Takitakitoa wetland near Henley. Photo supplied.
Proposed rural water regulation changes are too
"aggressive", "unachievable", "inflexible" and could end
farming, forestry and horticulture as the region knows it, some
of its opposers say.
Those in opposition include big business, farmers, local
government and even Otago's conservation board, with many
indicating the economic impact of the changes would be
"detrimental" to the region.
About 330 submissions have been made to proposed Plan Change
6A and council analysis show 39 indicated their general
support and 71 voiced their general opposition, while others
expressed views only on particular parts of the plan.
The regional council says there is "universal" support for
the principal of managing good water quality and "almost
universal" support for the management approach of setting
permitted discharge standards.
For many the support was for the approach, but concerns about
how it could be practically implemented were raised in their
The Clutha Agricultural Development Board said many of the
changes would seriously affect livelihoods, developments and
the "very progress of the Otago province".
"If farmers are required to de-stock or to retire a large
percentage of land to increase fencing and wetland plantings,
then reductions in profitability, reductions in land values
and reductions in economic turnover in the province is
The Cow Farm, of Ettrick, is in one of the plan's sensitive
zones which had a proposed nitrogen loading limit of 10kg per
ha, and owner Grant Scott said reducing its stocking rate to
meet the requirement would make the farm unviable.
"I believe no economic livestock farming operation could
comply with the limit and it is unlikely that any arable
operation would fare any better."
The "shortcomings" of the plan change were "significant,
widespread" and would potentially undermine the rural sector
and the "one size fits all" approach took no account of
naturally variable environments.
"The targets appear arbitrary, onerous, inflexible and
Otago Conservation Board chairwoman Abby Smith believed the
changes were overly complex for landowners and would only
lead to a deterioration in water quality.
By not using more extensive consenting requirements, the
process relied on "individual landowner to maintain accurate
records and undertake appropriate monitoring to ensure
compliance", she said.
Queenstown Lakes District Council had similar concerns that
the changes could lead to a deterioration of water quality
and called for assurance that significant resources would be
allocated to ensure effective regular monitoring.
University of Otago Zoology Department's submission also
expressed concerns about how well the plan could be expected
to work in practice.
"The expectation that farmers should regularly collect
discharge samples from runoff, dams and irrigation systems on
their properties seems unrealistic without frequent checks
from council compliance staff and resulting enforcement
action under the RMA."
It would require considerable staff time and money and could
create a climate of resentment among farmers.
Fonterra was concerned that practical options for farmers to
do monitoring did not exist, while Silver Fern Farms was
worried the rule changes would affect its discharge consents
and lead to the closure of its Finegand plant.
New Zealand Institute of Forest Otago-Southland section
chairman Angus McPherson said the section had concerns that
without substantial modification the plan would require the
forestry industry to comply with standards that were
"unrealistic and not achievable even in undeveloped, pristine
Waitaki Irrigation Company believed some of the proposed
rules seemed unachievable, overly open to subjective
interpretation or "simply confusing".
Company member Chris Dennison, in his own submission, said
the council should recognise the Waitaki plains as a special
designated area. With border dyke irrigation being dominant,
it would not be possible to meet the 30kg per ha limit.
"The changes in stock carrying capacity would need to be
reduced in some circumstances by almost 40% to achieve this
target, which would render these uneconomic."
Substantial capital investment and significant time would be
need to convert properties to spray irrigation, he said.
The technology was not configured to cope with arable
properties covered by the scheme, he said.
The submissions had now been circulated to all submitters for
further consideration. They had until June 18 to make a
further submission before a hearing was held.
Proposed plan change 6a (rural water
• Sets targets for good water quality in Otago.
• Aims to meet the requirements of the national policy
statement for freshwater management.
• Removes permission for rivers to be used to dilute
• New controls prohibiting discharges that adversely affect
• Discharges that meet specified limits will be
• Limited option for consents which do not meet the
• Provisions to control bed disturbance and make it easier to
construct single span bridges, regarding river and lake beds
and regional significant wetlands.
• Provisions to stop the use of rivers as regular stock