Submitter details
1. Submitter name
Individual or organisation name
(Required)
Greenbank Pastoral Ltd
Section 2: Defining lower intensity farming for the purpose of an exception
1. Do you consider stocking rate (ie, SU/ha) is an appropriate measure to define lower intensity farming or do you recommend a different approach?
Please select one item
Radio button:
Unticked
Yes
Radio button:
Ticked
No
Radio button:
Unticked
A different approach
Please explain your answer here
"Lower intensity farming" based on an annualized threshold of SU/Ha applied to the farm as a whole is totally inappropriate as it applies to our property. The ability to graze our block of flat land adjacent to the Taieri River ( and part of the scroll plain- an area of approx 50 ha ) should in no way be tied to the intensity of use of how we farm the other 1255 ha of our property.
We farm the 1255 ha intensively ( irrigated by 8 center pivots) but currently graze the 50 Ha of river flat very extensively , only grazing young cattle and only grazing at certain times of the year, to cover any impact that grazing may potentially cause.
It is not logical that our property could continue to graze the river flat if the rest of the farm had no irrigation , and hence had a very low stocking rate , but banned because of how we farm the adjoining land ! Totally crazy. Each parcel of land should be judged on its merits.
We farm the 1255 ha intensively ( irrigated by 8 center pivots) but currently graze the 50 Ha of river flat very extensively , only grazing young cattle and only grazing at certain times of the year, to cover any impact that grazing may potentially cause.
It is not logical that our property could continue to graze the river flat if the rest of the farm had no irrigation , and hence had a very low stocking rate , but banned because of how we farm the adjoining land ! Totally crazy. Each parcel of land should be judged on its merits.
2. What do you think is the appropriate stocking rate threshold (in SU/ha) for the definition of lower intensity farming?
Please explain your answer here
As the concept of defining "lower intensity farming" is totally flawed, this question does not warrant answering .
3. Do you think there should be different stocking rate thresholds for beef cattle and deer, or one threshold for all stock types?
Please explain your answer here
Again the concept of "stocking rate thresholds" being based on the "farm as a whole approach" is totally flawed and unacceptable .
Thus none of the options as below
Thus none of the options as below
4. Is there any other information that you think we should consider in relation to developing an exception for lower intensity farming?
Please write your answer here
Any exception should be based on how the land in question is currently used and projected to be used .
Each particular area of scroll plain should be evaluated on its particular merits and environmental requirements. No two pieces of land are the same, and this diversity needs to be recognized.
.
Each particular area of scroll plain should be evaluated on its particular merits and environmental requirements. No two pieces of land are the same, and this diversity needs to be recognized.
.
5. Do you consider that there are any situations where an exception for lower intensity farming should not apply, and the map should continue to apply?
Please explain your answer here
Yes - where the individual piece of land has features or unique botanical features that should be protected going into the future by excluding grazing.
Such a decision would be based on what values need to be protected, not based on how the remaining portion of the farm is operated ( either intensively or non intensively)
Such a decision would be based on what values need to be protected, not based on how the remaining portion of the farm is operated ( either intensively or non intensively)
6. Do you have any views on how those specific situations should be identified?
Please write your answer here
Yes - each bit of land should be analysed on its own merit and requirements. Specific situations cannot be decided on a "one size fits all " basis
7. Is there information that is readily available to farmers and councils to support the implementation of an exception based on stocking rates?
Please select one item
Radio button:
Unticked
Yes
Radio button:
Ticked
No
Radio button:
Unticked
Unsure
How is/should this information be used or shared by farmers and councils?
Specifically there are tracts of Taieri River Flat that have had stock excluded now for some generations. The Otago Regional Council should by now have done an intensive study to evaluate what has been the environmental outcome of such long term stock exclusions .
No hard and fast rules relating to stock exclusion ( be it sheep/cattle/or deer) should be promulgated until the results of such a study are completed .
No hard and fast rules relating to stock exclusion ( be it sheep/cattle/or deer) should be promulgated until the results of such a study are completed .
