Opinion: Fresh water farm plans -workable legislation?
Under new legislation being drafted all livestock and arable farmers over 20 hectares and horticulture over five hectares would require a government prescribed freshwater farm plan; although calling this a farm plan is a bit of a euphemism.
What these are is a government-imposed farming directive that undermine the value of farm plans. How would this directive change the way we farm and is it workable legislation?
The first step is a freshwater farm plan prepared in line with the government’s legislation.
Each individual property will need to identify their impacts on freshwater, how those impacts will be managed and how regulatory requirements relating to freshwater will be met.
The second step is the plan will need to be certified by a suitably qualified person appointed by regional councils.
The role of the certifier is to ensure the plan meets all the legal requirements. The third step is ongoing audits – again by someone suitably qualified and appointed by regional councils.
The auditor must be a different person to the certifier.
The role of the auditor is to determine a pass or fail in terms of whether your actions on farm met the requirements in your certified farm plan and in regulations.
There are fundamental failures with what the Government has proposed.
The prescriptive, one size fits all approach fails to account for the huge variation between farms and the constantly changeable nature of farming, particularly in relation to climatic and natural events. This creates an impossible task for a certifier to create a flexible, workable farm plan and explains why there is a reluctance amongst the consultancy sector to take on certifier and auditor roles.
Another failure of the Governments policy is it assumes all existing regulations are workable and able to be implemented.
Farm plans will be audited against regulations like low slope and stock exclusion. In Canterbury because it is impossible for hill and high-country farmers to physically comply with the unworkable stock exclusion rules will mean all these farmers are destined to fail their audits.
To be successful this policy requires a huge bureaucracy. Hundreds of consultants to write 35,000 farm plans; hundreds of qualified certifiers and auditors; and more regional council staff to oversee certifiers and auditors, monitor the audit process, and ensure farmer compliance with the requirements.
On top of this, Ministry for the Environment have recently advertised multiple farm plan supervisor and manager positions throughout the country with healthy $200,000 pay packets to boot.
With existing widespread labour shortages there are not the people available to fill all these roles.
Because of the failure of the Governments approach to farm plans, Groundswell NZ supports the calls from our farming advocacy groups and regional councils for an industry led approach that has farm advisors working in partnership with farmers to identify and implement the environmental priority actions relevant to each individual farm and catchment.
A simple, effective system that has a proven track record through the successful Catchment Board farm plans.
by Jamie McFadden
Groundswell NZ environmental spokesperson