Farming groups say proposed freshwater farm plans should be based on the risk from individual farms rather than a one-size-fits-all, blanket requirement.
In letters to government ministers, Beef + Lamb NZ, DairyNZ and Federated Farmers have outlined similar positions on how they want freshwater farm plans (FWFPs) structured.
The coalition government has released its goals for July 1 to 30 September and one action is to amend requirements for farmers “in certain areas” to have certified freshwater farm plans.
Beef + Lamb NZ (BLNZ) has also called for the suspension of FWFPs currently being implemented in Waikato and Southland until the new policy is finalised.
The three farming groups are united in wanting FWFPs to be risk based on individual farms and each catchment rather than the current blanket approach.
BLNZ also wants a review of all National Policy Statement for Freshwater (NPS-FW) water quality bottom lines, specifically for sediment and E coli, saying it has concerns with the methodology used and the way they are set, and questions if those targets are achievable.
Its preference is for limits to be set and for targets set specifically to each catchment.
DairyNZ and Federated Farmers both want the 20 hectare threshold raised at which FWFPs are required, saying it is too small and the requirement should only apply to commercial size farms.
DairyNZ chair Jim van der Poel and Federated Farmers president Wayne Langford went further, renaming the FWFP planning documents farm plans to reflect their ability to deliver improvements to freshwater and the environment.
Langford said plans should not be costly or overly burdensome nor additional to consenting requirements and standards but instead be practical and outcomes focused.
Each plan’s contents, actions and audit frequency should be dictated by the context of each catchment and the relative farm and activity risk.
“The minimum standards for all farm plans, contents and actions would be driven by these relative risk factors.”
This would mean a tiered system where high-risk activities in high-risk catchments are subject to greater scrutiny than low-risk activities in low-risk catchments.
He said farm plans are a tool to manage winter grazing, stock exclusion, wetland protection and fertiliser use.
Protection of FWFP data, considered private, was a concern to all groups and considered crucial to secure farmer buy-in.
Concerns have been raised that FWFPs could be subject to Official Information Act requests to councils and therefore available to environmental and animal welfare groups.
The farming bodies said this information must sit with farmers and only be available for auditing and regulatory purposes.
DairyNZ’s Van der Poel said existing industry-supply requirements should be recognised, plans based on best practice and integrated with regional council plans tailored to individual catchments.
He also wants the removal of unnecessary and duplicative regulation, realistic and achievable implementation time frames, the protection of farmer data and FWFPs to be part of larger freshwater management framework.
BLNZ chair Kate Acland said 90% or more of the 614 respondents to a survey of levy players agreed or strongly agreed they should be able to complete farm plans themselves, and that these should be tailored to the potential risk of individual farms.
There was equally strong agreement that certification and auditing of plans should be simpler than the proposed process of certification plus regular auditing.
Federated Farmers board member Colin Hurst said these letters follow pre-submission workshops involving farming groups, officials and non-government organisations.
He said while everyone will not get what they want, the workshops reveal the positions and reasons for these positions.
“This way there should be a more robust policy notification.”
He sees merit in renaming FWFP farm plans as it reflects the move to a risk-based planning approach.
“A risk-based approach means we tailor our impact to the environment.
“It means we can put resources where they are required, on the farms that are impacting the environment.”
