Silver Fern Farms Limited Fairton Office Road, Fairton, 7772 PO Box 30, Ashburton, 7740 New Zealand

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1 Silver Fern Farms Limited Fairton Office Road, Fairton, 7772 PO Box 30, Ashburton, 7740 New Zealand TEL: FAX: November 2011 Freepost 1201 Proposed Canterbury Regional Policy Statement Environment Canterbury P O Box 345 Christchurch 8140 mailroom@ecan.govt.nz RE: FURTHER SUBMISSION BY SILVER FERN FARMS LIMITED ON THE PROPOSED CANTERBURY REGIONAL POLICY STATEMENT Silver Fern Farms would like to make a further submission in respect to six submissions made by other parties on the proposed plan. Please see the attached form for details of the specific submissions, support or opposition given and the rationale. Silver Fern Farms would like the opportunity to be heard in support of our submission, and would be prepared to consider presenting our submission in a joint case with others making a similar submission at any hearing. Please feel free to contact me by phone ( ext / ) or alison.johnstone@silverfernfarms.co.nz if you have any questions regarding the above. Yours faithfully Alison Johnstone Environmental Officer CC: Waitaki District Council Attn: Mr David Campbell Private Bag Oamaru 9444 Irrigation New Zealand Inc. Attn: Mr Andrew Curtis 6 Sonter Road Wigram Christchurch 8042 Horticulture New Zealand Attn: Chris Keenan PO Box The Terrace Wellington 6143 Solid Energy New Zealand Attn: Mr Tim Lester Private Bag 502 Huntly 3740 Fish & Game New Zealand, North Canterbury Region Attn: Mr Tony Hawker 3 Horatio Street Christchurch Central

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3 FOR OFFICE USE ONLY Further Submission on The Proposed Canterbury Regional Policy Statement Submitter ID: File No: PLAN/RPS1/PROP/6SU/5 Form 6: Further Submissions on a Publicly Notified Change to a Plan or Policy Statement under Clause 8 of the First Schedule to the Resource Management Act 1991 Return your signed further submission by 5pm, Monday 14 November to: Freepost 1201 Proposed Canterbury Regional Policy Statement Environment Canterbury P O Box 345 Christchurch 8140 A Full Name: Alison Johnstone (Environmental Officer) Phone (Hm): Organisation*: Silver Fern Farms Ltd Phone (Wk): (03) ext 3481 * the organisation that this submission is made on behalf of Postal Address: PO Box 941, Dunedin Phone (Cell): Postcode: alison.johnstone@silverfernfarms.co.nz Fax: (03) Contact name and postal address for service of person making submission (if different from above): PO Box 30, Ashburton 7700 Only certain people can make further submissions. Please tick the option that applies to you: I am a person representing a relevant aspect of the public interest; or I am a person who has an interest in the proposal that is greater than the interest the general public has (for example, I am affected by the content of a submission); or I am the local authority for the relevant area. Trade Competition A person who could gain an advantage in trade competition through any submission may make a further submission only if directly affected by an effect of the proposed policy statement or plan that: a) adversely affects the environment; and b) does not relate to trade competition or the effects of trade competition. Please tick the sentence that applies to you: I could not gain an advantage in trade competition through this further submission; or I could gain an advantage in trade competition through this further submission. If you have ticked this box please select one of the following: I am directly affected by an effect of the subject matter of the original submission I am not directly affected by an effect of the subject matter of the original submission 2

4 Service of your further submission: Please note: any person making a further submission must serve a copy of that submission on the original submitter no later than five working days after the submission has been provided to Environment Canterbury. If you have made a further submission on a number of original submissions, then copies of your further submission will need to be served with each original submitter. Signature: Date: 14 November 2011 (Signature of person making further submission or person authorised to sign on behalf of person making the further submission) Please note: (1) all information contained in a further submission under the Resource Management Act 1991, including names and addresses for service, becomes public information. B I do not wish to be heard in support of my further submission; or I do wish to be heard in support of my further submission; and if so, I would be prepared to consider presenting your further submission in a joint case with others making a similar further submission at any hearing 3

5 Silver Fern Farms Ltd 9 November 2011 C (1) Name of person or group making original submission and postal address Waitaki District Council Attn: Mr David Campbell Private Bag Oamaru 9444 Horticulture New Zealand Attn: Chris Keenan PO Box The Terrace Wellington 6143 Fish & Game New Zealand, North Canterbury Region Attn: Mr Tony Hawker Original submission reference (Submission point reference number from the second column in the summary of decisions requested table) (Method 3) WDC supports having regard to recommendations from the regional water management zone committees and would go so far as to require this method be strengthened further (Explanation) Policy seeks to avoid, remedy or mitigate adverse effects on water quality through managing of changes in land uses. However it is not clear what may constitute a change in land use. Is it a total change of system - say from cropping to dairy? Or could it be changes within a system - such as change to the cropping regime? It may be more effective to state the nature of changes that are of concern that simply changes in land use. (Relief sought) Clarify the intent of Policy and what constitutes a change of land use. Redefine as activities; and explicitly provide definitions for what will be considered a change in activity [Principal reasons and explanation] Suggested amendment: Any controls on land uses to manage non-point source or 4 I support or oppose the relief sought in the original submission Oppose Silver Fern Farms is unsure as to what is meant by strengthening the method further. Silver Fern Farms would presume strengthening, meant referencing to the Canterbury Regional Policy Statement. While Silver Fern Farms acknowledges that this can be done through the Schedule 1 process, it submits that doing so at this late stage mid way through a public consultation phase would seem inappropriate. Silver Fern Farm submits that incorporation of regional water management zone committee recommendations should be by a new variation to the Canterbury Regional Policy Statement with the appropriate notification and consultation.. Support Silver Fern Farms supports the submission. Silver Fern Farms feel it important to clarify the intent as it could be construed that the method is trying to impose land use controls for permitted activities through any land use changes. Oppose deletion The section 32 report has identified that:

