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Views on the Overall Package

Agriculture

In general there was agreement that the main issues had been identified, although it was suggested that the importance of science and measurement in good water management should be highlighted more. Submitters also suggested that research needs and the impacts of urban land and water use be identified as additional issues.

The following criticisms of the issues were expressed:

  • The document does not contain enough detail to clearly identify problems, and issues represent the status quo rather than a way forward.
  • Uses of water for productive purposes and the rights of abstractors are ignored and users have not been specifically consulted.

Many submitters from the agricultural sector were very clear that decisions should be made locally. Local decision-making was considered to be appropriate as the pressures and problems are variable across the country, and catchment-based solutions were generally considered to be optimal. The ideal role of central government was characterised as being limited to supporting local government, and providing information, guidance, and funding. Submitters were supportive of additional central government departments becoming involved in water management, particularly Ministry of Economic Development and Ministry of Agriculture and Forestry.

Many submitters considered the development of water harvesting and storage would greatly progress water allocation issues in their region. Submitters noted that there is scope for both central and regional government to be involved in the development of irrigation infrastructure. Submitters identified links to strategic planning and funding as a way forward.

Submitters were supportive of an approach that aims to strengthen current arrangements rather than a radical review. Submitters requested a water management framework that:

  • is flexible
  • is fair
  • supports efficient water use
  • sets reasonable environmental limits
  • is able to facilitate sound choices between competing needs and values
  • limits the ability of speculators to tie up the resource for windfall gains
  • identifies the risk (in terms of reliability) for new applicants.

The important drivers for the agricultural sector are: reliability, security of supply, certainty of volumes, certainty of investment, adequate quality, straightforward consent requirements, and minimal compliance costs. Submitters were very concerned that the rights of existing users be protected, noting that farmers have considerable financial investment in their land and irrigation systems.

Submitters were supportive of approaches involving education, best practice and pilot programmes. Whole of government submissions on regional plans were considered to be an approach that might be useful, whereas approval of plans was not supported. Submitters indicated central government could usefully develop new tools for water users. Expression of the national interest (possibly through a national policy statement or national environmental standard) was considered to be appropriate if it was essentially guidance that was incorporated into regional planning.

Consultation and engagement with the agricultural sector was considered to be essential so that any new tools are functional, incorporated and used.

Some agricultural submitters were concerned that the programme to address water quality issues is unclear. Submitters recommended an increased emphasis be placed on urban water issues, and also identified information and science gaps.

Energy

In general there was support for the issues identified. A key focus for submitters from the energy sector was protection of the rights or entitlements of existing users in order to provide certainty for investment.

Submitters from the energy sector were particularly interested in achieving equitable and efficient water allocations. While supportive of some recommendations, submitters indicated they fall short of describing a water allocation framework that strikes the best balance between conflicting demands. The energy sector noted that their stance is not neutral, but that as electricity generation is essential to economic growth and improving standards of living there is a large overlap between their interest in security of investment and the national interest.

Matters of particular importance to the energy sector include:

  • ensuring decision-making power is allocated to those with the most relevant knowledge or skills
  • ensuring decision-makers have incentives to exercise their power appropriately and decisions are not subject to influence by parties with vested interests
  • recognising the importance of minimising costs associated with decision processes
  • providing confidence to existing and prospective rights holders that their investments will not be eroded
  • clarity and duration of the entitlement, security and exclusivity of tenure, transferability and flexibility in how the right can be exercised.

The energy sector were also concerned that the allocation regime be environmentally sustainable; able to meet broader community needs and recognise cultural values associated with water; flexible enough to adapt to such things as evolving knowledge, different hydrological patterns and changing uses for water; and not susceptible to capture by interest groups. Submitters noted the allocation regime must address the following issues: how to specify the amount of allocable water; the nature of the use entitlement; who should receive initial allocations; and how water should be reallocated over time. Submitters were supportive of making decisions on the amount of water available for allocation through an administrative process, and reallocation through administrative or market-based approaches. The energy sector considers administrative approaches are most efficient where there are few competing demands, and market approaches are best where water is scarce relative to demand.

Development of standards, indicators and benchmarks were also identified as priorities, to allow monitoring of environmental trends and to track progress towards stated objectives and policy goals.

