Next steps for fresh water
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Submission form
The questions below are a guide only and all comments are welcome. You do not have to answer all
the questions. To ensure your point of view is clearly understood, please explain your rationale and
provide supporting evidence where appropriate.
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* Questions marked with an asterisk are mandatory.
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Fresh water and our environment
1. Do you agree that overall water quality should be maintained or improved within a freshwater
management unit rather than within a region? Why or why not?
Yes
No
However, Firstly there should be a requirement for FMU’s within the catchment (e.g Lower Waitaki
and Upper Waitaki River) to have the same requirements for upstream/downstream catchments,
and that this should reflect the upstream catchment water quality targets. There should also be a
requirement for the water quality to consider the recieving environment as part of the overall scope
and quality targets.
Secondly, the Funding for the FMU’s should be increased to recognise the community efforts that
contribute to the discussion.
Thirdly, the Region should still be accountable and responsible for poor performance achieving
quality targets within an FMU – this safety net must still exist, and be enforceable within a short time
frame
2. How should the attributes be applied, or the values protected, in giving effect to the requirement
to maintain or improve overall water quality? Please explain.
Regional Authorities should be funded to provide a clear understanding to the FMU’s of the baseline
of all surface water bodies, with the aim of categorising the freshwater bodies from highest value –
lowest value, and the relevant attributes allocated to each water body. E.g Tekapo River, High Value
Backcountry River, Freshwater Objective Target A + Other Attributes (MCI, Nutrients, etc) to support
this. The addition of the receiving environment is key. This also removes the need for all surface
water to be at the same standard which is unachievable. Further notes are under MCI section around
river categories.
Attributes should only be set for improving water quality. Maintaining water quality is not an
acceptable target.
3. What is an appropriate way to include measures of macroinvertebrates in the National Policy
Statement for Freshwater Management? What alternative measures could be used for
monitoring ecosystem health?
I strongly support this. MCI index could be developed to reflect the typical river system types, e.g
spring creek, stillwater, lowland – meadows, lowland – bush, lowland – urban, braided alpine river,
mountain stream, bouldery stream etc, which all have different make up of MCI and ranges. This
broad baseline would suit a starting point for targets.
4. What information should be required in a request to include significant infrastructure in
Appendix 3 of the National Policy Statement for Freshwater Management, and why would this
information be important?
I would support that the significant infrastructure is still identified at a National Policy level, as
removing this could create significant debate around what is considered legally to be significant
infrastructure.
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Evidence based gathering for limit setting needs scientific input, limits on occurrence and time of
exceeding bottom line standards (e.g only infrequent and short exceedances of bottom line
standard), and demonstration of the benefits to gain my support for this.
5. Do you agree with applying lake attributes and national bottom lines to intermittently closing or
opening lakes or lagoons? Why or why not?
Yes
No
These are quite different water bodies, and will require quite different attributes to a freshwater
lake. I would also support and recommend that inflow requirements (which originally caused variable
lake levels (only called flooding now that infrastructure is within this zone) are reviewed. For example
water takes from river systems that supply ICOLL’s has a big impact on the normal physical process of
opening the lake to the sea (via breach).
6. What information should be required in a request to list a water body in Appendix 4 of the
National Policy Statement for Freshwater Management, and why would this information be
important?
No comment
7. Do you agree with the proposed requirements and deadlines for excluding livestock from water
bodies? Why or why not?
Yes
No
Yes I agree with the policy to exclude livestock, but the dates for compliance are 10-15 years from
now. This conversation has been happening for 10-15 years already and many have voluntarily
complied with this. This should be standard policy. An alternative to setting timeframes and limits at
a national level for compliance is to set a compliance date, and then any landowner who has not
complied by that time needs to submit an application for exemption (which could consist of a small
bond, time frame to resolve, and actions under the farm management plan to manage in the short
term).
Another alternative is to set the compliance based on a stock unit rate (ha) which is a better
indication of intensity of farming – for example high country farms have a lower stock rate which
may have a very low impact on water quality compared to a dairy farm on rolling hills – If the slope
criteria was used both of these farms may be exempt under this policy.
Livestock will still need access to water, so for some areas (e.g backcountry /highcountry) this will
need consideration.
Economic use of fresh water
8. Should standards for efficient water use be developed? Should standards for good management
practices for diffuse nitrogen discharges be developed? Who should be involved in their
development? When should they be applied to consents (eg, on consent expiry and/or on limit
setting and/or permanent transfer)?
