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Auckla nd Welling ton Chris tchu rch
Memorandum
TO
π
RE
James Ryan
FROM
Shirley Hayward
DATE
14 September 2012
Technical review of freshwater outcomes and nutrient management policies in
Environment Canterbury’s proposed Land and Water Plan
As requested, this memo provides comments on the sections of Environment Canterbury’s proposed Land and Water Regional Plan
dealing with freshwater outcomes and nutrient management policies and rules.
1.0 Fresh water outcomes in Tables 1a, b, c
The proposed Land and Water plan (proposed plan) fresh water outcomes in Tables 1a and b have been transferred directly
from the NRRP water quality objectives WQL1 (Chapter 4) with additional outcomes included from the NRRP water quantity
Policy WQN3 (Chapter 5) to ensure an “integrated set of fresh water outcomes for both water quality and quantity” (S32
report).
The fresh water outcomes in Tables 1a and b (rivers and lakes) were based on recommen dations in a technical report (the
technical report) written by Environment Canterbury scientists (Hayward et al., 2009). As one of the three authors of this
report, my comments below are based consideration of how recommendations have been implemented in th e proposed
Land and Water Plan.
Table 1c is a modified version of the NRRP groundwater quality objectives WQL2.1 and quantity objectives WQN3.
The proposed plan objectives provide narrative statements that describe in broad terms the outcomes or goals for land a nd
water management in Canterbury. These objectives apply across the region and sit above the sub -regional chapters. A
distinction between how the NRRP and the proposed plan use the numeric outcomes (Tables 1a, b and c) is their location
within objectives in the NRRP in contrast to sitting in policies within the proposed plan. The proposed plan approach
provides the opportunity at the sub-regional level for review and development of catchment specific fresh water outcomes
and limits that ensure biophysical, cultural, social and economic consequences are assessed and understood.
1.1
Selection of indicators of water quality outcomes for rivers and lakes
Norton and Snelder (2009) provided a framework for setting numeric water quality objectives and standards that formed
the basis of the technical report. They recommended identifying water quality outcomes for each management unit ( river
or lake type e.g., alpine-upland river) that related to the combined effect of all activities (e.g., discharges, water
abstraction etc) and enabled the appropriate condition of the water body identified in relation to its key values.
The technical report included recommendations for a range of indicators that broadly covered the issues of ecological
health, nutrient enrichment, habitat quality, visual amenity and microbial quality. The technical report authors explored a
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number of options for indicators, and selected those they considered most appropriate based on scientific defensibility,
extent of use both nationally and regionally, understanding by water resource practitioners, responsiveness to activities tha t
are being managed and relevance to purposes for management. Some indicators chosen lacked national guidance (e.g.,
macrophyte cover and sedimentation) but their inclusion was considered crucial in order to provide full coverage of the
main issues affecting the region’s waterways.
The main indicator of ecological health, QMCI 1, was not considered ideal because of its natural variability and sensitivity to
sampling methodologies. Nor is it the indicator Environment Canterbury routinely uses to report on stream health
monitoring. However, its inclusion was justified on the basis that it is reasonably well understood nationally, is responsive
to a range of human influences and for which there are national monitoring protocols.
The key indicators of nutrient enrichment are: macrophyte cover of the stream bed (% cover of emergent and total
macrophytes) and periphyton (biomass as measured by chlorophyll a, and % cover of filamentous algae) for rivers, and the
trophic level index 2 for lakes. Indicators such as QMCI, dissolved oxygen, LakeSPI 3, and visual colour are indirectly related
to nutrient enrichment. Periphyton biomass (chlorophyll a and cover of nuisance algae) and the trophic level index are
widely used and understood in New Zealand but with some degree of contention about their appl icability to all rivers or
lakes, and to management responses. However, they do integrate the effects of nutrient inputs, climate, hydrology and
other biophysical conditions that mean they are suitable as indicators relating to a number of management poli cies.
