DairyNZ’s position on Essential Freshwater
Farm Environment Plans
We support mandatory Farm Environmental Plans (FEP) as the best way to manage environmental risks on farm and to further improve water quality outcomes quickly for all contaminants. For this reason, the dairy sector has already committed to all farmers having
farm plans through our Dairy Tomorrow strategy. However, we do have some concerns around how the proposed FEP will be implemented.
Standards for intensive winter grazing
In principle we support national standards for intensive winter grazing. The majority of practices listed are already considered to be Good Management Practice by the primary sector, for example as documented in
DairyNZ’s Wintering on Crop and Pasture. However we do have concerns about the proposed definitions that they want to use, for example how “pugging” is defined.
Stock exclusion
We support stock exclusion as one of the most effective measures for reducing contaminants entering permanent waterways. Through the Sustainable Dairying: Water Accord our dairy farmers are already a long way on this journey.
We support current fencing to remain in place, if minimum buffer widths are achieved. Our scientists are reviewing the need for a 5m buffer to see if there is scientific evidence to support that position. We support the proposed average width approach. This
gives farmers the opportunity to target at-risk areas, such as critical source areas.
New bottom line for instream nitrogen and phosphorus
While we support policies that will protect ecosystem health alongside swimmability, we do not support the proposed nitrogen and phosphorus bottom lines as the most effective way to achieve this.DairyNZ’s position is that these new nutrient thresholds are not
scientifically robust and are unlikely to be the most effective way to achieve improvements in waterway health sought by the community.
Intensification in some catchments
We broadly support no further intensification in over-allocated catchments until the limit setting process is implemented. Any increases in nutrient loading in these areas risks requiring all farmers to make greater reductions to their footprint in future.
Intensification is already prohibited for many regions through existing regional planning processes. We are questioning how the proposal would quantify sediment and bacteria discharges. We also support a measured approach in catchments that are not over-allocated.
Reduce nitrogen loss
We have some concern that just focusing on nitrogen won’t deliver the ecosystem health outcomes sought and therefore prefer an ecosystem outcomes approach to ‘at-risk’ catchments. At the same time, we recognise the need to manage high nitrogen losses across
many catchments. We are still working on the best possible solution to address this challenge. We do believe in an outcome approach, not an input one.
Economic and social impacts
Our view is that the Government’s analysis of the economic and social impact of the proposed policies on farmers, regional economies and communities is incomplete. We are undertaking a more robust analysis to support our submission and will share this as soon
as we can, as it will support farmers to make submissions before the end of the consultation.
For more detail on DairyNZ’s positions and the Essential Freshwater proposal
visit our website. We will update this as we complete our technical reviews.
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