Appendix 2: Analysis of Submissions on MAF Policy Paper 106

(a) The Sustainability of Present Farming Systems

Public submissions expressed a diverse range of opinion regarding the sustainability of New Zealand's present farming systems. Land owner/user groups and agribusiness supported the statement in the policy proposal that, with a few notable exceptions, most current New Zealand farming systems are sustainable and that the policy would mean little change for most farmers.

However, submissions from other groups of respondents challenged this statement. Their reasons for this view are:

  • there are many other instances of biophysically unsustainable systems in New Zealand other than those mentioned in the policy proposal;
  • there has been insufficient time and monitoring to adequately assess the impact of agriculture on the environment and its sustainability;
  • New Zealand agriculture is heavily dependent on non-renewable resources: imported fertiliser, agrochemicals, and energy. Some submissions favoured a closed system of sustainability; and
  • there is evidence of declining economic and social sustainability as evidenced by high levels of farm debt, amalgamation of farms, the importance of off-farm income to farming families and declining real prices for farm products, and rural depopulation.

The sustainability of present farming systems is discussed in more detail in section 3.

(b) The Need for Policies to Promote Sustainable Agriculture

There was general agreement on the need for a policy on sustainable agriculture. A number of submissions recommended an integrated land management policy to cover all land uses, not just agriculture. This is the approach already being undertaken by the interdepartmental working group as mentioned in section 4.1. There was widespread support for the policy to be consistent with the provisions of the Resource Management Act and to meet its definition of sustainability.

Many respondents considered the policy needed more specific objectives and directions, and some commented on how the policy will be implemented, monitored for progress, and funded. MAF's definition of sustainable agriculture can be found in section 2.3. The specific actions MAF can take in achieving sustainable agriculture outcomes, and implementation issues, are set out in section 5.1.

There was general support for the MAF view that economic, social and environmental concerns must be balanced to meet society's goals. However, many respondents considered that the paper gave more weight to economic and social goals than to environmental and ecological goals. Many submissions favoured non-negotiable `bottom lines' based on research and legal precedent. These are required to manage risk arising from imperfect information about the consequences of exploiting a resource to the point of collapse.

(c) The Best Ways to Achieve Sustainable Agriculture

There was general agreement that adequately funded research, monitoring, education and extension activities will be required to support any sustainable agriculture policy, and to achieve a consensus between the different parties involved, individuals, communities, local and central government.

Economic instruments, especially financial incentives, to encourage sustainable management practices were favoured by a majority of correspondents because of the recognition that successful implementation of policy requires the consideration of economic factors. However, regulation was seen as an important means of setting a bottom-line to natural resource degradation. Regulations and economic instruments would both require effective monitoring and enforcement.

MAF is in general agreement with these views. The role of central government, and the policy instruments available for promoting and achieving sustainable agriculture, are set out in section 4.

(d) The Role of MAF in Facilitating Sustainable Agriculture

There was major concern that MAF is proposing to duplicate the efforts of other agencies and is failing to adequately liaise with other organisations. There was also considerable concern about the potential conflicts between the role of regional government in managing resources under the Resource Management Act, and MAF's role in promoting sustainable agriculture.

Agribusiness and land-user groups would like MAF to provide leadership for agriculture (after consultation with agribusiness and farmers) which would include taking a higher public stance on issues affecting the agriculture sector, that is, an advocacy role. Other groups supported a pro-active role for MAF in providing neutral policy advice to central and regional government on resource management issues as they impact on agriculture.

There was support for MAF to take a leading role in promoting and funding research and technology transfer, and to reappraise its own research priorities. MAF must also continue its role in quality assurance for export produce, border protection and international trade access.

Clarification of MAF's role is provided in section 5.

(e) Other Issues

There was support for central government funding for situations requiring major adjustment of land use to meet sustainability criteria. Some respondents suggested that past government policies and interventions have been a major contributing cause of unsustainable situations, and that society will benefit from sustainable management. Therefore, government and society must share the responsibility and costs of implementing sustainable agriculture policies.

A number of submissions commented on the failure of the policy paper to consider Maori needs, and to adopt the principle established under the Resource Management Act to consider the Treaty of Waitangi and the Maori cultural view regarding sustainable land management. This deficiency has been addressed in this final policy document.

A number of submissions provided detailed information which can be accessed when preparing more detailed policy responses as specific issues arise.

 

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