Response 464486507

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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
Yes
No
A different approach
Please explain your answer here
That stock exclusion from waterways is based on the risks to the waterway regardless of size and altitude.

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
It should be based on the risks to the waterway.

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
It should be based on risks to the waterway.

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
A simpler way is to base stock exclusion on the risks to individual waterways. The low slope mapping is clearly illogical and impractical, for example where it specified stock should be excluded from part of a waterway because it is below 500m asl where part is below and part is above but essentially there is no difference. This illustrates how illogical the low slope map approach is. It should be based on the risks to individual waterways.

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
Requiring an exemption is additional unnecessary bureacracy and cost to farmers. Stock exclusion should be based on the risks to individual waterways.

6. Do you have any views on how those specific situations should be identified?

Please write your answer here
Do away with the low slope map because it is illogical and impractical, and base stock exclusion on the risk to waterways.

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
Yes
No
Unsure

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 explain your answer here
At this point not much is known about what a freshwater farm plan looks like. Farm Environment Plans are an ideal way to identify risks to waterways and prioritise exclusion of stock where it will result in improvement to water quality.

9. Is there any other information that you think we should consider?

Please write your answer here
Do away with the low slope map and base stock exclusion on the risks to individual waterways. It is a flawed concept.

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 explain your answer here
Stock exclusion from wetlands should be based on the risks to individual wetlands. There are benefits to some types of stock grazing in wetlands.

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
If you base stock exclusion on risks to waterways and wetlands eg via a Farm Environment Plan, then you won't need to add in additional requirements to try and fix the fact that the low slope plan approach is flawed to start with.

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
Stock exclusion from wetlands should be based on the risks to the wetlands.

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 explain your answer here
"Stock exclusion" is sufficient where there is a risk that justifies keeping stock out. It is up to the farmer how that is undertaken.

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 explain your answer here
Do away with the low slope map.

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
Stock exclusion should be based on the risks to individual wetlands and waterways.

Provide general feedback

Any general feedback on the consultation

Add your comments, ideas, and feedback here
Stock exclusion should be based on risks to waterways and wetlands. The low slope map is illogical and impractical, and should be trashed. There are plenty of creeks below 1m that would be a much higher risk than a stony creek over 1m. Target the exclusion to where it will make a difference. You don't need to be a genius to see this. Farm Environment Plans are a way of identifying where the risks are, where stock exclusion may be needed, and prioritising actions. LISTEN! And avoid another big bureaucratic mess that won't achieve anything.