3rnrn17 M Gmail - Waikato...M Gmail Bruce & rlVonne G PCl submission 2 messages Bruce & ltonne C Wed, Mar 8,2017 at 3:28 PM

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M Gmail Bruce & rlVonne G <[email protected]>

PCl submission2 messages

Bruce & ltonne C <[email protected]> Wed, Mar 8,2017 at 3:28 PMTo: healthyrircrs@raikatoregion. govt. nz

Dear sirPlease find attached my submission-I also wish to add under Policy 3 that l-lorticulture should be exempted frrom nutdent discharges as proposedin this policy and followAuckland pdicy of exempting Horticulture proUded ttrey ffilow excepted goodmanagement practices.This is in recondition of their importance to the growing population in the region"RegardsBruce Cameron

Sent fiom my iPad

g1 BBC Submisdon to PCI 2017.docx- 6oK

llealthy Rive rs <[email protected]. nz>To: Bruce & Yronne C <[email protected]>

Hithere,

Wed, Mar 8,2017 at 4:53 PM

Thank you for your submission, it has been receired. We will be in touch in the next week or so should werequire any further information from you.

Kind regards,Danica

Danica de Lisle I Submissions C.oordinator lScience and StrategyWaikato Regional CouncilDDI: 07 859 0835Primte Bag 3038, Waikato MailCentre, Hamilton 3240Please consider the enrironment before printing this email

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Submission: Waikato Regional Gouncil's Proposed HealthyRivers/Wai Ora Plan Change I (PPCI)

Submission on a publicly notified proposed Regional Plan prepared underthe ResourceManagementAct 1991.

Submitting On: The Waikato Regional Council's Proposed Healthy RiversMai OraPlan Change 1 (PCl)

SubmittingTo: WaikatoRegionalCouncil401 Grey StreetHamilton EastPrivate bag 3038Waikato MailCentreHAMILTON 3240

Submission

1. I have reviewed Waikato Regional Council's Proposed Healthy RiversM/ai Ora PlanChange 1 (PPC1) and gppg the Plan Change in its cunent form.

2. I wish to be heard in support of this submission.

I am not a trade competitor for the purposes of the submission but the proposed plan has adirect impact on my ability to farm. lf changes sought in the plan are adopted they mayimpact on others but I am not in direct trade competition with them.

Waikato Regional Council's Proposed Healthy RiversMaiOra Plan Change 1 1

28 March 2017

Full Name: Bruce BellCameron

Phone (home): 09 233 3045

Phone (mobile/work): 0274 531 382

PostalAddress: RD5Tuakau2695

EmailAddress: [email protected]

B B Cqmeron 1-3-I7

Signoture dole

3. Thank you for the opportunity to submit on the Waikato RegionalCouncil's Proposed Plan Change 1 (PPC1).

Waikato Regional Council's Proposed Healthy RiversM/ai Ora Plan Change 1

28 March 2O17

I own, along with my wife, Glenullen Holdings Ltd which runs a drystock property of 334hacarrying around 400 bulls, rearing most from calves and taking them through tolSmnths/2years of age before sending them to the works.

We also run sheep; 1000 breeding ewes with all progeny sold prime to the works.

The property is in the Whangape Sub Catchment number 16 and is listed as a priority one.

I have farmed this property for43 years along with my wife.

When I first took over running this property, I started a large scheme of planting poplar andwillow poles to stabilise hillsides and streams-

A substantial amount of funcing has been canied out on this property with approximately20ha of bush and wetlands fenced off from stock and retired.

I have also fenced ofi approximately 3 kms of watennays-

\A/hen I first took over this property, if a beast or sheep got into a stream, it would tummuddy. I had a couple of places along the streams where I would be able to check (by it'sclarity) if any animals had got in.

Now that virtually allthe watenuays are fenced off with no stock getting into them, I haveregular muddy waterways from having koi carp moving in and stining up the stream bottom.

As a note, koi carp have not been addressed in PC1. Koi carp are endemic in thiscatchment, especially in Lake Whangape. Koi carp will move 14 times their weight in silt perday, which, extrapolated out, equates to 1 tonne of koi carp moving 14 tonnes of silt per day.

Over the 43 years of farming this property, I have developed a stock policy with a mix ofsheep and cattle that suits the climate and the land type.

Cattle are kept off the wet hills in the winter, with sheep being grazed in these areas. Wemake extensive use of electric fencing.

