Q & A on Southland IWG Advisory Group

Following a meeting in Southland with Ministers O’Connor and Parker in September, a group was formed and asked to look at the implementation of the intensive winter grazing rules within the new National Environmental Standards for Freshwater.

Intensive winter grazing can present high risk to water quality and therefore it is important that it is well-managed and well-regulated. Group members are unanimous in their view that the current National Environment Standard for Freshwater does not deliver the required quality of regulation. To ensure effective management and to avoid risk of perverse outcomes, change is required.

The Southland Advisory Group brought together a diverse range of perspectives, values and experience. The group included several farmers, Beef + Lamb NZ, DairyNZ, Federated Farmers, Fish and Game and Environment Southland staff, who have worked together on finding practical solutions to some of the issues raised with implementing the regulations across the country.

The group recommends that government:

1. A - Where permitted activity conditions cannot be met, an alternate permitted activity pathway is provided via an intensive winter grazing module. These modules would need to be submitted to the regional council and be subject to audit process. An example template is provided (see Appendix 1) to assist with the development of these modules. OR
   B - Defer the application of the Regulations 26 (4) until such time as Freshwater Farm Plans are in place.
2. Amend condition 26 (4) (b) intensive winter grazing must not be conducted on slopes greater than 15 degrees.
3. Delete the pugging conditions (Regulation 26 (4) (c)) and replace with a requirement to protect critical source areas (see Recommendation 6).
4. Delete the replanting date condition (Regulation 26 (4) (e)) and replace with a requirement to protect critical source areas (see Recommendation 6).
5. Clarify that reference to ‘drains’ in Regulation 26 (4) (d) does not include sub surface drains.
6. An additional condition is inserted that requires critical source areas in intensive winter grazing area(s), must be protected (uncultivated and ungrazed).
7. Amend Regulation 29(3) so that it applies as a further condition of Regulation 26 (4) and can accordingly be departed from if the intensive winter grazing is undertaken in accordance with a Freshwater Farm Plan or intensive winter grazing module.

While the group was established in Southland and the context for their recommendations was based on Southland experience, any changes that the Ministers might make to the regulations will impact on all regions.

Ministers expressed their gratitude for the collaborative effort put in by the group to develop the recommendations. The group felt that the Ministers had received the recommendations positively, seemed genuinely interested in the advice provided and asked questions to clarify the thinking behind some of the recommendations

Ministers are now seeking some advice on the recommendations before determining any next steps.

MPI is actively pursuing the potential for an intensive winter grazing module to provide an interim pathway until a process for Certified Freshwater Farm Plans is implemented.

Until the Ministers’ have considered the group’s recommendations and the Government has implemented any decisions as a result of the recommendations, farmers will still need to plan to meet freshwater requirements, including applying for any necessary consents.

This includes applying for resource consents to re-plant paddocks if you can’t comply with the 1 October (1 November in Southland and Otago) deadline to have paddocks used for intensive winter grazing replanted.

We’ll continue to keep farmers informed of future progress on the intensive winter grazing recommendations.

The group will present the report to the Freshwater Implementation Group and ministry staff in December. They have also made themselves available to the Ministers and their officials to answer questions and provide further assistance as they seek advice.