FEP Audits

Environment Canterbury does not have control on the charges set by the FEP Auditors. The costs will, however, be dependent on the size and complexity of the farm systems and the time spent to undertake the audit.

If you are supplied with water from an Irrigation Scheme or Principal Water Supplier and your property is covered by their consent or permit, or if you are part of an HWRRP Collective with an approved Environment Management Strategy, the FEP Audit will be arranged in line with your contract.

It is unlikely that you would require an additional audit, as long as the ISO accredited audit programme has been approved by Environment Canterbury and meets the requirements of your consent.

A list of approved ISO accredited audit programmes is available from our customer services, ecinfo@ecan.govt.nz.

The date of the first audits is determined by your resource consent or your Irrigation Scheme, Principal Water Supplier or Hurunui Waiau Collective.

The timeframe of subsequent audits is dependent on the audit grade awarded to you at the time of your previous audit.

If you have a change in management or significant change in farm systems you will have to be re-audited within the year or 6 months depending on your previous audit grade.

• The most recent version of your FEP and the consent containing FEP requirements – you need to ensure that your FEP meets at a minimum the FEP requirements included in your consent (The Auditor will ask you for this information before the audit)
• Your Nutrient Losses (including GMP losses as estimated by the Farm Portal. The Auditor will ask you for this information before to the audit):
• The Farm Portal Farm Report
• Hard Copy report of electronic file generated by the person that estimated your losses
• Records related to the management of fertilizer, irrigation, soils, effluent, waterways, waste/offal/silage pits and non-irrigation water, for example:
• Pictures of stock exclusion methods, riparian margins management, and where applicable, mahinga kai management;
• Farm Diary or other records types relating to:
• Irrigation scheduling and application;
• Fertilizer application; and
• Effluent application.
• Soil moisture records;
• Water Use for dairy shed and stock-water;
• Maintenance records for machinery such as travelling irrigator, liquid and solid effluent facilities, irrigation systems, fertilizer application, machinery etc.; and
• Inspection sheets for crossing facilities, feed-pads, waste/offal/silage pits.

Record keeping is useful for your business and it can help you identify where you can reduce costs and increase efficiency.

Individual consented farmers and farming enterprises (multiple properties under single management)

The Certified FEP Auditor will enter data into an online reporting tool hosted by Environment Canterbury. The audit information (what is contained within the audit report) is held by Environment Canterbury. However, Environment Canterbury is planning on reporting information at an aggregated level for the following:

• Audit Grade; and
• Primary Farming Type; and
• Nutrient Management Zone; and
• Level of Confidence for each objective and associated target(s).

Farming enterprises (multiple properties under multiple management)

The Certified FEP auditor shall not submit any information to Environment Canterbury. Farming Enterprises under multiple management shall themselves submit a summary report to Environment Canterbury containing:

• Name of Certified FEP Auditor
• Date of Audit
• Name of each Farm
• Farm Type
• Audit Grade for each farm belonging to the farming enterprise; and
• Consent Number covered by the Audit containing FEP audit requirement
• Audit grade for each farm
• Average Annual nitrogen loss
• Sum of nitrogen baselines
• And where applicable:
• Sum of Baseline GMPs (as shown in the farm portal farm report - this should be updated prior to the audit)
• Percentage reductions

Irrigation Scheme, Principal Water Supplier or is part of a Hurunui Waiau Collective

No FEP audit data will be sent to Environment Canterbury if you receive water from an Irrigation Scheme, Principal Water Supplier or is part of a Hurunui Waiau Collective. The registered FEP Auditor will liaise directly with them instead.

Irrigation Schemes or Principal Water Suppliers of HWRRP Collectives shall submit a summary report to Environment Canterbury containing the following information:

• Name of Certified FEP Auditors
• Period of Audits
• Aggregated N loss for the year from all properties within the Irrigation Scheme, Principal Water Supplier, or HWRRP Collective by nutrient management zone.
• Summary of the number of farms graded A, B, C and D per farm type
• Summary of the number of farms that are repeated C, D (1st repeat, 2nd repeat) per farm type
• List of the main reasons why farms have been graded C or D
• Programme to improve the performance of these farms
• Progress report on previous identified issues
• Identified illegal discharges and actions taken

Environment Canterbury is governed by the Local Government Official Information & Meetings Act and will apply that legislation together with the Privacy Act when considering any specific request for an individual’s FEP audit information.