Measures of macrophyte growth also integrate a range of factors but there were no national guidelines available at the time
of the NRRP hearings, which therefore required a pragmatic approa ch based on existing data and a professional
assessment of what might constitute ‘natural and acceptable’.
The microbiological indicator is based on the protocols in the Ministry of Health and Ministry for the Environment’s
microbiological guidelines for marine and fresh water recreational areas (MfE/MoH 2003). Th e tables refer to the suitability
for recreation grade (SFRG) which is a grading system for contact recreational waters based on a combination of faecal
indicator concentrations (E. coli concentrations for fresh waters) and site risk assessments. The recr eational guidelines
provide a five point grading system ranging from very good for sites that routinely have very low concentrations of indicator
bacteria and low risk to very poor for sites with routinely very high bacterial concentrations and known risks .
The fresh water outcome tables also include some narrative statements that apply to all rivers or lakes, mainly relating to
effects for which it is impractical to derive numeric objectives, or for which there is insufficient data or guidance.
Overall, the selection of numeric indicators are a pragmatic choice which provides a useful basis for evaluating community
expectations in a manner that can be measured over time, and they allow quantitative assessment of activities in relation
to some of the key water quality objectives and policies of the plan. The choice of some indicators such as sedimentation
and macrophyte cover was novel at the time, and the subsequent development of national guidelines for these indicators
needs to be taken into consideration, ideally at the time the zone committees consider fresh water outcomes for the subregional chapters.
1
QMCI – quantitative macroinvertebrate community index. This index allocates invertebrate taxa a score between 1 and 10 depending on
each taxon’s tolerance to organic enrichment. These scores are multiplied by the abundance of the taxa and divided by the tot al
abundance then combined to give an overall QMCI value.
2
Trophic level index (TLI) integrates measures of nitrogen, phosphorus, chlorophyll a and water clarity into an index that des cribes the
trophic status of a lake on a scale of 0-7.
3
LakeSPI (Lake Submerged Plant Indicators) is an information and management tool used to assess and report on the ecological condition
of a lake by assessing the composition of native and exotic plants growing in it, taking into account natural limiting factors such as depth or turbidity.
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1.2
3
Numeric thresholds of Tables 1a, b and c
The water quality objective recommendations in the technical report were developed with the aim of setting ‘aspirational
but achievable’ objectives. It was acknowledged that for some water body types (particularly urban and rural spring -fed
streams), the objectives recommended were higher (better) than that found currently and that longer timeframes (longer
than the life-time of the plan) would be needed for the majority of streams to achieve the objectives. The NRRP also noted
that ‘Although the improvement may take longer than the 10 years before all the provisions of NRRP have been reviewed, it is
expected that substantial progress will be made during that time.’ While the authors of the technical report aimed to set objectives
that were for the most part ‘technically’ achievable, the full cost and consequences of achieving the objectives were not determined.
Subsequent national guidance on some of the less well established indicators (e.g., macrophytes and sedimentation) is
emerging (Clapcott et al 2011, Matheson et al., 2012). A reasonable expectation is that the zone committee process will
take account of recent guideline developments to assist with development of specific objectives at their catchment and
community level.
An important aspect of the fresh water outcomes in Tables 1a and b is the broad categories used to group river and lake
types, within which there will be considerable variability in responses and resilience of individual rivers and lakes to natural
and anthropogenic influences. The relatively coarse categories means that the numeric limits may not be appropriate for
some individual rivers or lakes, particularly where their characteristics deviate from the broad characteristics of the river or
lake type. For example, some hill-fed rivers in Canterbury that have a high proportion of tertiary sediments in their
catchment are naturally enriched in phosphorus and other minerals, and generally produce a high periphyton biomass
which then impacts on invertebrate communities. These rivers may not be able to reasonably achieve one or more of the
numeric limits set for hill-fed rivers and therefore the opportunity to review the numeric outcomes at the catchment scale is
needed.