Section 3: Using certified freshwater farm plans
8. Do you consider that certified freshwater farm plans should be used as the basis for an exception, or an alternative, to the map and associated requirements to exclude stock?
Please select one item
Radio button:
Ticked
Yes
Radio button:
Unticked
No
Radio button:
Unticked
Unsure
Please explain your answer here
Because a freshwater plan is specific to the land in question. Such an approach is preferable to a one size fits all approach based on a flawed concept of an overall stocking rate of the property.
Again to reiterate how flawed the "intensity" concept is. Take 2 farms with say 50 ha of river flat ( potential stock exclusion country) On has 500 ha of intensively irrigated land and 3000 ha of very lowly stocked hill/high country. The other has 500 ha of intensively irrigated land but no high country. The former could well be judged overall to be low intensity ( and exclusion wiped) wheras the latter would be judged to be farmed intensively and the same class of river country would face exclusion.
I rest my case! The concept looks good in theory !
Again to reiterate how flawed the "intensity" concept is. Take 2 farms with say 50 ha of river flat ( potential stock exclusion country) On has 500 ha of intensively irrigated land and 3000 ha of very lowly stocked hill/high country. The other has 500 ha of intensively irrigated land but no high country. The former could well be judged overall to be low intensity ( and exclusion wiped) wheras the latter would be judged to be farmed intensively and the same class of river country would face exclusion.
I rest my case! The concept looks good in theory !
Section 4: Stock exclusion for natural wetlands
10. Do you consider that an exception for lower intensity farming systems, or the alternative approach using certified freshwater farm plans, should apply more broadly to natural wetlands?
Please select one item
Radio button:
Unticked
Yes
Radio button:
Ticked
No
Radio button:
Unticked
Unsure
Please explain your answer here
Firstly there has to be a robust way in defining a "natural wetland" Even after extensive discussion and work by MFE and ORC over the last three years, we are no closer to coming up with an acceptable definition that has integrity.
11. Are there any situations where any exception, or the alternative approach using certified freshwater farm plans, should not apply?
Please write your answer here
Question ambiguous
12. Is there any other information that you think we should we consider in relation to wetlands within lower intensity farming systems?
Please write your answer here
What actually is meant by "lower intensity farming systems" . In the context of Central Otago farming, if you have irrigation you will have an intensive farming system - if you don't have reliable irrigation you will not be able to have an "intensive farming system.
How an individual piece of so called wetland is grazed or not grazed should be judged on the merits of that wetland, not on how the remaining farmland of the owner of the wetland farmed
How an individual piece of so called wetland is grazed or not grazed should be judged on the merits of that wetland, not on how the remaining farmland of the owner of the wetland farmed
Section 5: Other issues
13. Do you consider the definition of a permanent fence is too prescriptive, and that other fence types should be included?
Please select one item
Radio button:
Ticked
Yes
Radio button:
Unticked
No
Radio button:
Unticked
Unsure
Please explain your answer here
There is no such thing as a permanent fence on the Taieri River scroll plain . Regular floods destroy permanent fences
14. Do you agree that amendments to the stock exclusion regulations should clarify that the map and associated requirements to exclude stock do not apply on slopes that are greater than 10 degrees?
Please select one item
Radio button:
Ticked
Agree
Radio button:
Unticked
Disagree
Radio button:
Unticked
Unsure
Please explain your answer here
Again a one size fits all is not appropriate. . A 20 degree slope bordering a sensitive river system in a 400 mm annual rainfall location poses an entirely different environmental risk as a 20 gegree slop some 10 km from the nearest stream in a 40 mm annual rainfall area
15. Are you aware of any other issues with the stock exclusion regulations that should be addressed? And if so, why?
Please write your answer here
As demonstrated above in 14, the "one size fits all "approach as regulations inherently are not the way to go. They will only deliver perverse outcomes.
Provide general feedback
Any general feedback on the consultation
Add your comments, ideas, and feedback here
The opportunity to provide feedback is appreciated, but a tsesing assignmnet of a "totally flawed concept"