Belford, Tom
102932
007
Submission on HBRC Plan Change 6
Tukituki River Catchment
Yes, I wish to present verbally if that opportunity exists.
Comments
1. The chief values I believe must be protected are overall ecosystem health for
all species, as well as strong protection of amenity and contact recreation values.
Protecting these values requires that any economic activity undertaken in the
catchment must not further diminish these values, and indeed must put the
catchment on a trajectory where its ecological health is in fact improving from its
current degraded state. Economic activity must be consistent with and sustain
these other values, not supplant or erode them.
Protecting these values also requires integrated management of the entire
watershed, not a zone system that arbitrarily permits the shuffling of values (and
pollution limits) amongst zones in a manner that ultimately escapes
measurability and transparent accountability.
I believe the so-called ‘consultation’ process around catchment values has been
deeply flawed, centered chiefly around affected economic interests, as opposed
to seeking or investigating the attitudes of the total affected community.
Available NZ survey data indicate that the public places a very high importance
on ecological, amenity and recreational values, and in fact rejects the option to
degrade those values so as to create ‘headroom’ for economic intensification. The
broader public, when asked in objective surveys, rejects the false ‘economy vs
environment’ tradeoff that the HBRC and its user group ‘stakeholders’ so
fervently espouse.
2. The Plan must be constructed so as to prevent excessive algae growth in all
parts of the catchment. I support the science-based view of HB Fish & Game that
adequate protection of the ecosystem as well as maintenance of freshwaters
suitable for contact recreation requires the management (and by that I mean
regulation) of both phosphorus and nitrates throughout the system.
In particular, nitrates must be more stringently limited than currently set forth
in the proposed Plan Change so as to ensure control of algae growth, not simply
set at levels related to species toxicity.
I support controlling nitrogen leaching at the source and therefore support a
regime of on-farm nitrogen caps.
3. It is my understanding that national drinking water standards must be
protected throughout the catchment, requiring that any extractions of water
from rivers or aquifers in the catchment be carefully monitored against specified
contaminants at the point of extraction. I am concerned that adequate
monitoring provisions have not been made in this proposed Plan Change. This is
made important by the fact that there are already known ‘hotspots’ of nitrate
contamination in the catchment, and indeed these levels and their risks may be
under-stated.
4. I support the raising of minimum flow levels in the catchment. My concern is
that these minimum flows will not be maintained by the proposed dam scheme.
Nor will the ‘flushing flows’ associated with dam operation be sufficient to
prevent or deal with algae build-up.
5. Dealing with water pollution must begin on the land. I regard the proposed
Plan Change as deficient in its permissive approach to land use practices,
including present practices that enable substantial soil erosion from hill country
parts of the catchment. Land use practices are available to the region that offer
the opportunity to improve soil productivity while increasing the water
retention capacity of the land. If the Plan addressed these opportunities more
explicitly and proactively, significant pressure could be taken off current water
supplies, while at the same time improving water quality.
The HBRC’s current and proposed ‘hands-off’ attitude to regulating land use
practices (and promoting better, including more profitable, farming and soil
restoration methods) is what has gotten the Tukituki catchment to its current
degraded state. More of this same ‘hands-off’ approach will not suffice to
improve the situation, both with respect to water supply and water quality.
It is this refusal to seriously address what is happening on the land now (to say
nothing of any dam-enabled farming intensification) that drives the HBRC’s need
to increase acceptable pollution levels in their proposed Plan Change.
HBRC’s intention to permit increased pollution from land use intensification in
the catchment is signaled clearly by its proposal to strike “maintenance and
enhancement” from the RRMP Objectives 22, 27 and 43.
As to what should be done to mitigate the pollution effects of farming in the
catchments, I would support a Plan Change that incentivises farmers, including
monetarily, to improve soil quality parameters measured on a farm-specific
basis, along the lines recommended by submitter Phyllis Tichinin. And I note that
improving soil quality translates into greater water retention.