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Making a submission on factory farming

I’ve made my submissions to Environment Canterbury against the establishment of factory farming in the MacKenzie basin. My previous post lays out some reasons why it is a tremendously bad idea for the entire country.

I encourage everyone that has an opinion on factory farming to go to the Ecan web site and make their own submissions. Every submission counts under the Resource Management Act so your voice will make a difference.

To have your say:

1. Go to the three applications on the Ecan web site:

Williamson Holdings
Southdown Holdings
Five Rivers

Each link takes you directly to the submission form for the applications.

2. Enter your details

3. Tick the support/oppose box for each consent under the application

4. Tick “I want to be heard” (There is no obligation to show up but it gives your submission more weight and you will be notified of hearings later).

5. In the box marked “Your Reasons” enter your submission text. Here’s mine as an example but feel free to copy it (adapted from the excellent Green’s Guide).

I oppose this application in it’s entirety. Issues around environmental degradation, water quality, animal welfare and NZ’s international brand make this application completely inappropriate for New Zealand’s national interest.


•The Mackenzie Country is an iconic brown tussock landscape. This unique and fragile environment will be radically altered by irrigation and intensive dairying.
•The Mackenzie is important habitat for threatened plants and birds which rely on a dry tussockland habitat.
•The proposed farms will be heavily reliant on supplementary feed being trucked in from elsewhere, with resulting milk produced in large volumes needing to be trucked out.
•Large amounts of fecal solids will be stored above ground to be applied to pasture in specified months. Leachate from these deposits will radically alter the nutrient levels in the surrounding land, making life untenable for much of the native flora and fauna.

Water quality:

•The consent applications include large effluent ponds and plans to discharge large amounts of diluted effluent onto the land every day. This will alter the nutritional balance of streams, waterways and rivers in the vicinity.
•The majestic Upper Waitaki & important recreational lakes such as Lakes Benmore and Aviemore are at risk of contamination from effluent and nutrient runoff.

Tourism and international brand

•The Mackenzie Country is a major drawcard for international tourists, and the gateway to Aoraki / Mt Cook National Park. Over 200,000 international tourists visit the National Park each year
•New Zealand’s tradition of farming animals outside and on pasture is integral to our clean, green image and our competitive advantage. News that New Zealand dairy products come from factory farmed cows will undermine our international brand, which is unfair to the many good farmers who are farming sustainably.

Animal health and welfare:

•It is cruel to house cows inside without fresh air and sunlight for 8 months of the year and for 12 hours a day during summer.
•Animals confined in close quarters are at greater risk of injury and infection and are likely to need controlling with antibiotics.

6. In the box marked “Consent”, enter your desired outcome, for example

I wish Environment Canterbury to decline the application in it’s entirety.

7. Hit the submit button and wait for your confirmation email.

Don’t forget you need to do this for all three applications. If enough people make submissions we can stop factory farming getting a foothold in New Zealand.


  1. sue said,

    December 15, 2009 @ 8:51 am


    this was the very best and easiest of tips and help i could find
    thank you

  2. Tim Homes said,

    December 15, 2009 @ 8:13 pm

    Thank you for assisting me in making my submission.

    Copy for your Info.

    I oppose this application in its entirety. The McKenzie is a semi alpine environment, unsuited for this application. Water take and waste discharge will degrade this environment. Animal heath will be compromised by the restriction of movement proposed. There will be a significant increase in demand for power usage, both for electricity and for road transport.

    The climate in the McKenzie is one of extremes, from searing hot sun and wind, to freezing snow and frost. During the summer months strong hot winds can raise the ambient temperature to well over 35 Deg C. Also in summer there can be very heavy convection thunderstorms, with rain rates of 20 mm an hour or more. These can be slow moving, giving rise to localised flash flooding. During winter snow and frosts can lower the temperature to well below – 10 Deg C. This makes vehicle and personal movement within the McKenzie a dangerous, and at time areas can become isolated for a week or longer.
    Under these conditions there is a strong likelihood that effluent discharge will be disrupted, and spills, runoff from freshly applied effluent will contaminate the local waterways. Once effluent has entered the waterway it will carry on to flow into the Waitaki river system, fouling the Waitaki and Upper Waitaki lakes. It is not a question of if this will happen, but a question of when and how bad.

    Water take will cause drying up of existing streams and springs. Lower groundwater levels will cause more dust and loose soil to be blown about in gusty conditions. The application of effluent will add in a high level of nitrates, which will adversely affect the local fauna and flora. Black Stilts in particular, which nest in the river beds of the McKenzie will be adversely affected by this.

    Dairy cow health will be compromised by this application. Cows will not be able to move about sufficiently for good health, like a person house bound they will quickly become unfit, and more susceptible to health problems. Overseas studies show that cows kept indoors for extended periods have increased health problems.

    There will be a significant increased demand for electric power. This is to drive lighting, heating/cooling, water pumps, effluent pumps, and air movement systems. An alternative electric supply will also need to be built on site in case of power outages due to adverse weather conditions.