The age of the cattle canied has been reduced to lessen their impac{ over winter.ln the future, I intend to finish my stream fencing, and fence more areas so I can carry morecattle on the property without having any further impact of significance on the land.

I am concerned the way PC1 is proposed, as it does not allow for increases in productionwithout having to go through significant resource consent costs.

I could carry on doing conservation planting and fencing, but I would be hesitant to do so, asPCI provides me with no certainty that the investment would be worth it, as, in 10 years'time, when the plan is revisited, I may be told that not enough has been achieved in thereduction of the four contaminants into the Waikato River and the land has now got to beplanted into trees.

I NEED CERTAINTY THAT MY INVESTMENT IN MITIGATION OF CONTAMINANTS ISNOT WASTED.

Waikato Regional Council's Proposed Healthy RiversMaiOra Plan Change 1

28 March 2017

ln the section 32 analysis page A4 C.2.2.2 HistoricalChanges in land use and nitrogenleaching losses

I note that it states: "estimated nitrogen losses from nondairy pastonl land useincreased by 4o/o over the peiod 1972 to 2012"

So, over a 40 year period a 4016 increase is very minor, yet PCI as proposed is using adraconian sledge hammer over this sector of farming at huge cost with questionable gain tothe environment.

ln Summary:

PC1 effectively caps production out of the Waikato and Waipa catchments, and with therestrictions placed on it, would make it hard and costly to increase production.

With Auckland being on the very front door of the Waikato and having an expectedpopulation increase of one million people by 2O35laO, extra food producdion is going to berequired especially in the horticultural sector. With no further increase in horticultural landpermitted for 10 years, are we now going to be expected to Airfreight fresh vegetables infrom overseas in the future?

With the mitigation costs involved in meeting PCl, expectations as ground truthed by theFederated farmers study I can see a large number of farms being made uneconomic.

Banks would most likely not lend to farms to carry out mitigation work which would make thefarm uneconomic and this then defeats any attempt to improve river quality.

For young people wanting to come on to the land and increase a farm's potential, it wouldnot now be viable.

Young people need to be able to see how they can improve production/profit, whilst stilllooking after the environment and under PC1 there can be no lift in the "N" reference point.For this reason, our son will not be taking over our property, and has left the farming industryas he does not see a future in it for him under PC1.

Waikato Regional Council's Proposed Healthy RiversMaiOra PIan Change 1

28March2017

4. The table below are the details for the specific provisions of the proposal that this submission relates to and thedecisions it seeks from Council. The outcomes sought and the wording used is as a $uggestion only, where asuggestion is proposed it is with the intention of 'or words to that effect'. The outcomes sought may requireconsequential changes to the plan, including Objectives, Policies, or other rules, or restructuring of the Plan, or partsthereof, to give effect to the relief sought,

No. Scctlon nunb.roftfic Propolcd FhnCftenor I

$uBBortlOpFe

Suhnlsllon Decldon sought

3.11.2 Obiectives4.1 Objective I

Longterm restorationand protection ofwater quality for eachsub-catchment andFreshwaterManagement Unit

Support withamendments

Support the intention of Objective 1.

Oppose the attribute targets set in Table 3,1 1-1. The attribute targets are too prescriptive andshould align with the National Policy Statementfor Freshwater Management (NPS-FM) andWaikato River Authority's (WRA) Vision andStrategy.Objective 1:r Does not consider all contaminant

sources holisticallyo lncludes flood/high flow conditions in

water quality target data which areconsidered outliers

o Does not take into consideration thevariability associated with sub-catchmentsi.e. climate and soiltvoe

Retain the long-term restoration and protection ofwater quality for the Waikato and Waipa rivers.

Amend PC1 to be holistic and include all sourcesinfluencing the health and wellbeing of theWaikato River and its catchments, for exampleKoi Carp, point source discharges, and hydro-dams.

Remove flood/high flow conditions from waterquality target data.

Address contaminants on a sub-catchment basis,to enable targeting of the highest omitting sub-catchments.

4.2 Obiective 2Social, economic andculturalwellbeing ismaintained in the longterm


Support maintaining the long term social,economic and culturalwellbeing; this must bea foundation objective in PC1.

However, PC1 is not achieving Objective 2because:o The section 32 analysis is incomplete due

to the withdrawal of the Hauraki iwi area.

Retain the maintenance of longterm social,economic and cultural wellbeing in the Waikatoand Waipa catchment communities.

