Freshwater farm plan FAQs


General questions

If a property meets the below, they will require a freshwater farm plan: 

  • 20 or more hectares of the farm is arable land use 
  • 5 or more hectares of the farm is horticultural land use 
  • 20 or more hectares of the farm is pastoral land use 
  • A prescribed area of the farm is other agricultural land use prescribed in regulations made under section 217M(1)(b) 
  • 20 or more hectares of the farm is a combination of any 2 or more of the land uses described above. 


The regulations turn on in Otago in stages from February 2024. Properties will need their plan in place and certified 18 months after their part of Otago goes live. These dates are shown below.  



Start date 

North Otago FMU 

1 Feb 2024 

Lower Clutha Rohe 

1 Aug 2024 

Upper Lakes Rohe, Dunstan Rohe, Manuherekia Rohe, Roxburgh Rohe 

1 Feb 2025 

Taieri FMU 

1 Aug 2025 

Catlins FMU 

1 Aug 2025 

Dunedin and Coast FMU 

1 Dec 2025 

*Note that some of these measurements cover farms which are across FMU boundaries and incorporate parts of farms.

Yes, you will still require resource consents for certain activities if you have a freshwater farm plan. However, there will be activities that you may be able to include in your farm plan and have certified.  

This can happen where: 

  • A piece of legislation says that you can have it included in your farm plan instead of a consent for that activity. For example, you may want to use this for your intensive winter grazing activity.
  • A rule in the regional plan says you can use a farm plan instead of a consent. This option is not available yet in Otago but is being looked at through the development of the Land and Water Regional Plan. 


If the pathway is available, your certifier will then need to confirm that your activity meets the test to be considered part of a farm plan and not a consent. This decision happens separate to Council.  

The farm plan pathway instead of consents, can only be used once the farm plans have turned on in your part of Otago. It is recommended you contact the Consents Team before you use this option. 

  • Administrative details about the farm 
  • Maps 
  • Catchment information 
  • Identification and assessment of risks to freshwater and freshwater ecosystems  
  • Identifying actions with timeframes to avoid, remedy or mitigate effects on freshwater and freshwater ecosystems. 

There is no specified format or template for freshwater farm plans in the regulations. This enables you to use existing plans or tailor a document to your farm.  

Information on what to include in your plan and how to structure it, can be found here.

It's designed it to be very flexible, and it all comes down to the environmental risk on each farm. For some, the focus might be on soil health, and for others, it might be on water quality, or adapting fertiliser use to reduce nitrogen. 

Freshwater farm plans provide flexibility and enable the farmer to work within a framework to identify actions that are going to have the highest value from an environmental perspective. The plan will meet requirements, match with their long-term objectives and add value to their farm and products. 

A lot of farmers will already have an industry plan in place. In those cases, they will simply need to keep doing what they're already doing, but they'll need to add some improvements over time. 

Others might not have an industry farm plan in place, and they need to be aware that this is a new requirement to consider. There's help and assistance available across the country for farmers starting out on their farm plan journey. 

We understand this is going to take time, and farmers have 18 months from when the system goes live in their area to prepare their first plan. 

The freshwater farm plan system comes back to the idea that every farm and every catchment is different. Freshwater farm plans will be tailored to the size of the farm, and farmers will be able to identify and manage their individual risks. 

Smaller farms will need to consider what's relevant in their catchment and what they need to do to address these issues over time. Freshwater farm plans enable farmers to plan, over a number of years, the risks they need to manage and the investments they need to make. Irrespective of whether a farm is large or small, they will be able to develop a tailored plan. 

The number of freshwater farm plans created is not the focus. Rather, it is about making sure risks to freshwater are correctly identified and actions are crafted to manage these risks. 



How much a plan will cost to prepare or certify is up to the certifier and will depend on a range of factors such as the type of farm, scale and if the certifier prepares the plan as well as certifying it. It is recommended that you check with your certifier about the scope of work and cost when seeking to engage them.  


Certification and auditing process

If they have not written the plan, they will check to see if the freshwater farm plan you, or a plan writer has developed, meets the certification requirements. This includes deciding if the plan has appropriately identified and assessed on-farm risks to freshwater, selected actions to manage risks and accounted for their catchment context. If they are preparing the plan for you then they will do all of the above, as well as writing the plan.  

