'Swimmable' in the context of the proposals is complicated. For example, for rivers it means that median levels of E-coli in a waterway must be at or under 130 E-coli/100mls, which equates to a 1 in 1000 risk of contracting an infection during swimming.
Recognising the impact of rain events on E-coli levels, however, a river would still be considered 'swimmable' if monitored E-coli levels were much higher, provided that the elevated E-coli levels happened relatively infrequently.
We see it as positive to have a policy goal to work towards in terms of making our waterways safe to swim in - it's a goal everyone can relate to, even if it is an ambitious target. However we are aware that the complexity of swimmability means that there are disagreements in the science community about how that goal should be expressed and measured. This is a debate that we will need to watch closely to ensure that the outcomes we seek around swimmable lakes and rivers have a sound and credible scientific basis.
An important and pleasing part of the swimmability proposals is the recognition that we need to work together on our farms and in our own catchments to continue to achieve what the proposals would task us to do. We have consistently argued that taking a catchment and sub-catchment approach is the key to tackling freshwater management issues, and it is great to see this type of approach recognised.
Changes to the National Policy Statement for Freshwater Management
The Government is also proposing a series of amendments to the NPSFM to clarify and assist in its implementation. These amendments include:
Requiring regional councils to consider swimming at all points of the objective and limit-setting process in plan development;
Requiring regional councils to monitor bug and insect life in appropriate rivers and streams as part of the assessment of ecosystem health;
Clarification of the 'maintain and improve' principle to make it clear that this is at a freshwater management unit level, usually a catchment or sub catchment, rather than at a regional level;
Managing nitrogen and phosphorus through the establishment of in-stream objectives for their concentration as part of managing for periphyton (algae and 'slime') growth;
Requiring councils to consider the community's economic and social well-being when making decisions on water quantity, the pace of water quality improvements and when establishing freshwater objectives;
Providing for the identification and recognition of Infrastructure that provides for economic wellbeing of communities, when setting and managing to freshwater outcomes, including providing for cases where the environmental bottom lines can be breached.
On that last of these points, it is significant to have economic interests explicitly recognised as relevant to the management of freshwater resources. This does come with its challenges, however, and in implementation it will be important to ensure there is balance between economic goals and the capacity of our land and water to support them.
Keeping Stock out of Waterways
The Land and Water Forum early on agreed that excluding stock from waterways was a significant tool to support improvement in water quality.
The Government is proposing to start excluding stock from waterways from 1 July 2017, and progressively building upon these initial exclusion requirements to capture different stock types on different types of land. The exclusion requirements will apply to the bed and banks of lakes and natural wetlands and rivers, streams and permanently-flowing streams and drains.
The rules will apply to dairy and beef cattle, pigs and deer because these animals are the ones that can affect water quality the most. Where land slope or other factors mean that it is not possible to exclude stock in conventional ways, farmers can work with regional councils to develop a stock exclusion plan.
The Government expects the total cost of stock exclusion (including water reticulation) to be $367 million across the beef, dairy, deer and pig industries over the next 13 years. This is a significant cost and so we will be advocating that options for stock exclusion need to be flexible enough to allow the outcome of exclusion to be met in the most cost-efficient way for our farmers.
From this perspective, it is good that the proposals would allow a farmer that is unable to meet exclusion requirements for practical reasons to apply to the relevant regional council for permission to develop a 'stock exclusion plan' as an alternative. These plans would set out how environmental impacts associated with stock access to waterways would be managed, and could even form part of a farm environment plan.
Beef + Lamb New Zealand will analyse the proposal in more depth over the coming weeks as we prepare our submission on the document.
We will be looking to engage with farmers as we do this to help ensure that the outcome of improved water quality is achieved in a way that recognises the important positive contribution farmers can make and minimises the compliance burden.
Sam McIvor is CEO Beef + Lamb New Zealand.