Overall Grade	A	B	C	D
Compliance against your resource consent	Compliant	Compliant	Non-compliant	Non-compliant
Although a B Audit grade is considered to be Compliant against your resource consent, there is a requirement that progress will be made over a reasonable timeframe to A grade, demonstrating the farm is at Good Management Practice (GMP) for all management areas.

Frequency of audit	A	B	C	D
Individual consented farm and farming enterprises	3 yr	2 yr	1 yr	6 months
Farms connected to an Environment Canterbury Approved ISO Accredited Audit Programmes (Industry Programme)	Dependent on Approved ISO Accredited Audit Programme timeframe	2 yr	1 yr	6 months
Farms connected to an Irrigation Scheme, Principal Water Supplier, or Hurunui Waiau Collective	4 yr	2 yr	1 yr	6 months
Change in management or significant change in farm systems	1 yr	1 yr	Within the year	6 months

A Grade – Required standards have been met. As a minimum, this means that GMPs have been adopted and implemented in all FEP management areas assessed. In instances where higher standards (i.e. beyond GMP) have been set, an ‘A’ grade recognises the adoption of these standards.

B Grade – Required standards have not yet been fully met in one or more FEP management areas. In these management areas, the auditor has assigned a Medium LOC that the objective has been met. All other management areas have been assigned High LOC ratings. For those activity areas where the standards have not been met there is verifiable evidence of an action plan with set time frames in place.

If at the following audit the auditor judges GMP is now being met for all management areas, they can award an A grade. However, the auditor may award a further B grade under the following circumstances:

• if they are confident that progress is being made in the delivery of the previously agreed action plan, within the agreed timeframe, although some areas are not yet at GMP. If the auditor judges that insufficient progress has been made towards the delivery of the agreed action plan, they could award a C grade, at which point the farm will be deemed to be non-compliant against its resource consent;
• where previous action plans have been fully implemented, but there is a Medium LOC in another management area.

C Grade – Required standards have not yet been fully met in one or more FEP management areas. In these management areas, the auditor has assigned a Medium LOC that the objective has been met. All other management areas have been assigned High LOC ratings. For those activity areas where the standards have not been met, for one or more of the identified areas there is no verifiable evidence of an action plan with set timeframes in place or the action plan has not been implemented and required actions from the previous audit adequately addressed.

D Grade – Required standards have not yet been met in one or more management areas. The auditor has assigned a Low LOC rating that the objective has been met for one or more FEP management area.

Farm Environment Plans are assessed in accordance with the protocols contained in the Canterbury Certified Farm Environment Plan (FEP) Auditor Manual. We also have industry-agreed Farm Environment Plan Guidelines for Auditors.

Please note: If you have received any advice or input from an auditor in any component of the preparation of an FEP or audit, including nutrient budgets, then the same auditor cannot audit that farm.

Background

There are circumstances where the consent holder would like to extend the date that their Farm Environment Plan (FEP) audit is due. The circumstances may include but not be limited to:

• Compassionate grounds; or
• Biosecurity reasons e.g. Mycoplasma bovis; or
• High risk activities not occurring when first audit due date falls; or
• High stress periods e.g. calving, harvest etc.
• Who do I contact to request an audit extension?

All audit requests extensions should be sent via email to FEP.Audit@ecan.govt.nz, expect acknowledgement of the request within 24 hours. If the request cannot be granted immediately you will be provided with a timeframe for a decision (usually within 5 working days).