The auditor will assess if you are implementing the freshwater farm plan as set out in the certified plan. 

Council’s role is to: 

  • write and publish a catchment context for each part of Otago 
  • develop and administer a regional training programme for certifiers and auditors 
  • monitor compliance with the farm plan regulations and have a compliance strategy 
  • support the implementation of farm plans in Otago 
  • publish and maintain a list of regionally trained certifiers and auditors. 

Council does not have a role in writing, certifying, or auditing plans. This part of the system is separate to the Council which has been set up by the legislation.  

ORC will have a list of regionally appointed certifiers on our website from which you can choose. 

Certifiers will first have to be nationally certified, then certified for each region they work in. There will be regional specific training and requirements that a certifier will need to pass. Someone can be appointed as a certifier for more than one region.  

To certify or audit a freshwater farm plan where the farm straddles a regional boundary, the certifier and auditor will need to be appointed in all relevant regions. 

Yes. Your freshwater farm plan will be audited by an auditor. It will need to be audited within 6 months of it being certified. You will then be audited on an annual basis determined by the grade you get. These timeframes can be found here: 



Next audit arranged within 


All regulated actions, catchment actions and supplementary actions have been implemented within the required timeframes 

3 years 


All regulated actions and catchment actions are implemented within the required timeframes, but one or more supplementary actions have not been implemented within the required timeframes. 

2 years 


All regulated actions are implemented within the required timeframes, but one or more catchment actions have not been implemented within the required timeframes. 

1 year 


One or more regulated actions have not been implemented within the required timeframes 


one or more catchment actions or supplementary actions have still not been implemented within the required timeframes, following a subsequent audit – that is, there is a repeated non-implementation of the action(s). 

6 months 

No. While farm operators can apply to be certifiers and auditors, they cannot be the certifier for their own freshwater farm plan or audit their own farm. They must choose another person from the list of approved certifiers and auditors.


Locations/border crossovers

Clarity is being sought from the Ministry for the Environment as to whether a single freshwater farm plan can be prepared for farms that include multiple non-contiguous land parcels.  

There are several factors that influenced this decision, including: 

  • Water quality issues 
  • Mana whenua support for the rollout order 
  • Availability of Canterbury-based certification and auditor resources 
  • Engaged community 
  • Dairy Farmers already have farm plans, so this is a good place to start. 

Which freshwater management unit (FMU) your property is in, and the rollout date for your area, will decide the date you need to have your plan certified. You can find out what FMU your property is in by using the tool here.

As well as being shown on the map here, below is a description of the areas inside each FMU:

North Otago FMU

From the Waitaki River in the north, down through Oamaru and Palmerston townships, to the bottom of the southern branch of the Waikouaiti River; and including parts of the lower Waitaki Plains; and Trotters Creek and the Kakanui, Shag, Waikouaiti, Waianakarua, and Pleasant Rivers.

Lower Clutha Rohe (Clutha Mata-au FMU)

The part of the Clutha/Mata-au FMU known as Lower Clutha Rohe includes the Pomahaka catchment; and several other river catchments that feed the Clutha/Mata-au River, including the Waitahuna, Waiwera, Tuapeka, and Waipahi catchments.

Upper Lakes Rohe (Clutha Mata-au FMU)

The area covering the lakes of Whakatipu, Wānaka, and Hāwea, from their tributaries to their outlets.

Dunstan Rohe (Clutha Mata-au FMU)

The area running from the outlets of Lakes Wānaka, Whakatipu, and Hāwea south to the Clyde Dam and including the Kawarau, Nevis, Shotover, Upper Clutha/Mata-au, Hāwea, Cardrona, Arrow, and Lindis Rivers and many smaller tributaries of the Clutha/Mata-au River such as the Lowburn, Amisfield Burn, Bannock Burn, and Luggate Creek.

Manuherekia Rohe (Clutha Mata-au FMU)

The area located between the Dunstan Range to the west, the St Bathans Range to the north, the Hawkdun Range and Rough Ridge to the east, and the Knobby Range to the south.

Roxburgh Rohe (Clutha Mata-au FMU)

The area extending from the Clyde Dam to Beaumont; and covering Alexandra, Clyde, and Roxburgh; and including tributaries of the Clutha/Mata-au River, such as the Fraser River (also known as the Earnscleugh), Benger Burn, and Teviot and Beaumont Rivers.