Environmental groups

Submitters from the environmental sector had mixed views about the statement of issues. While many submitters agreed that they are the main water management issues, some felt they did not go far enough or did not have enough detail on specific problems. There was some concern that the focus might be more on economic development than sustainable management of freshwater ecosystems. A sense of urgency was expressed, with several submitters calling for clear timeframes for action.

Some submitters disagreed that the issues reflected priorities in freshwater management. These submitters and those who sought more focus on specifics identified a range of additional or alternative issues which should be considered. Those commonly mentioned included:

  • protection of biodiversity and ecosystem health, including greater attention to wetlands and small stream systems
  • the need for integrated land and water management
  • a broader focus on the decline in water quality and the effects of land use on this
  • protection of water bodies with significant natural values
  • the impacts of increasing water abstraction
  • riparian management
  • control of weeds and pest species
  • public access to waterways.

Some concerns were also raised about the effect of changes proposed in the Resource Management Act review on the ability to address some of the issues.

While submitters were generally supportive of decision-making being retained at the local level, there was a call for greater central government direction. Submitters were critical of a lack of clear goals, objectives, targets and timetables in the discussion document. Submitters were concerned that water bodies must be enhanced rather than degraded, and noted an emphasis in the discussion document on the availability and allocation of water, rather than water quality. Submitters noted that the discussion document places too little emphasis on fixing serious environmental problems relating to freshwater (for example, pest management, biodiversity, international obligations, fish passage, wetlands). Submitters suggested the programme be redirected to focus on establishing a series of measurable goals for improving water quality, halting the decline in biodiversity, protecting natural character and enhancing public access.

Submitters were concerned that the recommendations in the Parliamentary Commissioner for the Environment's recent report (Growing for good) had not been addressed. The management of land use was identified as a priority issue, and the response in the discussion document was considered to be inadequate. National policy statements and national environmental standards were considered to be the most desirable actions. Best practice, guidelines, incentives and voluntary agreements were considered to be a useful complement to more directive actions. Responses to market mechanisms were mixed and submitters raised concerns about the privatisation of water. Submitters supported actions with strong links to education; and were very supportive of enhancing consultation and community engagement.

Submitters were also concerned about impacts of the current Resource Management Act (RMA) review on water management. Submitters perceived the changes to the RMA to promote infrastructure and contain excessive and unchecked powers, reducing submitters' ability to protect and enhance waterways.

Local government

While many submitters in the local government sector supported the intent of the programme and the issues identified, there were also some reservations expressed about the statement of issues. The main reservations were that:

  • the issues are not sufficiently clearly defined or lack quantitative details and real examples to support them
  • the scale of the issues varies between localities and regions - not all are significant in all regions. This underlines the need for local management and decision-making
  • many of the issues are already being addressed by tools currently available, particularly in relation to water allocation.

Other matters raised included:

  • concerns about the focus of work on water bodies of national importance and how the information gathered would be used in relation to sections 5 and 6 of the RMA
  • a concern that the document does not address how the economic, social and cultural aspects of sustainable development can be interpreted in policies and plans developed under the sustainable management focus of the RMA.

Key additional issues identified included the need for an integrated management approach and greater emphasis on demand management.

Local government submitters were supportive of local government retaining responsibility for water management, as issues vary across the country and local authorities are in the best position to design local solutions. Submitters were generally concerned about proposals for increased central government involvement in water management, and a potential decrease in local government autonomy.

Local government submitters were opposed to central government potentially duplicating or overriding provisions of regional plans that have been developed in conjunction with local communities. Submitters were particularly concerned about some of the more prescriptive actions proposed in the discussion document, and the potential costs of implementation. However, councils were generally supportive of actions that better express the national interest and which complement or support regional councils. Many regions are preparing second generation regional plans for water. Submitters noted that central government guidance and other non-statutory approaches would be useful.

National policy statements and environmental standards were generally supported where they are setting high level direction. Quantitative blanket values are not supported. Other actions that were generally supported are:

  • increased support for local government
  • central government participation in regional planning
  • special mechanisms for regional councils
  • enhanced transfer of consents
  • raised awareness
  • pilot programmes.

