OK, council, which one is it?

Tukituki farmers are unfairly finding themselves needing resource consent, despite meeting their individual on-farm nitrogen leaching limits.

This is triggered by a rule requiring every farmer in a sub-catchment to apply for a farm consent when the overly restrictive in-stream dissolved inorganic nitrogen (DIN) limit is exceeded. The Mangaonuku, Kahahakuri and Papanui sub-catchments currently have this problem.

Federated Farmers was alarmed to hear that even if all farms complied with their on-farm limits, the DIN in-stream limit would still be unachievable in the subject sub-catchments. This clearly demonstrates that the DIN limit is incompatible and not linked with the farm limits.

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Farmers will be expected to reduce their N-leaching profiles, yet for most this will mean reducing below what they are actually allowed.

In the Kahahakuri sub-catchment, 72 per cent of the farmers already comply with or are even below their farm N limits. These are farmers who already have conservative N profiles. It's akin to telling drivers it's absolutely safe to travel at 50km/hr on a stretch of road, but they're not to exceed 30km/hr.

Usually in an RMA rule regime, you need special permission via a resource consent to do more than what you are permitted to do. In this case, resource consent will be issued to make you do less than permitted!

Federated Farmers is opposed to the undermining of the permitted baseline by the consent regime.

Another on-going concern about farm consents is the rigidity of consents being incompatible with the flexibility inherent to farming. Consents based on the on-farm N rates average of the previous two years will rigidly lock in production.

Farmers will be stuck with two undesirable scenarios: consents will set up a system that lets farmers do less in bad years, but do not allow them to make up for it in good years, or constant revision by farmers and the regional council will be needed every time there is a change.

Federated Farmers hopes that the resource consent requirements will be delayed, and the unachievable DIN limit reviewed.

• Rhea Dasent is a senior policy adviser for Federated Farmers

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