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FURTHER SUBMISSION FORM
www.epa.govt.nz
Tukituki Catchment Proposed Plan Change 6 Section 149F of the Resource Management Act 1991, Form 16C
To:
Environmental Protection Authority Email: [email protected]
Level 10, 215 Lambton Quay Fax: 04 914 0433
Private Bag 63002, Waterloo Quay
Wellington 6140
This is a further submission on the Hawke’s Bay Regional Council’s Proposed Plan Change 6.
It is important that you complete all sections on this form and that the EPA receives this submission before the closing date and time for further submissions - 5.00pm, Friday 30 August 2013.
Privacy statement
Your personal information included in Part A of this form, will be held by the EPA, 215 Lambton Quay, Wellington.
The information provided will be used by the EPA for the administration of the Tukituki Catchment Proposal Board
of Inquiry process. Copies of your full further submission will be provided to the Board of Inquiry and the applicant,
and the original submitter, and may also be provided to other parties in the process. Other than your name, your
personal contact information will not be published on the EPA website. You have the right to access and correct
personal information held by the EPA.
Your name, the information in Parts B and C of this form, and any attached information will be published on the
EPA website, and made available to members of the Board of Inquiry, the applicants and the public for use in the
processing and consideration of the Tukituki Catchment Proposal.
Note: If the submitter is a company, full business contact details will be publicly available.
All information held by the EPA is subject to the Official Information Act 1982.
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Tukituki Catchment Proposed Plan Change 6 Further Submission Form
August 2013 EPA0284
How to make a further submission
Further submission forms are available from http://www.epa.govt.nz/Resource-management/Tukituki or can be
requested by calling 0800 577 566.
The EPA can receive submissions:
• online using the online further submission form available at www.epa.govt.nz/Resource-management/Tukituki; • by email to [email protected], (if smaller than 10MB), with the subject line: Further submission:
(your name), Tukituki Catchment Proposal Proposed Plan Change 6;
• by fax to (04) 914 0433, with the subject line: Further submission: (your name), Tukituki Catchment Proposal
Proposed Plan Change 6;
• in hard copy or on an electronic storage device (if larger than 10MB) either:
o posted to the Environmental Protection Authority, Tukituki Catchment Proposal, Private Bag 63002,
Waterloo Quay, Wellington 6140; or
o delivered in person to EPA Head Office, Level 10, 215 Lambton Quay, Wellington. The further submission must be in writing in the prescribed form, and be received by the EPA no later than 5.00pm, Friday 30 August 2013.
You must send a copy of your submission to both the Hawke’s Bay Regional Council and the original submitter no later than five working days after you have served your submission on the EPA. The EPA will provide you with contact details for the original submitter upon receipt of your further submission.
You can send your further submission to Hawke’s Bay Regional Council either:
• online by selecting to automatically send the applicant a copy of your submission from the online further
submission form;
• by email to [email protected] (if smaller than 10MB);
• by fax to (06) 835 3601; • in hard copy or on an electronic storage device (if larger than 10MB) either:
o posted to Hawke’s Bay Regional Council, Private Bag 6006, Napier 4142, Attention: Helen Codlin; or
o delivered in person to Hawke’s Bay Regional Council, 159 Dalton Street, Napier, marked for the
attention of Helen Codlin.
Where to get help preparing your further submission
If you have questions about making a further submission, or you do not understand this form, please contact the
EPA by phone on 0800 577 566 or by email at [email protected].
Alison McEwan from Langley Twigg Law has been appointed as an independent ‘Friend of Submitter’. The Friend
of Submitter is available to help you with information on the board of inquiry process and making a further
submission. You can contact the Friend of Submitter on 0800 020 008 or via email on [email protected].
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Tukituki Catchment Proposed Plan Change 6 Further Submission Form
August 2013 EPA0284
Part B
3. Further Submitter Eligibility The following persons are eligible to make a further submission on the matter under section 149F(3). If you do not
fit one of the categories below, you cannot make a further submission.
Please tick which category/categories apply to you:
A person representing a relevant aspect of the public interest
(Please provide an explanation in the space provided below)
Federated Farmers represents farmers in the Hawkes Bay region.
A person who has an interest in the proposal that is greater than the interest of the general public
(Please provide an explanation in the space provided below)
The local authority
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Tukituki Catchment Proposed Plan Change 6 Further Submission Form
August 2013 EPA0284
4. Further Submitter Position This is a further submission in support of, or in opposition to (as noted below) a submission or submissions originally made on the Hawke’s Bay Regional
Council’s Proposed Plan Change 6 to the Regional Resource Management Plan. Further submissions cannot be made on the notice of requirement and/or the
applications for resource consents.
Original submitter name
Original Submission number
Support or oppose the original submission
The particular parts of the original submission that I / we support / oppose are:
The reasons for my support / opposition to the original submission are:
Please indicate the decision you seek*:
Please see Federated Farmers attached Further Submission.
* NB: the decision you seek can be to allow or disallow the whole or part of the original submission
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Tukituki Catchment Proposed Plan Change 6 Further Submission Form
August 2013 EPA0284
* NB: the decision you seek can be to allow or disallow the whole or part of the original submission
Please use additional pages if required.
