What are the plans and who do they impact?
The current government has the goal to stop further degradation of our freshwater ecosystems, make material improvements, and reverse past damage to bring our waterways to a healthy state within a generation. The Government sees freshwater farm plans as a key tool in driving improvements to freshwater quality across New Zealand. Each plan will set out how the farm owner will reduce the impact of agriculture on freshwater.
Isn't viticulture a low-risk activity to freshwater quality?
Both central government and regional councils are aware that viticulture is a low-risk activity for freshwater ecosystems. The Government has been clear that it believes regulating all primary sector land users above specified thresholds is needed to meet the goals of the 2020 Essential Freshwater Package. All vineyards over five hectares will need a freshwater farm plan. If your vineyard is smaller than 5ha you will not require a freshwater farm plan. There are similar thresholds set for a range of different farm sizes across the entire New Zealand primary sector (for example horticulture, dairy, and sheep and beef farms). The Government has developed a one-size-fits-all solution, rather than a solution based on risks of specific farming activity.
Why is this not part of my SWNZ certification?
The regulations are a piece of secondary legislation which put into effect rules specified in the Resource Management Amendment Act 2020. Part 9A of the Act specifies a prescriptive approach to farm planning that effectively prevents an industry programme like Sustainable Winegrowing New Zealand (SWNZ) from certifying members' plans. Part 9A requires a two-step approval process where each site wil be visited on-site twice, first by a certifier and then by an auditor with specific timeframes to present information to regional councils after each step. The rules specify that the certifier and the auditor can't be the same person or organisation.
The rules make it almost impossible for SWNZ, where certification takes place remotely after on-site audit verification, to accommodate this two-step approval process. Furthermore, it would mean that SWNZ would need to run duplicate systems, one for freshwater (requiring significant additional resources), and one for the other five programme focus areas.
What's the time frame?
The regulations will be turned on at different times in different regions. The regulations have already been turned on in the Waikato and Southland regions (there are no vineyards over 5ha in either of these regions). The Government expects the regulations to be turned on in all regions by the end of 2025, covering over 35,000 farms and more than 1,300 vineyards. Once the regulations have been switched on in your region you will have 18 months to engage with a certifier and complete your freshwater farm plan.
What risks does my plan need to manage?
Freshwater farm plans seek to manage the impact of farming activities on the freshwater environment. Regional councils will use existing information to help identify key challenges for freshwater quality across different catchments in their region. This information will form a 'catchment context' that will help to inform the planning process. Catchment context, and the key risks to freshwater quality, will vary across New Zealand. Freshwater farm plans will then detail how farmers will adjust their practices to mitigate these risks.
My vineyard is small without surface waterways. Do I still need a plan?
All vineyards with more than 5ha of producing area will need a freshwater farm plan. If your vineyard is smaller than that, you will not require s freshwater farm plan.
What about a vineyard on a mixed-use property?
If your vineyard is part of a broader farm system (i.e., viticulture is not the sole land use) it is likely that your whole farm (not just the vineyard) will need a freshwater farm plan.
Who will certify and audit my plan?
At this stage it is unclear who will certify and audit freshwater farm plans in any region. The regulations effectively create a market for individuals with the right qualifications and experience to fill the certifier and auditor role. Each certifier and auditor must be approved by the relevant regional council in different regions.
How much will it cost me to develop a plan and get it certified and audited?
At this stage it is unknown how much the freshwater farm planning process will cost on an annual basis. The Ministry for Environment (MFE) has highlighted that the costs of preparing, certifying and auditing a freshwater farm plan will vary depending on the range of risks that the plan seeks to manage, the more complicated the plan, the greater the costs. Information released by MFE during consultation in early 2022 highlighted that it could be between $3,000 and $15,000 per property for certification. MFE have also acknowledged that many vineyard properties are relatively low risk, hence they expect these properties, in general, to be lower cost.
What’s next?
We are disappointed that SWNZ can’t play a more comprehensive role initially. However, we understand that government officials are interested in exploring how industry assurance programmes like SWNZ can play a more comprehensive role in helping members meet their regulatory requirements. We will be actively engaged with government on this issue in coming months.
In addition, we have been working with government agencies such as the Ministry for Primary Industries and MFE on a project called ‘Supercharging SWNZ’, which aims to identify how to adjust the programme to assist members to meet the new regulatory requirements. The first phase of this project is almost complete, and we are working to secure funding to assist implementation.
Where can I find support?
The Ministry for Environment (MFE) is the lead government agency on the freshwater farm plan initiative. They are working to develop industry specific guidance material. NZW is working closely with MFE and will share information with members as soon as its available. Other key sources of information include:
