Stand-up and be counted on fresh water

Stand-up and be counted on fresh water

Tuesday, October 15, 2019

Stand-up and be counted on fresh water

Deer Industry NZ and the NZ Deer Farmers Association strongly encourage farmers who are concerned about aspects of the government’s proposed fresh water reforms to make a submission.

DINZ chief executive Innes Moffat says he knows it’s a very busy time of the year for deer farmers, but submissions written in a submitter’s own words can be influential.

“You don’t have to comment on all aspects of the proposals, just those that are of concern to you. Remember that clean water is something we all support. How that is to be achieved is the issue. For farmers, the changes need to be practical, cost-effective, result in better water quality and not penalise those who are doing the right thing.”

NZDFA chair John Somerville says the proposals undermine regional council plans and are unduly prescriptive. Each farm and each region has different water quality issues that need to be addressed regionally, not by applying blanket rules across the country.

“Areas of concern include an undue emphasis on resource consents and the fencing of waterways. Deer fencing is expensive and on many extensive farms there are targeted actions farmers can take that will markedly improve water quality at much less cost than fencing,” he says.

“I urge all deer farmers to thoroughly read the proposal and submit on how the proposed rules would actually effect them. Explain how proactive you have been, what you have achieved and what this has involved in terms of time and money.”  

DINZ environmental stewardship manager Lindsay Fung says the Beef + Lamb New Zealand (B+LNZ) website has a good summary of issues of concerns and a template for submissions:

DINZ shares B+LNZ’s concerns and supports the position as stated in the template, he says.

There are three areas that DINZ considers deer farming to be quite distinct from sheep and beef farming that are useful to highlight:

  • Winter grazing management practices (deer are typically not confined to a narrow feeding break so the risk of mud and pugging is less than for heavier cattle or dairy cow stock).
  • Excluding stock from wetlands in hill and high country fawning blocks (please use “fawning” as this removes doubt about species) will be very costly and impractical.  These blocks are not used for most of the year and when in use they are stocked at low rates to allow hinds to spread out.
  • The use of wintering barns for deer (particularly mixed aged stags) has a very low risk to the environment.  They are quite different from beef feedlots or other stock holding areas but could be captured under the current wording for duration of housing or requirements for base permeability standards.  Explain how different they are (especially with regards to bedding capturing all the effluent and dung and there being no risk of leachate loss). Similarly self-feeding silage pits may captured by the proposed regulations depending on the definition of a “stockholding area”.

“If you won’t want to comment on all of the questions in the discussion document or issues described in the template, we still encourage shorter submissions that focus in on one or two areas of concern.  Examples could be winter grazing management or stock exclusion from hill or high country wetlands,” Fung says.

The NZDFA is now preparing its submission and DINZ will release its draft positions on the proposals by 21 October. Submissions close on Thursday 31 October.

The submission could be in the form of a letter or a shortened version of the B+LNZ template, e.g.:

    To view this form as a printable PDF, please click here >>

      Personal Information

      • Name:
      • Address & Region:
      • Phone:
      • Email:

      Background about your farm:
      (Keep this section brief. It is not required, but does help set the scene, some suggestions are listed)

      • Where you are farming (catchment) and type of country you are farming (flat, rolling, hill);
      • What type of farm;
      • Stock class and ratio and whether or not this changes overtime;
      • How long has the property been in your family and how long have you been farming the property;
      • Property under development – future aspirations and motivations?
      • Describe your environmental management? Are you actively planting riparian strips or allowing native regeneration, do you have QEII covenants, plantation forestry, manuka, wetlands or lakes? Have you already fenced off waterways and if so what was the cost of doing so?
      • Type of fertiliser use and application, and nutrient leaching rate if it is known.

      Impacts and implementation:
      (This section is an ideal opportunity for you to detail what the specific impact of these proposals could be on your farm. Do you have significant stretches of waterways that would require fencing? How much would this cost? How will grandparenting provisions that lock in discharges and land use limit your ability to adapt your farm system to pay for any required environmental mitigations? What will be the impact on your community if over two thirds of deer, sheep and beef farms were converted into forestry?)

      I support or oppose: (insert proposal e.g. stock exclusion of wetlands)

      My submission is that:

      (Give reasons for your submission and outline your concerns or those areas you agree with. Keep it clear, concise, and constructive.)

      The decision I would like the Government to make is:

      (Clearly outline the changes you would like to see. Bullet points are a good way to go. Make sure you say if you want something to be deleted, i.e. a standard, and clearly set out if you think it should be replaced with something else.)

      For further information please contact Lindsay Fung, Environmental Stewardship Manager ( or 04 471 6115).