FURTHER SUBMISSION

TELEPHONE 0800 327 646 I WEBSITE WWW.FEDFARM.ORG.NZ

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To: Bay of Plenty Regional Council

From: Federated Farmers of New Zealand – Submitter 116

Further Submission on: PROPOSED Bay of Plenty Regional Council – Regional Policy Statement

Date: 19 May 2011

Contacts: NEIL HEATHER

PROVINCIAL PRESIDENT ROTORUA/TAUPO

945 Paradise Valley Road, RD 2, Rotorua, New Zealand

P 07 357 2142

F 07 357 2908

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JOHN SCRIMGEOUR

PROVINCIAL PRESIDENT BAY OF PLENTY

466 Bush Road, RD 6, Pongakawa, TE PUKE 3368

P 07 533 3681

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Address for service:

GWYN MORGAN

REGIONAL POLICY ADVISOR

Federated Farmers of New Zealand

PO Box 447, Hamilton, 3240

P 07 858 0815

F07 838 2960

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·  Federated Farmers has an interest in the proposal that is greater than the interest the general public has. The grounds for saying that I come within this category are that:

Federated Farmers of New Zealand is a representative body for all farmers. The subject matter of the appeal is a matter of interest for the farmers of the Bay of Plenty Region, and they constitute a sector of the public at large. Federated Farmers is in an appropriate position to represent that interest.

·  We wish to be heard in support of our submission

·  If others make a similar further submission I would be prepared to consider presenting a joint case with them at the hearing.

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Where Federated Farmers submitted on the same variation point as any other submitter it stands by its original submission.

This Further Submission provides Federated Farmers views on points raised by other submitters in sections that are not already covered in our original submission.