Withdraw PC1 untilthe Hauraki lwi area and theWRA's Vision and Strategy has been amended.Then conduct a section 32 analysis to investigatethe revised impact PC1 could have on society and

28 March 2017Waikato RegionalCouncil's Proposed Healthy RiversMaiOra Plan Change 1

lnadequate social modelling conductedCompliance costs alone are likely to costmy business a considerable amount ofmoney as estimated by the FederatedFarmers (2016) case study.Outcomes from PC1 will highly alter mybusiness Glenullen Holdings Ltd andcommunity of Glen Murray because theywill be undermined through unsustainableand unjustified compliance and mitigationcosts, farm devaluation and NitrogenReference Point (NRP).Waikato Regional Council (WRC) hasstated they currently have no knownmeans of robustly measuring social,economic or cultural wellbeino.

economy.

Amend rules in PC1 to remove NRP to align withintention of Objective 2.

Enable appropriate mitigation strategies to beadopted in the context of water quality gains to bemade, through a tailored Farm Environment Plan(FEP) to align with intention of Objective 2.

Address contaminants on a sub-catchment basis,to enable targeting of the highest omitting sub-catchments to align with intention of Objective 2.

Develop robust indicators to measure social,economic and cultural wellbeing.

4.3 Obiective 3Short-termimprovements inwater quality in thefirst stage ofrestoration andprotection of waterquality for each sub-catchment andFreshwaterManagement Unit


Support reducing the ditfuse discharges in theshortterm by 1Aa/o, of the overall long-term 80-year water quality targets.

However, there is a lack of scientific data tosupport PC1 to achieve Objective 3, Forexample, PC1 incentives high emitters - tomaintain flexibility on my farm, and thereforemy land value, I will need to keep my NRP ashigh as possible.To me, this is the opposite effect of what PC1should achieve to improve the health andwellbeinq of the Waikato and Waipa rivers.

Retain a 10o/o achievement of the longterm waterquality targets set out in PC1 by 2026.

Amend rules in PC1 to remove NRP.

Adopt a sub-catchment management approach toensure collaborative and fair management ofresources within each sub-catchment.

Enable appropriate mitigation strategies to beadopted in the context of water quality gains to bemade, through a tailored FEP.

4.4 Objective 4People andcommunity resilience


Support people and community resilience - itmust be a cornerstone objective in PC1.

However, currently PC1 does not meet therequirements of Objective 4. The proposedrules undermine communitv resilience in the

Retain the staged approach.

Amend rules in PC1 to remove NRP and land usechange restriction.

Adopt a sub-catchment manaoement approach to

28March2017Waikato RegionalCouncil's Proposed Healthy RiversAtVaiOra Plan Change 1

rural communities of the Waikato and Waipacatchments and will adversely impact on socialand economic wellbeing in both the short termand long term. The NRP, associated farmdevaluation and loss of flexibility, coupled withsubstantial compliance and mitigation costs onmany farms is unsustainable, as evidenced bycase studies.Water quality already meets attribute targets inthe majority of these sub-catchments, Despitethis, no benefit is awarded to low emitters whomay be forced off their land throughunsustainable financial impacts imposed byPC1. This will in turn undermine the ruralcommunities of the Waikato and Waipacatchments, as detailed in Objeclive 2.

ensure collaborative and fair management ofresources within each sub-catchment.


4.5 Objective 5Mana Tangata -protecting andrestoring tangatawhenua values


Support protecting and restoring Tangatawhenua values. Mana Tangata is important toNew Zealand's culture, but it also needs thesupport of industries, markets, andcommunities (primary production). TheWaikato region is an integrated communitytherefore co-management is the key, not runall orimarv sectors into the oround.

Revise PC1 to acknowledge primary productionas a core value to reflect Mana Tangata.

4.6 Objective 6WhangamarinoWetland

Support The Whangamarino Wetland should berestored.

Retain as proposed

3.11.3 Policv4.7 Policy I

Manage diffusedischarges ofnitrogen, phosphorus,sediment andmicrobial pathogens


Support managing water quality on a sub-catchment basis because it considers soilsuitability and climate conditions.

Support stock exclusion, however only where itis practicalto do so, and is relative to wateroualitv benefit oains.

Retain managing diffuse discharges and waterquality on a sub-catchment basis.

Enable appropriate mitigation strategies to beadopted in the context of water quality gains to bemade, through a tailored FEP.Amend rules in PC1 to reflect Policv 1 and 9.

728March2A17

Waikato RegionalCouncil's Proposed Healthy RiversMaiOra Plan Change I

Support enabling low intensity land uses.

Support moderate to high levels ofcontaminant discharges to reduce theirdischarges by appropriate mitigation strategiesthrough a tailored FEP,

However, the rules in PC1 do not reflect Policy1 and 9,

Oppose mandatory fencing in areas whereslopes are over 15'. This requirement isunjustified, does not align with proposedamendments to the NPS-FM, and is financiallyunsustainable for the majority. lt is consideredthat the increased erosion risk and sedimentloading in waterbodies from constructingfences over 15".

Amend Policy 1 in PC1 to state (changes arered):c. Progressively excluding cattle, horses, deerand pigs from rivers, streams, drains, wetlandsand lakes for areas with a slope less than 15degrees and on those slopes exceeding 15degrees where break feeding occurs.d. Requiring farming activities on slopesexceeding 15 degrees (where break feeding doesnot occur) to manage contaminant discharges towater bodies through mitigation actions thatspecifically target critical source areas.

Require clarification on how slope is measuredgiven the ranges of topography experiencedwithin each paddock and adjoining watercourses,

4.8 Policy 2Tailored approach toreducing diffusedischarges fromfarming activities


Support a tailored, risk based FEP, allowingappropriate and tailored mitigations to reducediffuse discharges.

Support the reduction of diffuse dischargesthroughout all sub-catchments, however onlywhere applicable i.e. if the sub-catchment iswell below all attribute targets thenmaintenance would be appropriate.

Oppose a NRP because there should not bean uncertain, estimated number that governsland management based upon nitrogen only.My FEP will provide transparency andconfidence to Waikato Regional Council, andthe wider communitv, that mv propertv is

Retain appropriate mitigation strategies to beadopted in the context of water quality gains to bemade, through a tailored FEP.

Amend PC1 to reflect Policy 1 in adopting a suFcatchment management approach to ensurecollaborative and fair management of resourceswithin each sub-catchment.


28 March 2017Waikato Regional Council's Proposed Healthy RiversMaiOra Plan Change 1

reducing, or maintaining where applicable, itsdiffuse discharges relative to allfourcontaminants.

4.9 Policy 4Enabling activitieswith lower dischargesto continue or to beestablished whilesignalling furtherchange may berequired in future


Support enabling low intensity land uses.

However, I consider the uncertaintysurrounding'future mitigation actions' to beunacceptable. The level of capital expenditurerequired to meet the lGyear plan withoutassurance of future compliance for hill countryfarmers is prohibitive and counterproductive. lfbest practice is being adopted, then futurecertainty should be provided.

Retain provisions allowing for low intensity landuses to continue and establish.

Remove any signalling of future mitigation actionrequirements from Policy 4 in PC1

4.{0 Policy 5Stage approach


Support an 80-year staged approach toachieve the long-term water quality targets.

However, Policy 5 does not support Objective2, 4 and 5. Because it does not:

o Minimisesocialdisruptiono Allow for innovation and new practices

to develop. Support prosperous communities

There is little scientific evidence that PC1 willreduce diffuse discharges to achieve the long-term water qualitv taroets.

Retain the staged approach.


Adopt a sub-catchment management approach toensure collaborative and fair management ofresources within each sub-catchment.


4.11 Policy 6Restricting land usechange

Oppose Oppose restricting land use change based onthe type of land use, as it is a blunt tool.This Policy, and related rule (3.11.5.7), willinhibit growth and innovation within theWaikato region, and nationally because I amunable to adapt to market demands/changes.Land use flexibilitv is key to runnino

Amend PC1 to state high priority sub-catchments,in relation to water quality, have a RestrictedDiscretionary activity status. And low priority sub-catchments to have a Permitted activity status.

Amend PC1 to adopt a sub-catchmentmanaoement aooroach to ensure collaborative

I28March2017

Waikato RegionalCouncil's Proposed Healthy RiversMaiOra Plan Change 1

sustainable business operations. Therefore,Policy 6 conflicts with Objective 2, 4,5 andPolicy 5.Where a sub-catchment is of high priority (interms of water quality), land use changeshould be a restricted discretionary activitystatus, However, where a sub-catchment is oflow priority, land use change should be apermitted activity.

and fair management of resources within eachsub-catchment. Then enable appropriatemitigation strategies to be adopted in the contextof water quality gains to be made, through atailored FEP

1.12 Policy 7Preparing forallocation in the future


Support as it takes into account land suitabilityregarding diffuse discharge reductions.

