Farming leaders say jobs will be lost and investment and economic activity will drop if downscaling farming operations is the only viable alternative to meeting tough, new environmental rules. Joanna Cuttance reports.

The Government has set the framework for “Action for healthy waterways” freshwater reforms with some amendments on the initial proposals. Industry groups agreed the amendments are an improvement but felt the blanket regulation would still cause concern for farmers. The impact of the changes would differ by region and by catchment, with little allowance given for regional differences. The framework and policies have been decided by Cabinet and cannot be changed, with the final detailed wording of the document to be released soon.

Mid Canterbury arable and sheep farmer David Clark was concerned about achieving the nitrate levels referred to in the document. Initially the proposed bottom line for dissolved inorganic nitrogen (DIN) was at 1ml/l. Clark said this was a bad idea and bad policy, and rightfully it was dropped and replaced with an increase to the existing bottom line for nitrogen toxicity in fresh water from 80% to 95%.

Nitrate toxicity is the nitrate concentration at which some fish species may be negatively affected. The higher the number, the smaller number of species it may have any effect on.

For example, at 95%, there may be 5% of fish negatively affected, at a level of 80% there may be 20% affected.

Clark said this new level effectively equated to a DIN of 2.4ml/l. Achieving this would be very difficult in the Mid-Canterbury region when water entering your farm was already above that point.

He explained that on the western side of the catchment area there was a spring water stream coming out of DOC land with a DIN of 3.2ml/l.

“Farmers are going to be hard pressed to have it at 2.4 through their own properties.”

He believed a much more catchment-controlled approach was needed. The Canterbury Land and Water Regional Plan had a total nitrate target of 6.9ml /l in groundwater, which was a difficult but achievable target and Mid Canterbury farmers were pleased to be able to work towards it.

“Now what is in front of us is not achievable and trying to reach this new target would come at a very significant cost to the community”.

He said there would be losses of jobs, investment, and economic activity as farmers saw downscaling as their only viable alternative rather than wanting to, or being able to, invest in changing farm systems.

Under the new regulations in-stream nitrogen levels in lowland streams are too high and farmers will have to continue to reduce nitrogen loss over coming decades. Councils would be able to tailor regulations to each catchment but they must remain within the minimum standard regulations set by the Government.


Otago and Southland farmers are trying to determine how winter grazing methods can meet the “permitted activity” criteria and the extended standards. Under the new regulations, grazing stock on forage crops in winter would be a permitted activity if:

  • the paddock was less than 10 degrees slope
  • the area planted was either less than 50ha or 10% of the farm (whichever was larger)
  • the crop was set back more than five metres from a waterway. Winter grazing
  • also had to meet other standards: pugging was to be no deeper than 20cm and cover less than 50% of the paddock, and bare ground in paddocks subject to winter grazing was to be re-sown as soon as practicable within one month of the end of grazing.
  • Waikoikoi sheep farmer Bill McCall submitted his concerns that the proposed winter grazing rules were unworkable in west Otago where he farmed. Growing and feeding crops was an essential practice to get stock through winter, he said. Since the decisions on the reforms had been released he had been getting on and doing what he could but he felt sceptical. His major concern was the impossibility of having bare ground for only four weeks. McCall explained they tended to finish feeding crops at the end of August. To be able to get back onto the paddock in a minimum of six weeks would be pretty good for them, he said. Although even if they did manage to get a tractor on it was unlikely seed would strike because of the cool soil temperature.
  • Invercargill-based agribusiness consultant Deane Carson said there was a level of confusion about what was required for this winter. There was a need for information telling farmers what to do. He believed the Government needed to provide an in-depth education plan to help farmers understand the requirements. When people were looking for ways around a regulation it showed something was not well-written, he said.
  • The requirements are from winter 2021, and if farmers wanted to plant above the thresholds or exceed the practice standards they would need to get resource consents. At this point it was not clear what consents would require or what the cost would be.


  • Southland farmer Dean Rabbidge has been future proofing the farm he owns with wife Sarah at Glenham, near Wyndham, for the past three years. Rabbidge said he had felt comfortable with the original proposal of a 5m setback for stock exclusion fences and many of the fences he had put up met this threshold because this was what worked best on his rolling country.
  • The minimum setbacks for new fences had been set at 3m, though some councils have indicated they would have a 5m setback. The deadlines to have them completed have been pushed out by at least two years.
  • Rabbidge’s biggest concern had been around the timeframes, and the extension along with sheep excluded had given a bit more breathing space. He felt farmers were heading in the right direction but there was a perception by some in society that all the changes would happen overnight and be effective immediately. That was not possible because it involved changing decades of what were educated farming practices of their time, he said. He felt the results from change now would take a long time to show. Rabbidge put in a new water supply last year on part of the farm, completed fencing for total stock exclusion for his cattle, and would continue with this work to include total exclusion for his sheep. He said the financial cost was huge.
  • Federated Farmers still believed that existing national regulation allowing for regional differences with tailored regional rules was far preferable to blanket regulation.
  • Principal policy advisor David Cooper said that, with the new framework decided, they were now providing feedback to government agencies. This was around where the proposed rules could best deliver on the policies and whether they were practical and pragmatic. In the longer term they would focus on working with regional councils on how these new requirements would be implemented.
  • Amendments causing most concern
  • New bottom lines for DIN and DRP removed. Replaced with tightening measures for in-stream nitrate toxicity.
  • Minimum for new stock exclusion fences set at 3m, a reduction from 5m. Timeframes pushed out by at least 2years.
  • Areas with minor amendments
  • Stock holding pads to meet a criteria otherwise consent required from winter 2021. Regulations now do not apply to; wintering barns, sacrifice paddocks, areas for animal husbandry and calf raising.
  • All feedlots need a resource consent from mid-2020 and must meet stock-holding standards.
  • Those with existing resource consents to take more than 5l/s of water (irrigation) must measure and report electronically. Compliance deadlines vary.
  • All farms must have a farm plan with a freshwater module, staggered over a timeframe.
  • Small wording change to the Wetlands policy to allow extra flexibility. Impact will depend on consenting requirements, which are yet to be worked through.
  • From mid-2020 until end of 2024 need a consent for specific forms of intensification. Requirements have changed from those proposed. Impact would depend on the nature of the consent.
  • Areas with less change
  • Grazing on winter forage crops.
  • Te Mana o te Wai – detail still to be settled, inference is that this would diminish the weighting given to economic use when freshwater policies are being implemented.
  • A national synthetic nitrogen fertiliser cap of 190kg/N/ha/year will apply to all pastoral sectors. Dairy farmers are required to report annually to councils the weight of nitrogen applied per hectare. Cap does not apply to arable and horticultural farming.
  • Further information can be found on the Ministry for the Environment website, Action for healthy waterways – information for sheep, beef and deer farmers.