Collective and Federated Farmers Submissions on the Proposed Rules

Firstly a big thank you to all our members for contributing to our job in compiling the Collective submission on Plan Change 10.  Here is a summary of the key issues and themes addressed in our submission.

Key issues/themes:

• The level of bureaucracy, complexity and ongoing cost around resource consents, farm plans and Overseer data
• The lack of recognition of farm industry good practice guidance and current farm plan templates
• The reasonableness (or otherwise!) of individual farm nitrogen targets
• The confusion between compliance against farm plans versus Overseer numbers versus both
• The failure of policy makers to consider alternative combinations of nitrogen and phosphorus lake targets in combination with alum dosing, especially given:

–    the unexpected success of alum in making the lake P limited
–    the lake meeting its TLI 4.2 water quality target since 2012
–    very long time lags before N regulations can make a difference in the lake
–    uncertainty around farm Overseer modelling as it has been updated, with its estimates of farm N losses nearly doubling for the same inputs
–    uncertainty around the catchment ROTAN model which has not been rerun since 2011, despite the massive changes in Overseer.

The changes we’d like to see in PC10 include:

• Adoption of best science, ongoing 5 years reviews starting in 2017
• Farm targets to be practical and affordable
• Change to the RPS to shift the focus from 435 tonnes  of N to the TLI target of 4.2
• Rolling  5 year averages  of Overseer for compliance
• Farm plans to site outside the Rules framework
• Thorough investigation of all lake mitigation solutions including risks, social, cultural and economic impacts