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On this page you’ll find a summary of P.LU.G. submissions, letters, and information on our response to PC1 and Central Government
proposals affecting farmers and growers.

Biodiversity Statement

P.L.U.G. Submission on Proposed Biodiversity Statement

‘Biodiversity’ refers to all living things. This includes all plants and animals and the places in which they live. Aotearoa has rich and unique biodiversity, but over 4,000 of our indigenous species are threatened or at risk of extinction.

DOC is leading a consultation for an action plan from 2020. New Zealand’s last biodiversity strategy laid out actions to protect our nature until the end of 2019. The new strategy will set a vision and guide our biodiversity work for the next 50 years.

New Zealand provides comparatively few incentives for landowners to conserve biodiversity. For example, if a landowner decides to set aside land for biodiversity, perhaps in a Queen Elizabeth II covenant they bear a cost while the benefits of enhanced biodiversity are spread much more widely.

Over the 20 years since 2000 there has been an increase in the level of engagement and commitment to biodiversity protection and restoration from local councils and communities.

Areas of significant biodiversity on land (places which have been identified to contain threatened species or rare or naturally uncommon ecosystems) and freshwater and coastal wetland habitats are still being reduced today, pointing to a failure to protect them.

There is also a wider suite of threats and issues that haven’t received enough attention – with one of the main ones being the rapidly expanding numbers of Koi Carp. Koi Carp being endemic to the lower Waikato and Waipa river systems, with smaller populations in other areas.

The new proposed strategy for Biodiversity states the following:

The vision we see for New Zealand by 2070 “Nature in Aotearoa is healthy, abundant, and thriving. Current and future generations connect with nature restore it and are restored by it.”

Amongst other things, this means that, in 2070:

  • Our species, habitats and ecosystems (especially those that are currently rare and threatened) are increasing, not declining, in number and extent, across private as well as public land and in the sea;
  • This increase is not just captured in statistics, we can all see and feel it – for example, the dawn chorus across Aotearoa New Zealand sounds like it does on our offshore islands;
  • Thriving nature is seen to underpin our economic success and wellbeing, rather than being seen to be in conflict with it – economic growth is a net restorer, not a net sub-tractor, of our natural environment;
  • Biodiversity is core to all decisions about land and water management, including on private land;
  • Everyone who wants to can access nature and gain the benefits of doing so, no matter where they live, and can, if they wish to, be a part of restoration;
  • Mana whenua feel that they can genuinely practice their role as kaitiaki, and nature is thriving to the extent that they are able to practice customary take.

Yet with the failure at all levels (Central, Regional & District) of government to effectively address and put in place control measures for Koi Carp (A well-known omnivorous pest predator fish) we will never be able to see “Our species, habitats and ecosystems (especially those that are currently rare and threatened) are increasing, not declining, in number and extent, across private as well as public land and in the sea;” actually increasing.

The Biodiversity statement also has the following:

By 2030, if we have been successful, we will see:

  • No net loss of extent of rare and naturally uncommon terrestrial indigenous habitat (active sand dunes, braided riverbeds, estuaries, cloud forests etc)
  • Ten key freshwater pest species and ten key land-based weed species are reduced or controlled to a level that does not diminish ecological integrity.
  • Marine Protected Areas established in priority areas, and priority risks being actively managed. Indicators are demonstrating positive changes.
  • New Zealand acknowledged internationally as a source of biodiversity protection and restoration know-how.

Given the effects of uncontrolled expansion of numbers of Koi Carp which must be seen as one of the top freshwater pest species we will never be able to achieve this objective.

In fact with the current level of knowledge regards the Koi Carp and their effects on the freshwater ecosystems, we need to acknowledge that without putting in place some form of control we have failed currently and will continue to do so into the future.