    Transport power considerations will also increase, with trucking of food stuffs and supplements to the sites, then different trucking of milk away from the sites. Round trips for the trucks will be between 300 and 500 km. Locally, effluent will also need to be trucked from the farms stalls to the spread areas.

    Many thanks

    Tim Homes

  3. Madeleine said,

    December 16, 2009 @ 12:30 pm

    The ecan site specifically notes that these applications relate to the effluent storage and disposal only, meaning a lot of those other points are irrelevant as far as making submissions go. Tim’s expansion on the effluent issue w.r.t. the local environment is therefore very useful.

    So where are the applications made regarding establishing these farms in the first place? That’s what I want to object to!

  4. FarmGeek said,

    December 16, 2009 @ 12:41 pm

    Thanks for the feedback Madeleine.

    Under the RMA, while the applications cover land use and effluent discharge, the submissions can use a range of criteria (like environmental damage, water quality and wider national interest).

    The original consents to operate were granted by the local council and they did not feel the need to publicly notify and gather submissions.

  5. Madeleine said,

    December 16, 2009 @ 1:29 pm

    Ooo, here we go, from the pdf files linked to here: http://ecan.govt.nz/get-involved/have-your-say/Pages/upper-waitaki-dairy-effluent.aspx

    Poor old Craig McKibbin, with his email address and phone number there for all to plainly see. There’s a lot of technical guff, and three of them, so I only skim read, but…

    In skim reading each of the applications, it seems the effluent ponds would be large enough to store up to 7 months of effluent so that it can be retained until release at a suitable time (they say summer) so transient inapproprate weather conditions won’t cut it as an objection. All note that managed distribution is superior to discharge all year long, directly onto land, straight from the cow. This would have merit but I don’t see how applying 6 months worth of effluent in one go across a whole farm is different to moving cows from one area to a next such that 6 months’ of effluent is spread across a whole farm over the period of 6 months. However, if this is land that couldn’t cope with open farming methods, then how will it cope with these? Same number of cows; same amount of waste. It’s all got to go somewhere.

    In the Williamson app, I note (in section 5.4), there are plans to export some solid wastes offsite to keep the N level below 200kg/ha. Hmmm – where to?
    Five Rivers’ distribution of the effluent will be matched to plant uptake of nitrogen, with any excess being sold (wherein I get to say: who buys this shit?) as solids (Appendix B).

    The N leaching would be at rates of 19, 16 and 13 kg/ha for each application respectively, all apparently “within the assessed assimilative capacity of the most sensitive receiving water bodies” (Ahuriri River, Wairepo Stream, Quail Burn respectively; also in Appendix B of all apps).

    It’s also apparently the Waitaki District Council that they apply to for consent to run a cubicle farm.

    Finally, the applications for water permits:
    Williamson: CRC041787 – 041788 061154 to take 750L per second from the Ahuriri River
    Five Rivers: CRC061154 950L per second from Lake Ohau
    Southdown: CRC040835 1.2 cumecs from Lake Ohau

    And I thought this was in an area often short of water.

    Unfortunately, CRC061154 at least is well old: http://ecan.govt.nz/publications/Consent%20Notifications/Report_13_FiveRivers_final.pdf is the report by Claire Penman. There appear to be some issues (see Overall Conclusion sections 75 and 95 and also the outstanding issues in her recommendation in sections 108 and 109).

    In skimming Southdown’s report (http://ecan.govt.nz/publications/Consent%20Notifications/Report_35A_Southdown_final.pdf), I note that Glen Eyrie Downs, the proposed discharge area, “is noted for vigorous red tussock community and moraine dammed swamp. There are tarns and stream which support waders and waterfowl.” (section 36c). Hmmm – a water sensitive ecosystem, then?
    In her investigation recommendations, Penman says in para 125 “It should be noted that the investigating officer is not satisfied that these conditions would adequately mitigate that adverse effects that are of key concern.”

    OK that’s all I have time for for now.

  6. Neil Forster said,

    January 12, 2010 @ 6:30 am

    Good post John, and submission underway.

    I agree with the key focus on the NZ market place perception, both for our exports and tourism. The local issues of “animal welfare and water quality” can be mitigated (some may disagree) and the “100% pure” image NZ has wanted to portray will be severly impacted by this sort of farming.

    Additionally this level of intensity provides increased argument for our competitors in the primary production markets. That in short, produce from NZ is “just the same as their country”. Many countries, for a number of reasons, produce milk in this nature. The result, with the points you’ve made, is we have dropped our competitive advantage and are now just the same as them. While the individual farmer has improved his output and revenue, NZ will suffer. We will then have to directly compete, without any real differentiation with very large countries farming in this manner (eg. USA, China) and we just aren’t big enough to do this.

    I think Fonterra’s view on this is critical to help prevent any progress of this type of production in NZ. Additionally perhaps we need to look at rewarding production that supports and enhances NZ’s competitive advantage, rather than primarily just being production/Ha based. We have to target high value markets with high value product.

    The worst point, in my opinion is that of Fed. Farmers, they are looking one one point, they appear to have actually changed position and they have forgotten about the country they help represent and it’s position in the world market place.

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