertiliser Industry. There is a separate Standard Setting Group, comprising university staff, dairy industry members and fertiliser industry members. The formal A pond, tank or structure used for the containment, storage or treatment of agricultural animal effluent. Ravensdown seeks for Council to introduce a new definition as follows: Certified Nutrient Management Adviser: Means a Nutrient Management Advisor certified under the Nutrient Manager Adviser Certification Programme Ltd.

19 complaints process and on-going professional development are essential components of the programme. [ Given the significant implications of the farm specific OVERSEER Nutrient Budget in the proposed plan, it is disappointing to see that there is no clear requirement for any assurance on competency and currency in the use and application of OVERSEER Nutrient Budgets and nutrient management advice. Quality assurance in competency and currency is provided by the Certified Nutrient Management Adviser Programme, and is the reason it was developed. Critical Source Area Page 109 Support Ravensdown supports the definition as it is written. Fertiliser Page 110 Support in part While Ravensdown generally supports the definition of Fertiliser, it considers it is necessary to add the wording to be consistent with ACVM Regulations for the purpose of national consistency. Ravensdown seeks for the definition of Critical Source Area be retained. Ravensdown seeks the definition of fertiliser be amended as follows: Fertiliser Any substance (whether in solid or fluid form) that is described as or held out to be for, or suitable for sustaining or increasing the growth, productivity or quality of plants or animals through the application of the following essential nutrients to plants or soils: nitrogen, phosphorus, potassium, sulphur, magnesium, calcium, chloride, sodium as major nutrients; or manganese, iron, zinc, copper, boron, cobalt, molybdenum, iodine, selenium as minor nutrients or fertiliser additives., and includes non-nutrient attributes of the materials used in fertiliser; but

20 New Definition: Good Management Practice Page 110 Request Ravensdown considers the Plan should provide a definition of Good Management Practice. An industry accepted definition is recommended. does not include substances that are plant growth regulators that modify the physiological functions of plants. Ravensdown seeks that the following definition of Good Management Practice be included in the Plan: Good Management Practice Practices, procedures or use of tools which are effective at achieving the desired performance while providing for environmental responsibility. Good management practice evolves through time and results in continuous improvement as new information, technology and awareness of particular issues are developed and disseminate. Support is given to identifying these as: Industry Agreed Good Management Practices being the practices described in the document entitled Industry-agreed Good Management Practices relating to water quality - dated September Intensive Winter Grazing Page 110 Neutral Ravensdown has concerns with the definition of intensive winter grazing which it considers may lead to unintended environmental effects and consequences. Nutrient budget Page 114 Request Ravensdown considers it is necessary to include a definition of Nutrient Budget, and provides an industry accepted definition. Ravensdown seeks a review of the definition with intention of making it consistent current practice in Southland. Ravensdown seeks a definition of Nutrient Budget be added to the Plan as follows: A Nutrient Budget means: A statement of the total nutrient balance for a particular farm property or farming enterprise, taking into account all the nutrient inputs and all the outputs. For use in the Appendix N Farm

21 Physiographic zone Page 114 Support in part Ravensdown considers it is necessary that Physiographic zones be clearly defined to describe the zones. This provides clarity to the plan reader, and for Council implementation. Management Plan a nutrient budget must be prepared: (i) in accordance with the most recent version of the Overseer Best Practice Data Input Standards ; and (ii) by a person who is a Certified Nutrient Management Advisor. Ravensdown an amend to the definition of Physiographic zone to read: A physiographic zone represents areas of the landscape with common attributes that influence water quality, such as climate, topography, geology and soil type. Zones differ in the way sediment, microbes, and nutrients such as nitrogen and phosphorus accumulate and are transferred through the soil, aquifers and into waterbodies. The zones as are depicted on Map Series 4: Physiographic Zones and individually described in the Plan, Part A, pages Appendices Appendix E Page Support Ravensdown supports the list of water quality attributes which might be applied at the FMU level. However, the current combination of attributes under each of the designations for water bodies in Appendix E may or may not be appropriate for local community values at FMU level or subcatchment level. Appendix N Part A Part B 1-3 Page 198 Support While Ravensdown supports the intent and content included in Part A and Part b 1 3 of Appendix N, if considers for consistency with other regional plans that the Appendix should refer to Farm Management Plan. Ravensdown seeks an amendment of the water quality attributes addressed in Appendix E to be applied at the Freshwater Management Unit or sub-catchment level. Ravensdown seeks for an amendment to Part A and B of Appendix N to refer to Farm Management Plans.