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9. Do you support easier transfer of consents? Do you think the changes outlined in Proposal 2.4
would better enable transfers? What other changes would better enable transfers?
I support a better database of water use (via the new requirement to install water meters) to better
understand water use. However, if water is available from optimisation of irrigation in particular,
then I don’t support transfer of the water to another user, unless this is within an irrigation scheme
only and within the consented take.
I don’t support transfer of contaminant discharge allowances, on the proviso that contaminant
discharge allowances for existing users are reasonable (e.g grandfathering of land use) and do not
impact on productivity. Again this should satisfy the critieria for the receiving environment, i.e
farming in high sensitivity areas can have a large impact on a surface water.
10. How should the Government help councils and communities address over-allocation for water
quality and water quantity? Should it provide guidance, rules or something else (please specify)?
No comment
11. Should councils have greater flexibility in how they meet the costs of improving freshwater
management? For example, by recovering costs from water users and those who discharge to
water? Please provide examples.
Councils should be able to increase rates for the urban areas, allow for a % of industrial water takes
(similar to a development contribution), and be able to enforce reasonable levels of monitoring and
compliance on agricultural users, i.e managed within farm management plans.
Iwi rights and interests in fresh water
12. How can the Government help councils and communities to better interpret and apply Te Mana
o te Wai in their region?
13. Should councils be required to identify and record iwi/hapū relationships with freshwater bodies,
and how should they do it?
14. What would support councils and iwi/hapū to engage about their values for freshwater bodies?
15. What are your views on the proposal for a new rohe-based agreement between iwi and councils
for natural resource management? What type of support would be helpful for councils and iwi to
implement these to enable better iwi/hapū engagement in natural resource planning and
decision-making?
The links to the FMU’s should be fundamental and clearly align with the rohe-based agreements.
16. What are your views of the proposed amendments to water conservation orders? Outline any
issues you see with the process and protection afforded by water conservation orders?
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17. If you are involved with a marae or live in a papakāinga, does it have access to clean, safe
drinking water? What would improve access to clean, safe drinking water for your marae or
papakāinga?
Freshwater funding
18. Do you agree with the proposed criteria for the Freshwater Improvement Fund? Why or why
not?
It is imporant to note that a significant amount of investment has been made on the Waikato River,
whereas a very small proportion has been invested in the South Island. This needs to change.
Crown Irrigation Fund has not provided a viable alternative to funding shortfalls for irrigation
schemes yet.
The Freshwater Improvement Fund should have a long list of improvement projects, not just set
aside projects. For example Augmentation of the Wainono Lagoon should be a priority project.
Set aside (or payment of productive land) should focus on highly sensitive, high value (e.g Tekapo,
Mackenzie Basin) areas to offset restrictions on development that are required to meet nutrient
discharge targets and other quality targets. The impact of these decisions is not just about supporting
farmers, but also around increasing the certainty of the ‘clean green image’ in highly visited areas
from a tourism perspective.
The 50% funding requirement is unreasonable. Government will need to take a lead in this, and
perhaps a better approach is to fund the capital 100%, as long as the operating/maintenance can be
supported by the local council, region, or community.
Projects should have a genuine impact, and be supported by a Better Business Case type approach to
determine funding requirements. This needs to reflect the other options that are on the table, so
that there is a considered approach to achieving the environmental benefits. i.e Make the Funding %
higher, but make the steps to get funding a reasonable requirement (buy in not cost wise).
Other comments
19. Do you have any further comments you wish to make about the Government’s proposals?
The freshwater policy states that we take 2% of our freshwater, but this needs substantiation, and
does not reflect that pressure on select areas. For example the South Canterbury Rivers are almost
dry each summer and this pressure is far greater than 2%. Compared to say the Waikato River.
A better picture of the water short areas (which are typically high production areas) should docu
attention in the right regions from a water allocation and management perspective.
The needs to categorise the value/baseline water quality and improvement of highly value rivers is
critical – e.g an implementation program that has some reality in how it is rolled out and focussed on
retaining pristine environments, or restoring great environments to pristine.
The Freshwater Policy does not mention groundwater resources. This should be considered.
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If you are posting your submission, send it to Freshwater Consultation 2016, Ministry for the
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Submissions close at 5.00pm on Friday 22 April 2016.
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