5 November 2019
Nutrient management and environmental experts Ravensdown have delivered their submission to the government’s discussion
document on “Action for healthy waterways.”
The farmer-owned co-operative strongly supports the minister’s message that new requirements must be practical,
enduring, science-based, understood by the public and underpinned by effective regulation and enforcement. But concerns
remain on one-size-fits-all limits, mitigation approaches and the resourcing of farm environmental plans (FEPs).
“Ravensdown has the capabilities and competencies to help deliver robust FEPs accompanied by sound nutrient management
advice,” according to Anna Wilkes, Environmental Policy Specialist. “After all, we have the largest number of Certified
Nutrient Management Advisors in the country.”
“We believe in smarter farming and so we support the moves towards Good Management Practice in ways that keep farmers’
opportunity to innovate and to run farm businesses that are productive, sustainable and profitable for the benefit of
New Zealand,” continues Anna. There are three main areas of concern:
One-size-fits-all limits
Every waterway is different. Because nitrogen and phosphate levels can vary due to so many factors, Ravensdown opposes
national bottom lines and prefers regional limits. Even with the implementation of Good Management Practice, we believe
the proposed limits are unachievable in a number of waterways. Economic analysis of the financial impacts to farming,
which are likely to be severe for some, is currently lacking. An inflexible, ‘blanket approach’ is likely to smother the
ability of regions to settle on a limit that’s right for their catchments and ecological health.
Resourcing of farm environmental plans (FEPs)
It is estimated that 28,000 more farm environmental plans are needed. While we support the ideal of each farm having an
environmental plan, questions remain about who will be completing them, how fast they can be delivered, how the provider
will be certified and who by. Introducing a freshwater module into farm environmental plans is an admirable ambition,
but begs the questions: where an ‘army of freshwater specialists’ is going to come from and what hydrological tools they
are going to use.
Mitigation approaches
All the case studies featured in the document are from Canterbury. Soils, climate and management practices mean the
representativeness of these examples is severely limited. Rainfed volcanic soils with short rivers generating pasture as
the primary feed source will have a very different approach to sedimentary soils with low rainfall with a higher
reliance on forage crops throughout the winter.
The co-operative’s other concerns:
• Ravensdown opposes the requirement to move existing fences to meet the proposed new five-metre setback for
fencing waterways. Farmers who have already fenced waterways have invested significant time and expense in doing so and
any new setback requirement should only be required to be met at the end of the life of the fence.
• The proposed stocking rate thresholds for non-low-slope land could have significant implications for farmers
where standard farm practices (such as rotational grazing) will likely trigger the requirement to fence rivers over a
metre wide and lakes across the entire property with a five-metre setback by July 2021.
• The consultation period has been too short for the kind of rigour warranted for such an important topic.
ENDS