Open letter to the Otago Regional Council

I have read in the News that it will be done the “Best possible way”. Everything is done by the rules, Otago Regional Council is setting up some monitoring tools, and there will be some jobs (Wanaka Sun 25th August). Great. But in the 25^th September meeting in Hawea, ORC acknowledged that it cannot guarantee water quality.

Intensive dairy farm “the best possible way” does not mean it is good enough. Laws are too loose to protect our waters as detailed in this submission against the Freshwater management act by the Guardians of Lake Wanaka and The Cawtron report on National Policy Statement available from Fish & Game website.

To summarize the issues, Regional councils can let water quality degrade as long as some others are improved. In the case of our pretty good water quality overall in our upland area, it simply means that the law allows our waters to be degraded. It is important to be aware of the fact that the current laws do not set any limits to freshwater pollution. Water quality standard, mainly compliance criteria exist only for public drinking water.

National laws let the Regional Council decide. Now I ask you, my Regional Council, to decides on good water quality levels.

Intensive dairy farming is the main water polluter in NZ

Damming is partly responsible for freshwater species decline when it does not provide migratory routes facilities. Industrial and human pollution are affecting water quality obviously too. But many studies prove that land use intensification is the main cause of water quality decline in New Zealand, in particular intensive dairy farming.

From the detailed article “Clean, Green and endangered” article by David Brooks published in Forest & Bird Issue 341, August 2011, dairy farming leads to:

• lots of water being removed from rivers,
• pasture erosion, leading to flows of sediments
• damaging nutrients from fertilisers and animal waste leaching back into our water bodies.

In a following article “Our Sacred cows”, by Dr Mike Joy says “the number of cows milked in the South Island has increased sevenfold”. He adds:

• Only shed effluent is controlled by regulation
• Other effluents are unchecked (uncheckable indeed), just an externality
• Worse still, cows are fed with imported palm kernel, for which rainforests are massively destroyed
• In 20 years, the dairy boom has generated a 700 per cent increase in nitrogen fertiliser use, with the consequences detailed in a previous research.

That is a case against intensive dairy farming alltogether, not only in our backyard.

If intensive dairy farming is a national threat to waters, then surely it is not good for Hawea waters, is it? How doing the same thing could have a different outcome?

What happens when the monitoring tools will show an increase of pollution? Can you remove pollution from water tables? Will they then reduce the numbers of cows when the damage is done?

No resource consent needed

If water if not a resource, then what is? Yet, there is no need for public submission to resource consent for land use intensification. This is why there was no resource consent submission for Hawea dairy farming plan, therefore no avenue for people to say what they think. We cannot trust our Council to protect our waters, because laws do not cover it properly. The community interests are not protected by the law. The laws give advantage to dairy farming which is a leading NZ export sector (i.e. lots of $$ for some), provided that they intensify production. Meanwhile in Europe, the catastrophic state of rivers prompted capping intensification and reducing fertilisers use.

I have explored the MFE website, in particular the “Managing Waterways on Farms” section. Now, tell me if I am wrong but the only thing I found is: “The first priority for the management of nutrient contamination should be excluding livestock from streams and stream channels.” Should! It is not even compulsory! I have also skimmed the Otago Regional Council Plan : Water and found the word “livestock” once. In the FAQ however, I find: “while you are allowed to graze all forms of stock near waterways, they must not damage or pug the bank or contaminate the waterway in any way”.

Even this law is not applied. I often witness cows walking in the rivers around the area, for example: Bulls grazing in Cardrona River on Robrosa Station, or cows roaming Motatapu river below the Wanaka-Mount Aspiring Road bridge.

It is also shown in the beautiful award-winning documentary River Dog by James Muir.

Now cows defecation impact on water quality is well documented for example in this study “Water quality impact of a dairy cow herd crossing a stream” by the Royal Society of New Zealand published in 2004 (find the conclusions on page 7)

It is important to note that even if not poured directly in the river, dejections and fertilisers do reach the water table or the rivers as it is acknowledged on the MFE website page Type of Activities that pose a threat to water quality. Check it out. There is no “Best possible solution”. Cows dejections and fertilisers WILL sooner or later end up in our waters.

May I remind some decision making principles detailed in page 27 of the Know How guide to decision making the Local Government Act 2002? http://www.lgnz.co.nz/library/files/store_021/DecisionMaking.pdf

1. Consideration of community views.

2. Recognition of diversity.

3. Interests of future communities.

4. Impacts on well-being.

5. Prudent stewardship.

6. A sustainable development approach.

It seems to me in this dairy farm decision that all these points have been neglected.

So I ask ORC to impose public submission for resource consent before a farm becomes intensive, and to enforce the recommendations about keeping cows out of waterways.

