All submissions were summarised by general topic as well as by feedback points (individual aspects of the proposed NES). Each of these points was allocated to one of the following four positions – support, oppose, support in part (conditional support) or N/A (unknown / position not stated) – and the comments were summarised (see Appendix C). Some submitters did not state their position and preferred to comment on aspects of the wording or technical methods proposed in the NES. Where it was possible to identify conditional support this was attributed, otherwise a point was allocated to ‘N/A’. In all, 2370 feedback points were logged; a breakdown of the positions taken is shown in figures 3 and 4.
The key topics identified during the analysis of submissions are presented in table 1 and discussed briefly in the following text. Key topics have been derived from the questions posed in the discussion document (sections 5 to 8) but also include general comments made about the proposed NES itself and about the process used. These key topics have been broken down into sub-topics and form a framework within which submission feedback points were analysed. (Note that not all submitters made a point in respect of each of the topics and sub-topic listed opposite.)
Table 1: Topics summary
| Topic | Sub-topic |
|---|---|
| Scope of proposed NES generally | Relationship with national policy statements and RMA |
| Effect on regional and local plans | |
| Effect on applications | |
| Application to all rivers / water bodies | |
| Implementation / resource costs | |
| Climate change | |
| Process to adoption/involvement | Consultation |
| Q1 – Problem statements and issues | |
| Q2 – Assessment and evaluation of alternatives | |
| Q3 – The need for interim limits | |
| Q4 – The interim limits | Proposed numbers (flows and levels) |
| Division of rivers and streams and groundwater systems? | |
| Scope – what is included? | |
| Other | |
| Q5 – Time bound/limit for interim levels | Time limit |
| Implementation costs | |
| How to implement? | |
| Other | |
| Q6 – Inclusion of existing consents within allocation limits | Apply to existing consents |
| Renewals (and clawback) | |
| Clawback through regional plan | |
| Other | |
| Q7, 8 and 9 – Technical methods | Need |
| Approach proposed | |
| New methods / innovation | |
| Q10 – Proposed NES approach to breaches | Applications |
| Current breaches | |
| Q11 – Application of the proposed NES to existing and replacement consents | |
| Q12 and 13 – Benefits and costs of preferred option? | Range |
| Accuracy | |
| Assumptions |