The thresholds for periphyton indicators (chlorophyll a and filamentous algae cover) are derived from the NZ periphyton
guidelines (Biggs 2000), with the most conservative threshold that provides for protection of high biodiversity (50 mg/m 2
chlorophyll a) applied to the upland reaches of alpine and hill-fed rivers and inland spring-fed streams. This threshold is
well recognised as conservative and it is likely that at least some individual rivers within these upland areas naturally
exceed this threshold on a regular or irregular basis. The chlorophyll a thresholds of 120 mg/m 2 and 200 mg/m 2 were
applied to rivers based on river types that had high salmonid fisheries values (120 mg/m 2 ) or are primarily valued for their
aesthetic/amenity and general biodiversity values (200 mg/m 2 ). These thresholds are applied widely throughout New
Zealand and are appropriately set for the broad river types used in the proposed plan. However, as discussed above,
examination of individual rivers or catchments may justify al ternatives to these values.
Macrophyte cover thresholds were based largely on observed data and on observed effects (e.g., stream choking). It is
acknowledged that many lowland streams (spring-fed-plains) exceed this threshold regularly. A recently released review of
national guidelines for aquatic plant and nutrients provide a provisional guideline for total macrophyte cover of 50%
(Clapcott, et al 2011), which is similar to the proposed plan thresholds for spring -fed-plain streams but is more permissive
than the thresholds for upland and inland basin spring-fed streams (30% maximum cover).
The QMCI thresholds in the proposed plan vary widely. QMCI thresholds that indicate good to excellent water quality are
set for the upland reaches of alpine and hill-fed rivers and spring-fed streams. In contrast, QMCI thresholds for urban
streams are set at levels indicative of poor water quality. The lower reaches of the main river groups are broadly set at
levels indicative of fair to good water quality. The QMCI indicator is described as a ‘minimum score’ meaning that any
QMCI value for a river should not be less than the value set. Given the inherent variability in QMCI values, many sites will
‘fail’ this threshold on occasions without any long -term consequences. It would be preferable to set thresholds based on
average or median QMCI values for a river, which is more likely to reflect the resilience of the river system and
accommodate natural variability.
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The trophic level index (TLI) for lakes varies from large high country lakes being set at the microtrophic/oligotrophic
boundary (low level of enrichment) to coastal lakes set at the highly enriched supertrophic/hypertrophic boundary. The
smaller high country lakes were set at the mesotrophic/eutrophic boundary. One coastal lake, Coopers Lagoon/Muriwai,
has a lower TLI set because it is currently in a better condition than most other coastal lakes and it was considered
inappropriate by the NRRP hearing panel to set the level for this lake much lower than its current condition. The use of the
trophic level index as a broad indicator of trophic condition of coastal lakes is subject to some debate because the effects
often associated with high TLI values such as cyanobacterial bl ooms, deoxygenation of lake bed sediments and fish kills are
not routinely observed in many coastal lake classified by TLI as supertrophic or hypertrophic. Coastal lakes are often
shallow and subject to high levels of wind disturbance and they therefore do not de velop algal blooms and associated
affects predicted by the TLI. Some coastal lakes do, however, respond as predicted by the TLI (e.g., Lake Forsyth/Te Roto
O Wairewa has regular blooms of the toxin forming cyanobacteria Nodularia). There is considerable uncertainty of the
technical feasibility and social and economic implications of meeting the TLI thresholds in some coastal lakes in Canterbury
(e.g, Te Waihora/Lake Ellesmere), which is where the zone committee and community collaborative process is essen tial for
re-evaluating water quality outcomes at the catchment scale.
The microbiological thresholds for the suitability for recreation gradings set for the river and lake management units in the
proposed plan generally fit sensibly with their current co ndition and risks. It is worth noting that no value has been set for
spring-fed streams on the plains (commonly referred to as lowland streams) and urban streams, indicating these streams
are not managed for contact recreational purposes. This is a pragmatic approach for these waterways where achieving low
levels of bacterial contamination will be very difficult and they are generally not used for contact recreation activities (e.g.,
swimming).