However, PC1 is severely restricting growthand innovation on my farm and in mycommunity in order to give more time to gainscientific data to appropriately implement thisPolicy in the future.

WRC needs to work collaboratively withstakeholder groups to develop sub-catchmentmanagement approach, and enableappropriate mitigation strategies through atailored FEP.

Retain reducing diffuse discharges whileconsidering land suitability.


WRC to work collaboratively with stakeholdergroups to develop sub-catchment managementapproach.

4.{3 Policy 8Prioritisedimolementation


Support prioritising sub-catchments andimplementing at different stages.

Retain as proposed with altered prioritycatchments as proposed in PC1

4.14 Policy 9Sub-catchment(including edge offield) mitigationplanning, co-ordination and funding


Support managing water quality at a sub-catchment level.

However, the rules in PC1 should give effect tothis Policy and enable appropriate mitigationstrategies through a tailored FEP.

Retain managing water quality on a sub-catchment level.

Amend the rules in PC1 to reflect Policy 1 and 9.

Enable appropriate mitigation strategies to beadopted in the context of water quality gains to bemade, throush a tailored FEP.

28 March 2017Waikato Regional Council's Proposed Healthy RiversArVaiOra Plan Change 1 10

4.15 Policy 10Provide for pointsource discharges ofregional significance


Support considering the regional significanceof infrastructure and industry because thereare certain point source discharges that arevitalto human health and wellbeing.

However, point source discharges should betaken into consideration for achieving the shortand long term water quality targets, through asub-catchment approach.

Retain the consideration of regional significanceof point source discharges infrastructure andindustry.

Amend PC1 to be holistic and include all sourcesinfluencing the health and wellbeing of theWaikato River and its catchments, including pestfish species, point sources, and hydro-dams.

Adopt a sub-catchment management approach toensure collaborative and fair management ofresources within each sub'catchment.

4.{6 Policy l{Application of BestPracticable Optionsand mitigation oroffset of effects topoint sourcedischarges


Support applying Best Practicable Options.

However, this is not applicable to allstakeholders, and there are no specific rules toreflect this Policy in PC1,

Retain applying Best Practicable Options butamend to include all stakeholders e.g. throughFEP.

Provide clarification for what is a "significant toxicadverse effect".

Amend rules to reflect Policy 1'1.

4.17 Policy 12Additionalconsiderations forpoint sourcedischarges in relationto water qualitytargets.


Support considering past technology upgradesand costs associated with upgrading.

However, this consideration is not consistentwith land owners.Point source discharges can stage futuremitigations to spread innovation costs overtime to allow for a return in investment. This isnot the case for me as a land owner.There is also no regard to cumulative effectsfrom point source discharges.

Retain considering past technology upgrades andcosts associated with upgrading.

Adopt a sub-catchment management approach toensure collaborative and fair management ofresources within the region.

Amend PC1 to allow these considerations tooccur across all sources influencing the healthand wellbeing of the Waikato and Waipa rivers.This could be achieved by enabling appropriatemitigation strategies to be adopted in the contextof water quality gains to be made, through atailored FEP.

28March2017Waikato Regional Council's Proposed Healthy RiversMaiOra Plan Change 1 11

4.{8 Policy {3Point sources consentduration


Support considering the magnitude andsignificance of the investment made.

However, land owners should be provided thesame consideration when applying for consentunder rule 3.1 1.5.4,3.1 1.5.5, 3.1 1.5.6 and3.11.5.7 in PC1.

Retain consideration of the consent duration inrelation to the magnitude and significance of theinvestment made.

Adopt to include all property owners andenterprises within the Waikato and WaipaCatchments.

4.{9 Policy 14Lakes FreshwaterManagement Units

Support Support restoring and protecting lakes in 80years through tailored plans.

Retain as proposed.

1.20 Policy {5WhangamarinoWetland


Support restoring the Whangamarino Wetland.

However, I believe that all sources influencingthe water quality of the wetland should beconsidered and remediated in collaboration,not just one source.

Retain restoring the Whangamarino Wetland.

Amend Policy 15 to be holistic and include allsources influencing the health and wellbeing ofthe Waikato River and its catchments especiallypest fish species, in relation to sub-catchmentmanaoement.

4.21 Policy {6Flexibility fordevelopment of landreturned under TeTiriti o Waitangisettlements andmultiple owned Mioriland


Support flexibility for development of M5oriland. However, there is no rule in PC1 toreflect this Policy (16).

