Updated 15 September 2001
Throughout 2020 the Central Government announced a range of new environmental policy reforms aimed at stopping the degradation of our river, lakes and streams and to reduce on-farm emissions. These included:
- National Policy Statement for Freshwater Management 2020 (NPS-FM) which will direct regional councils on freshwater management and discharges.
- National Environmental Standard for Freshwater Management (NESFM) which will be equivalent to the rules in a regional plan. These baseline rules will have effect when the rules in the relevant regional plan are less strict.
- He Waka Eke Noa the government/industry partnership on climate change to reduce greenhouse gas emissions.
- Repeal and replacement of the Resource Management Act (RMA).
It will be the role of local councils to update their environmental plans by 2024 to ensure they are giving effect to the these new reforms at a regional and catchment level.
Through amendments to the Resource Management Act, the government has mandated Fresh Water Farm Plans in order to standardise what farmers and growers need to do to assess and manage risks to freshwater.
The term Farm Environment Plan (FEP) will in time become an overarching title as we move to a more integrated approach of how growers assess their environmental risks and demonstrate measurable progress towards National and Regional environmental objectives relating to fresh water quality, Green House Gas (GHG) emissions and biodiversity.
The Ministry for the Environment is currently consulting on Fresh Water Farm Plan regulations (the rules). The consultation period has been extended because of the COVID-19 alert level changes and the new closing date for submissions has been extended to Sunday 26 September.
NZ Avocado is currently working through the proposed regulations and implications of Fresh Water Farm Plans and are making a submission on behalf of avocado industry stakeholders.
This submission can be found on the industry website and we encourage all growers to read the industry’s current knowledge of Fresh Water Farm Plans to become familiar with what will be required and ways to engage further.
What is in a fresh water farm plan?
New requirements mean avocado growers will need to show they are managing their orchards to protect freshwater quality.
Properties with more than 5 Hectares in horticulture production will need to identify how they are working towards improving freshwater outcomes in the areas of farm practice, ecosystem health and the wider catchment. A Fresh Water Farm Plan will need to show a risk and impact assessment and the steps being taken to manage or mitigate those risks.
Plan will require orchard level information including land uses, property maps and will need to recognise and consider:
- The risk factors of each orchard or block due to is characteristics and management;
- The risk factors of orchard geographical location;
- The understanding and management of inputs of water and nutrients;
- Understanding potential outputs/losses such as the amount of nitrate leaching
- Understanding nutrient surplus and efficiency use; and
- Identification and implementation of actions to mitigate risks
The government is working towards recognising the tools needed to support growers to meet the additional reporting requirements. Industry is working with government to develop or update nutrient budgeting tools (e.g. Overseer or SPASMO) fertiliser and emission reporting platforms and risk assessment frameworks.
How will they be implemented?
The avocado industry wants growers to be able to deliver their Fresh Water Farm Plan through established industry assurance programmes like GLOBALG.A.P. We believe this will drive efficiencies in processes, reduce costs and in many cases exceed any new requirements.
A new version (GLOBALG.A.P. Version 6) that will include a specific module on environment and sustainability to reflect global consumer demands . Version 6 will be mandatory for all export growers from April 2023 and like previous versions will have specific provisions regarding fresh water management.
Certifying fresh water farm plans
The government is proposing a certification step for individual Fresh Water Farm Plans. Certification is seen as a way to ensure that the requirements of Fresh Water Farm Plans are consistently applied and comply with national regulations, regional council rules and any resource consents.
The government is proposing that this is done by people appointed by regional councils after either going through training and accreditation at a national or regional level.
However, the industry’s preferred approach is that industry assurance programmes themselves are certified as meeting the requirements, instead of the additional step of a third party certifier. This would be a more comprehensive approach for the industry while also being an efficient and cost effective approach for growers.
However, if the Ministry for the Environment does not back Global.G.A.P. group scheme certification, Fresh Water Farm Plan will need to be certified by individual accredited certifiers.
The proposed auditor’s role is to assess the properties ongoing compliance with its Fresh Water Farm Plan – in the same way as GAP audits are conducted. Due to potential conflicts of interest it is proposed that individuals could be both a certifier and an auditor if they meet the standards for both however, they could not certify and audit the same Freshwater Farm Plan.
The government is proposing that Regional Councils appoint auditors to operate in their region who have already been accredited by an existing accreditation body or by establishing a specific national accreditation scheme for Fresh Water Farm Plan auditors.
NZ Avocado is again proposing the auditing model and auditors working within existing industry assurance programmes are used meet the proposed audit requirements.
When will fresh water farm plans be required?
The government is proposing that Fresh Water Farm Plans will be phased in between mid-2022 to 2025 and it is likely that orchards in at risk catchments will be a priority.
However, Fresh Water Farm Plans will not be required across the country all at once. Due available resources such as certifiers, auditors and advisors. Regional Councils would also need time to implement their Fresh Water Farm Plan systems while also going through the process of recognising industry run schemes.
What will a fresh water farm plan cost?
This will depend on the decisions that the government make and the recognition they provide to existing industry assurance programmes. More information will become available over the coming months.
Multi land users
While it is expected that there will be generic parts to a Fresh Water Farm Plan – including maps, identification of land use and environmental risks, at this stage it is likely that for multi land users there will be a requirement for individual freshwater plans. For example, someone who has avocados, dairy and kiwifruit on their property would have three separate plans – NZGAP (EMS), Fonterra’s Tiaki and ZespriGAP. There is still work to be done by the government and industry to ensure there is an integrated and efficient approach for multi land users.