7
Tukituki Catchment Proposed Plan Change 6 Further Submission Form
August 2013 EPA0284
Part C 5. Do you wish to speak at the hearing? All further submissions will be considered by the Board of Inquiry.
As a further submitter you may speak about your further submission at the hearing. You need to advise us if you
are intending to speak.
The hearing is open to the public, and anyone is welcome to attend to listen.
If you indicate on your further submission that you do not want to speak at the hearing, you will not receive further
correspondence from the EPA until the draft decision report is sent to you. However, all information will be
available on the EPA website.
Please indicate if you want to speak at the hearing.
I / We do not wish to speak about my / our further submission.
OR
I / We wish to speak about my / our further submission
If others make a similar submission, I / we will consider presenting a joint case with them at the hearing.
I / We wish to present in Maori / Te Reo.
Please be aware that if you wish to speak at the hearing, a lot of information such as hearing schedules, board directions and
reports, will need to be sent to you in accordance with your preference for receiving information. Note: If you do not select one
of the above options, the EPA will assume you wish to speak about your further submission.
6. Do you intend to provide expert evidence? This section of the submission form relates only to people who want to speak at the Board of Inquiry hearing. If you
do not wish to speak at the hearing, you do not need to complete this section.
An expert is a person who through training or experience is a skilled practitioner in a particular subject and is able
to give professional evidence on that particular subject. All experts are expected to comply with Environment Court
Practice Note 2011 (available at http://www.justice.govt.nz/courts/environment-court/legislation-and-
resources/practice-notes/practice-notes), and be prepared to be cross-examined. The Board will determine what
weight is given to any material put before it.
Do you intend to have an expert support your submission at the hearing?
No, I / we have no expert witnesses (please go to section 9).
No, I / we have no expert witnesses, but I consider I have expertise to be considered an expert (please fill
in the table on the next page below).
Yes, I / we have expert witnesses (please fill out the table on the next page below).
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Tukituki Catchment Proposed Plan Change 6 Further Submission Form
August 2013 EPA0284
If you consider yourself to be an expert or intend to provide evidence from expert witnesses please outline the
areas of your/their expertise. If possible provide their names, or state their name is to be confirmed (TBC).
If you require further space, please attach additional pages.
Name of witness Area(s) of expertise Phone number Email address
To be confirmed.
7. Authority to act Please tick to confirm you are authorised to represent all persons making this further submission.
I / We confirm that I / we have authority to sign this further submission on behalf of all persons named on
this form.
Rhea Dasent 30 August 2013.
Signature Date
Signature of further submitter, or person authorised to sign on their behalf is required.
Note: A signature is not required for electronic (email) further submissions.
Please ensure you have completed all questions on the form. Unanswered questions may require clarification.
Before you send in your completed submission, please check that you have provided the following key information:
• Contact details (name, address, phone and email address) • Your further submitter eligibility • Your position on original submission(s) • How you would like to receive information • If you wish to speak about your further submission at the hearing
1
FURTHER SUBMISSION
To: The Environmental Protection Authority
Further The Tukituki Proposal
Submission on:
Date: 30 August 2013
Further Federated Farmers of New Zealand
Submission by:
Federated Farmers wish to be heard in support of our submission.
2
Federated Farmers Further Submission to the Tukituki proposal.
FURTHER SUBMISSION TO THE TUKITUKI PROPOSAL.
To: The Environmental Protection Authority
Further Submission to: The Tukituki Proposal
Further Submission by: Federated Farmers of New Zealand
Submission Number
Submitter Name
Statement Number
Support/ Oppose
Reasons for Further Submission
Decision Sought
C6 New New Provision in Change 6
17
Dairy NZ 1
Support
Federated Farmers agrees with the submitter that the importance of land use in the Tukituki for rural food production needs to be recognised.
That the submission be accpetde.
23
Forest and Bird Society
Central Hawke’s Bay
2
Oppose
Federated Farmers opposes the submitter’s relief sought to add a new provision that acknowledges cadmium and heavy metals in soil. Our opposition is on the basis that Plan Change 6 is intended to address water quality, and not soils.
That the submission be rejected.
24
Forest and Bird Society
Hastings/ Havelock North
10 Oppose
Federated Farmers opposes the submitter’s relief sought to impose a new farm management approach to maintain or improve water quality and a controlled status. Our opposition is on the basis that controlled status for farming is impractical and onerous, and that improving water quality will not achieve sustainable management as economic wellbeing will suffer.
That the submission be rejected.
3
Federated Farmers Further Submission to the Tukituki proposal.
34
Hawke’s Bay Fish & Game Council
31 Oppose
Federated Farmers opposes the submitter’s relief sought to identify outstanding water bodies in the Tukituki catchment, and include new provisions for their maintenance and
enhancement. Our opposition is on the basis that we
support Council’s position as outlined in the Section 32 report that this is a task to be done at a region-wide basis, as opposed to a catchment level.
That the submission be rejected.
66
Te Taiao Hawke’s Bay Environment Forum
12 Oppose
Federated Farmers opposes the submitter’s relief sought to list and protect outstanding water bodies in the Tukituki
catchment. Our opposition is on the basis that we support
Council’s position as outlined in the Section 32 report that this is a task to be done at a region-wide basis, as opposed to a catchment level.
