5.10   Part CC. Accounting for freshwater takes and contaminants

Objective CC1

To improve information on freshwater takes and sources of freshwater contaminants, in order to:

  1. ensure the necessary information is available for freshwater objective and limit setting and freshwater management under this national policy statement; and
  2. ensure information on resource availability is available for current and potential resource users.

Policy intent

Accurate information on the quantity of water being taken from freshwater bodies and the type and amount of contaminants going into freshwater bodies is essential for a number of reasons. Accounting for existing uses of water and existing sources of contaminants is needed to:

  • inform decisions on freshwater objectives and limits by providing an understanding of the existing use of water, and sources and amount of contaminants, when testing the economic and social impacts of various scenarios for freshwater objectives and limits
  • inform decisions on how to manage within limits (eg, to determine the most equitable and cost-effective way to reduce current discharges)
  • provide feedback to communities on their progress in meeting freshwater objectives, and act as a trigger for changes in management (eg, when existing initiatives are not having the required effect and targets are not being met)
  • provide consistent regional accounting information for investors on catchments where there is headroom for expansion.

A freshwater accounting requirement is already implied through the duties imposed on local authorities by sections 35(1) and 35(2) of the RMA. Section 35(1) requires local authorities to gather such information as is necessary to effectively carry out their functions under the Act. For regional councils those functions include the control of the:

  • taking, use, damming and diversion of water, and of the quantity, level and flow of water in any water body (section 30(1)(e))
  • discharges of contaminants into or onto land or water (section 30(1)(f)).

Section 35(2)(d) requires local authorities to monitor the exercise of resource consents.

The aim of Objective CC1 is to provide additional specificity for councils on how to undertake the functions required of them – in this case, effective accounting to manage freshwater resources.

The intention is that the accounting system includes all freshwater takes and all sources of relevant contaminants.

Accounting for freshwater takes

To meet the policy intent will require accounting for all freshwater takes. It will involve:

  • identifying who is taking water (consented or otherwise)
  • collecting information on, or estimating, how much is used (ie, the total actual take), the proportion taken by category, and eventually, when limits have been set, the proportion of the limit that is being used.

The data can be measured, modelled or estimated, depending on the significance of the resource issue. If modelling or estimates are used, some data verification may be necessary, and the information should be consolidated and available for the community at the time of setting or reviewing freshwater objectives and limits. The level of detail and precision that is appropriate in a freshwater accounting system will depend on the extent to which the water in the FMU (and the ability for the FMU to meet freshwater objectives) is affected by water use.

The information collected under the Resource Management (Measurement and Reporting of Water Takes) Regulations 2010 will contribute a significant amount of the information required for the water quantity accounting requirements. However, regional councils will also need to account for:

  • consented water takes that are not covered by the regulations (non-consumptive takes and takes of less than 5L/s)
  • water takes that do not need a resource consent (ie, permitted takes and takes authorised under section 14(3)(b) of the RMA) and any unauthorised takes.

Simple models can be used to estimate permitted, stock water and domestic takes; for example, multiplying stock numbers by average daily intake, with intake coefficients validated using sample surveys and other data (eg, from metered takes).

Accounting for freshwater contaminants

The phrase ‘relevant contaminants’ means the contaminants that impact, or have the potential to impact, water quality. The policy does not require regional councils to monitor every possible contaminant, only those that they and the community identify as being relevant to achieving freshwater objectives. Accounting for all sources ofrelevant contaminants requires broadly identifying the sources of the contaminant(s) that need to be managed to achieve particular objectives.

Sources of relevant contaminants include both point source and non-point source or diffuse discharges, and include background or naturally occurring contaminant sources. Sources are most usefully grouped into background, point and diffuse sources, with diffuse sources potentially broken down further by land-use type. This grouping can also assist with assessment of the economic impact of potential objectives to specific sectors or land-use types.

A preliminary assessment of likely values and objectives will need to be carried out, along with an initial low cost accounting process for the contaminant(s) most likely to be relevant. Once the possible range of objectives is narrowed, more accurate accounting may be needed (eg, if significant reductions in discharges of relevant contaminants are needed to achieve some of the objectives being considered).

Contaminant sources may in some cases be able to be individually identified and measured (eg, large point sources), and in other cases only broad identification will be possible (eg, estimated loads generated by each land-use type). Councils will need to use modelling to identify and estimate diffuse discharges from farmland, urban run-off, native bush, plantation forests, wildlife and septic tanks.

Policy CC1

By every regional council:

  1. establishing and operating a freshwater quality accounting system and a freshwater quantity accounting system for those freshwater management units where they are setting or reviewing freshwater objectives and limits in accordance with Policy A1, Policy B1, and Policies CA1-CA4; and
  2. maintaining a freshwater quality accounting system and a freshwater quantity accounting system at levels of detail that are commensurate with the significance of the freshwater quality and freshwater quantity issues, respectively, in each freshwater management unit.

