On January 14, the federation statement said Environment Southland publicised its draft limits and targets for nitrogen, phosphorus, sediment, and E.coli load reductions in Southland’s rivers, lakes and estuaries.
"These draft limits and targets are based off science that has never been subject to a formal approval, consultation, or plan change process, and which lack consideration of economic and community factors (which is a requirement of both the RMA and National Policy Statement for Freshwater Management)," the statement said.
"It is deeply concerning that Environment Southland chose to publicise the limits and targets over the holiday period, and without detailed explanation of their context. Environment Southland did this despite months of pressure to release the limits and targets and explain their intent. To date, this has not happened.
"Beyond the timing, Federated Farmers has real concerns about how the targets have been arrived at, in particular the suggestion that the ‘Share Your Wai’ campaign a couple of years ago was the ‘community consultation’ that led to the setting of these extreme targets.
"Feds is also deeply concerned about the reasonability of these targets. This is an aspiration to return our waterways to pre-settlement quality without considering the effect it could have on the major flood control modifications that were implemented for the good of the entire community.
"This risks undermining existing efforts undertaken by farmers to improve water quality, as people may disengage, and reduces the confidence that other businesses and financiers require to invest and participate in the rural sector."
Much of the E.coli in Southland was due to birds, exists naturally, and is of a reduced health risk, the statement said.
It also criticised how other targets were calculated and presented.
"Environment Southland are now saying that the targets are not final. Your provincial executive intends to hold them to that.
"Genuine community consultation is required to ensure that values are determined in consideration of costs. While there are costs and benefits that are not financial, the old adage, ‘you can’t be green if you’re in the red’, applies as strongly to the province as it does to individual businesses."
In reply, Mr Horrell said the federation’s statement could lead to confusion in the community.
"Let’s be quite clear, Environment Southland has not put out any new information over the holiday period, nor have we announced any draft limits or targets," he said.
"Environment Southland, in partnership with Te Ao Marama, continue to work towards improving freshwater — with specific processes and timelines laid out in the National Policy Statement for Freshwater 2020.
"The community has also made it clear that they want to see improved water quality in our region, evidenced by feedback provided during our community engagement events such as the Share Your Wai campaign."
The council has compared its assessment of the region’s environmental health with its draft freshwater goals, Mr Horrell said.
"A significant improvement on the current state of waterbodies is signalled, rather than any return to a pre-European state.
"Recently, we’ve modelled the reductions in contaminants from waterways that could be required to meet these draft objectives. The numbers from this modelling provide a sense of the scale of change needed but they are NOT limits or targets.
"We are required to develop limits and targets, and these will be included as part of updating the proposed Southland Water and Land Plan. We’re aiming to notify this at the end of 2023."
Before then, the council would draw on environmental science, economical analysis, and Maori knowledge and give the public opportunities to be involved and provide feedback, Mr Horrell said.
"Environment Southland and Te Ao Marama Inc have been sharing this science information directly with various groups since October, and will continue that approach through this year. This included a briefing to the Federated Farmers executive at the start of November and a number of presentations to catchment and stakeholder groups and community boards. More are scheduled for this year.
"By sharing this information now, our intention is to build on good actions already under way in the region, including the work of catchment groups.
"The numbers from this latest science modelling are confronting," Mr Horrell said.
"It’s important that people take the time to understand this information; think about their own activities whether they be on farm, business or in town, and look at any improvements that could be made.
"The scale of change needed over the next 25 years is significant, but getting started now and working together will make this challenge far more achievable."
Mr Horrell encouraged people to read the relevant information on its website, join their local catchment group, or contact the council if they have questions.