That the submission be rejected.
C6 OBJ TT1
22 Fonterra Co-Operative
Group Ltd 1 Support
Federated Farmers agrees with the submitter that an additional clause is included in the objective to recognise that the Plan Change outcome is to enable people and communities access to water to provide for their social and economic wellbeing. This will achieve sustainable management.
That the submission be accepted.
34
Hawke’s Bay Fish & Game Council 40 Oppose
Federated Farmers opposes the submitter’s relief sought to amend Obj TT1(d) to include all wetlands and not just natural wetlands. Our opposition is for the reason that the inclusion of artificial wetlands will discourage their formation, and that resources are better directed at natural wetlands that will benefit most from protection provisions.
That the submission be rejected.
4
Federated Farmers Further Submission to the Tukituki proposal.
41
Irrigation New Zealand Inc 1 Support
Federated Famers agrees with the submitter that Objective TT1 needs to recognise and provide for the socio-economic contribution of food and fibre production in the Tukituki catchment.
That the submission be accepted.
64 Silver Fern Farms
1 Support
Federated Famers agrees with the submitter that Objective TT1 needs to enable economic wellbeing in order to achieve sustainable management.
That the submission be accepted.
376
Mr Apple New Zealand Ltd 2 Support
Federated Famers agrees with the submitter that Objective TT1 needs to enable the use of land and water for primary production in order to achieve sustainable management.
That the submission be accepted.
378 Dairy NZ
9 Support
Federated Famers agrees with the submitter that Objective TT1 needs to recognise that scoioeconomic wellbeing relies on access to water and the ability to carry out food production.
That the submission be accepted.
384
Horticulture New Zealand and Others
3 Support
Federated Famers agrees with the submitter that Objective TT1 needs to be amended to enable the use of land and water for food production and other forms of primary production.
That the submission be accepted.
C6 OBJ TT2
41 Irrigation
New Zealand Inc 2 Support
Federated Farmers agrees with the submitter that OBJ TT2 needs to provide for an integrated approach to water management when discussing the improvement of water quality.
That the submission be accepted.
5
Federated Farmers Further Submission to the Tukituki proposal.
283 Ruataniwha Water
Users Group 5 Support
Federated Farmers agrees with the submitter that OBJ TT2 needs to provide for an integrated approach and reasonable time limits to water management when discussing the improvement of water quality.
That the submission be accepted.
C6 OBJ TT4
34
Hawke’s Bay Fish & Game Council 45 Oppose
Federated Farmers opposes the relief sought by the submitter to amend the objective to reduce existing abstractions, and to restrict transfer of consents. Our opposition is on the basis that reducing existing abstractions could lead to adverse effects on economic and social wellbeing. Transfers need to be enabled as the cumulative effect on the catchment is minimal, but for individual takes the ability to use more water as it is transferred from a property where need is reduced will have positive effects on individual social and economic wellbeing.
That the submission be rejected.
41 Irrigation
New Zealand Inc 3 Support
Federated Farmers agrees with the submitter that when discussing the avoidance of new allocations, that this excludes the renewal of existing consents. Renewal of existing consents is vital for those water users.
That the submission be accepted.
22 Fonterra Co-operatvie
Group Ltd 3 Support
Federated Farmers agrees with the submitter that Objective TT4 needs to specify that it’s is the consent holder that decides that their consent is surrendered or not renewed, current wording is unclear that it could be the Council that decides.
That the submission be accepted.
6
Federated Farmers Further Submission to the Tukituki proposal.
C6 OBJ TT5
283 Ruataniwha Water
Users Group 8 Support
Federated Farmers agrees with the submitter that the footnote limiting community irrigation schemes to those that can service over 5,000ha is restrictive. The area of land or the size of a property irrigated is not a determining factor with respect to the efficient use of water.
That the submission be accepted.
384 Horticulture
New Zealand and Others
7 Support
Federated Farmers agrees with the submitter that the footnote limiting community irrigation schemes to those that can service over 5,000ha is restrictive and should simply provide for schemes where they improve efficient allocation and use of water regardless of size.
That the submission be accepted.
C6 POL TT1 Policy TT1 (Surface water quality limits, targets, indicators)
21 Fertiliser Association
of NZ Inc 5 Support
Federated Farmers agrees with the submitter that POL TT1(a) needs to change wording from “avoid” toxicity and focus instead on meeting accepted risk levels that are appropriate for that sub-catchment. Avoidance may not always be possible in a sustainable management context, and focussing on meeting an appropriate target provides a positive goal.
That the submission is accepted.
384 Horticulture
New Zealand and Others
16 Support
Federated Farmers agrees with the submitter that POL TT1 needs to set limits and targets that still provide for the maintenance of existing landuses and enhancement of primary production where limits are not exceeded. Land use and production occur throughout the Tukituki and contribute to people and communities wellbeing, and should be maintained or enhanced.
That the submission be accepted.
7
Federated Farmers Further Submission to the Tukituki proposal.
