Federated Farmers is constantly working on advocacy issues and projects which impact on farming in New Zealand. We have a National Council representing all 24 provinces and a Board who work specifically on each of these issues as well as a large team of staff.
Federated Farmers has 13,000 members, farmers and growers producing a wide range of products across the country. We also have a ‘lifestyle’ farm membership designed to help small block landowners understand their obligations, and how to handle them.
Here are the national issues we are tackling at the moment.
He Waka Eke Noa & pricing agricultural emissions
The HWEN partnership, which included Federated Farmers, published its final recommendations report in the first week of June 2022. Though HWEN’s scope shrank throughout its development (namely via losing involvement of government) the goal remained to present a means of pricing agricultural emissions all industry groups could agree to.
All groups involved made concessions. For Feds the justification in remaining involved HWEN’s proposal would still leave farmers better off than having their emissions priced via the Emissions Trading Scheme.
In October 2022 government released their response to the HWEN proposal, and it would be fair to say Federated Farmers was disappointed by the response. Feds does not support pricing agricultural emissions as outlined in the October 2022 Pricing Agricultural Emissions: Consultation Document.
A couple of key changes made the proposal unacceptable to Feds.
The government’s proposal entirely removed the opportunity for farmers to use sequestration to balance their emissions budget on-farm. It also removed a number of conditions required to set a price, down to just achieving the emissions reduction targets. In the HWEN proposal the committee setting the price would have been required to consider the impact on food production and farm business sustainability. As opposed to achieving the targets at any cost.
The Federated Farmers media release about the government proposal can be read here. We made the point that the government’s own modelling in the consultation document showed 20% of sheep and beef farmers would go broke, and up to 5% of dairy farmers.
Federated Farmers and the HWEN partnership
Feds continues to be a partner in the HWEN group but did choose to make its own submission on the consultation document, and therefore did not align itself with the HWEN partnership’s submission.
Feds wanted to use this submission to again highlight it only supports the pricing of agricultural emissions in New Zealand if any pricing mechanism is based on a scientific target for methane based on no additional warming by 2050, exclusively incentivising viable and cost-effective mitigation options that are available to New Zealand farmers, and an assurance no emissions leakage or reductions in food production occur.
Our submission’s position was informed by and is consistent with the results of a member survey, which received 2,175 responses (see Appendix 1 of our submission for the results).
Emissions reduction plan
Feds responded to the release of the government’s Emissions Reduction Plan just before the Budget was released in mid-May. We were pleased the government recognised solutions to agricultural emissions lie in new technologies and tools, and is stepping up investment on that front.
Nitrate and methane inhibitors, gene editing and animals bred for their lower methane ‘burping’ are the kind of advances which will enable our sector to continue to perform for the economy while maintaining our world-leading meat and dairy carbon footprint.
It will be important to understand how the proposed new Centre for Climate Action on Agricultural Emissions fits with existing bodies such as the NZ Agricultural Greenhouse Gas Research Centre, the Pastoral GHG Research Consortium (PGGRC) and the international bodies New Zealand partners with such as the Global Research Alliance. NZ farmers have been funding millions of dollars into greenhouse gas mitigation tools since 2003 via the PGGRC.
Feds again make the point that serious investigation and society-wide discussion is needed on the role genetic technologies – particularly gene editing – can play in the thorny environmental issues confronting us. Feds supports giving food producers and consumers the choice with gene editing technology.
Feds advocates for a targeted catchment approach for managing water resources. Work has been done on the Essential Freshwater regulations “fixes” in 2020 and 2021, and in June we were pleased with a number of changes announced by the government, in particular regarding winter grazing conditions and wetlands. However, we still feel significant aspects of the regulations are unworkable and represent regulatory overreach. The challenge for the water team in 2022 is creating the operating space and comfort for Ministers and officials to drop the worst aspects of them and tweak and change the others. We are also part of the Freshwater farm plan group but progress is slow.
We continue to see major problems for farmers with the National Environmental Standard for Drinking Water. In March we submitted to the Ministry for the Environment on the proposed changes, which would extensively protect drinking water sources. We want more thought to go in to how to standardised definitions of source water areas, strengthen regulation of activities around water sources and include more water suppliers under the NES-DW.