Table 1c include water quality outcomes for nitrate concentrations in groundwater relating to the NZ drinking water
standards maximum acceptable value (MAV) for nitrates (MoH 2008). This is a modified version of the groundwater quality
objectives in the NRRP. The main difference is the removal of the perm issible change in ‘overall aquifer’ nitrate
concentrations for the shallow unconfined aquifers which has been replaced with an average limit of 5.6 mg/L, and a
maximum limit of 11.3 mg/L (NZ drinking water standard MAV for nitrate nitrogen). The interpretation of what is meant by
average within the context of an aquifer is absent in the plan, although the Section 32 report (Appendix 6) describes this
as ‘generally determined from a range of samples gathered from wells at the lower end of the zone’. Setting the average nitrate
nitrogen concentration at half the drinking water standards limit may be overly conservative, depending on how the ‘average’ is
intended to be calculated.
1.3
Use of the fresh water outcomes tables in proposed plan policies and rules
The fresh water numeric outcomes in Policy 4.1 (Tables 1a, b, and c) are linked primarily to the nutrient policies 4.28 to
4.36 and rules for farming activities, but are also included in matters to be considered for stormwater discharges (Policy
4.13). The basis of the nutrient allocation map is linked to whether or not the fresh water outcomes are met, although the
degree of connection between the numeric outcomes and the allocation zone map is unclear. This is discussed in more
detail in the following section.
The nutrient allocation map is linked to the nitrogen limits set for all farming activities and changes to farming activities.
These control whether a land use consent will be needed for farming activities and whether further development can occur
within each catchment zone. A key concern is the use of the nutrient allocation zones and farm nitrogen limits as a
primary method for achieving the broad regional-scale numeric outcomes. These numeric outcomes were developed at the
regional scale using broad categories of river, lake and aquifer management units, and a mixture of well-established and
novel indicators. They were based on an assumption of being ‘aspirational but achievable’, but the economic and social
implication of their achievability has not been determined.
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The zone committee and collaborative community approach is a more appropriate mechanism for establishing catchmentscale fresh water outcomes and limits with full understanding of their implications of their community. The use of the
region wide numeric outcomes to determine the default nutrient allocation status sets a precedent against which some
zone committees may find it difficult to recommend alternatives but that constrains achieving their broader aims for their
communities.
2.0 Nutrient Allocation Zones
2.1
Rationale for nutrient allocation zones
The rationale for the nutrient allocation status is provided in the Section 32 report in Appendix 6, which is a memo written
by Environment Canterbury’s three surface water quality scientists. The nutrient allocation zones were categorised
according to whether the water quality outcomes were being ‘met’, ‘at risk’ or ‘not met’. Separate ‘small sensitive lake ’
and ‘unclassified’ catchments were also identified.
Appendix 6 of the Section 32 report provides a broad description of the process the scientists used to derive the nutrient
allocation zones. The process is described as an ‘expert opinion’ approach based on ‘knowledge of nutrient sensitive
values’. However, the memo fails to provide sufficient detail that allows examination of the framework or data used in the
assessments. The memo provides a list of the assessed status for each catchment zone and an elementary description of
the reason for the assigned status. However, there appears to be considerable inconsistencies in the status assigned to
catchments.
Examples of inconsistencies include:
Hakataramea catchment – classified as ‘at risk’
The Hakataramea River is monitored by NIWA as part of the national rivers water quality network and a recent report
on trends in nuisance data collected by NIWA show the Hakataramea site has a mean annual maximum filamentous
algae of 40% cover (Quinn 2009). This indicates frequent exceedence of the periphyton outcome for filamentous
algae for this river, which would presumably lead one to conclude this catchment does not meet the water quality
outcomes.