C6 POL TT2 Policy TT2 (groundwater quality limits)
34 Hawke’s Bay
Fish & Game Council 53 Oppose
Federated Farmers opposes the submitter’s relief sought to amend Policy TT2 to recognise connection between groundwater and surface water. The connections, where they are and how they operate, need to be better established and evidence-based before being included in this policy.
That the submission be rejected
C6 POL TT4 Policy TT4 (implementing nitrate-nitrogen limits)
17 Dairy NZ 12 Support
Federated Farmers agrees with the submitter that Policy TT4 needs to enable the use of existing industry farm planning tools so there is no unnecessary duplication on farms.
That the submission be accepted.
21 Fertiliser Association of New Zealand Inc.
8 Support
Federated Farmers agrees with the submitter that Policy TT4 include a requirement to facilitate a working group approach between the Regional Council and primary sector groups to develop industry good practice. Collaboration is vital to ensure good management practice is workable and practical to apply on farm while achieving desired results.
That the submission be accepted.
34 Hawke’s Bay
Fish & Game Council 65 Oppose
Federated Farmers opposes the submitter’s relief sought that a dissolved inorganic nitrogen limit be applied throughout the Tukituki catchment
That the submission be rejected.
34 Hawke’s Bay
Fish & Game Council 66 Oppose
Federated Farmers opposes the submitter’s relief sought to delete reference to using an alternative model to Overseer for calculating nutrient budgets. This is because the policy needs to remain flexible to enable uptake of newly developed models that could improve on and supersede Overseer
That the submission be rejected.
8
Federated Farmers Further Submission to the Tukituki proposal.
34 Hawke’s Bay
Fish & Game Council 67 Oppose
Federated Farmers opposes the submitter’s relief sought to delete TT4.1(b) which currently requires industry good practice. Industry good practice is an important tool that will work towards achieving the desired outcomes while enabling landowner and stakeholder buy-in. The variability of good practice is an asset, as it will improve over time as new methods and technologies are developed.
That the submission be rejected.
34 Hawke’s Bay
Fish & Game Council 68 Oppose
Federated Farmers opposes the submitter’s relief sought to delete TT4.1(c) because the submitter considers that methods will be ineffective. Industry good practice and time to develop this practice is an important tool to achieve the desired outcomes.
That the submission be rejected.
283 Ruantaniwha Water
Users Group 12 Support
Federated Farmers agrees with the submitter that footnote 11 is amended to include reference to alternative models may be used as well as Overseer. This will be consistent with POL TT4.1(a).
That the submission be accepted.
384 Horticulture
New Zealand and Others
27 Support
Federated Farmers agrees with the submitter that any alternative models to Overseer should be approved for use by industry as well as by the Regional Council in POL TT4.1(a). It is important that good practice is practical and acceptable to industry for it to work effectively.
That the submission be accepted.
C6 POL TT5 Policy TT5 (implementing phosphorus limits and targets)
34 Hawke’s Bay
Fish & Game Council 81 Oppose
Federated Farmers opposes the submitter’s relief sought to amend POL TT5.1(d) so the timeframe for stock exclusion is reduced to 2017. A timeframe of 2017 is not achievable as stock exclusion requires fencing, alternative water supply and changes in management.
That the submission be rejected.
9
Federated Farmers Further Submission to the Tukituki proposal.
34 Hawke’s Bay
Fish & Game Council 82 Oppose
Federated Farmers opposes the submitter’s relief sought to include a new clause in POL TT5.1(d) to set an environmental effect threshold for stock access that is permitted. Stock access has been restricted by the policy and allows access only in limited situations where it is necessary for weed control and crossings, so the environmental effect has already been addressed.
That the submission be rejected.
28 Harker, Jeremy 1 Support
Federated Farmers agrees with the submitter that sheep are removed from the stock exclusion requirements. Normal sheep behaviour is to avoid standing in water or in boggy areas, so the problem of trampling and stirring up sediment on the bed is not an issue.
That the submission be accepted.
389 Hunter, James 3 Support
Federated Farmers agrees with the submitter that sheep are removed from the stock exclusion requirements. The cost to the individual of fencing for sheep is high, while the benefits for the community in the potential reduction of phosphorus is low because sheep are not a significant source.
That the submission be accepted.
11 Irrigation
New Zealand Inc 11 Support
Federated Farmers agrees with the submitter that sometimes terrain can impede stock exclusion measures, and that a Farm Environment Plan be used to demonstrate to Council if this is a reason why exclusion may not be feasible for a farm.
That the submission be accepted.
304 Environmental
Defence Society Inc 33 Oppose
Federated Farmers opposes the submitter’s relief sought to amend POL TT5.1(d)(iii) for all stock crossings to be bridged or culverted. This is impractical as some crossings are used infrequently and the cost of a bridge or culvert will not outweigh the benefit.
That the submission be rejected.
10
Federated Farmers Further Submission to the Tukituki proposal.
304 Environmental
Defence Society Inc 35 Oppose
Federated Farmers opposes the submitter’s relief sought to require a contaminant management plan. Federated Farmers is unclear as to what this means, whether individual farms will all be required to have such a plan, or what the plan intends to achieve. Farm Environment Plans as discussed throughout the plan change seem to address this submitter’s concern.
That the submission be rejected.
