The Government last week released the exposure draft of the National Policy Statement for Indigenous Biodiversity and is seeking feedback. The consultation period closes at 11.59 pm on Thursday 21 July 2022. B+LNZ has undertaken a preliminary analysis of the exposure draft and has emailed these observations to farmers:
The Government released updated proposals to the National Policy Statement for Indigenous Biodiversity (NPSIB) last week.
The NPS for biodiversity is of particular relevance to sheep and beef farmers given the significant amount of native vegetation on our farms – some 2.8 million hectares, according to research by the University of Canterbury.
B+LNZ, along with other primary sector groups, successfully convinced the Government to pause the initial biodiversity reforms in 2020. Farmers had significant concerns about the proposed rules, particularly around Significant Natural Areas (SNAs) and the potential restrictions on what they could do in those areas.
We believe the latest release is badly timed. We reiterated in our media release last week that farmers are already feeling overwhelmed by environment-related legislation, on top of labour shortages, high on-farm inflation and managing COVID-19.
We have undertaken a preliminary analysis of the exposure draft and will be arguing strongly for the Government to make improvements to the latest proposals and slow down its deluge of environmental policy reforms.
- Based on our initial review, while we acknowledge there have been some small changes made to the NPSIB exposure draft, there are still significant issues.
- We encourage an integrated approach to our farming systems where pastoral land use can coexist and support positive indigenous biodiversity outcomes.
- The six-week consultation period does not provide enough time to respond to these complex issues. We have expressed strongly that this consultation period should be longer.
- We have serious concerns over the criteria for determining Significant Natural Areas (SNAs), and the areas this would include. The criteria for identifying an SNA remains very broad and will capture significant areas of sheep and beef farms. We previously advocated for the definition to be narrowed to identify habitats that are threatened, at risk, or rare as SNAs. Our proposed definition is already used by some councils and has been working well.
- This is important as there are large tracts of indigenous vegetation on farms. If the land is classified as an SNA, it will restrict farmers’ ability to undertake new or modified activities within or in surrounding SNAs. In some cases the activity may not be able to occur, in others it may be granted via a resource consent process which involves an ecological assessment.
- The Government has indicated that there will be support for implementation of the NPSIB, however we are concerned that this will fall short of what is needed.
- We are currently undertaking an in-depth analysis of the exposure draft and talking to Federated Farmers and DairyNZ.
- We will provide further advice to farmers on the implications of the proposed regulations and how they can make submissions. The justified concerns we’ve heard from farmers will inform our own submission.
- We will continue to advocate for an efficient and effective approach where the protection and enhancement of indigenous biodiversity can integrate within pastural farming systems with mutual benefits.
- We will also be asking whether this process can be paused, or at the very least the consultation period extended, to ensure that we can provide comprehensive feedback on such an important issue during what is a very busy period.
You can find more information on B+LNZ’s Biodiversity consultation webpage.