NZIPIM's submission on Essential Freshwater Package 2019

NZIPIM has completed its submission to Government's Action Plan for Healthy Waterways, which sets out the proposed new requirements to improve freshwater and to stop further degradation of New Zealand's lakes and rivers. NZIPIM's submission to the proposals is available here, and focuses on the following areas:

  • Agree on the intent of the policy direction to improve water quality entering our waterways;
  • Highlight the cumulative impact and pressure faced by the farming community in meeting the proposed requirements on top of - proposals to reduce greenhouse gas emissions under the Zero Carbon Bill, increased pressure on bank lending arrangements, additional statutory requirements and compliance costs to farm businesses;
  • Identify capability and capacity shortfall of farm environmental planners in the market to develop plans (FW-FPs). We estimate that approximately 200 full-time farm environment planners will be needed over the next two to five years to develop FW-FPs for farmers and growers, plus 120 full-time approved auditors to audit these plans.
  • Concern at the general lack of analysis of the social and economic impact of the proposals which is a significant shortcoming in the Discussion Document;
  • Oppose new bottom line for nutrient levels for dissolved inorganic nitrogen and dissolved reactive phosphorus which appear unachievable in certain regions in New Zealand, and that further consideration needs to be given to key attributes to assess and measure the condition of waterways in a manner that more directly correlates positive land use practices to improving water quality and macro-invertebrate health;
  • The 'one size fits all' approach for stock exclusion setbacks of a five metre average coverage including the requirement for farmers to re-fence waterways that don't comply which is both expensive and punitive; and
  • Additional regulatory oversight and compliance costs associated in the monitoring and reporting on the state of wetlands to councils, including constructed wetlands.