Federated Farmers has made it clear to the Government that it could support a national farm plan system, but only if it meets four firm bottom lines.
The Government is currently seeking feedback on its draft legislation to replace the Resource Management Act.
This includes a proposal to introduce nationally consistent farm plans under the new Natural Environment Bill.
“We’ve been looking closely at the wording and it’s fair to say we have some serious concerns,” Federated Farmers vice president Colin Hurst says.
“Farm plans should be a positive, practical and enabling tool that help farmers improve environmental outcomes in a way that makes sense on their own farms.
“We don’t want to see farm plans adding unnecessary complexity, duplication, or another layer of expensive regulation for farmers to grapple with.
“Unfortunately, we don’t think the regulations as they’re currently drafted will deliver what farmers are expecting or what’s been sold to them by politicians.
“That’s why Federated Farmers is stepping up, drawing a line in the sand, and making it clear we have four clear bottom lines when it comes to farm plans.”
Federated Farmers’ first and most important non-negotiable is that farm plans must replace regulation, not add to it.
“Farm plans need to be the primary compliance tool for farmers. That’s what will make a real difference for farming families,” Hurst says.
“That means a farm plan should be able to replace all of the overlapping rules, duplicated requirements and expensive resource consents from the current system.”
Under the proposed legislation, all commercial dairy farms and all other farms over 50 hectares would be required to have a farm plan covering the whole farm.
However, those same farms could still be required to get a resource consent in addition to their farm plan.
“That framework doesn’t simplify anything. In fact, it’s actually adding more complexity and duplication for farmers,” Hurst says.
“It’ll create a system that’s even more onerous than what farmers face now, where they either operate within permitted standards or apply for a resource consent.”
Federated Farmers wants to see changes so that a farm plan is enough to demonstrate compliance.
“A certified farm plan should be the equivalent of holding a resource permit or consent,” Hurst says.
The second bottom line is that farm plans must be proportionate, practical and scaled to risk.
“Farms that are low-impact and low-risk should be able to complete a simple, quick and easy plan themselves,” Hurst says.
“We agree that higher-risk farms may need more detailed plans, but there’s absolutely no point putting low-impact farms through the wringer.”
The third bottom line is that, while farm plans should be auditable, not every plan should be audited.
“Many farming activities are currently low-risk and don’t require consents or ongoing oversight,” Hurst says.
“Requiring those activities to have a farm plan, and then auditing that plan, will put in place expensive red tape for absolutely no environmental gain.
“It will waste time and money that could be put to far better use improving the environment rather than just ticking boxes and shuffling paper.”
Hurst says certification may make sense for higher-risk activities if it replaces the need for a consent, but routine auditing of every farm sends the wrong message.
“Audit-everyone systems don’t create a high-trust environment. They simply create a box-ticking culture and get farmers offside, rather than driving better outcomes.”
Federated Farmers is instead advocating for a model similar to the tax system.
“That means everyone is expected to do the right thing, but only some are audited, either randomly or where non-compliance is suspected.
“That’s a fair, practical approach that farmers can understand.”
The fourth bottom line is that existing farm plans must be recognised.
“Many farmers already have plans in place through industry programmes or local catchment groups,” Hurst says.
“Farmers have put real time, thought and money into these plans because they care about water quality.
“They shouldn’t be punished for being proactive or early adopters.”
Federated Farmers wants existing plans that meet minimum standards to be recognised as equivalent.
“Forcing farmers to start again from scratch would be a completely unjustifiable waste of time and money,” Hurst says.
While the detailed regulations are still to come, Hurst says expectations are clear.
“Farm plans must be tailored to risk and, for higher-risk farms, should become a genuine one-stop shop that replaces permits and consents.
“That’s how farm plans can actually work.”