Sub Point / Submitter Name / Section of Plan / Support/ Oppose / Reasons for submission
27 - 8 / Eastern Bay of Plenty Branch Royal Forest and Bird Protection Society NZ Inc / Whole Document / Support / re-organising to include all objectives, policies and methods in the same topic area being in the same section will be a lot easier to follow..
111 - 1 / Environmental Defence Society Inc / Whole Document / Oppose / Document structure is hard to follow.
24 - 4 / Winstone Aggregates / Address minerals and specifically aggregates. / Oppose / One Land use should not have priority over another.
126 - 1 / Fulton Hogan Ltd / Address minerals and specifically aggregates. / Oppose / One Land use should not have priority over another.
8 - 2 / Transpower New Zealand Limited / Appropriate provision for the ongoing operation and maintenance of the network, including
ensuring that lines can be accessed; / Oppose / Access should be negotiated with landowners.
30 - 1 / New Zealand Fertiliser Manufacturers' Research Association Inc / Whole Document / Support / Amend the Proposed RPS so that in relation to “sustainability”, greater recognition of the
benefits derived from development of natural resources, including land use, must be afforded.
42 - 2 / TrustPower Limited / Regionally
significant issues / Oppose / Regionally significant issues need to be identified through a formal process.
78 - 1 / Royal Forest and Bird Protection Society of New Zealand Inc / Whole Document / Oppose / The Proposed RPS should not adopt a “strong sustainability model” as identified in one publication and should define its own sustainability model that incorporates the whole communities needs and not just one sector.
78 - 2 / Royal Forest and Bird Protection Society of New Zealand Inc / Whole Document / Oppose / The proposed RPS Should not be as directive in nature.
78 - 3 / Royal Forest and Bird Protection Society of New Zealand Inc / Whole Document / Oppose / Use of the term enable is positive and a clear alignment with the RMA.
125 - 22 / Te Runanga o Ngati Awa / Hazardous substances and contaminated sites / Support / Contaminated sites are usually found within the rural environment. Given the potential land use restrictions and costs associated with remediation works it is vital that landowners have the opportunity to be involved in all discussions and decisions relating to these issues
130 - 7 / Hancock Forest Management (NZ) Ltd / Whole Document / Support in part / it is unclear from the relief sought whether the submitter is seeking to have SNA areas identified and mapped or whether it is simply a statement about the importance of consistency if scheduling of sites is determined to be the best planning approach in the future. Whilst Federated Farmers accepts the importance of consistency we do not support the scheduling of SNA’s via this process. A variation to the RPS would be required to ensure appropriate consultation with affected landowners and their representatives.
Part 1
134 - 2 / Horticulture New Zealand, Avocado Industry Council Inc, New Zealand Kiwifruit Growers Incorporated / Part 1 / Support
110 - 1 / The Energy Efficiency and Conservation Authority / Section 1.1 / Oppose / Delete the last sentence from Section 1.1, page 3, paragraph four; “Many people value the existence of natural resources and features in their own right,
and accordingly seek their protection.”
102 - 3 / Department of Conservation - East Coast Bay of Plenty Conservancy / Section 1.5.1 / Oppose in part / Does not require a variation - just amend the text to the operative NZCPS.
154 - 26 / Fonterra Co-operative Group Limited / Section 1.5.1 / Support / Amend the second paragraph of Section 1.5.1 to refer to the New Zealand Coastal Policy
Statement 2010 now being operative (and delete the reference to the 1994 document).
27 - 10 / Eastern Bay of Plenty Branch Royal Forest and Bird Protection Society NZ Inc / 1.6 Section 1.6 / Oppose / relief sought is inconsistent with the sustainable management principle of the RMA.
53 – 2 / Transition Tauranga / 1.6 / Oppose / it is inappropriate to limit the term ‘wellbeing’ based on one submitter’s interpretation.
118 – 11 / The Maori Trustee / 1.12 / Support / For reasons stated by submitter
10 - 3 / Tauranga Branch, Royal Forest & Bird Protection Society Inc / polices: IR 1B, IR 2B, IR 3B and MN B4. / Oppose / Protection and enhancement of vegetation is very broad ranging and has no consideration of private land owners and farming business needs.
Part 2
15 - 3 / Silver Fern Farms Ltd Rotorua / Part 2 / Oppose / Many amendments are required in part 2 of this RPS
28 - 2 / Lachlan McKenzie / Part 2 / Support / Federated Farmers supports the inclusion of a clear objective for economic growth for the region.
81 - 1 / Aggregate and Quarry Association of New Zealand / Part 2, Section 2.1 / Oppose / Federated Farmers opposes the inclusion of a new section 2.12 on mineral extraction and it will give one land use priority over another.
102 - 50 / Department of Conservation - East Coast Bay of Plenty Conservancy / Part 2 / Oppose
131 - 1 / Matariki Forests / Part 2 / Oppose / Federated Farmers opposes the inclusion of promoting forestry as it will give one land use priority over another.
131 - 2 / Matariki Forests / Part 2 / Oppose / Federated Farmers opposes the inclusion of promoting forestry as it will give one land use priority over another.
132 - 1 / Kaingaroa Timberlands / Part 2 / Oppose / Federated Farmers opposes the inclusion of promoting forestry as it will give one land use priority over another.
132 - 2 / Kaingaroa Timberlands / Part 2 / Oppose / Federated Farmers opposes the inclusion of promoting forestry as it will give one land use priority over another.
154 - 33 / Fonterra Co-operative Group Limited / Part 2 / Support / Federated Farmers supports the inclusion of a clear objective for economic growth for the region.