Taiari/Taieri FMU

The area covering the entire Taieri River catchment, reaching from Taieri Mouth across the Taieri Plain into the Strath Taieri and Maniototo Basins.

Catlins FMU

The area located along the southern coast of Otago Region including the Catlins, Ōwaka, Maclennan, and Tahakopa Rivers.

Dunedin & Coast FMU

The area running from just south of Karitane down to the mouth of the Clutha/Mata-au River and including the Waitati River, Leith Stream, and Kaikorai Stream catchments within Dunedin city; and the Tokomairaro (Tokomairiro) River in the south.

The FMU boundaries used for the farm plan regulations were based on the boundaries used in the proposed Regional Policy Statement and stage 2 of the Land and Water Plan consultation. The boundaries for these FMU’s changed slightly through the RPS process. It is not proposed to change the boundaries for the Freshwater Farm Plan rollout.



The latest date will apply.  

ORC will aim to have a list of certifiers available on our Freshwater far plans web page but this will not be until early 2024, or until national and regional training for Otago certifiers has been completed. 


Process for freshwater farm plans

The freshwater farm plan will need to be re-certified for any parts of the farm affected, if within 12 months of the plan being certified, the following applies: 

  • The new farm operator undertakes significant changes in farming activities 
  • The farm changes farm operator and the new operator does not adopt the existing certified freshwater farm plan. 

The farm operator may submit the relevant part of the certified freshwater farm plan that has been amended. 

[Regulation 27 of the NES-FW] 

You will be able to use information already in that farm plan as part of your freshwater farm plan. There are parts you will need to update to meet the regulations, including looking at the catchment context for your area and checking that actions are included that address matters included in this. If you have an industry plan it is recommended that you speak to your industry rep about the plan and any support available to you.  

Whoever helps you draft your freshwater farm plan will also be able to work with what you already have and identify what else is needed. 

The INFDP is the national database being built to manage the certification and auditing of farm plans. Farm plans from all regions of New Zealand will be managed in the same system. 

Not as such. It is the consistency in data collection and how land units are identified which have greater implications for the INFDP. All freshwater farm plans, no matter what scale, will need to have data entered into the INFDP that aligns with the data schema requirements. This will be covered further in the INFDP system guidance.  

Absolutely. It's the farmers' and growers’ data, and the material passed to councils will be the action plans and some administrative information. Councils will need this information to ensure compliance with the regulations as well as for monitoring the effectiveness of the system. 

To learn more about freshwater farm plans and how they will affect you, head to the Ministry for the Environment website. 

Freshwater farm plans will contain information about a property, some of which will need to be supplied to Council by certifiers and auditors. This information is limited and includes:  

  • Administrative details 
  • The certified action plan 
  • Maps 
  • A statement of where the plan is being used to meet other regulatory requirements 
  • A conflict-of-interest declaration 
  • Audit report  
  • Audit grade.  


All other data and information included in the plan does not need to be proactively supplied to Council. 

Freshwater farm plan data will be securely stored on the INFDP. The INFDP will be a secure, standardised data collection and reporting tool ready for use by 2024. 

This is currently being worked though with MfE and the regional sector. 

CCCV is developed by Council and will provide catchment information to be included in freshwater farm plans so that people can understand the risks in their catchment and target their onsite actions to the specific issues in their catchment. 

This is important as it will assist you in addressing specific aims for your catchment through your freshwater farm plan. 

This may be a sensible approach for the farmer/grower 

Regional Council Compliance teams are required to monitor farm operators and their freshwater farm plan under these regulations. 

The focus on the compliance will be around educating and supporting farmers to under the freshwater farm plan requirements. 

If non-compliance is identified, appropriate action will be undertaken in accordance with the Resource Management Act (RMA) Compliance and Enforcement Policy. 

ORC is working alongside Te Uru Kahika and other regional councils across New Zealand to develop our approach to support best practice and consistency across the regions. 


Further information

The Freshwater Farm Plans Regulations published on 19 June 2023: 

Resource Management (Freshwater Farm Plans) Regulations 2023 (SL 2023/113) – New Zealand Legislation 

Government freshwater work programme   

ORC Media release: Freshwater Farm Plans on horizon for Otago 

ORC Media release: Freshwater Farm Plans Rollout Confirmed 


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