Waikakahi catchment – ‘not meeting water quality outcomes’ and Whitneys catchment - ‘meeting water quality outcomes’
Figure 1 illustrates nutrient concentration ranges for a number of lowland stream sites within dairying catchment in
Canterbury (from Hayward 2009). While the graph show somewhat older data (for the period 2005 -2009), water
quality patterns will not have dramatically changed in recent years. What stands out as an apparent contradiction is
the classification of the Waikakahi catchment as ‘not meeting water quality outcomes based on high and increasing
nutrient concentrations’ while the adjacent Whitneys catchment (part of the Morven Glenavy nutrient allocation
zone) is classified as ‘meeting water quality outcomes’. Both o f these streams have elevated phosphorus
concentrations, and Whitneys Creek’ has particularly elevated dissolved phosphorus concentrations (highest range of
all streams illustrated) but nitrate concentrations within these streams are similar, and lower tha n other areas
classified only as ‘at risk’. Both streams are within the Morven Glenavy Ikawai irrigation scheme command area and
are subject to similar irrigation practices and land uses. While there may be justifiable reasons for this sharp
contrast between these two otherwise similar catchments, this is not apparent from the information provided in
Appendix 6.
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Figure 1 – Nutrient data for lowland streams within dairying catchments in Canterbury (data for period 2005 – 2009)
overlaid by nutrient allocation status as in the proposed plan (red= not meeting water quality outcomes, orange=at
risk, green=meeting water quality outcomes).
Notes: streams identified as Amuri fall within the Hurunui Waiau
Regional Plan.
The key point of these examples is that it is difficult to have confidence that the ‘expert opinion’ approach provided a
robust and consistent framework for evaluating the nutrient allocation zone status. Furthermore, the memo is sufficiently
obtuse that it will be difficult for a consent applicant to evaluate their impact on the nutrient status of the zone.
For example, a farmer within the ‘pale blue or green’ or ‘orange’ areas on the planning maps wanting to apply for a consent
to change their land use (ie add irrigation or increase N loss by more than 10%) as restricted discretionary or discretionary
activity, will be required to determine the effect of their nutrient losses on the nutrient allocation status of their releva nt
management zone. In the absence of a robust and consistent framework for the nutrient allocation status, the analysis
may be ad hoc and most likely adversarial, creating unnecessary uncertainty, cost and stress on individuals.
A perverse outcome of the current nutrient status maps is that because of the constraint in changing land use on the
plains and because of the obscurity of the basis of the nutrient status map, a potential outcome is that it may be easier to
undergo land use changes in the high quality upland areas of Canterbury than on the plains.
2.2
Zone boundaries
The nutrient allocation zone boundaries are largely derived from surface water catchment boundaries of either main river
catchments or tributary sub-catchments. The larger zones on the plains appear to relate to gr oundwater allocation zones.
The boundaries do not follow roads or property boundaries and therefore, many farm boundaries cross between zones
differing in their nutrient status. While it is preferable for zone boundaries to be based on technical data thi s creates a
practical problem for properties that occur across the boundaries.
2.3
Lake zone
Lakes are notoriously sensitive to the cumulative impacts of nutrient inputs (e .g. Taupo, Rotorua, Waituna, Brunner). This
is primarily because of their long water residence time (compared to a river) along with other processes that mean they
have a high potential to accumulate nutrients. With time and favourable conditions this manifests as increased algal
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biomass, reduced water clarity and a range of other effect s that can, in severe cases, lead to catastrophic changes in lake
ecosystems.
It is not unreasonable to identify lakes that are either currently or potentially at risk of unacceptable changes in their
trophic status, and manage those risks accordingly. Most of Canterbury’s high country lakes are likely to be co -limited with
regard to nutrient limitations, and therefore, management of both N and P losses to avoid enrichment effects is justified.
The sensitive lake catchment status was based on a review of existing TLI data and also considered recent intensification of
land uses, the extent of catchment development, and recent changes in TLI.’ The list of ‘sensitive lakes’ appears to include most
small (between 1 -7 ha area) high country lakes and some (but not all) small coastal lakes.