Additionally, under PC1 all property ownersand enterprises have restricted flexibility. Thisin turn reduces the social, economic andcultural benefits for everybody because thesurrounding rural communities arecompromised.

Retain flexibility for development of M6ori land.

Amend PC1 to include a rule to reflect Policy 16.

Consider a similar flexibility for all propertyowners and enterprises.

1.22 Policy {7Considering the widercontext of the Visionand Strategy


Support applying policies and methods basedon the Vision and Strategy"

However, the WRA's Vision and Strategy iscurrently under review, therefore PCI may endup inadequately reflecling the Vision andStrateov.

Retain applying policies and methods based onthe Vision and Strategy.

Withdraw PC1 untilthe Hauraki lwi area and theWM's Vision and Strategy has been amended.

3.1 1.4 lm plementation Methods

28 March 2017Waikato Regional Council's Proposed Healthy RiversAA/aiOra Plan Change 1 12

4.23 3.11.4.1Working with others


Support working with stakeholders to ensurePC1 is implemented efficiently and costeffectivelv

Retain with reference to efficiency and costs.

4.24 3.11.4.2Certified lndustryScheme

Support Support that I can opt into a Certified lndustryScheme to help me manage my operation tothe highest environmental standard, whileconsidering my social, cultural, and economicimpacts.

Retain as proposed.

1.2 3.{1.4.3Farm EnvironmentPlans


Support a tailored, risk based FEP for mybusiness to improve, or maintain whereapplicable, my environmental standard in adesired time-frame negotiated between myFarm Environmental Planner and myself.

However, I understand there could be ashortage of Certified Farm EnvironmentPlanners. As an alternative, I suggest that landusers who have adequate experience andcapabilities should be able to work with anapproved industry or scheme, run by WRC, tobe accredited to develop their own FEP basedupon a common template.

Support robust third party auditing and thismust be independent of \A/RC also.

Retain a tailored, risk based FEP,

Enable land users who have adequate experienceand capabilities should be able to work with anapproved industry or scheme, run by WRC, to beaccredited to develop their own FEP based upona common template.

The auditing process to be independent of thefarmer, the certified Farm Environment Plannerand WRC

4.26 3.11.4.4Lakes andWhangamarinoWetland


Support WRC working with others to gainknowledge and information around lakes andthe Whangamarino wetland.

Support 3.11.4.4 (d) "work towards managingthe presence of pest weeds and fish in theshallow lakes and connected lowland riversarea, including Whangamarino Wetland'.

However, there are no policies, obiectives or

Retain working with others in relation to lakes andWhangamarino Wetland.

Retain managing pest weeds and fish.

Amend PC1 to include the management of pestweeds and fish in the policies, objectives andrules in the Waikato and Waipa Catchments.


rules in PC1 that recognise this point. lt shouldalso be extended to the Waikato and Waiparivers and their catchments, not just shallowlakes and connected lowland river areas,

4.27 3.11.4.5Sub-catchment scaleplanning


Fully support managing diffuse discharges andwater quality on a sub-catchment level.

However, this method is not reflected in therules of PC1.

Retain managing diffuse discharges and waterquality on a sub-catchment level.

Amend PC1 to reflect this method in the rules.

4.28 3.{1.4.6Funding andimplementation

Support Support WRC providing resources andleadership to implement PC1.

Support securing funding for implementation ofPC1.

Retain as proposed.

4,29 3.11.4.7t8lnformation needs tosupport any futureallocation/ReviewingChapter 3.11 anddeveloping anallocation frameworkfor the next RegionalPlan


Support gaining data.

Support allocation on a sub-catchment basis.

Oppose future allocation.

Retain gaining data.

Amend PC1 to enable the management of diffusedischarges on a sub-catchment basis.

4.30 3.1,l.4.9Managing the effectsof urban development

Support Support managing the effects of urbandevelopment,

Retain as proposed

4.31 3.11.4.12Support research anddissemination of bestpractice guidelines toreduce diffusedischaroes

Support Support implementing best practice guidelineto reduce diffuse discharges.

Retain as proposed,

3.{1.5 Rules4.32 3.r1.5.1

Permitted ActivitvSupport Support enabling low intensity land uses to

continue and establish under a PermittedRetain enabling low intensity land uses tocontinue and establish under a Permitted Activitv

28 March 2017Waikato Regional Council's Proposed Healthy RiversANaiOra Plan Change 1 14

Rule - Small and Lowlntensity farmingactivities

Activity status.

Stock exclusion should be in conformance withthe proposed amendments to the NPS-FM.

Additionally, clarification is required todetermine what constitutes slope on landwhere topography is undulating, and portions

of the slope are both under and over the 15"threshold. This is currently subject tointerpretation and difficult to implement.

status.

Amend PC1 for stock exclusion:Cattle, horses, deer and pigs are excluded fromwater bodies in conformance with Schedule C forareas with a slope less than 15 degrees and onthose slopes exceeding 15 degrees where breakfeeding occurs.

Provide clarification on how/where to measureslope on undulating land,

tl.33 3.11.5.2Permitted ActivityRule - Other farmingactivities


Support low intensity land uses that have littleto no environmental risk to be under aPermitted Activity status.

Support stock exclusion, however only where itis prac'ticalto do so, and is relative to waterquality benefit gains.

Oppose a NRP because there should not be anumber that controls my ability to manage myland in the way I see fit, My FEP will provide arisk based mitigation plan to reduce all mydiffuse discharges. Additionally, the 201 41201 5and201512016 financial years occur when mystocking levelwas lower, therefore my on-farminputs were lower. This is not a truerepresentation of the past use of land.

Opposed 3.11.5.2-3b(i), I should not be limitedto my stocking rate on my land at 22 October2016. This is not a true representation of myfarmino activitv and it severelv limits my orowth

Retain Permitted Activity status for low intensityland uses.

Amend PC1 for stock exclusion:Cattle, horses, deer and pigs are excluded fromwater bodies in conformance with Schedule C forareas with a slope less than 15 degrees and onthose slopes exceeding 15 degrees where breakfeeding occurs.


Address contaminants on a sub-catchment basis,to enable targeting of the highest omitting sub-catchments,

Enable appropriate mitigation strategies to beadopted in the context of water quality gains to bemade, through a tailored Farm Environment Plan.

Amend 3.11.5.2 introduction to:The use of land for farmino activities (excludinq

28 March 2017Waikato Regional Council's Proposed Healthy RiversMaiOra Plan Change 1 15

and innovation. lt also hinders my economicviability for my business and for mycommunity. ln turn, this will generate anadditional load of stress on myself and mycom munity. Overal I this u ndermines Objec'tive2, 4, 5 and Policy 5.By adding a maximum of 18 stock units perhectare, at 30 June 2016 would indicate theoptimal winter carrying capacity of the land,aligning with good management praclices.

Oppose 3.11.5.4 c, "or grazed' should not beincluded and cultivation should be allowed upto 25". Again, it severely limits my growth andinnovation. lt also hinders my economicviability for my business and for mycommunity. ln turn, this will generate anadditional load of stress on myself and mycommunity. Overall this undermines Objeclive2,4,5 and Policy 5.

Require clarification around stock exclusion.3.1 1 .5.2-3e and 3.1 1 .5.2-4e(ii) states a three-metre buffer between water body and stock isrequired. However, in Schedule C the buffer isone-meter, and in Schedule 1 the buffer isbased on slope.

commercial vegetable production) and theassociated diffuse discharge of nitrogen,phosphorous, sediment and microbial pathogensonto or into land in circumstances which mayresult in those contaminants entering water wherethe property area is greater than 4.1 hectares,and has more than 6 stock units per hectare butless than 18 stock units per hectare at the 30June 2016, or is used for arable cropping, is apermitted activity subject to the followingconditions:

Amend rule in PC1 to remove 3.11.2-3b(i).

Amend rule in PC1 to:No part of the property or enterprise over +5 25"slope is cultivated er€rezed unless effects ofdiffuse discharges can be mitigated

Provide clarification around stock exclusionrequirements i.e, setback buffers and where tomeasure setback from on undulating land.

4.34 3.11.5.3Permitted ActivityRule - Farmingactivities with a FarmEnvironment Planunder a Certifiedlndustry Scheme


Support a tailored, risk based FarmEnvironment Plan to reduce diffusedischarges.

Support a Certified lndustry Scheme

Support stock exclusion, however only where itis practicalto do so, and is relative to water

Retain FEP, Certified lndustry Scheme, and stockexclusion where practical.

Amend rule in PCI to remove NRP.