This policy requires that regional councils establish and operate freshwater quality and quantity accounting systems, and that they collect and record freshwater accounting information for all FMUs. This is to be done at a level of detail that reflects the scale of the water quality/quantity issues in the FMU. Therefore, the information gathered may include direct measurements, modelling results or estimates.

Freshwater quality accounting systems

“A system that, for each freshwater management unit, records, aggregates and keeps regularly updated, information on the measured, modelled or estimated:

  • loads and/or concentrations of relevant contaminants;
  • sources of relevant contaminants;
  • amount of each contaminant attributable to each source; and
  • where limits have been set, proportion of the limit that is being used”
  • (NPS-FM definition).

A freshwater quality accounting system will keep account of the type and amount of relevant contaminants affecting an FMU. The system will also identify where those contaminants are coming from by source, and the amount generated by each source. This will include both point and diffuse discharges. When limits are set, the accounting system will also be able to identify the proportion of any limit that is being used in an FMU.

Freshwater quantity accounting systems

“A system that, for each freshwater management unit, records, aggregates and keeps regularly updated, information on the measured, modelled or estimated:

total freshwater take;

proportion of freshwater taken by each major category of use; and

where limits have been set, proportion of the limit that has been taken”
(NPS-FM definition).

A freshwater quantity accounting system will keep account of how much water is allocated, as well as how much is being taken from freshwater bodies, and broadly what that water is being used for (eg, municipal, irrigation, hydroelectric power). A freshwater quality accounting system will also keep account of how much of the limit is being used in each FMU.

Extent and timing

Regional councils are required to establish freshwater quality and quantity accounting systems in FMUs where they are setting or reviewing freshwater objectives and limits. This means freshwater accounting systems do not have to be established for the whole region, and data does not have to be gathered for all FMUs at once. Regional councils can take a staged approach to setting up accounting systems and data gathering. Eventually, just as a whole region is required to be covered by FMUs, the region will also be covered by an accounting system at a scale or scales commensurate with the issues affecting each FMU.

A two-year period has been allowed before the accounting requirements take effect (from 1 August 2014 – the date that the NPS-FM came into effect). The two-year delay provides time to establish an accounting system and collect the data for the first FMU in which the regional council is setting or reviewing freshwater objectives and/or limits after the NPS-FM takes effect.

Scale and significance

The level of detail of the accounting systems will depend on the scale and significance of issues in each FMU. The policy provides the flexibility for regional councils to determine this at a local level.

It is appropriate to have a targeted focus on the relevant contaminants (that is, those that are most critical to manage to achieve the objective specified for the FMU). It is also appropriate to tailor the level of detail at which the sources of relevant contaminants are identified (eg, by broad category or more specifically) or water takes are measured, and the frequency of the accounting cycle, commensurate with the scale of resource use and the drivers and pressures affecting that FMU.

For example, in FMUs with little pressure on freshwater resources it may be sufficient to account for sources of contaminants by broad category or sector; however in FMUs where significant reductions in a contaminant are needed to achieve an objective, a more detailed breakdown of sources by individual source (users) may be needed to assess, and possibly refine, the management approaches being taken. Pressures on water quality are likely to affect the approach towards accounting for water takes. Where pressure on water use is minimal, estimating water takes may be appropriate, while measurement may be required in under-pressure FMUs to ensure a greater degree of accuracy.

Policy CC2

By every regional council taking reasonable steps to ensure that information gathered in accordance with Policy CC1 is available to the public, regularly and in a suitable form, for the freshwater management units where they are setting or reviewing, and where they have set or reviewed, freshwater objectives and limits in accordance with Policy A1, Policy B1, and Policies CA1-CA4.

Objective CC1 and Policies CC1 and CC2 will take effect 24 months from the date of entry into effect of the National Policy Statement for Freshwater Management 2014.

This policy requires that the information collected under Policy CC1 is available to inform the process of setting (or reviewing) freshwater objectives and limits. The information collected must be available in a suitable form for the council and the community when making decisions as part of the iterative process of setting and managing within freshwater objectives and limits. This means the data can be aggregated or collated and should clearly reflect any change over time.

For water quantity, the system used to gather and report data as part of the Resource Management (Water Measurement and Reporting of Water Takes) Regulations 2010 could be used to incorporate those takes not covered by the regulations (ie, non-consumptive takes and takes of less than 5L/sec). This would allow a full account to be made of water taken and used in FMUs within a region, and provided on an annual basis.

For water quality, the system used to manage data will depend in part on the level of detail required from the accounting system; this in turn will reflect the complexity and seriousness of issues affecting a particular FMU.

The regional accounting system needs to be flexible enough to allow for various scales of complexity and still enable comparisons between FMUs to be made. The reporting period for water quality accounts may vary for each FMU depending on:

  • the pressure on the resource
  • the complexity of the accounting undertaken
  • information needs (for setting and reviewing freshwater objectives and limits, providing information to the community on available resource use, and tracking progress toward targets).