These actions provide for increasing the capacity of the regions to deal with regional issues and a cooperative approach between stakeholders.

Submitters identified significant barriers with developing market mechanisms for diffuse discharges and allocation of water to priority uses.

Submitters were concerned at the lack of attention on water quality issues. The lack of focus on urban issues was also identified as an area of concern. Managing the impacts of land use on water quality was identified as an area where central government support would be particularly useful. Submitters identified a potential way forward:

  • investigate and develop (in conjunction with local government) a set of tools to assist in the management of non-point source discharges
  • collate and develop examples of best practice
  • increase participation through whole of government submissions on plans
  • increase awareness of issues (particularly effects of diffuse discharges) through education programmes
  • facilitate focused research.

Submitters noted that any increased support to local government should be a serious and ongoing commitment.

Māori

Māori submitters supported the need to review current freshwater management and some expressed agreement with the issues identified. However significant concerns were raised about the lack of discussion of the Treaty of Waitangi and obligations arising from this. Submitters felt there was inadequate recognition of the role of iwi and hapū as Treaty partners and as kaitiaki of freshwater resources in their rohe. The need for ongoing dialogue with iwi and hapū to incorporate their perspectives was stressed.

Some submitters also identified a need for a holistic, whole-catchment approach to freshwater management.

Many Māori submitters were generally supportive of the vision proposed in the discussion document, that 'freshwater is managed wisely to provide for the present and future social, cultural, environmental and economic wellbeing of New Zealand'. Submitters were very clear that freshwater is of fundamental importance.

Submitters were concerned that the role of the Treaty in the Crown's management of freshwater resources has been minimised, and considered that Māori interests have been relegated from Treaty partner to merely being another stakeholder. Submitters highlighted the objective 'Manage freshwater in the context of Māori cultural values and the Treaty relationship between Crown and Māori', and noted that the Treaty is not referred to in the proposed actions. Submitters were concerned that failure to translate this objective into action, and to simply focus on improving consultation with Māori, undermines Māori as a Treaty partner. Many submitters were concerned that the proposals do not recognise the proper role of Māori. Submitters recommended that a substantive dialogue be undertaken between Crown and tangata whenua on rights and responsibilities of Treaty partners in respect of water.

Many submitters raised issues of ownership and customary rights to water. For example, submitters were particularly concerned about proposals to establish market mechanisms for the allocation of freshwater. Submitters noted that customary rights in water must be addressed prior to establishing market based systems for freshwater.

Submitters were also concerned that proposals in the discussion document redefine the involvement of Māori rather than enhancing participation, and that no consideration had been given to how the existing enabling provisions of the RMA could be better used to improve Māori participation. Submitters noted that there is scope to address Māori customary interests within the mechanisms proposed, but the options need to be explored (for example, preserving a percentage of water rights for Māori).

Submitters were also concerned that the development of any national polices, standards or values must incorporate a Māori world view, and properly consider Māori interests.

While submitters generally supported the provision of more support and resources for local government, they were also concerned that central government should better resource iwi, hapū and marae to participate in water management.

Industry

Submitters were concerned about the lack of coverage of a variety of specific matters, although there was no common thread to these. Concerns included that:

  • there is no information on cost implications and how implementation would affect industry
  • conflicts between competing interests are not given sufficient consideration
  • there are few incentives for improving water management
  • there is no recognition of the importance of the ecological, social, cultural and economic values of freshwater fisheries
  • the linkage between water allocation and water quality is not made
  • a distinction between domestic and industrial use of water is not helpful as in municipal areas these are generally supplied from the same source.

Submitters from the industrial sector were generally supportive of central government providing high level direction. Submitters preferred that decision-making occur at the local level within a central government framework. The industrial sector submitters consider that the final package of actions should retain a range of tools for managing water quality and allocation. Submitters suggested that priority be given to actions which allow regional councils to act strategically and in a way which creates an environment of certainty, and enables sound investment decisions.

While submitters considered a number of the proposed actions to have merit, they were concerned about over regulating water management. Voluntary and collaborative approaches were identified as useful, and pilot projects were considered to be a sensible way forward. Submitters were generally supportive of exploring market-based mechanisms for water management.