22 Appendix N Part B4 Nutrient Budget Appendix N Part B 5 Good Management Practices Page 199 Support in part While Ravensdown supports the intend of Part B 4. of Appendix N, it considers there is a need to further clarify nutrient budget requirements. Ravensdown considers that the annual review of the input data is not required, as any material changes in land use will be addressed by the condition (i). Page 199 Support in part While Ravensdown supports Part B 5. of Appendix N, it seeks the following to be addressed: Firstly, Ravensdown considers that clause (vi) is covered under clause (i) and can therefore be deleted. Ravensdown seeks that Appendix N Part B4 is amended as follows: (a) A nutrient budget based on including soil nutrient tests has information shall be prepared once every 3 years been prepared, by a Certified Nutrient Management Advisor, using the latest version of the OVERSEER model, in accordance with the latest version of the OVERSEER Best Practice Data Input Standards, or an equivalent model approved by the Chief Executive of Southland Regional Council; except that: (i) where a material change in the land use associated with the farming activity occurs (being a change exceeding that resulting from normal crop rotations or variations in climatic or market conditions) the nutrient budget shall be prepared at the end of the year in which the change occurs, and also three years after the change occurs. (ii) where a material change in the land use associated with the farming activity does not occur, the nutrient budget shall be prepared once every three years; (iii) (b) an annual review of the input data used to prepare the nutrient budget shall be carried out by or on behalf of the landowner for the purposes of ensuring the nutrient budget accurately reflects the farming system. A record of the review shall be kept by the landowner. Ravensdown seeks for the intent of Part B 5 to be retained, with the following amendments: Delete Clauses (ii) and (iv); Incorporate Part B6 to 10 (Riparian Management, Cultivation, Intensive Winter Grazing, Collected Agricultural Effluent and irrigation Management)

23 Secondly, Ravensdown considers Clause (ii) is already a condition of Part B 3. (a map that shows the physiographic unit(s) in which the land is located) and can therefore be deleted. Thirdly, Ravensdown considers documentation of Good Management Practices for Riparian Management, Cultivation, Intensive Winter Grazing, Collected Agricultural Effluent and irrigation Management are currently required under Part B 6, 7, 8, 9 and 10 respectively. Ravensdown considers that these would logically be listed under Part B 5 Good Management Practices. Fourthly, Ravensdown notes the requirements of conditions (iv) and (v) indicate that the on-farm good management practices undertaken in the previous 12 month period will need to be submitted to council on an annual basis but neither Appendix N nor the rules section list the frequency that a Farm Management Plan is required to be updated and submitted to council. Fifthly, Ravensdown supports recognition in the Glossary, that Good Management Practice means Industry Agreed Good Management Practices, Sept 2015, developed by the primary industry sector groups in conjunction with Canterbury Regional Council. into the Good Management Practices section; Require for consistency an indication that the on-farm good management practices undertaken in the previous 12 month period will need to be submitted to council on an annual basis; Include recognition in the Glossary, that Good Management Practice means Industry Agreed Good Management Practices, Sept 2015, developed by the primary industry sector groups in conjunction with Canterbury Regional Council.

24 Appendix N Part B 6 Riparian Management Plan Appendix N Part B 7 Cultivation Appendix N Part B 8 Intensive Winter Grazing Appendix N Part B 9 Collected Agricultural Effluent Page 200 Support While Ravensdown supports Part B 6 of Appendix N, it considers it should be amended to incorporate Part B 5 Good Management Practices. Page 201 Support While Ravensdown supports Part B 7 of Appendix N, it considers it should be amended to incorporate Part B 5 Good Management Practices. Page 201 Support While Ravensdown supports Part B 8 of Appendix N, it considers it should be amended to incorporate Part B 5 Good Management Practices. Page 201 Support in part While Ravensdown supports Part B 9 of Appendix N, it considers a consequential amendment is required due to the request to amend the definition of agricultural effluent above Ravensdown seeks for Part B 6 of Appendix N to be retained, while amending it to incorporate Part B 5 Good Management Practices. Ravensdown seeks for Part B 7 of Appendix N to be retained, while amending it to incorporate Part B 5 Good Management Practices. Ravensdown seeks for Part B 8 of Appendix N to be retained, while amending it to incorporate Part B 5 Good Management Practices. Ravensdown seeks for Part B 9 of Appendix N to be retained, while amending to read Collected Agricultural Animal Effluent and amending it to incorporate into Part B5 Good Management Practices.