Winter Grazing Regulations
The Government’s Essential Freshwater regulations require that winter grazing of forage crops between 1 May and 30 September fall into one of the following three pathways: Meet minimum criteria relating to size, slope, be no closer than 5m to a water body or wetland, and not be in a critical source area; Have a certified freshwater farm plan; and gain a restricted discretionary resource consent.
In April 2022 ministers were still saying they expected certified freshwater farm plans regulations to be ready this year.
Federated Farmers, alongside DairyNZ and Beef Lamb NZ, wrote to Minister David Parker and requested a delay to these regulations.
Minister Parker has now replied stating that no delay will be granted and that he does not believe many farmers will require a resource consent.
Feds has made a detailed request to both the Minister and Ministry for the Environment for information they hold that supports these assertions.
Resource Management Act (RMA) Reform
Feds advocates for targeted changes to the RMA without re-inventing the wheel. Last year Feds submitted on an exposure draft of the Natural and Built Environments (NBEA) Bill. While the Select Committee recommended some changes to this draft we consider these do not go far enough and do not appropriately provide for rural activities. In February Feds provided a comprehensive submission on these proposals, together with detailed case studies to illustrate how farms are currently regulated (at a national, regional and district level) and to demonstrate our concerns with the proposals.
A full draft NBA was referred to Select Committee in the last quarter of 2022. Feds has written a comprehensive submission on the Bill. Our key concerns relate to changes to permitted activities, consent activity classes (e.g., there would be an ability to decline controlled activity consents and greater use of prohibited activities) and compliance, monitoring, and enforcement (e.g., the use of insurance for prosecution would be prohibited and it is proposed to significantly increase fines).
The government introduced the Natural and Built Environment Bill and Spatial Planning Bill in late November. The two bills contain a new resource management framework to replace the RMA. Submissions on the bills closed in February 2023.
Our assessment is that the bills would be a major step backwards for New Zealand. Little is contained in the bills that would make the consenting process
faster, cheaper, and more predictable. The bills also do not contain mechanisms to allow regional councils to make appropriate trade-offs between environmental and economic concerns. Meanwhile, a host of new terms are introduced that will take a decade for courts to interpret.
Noting that there will be a big transition cost in moving from the current system to the new, our view is it is better to keep the existing RMA framework while further work is done on a replacement than rush this framework through.
A review into the Future for Local Government is underway. The review is considering roles, functions, and partnerships; representation and governance; and funding and financing. A report to the Minister is due by 30 September 2022 followed by formal consultation and a final report in April 2023.
In terms of the ‘Three Waters’ proposals, Feds continues to point out the impracticalities of the attempts to regulate very small rural water supplies. However, we were pleased with many of the recommendations made by the rural water supplies working group set up by the government to consider the issues around ownership and maintenance of private and community-owned water supplies schemes.
Local authority elections were held in October 2022. On 14 July, the day before nominations opened for the elections, Federated Farmers launched its Local Elections Platform. The Platform discussed the rising cost of local government, rates, Three Waters, roading, freshwater management, RMA reform, and local democracy. Voting closed on 8 October and final results were released on 13 October.
Federated Farmers congratulates all members of Feds who were elected to local bodies.
Feds advocates for preserving biodiversity and supporting existing efforts while avoiding unnecessary restrictions on farming activities. Farmers manage and protect biodiversity on private farmland, as 24% of NZ’s indigenous biodiversity remains on privately owned sheep and beef farms.
In June the latest exposure draft of the National Policy Statement for Indigenous Biodiversity was released, with only a six-week period to submit – far too short for such a significant and complex issue. In particular we will be checking that the ‘Significant Natural Area’ criteria in the previous draft has been set correctly, and the NPS wont capture too much farmland and everyday biodiversity as ‘significant’. We also need greater surety around existing use rights and what farmers can and cannot do without consent.
We also noted in our media release at the time the totally inadequate amount set in the Budget, $20 million spread over five years, to fund the support required for this strategy to be implemented successfully. We consider a figure of $150 million to be more likely.
On November 3, Feds submitted on the Increased Penalties for Breach of Biosecurity Bill.
A robust biosecurity regime assists our farmers and growers in maintaining a positive reputation for their product when exporting and trading. It additionally allows for the continued significant earnings that the food and fibre sector provides to New Zealand’s economy ($52.2 billion in export earnings for the year to June 2022 according to the Ministry for Primary Industry).
