In which the writer proposes:

Splitting conventional wisdoms and inspecting for rot.
Wrestling with the status quo.
Weighing environmental and economic absurdities.
Disentangling metaphors.

Saturday 17 February 2018

LIVESTOCK WATERING REGULATIONS PROPOSALS: Our Comment

Jan 2018 the Ministry of Environment & Climate Change (MOE) issued Intentions Papers to enable ranchers to more easily access water on Public (Range) Land.
 
The Intentions Papers, although issued by MOE appears to have been written by the cattle industry or Range Branch and contains so many misleading statements that we doubt that this is a credible process undertaken in good faith.
Despite the emphasis on the objectives of protection of the environment, this process comes from the demands of the cattle industry for easy access and effective ownership of a public resource.  
The proposed regulations, with the numerous misleading statements in the Intentions Papers make us doubt that this is a credible process.
Anyone who thinks this narrowly focused attempt to respond to the wants of the cattle industry will result in meaningful improvements is ignoring the history and the failures of oversight agencies to prevent damage and public cost.

A few of the problems associated with cattle grazing:
grassland and riparian degradation…..
absurd water consumption raising low value crops…..
water contamination…..
cattle contribution to weed spread, cheat grass and other invasives…..
public fencing costs (decaying infrastructure which will result in huge public cost.)…..
ecological-restoration costs (millions in public funds spent to repair damage, without removing the primary root cause, cattle)…..
lost opportunity costs……
increased fire risk (and fire season) from cattle induced cheat grass infestations…..
forest regrowth damage…..
conflicts with wildlife, habitat, food…..
growing awareness of cattle contribution to global warming……

We have submitted comment to Government and have detailed the :
  • Broader Issues
  • Misleading Statements
  • Why Existing & Proposed Regulations Fail to serve the Public Interest
  • Conclusions & Recommendations
 However it appears that MOE is not publishing submissions (as has been the practice on other issues) nor have we received any confirmation of receipt of our submission. That suggests further that this process may not be credible.
Our detailed submission can be viewed at:
Our recommendation in that submission is that these proposals should be shelved pending a full comprehensive and independent economic analysis of public land (Range) use to include public and environmental costs including lost opportunity costs.
It is our expectation that an independent, objective analysis would show that the public cost of Range use greatly exceeds the Public benefits, even before the inclusion of lost opportunity costs. Similar analysis in the US (with a similar range use regime) shows that public costs far exceed benefits, to the point that it would be cheaper in the mid to long term to pay ranchers to relinquish grazing permits, for payment. Paying ranchers in effect for grazing rights that they do not in fact “own.”

Proposal of a full economic/environmental assessment/study then poses a difficult question.
No Ministry in our experience could be relied upon to produce or commission such a study without inserting the usual bias in favour of the ranching industry.

Perhaps it is a job for the Auditor General
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Gov't also provided short term access to a blog to allow comment on these proposed regulations. It appears that the blog is now closed for comment. For now the comments can be viewed at: