Submission on dairy farm applications near Omarama, Mackenzie Country
Dr Russel Norman MP
Green Party Co-leader
Parliament, Wellington
04 817 6712
russel [dot] norman [at] parliament [dot] govt [dot] nz
I submit on these consent applications to collect, store and discharge effluent to land:
· Williamson Holdings Ltd - CRC100227, CRC100475, CRC100478, CRC100479 & CRC101541
· Southdown Holdings Ltd - CRC100224, CRC100480, CRC100481, CRC100482 & CRC101542
· Five Rivers Ltd - CRC100787, CRC100788, CRC100824, CRC100827 & CRC101540
I ask the commissioners to DECLINE all these applications.
I wish to be heard in support of my submission.
Reasons for opposing applications:
Principles of the Resource Management Act
I consider that these applications are contrary to the principles of the Resource Management Act. They are contrary to the Section 5 Purpose: promoting "sustainable management of natural and physical resources". They are contrary to S6 Matters of National Importance: requiring the protection of "outstanding natural features and landscapes from inappropriate…development" and the protection of "areas of significant indigenous vegetation and significant habitats of indigenous fauna". The applications also fail to have regard to S7 matters, particularly the "intrinsic values of ecosystems" and "maintenance and enhancement of the quality of the environment".
Water quality
The consent applications include effluent ponds with 414 million litres of storage capacity and plans to put as much as 1.7 million litres of diluted effluent onto the land every day. 18,000 dairy cows will produce the effluent equivalent to a city of 270,000 people in the Mackenzie Country.
The sheer volumes of effluent being collected and dispersed mean that there is no way the applicants can guarantee that the effluent will not enter and affect the streams, rivers and lakes of the Upper Waitaki catchments and their ecosystems.
This is an area that is completely unsuitable for intensive dairying - the soils are thin overlying gravel aquifers and their the ability to maintain normal function in the wake of large sustained effluent disposal may be compromised, meaning that nutrients will inevitably be transported to downstream systems.
Lakes Benmore and Aviemore, so important to the local community and tourists alike for fishing and recreation, are likely to be contaminated with effluent and nutrient runoff. The water in the Waitaki is already heavily reduced from extraction and extra nutrients may lead to re-concentration of nitrates to unacceptable levels in the lower river system.
Environment
The Mackenzie Country is an iconic brown tussock landscape. This unique and fragile environment will be radically altered by irrigation and intensive dairying.
The special character of the Upper Waitaki is already under pressure from introduced species and pests. This means it is critical that the delicate balance of this environment is not subject to the multiple pressures that would arise from large-scale intensive dairying.
Instead the area should be protected and enhanced for its unique character: its role as important habitat for threatened species such as the black-fronted tern and black stilt, and the critical ecosystem services it provides.
I realise that the following concerns are mostly outside the scope of the applications currently before the commissioners. However, I feel it is important to address them in my submission as the individual components of this proposed land-use change cannot be assessed in isolation, so significant are their implications.
Animal health and welfare
It is cruel to house cows indoors for 8 months of the year and 12 hours a day during summer. Animals confined in such close quarters are at greater risk of injury and infection that is likely to need controlling with antibiotics.
There is an outcry from the public about the proposed expansion of intensive indoor farming to dairy cows, given the recent controversies over these farming methods in relation to chickens and pigs.
Tourism and international brand
The Mackenzie Country is a major drawcard for international tourists, and is the gateway to Aoraki / Mt Cook National Park. Over 200,000 international tourists visit the National Park each year.
New Zealand's tradition of farming animals outside and on pasture is integral to our clean, green image and our competitive advantage. News that New Zealand dairy products come from factory-farmed cows will undermine our international brand, which is unfair to the many good farmers who are farming sustainably.
This is not the clean, green and ethical product that our overseas markets are seeking, and does not represent a sustainable future for our dairy industry, either in environmental or economic terms.
Carbon footprint
The factory farms are likely to be heavily reliant on supplementary feed being trucked in from elsewhere, resulting in a significant carbon emissions. It is likely that feed will include palm kernel expeller (PKE), which contributes to deforestation in South East Asia and is already bringing the dairy sector into disrepute through its growing use in intensive farming.
Finally, I call on Environment Canterbury to request that the Minister for the Environment call in the applications for hearing by a board of inquiry, under section 142 of the Resource Management Act.
If that course of action is not able to be taken, I request that the consent process is at least delayed until the Government's collaborative governance process (the Land and Water Forum) is resolved.