The Biodiversity statement also has the following:

By 2050, if we have been successful, we will see:

  • Overall, the net extent of indigenous ecosystems is increasing.
  • The extent of our undegraded rare and naturally uncommon terrestrial indigenous habitat (active sand dunes, braided riverbeds, estuaries, cloud forests etc) is increasing.
  • The number and extent of our freshwater and coastal wetlands is increasing.
  • Ten key freshwater pest species and ten key land-based weed species have been eradicated.
  • Aotearoa New Zealand is free from stoats, possums and rats.
  • All established pests are reduced to the level where ecological integrity is not diminishing.
  • Populations are increasing for all our threatened species.
  • Bycatch of seabirds, corals, and marine mammals is reduced to zero.
  • Mahinga kai, cultural take and sustainable use of our indigenous species is taking place.
  • Every business is helping to restore nature.

All of the highlighted areas of the Biodiversity Statement that are shown above will be shown to have amounted to a massive failure without some form of control being placed on Koi Carp.

Koi Carp are an omnivorous feeder and they cause erosion of waterway margins as well as a severe degradation of water quality through release of sediments and consequent raised levels of Phosphorous which in turn support the increased levels of algal blooms in our waterways.

Koi Carp feed on the eggs and young of our native freshwater fishes as well as destroying their natural breeding habitats by this erosion from their feeding methods. They are able to survive in severely degraded water quality where our native fishes cannot, they have a highly successful breeding rate in the New Zealand conditions and this coupled with the lack of any natural predators in our waterways, makes them in my opinion the number one pest species in both our waterways and the riparian margins to those waterways.

The Biodiversity statement also has the following:

Proposed system shifts

The following section sets out five proposed system shifts for implementation. These have been identified based on what people have said are the most important areas to focus our efforts in the first five years of the strategy. It is proposed that by being focused and taking coordinated action in these areas, we – all New Zealanders – could make the greatest progress towards the goals and long-term outcomes of the new strategy. The system shifts are intended to be the main areas for investment and change across the biodiversity system for the first five years of the strategy. After this first five-year period, they will be reviewed to see if they are still the most important areas to focus on.

Our current biodiversity system isn’t working as well as it should. It fails to tackle issues at the scale needed to address the ongoing and cumulative loss of indigenous biodiversity. People have strongly voiced that action in this area must be a priority and that it needs to happen now in order to address the range of drivers of biodiversity loss.

There is currently a lack of coordination and clarity around who is supposed to do what. Central government (mainly the Department of Conservation, the Ministry for the Environment, Fisheries New Zealand, Biosecurity New Zealand and Te Uru Rākau) and local government have legislated roles and responsibilities for biodiversity, but these are ambiguous, and result in different approaches across the country.

The new biodiversity strategy will provide priorities at the national level and will support more detailed and specific planning at a regional, local and sector level. Local authorities have responsibilities under the Resource Management Act 1991 for land use planning and the management of natural resources. They do this through polices and rules in regional and district plans. Regional Councils also have responsibilities for biodiversity and biosecurity management. National direction, such as a national policy statement, can guide how district and regional plans are developed.

At present there is a lack of cohesive prioritisation or direction in the biodiversity system. It’s hard for everyone involved in the system to see how they fit together, where there are overlaps or gaps, and how to share knowledge or resources. No one has a role to facilitate coordination, partnerships and communication between those involved. A shift in culture across the system from one where entities work in silos to one where there is true collaboration, co-design and partnership would deliver better outcomes for nature.

We need to enable community ownership of biodiversity action. We also need to provide consistent, effective and targeted best practice advice, support and capability-building that is accessible to all individuals and groups. We need to standardise, align and simplify funding processes and ensure funding is tied to delivery of biodiversity outcomes.

There is an opportunity to enable and support local people, in monitoring and restoration projects.

Case study: The Waikato Biodiversity Forum

The Waikato Biodiversity Forum was formed in 2002, in response to the release of the New Zealand Biodiversity Strategy and its suggestion that regional networks be set up to better co-ordinate biodiversity efforts. It has been the first and longest running regional biodiversity network of its kind in New Zealand. The Forum is an enabling body which helps make biodiversity groups visible and utilises its strong network to connect groups to resources which are available to them (advice, funding etc), but may be difficult to source on their own. It utilises an interagency and community approach to support its biodiversity community, which creates efficiencies through collaboration. Over 450 individuals and groups are part of the Forum, including iwi, agencies, research providers, community and landcare groups, NGOs, plant nurseries, private landowners and interested individuals. The Forum recognises that no one agency, sector or element of society has all the answers to the biodiversity issues we face regionally and nationally – there is a need to work together.

