Healthy Rivers plan change called unfair and unworkable
A Waikato environmental leader has slammed the Healthy Rivers Plan for Change as unfair and with an unworkable 80-year time frame.
The plan change was flawed because of its reliance on the nutrient budgeting tool Overseer and it would never achieve its aim of improving the water quality of the Waipa and Waikato Rivers, Save Lake Karapiro president Angus Robson said.
Submissions close on March 8.
Overseer is used in the plan change as a tool for farmers with properties greater than 20 hectares to calculate their nitrogen (N) reference point, based on the N leached in the 2014-15 or 2015-16 seasons.
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Robson said Overseer would never do the job regulators wanted it to do because the actual data and the Overseer modelled data never matched up, he said.
"People love it because they know it doesn't work and they know they can never be held to it."
As a result, he predicted land users would use Overseer to "game" (cheat) their way to reach the plan's 10 per cent improvement goal for the first 10 years.
Overseer should be dumped from the plan change until it worked properly and be replaced with guidelines for farming practices and studying the intensification of all land users. It was obvious that sediment, nitrogen and pathogens were entering rivers and causing pollution, he said.
"All you have to do is an intensification exercise on each farm and say 'how intense are you?' What are your stock numbers divided by your area and what is your purchase of fertiliser?
"It's not like it's a big mystery. It's all known."
That did not mean all farmers should switch to a super-low input system because there were plenty of examples of medium to high intensity farmers maintaining a low environmental footprint.
Robson said the plan change's 80 year time frame was too long and the dairy industry knew it could immediately achieve the 10 per cent gain aimed for in the first 10 years by gaming Overseer.
"You can claim you have gained 10 per cent [improvement] by how you work Overseer, but it might not be a real gain even if it shows up that way.
"Dairy [farmers], who are the main polluters have quite a smug look on their faces when they talk about 10 per cent in 10 years because for them, they already have it in the bank, so technically they don't have to do anything and keep going the way they are."
However, a report commissioned by Federated Farmers released in November showed that the costings of the plan change on 11 Fonterra-supplied farms ranged from $5000-$111,000, although some of them related to effluent management upgrades which was covered by existing regulations.
Robson was not surprised at the anger the plan change had generated among drystock farmers and backed their claims that its proposal for a nitrogen reference point was unfair.
It set a level for existing polluters and penalised land users who had worked to improve their environmental record or who had a light environmental footprint.
Farmers who had expanded and intensified their business would receive a larger N allocation than those who had worked to reduce their environmental record.
"What we have got is an utterly perverse and unfair system here based on the biggest polluters getting the most allowance."
Financially penalising the greatest polluters and supporting low polluting land users was a better approach and would result in behavioural change.
However, this plan change was legally required under the National Policy Statement for Freshwater, which had objectives around water allocation that were flawed and resulted in land users fighting each other for the largest share possible, he said.
"It's fundamentally wrong in how it goes about it."
He also questioned whether the council could implement, monitor and enforce the plan change.
"The time frame, the inability to enforce, the non-use of proper data - it's all enabling the can to be kicked down the road."