WelcomeAlthough we understand everyone is flat out at this busy time of year, we thought it was important to share a quick update on the Tukituki Plan Change for your information. There is still uncertainty in some areas as to what farmers need to do, which we appreciate is very frustrating for all involved. It certainly is for us when we are trying to give advice in an ever-changing area. Therefore, in some cases we are working with clients to complete what we can at present, but not submitting to HBRC until we have more information and can adjust the work accordingly. Although this can drag the process out, it is helping to give clients a better understanding of how the rules may affect their business in the future and look at their options. Updating your FEMP All landowners in the catchment need to review and resubmit their Farm Environment Management Plans (FEMPs) to HBRC by 31 May 2021. In some cases, this is not a time-consuming exercise, but in others it can take some effort, especially if the FEMP is older. The work we have done to date has involved:
Please contact us to book this in at a time that suits to avoid the rush in early 2021. If you historically dealt with Courtney and would like to do so again, then please be aware she is going on maternity leave from December. Resource Consents Following the placeholder extensions granted to those in the Tukituki due to the drought and Covid-19, HBRC have recently announced that the new deadline for lodgement of full resource consent applications has now been set for 26 February 2021. Only a small number were submitted prior to the original May 31 2020 cut off, however we were part of that process for some of our farmers so understand what is required. A full application will require the following:
For more complex farms it is a significant amount of work, so we advise starting now by updating your FEMP and Nutrient Budget at the very least. Remember we also have planning expertise to help with the actual resource consent if you do not want to do it yourself. On Farm Nitrogen allowances The impact of version changes in Overseer from when the Plan Change was written and limits were set, has made it difficult for some farms to meet their allowance when using more recent versions of Overseer. HBRC attempted to address this problem by asking Massey University to develop updated allowances and having Table 5.9.1D recalibrated. This potential change was put through to the Minister for the Environment David Parker via a “fast-track” procedure. This was declined. HBRC have decided to not pursue this exercise any further but to make provisions in the Draft Long Term plan 2021-2031 to commence the review of nitrogen management in Year 1 2021-22. They have however communicated that they may take into consideration the effect of these changes in the immediate consenting process. So, the status quo remains in place for the short term. If you previously met your allowance it may have limited effect. However, ongoing changes to Overseer may have impacted your N loss even if your farm system has not changed significantly. Although we aware that many historically higher leaching farms have done great work in reducing their losses in the past few years, for some due to the impact of soil type, climate and farm system, making major reductions to meet the table are significant challenges. We will help as best we can but addressing N loss is not unique to the Tukituki so also take note of other farmers or advice from industry bodies to try to find the best long-term solution. DIN Sub-catchments All farms in sub-catchments exceeding their instream Nitrogen limits are required to get a Resource Consent by 26 February 2021. Currently the sub-catchments exceeding their DIN limit are the Kahahakuri and Mangaonuku but no longer the Papanui. The Tukipo, Maharakeke, Porongahau and Upper Tukituki Corridor are expected to exceed soon too so keep a look out of HBRC comms re catchment meetings and your requirements. Audits We have had a number of enquiries in regard to a letter sent by HBRC in July headed “PRODUCTION LAND USE PERMITTED ACTIVITY NOTIFICATION” and what it means for those who received it. If you received one it means you are currently in a good situation, have met all your requirements to date, and are not required to apply for a resource consent. However, it is a reminder to update your FEP and that it may be audited in future. The audit involves a check on your FEMP (so more a check on our work) and a check on how you may be going in relation to your outlined actions or ability to meet the various rules such as stock exclusion. We understand that it is more likely you will be audited if you are a larger farmer and are close to your N leaching allowances. Only one audit has been carried out to date and feedback is that it was a good learning opportunity for both farmer and HBRC staff as to ongoing actions. |
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Nutrient Budgets These now need to be completed in OverseerFM, a cloud-based system which the landowner controls. Historically you had limited access to the data we worked on but now it can all be shared. There is however some time involved in setting up the new account and a fee ($360 + GST for 12 months for each farm account) which must be paid to Overseer Ltd before results can be calculated and published to HBRC. See here for how to do it. FEMPs and any consent applications must be accompanied by an up to date nutrient budget which represents the current farming system. 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. For those exceeding N allowances either on farm or in their sub-catchment, 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. New National Rules In addition to the Tukituki Plan Change Rules, all farmers in New Zealand are now affected by the Government’s recent National Environmental Standards for Freshwater and the rules which make it up. If they are “tougher” than existing catchment rules, then they will come into force. Click here for more details but everyone is now affected by new rules around issues such as stock exclusion, forage cropping, intensification and wetland protection. Resource consents will be an increasingly common requirement for historically regular practices so make sure you get advice as to what you need to do to avoid stepping outside of these rules. We can help, once we understand them all ourselves! We understand the tidal wave of regulations is daunting. However, in the time I get to spend on farm, I never cease to be impressed by the effort’s farmers are putting in to farm in a sustainable manner and the pride they have in doing so. So along with looking after families and staff, feeding stock, and paying the mortgage, keep on doing what you are doing to reduce your environmental impact. Hopefully we can help give you some further advice and make sure all the regulatory boxes are ticked. Want to find out more? Yours sincerely, Principal Consultant-Environmental |