This Waikato Biodiversity Forum was formed in 2002 and yet here we are in 2019 (17 years later) and still without any credible strategy to manage, control or eradicate Koi Carp.

The Forum is supposed to be an enabling body and with that in mind I question what exactly they have spent their funds enabling, as I can see no credible value in their existence. Koi Carp are still expanding their numbers exponentially and spreading their habitat with all of the accompanying deleterious effects on the waterways and our native flora and fauna. 

I have included a copy below of an excerpt from a report in relation to Koi Carp in Lake Ohinewai and I do so because it shows that the effects from Koi Carp were known back in the early 1990’s and yey we have still not got a credible strategy for control or eradication.

Whilst it is great to have a Biodiversity Statement/Strategy that puts in place templates for the process of developing plans for how we will control or eradicate pest fishes, it is much more important to actually do something physical to fix the problem.

So overall this submission has two parts;

  1. The need to recognise Koi Carp as an extremely serious pest that can affect our native flora and fauna in many detrimental ways.
  2. The need to put in place a physical system to actually deal with the problem rather than spend more time and money discussing how to go about it.

The problem has now reached such serious proportions given the estimates that there are approximately 500,000tonnes of Koi Carp in the Lower Waikato and Waipa River systems, that Koi Carp are actually a much bigger problem in relation to water quality in that area, than both farming and urban development combined.

I am also reliably informed that there have been Koi Carp released into the Lake behind the Karāpiro Hydro Dam. If this is actually true then the perpetrators of this release should be treated as environmental terrorists and face the maximum penalties available under the law.

Andy Loader
Co-Chairman P.L.U.G.
Primary Land Users Group.

APPENDIX:

5.2 Removal of Invasive Fish and Exclusion of Koi Carp from Lake Ohinewai

Grant Tempera 1, Nicholas Ling 1, Adam J. Daniel 2 &: Dai Morgan 3

  1. ‘The University of Waikato, Hamilton, New Zealand
  2. ‘Auckland/Waikato Fish & Game Region, Hamilton, New Zealand
  3. NorthTec, Whangarei, New Zealand

Management Issues

The lower Waikato River floodplain contains many shallow lakes. The floodplain has been highly developed for pastoral agriculture, primarily dairy farming, resulting in extensive drainage and flood control measures to regulate river and lake levels. Most lakes have degraded water quality as a result of nutrient and sediment enrichment, and the additional impacts of pest fish such as koi carp, goldfish, catfish and rudd have generally contribute9 to the total collapse of submerged macrophytes and progression to a highly eutrophic state. Of all New Zealand lakes monitored regularly for water quality, around 25% of those categorised as supertrophic or hypertrophic are on the Waikato River floodplain (Verburg et al. 2010).

Lake Ohinewai is a shallow (4.5 m depth), 16.8 ha lake on the floodplain. The lake has a 331 ha catchment that is primarily flat and dominated by intensive pastoral farming with several inlet drains. A single outlet drain leads to Lake Waikare via Lake Rotokawau and passes through a circular road culvert 930 m from the lake outlet. Lake Ohinewai deteriorated from a stable oligotrophic (macrophyte-dominated) state to a stable eutrophic (algal-dominated) state during the early 1990s, and now lacks aquatic macrophytes. In 1981, 80% of the lake was covered in aquatic macrophytes but by 1991 none remained (Edwards et al. 2005). 

Invasion by koi carp over this period was implicated in this change of state.

Lessons Learned

It is highly likely that the biomass of koi carp in this lake contributed to persistently poor water quality and the algal-dominated eutrophic state.

