WelcomeWe know that you have plenty to deal with at present and for many it is tough going. Where I live in Ashley Clinton, a traditionally summer safe area, the recent rain greened things up but feed is short, and many are continuing to have to carefully manage stock water. I certainly haven’t had any issues keeping cattle out of waterways, because they haven’t been flowing for over six months! Given the recent communications from HBRC, we thought it was important to share a quick update on the Tukituki Plan Change for your information. HBRC Tukituki Catchment Plan (PC6) Drought and COVID-19 Response Key points from HBRC’s communications are
Who needs a Resource Consent? HBRC will require you to apply for a Resource Consent if the following applies:
Farm Nitrogen loss over LUC based allowance Most people should be aware if they are in this situation. It’s great to see the efforts customers have made to farm management to reduce their losses. HBRC are investigating the impact of version changes in Overseer from when the limits were set, as this makes it difficult for some farms to meet their allowance when using the current version. This may result in a technical plan change but is unlikely to happen in the short term. We can look at how this may potentially affect you based on some work completed by Massey University for the Horizons Regional Council. Generally, it is good news. However, at this stage the existing rules remain. Stock Exclusion Prior to the lockdown you will have seen the signs in CHB outlining that you will need to get a Resource Consent if you cannot meet the Stock Exclusion Rules. Unfortunately given their complexity, there is still some confusion as to exactly what is required. For clarification see HBRC’s guidance information but a few key points are below.
Simple eh?! It should be outlined in your FEMP as to your requirements but call us with any queries. DIN Sub-catchments Currently the sub-catchments exceeding their DIN limit are the Kahahakuri, Mangaonuku and Papanui. The Tukipo, Maharakeke, Porongahau and Upper Tukituki Corridor are expected to exceed soon too but at this stage do not need consents. Updating your FEMP Farm Environment Management Plans (FEMPs) and associated nutrient budgets are key parts of the consent applications. The requirements for a compliant Tukituki FEMP are already comprehensive. However, if it is to be used as part of a Resource Consent application, some additional updates may be required from the initial work done. We have been doing this already for a number of customers. The work we have done to date has involved:
In some cases, this is not a time-consuming exercise, but in others it can take some time. It has been great to see the changes people have made since their initial FEMPs to both meet rules and take voluntary actions. |
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Nutrient Budgets There is however some time involved in setting up the new account and a fee ($200+GST) which must be paid to Overseer Ltd before results can be calculated and published to HBRC. See here for how to do it. A consent application must be accompanied by an up to date nutrient budget which represents the current farming system. In a few situations we have seen that farmers may now not need to apply for a consent (or need a less complex consent) due to a decrease in their N-loss from historical work. HBRC have also asked that those unable to apply for a consent by 31 May 2020 provide any Nutrient Budget information to them as well. In some cases where farming systems are relatively stable, historical work can form the basis of the updated OverseerFM nutrient budget, as a good representative of a four-year rolling average. Others are having to do considerable work to update this information, if the farm system has changed or there is complexity due to the number of crops, blocks or livestock classes. Nutrient budgets may represent a rolling average, a year end (for a set 12-month period) or in some cases a forecast of what the farm is going to look like once a system is developed. It is important that you understand the different types, and that this is communicated to HBRC as these will be audited in future. For those exceeding N allowances, the nutrient budget needs to help the FEMP provider understand some actions in the future which will reduce N-loss. Hopefully these will also have some financial advantages by improving efficiency. However, in some cases these will also affect your farm productivity and profitability, so please ensure you understand these before committing to any actions. How can we help If you want to continue with updating your FEMP or submitting your Resource Consent application by the due date, please get in touch and we will see what can be done given the current situation. If you want us to provide the data to HBRC to delay your Resource Consent Application, we can take that off your hands too. There will be a flat rate of $150 + GST charged to your Ravensdown account for this, but it will be taken off the cost of any future consenting work. Want to find out more? Please look after yourselves, your families and your mates, and take advantage of the advice and support available to help get through these challenging times. Yours sincerely, Principal Consultant-Environmental |