C6 POL TT6 Policy TT6 (use of production land)
21 Fertiliser Association of New Zealand Inc
32 Support
Federated Farmers agrees with the submitter that the consent timeframe needs to be extended to promote business confidence in investment and growth. The proposed 5 year term is too short to enable confidence.
That the submission is accepted.
22 Fonterra Co-operative
Group Ltd 15 Support
Federated Farmers agrees with the submitter that POL TT5 is amended to enable the Supply Fonterra scheme agreement to be used as an alternative to the Farm Environment Management Plan to demonstrate compliance. This will avoid unnecessary duplication.
That the submission be accepted.
34 Hawke’s Bay
Fish & Game Council 89 Oppose
Federated Farmers opposes the submitter’s relief sought to amend Pol TT6 so that matters are complied with rather than regarded when considering consent applications. Matters in the policy enable consent applications to be assessed on their individual merits and so outright compliance is not appropriate in this policy context.
That the submission be rejected.
11
Federated Farmers Further Submission to the Tukituki proposal.
34 Hawke’s Bay
Fish & Game Council 92 Oppose
Federated Farmers opposes the submitter’s relief sought to amend Pol TT6.1(a)(vii) to require riparian planting instead of ensuring appropriate riparian management occurs. The current wording should be retained as it enables other management than planting only, and recognises that it may or may not be appropriate or achievable for any individual property.
That the submission be rejected.
291 Hawke’s Bay
Regional Council 2 Oppose
Federated Farmers opposes the submitter’s relief sought to add a new clause to TT6.1 to impose a three year lapse period on consents to discourage speculative land use. Section 195 of the RMA already has a five year consent lapse timeline, which allows for consent holders to make progress towards carry out the consented activity in other ways, such as raising capital or developing their business. There is no need for a three year lapse period.
That the submission be rejected.
304 Environmental
Defence Society Inc 39 Oppose
Federated Farmers opposes the submitter’s relief sought to amend Pol TT6 so that matters are complied with rather than regarded when considering consent applications. Matters in the policy enable consent applications to be assessed on their individual merits and so outright compliance is not appropriate in this policy context.
That the submission be rejected.
304 Environmental
Defence Society Inc 44 Oppose
Federated Farmers opposes the submitter’s relief sought to provide for common expiry dates for consents throughout the catchment. Term of consent needs to provide for enough time to give the consent holder some business certainty, for consents that are applied for at different times to be given the same expiry date will negatively impact on later consent applications who will be given a lesser term.
That the submission be rejected.
C6 Table 5.9.1A Table 5.9.1A (catchment-wide surface water quality limits and targets)
12
Federated Farmers Further Submission to the Tukituki proposal.
32
Hawke’s Bay Environmental Water
Group 17 Oppose
Federated Farmers opposes the submitter’s relief sought to have temperature limits for aquatic ecosystems and trout spawning added to the Table. Table 5.9.1A already has a limit for temperature that it be suitable for sustaining aquatic habitat, and this allows the temperature to be appropriate for it’s location throughout the catchment. There is no need for further specification as the table is to apply catchment-wide.
That the submission be rejected.
32
Hawke’s Bay Environmental Water
Group 19 Oppose
Federated Farmers opposes the submitter’s relief sought to have total suspended solids, soluble inorganic nitrogen, sediments-contaminants and heavy metals standards added to the Table. Table 5.9.1A is intended to apply catchment-wide and therefore the relefi sought is inappropriate here, and Table 5.9.1B is more specific as it sets limits and targets for specified zones which addresses the submitter’s concern.
That the submission be rejected.
C6 Ch 5.9.3 POLs Gen Chapter 5.9.3 TT Water Quantity Policies - General
394
Irrigation New Zealand Ltd
2 Support
Federated Farmers agrees with the submitter that the minimum flows set in Tables 5.9.3 and 5.9.5 need to take into account two possible scenarios – one of the Ruataniwha Dam going ahead, and one without the dam in place. There is still uncertainty whether the dam will be granted resource consent or not and it would be inequitable and sustainable management would not be achieved if the minimum flow levels were increased and yet access to water via the dam did not occur. This would have a major impact on the wellbeing of individuals and their communities if access to water for primary production did not occur because minimum flows were increased.
That the submission be accepted.
13
Federated Farmers Further Submission to the Tukituki proposal.
C6 POL TT7 Policy TT7 (minimum flow limits)
29
Hastings District Council
4 Support
Federated Farmers agrees with the submitter that access to water for irrigation during a drought emergency should be enabled when this does not cause irreparable damage to the environment. During a drought, severe or irreparable damage can be done to crops (such as horticultural trees which are considered a capital asset) and sustainable management is not achieved when such assets are damaged and this has lasting impacts on economic wellbeing of individuals and communities. The ability to make such decisions according to the circumstances needs to be imbued within the policy framework.
That the submission be accepted.
