The viability of some meat processing plants in New Zealand will be in doubt under the Government's current freshwater proposals, according to the Meat Industry Association (MIA).
"While we generally support the ambition of the proposals for cleaner freshwater, the planned river quality limits are excessively tight and exceed current limits already consented by regional councils," said chief executive of MIA Tim Ritchie.
According to Ritchie the limits were likely to result in "substantial economic costs" to the meat processing sector without resulting in "substantially improving environmental outcomes".
The meat processing industry is the country's largest manufacturing sector and employs approximately 25,000 people said Ritchie.
"[That's] the vast majority in regional New Zealand, so these proposals will have a significant impact on rural communities".
Many processing plants' wastewater treatment systems have also been significantly upgraded in recent years, often at considerable expense he said.
The sector is urging the Government to re-assess the proposed dissolved inorganic nitrogen (DIN) and dissolved reactive phosphorous (DRP) national bottom lines.
"We generally support setting in-stream limits for DIN and DRP – clear bottom lines will provide business with greater certainty" said Ritchie.
"However, these should be science-based, recognise the diversity of unique ecosystems and natural variation, and reflect the local conditions of that waterway".
According to Ritchie the DRP limits have also not been identified as a level causing adverse environmental impact and "the proposed DRP limit is unlikely to achieve better environmental outcomes while imposing significant economic costs".
Ritchie said MIA did not believe most processors would be able to meet the proposed DRP limit.
"Overall, the national limits need to be reassessed to ensure they are based on a scientific understanding of the environmental impact on waterways and lead to appropriate water quality without inflicting unnecessary damage on New Zealand's regional economy".
In a number of cases, the water quality upstream of processing plants already exceeds or is very close to the proposed limits said Ritchie.
"We are concerned our sector will be paying more than our fair share to fix water quality issues caused by others".
MIA also opposes the moratorium on farm land use change said Ritchie, as he believed it discriminated against farms which were already operating within environmental limits.
"Our processors and exporters have an interest in both ensuring supply of livestock is maintained, as well as that livestock is produced in an environmentally sustainable way to meet increasing customer demands for sustainable food.
"One of the cornerstones of New Zealand's productive world-class farming systems has been flexible land use, as farmers innovate and rapidly shift production according to market signals and regulatory requirements" he said.
Ritchie believed the moratorium would prevent farmers from maximising their production within environmental limits and said farms that meet environmental limits should be able to farm flexibly.
"Any decline in farming will have a knock-on effect, with reduced processing and eventually the closure of processing plants in regional towns where meat processors are often the largest employer" he said.
"The economic and social impacts of the freshwater proposals cannot be underestimated".