180 - 1 / Golden Bay Cement / Part 2 / Oppose / Federated Farmers opposes the inclusion of a new chapter on mineral extraction and it will give one land use priority over another.
25 - 1 / Western Bay of Plenty District Council / Section 2.1 / Oppose / Amend 2.1 Air quality to include the following paragraph: "At times primary production activities
will generate effects such as noise, odour and dust - residents living in the rural environment
should therefore reasonably expect amenity values to be modified by such effects" (or words to
this effect).
134 - 10 / Horticulture New Zealand, Avocado Industry Council Inc, New Zealand Kiwifruit Growers Incorporated, / Section 2.1 / Support / Add a reference to the current NZS 8409:2004 for agrichemical use.
155 - 1 / Ray and Liz Steiner / Section 2.1 / Support / Support outlining the necessary practices in farming such as effluent spreading, silage feeding etc and the expected and anticipated odour resulting from these every day farming practices.
25 - 2 / Western Bay of Plenty District Council / Section 2.1 / Oppose / Amend to add a reference to the current NZS 8409:2004 for agrichemical use.
94 - 4 / Pirirakau Incorporated Society - Environment Division / Section 2.1.1 / Oppose / Reverse Sensitivity Issues need to be assessed on a case by case basis. Existing use rights.
25 - 3 / Western Bay of Plenty District Council / Objective 1 / Oppose / Amend Objective 1 to read: "People and the environment are not adversely affected by
discharges such as odours, chemicals and particulates" (or words to this effect).
27 - 12 / Eastern Bay of Plenty Branch Royal Forest and Bird Protection Society NZ Inc / Section 2.2 / Oppose / Leave ‘enable’ as currently included.
78 - 6 / Royal Forest and Bird Protection Society of New Zealand Inc / Section 2.2 / Oppose / The cost of a review is prohibitive and we need a stable policy framework for landowners to work from on a long term basis.
84 - 3 / East Coast Bay of Plenty Conservation Board / Section 2.2 / Oppose / No variation required.
111 - 10 / Environmental Defence Society Inc / Section 2.2 / Oppose / This detail is for to prescriptive and is not required in a Regional Policy Statement
4 - 2 / Garry Webber / Section 2.2.2 / Oppose / Amend in the second paragraph of Section 2.2.2 so that the sentence beginning, "‘Sediment and
nutrients from earthworks, stormwater and agriculture ...", refers to sediment generated from
catchments under bush, scrub and native forest, and nutrient loading from domestic sewage.
This will accurately reflect the
findings of the recent Tauranga Harbour Sediment Study. The media release states 28% of the
sediment in the harbour is generated from catchments under bush, scrub and native forest.
25 - 18 / Western Bay of Plenty District Council / Section 2.2.2 / Oppose / Amend in the second paragraph of Section 2.2.2 so that the sentence beginning, "‘Sediment and
nutrients from earthworks, stormwater and agriculture ...", refers to sediment generated from
catchments under bush, scrub and native forest, and nutrient loading from domestic sewage.
This will accurately reflect the
findings of the recent Tauranga Harbour Sediment Study. The media release states 28% of the
sediment in the harbour is generated from catchments under bush, scrub and native forest.
32 - 3 / Northern Tauranga Harbour Action Team / Section 2.2.2 / Oppose / Amend in the second paragraph of Section 2.2.2 so that the sentence beginning, "‘Sediment and
nutrients from earthworks, stormwater and agriculture ...", refers to sediment generated from
catchments under bush, scrub and native forest, and nutrient loading from domestic sewage.
This will accurately reflect the
findings of the recent Tauranga Harbour Sediment Study. The media release states 28% of the
sediment in the harbour is generated from catchments under bush, scrub and native forest.
61 - 2 / Waikaraka Estuary Managers Incorporated / Section 2.2.2 / Oppose / Amend in the second paragraph of Section 2.2.2 so that the sentence beginning, "‘Sediment and
nutrients from earthworks, stormwater and agriculture ...", refers to sediment generated from
catchments under bush, scrub and native forest, and nutrient loading from domestic sewage.
This will accurately reflect the
findings of the recent Tauranga Harbour Sediment Study. The media release states 28% of the
sediment in the harbour is generated from catchments under bush, scrub and native forest.
134 - 15 / Horticulture New Zealand, Avocado Industry Council Inc, New Zealand Kiwifruit Growers Incorporated, / Section 2.2.2 / Oppose / Amend in the second paragraph of Section 2.2.2 so that the sentence beginning, "‘Sediment and
nutrients from earthworks, stormwater and agriculture ...", refers to sediment generated from
catchments under bush, scrub and native forest, and nutrient loading from domestic sewage.
This will accurately reflect the
findings of the recent Tauranga Harbour Sediment Study. The media release states 28% of the
sediment in the harbour is generated from catchments under bush, scrub and native forest.
85 - 10 / Te Tumu Landowners Group / Section 2.2.5 / Support / This statement does not recognise that effects of land use and development are or can be mitigated or remedied.
154 - 28 / Fonterra Co-operative Group Limited / Section 2.2.5 / Support in part / Amend Section 2.2.5 Issue 1 to read: ". . .is adversely affected by inappropriate land use and
development, hazard mitigation works, earth works, recreational activities, encroachment,
inappropriate grazing, changes in land use and the presence of pest plants and animals."
134 - 19 / Horticulture New Zealand, Avocado Industry Council Inc, New Zealand Kiwifruit Growers Incorporated, / Section 2.2.5 / Oppose / Leave wording as is.
155 - 2 / Ray and Liz Steiner / Section 2.3 / Support / Amend Section 2.3 to consider the adverse effects of utility networks.