Feds agrees with the proposed increased penalties from $400 to $1,000, an increase in the conviction fine to $2,000, and providing biosecurity officers a stronger ability to refuse entry into New Zealand to people who knowingly bring in a biosecurity risk when attempting to enter on a temporary entry class visa.
While many farmers are keen to plant more trees on their land, the cumulative effects of government policies are distorting the market with serious impacts on rural communities. This concern has sharpened its focus on carbon farming in particular, as it dwarfs the land use returns of equivalent sheep and beef operations.
Federated Farmers recently submitted to MPI on ‘Managing Exotic Afforestation Incentives’, highlighting that while proposed policy changes would make permanent carbon-only pine forestry less attractive it would not restore a level playing field to land use decision making.
On 30 September 2022 Federated Farmers submitted on the Government’s Draft Forestry and Wood Processing Industry Transformation Plan. Frustratingly, the draft plan states “Work is needed to help people understand the benefits of forestry and wood processing, how the sector works, and the value of its products”.
Our submission assures the Government that Feds, farmers generally, and rural communities understand the forestry and wood processing industry and its impacts perfectly well. We submit that meaningful structural policy change is needed to restore the forestry sector’s social licence to operate, not a public relations campaign.
On November 18 Feds submitted on the National Environmental Standards (NES) on Plantation Forestry. The NES on Plantation Forestry is designed to:
- Manage the environmental effects of all exotic carbon forests
- Control the location of afforestation (plantation and exotic carbon) to manage social, cultural, and economic effects
- Improve wildfire management in all plantation and exotic carbon forests
- Address the most important findings of the Year One Review of the NES-PF (National Environmental Standards for Plantation Forestry) regulations.
Immigration and labour supply
After significant lobbying by Feds the government created a pathway for farm workers with visas living in New Zealand to gain residency. Since the first COVID-19 lockdown we have worked continuously to signal to the government the importance of our rural international workforce to keep the primary industries running. These efforts culminated in the 2021 Residency Visa, which is available for the majority of migrants working in agriculture in New Zealand from 29 September 2021 who meet health and character standards. All applications must be made by 31 July 2022.
There are continued reports of the difficulty of recruiting staff, both migrants and New Zealand citizens. The migrant labour market is continuing to be highly mobile, with many employers offering higher hourly rates and the last of three-year Essential Skills visas to attract workers. The FarmSource website currently has over 1,200 dairy roles advertised, a significant increase from the 800 earlier in the year. Official figures for unemployment are at 3.2%, the lowest since 1986.
The Animal Welfare Amendment (Banning the Export Livestock by Sea) Bill passed its second reading in May and is likely to be passed by the end of the year. This will bring into law the ban on exporting livestock by sea and will come into effect on 30 April, 2023. Federated Farmers had earlier submitted to the Primary Production Select Committee supporting the continuation of the livestock export trade and taking the opportunity to lift standards and continue to lead the world in animal welfare.
Feds advocates for farmers to maintain best practice animal welfare practices with regulation that is practical. The draft of the Dairy Cattle Code has been released for consultation and has raised concerns. Feds made a comprehensive submission which, while acknowledging that welfare standards are evolving, concentrated on making sure that are any changes are affordable, practical and make a real difference to livestock welfare.
A draft of the Code of Welfare for Pigs was recently out for consultation. Our submission supported NZPork’s stance and questioned the National Animal Welfare Advisory Committee (NAWAC) process used to develop the draft.
There is increasing pressure to minimise bobby calves from the industry including a Fonterra directive that all non-replacement calves shall enter a value stream from next year as beef, calf-veal or petfood. We continue to watch this space.
Many farmers have been concerned about behaviour of some livestock agents and feel the industry needs to be regulated. We have worked with OSPRI to develop a NAIT standard (Registration of Entities Trading in NAIT animals) which lists required behaviours and responsibilities stock agents are expected to meet and includes complying with the NAIT Act. We had been given an undertaking along with the Minister of Agriculture that this standard will be implemented this year.
Feds also provided pre-consultation feedback on the draft of the Sheep & Beef Cattle Code. Public consultation is expected soon.
Feds advocates for cost-effective and modern rural connectivity solutions, and for more funding to expedite its implementation. Feds meets regularly meet with MBIE and MPI officials to discuss issues around improving rural connectivity and specific work actions that would help progress a remote user scheme that would see the government provide grants to extend coverage to those that would be missed under Rural Broadband Initiative (RBI) and similar rollout programmes. Arising from these discussions is the Budget 2022 announcement of $60m being allocated for rural connectivity over the next three years.
Coverage, reliability and speed of mobile and internet services for many farming families and businesses are treading water, if not going backwards, the 2022 Federated Farmers Rural Connectivity Survey found – it was released in September.
More than half of the nearly 1,200 farmers who responded to the survey report internet download speeds at or less than what could be considered a bare minimum (20 megabytes per second/Mbps) and those who said their mobile phone service had declined in the last 12 months jumped from 20% to 32%.
Additional consumer-centric questions were added in this year’s survey to better understand relationships with service providers. Special questions this year focused on health, safety and wellbeing implications from poor connectivity.
Feds advocates for better employment conditions and compliance on-farm, and for legislation allowing a flexible labour market. The Fair Pay Agreements Bill was introduced in April and it is being considered by the Education & Workforce Select Committee. On 19 May Feds submitted in opposition to the Bill and presented our submission to the Select Committee on 20 June.
We have no interest being involved in compulsory nationwide pay agreements and believe the best value lies in ensuring good employment practices continue across the sector.
Consultation is underway on the Minimum Wage for 2023/24. On 23 September Federated Farmers submitted in opposition to any increase on the grounds that the minimum wage should be an entry level tool for the industry and that average wages are increasing considerably across the sector.
Federated Farmers sits on both the Governance and Operational Groups overseeing the National Wallaby Eradication Programme. Two main populations of wallabies are found – Dama wallabies in the North Island (centered on BOP) and Bennett’s wallabies in the South Island (centered in Waimate and Bank Peninsula).
MPI runs the programme with funding of $27.4 million over five years (2020-2024) to control the spread of wallabies and reduce their numbers with the ultimate objective of eradication. A draft strategy for the programme includes research on toxin trials, developing surveillance tools and better understanding of the wallaby’s home range and habitat selection. Publicity has started to encourage people to report wallabies found outside containment areas.
Economics and commerce
Federated Farmers’ latest Farm Confidence Survey was undertaken in July 2022, with results released in August. Although most farms are currently profitable thanks to high farmgate prices, farmers are deeply negative about the general economy and expect their profitability to fall over the next year. Production expectations also fell into negative territory while spending expectations continued to surge on the back of higher farm input prices. Relatively fewer farmers expect to reduce their debt while labour shortages also remain acute. Government policies and regulation continue to be the biggest concerns for farmers, followed by input costs. The next survey will be undertaken in January 2023.
In January we submitted on the Budget Policy Statement urging responsible fiscal policy and a focus on policies to strengthen the economy.
In April we submitted in opposition to the proposed income insurance scheme for unemployment, which would be funded by a ‘levy’ on wages and salaries.
Agricultural debt amounted to $61.4 billion in April 2022, down 1.0% on April 2021. Dairy farming has faced the brunt of the squeeze on lending, with horticulture lending up strongly. Our Banking Survey in May showed farmer satisfaction slipped compared to the previous survey in November 2021, there was a slight increase in those perceiving undue bank pressure, and average interest rates for mortgages and overdrafts increased. The next survey will be in November.
Feds advocates for a trade policy that restores public and political consensus for trade liberalisation. We advocate for less tariffs on our exported products and less protectionism in our export markets.
Feds monitors the progress of various Free Trade Agreement negotiations between New Zealand and our trading partners, plus FTAs which affect us indirectly. There are several in different stages of negotiation at present, some of which we’ve submitted on where necessary to influence the desired outcomes above.
There has been a recent uptick in noise regarding the conclusion of negotiations on an European Union NZ FTA. In early June the Dairy Companies Association New Zealand and the Meat Industry Association issued press releases expressing alarm at rumours that the EU is refusing to offer an ambitious and comprehensive market access offer. Market access for meat and dairy are the most challenging issues. The protection of geographic indications (GIs), such as feta cheese, prosecco wine and scotch fillet steaks, is important to the EU and could hinder any deal.
Firearms & Crime
Feds want farmers to be able to use guns responsibly for on-farm applications like pest control. We advocate for rules around firearms that are practical and sensible. The largest change impacting farmers from firearms control laws enacted following the 2019 Christchurch mosque shooting is the requirement to register guns held by a licence holder if held for more than 30 days. This will apply from 2023 and we are in the working group for the implementation of this new requirement.
