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If some of the proposed water-quality nutrient standards are applied literally, he doubts any drain discharge from an Otago farm will comply, Dairy NZ consultant Dr Michael Freeman says.
"That will mean literally thousands of resource applications [will be needed]," he said at the 18th day of the 6A water plan hearing in Dunedin yesterday.
The proposed regulations would impose restrictions on landowners which did not appear to be justifiable on an effects basis, he said.
There was no distinction between discharges going in to a "tiny stream" or a "large river" so the standards applied to both, irrespective of adverse effects the discharge might or might not have.
The proposed plan did not provide regulatory certainty to the Otago community, with "inappropriate implicit and explicit discretion" reserved for the Otago Regional Council with no clear guidance on how the discretion would be exercised, he said.
"[It] does not provide the Otago community with an assurance that the implementation of PPC6A would achieve 'good-quality water' in Otago's water bodies by the target dates."
Fonterra co-operative Group former sustainable dairying policy manager Sean Newland said Fonterra identified two dairy farmer suppliers who would be significantly impacted by the proposed 20kg/ha nitrogen loss limit within the Ettrick basin aquifer zone.
"Our assessment is that it will be extremely challenging, if not impossible, for these farmers to continue to operate as dairy farms, even with what could be expected to be reasonable changes in farm system to meet the proposed N (nitrogen) loss limit. This concern is increased if Overseer 6 is to be used to model N loss."
Fonterra believed Overseer 6 would result in a significant increase in land users required to seek consent as modelling had shown nitrogen loss numbers increased significantly.
Farmers needed more certainty around the costs and requirements of sampling nutrients. The costs of sampling were "not insignificant" with "per test costs approximating the value of a single lamb or 142 litres of milk at the farm gate", he said.
Fonterra was planning from next season to require suppliers to provide its nitrogen-loss figures which would be audited and could be used to provide evidence of compliance.
Alliance Group Ltd environmental manager Francis Wise said there did not appear to have been adequate consideration given to discharges that arose from industrial and trade premises, particularly the social and economic effect, she said.
"It is also not clear what the ramifications are for activities that do not comply with the limits in the schedule, and how this will affect existing and future activities in the region."
Alliance consultant planner John Kyle said while the plan change targeted diffuse rural discharges it had a much broader effect.
There was "considerable uncertainty" in the proposals which could mean the company's discharge permit for composting leachate that might enter water was covered by the proposed plan change rules.
"The implications are more far-reaching and will adversely affect a significant number of existing activities within the Otago region."
The proposed objectives were not suitably balanced and the policies would subject resource consent applications to assessment against overly rigid water-quality standards which derived from "questionable empirical origins".
"The approach to rule drafting is fundamentally flawed and will in my opinion not be able to be implemented in an effective and efficient manner."
Panel chairman Cr Duncan Butcher adjourned the hearing until October 23.
Panel: Crs Duncan Butcher (chairman), David Shepherd and independent member Clive Geddes.
Proposal: Changes to Otago's water regulations to prevent run-off in rural areas polluting the region's waterways.
Submitters: Alliance Group Ltd environmental manager Francis Wise, consultant John Kyle; Dairy NZ consultant Dr Michael Freeman; Fonterra co-operative Group former sustainable dairying policy manager Sean Newland and resource management consultant Gerard Willis.
Quote of day: "If you have regulations they should be fair and equitable. I couldn't look our suppliers in the eye if they were more constrained by regulations" - Sean Newland, Fonterra.