34
Hawke’s Bay Fish & Game Council
101 Oppose
Federated Farmers opposes the submitter’s relief sought to delete the exclusion to minimum flows for in-stream dams, and to apply minimum flows to permitted takes as well as consented takes. In-stream dams are intended to store water and enable taking of water when un-dammed river flows would otherwise be lower, so minimum flows that have been developed for the river are inappropriate for the in-stream dam. Permitted takes are enabled because they are so important to wellbeing of people and communities, and do not cause a level of adverse effects that is unacceptable. It would be inappropriate to apply minimum flow reduction or cessation conditions to permitted takes such as domestic and animal drinking supply that are enabled under Section 14(3)(b) of the RMA..
That the submission be rejected.
14
Federated Farmers Further Submission to the Tukituki proposal.
304
Environmental Defence Society Inc
49 Oppose
Federated Farmers opposes the submitter’s relief sought to apply minimum flows to all takes including permitted takes Permitted takes are enabled because they are so important to wellbeing of people and communities, and do not cause a level of adverse effects that is unacceptable. It would be inappropriate to apply minimum flow reduction or cessation conditions to permitted takes such as domestic and animal drinking supply that are enabled under Section 14(3)(b) of the RMA..
That the submission be rejected.
C6 POL TT8 Policy TT8 (allocation limits)
34
Hawke’s Bay Fish & Game Council
108 Oppose
Federated Farmers opposes the submitter’s relief sought to amend POL TT8 so allocation limits are no longer based on existing volume of consented takes as the submitter considers that this will not achieve sustainable management. Enabling existing takes to continue within the policy framework is an important factor in achieving sustainable management, because economic and social wellbeing that relies on the existing takes will be provided for.
That the submission be rejected.
283
Ruataniwha Water Users Group
21 Support
Federated Farmers agrees with the submitter that the recognition of the interconnectedness of groundwater and surface water should be specified that this is in certain locations. This will allow evidence-based recognition rather than applying this assumption to the entire catchment.
That the submission be accepted.
15
Federated Farmers Further Submission to the Tukituki proposal.
C6 Table 5.9.3 Table 5.9.3 (minimum flow limits)
378
Mr Apple New Zealand Ltd
16 Support
Federated Farmers agrees with the submitter that the timeframe for the transition period needs to take into account when the community irrigation scheme is implemented. The assumption that the dam will be consented and then implemented may not occur, and the minimum flows will have a substantial impact on water takes and wellbeing if there is no alternative water source available.
That the submission be accepted.
34
Hawke’s Bay Fish & Game Council
109 Oppose
Federated Farmers opposes the submitter’s relief sought to provide for 90% habitat retention for critical species throughout the catchment. 90% protection may not provide for economic and social wellbeing if water takes are reduced to meet this level. Environmental protection needs to be balanced with other wellbeings in order to achieve sustainable management.
That the submission be rejected.
C6 Table 5.9.4 Table 5.9.4 (surface water allocation limits)
41
Irrigation New Zealand Ltd
14 Support
Federated Farmers agrees with the submitter that when setting in the Table the information needs to be robust and sound, and incorporate all factors not just the economic impact on pasture-based production. Sustainable management will not be achieved unless economic and social impacts of increased minimum flows are assessed on a wider basis of production types.
That the submission be accepted.
16
Federated Farmers Further Submission to the Tukituki proposal.
34
Hawke’s Bay Fish & Game Council
110 Oppose
Federated Farmers opposes the submitter’s relief sought to provide for new allocation limits that do not exceed 30% MALF, and incorporate permitted takes into the surface water allocation limits. Any reduction in existing limits will have a negative impact on existing water users. Permitted takes are enabled because they are so important to wellbeing of people and communities, and do not cause a level of adverse effects that is unacceptable. It would be inappropriate to apply allocation limits to permitted takes such as domestic and animal drinking supply that are enabled under Section 14(3)(b) of the RMA..
That the submission be rejected.
C6 Table 5.9.5 Table 5.9.5 (groundwater allocation limits)
34
Hawke’s Bay Fish & Game Council
111 Oppose
Federated Farmers opposes the submitter’s relief sought to provide for new allocation limits that do not exceed 30% MALF, and incorporate permitted takes into the groundwater allocation limits. Any reduction in existing limits will have a negative impact on existing water users. Permitted takes are enabled because they are so important to wellbeing of people and communities, and do not cause a level of adverse effects that is unacceptable. It would be inappropriate to apply allocation limits to permitted takes such as domestic and animal drinking supply that are enabled under Section 14(3)(b) of the RMA.
That the submission be rejected.
34
Hawke’s Bay Fish & Game Council
113 Oppose
Federated Farmers opposes the submitter’s relief sought to amend footnote 29 to include community irrigation schemes in allocation limits. In-stream dams are intended to store water and enable taking of water when un-dammed river flows would otherwise be lower, so allocation limits that have been developed for the river are inappropriate for the in-stream dam.
That the submission be rejected.
17
Federated Farmers Further Submission to the Tukituki proposal.
C6 POL TT9 Policy TT9 (implementing minimum flows and allocation limits)
34
Hawke’s Bay Fish & Game Council
114 Oppose
Federated Farmers opposes the submitter’s relief sought to include new criteria which requires water efficiency to be maximised. Water efficiency is best defined by the water user
That the submission be rejected.
