Submission

 Submission on the Freshwater Farm Plan Regulations

The Government has consulted on regulations to give effect to freshwater farm plans, which form part of the recent changes to the Resource Management Act 1991.  In essence, the proposed regulations will establish what is required in a freshwater farm plan, and how they will be implemented and administered.

Our key concern is that there is insufficient detail in the discussion document to really understand what is being proposed and, where it does seem to be clear, it appears these plans will be overly burdensome on farmers.  Freshwater farm plans need to be a workable alternative to the ordinary consenting regime, simply implement good management principles, and not result in a double layer of regulation.  Further, the Government must provide a way for existing farm plans to meet the requirements of freshwater farm plans without binding (and therefore penalizing) farmers who have aspirational farm goals. There also appears to be too much power given to certifiers and auditors will little recourse if they get it wrong, and issues with how freshwater farm plans will be rolled out.

Ultimately, Federated Farmers has told the Government that freshwater farm plans should:

• be owned and directed by the farmer;
• utilise existing farm plan regimes to the greatest extent possible;
• recognise that each farm is unique, provide farmers the flexibility to adapt and to choose how to achieve the required environmental outcomes (from risk assessment to consideration of mitigations);
• not be unduly burdensome (time, resource, cost to complete);
• not require farmers to disclose confidential data/information about their farming operation;
• provide for staged implementation managed by risk and to take into account limitations with resources (for example lack of certifiers).