A notable exclusion is Wainono Lagoon, which is identified specifically in the proposed plan as not meeting water quality
outcomes and within an ‘over allocated’ nutrient zone. The reason for its exclusion from the sens itive lake catchment
classification is not obvious, but probably relates to the high number of properties that would be affected by its inclusion in
the sensitive lake catchment rules.
2.4 Implications of nutrient allocation zones
The authors of Appendix 6 describe attempting to use existing hydrological and water quality to assess sites against a range
of water quality guidelines and models. This resulted in most catchments being classified as ‘water quality outcomes not
met’, which they considered as ‘too conservative and unrealistic’. They then proceeded to use an expert opinion
assessment. This implies that the authors had to make ‘value judgements’ in order to balance consequences of using
conservative guidelines against social implications. This co ntradicts recent advice to the Ministry for the Environment that
identifies the role of science to ‘describe the effects of various management options, on environmental, social and economic
values, so that informed choices between the options can be made by decision makers, not scientists’ (Norton et al 2010). This
recommendation is consistent with the ‘Preferred Approach’ promoted by Environment Canterbury (Brown et al 2011).
The consequence of this ‘expert opinion’ approach is that rules relating to nutrient red zones po tentially place a severe
restriction on future irrigation development including the development of the water storage proposals which rely on
increased irrigation uptake. Such an approach would seem contrary to the intentions of the Canterbury Water Manage ment
Strategy and contrary to the promotion of water storage. This contradictory approach to water management is not helpful.
An alternative option is to not include the nutrient allocation zone map until the sub-catchment chapters have been progressively
developed through the collaborative community approach (‘preferred approach’). The activity status for land use changes could be
designated as restricted discretionary or discretionary requiring an assessment of the activity directly against the fresh water
objectives and policies (e.g., Tables 1a, b and c) relevant to the catchment in which the activity occurs. The advantage of this
approach is that by considering the broader effects of the land use activity on the freshwater outcomes, mitigations can focus
appropriately on the most relevant issues, which are not always nutrient management.
3.0 Link between nitrogen rules and fresh water outcomes
The proposed plan uses nitrogen limits as a mechanism to control diffuse nutrient discharges as indicated in Section 2.6.
‘The region-wide nitrogen limits in Section 5 of the Plan are designed to move from a regime of little or no statutory
management of diffuse non-point source discharges of nutrients to a statutory regime that requires ‘good management
practice’ across the region.”
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The nutrient zone policies (policies 4.34 to 4.36) imply nitrogen management is the primary mechanism for achieving the
fresh water outcomes. The Section 32 report articulates this assumption by stating that ‘Other contaminants – sediment and
microbial pathogens – are also a significant problem, but if mitigation measures can successfully manage nutrients, in particular
nitrogen9, there is also likely to be a reduction in these other contaminants’ (Appendix 1 – Section 2.1). This assumption contradicts
a general understanding that mitigation measures for minimising nitrogen losses are quite different to those that manage losses of
phosphorus, sediment and microbial inputs. This narrow focus risks failure of fresh water outcomes being achieved in the best
way.
The specific ‘farming rules’ use nitrogen losses to determine activity status for farming activities and changes to farming
activities. Most of the farming rules will require the preparation and auditing of farm environment plans. The scope of the
farm environment plan as described in Schedule 7 encompasses a broad range of issues including nutrient, irrigation, soils
and effluent management, wetland and riparian management and stock access to waterways. Prioritisation of these issues
for each farm is more likely to contribute to achieving the fresh water outcomes, than managing nitrogen or nutrients
alone. Using nitrogen limits as a trigger for control on these other activities is questionable, and is likely to drive farmers to
focus on ensuring they meet the relevant nitrogen limit, at the risk of less focus on other environmental aspects of their
farm operation. Furthermore, if N limits constrai n farm production and profitability, farmers will have less discretionary
funds for mitigation of other environmental effects.
Plant growth in majority of rivers in Canterbury is primarily limited by the amount of phosphorus, particularly in the rivers
and streams that cross the Plains (Stevenson et al., 2010). The upper reaches of river and lakes are more likely co -limited
(both N and P concentrations affect plant and algae growth). In addition to phosphorus inputs, other factors such as flows,
sedimentation, temperature and shading influence the amount and type of plant growth (algae and macrophytes) and
ultimately affect the ecological and aesthetic condition of a waterway. Critical factors such as sedimentation and flows are
some of the key constraining factors limiting the ecological health of many of Canterbury’s lowland and hill -fed rivers
respectively (Stevenson et al., 2010). Therefore, while the focus on nitrogen management is the most constraining limit
on land use and irrigation development, it is one of the less likely tools to achieve the fresh water outcomes.
4.0 High naturalness water bodies
The main effect of high naturalness water bodies is the constraint (non -complying activity status) of any water takes,
diversions, dams, and works and structures in the their beds. They are included in the definition of outstanding fresh water
bodies and therefore are part of Objective 3.5 Objective 3.5 - Outstanding fresh water bodies and hāpua and their margins are maintained in their existing state or
restored where degraded.
The areas currently identified as being ‘high naturalness’ were taken directly from the NRRP.
as follows:

Full length of the Clarence River (including lakes Rotoiti, Rotorua and Tennyson)

Ashley River gorge

Many Rakaia lakes – identified in the Rakaia WCO

Ashburton lakes –Ō Tū Wharekai- one of the three sites that make up DOC’s national ArawaiKakariki wetland
restoration programme.
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Upper reaches of Hook River and Waimate Creek (not in NRRP – added to L&WRP because an ecological survey
indicated sensitive invertebrate communities and high habitat and water quality conditions warranted special
protection – Kingett Mitchell, 2005)
High naturalness areas of the Hurunui Waiau catchments previously identified in th e NRRP are now covered in the proposed
Hurunui Waiau plan. Other areas of that would fit the descriptions of ‘high naturalness’ are the upper reaches of the major
alpine rivers, which have either separate catchment plans (Waimakariri River Regional Plan, Waitaki Catchment Water
Allocation Regional Plan) or have Water Conservation Orders (Rakaia and Rangitata rivers).
The NRRP included in the description of high naturalness as ‘Areas where those elements remain largely free of human influence
have high naturalness.’ The characteristics that describe high naturalness water bodies include high visual amenity, high
degree of naturalness, outstanding wildlife, fisheries and recreational features, and includes the habitat for brown trout an d
Chinook salmon. It is questionable whether the habitat for trout and salmon and their associated fisheries are appropriate
for inclusion of high naturalness water bodies. However, this has probably been well debated in the NRRP hearings and
clearly has persisted.
The selection of sites that fit into the ‘high naturalness’ classification is appears variable. It is understandable that ma ny
of the high country lakes are so classified, as well as sites where data supports high ecological values along with an
unmodified setting (Hook R and Waimate Ck). For other sites it is less clear about why they have been selected (e.g. full
length of Clarence River and Ashley Gorge) when it is likely that sites in comparable condition exist elsewhere that have not
been included.
The only one of these that significantly affects intensive agriculture is the Ashley gorge as water storage options have been
identified and explored for the gorge.
5.0 Summary
The fresh water outcomes in Policy 4.1, Tables 1a, b and c were transferred with small modifications from the objectives
and policies in the NRRP. They were developed at the regional scale using broad categories of river, lake and aquifer
management units, and a mixture of well-established and novel indicators. While the numeric outcomes were based on an
assumption of being ‘aspirational but achievable’, the economic and social implications of their achievability for individual
catchments have not been determined. Therefore, Tables 1a, b and c can be viewed as a useful set of numeric indicators
and thresholds which generally provide for the key values identified for the broad river, lake and aquifer types. However,
these broad outcomes should be reviewed at the catchment scale and considered within the context of catchment spe cific
characteristics and community aspirations prior to setting catchment-specific outcomes and limits, and consequently
determination of allocation status.