Proposed ‘Essential Freshwater Package’

 Economic Misdirection At it’s Finest

A report by the New Zealand Institute of Economic Research (NZIER) has suggested that the government’s proposed clean-up of waterways will not harm New Zealand’s overall economy.

That was because the dairy industry was smaller than was commonly supposed, averaging just 3.9 per cent of the New Zealand economy over two and a half decades.

But the report admitted some regions might suffer economic hardship more than others.

The research was commissioned from NZIER by three environmental bodies, Forest & Bird, Greenpeace, and Fish and Game.

It followed this month’s launch of the Action Plan for Healthy Waterways by the government.

That plan aimed to improve the ecological health of wetlands and streams via a range of measures.

These included setting higher standards of water quality in popular swimming spots, putting interim controls on land intensification, launching accelerated planning processes and other measures.

The announcement spurred strong complaints from some farmers that agricultural production could be made untenable in some regions.

But the NZIER report said this would not translate into overall economic harm for the nation.

This report only mentions the dairy industry as a basis for making the assumption that there will be very little economic harm done to New Zealand and totally ignores the facts of this whole situation.

Right…so the replacement of 68% of our beef and lamb exports and 13% of our dairy exports (as modelled by the Regional Sector Water Subgroup, and quoted by the Chair of that group & Chief Executive of Waikato Regional Council Vaughan Payne) with speculative, largely foreign owned, carbon farming is going to have a minor impact on the economy – yeah right.

It was stated that the total profit estimated to be obtained from land-use declines only by around $7 million per year, but this is because the falls in profits for the dairy sector (of around 7%) and drystock sector (around 40%) are offset by very large increases in forestry profits (190%).

Given that the projected large increases in forestry profits will not eventuate for at least twenty five years and the costs for development and planting of these forests, it is no more than idle speculation to state that there will be a 190% increase in profit from forestry.

Who knows with any certainty what is going to happen twenty five plus years into the future. Will there be a market for forestry products and if so will there be higher or lower levels of demand with the attendant effects on prices either up or down.

This statement is nothing more than an educated guess backed up by some crystal ball gazing and a huge gamble by government using private equity with no rights of recourse for the true stakeholders (i.e. the owners of that private equity). 

Given that the replacement of these farming operations with forestry, goes ahead, there has been no recognition given to the fact that not only are we talking about a very significant part of New Zealand’s income but also that it will take approximately thirty years (time till trees are ready to harvest) for the replacement operation to show a return on investment.

There is also no recognition given to the fact that the change to forestry will come with reduced levels of employment and virtually guarantee that there will be another large move from the rural towns into the cites to allow the population to try to find stable employment.

We will see more rural ghost towns when the effects of reducing populations in these rural centres see the local doctors, dentists, supermarkets, hotels etc. unable to sustain operations with a reduced number of customers due to this drift away, because of the lack of employment opportunities.

You only need to go and spend some time in the Tokomaru Bay and the whole East Cape area, to get a taste of what happens to communities where farming is deliberately replaced with forestry (as it was in the Northern cape post cyclone-Bola) Then let’s see if they can write another report on the amazing economic opportunities in the East Cape that have come about from the development of forestry…… Yeah Right!

There is no mention whatsoever about the effects from urban developments on the water quality even though it has been publically acknowledged by the government that some of the worst polluted waterways have come about from urban development discharging to natural waterways.

In addition to the Rural Ghost Town effect, this population drift into the cities can only exacerbate this problem in relation to the water quality, caused from discharge to natural waterways from urban developments.

Whilst I believe this report may be a true indication of the impacts from the changes to dairying I also believe that it amounts to a blatant distortion of the true situation by wilfully omitting to mention the effects from the changes to the overall rural outcomes from the changes to all types of farming that will result from the “Action Plan for Healthy Waterways”.

The Prime Minister is on record as saying that in bringing agriculture into the ETS (and working within the water quality restrictions) her government wishes to avoid the traumas of the 1980s when subsidies were removed.

She is concerned about rural communities and their welfare.

In actual fact I believe that this type of acting without adequate overall economic analysis, will lead New Zealand into a situation that will create a much worse trauma than anything that we experienced as part of the removal of subsidies in the 80’s.

