PC1 is the first step in an 80-year programme to restore and protect the water bodies in the Waikato and Waipa River catchments including rivers, streams, lakes and wetlands.
PC1 regulates the discharge of four major contaminants in the catchments: nitrogen, phosphorus, sediment and microbial pathogens (primary contaminants).
Under PC1 farming in Whangamarino Wetland catchment is to become a Restricted Discretionary Activity and will require Farm Environment Plans to be developed, which will provide evidence that farm practices take into account the significance and sensitivity of the Whangamarino Wetland.
This requirement has been confirmed in the interim decisions related to the appeals of Plan Change 1 in the environment court.
WRC in their initial costing of the implementation of PC1 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.
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.
It is claimed that the new rules will result in improved human health from better quality water, reduced sediment and less erosion, but what is not being said is that they could cost rural jobs and community services and the uncertainty is already causing increased mental health issues among farmers.
What has also not been said is that 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/controlled?
Koi Carp must be addressed as they have a huge effect on the waterways and 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 nation’s 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.
The proposed rules would appear to add to production costs rather than add to measurable outcomes. This is particularly true when you read the interim report from the Environment Court and find that there is no mention anywhere in that 376 page report, of controlling/eradicating koi carp- the number one enemy.
When it comes to making a discernible impact on improving water quality in the catchment then the effects from Koi Carp must be taken into consideration.
The true fact is that without an achievable eradication/control plan for Koi Carp then reduction in sediment and erosion effects will never be realised and in fact the levels of both sedimentation and erosion of the waterways and watercourses will only get worse.
Failure to control or eradicate Koi Carp will also lead to a reduction in the levels of indigenous flora and fauna and over time will more than likely lead to mass extinction of native species of both flora and fauna in, and on the margins of, the waterways.
The eventual outcome will be that the deleterious effects from Koi Carp will far outweigh any benefits that may be gained from the farming sectors under these new rules.
It has been suggested that the implementation of the new rules under PC1 will result in approximately 60% of Sheep & Beef farmers and 13% of Dairy farmers leaving the agricultural sector and will most likely lead to increased loss of productive land eventually resulting in upward costs of food production and reduced security of supply.
Given the failure to implement strategies to eradicate/control Koi Carp, the proposed rule changes would appear to add to production costs rather than add to improvements in water quality.
Back in 2017, Dr. D C Edmeades & Mr. F Philips from agKnowledge Ltd prepared a report on the Lake Waikare & Whangamarino Catchment Plan for the Primary Stakeholders Catchment Trust.
The Primary Stakeholders Catchment Trust (PSCT) which was established by landowners in the Lake Waikare-Whangamarino catchment to facilitate their involvement in the development of a Catchment Management Plan (CMP).
The Trust asked agKnowledge Ltd to:
It has been acknowledged that there are some issues relating to the internal management of the Whangamarino Wetland and Lake Waikare, which indirectly affect land management and farming, in the wider catchment, because they may influence the water quality targets set for the sub-catchments. Of particular importance are:
Water quality measurements taken from the WRC Technical Report 2015/15 show;
The total P load discharged at Island Road is about 32 tonnes/year of which 21% is derived from the Matahura sub-catchment and 14% from the catchment above Jefferies Road.
Thus the two predominantly farming catchments (above the Jefferies Road and the Matahura sites) contribute about 35% of the P load leaving Whangamarino Island Road site. By difference about 65% is coming from Lake Waikare and the Whangamarino Wetland
Notwithstanding the limitations in the data available, several conclusions can be drawn from analysis of that data:
Given that as shown by the WRC report data, about 65% of the P loading is coming from Lake Waikare and the Whangamarino Wetland and taken in conjunction with the other findings, the focus on controlling farming and ignoring the Koi Carp issue is in fact not addressing the main cause of the water quality issues in this catchment.
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 and they burrow away at the banks causing erosion7 as well, so they contribute to poor water quality in a number of ways. 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.
This habit means that, at high densities in shallow lakes, they can greatly increase the turbidity of the water because they are constantly disturbing the substrate. This makes waterways unattractive and reduces the abundance of aquatic plants, invertebrates & native fish.
This cause of erosion is a major contributor to the elevated levels of phosphorous and sediment in the waters being discharged from the Lake Waikare-Whangamarino catchment.
The Koi carp population has exploded, and they now make up approximately 80% of the total biomass3 in the lower Waikato river catchment. It has been estimated that there are approximately 500,000 tonnes of Koi Carp in the lower Waikato Catchment.
Koi carp prefer still waters, spreading from rivers into lakes, streams or backwaters in rivers. They are highly tolerant of poor water quality – surviving well in degraded water and contributing to the decline.
