ERPA director Millan Ruka says at the beginning of the 26-page submission that most of it had been sent to the Northland Regional Council (NRC) in September last year, but additional material included submissions on "dairy support cattle", poplars planted to deal with riverbank erosion not being suitable for the job, and concrete river crossings making waterways less navigable.
Mr Ruka claims the NRC classifies any cattle on a dairy farm which are unmilked as "dairy support cattle" not required to be fenced from waterways.
"This is a complete departure from the obligations of the 2013 Clean Streams Accord and its replacement 2013 Sustainable Dairying: Water Accord."
The NRC had said there were no regional rules requiring stock to be excluded from rivers and lakes, but ERPA was unaware of any consultation to adopt this change in policy.
"Fonterra delivered the korero that all cattle on a dairy farm or a run-off come under the original accord and as recent as 2015 in the new 2013 accord," Mr Ruka says.
"Fonterra have already taken the stance that their dairy farmers are not in breach of the accord where cattle are reported unfenced on a riparian as it is a 'permitted activity'. So there is a critical change in policy without consultation to the public. This essentially nullifies the power and intent of the 2013 Sustainable Dairying: Water Accord."
The ERPA submission opposed the apparent new policy referring to "dairy support cattle" and recommended independent auditing when Fonterra or a dairy company declare their farmer to be compliant with the 2013 Sustainable Dairying: Water Accord.
The submission also called for Fonterra, the NRC and Whangarei District Council (WDC) to compile a stock exclusion fence reporting code. The ERPA pointed out the WDC had 28 pages of traffic and parking bylaws but the NRC had no bylaws covering unfenced cattle on waterways.
The submission says poplars which the NRC encourages planting for Mangakahia River stabilisation were the wrong tree for unstable silty river banks.
"They are very tall, huge in fact, but have a very small root system. They catch the wind like a sail when their leaves are on and continually fall into the river during storms," Mr Ruka said.
Log jams were rare before the poplars were planted in the 1980s. ERPA called for the NRC to switch from poplars to indigenous trees and to contract hapu to clear log jams.
The ERPA submission also covers a Hancocks Forestry application to allow a concrete river crossing on the Mangakahia River to enable the harvest of the 1300-acre Robinson pine forest. The ERPA says the forest could be harvested with a Bailey bridge, helicopter or fly-wire across the river.
It wants the concrete river crossing turned down as it would create an obstruction to river traffic such as school paddlers, recreational users, eel harvesting and kaitiaki patrols like those carried out by the ERPA.