I challenge the government to show me how these reductions in farming, farm employment and consequent reductions in export commodities will maintain our current overseas income levels and allow New Zealand to service our loan commitments.

Feedback from the MfE Freshwater Policy Meeting
Pukekohe 24th September 2019

Feedback by Kelly Diehl; Environmental Management Solutions

On Tuesday, we attended the MfE meeting in Pukekohe on the recently proposed Freshwater Policies. In a nutshell – it was more frustrating than helpful!

MfE staff gave an extremely high-level overview of the policies, did not address any of the impacts and struggled to answer the simplest of questions. “Good question – we’ll park that and take it back” seemed to be a common response.

We all want clean waterways – I’ve never heard anyone in my career say they don’t – and the majority of landowners are already working very hard towards this. The policies proposed however, do not recognise this and are likely to have a significant negative impact on our national economy and on the livelihoods of everyone, both urban and rural. Yes, urbanites will be hit in the pocket under these proposals too, although the rules are generally targeting the rural sector.

The following key points came through in this meeting:

  • It was confirmed in the meeting by a member of the Freshwater Leaders Group who were integral in developing the proposed Freshwater policies, that they were told explicitly to disregard economic impacts during the Policy development.
  • MfE confirmed that they have not completed a thorough economic analysis on the impacts of the proposed policies. Local Government modelling has however, verified that the impacts are likely to be major. A recent local government economic advisory report indicates that the proposed freshwater policies could put many farmers out of business, with the study confirming that under the current proposal, 68% of the Waikato drystock sector will likely be gone, with an expected 160% increase in forestry (refer Local Government New Zealand Regional Sector Water Subgroup Initial Economic Advisory Report on the Essential Freshwater Package, page 21 paragraph 3).
  • There has been no consideration from what we could gather, on the social impacts of the proposals either. If we use the above example, there is no pay out for ~thirty years in forestry, which in our opinion will likely be sold to foreign investors, not to mention the inability to feed a growing population or respond to market demands, lost export revenue, and most importantly the social aspects – the displaced rural communities, the people who have made considerable investment over generations not only into their land and the environment, but also into the communities in which they live. No consideration has been given to these impacts. Nor does there appear to have been consideration of the potential sedimentation effects when the forestry is removed en masse, they only need to look to Marlborough Paua industry for an example. To completely disregard the social and economic impacts (and to give direction to this effect), and to allow no time for communities to respond thoroughly, is unacceptable. This matter is of national significance, yet there appears to be no real media coverage – why?MfE could not answer simple and relevant questions such as ‘how will we provide cost effective, fresh produce to our communities under the current proposals”, to which they responded, “good question, we do need to consider this and will park it for now”.

    Submissions are due by the end of October. To read the documents and to learn how the proposals could affect you, go to:

    www.mfe.govt.nz/consultation/action-for-healthy-waterways

Lake Taupo Nitrogen Cap

Financial impact of the Waikato Regional Plan Nitrogen Cap on Taupo Farmers

Prepared for the Waikato Regional Council by Phil Journeaux, Darren McNae & James Allen; May 2019.

The financial impact of the nitrogen cap was analysed across various aspects:

(i) Impact on farm working expenses. As a generalisation, the rate of increase in farm working expenses across farms in New Zealand over time is greater than the rate of increase in farm income. This is the classic ‘cost/price’ squeeze which has affected New Zealand farming for
many decades. 

Within the catchment, there was insufficient information available to readily determine if the nitrogen cap was having any additive impact on this issue.

(ii) Compliance costs. There has been an increase in compliance costs for the catchment farmers, with respect to:

  • Cost of consenting.
  • Time cost to farmers and/or staff in monitoring and annual audits.
  • Annual monitoring cost to Waikato Regional Council.
  • Cost of employing professions (consultants, accountants) to assist in the annual monitoring/audit process

This compliance cost is often exacerbated for the Maori farming entities, given their governance and multiple-ownership structures. 

You can download the full report below