Chairman Horrell responds to Federated Farmers statement
Statement from Federated Farmers sent to their members on 14 January 2022
Federated Farmers' position on Environment Southland limits and targets.
To all Southland members,
Over the holiday period, Environment Southland publicised its draft limits and targets for nitrogen, phosphorus, sediment, and E coli load reductions in Southland’s rivers, lakes and estuaries. These draft limits and targets are based off science that has never been subject to a formal approval, consultation, or plan change process, and which lack consideration of economic and community factors (which is a requirement of both the RMA and National Policy Statement for Freshwater Management).
It is deeply concerning that Environment Southland chose to publicise the limits and targets over the holiday period, and without detailed explanation of their context. Environment Southland did this despite months of pressure to release the limits and targets and explain their intent. To date, this has not happened.
Beyond the timing, Federated Farmers has real concerns about how the targets have been arrived at, in particular the suggestion that the "Share Your Wai" campaign a couple of years ago was the "community consultation" that led to the setting of these extreme targets.
Feds is also deeply concerned about the reasonability of these targets. This is an aspiration to return our waterways to pre-settlement quality without considering the effect it could have on the major flood control modifications that were implemented for the good of the entire community.
This risks undermining existing efforts undertaken by farmers to improve water quality, as people may disengage, and reduces the confidence that other businesses and financiers require to invest and participate in the rural sector.
Feds notes that the E coli target in particular is based off a false starting point – much of the E coli in Southland is of avian origin, would exist naturally, and is of a reduced health risk. Environment Southland’s own published reports show this, but their draft limits and targets fail to take it into account.
Other targets are based on scenarios and models that do not correlate to the risks they seek to address, and the presentation of load reductions as gross percentage numbers risks misleading farmers about where the burden of load reductions falls.
Environment Southland are now saying that the targets are not final. Your provincial executive intends to hold them to that.
Genuine community consultation is required to ensure that values are determined in consideration of costs. While there are costs and benefits that are not financial, the old adage, ‘you can’t be green if you’re in the red’, applies as strongly to the province as it does to individual businesses.
For more information, please contact:
Chris Dillon
Provincial President
0274 592 902
Peter Wilson
Senior Policy Advisor
Federated Farmers
021 151 3486