Federated Farmers has made it clear to the Government
that it could support a national farm plan system, but only
if it meets four firm bottom lines.
The Government is
currently seeking feedback on its draft legislation to
replace the Resource Management Act.
This includes a
proposal to introduce nationally consistent farm plans under
the new Natural Environment Bill.
“We’ve been
looking closely at the wording and it’s fair to say we
have some serious concerns,” Federated Farmers vice
president Colin Hurst says.
“Farm plans should be a
positive, practical and enabling tool that help farmers
improve environmental outcomes in a way that makes sense on
their own farms.
“We don’t want to see farm plans
adding unnecessary complexity, duplication, or another layer
of expensive regulation for farmers to grapple
with.
“Unfortunately, we don’t think the regulations
as they’re currently drafted will deliver what farmers are
expecting or what’s been sold to them by
politicians.
“That’s why Federated Farmers is
stepping up, drawing a line in the sand, and making it clear
we have four clear bottom lines when it comes to farm
plans.”
Federated Farmers’ first and most important
non-negotiable is that farm plans must replace regulation,
not add to it.
“Farm plans need to be the primary
compliance tool for farmers. That’s what will make a real
difference for farming families,” Hurst says.
“That
means a farm plan should be able to replace all of the
overlapping rules, duplicated requirements and expensive
resource consents from the current system.”
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Under the
proposed legislation, all commercial dairy farms and all
other farms over 50 hectares would be required to have a
farm plan covering the whole farm.
However, those same
farms could still be required to get a resource consent in
addition to their farm plan.
“That framework doesn’t
simplify anything. In fact, it’s actually adding more
complexity and duplication for farmers,” Hurst
says.
“It’ll create a system that’s even more
onerous than what farmers face now, where they either
operate within permitted standards or apply for a resource
consent.”
Federated Farmers wants to see changes so
that a farm plan is enough to demonstrate
compliance.
“A certified farm plan should be the
equivalent of holding a resource permit or consent,” Hurst
says.
The second bottom line is that farm plans must
be proportionate, practical and scaled to risk.
“Farms
that are low-impact and low-risk should be able to complete
a simple, quick and easy plan themselves,” Hurst
says.
“We agree that higher-risk farms may need more
detailed plans, but there’s absolutely no point putting
low-impact farms through the wringer.”
The third
bottom line is that, while farm plans should be auditable,
not every plan should be audited.
“Many farming
activities are currently low-risk and don’t require
consents or ongoing oversight,” Hurst says.
“Requiring
those activities to have a farm plan, and then auditing that
plan, will put in place expensive red tape for absolutely no
environmental gain.
“It will waste time and money that
could be put to far better use improving the environment
rather than just ticking boxes and shuffling
paper.”
Hurst says certification may make sense for
higher-risk activities if it replaces the need for a
consent, but routine auditing of every farm sends the wrong
message.
“Audit-everyone systems don’t create a
high-trust environment. They simply create a box-ticking
culture and get farmers offside, rather than driving better
outcomes.”
Federated Farmers is instead advocating for
a model similar to the tax system.
“That means
everyone is expected to do the right thing, but only some
are audited, either randomly or where non-compliance is
suspected.
“That’s a fair, practical approach that
farmers can understand.”
The fourth bottom line is
that existing farm plans must be recognised.
“Many
farmers already have plans in place through industry
programmes or local catchment groups,” Hurst
says.
“Farmers have put real time, thought and money
into these plans because they care about water
quality.
“They shouldn’t be punished for being
proactive or early adopters.”
Federated Farmers wants
existing plans that meet minimum standards to be recognised
as equivalent.
“Forcing farmers to start again from
scratch would be a completely unjustifiable waste of time
and money,” Hurst says.
While the detailed regulations
are still to come, Hurst says expectations are
clear.
“Farm plans must be tailored to risk and, for
higher-risk farms, should become a genuine one-stop shop
that replaces permits and consents.
“That’s how farm
plans can actually work.”
Federated Farmers has put
these four non-negotiables to the Government in its
submission on the RMA reform, which you can read in full here:
(https://fedfarm.org.nz/Web/Policy/Submission/2026/February/Submission-on-the-NEB-Bill-and-Planning-Bill.aspx)
