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Overview of Submitters

Which sectors made submissions?

Organisations from a wide range of sectors interested in freshwater management made submissions, with involvement by local government, environmental groups, the agriculture sector and Māori organisations being particularly strong. Submissions from the energy and industry sectors, while smaller in number, included some which had been prepared jointly by several companies. There were also a significant number of submissions - more than a quarter of the 292 received - from individuals not representing any organisation. Figure 1 shows the number of submissions from each sectoral group.

Figure 1: Number of submissions lodged by sector

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While many submitters commented on the full set of issues and actions identified, others focused on particular concerns. [See Appendices Three and Four for details of the issues and actions on which sectors and regions made submissions.] Overall, issues relating to setting environmental bottom lines and management of diffuse discharges received most comments, with fewest comments made on the issue of the tension between investment certainty and planning flexibility. The action with the greatest number of comments was that relating to national environmental standards, and there was also a strong focus on national policy statements, nationally important values and support for local government. Fewest comments were received on actions regarding market mechanisms for diffuse discharges.

There were some apparent differences between sectors in the focus of comments:

  • The issues most commented on by local government were those related to setting environmental bottom lines, infrastructure and water allocation. There were fewer comments from this sector on Action 9 (requirements for regional plans) than on other actions.
  • Māori organisations had a very strong focus on the issue and action relating to Māori participation. There were no comments on the issue of infrastructure provision and few on Action 9.
  • Issues most commonly discussed by submitters from the agriculture sector were those relating to water allocation, strategic planning, environmental bottom lines and investment certainty. Fewer commented on issues and actions related to Māori participation and diffuse discharges than those on other matters.
  • Submitters from the industry and business sector commented less on Māori participation than on other issues and actions.
  • Management of diffuse discharges was a strong focus for submitters from environmental organisations, with emphasis also on issues and actions relating to strategic planning and national direction.
  • There was a particular focus in the research and academic sector on issues relating to setting environmental bottom lines and managing diffuse discharges.
  • Individual submitters commented most on the issue of managing diffuse discharges and on actions relating to national direction, national values and support for local government. The issue commented on least was Issue 5 (the tension between investment certainty and planning flexibility).

Which regions did submissions come from?

Submitters came from throughout New Zealand, with several submissions also received from overseas. However there was a marked variation in the numbers of submissions received from different regions, as shown in Figure 2 below.

Figure 2: Number of submissions lodged by region

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The large number of submissions from the Wellington region is strongly influenced by Wellington's role as headquarters for many national organisations. Approximately half of the submissions identified as being from the Wellington region came from national organisations based in the capital.

Apart from Wellington, there are two areas of New Zealand where interest was particularly strong. The greatest concentration of submitters came from the Canterbury and Otago regions on the dry eastern side of the South Island. There was also substantial input from submitters in the northern part of the North Island (Northland, Auckland, Waikato and the Bay of Plenty). Regions with the smallest numbers of submitters were Taranaki and the West Coast.

Differences in focus between regions were not as strong as the differences between sectors. However, some were noted. Māori participation was a strong focus in the Northland, Waikato and Bay of Plenty regions, but was one of the matters least commented on in Wellington and the South Island. As well as this:

  • Northland submitters made few comments on Action 8 (market mechanisms for diffuse discharges) or Issue 5 (the tension between investment certainty and planning flexibility)
  • submitters from Auckland commented most on the issue of managing diffuse discharges, and on actions relating to national direction and nationally important values
  • Waikato submitters made most comments on national policy statements and least on market mechanisms for diffuse discharges and setting requirements for plans
  • there was a focus by submitters from the Bay of Plenty on the issues of strategic planning and setting environmental bottom lines, with least interest in the issue of over-allocation
  • infrastructure was the issue receiving fewest comments from submitters in the Gisborne region
  • the issues most commented on by Hawkes Bay submitters were strategic planning and over-allocation and the action receiving most comments was Action 5 (central government support for local government). Action 7 (enhancing transfer of allocated water) received few comments
  • submitters in the Manawatu-Wanganui region focused on the issue of over-allocation and actions relating to national direction, support for local government and collaboration
  • submitters based in the Wellington region commented most on the issue of national values and on actions relating to national direction, central government participation and support for local government and public awareness
  • in the Nelson/Tasman area, there was a focus on the issue of over-allocation, but few comments on the allocation of water to priority uses. Issues relating to national values and management of diffuse discharges also received few comments
  • Canterbury submitters commented most on the issues of infrastructure, management of diffuse discharges and setting environmental bottom lines, and on actions relating to national direction, national values and central government support for local government
  • the strongest focus of submitters from Otago was on the issues of managing diffuse discharges, over-allocation and setting environmental bottom lines, and on actions relating to national direction and central government participation in regional planning.