Federated Farmers of New Zealand.

1. Federated Farmers submission toPC22 to the Horowhenua District Plan15 November 2011Presented by Rhea Dasent, Federated Farmers Regional Policy Advisor

2. Federated Farmers of New Zealand. • Not-for-profit primary sector policy and advocacy organisation, representing farmers at central government and local government levels. • Involved in district plan process around NZ. • This submission is representative of member views and reflects the fact that Plan Change 22 of the Horowhenua District Plan will impact on our member’s daily lives as farmers and members of local communities.

3. What do we want achieved? • ONFLs have been appropriately identified: • Robust and objective criteria • Ground-truthed • That PC22 balances economic, social and cultural well-beings as well as environmental and amenity values. • Certainty for land owners: • Around permitted activity limits • Where the rules will apply on their property • That normal farming activities are not unreasonably affected. • That public good being recognised: • Land owners are acknowledged for their role in protecting landscapes

4. Consultation Map scales are at 1:120,000, and lines are only “indicative” Difficult for land owners to work out if their property has been mapped as an ONFL. Very difficult to determine where the ONFL boundary will be on a farm, and subsequently where rules will apply. Federated Farmers is unable to verify how many properties used for production are classified as ONFLs, due to lack of access to appropriate technology. Federated Farmers submits that meaningful consultation be undertaken with affected land owners on an individual basis. • Maps need to be provided on a smaller scale so landowners can conclusively see ONFL boundaries. • Further ground-truthing and site visits need to occur. • Landowners care for and invest in their land. Better consultation will result in better outcomes.

5. Consultation

6. Outstanding Natural Features and Landscapes • Federated Farmers recognises the obligation that Section 6(b) of the RMAplaces on local government. • Support for reduction of ONFLs where these have been found in the peer review to not meet criteria. • Opposition to ONFL classification over primary production land. • As this does not recognise that that farm land is shaped by human land use and activities. RMA Provisions: • Enabling intent of Section 5 of the RMA; • Protection of ONFLs from inappropriate activities in Section 6(b) which in turn means enabling appropriate activities.

7. Outstanding Natural Features and Landscapes Moutere Hill – an ONFL that is also a working pastoral farm.

8. Earthworks in ONFLs • All earthworks in ONFLs will need resource consent as a non-complying activity. • This does not enable appropriate activities where ONFLs have been identified over primary production land. • Policy 4.14C directs that regard shall be had for existing land uses within landscape areas to accommodate subdivision, use and development without adverse landscape effects, the rule is currently not consistent with this policy. • Earthworks such as access tracks, silage pits, pipe laying, tank installation, preparation for fencing, land slide clean-up are all normal activities with minor visual effects. • Federated Farmers submits that earthworks up to 2,500m3 and primary production buildings in ONFLs be permitted.

9. Buildings in ONFLs • Buildings: • Buildings for primary production are not excluded from Discretionary Rule 19.7(b) nor Non-Complying Rule 19.9.3: • Inconsistent with the enabling intent of the RMA, and Policy 4.14C of PC22. • Many ONFLs are actively used for primary production, and that land use contributes to the landscape we see today. • The gradated rule from Discretionary at 3-7m high and Non-Complying at +7m is an attempt to address our concern. • Federated Farmers submits that primary production buildings and farm houses are permitted in ONFLs. • Activity Status: • Rules restricting buildings on ONFLs are intended for a distinct purpose: • The protection of ONFLs from inappropriate subdivision, use and development. • Limited Discretionary status is more suitable than Non-Complying, without the Council losing its ability to assess effects and make a decision accordingly. • Discretion can be restricted to effects on the specific qualities that made the landscape identifiable as Outstanding: • Biophysical; Sensory; and Associative. • Federated Farmers submits that activity status for other buildings in ONFLs is Limited Discretionary.

10. High Amenity Landscapes • No direction in the RMA to identify High Amenity Landscapes; • Nor in Horizons One Plan (Chapter 7 decisions version) • Section 7(c) maintenance and enhancement of amenity is achieved by normal zoning provisions. • These landscapes are not just for looking at, but are where people live and work. • All HALs are acknowledged to have primary production and are rural in character. • HAL provisions are unnecessarily preventing the continuance of normal farming activities, for no amenity gain. Federated Farmers submits that all High Amenity classifications and provisions be deleted.

11. High Amenity Landscapes Hill Country Domain – classified as an HAL and consisting of forestry and agricultural land uses.

12. Earthworks in HALs • Federated Farmers supports the deletion of Rule 19.5(c) and its replacement with permitted levels of earthworks (time x volume x distance). • However, the limits in rewritten Rule 19.2.28 are too small to enable normal farming activities to continue. • Farmers usually hire earthmovers to do several jobs at once every few years, such as: • Forming or maintaining farm tracks and cow races • Digging silage or offal pits, effluent ponds • Cleanfilling around troughs and gates to reduce mud • Pipe laying and subterranean tank installation • Clean up of landslides or slips • Formation of underpasses or bridges • These are normal farming activities on land that has been used for farming for decades. • Federated Farmers submits that Earthworks limits should be increased to 2,500m3

13. Buildings in HALs • Federated Farmers supports the express exclusion of primary production buildings from HAL Limited Discretionary height and area restrictions. • This is positive acknowledgement that HALs are working landscapes. • Dwellings often screened by gardens and trees. Farmer’s homesteads and workers’ accommodation are part of a farmed landscape and contribute positively to amenity. • Traditional farm houses are part of rural character, and modern houses are unobtrusive in the landscape. • It is vital that farmers are able to live on the land they work. • Federated Farmers submits that all primary production buildings and farm houses be permitted in HALs.

14. Federated Farmers thanks the Commissioners for considering our submission to PC22 to the Horowhenua District Plan.