• Nutrient Budgets (latest version of OVERSEER® or equivalent model approved by Environment Canterbury)
• Farm Portal Farm Report
• Critical nutrient source map
• Spreadmark certificate
• Proof of fertilizer placement records
• Fertiliser records
• Fertiliser application records (incl. GPS records)
• Soil moisture records
• Soil temperature records
• Soil test results(incl. Deep soil N test results)
• Plant analysis results
• Advisors recommendations report
• Crop calculator records
• Fertilizer application equipment calibration results

• Design specifications
• Certified/Accredited designer used
• System evaluation report
• System commissioning certificate
• System calibration
• Water take records
• Preseason system maintenance records
• Maintenance records
• Breakages & system failure records
• Annual system audit report
• Bucket test results
• Scheduling record
• 10 day water budget
• Application depth records
• Map of irrigation high risk areas
• Soil risk map
• Irrigation GPS records
• Specialised soil mapping records
• Rainfall records
• Climatic records
• Soil moisture records
• Staff training records

• Erosion risk map
• Record of erosion control activities
• Soil incident records
• Soil compaction field test results

• Regional Council Compliance letter
• Effluent irrigation incident records
• Backflow prevention device certificate
• Certified/Accredited designer used
• System maintenance records
• Management plan/procedures
• System incident records
• Emergency management procedures
• Effluent diary
• Procedures manual
• Effluent area map
• System maintenance records
• Application records (incl. depth and GPS records)
• Bucket test results
• Soil moisture records
• Effluent storage design specifications
• Dairy effluent storage calculations
• Effluent storage system leakage test
• Staff training records

• Stock Exclusion Map
• Waterway mapping - fencing
• Riparian management records
• Riparian planting plan
• Risk map and action plan

• Pit Location Map
• Contingency plan

• Water use data
• Water meter data
• Water meter certification
• Water efficiency calculation
• Certification of mechanical device
• Design specifications

The following checklist has been developed to assist Canterbury-based farmers to prepare for the outdoor pork production portion of an upcoming FEP audit: NZ Pork Preparing for FEP Audit

If you have other farming systems e.g. dairy, beef, sheep, arable, horticulture etc. then you can access support on those areas from the relevant industry body.

The below ISO programmes have been approved by Environment Canterbury:

• LEAD WITH PRIDE™ - SYNLAIT
• NZGAP - HORTICULTURE NZ

The Primary Industry Certification Programmes have been recognised by Environment Canterbury:

• Dairy Farm Systems Certification

• Canterbury Certified Farm Environment Plan Auditor Manual June 2019 (PDF File, 1.5MB)
• We also have industry-agreed Farm Environment Plan Guidelines for Auditors.

You can submit an FEP audit complaint or dispute if you are:

• A consent holder
• A property owner
• A Farm Enterprise Manager
• An Irrigation Scheme
• A Principal Water Supplier
• A Hurunui Waiau River Regional Plan Collective.

To submit an FEP audit complaint, you will need to complete an FEP auditing dispute submission form (FEP Auditing Dispute Submission Form - 22 March 2020 (PDF File, 664.77KB)).

The complaint will be investigated by Environment Canterbury and the outcome of the complaint decided by the Chief Executive of Environment Canterbury. If the complaint is substantiated the Chief Executive may decide to inform the professional institute that the Certified FEP Auditor belongs of the outcome.

Please note that if you are a member of an approved ISO programme, you will need to submit a complaint directly to the programme.

If you have an FEP audit dispute, you complete an FEP auditing dispute submission form and submit it along with a fee. The dispute process is cost recoverable, which means that:

• You, as the disputer, pay a submission fee upfront. We will refund this fee if the complaint is substantiated. We will retain the fee if the dispute is unsubstantiated
• The Certified FEP Auditor will pay the fee if the dispute is substantiated. In this case, we will send an invoice to the Certified FEP Auditor at the end of the process.

In considering the submission, we may ask the disputer and the Certified FEP Auditor to attend an interview. We may also ask the Certified FEP Auditor to submit a copy of the FEP audit report together with all the material and evidence they used to determine the audit grade and/or assigned actions. If the dispute is substantiated, Environment Canterbury may revoke the FEP Auditor Certification.

There is no right of appeal to Environment Canterbury’s decision on the resolution of an FEP auditing complaint or dispute.