Journalist and Marlborough farmer Joanna Grigg takes us through her efforts in writing a submission on the Government’s Essential Freshwater proposals.

Being the type of person just to dive in I opened the Ministry for the Environment submission page online and saw five headings which seemed straight forward enough. Of course, after more clicking, each of these had more sections embedded inside. They wanted answers to specific questions, 80 questions in fact. To get my points through to the reader, I’d best stick to them.

But getting my thoughts ordered in a tidy fashion and my points matched to answer the particular question was turning into a nightmare. It felt like I was drafting Angus cattle in the dark with a black huntaway.

So I opened the mother-source document Action for Healthy Waterways and read through the contents section. Straight away I could see Number 5 Raising the Bar on Ecosystem Health was going to have to be read, as was Number 8 Improving farm practices. Number 10 if I had time.

I recalled the sage advice of Lauren Phillips at the Beef & Lamb NZ roadshow to relate my submission back to our farm business. While considering where to start on this one (by way of random thoughts about the slope of the winter grazing paddock and how to fit in extra seed crops into a very low nitrogen cap set by grandparenting) an email arrived.

Federated Farmers had sent words of encouragement; “It’s a big ask at a busy time of year, but unfortunately, at this stage, this is the only chance to influence this regulation”.

They also urged me to spell out the good works already done on the farm as they “are not recognised in the proposals”.

So I need to think about that good work too; water testing below the break-feeding block, fencing the wetland and culling of 5000 goats in the catchment that feeds the town stream, and find a spot for that.

I also have to keep the structure simple and tell my viewpoint. Lauren put it bluntly, “the Parnell man with a Griselinia hedge, who thinks he’s environmentally knowledgeable, will certainly be putting his view across on farm practices”.

I gallantly resisted a glass of wine and went to feed the pet lambs. On return I decided my strategy was to pick the Improving Farm Practices heading on page 63 and dive in there. BINGO! As I read, I made notes in the margin as to whether I agree/disagree and why, relating it back to our 4800-hectare hill farm.

I then wrote these into short paragraphs in a Word document. It is hard to see what you have written when typing direct into the online submission so I decided against that. Plus I went to cook dinner and forgot to save it and someone closed it when they finished reading Country-Wide Sheep Special online. At this point I had that glass of wine.

I then copied some key questions they asked in the ‘Mothership’ document and tried to answer them by using my paragraphs where I could. It is still a work in progress. Here are some of my points along with those from others involved in agriculture. Hopefully it helps last-minute submitters get some ideas.

A friend emailed to say she was up all night worrying. They had just bought a farm and are relying on developing the farm and intensifying stock numbers to help pay the bills. The most practical thing she can do is write a good submission. Good luck.

Q25. Do you support the proposal to protect remaining wetlands? That’s a yes for Marlborough, particularly as there are not many left. But maybe not in the West Coast where there are many wetlands and dryland species need protecting?

It ain’t cheap: Wetland fencing and plants at Tempello cost the equivalent of $6000/hectare and has ongoing weeding costs of about $400/year. Planting labour was free thanks to Fairhall School.

Our fencing and planting enhancement project of our significant wetland this year cost $6000/ha capital spend (fencing, plants) and will be $400/ha/year to maintain. We also lose $240/ha/year of feed, as we fenced five metres from the wet zone, up to the top of the bank. I suggest fencing of wetlands should be staged over 10-12 years as that’s a big ask financially for farmers with many wetlands.

Q: Should a resource consent only be granted if the activity does not increase nitrogen, phosphorus, sediment or microbial pathogen discharges above the enterprise or property’s 2013-18 baseline (average for this period)?

No. This is grandparenting and unfair for low emitters and not related to environmental effects in a catchment.

Our low historic stocking rate of four stock units/effective hectare has considerable scope to be increased without affecting our natural capital (waterways, soils). Warming winters are giving us a lot more growth in winter and we need to control it (to maintain quality feed and reduce fire risk) by increasing stocking rates at times.

Sub-division helps control pasture covers which in turn, is key to protecting soils, but it goes hand-in-hand with lifting stocking rates at key times. Having stock numbers locked to previous nutrient losses is not the right approach. The better approach is managing stocking rate by proving effects on natural capital through an environmental plan and monitoring (soils, streams, biodiversity).

On our farm, increasing stocking rate (an extra one su/ha of trading cattle or dairy beef for three months) can hugely improve pasture quality and this actually helps our lambs grow and leave the farm faster and protects pasture covers (soils in summer) and helps manage fire risk on the hills leading to our 1400ha indigenous forest.

Fast-finishing lambs is better for preventing drench resistance, better financial returns (up to $80k in one year) and better ability to quit stock before summer drought hits. Our financial viability and our ability to manage our pastures and soils will be seriously compromised by this policy. Other low-emitting sheep/beef farms should have the opportunity to improve their efficiency by varying stock units in this way.

Q 52. For land-use change to commercial vegetable growing, do you prefer Option 1: no increase in contaminant discharges, or Option 2: farms must operate above good management practices. Option 2, as we need flexibility to grow seed crops like onion and cabbage seed when requested by our local seed company and when the price and climate is right.

We mainly grow meat/wool but this higher-value crop on less than 1% of the farm is important to our bottom line. Marlborough is a source of this seed. Some years we need to grow more area of crop (potentially 30ha) and must have the flexibility to do this without being forced to drop stock to fit within a total farm nutrient regime that is very conservative to start with. We do not apply nitrogen to hill country.

A farm environmental plan to protect streams and soils during seed production is the better approach. Our seed agent said seed production requires land to be free of disease from previous crop of like type, so this is why some years we will grow 20ha and some years none.

Q: Planned restrictions on clearing woody vegetation to pasture? This statement is not clear what height and type of vegetation this means. Every year we get regrowth of woody indigenous species (and weeds like barberry) that need clearing to just maintain our effective area. Having the need to get consents or be stopped from clearing this would have a severe impact on viability.

Q: Stock exclusion from waterways? Without grazing, exclusion zone will grow grass and woody species. These pose serious fire risks in dry conditions, creating fuel pathways to important areas of biodiversity. This is a real risk so sheep must be allowed to graze these areas.

Q6: Unintended consequences of the policies. I’m concerned about the potential impacts on our community. If there’s a change in land use, from farming to forestry in our area, farming families, their staff and their families will leave. What will happen to our school? What about our local hall? Rural delivery? It will drop business to rural suppliers (trucking firms, contractors, vets, etc) and town businesses (tractor firms, local cafes, supermarket). The impacts will be wider than our local community.

  • Beef + Lamb has developed this template for consultation on freshwater.


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