Waikato Koi carp rarely exceed 9 years of age. Females average 5.2 years and males 4.6 years of age. An average fish weighs 3 kg. Females produce 100 000 eggs per kg of body weight. A typical female can produce 300 000 eggs annually (or more if they spawn11 more than once). Koi carp spawn throughout the summer. As they gather for spawning12 or feeding in the shallow margins of the river, koi biomass can reach 4000 kg/ha.
Koi carp have no natural predators in NZ waters and this exacerbates the problem by allowing them to breed until the biomass reaches a level where the food chain cannot support any further increase in numbers of Koi carp.
Koi greatly increase the turbidity of the water because they are constantly stirring up the substrate. This makes waterways unattractive, reduces the abundance of aquatic plants, and can render the water unsuitable for swimming or drinking, even by livestock.
Most likely farmers in the Lake Waikare - Whangamarino Catchment will have to apply for a Restricted Discretionary Consent which may impact adversely on their decision-making ability.
In the years since PC1 was first set out for consulting on and eventually notified, farmers in this catchment have continued making improvements to their management practices. One only has to look at the requirements dairy farmers now face just to supply milk to the Milk Companies and meat producers must meet to supply stock to processors.
Given this, a lot of PC1 requirements surely are already being met. For instance, stream fencing on dairy farms is mandatory practice, nutrient management, e.g. Fertiliser is much more strategically used (Note Ballance Fertiliser Company which reports increased use of speciality mixes designed to limit runoff along with strategic limited use of Nitrogen)
The Sheep & Beef farmers too have not been stationary, planting along streams, ensuring that cattle are kept well away from critical source areas, and managing stocking rates to suit land type while vegetable growers too have to meet stringently imposed market audits.
I hoped that the Environment Court would have considered these changes, considered the current proposed legislative changes to Freshwater Policy and RMA reforms and recommended the use of self-developed Farm Plans that do not require overbearing external audit requirements.
I understand that WRC is currently looking at the Court Recommendations and will make its decision prior to 25th July.
My hope is that the Council (which is the ultimate decision-maker) firstly recognise the improvements to farming practices that are ongoing and secondly allows the current community consultation they are funding (Lake Waikare/Whangamarino Action Plan Committee) to provide economically sound, evidence-based recommendations for consideration.
This Community Committee is attempting to build an Action Plan to piggyback on the earlier Catchment Management Plan that was agreed amongst the Catchment Stakeholders. Numerous ideas are emerging for consideration.
If any of these are found to make a discernible impact on improving water quality in the catchment (such as controlling/eradicating koi carp- the number one enemy) then surely Council must back the Community.
I’m also concerned that imposing restrictive regulatory burdens on this Catchment will lead to rapidly increased loss of productive land eventually resulting in upward costs of this food produced within the catchment, - Vegetables, Grain production, Milk products, along with Meat & Wool production.
A responsible approach would therefore see Council recommending ‘Permitted Status’ as at present to continue until such evidence-based recommendations are presented and debated and ratified.
Alongside this Status, Council should increase support for Catchment led groups who are making a measurable difference. Many excellent examples are springing up around New Zealand including within our region, where measurable impacts are documented, unlike the proposed bucket load of regulations that appear to add to production costs rather than add to measurable outcomes.
New Zealand farmers are some of the World leaders in picking up and embracing new technology that leads to better long-term sustainability.
The current PCI regulations even stop agriculture making sensible decisions such as changing land use to better suit the needs of the region.
Farmers in our catchment like all other food producers already have market/consumer led quality control and environmental requirements to meet.
So to me the big question is “Will the Councillors back the food producers and support continued self-improvement, backed by market pressures, or will Councillors instead impose unnecessary bureaucratic driven regulations? “
Farming has had an impact on the natural environment over past years and will continue to do so but it must be acknowledged that in recent times, particularly the last decade, farming practices have improved and the impacts on the environment have been severely reduced.
NZ exports enough agricultural production to feed approximately 40 million people worldwide, but if we want to continue to both supply food and make an income from the land then we need to balance those ideals against the impacts on the environment and accept that there will be some changes needed to the natural environment to allow this to happen.
The agricultural industries understand and fully accept that there is a need for some regulation of their activities to ensure the protection of our environment and our waterways, but they are opposed to unnecessary bureaucratic driven regulations.
On the other hand Koi Carp will continue to breed and degrade our waterways through their natural feeding methods until either the food sources stop any further increases in numbers of the water becomes so polluted that even Koi Carp can’t survive in them.
We must address the problems of Koi carp as well as farming, if we wish to improve the water quality in our lakes and waterways.
It is the failure to address the problem of Koi Carp and other pest fishes, which makes me state that both the WRC and PC1 are failing to address the primary task of improving the water quality in our lakes and waterways.
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By Andy Loader, Poke the Bear