34
Hawke’s Bay Fish & Game Council
115 Oppose
Federated Farmers opposes the submitter’s relief sought to restrict the transfer of consents to reduce over allocation. Transfer of existing consents should be enabled because it will not increase the total amount allocated in the catchment so will have a neutral effect on water quantity, but will provide a substantial benefit to individual water users.
That the submission be rejected.
34
Hawke’s Bay Fish & Game Council
116 Oppose
Federated Farmers opposes the submitter’s relief sought to incorporate permitted takes into the surface water allocation limits. Permitted takes are enabled because they are so important to wellbeing of people and communities, and do not cause a level of adverse effects that is unacceptable. It would be inappropriate to apply allocation limits to permitted takes such as domestic and animal drinking supply that are enabled under Section 14(3)(b) of the RMA..
That the submission be rejected.
41
Irrigation New Zealand Inc
19 Support
Federated Farmers agrees with the submitter that policy TT9.1(b)(i) needs to specify that it’s is the consent holder that decides that their consent is surrendered or not renewed, current wording is unclear that it could be the Council that decides.
That the submission be accepted.
18
Federated Farmers Further Submission to the Tukituki proposal.
304
Environmental Defence Society Inc
59 Oppose
Federated Farmers opposes the submitter’s relief sought to require reductions in takes as a method of phasing out over-allocation. It is unclear what the submitter intends: the Council should not determine what volume the resource user should apply for, nor should users be required to reduce the amount of water that their consent allows them to take. Water take volumes are necessary for that business and to reduce these without the consent holder’s agreement is inequitable.
That the submission be rejected.
378
Dairy NZ 24 Support
Federated Farmers agrees with the submitter that policy TT9.1(b)(i) needs to specify that it’s is the consent holder that decides that their consent is surrendered or not renewed, current wording is unclear that it could be the Council that decides.
That the submission be accepted.
384
Horticulture New Zealand and Others
46 Support
Federated Farmers agrees with the submitter that increases in the volume of the rate or take should be enabled by the policy, when this increase in appropriate and implements good management practice. The ability to expand production is important to the economic wellbeing of people and communities and should be available as an option where appropriate. This will achieve the maintenance or enhancement of primary production, which is identified as a primary value in the Tukituki catchment.
That the submission be accepted.
19
Federated Farmers Further Submission to the Tukituki proposal.
C6 POL TT10 Policy TT10 (high flow allocation limits)
384
Horticulture New Zealand and Others
53 Support
Federated Farmers agrees with the submitter that times of minimum flow are provided for (A Block), times for maximum flow and winter storage are provided for (C Block,) but there is no provision for times on the shoulders of these seasons (B Block). We agree with the submitter that POL TT10 needs to define a B allocation block to provide for water storage options outside the area of the Ruataniwha water storage scheme above the median flow.
That the submission be accepted.
C6 POL TT12 Policy TT12 (transfers)
34
Hawke’s Bay Fish & Game Council
128 Oppose
Federated Farmers opposes the submitter’s relief sought to place limits on when transfer of consents can occur, including conditions on water efficiency. Transfer of existing consents should be enabled because it will not increase the total amount allocated in the catchment so will have a neutral effect on water quantity, but will provide a substantial benefit to individual water users.
That the submission be rejected.
304
Environmental Defence Society Inc
68 Oppose
Federated Farmers opposes the submitter’s relief sought to require transfer of a consent to go through a resource consent process. The consented activity has already gone through such a process, and the transfer will not incur any further adverse effects on the catchment as the new consent holder will also have to comply with the consent conditions.
That the submission be rejected.
20
Federated Farmers Further Submission to the Tukituki proposal.
C6 POL TT13 Policy TT13 (enabling community irrigation schemes)
41
Irrigation New Zealand Inc
23 Support
Federated Farmers agrees with the submitter that the limiting of community irrigation schemes to those that can service over 5,000ha is restrictive and should simply provide for schemes where they improve efficient allocation and use of water regardless of size.
That the submission be accepted.
75
Wilson, Gerald and Thomas
8 Support
Federated Farmers agrees with the submitter that the limiting of community irrigation schemes to those that can service over 5,000ha is restrictive and should simply provide for schemes where they improve efficient allocation and use of water regardless of size. This is an unnecessary restriction of opportunity to have smaller schemes.
That the submission be accepted.
C6 POL TT14 Policy TT14 (consent categorisation and durations)
75
Wilson, Gerald and Thomas
9 Support
Federated Farmers agrees with the submitter that the 5 year consent duration in Policy TT14.1(c) is inequitable compared to the 35 year duration for community schemes, and does not provide confidence to consent holders.
That the submission be accepted.
38
Holden, Duncan 2 Support
Federated Farmers agrees with the submitter that the 5 year consent duration in Policy TT14.1(c) does not provide confidence to consent holders and should be increased.
That the submission be accepted.
C6 Rule TT1 Rule TT1 (production land use)
17
Dairy NZ 28 Support
Federated Farmers agrees with the submitter that existing industry systems and programmes are currently in place and that existing nutrient budgeting under these should be considered to meet requirements the rule.
That the submission be accepted.
21
Federated Farmers Further Submission to the Tukituki proposal.