6 3 Horatio Street Christchurch Central Christchurch 8011 Irrigation New Zealand Inc. Attn: Mr Andrew Curtis 6 Sonter Road diffuse discharges need to relate to the land use(s) which cause(s) the effects, and address cumulative effects. For any control the cost must also be proportionate to the benefits. However, it is also important that where effects of land uses on water quality are uncertain or unproven, that a precautionary approach is taken in accordance with Policy Add additional point to Policy as follows: (4) provide opportunities for industry organisations and groups to take a lead role in the management of freshwater 5 costs will vary from catchment to catchment depending on the nature of the issue and the response taken, and will need to be assessed relative to the benefits in each case. Silver Fern Farms opposes the sentence deletion on the grounds of the need for consideration of appropriate whole of community benefit. For a number of communities in the Canterbury region primary production is vital to the sustainability of the community itself. The economic viability and broader sustainability of farming is closely linked with the social and economic welfare of farmers, farm workers and their local communities. Silver Fern Farms encourages the continuation of farming communities by having processing facilities servicing these communities. Whilst our operations have specific land use requirements they also provide substantial employment and associated benefits within the community. By way of example, the application of wastewater to land as a nutrient source for crops, provides both organic matter to the soils and ensures good crop growth. Organic matter diminishes soil erosion, and the crop grown provides an animal feed source to the community, along with harvesting opportunities for local contractors. Silver Fern Farms submits that a whole of costs/benefits approach is essential to ensure the imposition of controls is proportionate to the benefits; this is consistent with the S32 report recommendation. Oppose Silver Fern Farms oppose the addition.

7 Wigram Christchurch 8042 Whilst it is not disputed that industry organisations and groups will play a part in improving the management of freshwater, the inclusion of such a statement could lead to the unrealistic setting of expectations by those outside of industry over the reality of what can and can t be achieved through these methods as they are not statutory and enforceable. Irrigation New Zealand Inc. Attn: Mr Andrew Curtis 6 Sonter Road Wigram Christchurch 8042 Add additional point to the Explanation associated with Policy as follows: Industry groups and organisations have a valuable role to play in improving the management of freshwater in the region. This role includes the development of industry good practice guidelines and the provision of advice and support. Silver Fern Farms oppose the addition. Whilst it is not disputed that industry organisations and groups will play a part in improving the management of freshwater, the inclusion of such a statement could lead to the unrealistic setting of expectations by those outside of industry over the reality of what can and can t be achieved through these methods as they are not statutory and enforceable. Solid Energy New Zealand Attn: Mr Tim Lester Private Bag 502 Huntly 3740 Clause (1) of Policy is supported in part as it recognises the need to avoid new development near existing discharges where the new development is sensitive to the effects of the discharge. Notwithstanding the above, Method (6)(b) is opposed because it refers to territorial authorities establishing provisions to protect established discharges of contaminants to air from reverse sensitivity effects if the established discharge has adopted the best practicable option to prevent or minimise any adverse effects. This aspect of Method (6) is inconsistent with the direction provided in Policy The direction to avoid reverse sensitivity effects in Policy (1) is not subject to the implementation of the best practicable option to minimise effects. Whilst it is recognised that the need to ensure dischargers of contaminants to air are undertaking practicable measures to reduce their effect on the environment, it should also be recognised that the Support Silver Fern Farms support the relief sought and agree with the thought process that the actual or likely adverse effects of a lawfully established activity have been assessed under the framework of the RMA and in having a consent granted, can be considered to achieve its sustainable management purpose and this therefore does not need to be readdressed in the CRPS. 6

8 discharge of contaminants is a lawfully established activity and has been assessed under the framework of the RMA and considered to achieve its sustainable management purpose. Method (6)(b) should, therefore, be amended to more accurately reflect the direction of Policy The following relief is sought: Retain Policy as notified. Amend Method (6)(b) as follows: Provision is made to protect established activities discharging contaminants to air from adverse reverse sensitivity effects resulting from encroachment by sensitive land uses if the established activity has adopted the best practicable option to prevent or minimise any actual or likely adverse effects. Add further pages as required. 7

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