Amend rule in PC1 to:Cattle, horses, deer and pigs are excluded fromwater bodies in conformance with Schedule C for

28March2A17Waikato RegionalCouncil's Proposed Healthy RiversMaiOra Plan Change 1 16

quality benefit gains.

Oppose a NRP because there should not be anumber that controls my ability to manage myland in the way I see fit. My FEP will provide arisk based mitigation plan to reduce all myditfuse discharges. Additionally, the 201412015and 201512016 financial years occur when thepayout was low, therefore my on-farm inputswere lower. This is not a true representation ofthe past use of land.Also, Overseer is the only available toolfor meto generate my NRP, but it was neverdesigned as a regulatory tool; only as a greatmanagement tool.

Require clarification around stock exclusion.3.11.5.3 refers to Schedule C and Schedule 1,

both have stock exclusion requirements.Schedule C states the buffer is one-meter, andSchedule 1 the buffer is based on slooe.

areas with a slope less than 15 degrees and onthose slopes exceeding 15 degrees where breakfeeding occurs.


Provide clarification around stock exclusionrequirements i.e. setback buffers and where tomeasure setback from on undulating land.

Provide clarification around how long a FEP willbe viable for.


4.35 3.1{.5.4Controlled ActivityRule - Farmingactivities with a FarmEnvironment Plan notunder a Certifiedlndustry Scheme

Support a tailored, risk based FarmEnvironment Plan to reduce diffusedischarges.

Support stock exclusion, however only where itis practicalto do so, and is relative to waterquality benefit gains.

Require clarification around applying forconsent to produce food, and other primaryproducts, on my land. I have concerns aroundthe costs and the backgroundlknowledge levelof the planner approving my consent. I am inpriority sub-catchment 1, therefore I am a

Retain FEP, Certified lndustry Scheme, and stockexclusion where practical.

Amend rule in PC1 to remove NRP.


Recommend 15 years or more for consentduration.

Provide clarification around stock exclusionrequirements i.e. setback buffers and where to

28 March 2017Waikato Regional Council's Proposed Healthy RiversMaiOra Plan Change 1 17

Permitted Activity until 1 January 2020.

Assuming consents will not go past theproposed start date of 2026 for Plan Change 2,my consent will be for 6 years. The onlypositive of applying for a consent is thesecurity and certainty that I can farm my land,as stated in my consent, for the next so manyyears. This duration needs to an appropriatelength of time i.e, at least 10 years.

Oppose a NRP because there should not anumber that controls my ability to manage myland in the way I see fit. My FEP will provide arisk based mitigation plan to reduce all mydiffuse discharges. Additionally, the 201412015and 201512016 financial years occur when mystocking levelwas lower, therefore my on-farminputs were lower. This is not a truerepresentation of the past use of land.Also, Overseer is the only available toolfor meto generate my NRP, but it was neverdesigned as a regulatory tool; only as amanagement tool.

Require clarification around stock exclusion.3.1 1 .5.3 refers to Schedule C and Schedule 1,

both have stock exclusion requirements.Schedule C states the buffer is one-meter, andSchedule 1 the buffer is based on slooe,

measure setback from on undulating land.

Provide clarification around how long a FEP willbe viable for.


4.36 3.{,l.5.7Non-ComplyingActivity Rule - LandUse Change

Oppose Oppose non-complying activity status because:. Unaffordable to land owners wanting to

increase their land area, rather thanintensify

o Eventuallv end up costino the consumer


Reduce activity status to Restricted Discretionary

28 March 2017Waikato RegionalCouncil's Proposed Healthy RiversMaiOra Plan Change 1 18

due to limited food availabilityo Limits flexibility, therefore growth

innovation, and reduces land valueo Jeopardises business, family and

community success and growthr Transfers wealth based on high emissions

and/or high NRP i.e. a dairy farm with ahigh NRP will have a higher land valuecompared to a dairy farm with a low NRP

r Removes, to a degree, propefty rightse Adds stress to life, family life, and the

community's lifer Overall will largely affect the local, regional

and nationaleconomy.

Overallthis rule undermines Objective 2,4,5and Policv 1 , 2, 5 and 9.

for high priority sub-catchments, in relation towater quality, and limit discretion to themanagement of the diffuse discharges of the fourcontaminants.

Reduce activity status to Permitted for low prioritysub-catchments, in relation to water quality.



Documents

3rnrn17 M Gmail - Waikato...M Gmail Bruce & rlVonne G PCl submission 2 messages Bruce & ltonne C Wed, Mar 8,2017 at 3:28 PM