We submitted on proposals to clarify responsibilities for those who use or sell guns under the Arms Act focusing on the proposed requirement to store guns in transport. Most of our recommendations were incorporated into the regulations. We continue to advocate our position that ad-hoc sighting-in of guns and target practice on farmland should be exempt from proposed new requirements for shooting clubs and ranges.
In May 2021 we worked with NZ Police to do a rural crime survey of farmers, receiving over 1,200 responses. We collated a report of the results, which was presented to Police, FMG insurance and the Rural Crime Prevention Partnership group. The rural crime reporting app was launched in early May, with a trial happening in North Canterbury. If this trial is a success it will be expanded to the rest of rural New Zealand.
The Crown Pastoral Land Reform Bill passed its second reading in December last year and is expected to pass into law before the year is out. We submitted on this and still oppose it in its current form.
In March we submitted to the Department of Conservation (DOC) on its Stewardship land in Aotearoa New Zealand discussion document. We were supportive of the amendments proposed as they should result in a good process. We have concerns however regarding the five year timeline for the reclassification and the “one size fits all” approach.
Federated Farmers continues to push for a lift in the Access Boarding Allowance to the equivalent level of the Multi-barriers Allowance, and to look at lifting the transport conveyance allowance which has not been increased for over 20 years. The low levels of these allowances disadvantage rural families, especially farm workers who cannot afford boarding fees. Feds have been invited by the NZ Rural School Leadership Association to contribute funds to their work – a decision has not yet been made but discussion on the topic is planned.
Feds wishes for farmers to retain frequent and cost-effective postal services. We continue to work with NZ Post to ensure reasonable delivery times/frequencies at a reasonable cost so that rural communities are not disadvantaged.
In May the EPA released a summary of responses from its call for information on glyphosate, and they must consult with Māori on its usage before anything further could be considered. Following that we need to see whether there are grounds to reassess glyphosate and if so make a formal application. If that happens, Feds will be prepared to submit.
The Environment Select Committee’s report on the Hazardous Substances and New Organisms (Hazardous Substances Assessments) Amendment Bill was released in March and is awaiting its Committee Stage. We will be comparing the report to our submission to see if there is further action required.
In May we submitted to WorkSafe saying adjustments to their proposed amendments to restricted entry intervals for specified pesticides need to be re-examined so users of specified pesticides are safe while being able to continue with their business. Based on feedback we provided we have been asked to join a working group. We have not yet heard what the result of the consultation was.
In March we attended the EPA’s first Treated Seeds Advisory Committee meeting. The meeting was discussion of how they aim to improve a system for regulating treated seeds. We were contacted by EPA with a call for information on treated seeds, and we have arranged to meet with them to discuss this before we send any information.
Last year we submitted on MBIE’s document containing proposals on freedom camping, supporting stricter standards and raising broader freedom camping issues. The Government aims to pass some new legislation in time for the 2022/23 season with further changes having a longer transition period. We are comfortable with the proposed changes.
We submitted on MfE’s discussion document Taking Responsibility for Our Waste, calling for common sense in dealing with NZ’s waste issues. We opposed regulation of farm dumps insisting focus needs to be on addressing rural access inequities to waste recovery and recycling services.
We submitted on MfE’s discussion document Transforming Recycling, supporting the proposals subject to a) robust cost-benefit analysis, and b) that flexibility, pragmatism, and the need to address rural accessibility issues are at the forefront of considerations.
AgRecovery consulted on its Green Farms Product Stewardship Scheme which aims to apply for MfE accreditation in 2024. We submitted in support of the scheme.
Buildings and Farm Structures
New regulations come into effect in 2024 affecting any dam >4m with a volume of >20,000m3; or >1m with a volume of >40,000m3. Low-risk structures such as stock drinking ponds, weirs and small/low dams will be exempt. We think the guidance currently developed to help dam owners navigate the requirements will be very important.
On 4 September 2022 Feds submitted to MBIE on its review of the Building Consents System. While supporting measures to improve performance and reduce costs, our submission warned against assumptions that centralisation would have benefits, with Infrastructure commission research suggesting that bigger is not better with local government functions, including building consenting. In combination with Three Waters and RMA Reform, it would also impact on the viability of small councils.