Horizons Regional Council is consulting on targets for rivers and streams that will set the direction for future changes to the One Plan. The council’s modelling suggests some significant contaminant reductions will be required. The council is asking for feedback on their targets, visions and values.
What DairyNZ is doing
DairyNZ supports the need to improve water quality outcomes across the Horizons region, where current water quality state does not meet community expectations.
However, DairyNZ has significant concerns with the approach Horizons is using to estimate the reductions required to meet targets. We will outline this and other feedback in our formal feedback to Horizons and continue to communicate with the council on key issues. We will keep you informed of our progress.
Key concerns and what this means for you
The key concerns DairyNZ has on the information provided by Horizons are:
- That these reductions pose huge costs to farming in the Horizons region, which will have significant flow-on effects not just for individual farms but also the communities surrounding them and the broader regional economy.
- That the council should consider long-term timeframes (i.e., multi-generational) to provide a clear direction while enabling time to transition. Steps towards these long-term timeframes (every 10 years) will help make reductions reasonable but ambitious. Timeframes around 80 to 100 years allow the transition to play out over multiple generations.
- The suite of modelled actions gives an indication of scale of change the model requires but aren’t applicable to all farms. For this reason, the actions shouldn’t be incorporated into rules or activity controls in future stages of the policy review process. Instead, a risk-based approach to choosing actions on farm is most appropriate, for example through farm planning.
- That the model outputs used to estimate the reductions needed have not been validated against measured data. For example, measured periphyton biomass in many water management subzones (WMSZ) is currently meeting the proposed target attribute state, and yet the ‘model’ is indicating large reductions are required.
- That the Natural Form and Character value has been applied to all waterbodies which requires a minimum B band target attribute state for periphyton. We are concerned that this is more stringent than the minimum default grade for ecosystem health that was proposed in the Cawthron report. This value would be better directed towards waterbodies with high value form or character that have been identified by the community. We also don’t think that periphyton is a relevant attribute for waterbodies identified for their geomorphological form.
There are two key processes playing out within this round of engagement. One is the setting of targets states for attributes (i.e., whether the target is for A, B or C band quality) which are to provide for the community’s vision for the region’s waterways. DairyNZ has concerns about how these bands have been chosen, and how they relate to the vision of the community and the band recommendations made in the Cawthron report that Horizons refer to.
The second process is the modelling and thresholds applied in the models. DairyNZ is concerned that the models have not been validated using measured data collect by Horizons and that the reductions are more than what is required to meet the proposed target attribute state. It is important that the modelling is accurate because the next step the council must consider is setting limits on resource use and rules around activity controls to meet the reductions. If these rules and resource limits are set to achieve large reductions that are inaccurate, there could be considerable costs implications for individuals and communities.
What do you need to do now?
Provide your feedback to Horizons through their survey tool before 28 February - Oranga Wai | Water quality targets
You can mention your thoughts on the targets, modelling, cost and impacts, or how the targets reflect your community values.
What are the next steps?
DairyNZ will continue to communicate our key points to Horizons, as well as develop economic analysis to support our positions. We will keep you informed of our progress.
Horizons next steps
- Pre-notification steps - mid-2024
- Notification of Freshwater Plan Change - End of 2024
- Submissions, hearing and decision - within 2025
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