In many cases the costs of obtaining consent for a normal farming activity under the proposed Healthy Rivers Plan Change One (PC1) will outweigh the cost of undertaking the activity - in some cases by several multiples.

That's just one of the concerns Federated Farmers underlined in our submission on the Waikato Regional Council's proposed new rules.

After listening to the district's farmers at a multitude of feedback sessions - sometimes attending two meetings in one night - Federated Farmers put together a comprehensive submission.

It's likely that farmers will face substantial compliance costs when the provisions come into effect. It will stifle improvements and investment, and ultimately mean an under-performing rural economy, fewer jobs and lower spending power.


We don't believe the proposals tackle the environmental issues in an efficient or effective way. At its most fundamental level they show a total lack of acknowledgment of the significant economic impacts the rules will have on farmers and their communities.

As Federated Farmers represents farmers from all pastoral sectors - arable, dairy, dry stock, etc - wants a solution that will work for all sectors, the community and importantly also for the environment.

There is evidence that the nitrogen myopia seen in these rules does not reflect the actual issues in many of the sub catchments and Federated Farmers believes there is a much better way.

Good management practice needs to be embedded into all farming and other sectors when they affect the environment.

As basic monitoring of water quality is lacking in some of the sub catchments the region needs to do much more detailed work around the difference issues in the sub catchments.

More detailed proposals can be developed and implemented at a later stage through a sub-catchment, freshwater management unit-based assessment. Requirements proposed for the fencing off of water bodies are inequitable, repressive and unnecessary.

They are too blunt and will not satisfactorily address the water quality issues the region is facing and are extremely costly.

The better path is to adopt the fencing requirements measures in the government's recently announced Clean Water Package 2017 as an interim measure, with more detailed proposals developed later if needed.

We're very concerned at the extent to which the proposal locks rural production land users into present land uses.

Changes happen all the time in agriculture and land users should be able to modify their production systems within their present general land within reason as long as it is not fundamental affecting a subcatchment's water quality.

In case anyone feels Federated Farmers is advancing some sort of narrow interest view, the vast majority of farmers and the wider rural community back the thrust of our submission.

I've lost count of the number of meetings I and fellow Feds team members have talked through these issues. We noted carefully the kinds of questions and comments that cropped up. These were relayed to our policy experts, and informed our stance.

Before the regional council deadline, we had another round of meetings to road-test our submission and got further feedback.

I'd like to thank all of the people who made phone calls, emailed or took the chance face-to-face to give feedback to me. It made a real difference and showed our final position on the issues was sound.

Please read our submission and case studies on our website and tell us if we have got it right before hearings with commissioners start later this year.

We've issued dozens of press statements and member advisories, I've been interviewed at least 30 times by various media outlets. But if you're still not sure what Feds is doing in this space, please get on our website or attend our AGM on Thursday May 11 at the airport conference centre to engage with us.