Submissions on the region's Land and Water Regional Plan close Friday (October 5) and several representative bodies are raising concerns about the complex proposals.
"We will be submitting on the land use change percentage in particular," says Federated Farmers' Willy Leferink. "If your nutrient losses change by 10%, that will require a consent. That means a sheep farmer losing 4kg of N/year going to 4.5kg would require a consent. That's unacceptable."
Much of the implementation will come down to limits set by zone committees from 2017.
"We've told farmers get involved with those committees and make sure they have the best possible information to make the best possible decisions."
Irrigation New Zealand chief executive Andrew Curtiss is particularly concerned at the "arbitrary" numbers applied to water transfers which will see 25% or 50% of consent volumes lost in over-allocated zones.
He's also concerned the plan is too focussed on nitrogen, and the reliance on the Overseer nutrient management model. "We'll be advocating for farm plans and audited self management: targets and best practice rather than allocations of N."
Submissions close October 5. See www.ecan.govt.nz