22
Fonterra Co-operative Group Ltd
43 Support
Federated Farmers agrees with the submitter that the existing stock exclusion and stock crossing obligations for dairy farmers under the Supply Fonterra programme are an accepted alternative to Rule TT1(e), (f) and (g). We also agree with the submitter that te farm environment plan prepared under Supply Fonterra or the Sustainable Dairying: Water Accord is accepted as an alternative to This is an example of industry good practice being implemented as required by policies in the Plan Change.
That the submission be accepted.
11 Irrigation
New Zealand Inc 32 Support
Federated Farmers agrees with the submitter that sometimes terrain can impede stock exclusion measures, and that a Farm Environment Plan be used to demonstrate to Council if this is a reason why exclusion may not be feasible for a farm.
That the submission be accepted.
304
Environmental Defence Society Inc
79 Oppose
Federated Farmers opposes the submitter’s relief sought to change the activity status for production land use from permitted in Rule TT1 to controlled. Primary production is vital to the wellbeing of people and communities in the Tukituki catchment, and is an appropriate landuse. The permitted status reflects this importance while also placing restrictions and obligations on this landuse to achieve desired outcomes, so the submitter’s concerns about compliance are already addressed. Permitted status also does not mean that monitoring needs to be foregone.
That the submission be rejected.
22
Federated Farmers Further Submission to the Tukituki proposal.
C6 Rule TT2 Rule TT2 (production land use not complying with Rule TT1)
304
Environmental Defence Society Inc
Not numbered
Oppose
Federated Farmers opposes the submitter’s relief sought to include a prohibited activity status in Rule TT2 for activities that do not meet Rule TT1 standards and result in over-allocation. Prohibited status is extreme and inappropriate, and will not achieve sustainable management as it will negatively impact primary production and wellbeing of people and communities.
That the submission be rejected.
C6 Rule TT3 Rule TT3 (water takes)
304
Environmental Defence Society Inc
89 Oppose
Federated Farmers opposes the submitter’s relief sought to delete TT3 because the submitter considers permitted status of the filling of agricultural spray tanks is “rewarding” an activity that was a breach of the operative Plan. Federated Farmers considers that the permitted status is an appropriate recognition of an activity that is necessary for production and has minimal adverse effect.
That the submission be rejected.
384
Horticulture New Zealand and Others
65 Support
Federated Farmers agrees with the submitter that the permitted status to fill spray tanks should not be limited to tanks used for agrichemicals, but should also include fertiliser sprays as a similar activity.
That the submission be accepted.
C6 Rule TT4 Rule TT4 (water takes)
22
Fonterra Co-operative Group Ltd
46 Support
Federated Farmers agrees with the submitter that restricted discretionary status will be appropriate. Matters of restricted discretion then can be clearly identified and listed.
That the submission be accepted.
23
Federated Farmers Further Submission to the Tukituki proposal.
17
Dairy NZ 37 Support
Federated Farmers agrees with the submitter that a restricted discretionary status for some activities is appropriate, as the jump from permitted to discretionary has no intermediary for renewed consents and consents for water use on dairy farms such as for cooling or wash-down.
That the submission be accepted.
384
Horticulture New Zealand and Others
67 Support
Federated Farmers agrees with the submitter that restricted discretionary status will be appropriate. Matters of restricted discretion then can be clearly identified and listed.
That the submission be accepted.
C6 Rule TT5 Rule TT5 (water takes not complying with Rules TT3 and TT4)
304
Environmental Defence Society Inc
93 Oppose
Federated Farmers opposes the submitter’s relief sought to amend the activity status in Rule TT5 to prohibited. Prohibited status is extreme and inappropriate, and will not achieve sustainable management as it will negatively impact primary production and wellbeing of people and communities.
That the submission be rejected.
C6 Glossary New New meanings to be added to Glossary
362
Sage, Eugenie 4 Oppose
Federated Farmers opposes the submitter’s relief sought for a new definition of intensive farming to be 8 or 9 stock units per hectare. Stocking rates and stock density are not an accurate portrayal of intensive farming. High stocking rates can still maintain pastoral farming and are a matter of management methods.
That the submission be rejected.
24
Federated Farmers Further Submission to the Tukituki proposal.
C6 Schedule XXI Schedule XXI Records to be kept for nutrient budgeting
75
Wilson, Gerald and Thomas
14 Support
Federated Farmers agrees with the submitter that the requirement to provide annual accounts in (e) and invoices and receipts (f) to the Council will be a breach of business privacy and should not be insisted on.
That the submission be accepted.
25
Federated Farmers Further Submission to the Tukituki proposal.
Federated Farmers is a not-for-profit primary sector policy and advocacy organisation that represents the majority of farming businesses in New Zealand. Federated Farmers has a long and proud history of representing the interests of New Zealand’s farmers. The Federation aims to add value to its members’ farming businesses. Our key strategic outcomes include the need for New Zealand to provide an economic and social environment within which:
Our members may operate their business in a fair and flexible commercial environment;
Our members’ families and their staff have access to services essential to the needs of the rural community; and
Our members adopt responsible management and environmental practices.
This submission is representative of member views and reflect the fact that resource management and government decisions impact on our member’s daily lives as farmers and members of local communities.
Federated Farmers thanks the Environmental Protection Authority for considering our further submission to Tukituki proposal.