Consequences on our waters

“Just drink the water from the lake” is now a health hazard, as well as swimming in many areas. Water from the tap, is also an issue. The Ministry of health states in an ESR report dated 2006 that “ the actual number of waterborne cases lies between 18,000 and 34,000 a year”! In Hawea flat, residents take their water from bores reaching the aquifer. They will have to dig deeper to reach water and their water will be polluted one day.

Biodiversity is at great risk, with 60% of native fish, threatened with extinction, including the longfin eels. No fish ? No fishing! And many people have sadly observed a sharp decline in our areas in recent years. Also at risk, invertebrates, birds, freshwater crayfish and mussels.

New Zealand “100% pure” brand, a key to our thriving tourist industry is also at stake of course.

I have read the Otago Daily Time Article written to reassure residents about environmental impacts are that “Hawea is different, with low rainfall and different soil structure”. That raises more questions. How are they going to feed their cows on the famously lush- not!- grass of Hawea, without irrigation? Is irrigation not a factor of run-off? Different soil structure? Will it hold nitrogen in its little arms for ever? Or will the nitrogen take longer to reach the water table? Or what?

In other areas in New Zealand, Regional councils have taken steps once the damage was so obvious that it could not be ignored. After the devastating condition of the Waikato river, Waikato Regional council has established regulations to achieve 20 per cent reduction in the amount of nitrogen entering Lake Taupo, which includes 1.82 hectare per cow.

So I ask ORC to establish a sustainable maximum number of livestock heads per hectares.

Not sustainable!

As somebody texted it in a Wanaka Sun, “We, the people of Wanaka, were able to stop the already consented spread of human waste in Tarras by speaking out. (…) In a previous article in ODT, new owners were considering other options too, so we are not preventing them from doing business if we ask them to revert from their lucrative but damaging intensive dairy farm plan. And the stock will not arrive before next year so there is time for action. Let’s do it!

Fonterra can only collect milk for 10,000kg of milk solids a year or more for a farm situated beyond its usual routes (Alexandra, Omarama or Fox Glacier). Some data found on NZ Agritech website calculates that 250 cows produce an average of 315 milk solid per year. So they actually need 8000 cows on their farm…

Besides, this raises the issue of the fodder, fertilisers and milk travels and petrol use implied… Will Hawea flat milk travel to Christchurch to be processed or to Southland? Just not sustainable…

Now, in the Sustainable Development for New Zealand Programme of Action 2003, it is specified that government decisions should ensure the wellbeing of current and future generations as detailed in full in   http://www.beehive.govt.nz/sites/all/files/30199-med-susined-developm.pdf

PRINCIPLES FOR POLICY AND DECISION MAKING

The government recognises that its decisions should ensure the wellbeing of current and future generations. It will take account of the economic, social, economic, environmental, and cultural consequences of its decisions by:

• considering the long-term implications of decisions

• seeking innovative solutions that are mutually reinforcing, rather than accepting that gain in one area will necessarily be achieved at the expense of another

• using the best information available to support decision making

• addressing risks and uncertainty when making choices and taking a precautionary approach when making decisions that may cause serious or irreversible damage

• working in partnership with local government and other sectors and encouraging transparent and participatory processes

• considering the implications of decisions from a global as well as a New Zealand perspective

• decoupling economic growth from pressures on the environment

• respecting environmental limits, protecting ecosystems and promoting the integrated management of land, water and living resources

• working in partnership with appropriate Maori authorities to empower Maori in development decisions that affect them

• respecting human rights, the rule of law and cultural diversity.

It seems to me that the approval ORC gave does not follow these principles. It is just not professional !

You are paid by our rates to do a good job, to think before you sign an application. It is not too late to prevent the damage.

To summarise, I ask ORC:

• to decides on good water quality levels
• to impose public submission for resource consent before a farm becomes intensive,
• to establish a sustainable maximum number of livestock heads per hectares.
• to enforce the recommendations about keeping cows out of waterways
• to create all rules with the future in mind. We can decide now on things that will make a good future. If we mitigate now, we will have to repair (if possible! ) in the future. The council is responsible for now and for later.

I thank you very much for your attention and look forward to your answers.

Florence Micoud

021 027 92481

Wanaka

florencemicoud@gmail.com

Sent on the 20/11/2011 to ORC http://www.orc.govt.nz/About-us-and-the-Region/Contact-Us/Contact-Us/, to the ODT odt.editorial@alliedpress.co.nz, to the Wanaka Sun theeditor@thewanakasun.co.nz and to email contacts, link posted on Facebook and sent on Twitter

Click here https://wildclarisse.wordpress.com/2011/09/05/intensive-dairy-farming-in-hawea/ for a previous post on the subject and interesting comments.