Hawke's Bay Regional Council Chief Executive, James Palmer, says current approaches to the water quality issue are narrow-focused and ineffective, relying on the Overseer tool to handle regulatory issues that it was never designed for:
“I think in employing a diminutive approach to this issue, we run the risk of having highly imprecise actions to try deliver results. It’s a very crude method which doesn’t necessarily deliver you across other parameters, but rather focusses on one - nitrogen. There’s been a tendency to do this nationally because we have Overseer, and Because we’ve got that tool, which enables us to estimate total loss from a farm, it becomes a very tempting way to manage that one contaminant. However, it’s crude in terms of the relationship of the effect and it’s also of relative risk because Overseer’s a model with a degree of inherent uncertainties, and the model changes over time. So, it’s not a very strong tool for regulation, and of course, it wasn’t designed as a regulatory tool, it was designed to assist farmers in terms of optimising nitrogen inputs onto properties.”
The state of the nation’s water has been a serious issue for some time now, the biggest concern being excessive algal weed growth, which degrades fish habitats, reduces recreational value and ultimately leads to oxygen loss.
The drivers of this growth are varied and include things like temperature, lack of shade, and nutrient levels. Although nitrogen and phosphorous are both naturally occurring and are therefore always present in streams to some extent, their concentration is often swelled to unhealthy levels by human land use. As Palmer says, if a council wants to achieve a certain limit in terms of nutrient levels, it must measure the total load going into the environment, a process that will involve whole-farm planning and intensive relationships between farmers and regulators:
“I think what’s required is an emphasis on whole-farm planning, an emphasis on ongoing, living documents which are redactive, involve personal, intensive relationships with farmers and, over time, involve systemic changes to the way farming operations run.”
Strategies like these will need to be researched and discussed in depth by the government before they introduce regulation of the kind recently mentioned by David Parker.
His farm nutrient capping proposal sparked concern amongst many in the agriculture sector - Palmer, however, says he isn’t perturbed:
“I’m not so worried about what the minster’s said on this, because as a regional council, we are required to undertake section 32 analysis under the RMA on the plans that will enable this to happen, so we will be doing the economic, social and cultural impact assessments on a catchment by catchment basis before these things are imposed. Furthermore, I know people are anxious about destocking, but at the end of the day, we as a country must accept that we do have high stocking rates on some soils, which is resulting in high nutrient loss to water bodies and is also resulting in poor water quality outcomes. I don’t think we can deny that. Therefore, land use change is a necessary and inevitable part of the future.”
The question that must be addressed, he says, is how we go about putting that land use change into effect in the most cost-effective and expeditious manner.
Historically, pollution in water bodies has been combated through voluntary efforts on farms. Councils have identified streams and rivers with high volumes of nitrates, informed the community, then relied on farmers to put in individual efforts to reduce nitrogen loss. As dairy regulation has increased in recent years, attempts have been made to manage the most obvious point sources of pollution like spray irrigators and milking sheds. However, as Palmer says, these methods haven’t been hugely successful on a national scale:
“In many catchments, current efforts haven’t been sufficient to get nitrogen down to lower levels. So, then it becomes a question of how you cap the total and how you reduce it.”
The answer, he says, is matching land use with land use sustainability in a whole farm context, a strategy that will take time and effort but reap the best rewards:
“There’s no substitute for working with a landowner in an intense way around understanding the whole farm system, what the geophysical attributes of the system are, what effects those attributes are having both on and off the property, and what the agronomic options to configure are that will get the best mix of outcomes. Now all of that requires a fairly high level of resources in terms of farm planning, farm advisory services, it requires a lot of deep engagement with the landowner- these things take time and they take investment both by regulators and the farmer.”
Palmer admits the issue is a complicated one but believes targeted land use change and water augmentation are the way forward, as opposed to current strategies which are likely to generate stress and frustration in the long run, as can be seen in the Tukituki catchment:
“In our region, we’ve got a live catchment right now – The Tukituki. Nitrogen has been allocated under the plan that was gifted to us by the board of enquiry on the Tukituki catchment that gives an allocation based on land use capability mapping for every property, every property has to have an Overseer budget and farm plan, so there are 1100 of them - We’re going through this massive exercise to give everyone a farm plan. Now that’s a good thing, everyone having a farm plan, but, everyone also has to have a budget. Now once we get into reducing the nitrogen beyond best practice, the combination of both the farm plan and the Overseer budget will get everyone going to good management practice – so that’s good. But then if we require a further reduction of nitrogen, then the question is how you achieve that- and that’s when you get into putting everyone in the catchment or sub-catchment onto resource consent. Then you’re going to require certain things to happen on farms to achieve compliance and you’re going to have to try and prosecute those who don’t come to the party. All of that is going to take years and years, create huge tension and anxiety in the community, pit the regional council against the farming community, it’s quite an adversarial approach. So that is the risk that going down this route on a national scale will involve – I mean I was only talking about one catchment just then. I look at that and say, “might a quicker way be to look at targeted land-use change, targeted water augmentation, and so on”, cumulatively those things might be lower cost and achieve the outcomes the government’s looking for in a shorter time span.”
Palmer says farmers are more likely to get behind a strategy that they see to be practical and effective, which the current Overseer-reliant system is not:
“Farmers don’t particularly like being regulated, like any human being. More importantly, farmers are practical people and they are very responsive, in our experience, to making changes where they can see a practical action results in a practical outcome. One of my biggest concerns, therefore, about nitrate allocation using Overseer as a regulatory tool, is that there are so many uncertainties associated with that between what happens on farms and the effect that ultimately occurs in streams. That uncertainty makes it very difficult to get farmers to buy into the notion that there are worthy actions to take here. That’s why we should be focusing on practical efforts that have a demonstrable effect, then set to work on those as soon as possible.”