The rationale used to determine the interim allocation status of catchment zo nes across the region is poorly described and
may not be based on a robust and consistent framework. The setting of catchment -specific outcomes and limits should be
developed at the sub-regional level within a specified timeframe which would meet the requirements of the National Policy
Statement for Freshwater management regarding the requirement to set limits for all catchments.
The proposed plan appears to use the nutrient allocation zone as a principal method for achieving the fresh water
outcomes. This narrow focus of the policies and rules on nutrient management risks failure to achieve the fresh water
outcomes because other aspects such as physical habitat management and flow management are not given equal
consideration and it does not encourage innovative approaches.
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The rules relating to nutrient red zones potentially place a severe restriction on future irrigation development including th e
development of the water storage proposals which rely on increased irrigation uptake. Such an approach woul d seem
contrary to the intentions of the Canterbury Water Management Strategy and contrary to the promotion of water storage.
This contradictory approach to water management is not helpful.
The zone committee and collaborative community approach is an app ropriate mechanism for establishing catchment-scale
fresh water outcomes and limits with full understanding of their implications on their community. It is through this process
that catchment limits and allocation status should be determined. An interim approach for the regional plan could be to require
significant land use changes to be assessed directly against the fresh water outcomes in tables 1a, b and c. The advantage of this
approach is that by considering the broader effects of the land use activity on the freshwater outcomes, mitigations can focus on the
most relevant issues, which are not always nutrient management.
6.0 References
Biggs, B.J.F. (2000): New Zealand periphyton guidelines. Ministry for the Environment, Wellington.
Brown, I., Ford, R., Woods, T., Davie, T., Hayward, S., Johns, D., Ryan, J., Wedderburn, L., Norton, N., Harris, S. (2012): The
preferred approach for managing the cumulative effects of land use on water quality in the Canterbury Region: a working paper”
Environment Canterbury report R12/23
Clapcott, J.E., Young, R.G., Harding, J.S., Matthaei, C.D., Quinn, J.M. and Death, R.G. (2011) Sediment Assessment Methods:
Protocols and guidelines for assessing the effects of deposited fine sediment on in-stream values. Cawthron Institute, Nelson, New
Zealand.
Hayward, S. (2009): Water quality issues of the Amuri Basin streams and the Hurunui River – summary report March 2009.
Environment Canterbury unpublished report.
Hayward, S., Meredith, A., Stevenson, M., 2009: Review of proposed NRRP water quality objectives and standards.
Environment Canterbury report R09/16.
Kingett Mitchell Ltd (2005) Minimum flows for the Wainono Lagoon. Report prepared for Environment Canterbury, September 2005.
Report number U06/63.
Matheson, F., Quinn, J., Hickey, C. (2012): Review of the New Zealand instream plant and nutrient guidelines and
development of an extended decision making framework: Phases 1 and 2 final report. Prepared for Ministry of Science and
Innovation Envirolink Fund.
Ministry for the Environment and Ministry of Health. (2003). Microbiological Water Quality Guidelines for Marine and Fresh
water Recreational Areas. Updated by the New Zealand Ministry for the Environment in June 2003, Wellington.
Ministry of Health (2008): Drinking-water Standards for New Zealand 2005 (Revised 2008). Wellington: Ministry of Health.
Norton, N., Snelder, T. (2009): On Measurable Objectives and Receiving Water Quality Standards for Environment Canterbury’s
Proposed Natural Resources Regional Plan. NIWA Client Report CHC2009-040
Norton, N., Snelder, T., Rouse, H. (2010): Technical and scientific considerations when setting measurable objectives and limits for
water management. Prepared for the Ministry for the Environment. Christchurch: National Institute of Water and Atmospheric
Research Ltd.
Stevenson, M., Wilks, T., Hayward, S. (2010): An overview of the state and trends in water quality of Canterbury’s rivers and
streams. Environment Canterbury Report number R10/17.
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