The Ministry for the Environment’s Action for Healthy Waterways report predicts that some councils will face higher costs than others, particularly Canterbury, Southland and Waikato.

The predictions are that meeting new freshwater regulations will cost landowners $900 million and another $140m a year in annual compliance costs and loss of profits.

Forecast costs from the Ministry for the Environment (MfE) in the Action for Healthy Waterways policy, have been collated as follows:

Fencing 32,000km of waterways to meet new stock exclusion, regulations will cost $773m.

Loss of production from the 19,000ha in the three-metre riparian setback areas is estimated at $17m.

The MfE calculates fencing costs at $5/m for dairy, $14/m for sheep and beef and $20/m for deer.

But these suggested costs are much less than the costs calculated by the landowners.

A recent survey conducted in the Waikato region estimated the cost for drystock farms range from $300,000 to $785,000 and average about $800 a hectare.

The Te Tumu Paeroa trust which manages many blocks of Māori land in Taranaki, in its submission calculated the cost of a post and two wire fence at $10/m. With 130km to fence, the total cost will be $1.3m.

Stock exclusion rules for wetlands and waterways more than one-metre wide come into force in 2023 and the stock exclusion rules for slopes less than 10 degrees come into force in 2025.

MfE has said that there will be no exceptions; “The regulations require stock to be excluded from waterways and their margins by whatever means the stock owner decides is practical,” it said.

MfE also stated that the landowners will be responsible for weed control.

By 2025, every farm must have a specific farm environment plan, at a cost of $4000 each or $116m to the country’s 29,000 farmers and growers.

These must be audited every two years at a cost of $1500 a plan or $44m to the industry.

The annual cost of addressing environmental issues identified by those plans is estimated at $435m or $15,000 per property.

Intensive winter grazing rules come into force next year and if farmers cannot meet permitted activity rules, they will need resource consent at an estimated cost of $3000 per consent.

Councils currently spend $310m a year on freshwater management, but implementing the new policies will add a further $135m of costs mostly for employing additional staff ($31.5m).

Implementing other freshwater policies will cost councils a further $19.1m a year.

Improved human health from better quality water is calculated at $2.3 billion, benefits from water clarity and reduced sediment $123m and between $1.8m-$5.4m from less erosion.

The department acknowledges the policy could cost rural jobs and community services and the uncertainty causes increased mental health issues among farmers.

But it concludes the significant and lasting benefits of the policy will, over the long term, exceed the costs of transition and implementation.

These cost estimates are way below the actual costs being charged to landowners at present and are only expected to rise with the passing of time.

To predict that the cost of gaining a consent will be $3,000, annual audits will be $1,500, and farm environment plans will be $4,000 is ridiculous and in no way reflects reality. Current examples show these figures to be approximately half of the true costs being charged to farmers.

The estimates for implementing the new policies states that costs for employing more staff will be $31.5m but in the Waikato region alone with its 12,000 farmers, it has been estimated that the cost of extra staff could easily be as high as $10m and that is only one council out of many across the country.

If we assume that each farmer is going to require a consent to carry on their farming operations as they have been doing up to now, then there is going to be 12,000 new applications for consents that will need to be processed before we even look at the implementation of consent conditions/rules.

If we make a conservative assumption that each consent application will take one day to be processed (and this is probably a ridiculous assumption of the time required) then we are looking at 12,000 days to process all of these applications.

Working on the basis that there are 48 working weeks available each year and each week has 5 working days, it is going to take one person 50 years just to process all of these applications.

If they are to be processed in the twenty working day time frame required under the RMA then the WRC will need to process 600 applications every day. If these figures are extrapolated out across the whole country then there is not going to be enough productive workers left to generate enough taxes/rates to support this process and also allow our economy to survive.

Local Government New Zealand commissioned a report on the impact of the new rules on the Waikato region and the end result of the implementation according to that report is that 68% of Sheep & Beef farmers and 13% of Dairy farmers will leave the agricultural sector.

The report suggested that these farmers will be replaced by forestry operations and even if that were true (I personally disagree) the effect on the small rural communities from this gutting of the farming industries will still result in more rural ghost towns.

MfE’s predictions are that meeting new freshwater regulations will cost landowners $900 million and another $140m a year in annual compliance costs and loss of profits.

Yet the WRC in their initial costing of the implementation of PC1 which has virtually the same rules, predicted that the cost to the agricultural sector in the Waikato region alone would be $500 to $600 million dollars per year for the eighty year time frame of the proposed plan change implementation.

Big difference from the MfE figures which supposedly takes into account the cost to the agricultural industry country-wide.

The worst part of this whole debate around the costs of the implementation of these new rules is that all of the costs are non-productive and will only serve to increase the size of the non-productive bureaucracy across the whole country.

MfE states that the new rules will result in improved human health from better quality water, reduced sediment and less erosion.

The department acknowledges they could cost rural jobs and community services and the uncertainty causes increased mental health issues among farmers.

But it concludes the significant and lasting benefits of the policy will, over the long term, exceed the costs of transition and implementation.

Whilst this is a wonderful thought that the new rules will bring significant and lasting benefits, it is just not supported in any way by the facts.

In relation to improved water quality in the lower Waikato and Waipa catchments, the overall levels of sediment and erosion will never be controlled or even reduced until the noxious pest fish, Koi Carp, is eradicated.

Koi Carp by the nature of their rapidly multiplying numbers and their feeding methods are the main driver behind erosion of the banks and the sedimentation of our waterways in the lower Waikato and Waipa catchments.

The explosion of Koi Carp numbers not only exacerbates the erosion and sedimentation problems but they also lead to the extinction of indigenous flora and fauna within the waterways from both predation and the decrease in waterway health.

Koi carp contribute hugely to poor water quality and are a serious problem in New Zealand.

When they feed they stir up the bottom of ponds, lakes and rivers, muddying the water and destroying native plant and fish habitat. Koi carp are opportunistic omnivores, which means they eat a wide range of food, including insects, fish eggs, juvenile fish of other species and a diverse range of plants and other organic matter.

They feed like a vacuum cleaner, sucking up everything and blowing out what isn’t wanted. Aquatic plants are dislodged in the process and are unlikely to re-establish. Koi carp cause habitat loss for plants, native fish, invertebrates and waterfowl.

Even if we were to ban farming totally we would still have a problem with water quality from the effects of the invasive pest fish species.

So in relation to the Ecosystem Health as set out in the requirements of the NPS on Freshwater Management, surely Koi Carp must be addressed as they have a huge effect on the rivers from the damage they do. Along with Catfish they are one of the most rapidly multiplying invasive pests that have been released into the New Zealand environment.

In this post Covid economy NZ is looking to strategies to improve the health of the economy and the main way that this is going to be possible is through export earnings from agricultural production.

The last thing that we need is an accelerated implementation of the new rules that is going to negatively impact on the productive agricultural sector which provides a means of income and also security of food supply for our country.

What we're actually dealing with is the multiple impacts that humans are having on the waterways and if we really want to restore these water bodies to what we want them to be then we need to have fit for purpose legislation that still allows for all parts of society both Urban and Rural, to provide for their social, economic, and cultural well-being and for their health and safety as stipulated in the Resource management Act 1991, as well as allowing improvements to the environment to be made.

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