Some submitters from the industry sector were concerned about local government performance. Completion of regional plans was suggested as a priority. Submitters also suggested provision of more resources to Environment Court, so that hearings could be completed as soon as possible. Protection of essential infrastructure was also considered to be important.

Recreation

Recreation submitters were particularly concerned that there are no changes to the current management framework that would weaken protection of rivers. In this regard they raised concerns about the effect of the RMA review proposals and the need to define the national interest, and for this to give priority to the interests of the public.

Submitters in this sector were less supportive of the issues identified than those from other sectors, and identified RMA implementation by regional councils as an issue needing to be addressed.

Submitters from the recreation sector were particularly concerned about instream values. Submitters considered the most important actions were to specify nationally important instream values and then to protect those values. Submitters were also supportive of mechanisms to ensure that water is only abstracted for efficient and necessary uses.

Submitters were very clear that existing Water Conservation Orders must remain in place. Submitters preferred that water bodies of national importance be limited to instream values, and not include abstractive values. Submitters identified the impacts of agriculture and hydro energy generation as key concerns, and considered significant changes were required to make agriculture sustainable.

Actions that provide support to local government, identify nationally important values, raise awareness and use of pilot projects were considered to be useful. Efforts to manage diffuse discharges were also considered to be a priority.

Research

There was a general level of support from this sector for the issues identified in the document.

Submitters from research organisations were very concerned about the impacts of diffuse discharges on water quality. Submitters noted that there is no clear direction on how to address diffuse discharges, and there is little public understanding of issues. Submitters were supportive of implementing the recommendations of the recent report from the Parliamentary Commissioner for the Environment (Growing for good).

Submitters were concerned that there has been insufficient recognition of the critical role of information and monitoring (to assemble data underpinning information), and research on which to base management. Submitters considered the need for good unbiased information and monitoring should be highlighted. Submitters were concerned that there is a lack of information on national trends in the state of the freshwater, and that many freshwater environments are threatened by potentially unsustainable activities. Submitters were particularly concerned about the rate of change in use of water, and the intensification of land use in many areas.

Submitters were very clear that increased central government funding for research was required. Submitters were very supportive of collaboration between central and local government and scientists. Other priority actions were considered to be:

  • national policy statements and provision of guidance to regional councils on national priorities
  • developing good practice in water planning
  • implementing recommendations from the recent Growing for good report
  • exploring market mechanisms
  • community education and awareness raising
  • involving science advisory panels in the next phase of the programme.

Individuals and community groups

There was broad agreement from submitters that the key issues had been identified, but the following criticisms were also made:

  • The issues are poorly defined, show poor understanding of what is happening in the regions or lack practical steps.
  • The document gives undue weight to uses requiring consent, in contrast to the functioning of catchments as a whole.
  • Sustainability is not adequately addressed.
  • There is no recognition of the findings of the Parliamentary Commissioner for the Environment's report Growing for good.

Additional issues suggested by several submitters included the need for:

  • a stronger and broader focus on water quality, to include point sources and whole catchment management and the need for corrective action to reverse current trends
  • the programme to be compatible with the New Zealand Biodiversity Strategy, and proactive in addressing loss of biodiversity.

Many individuals and community groups were frustrated at the lack of practical immediate action. They were concerned about over-allocation of water and declining water quality. Sustaining and enhancing water bodies was identified as critical. Submitters considered these problems to be urgent and were concerned that action be taken as soon as possible.

Many submitters were supportive of local community involvement in water management (including urban communities) and local decision-making. Central government could usefully set guidelines and provide resources. Submitters suggested that the central government role be limited to basic principles, science, education and raising awareness; and that central government should only be involved in specific water management problems where they are of national significance (pilot projects were supported). Some submitters were supportive of central government developing standards, and providing leadership and direction.

Some submitters were very concerned about the potential for privatisation of water, and cautioned against the use of market mechanisms. Other submitters were supportive of exploring the enhanced transfer of water permits. Security of existing users and certainty of supply were considered to be important by some submitters. Submitters also identified the need for monitoring and good information.

Other organisations

Submitters from a range of other organisations indicated general agreement with the intent of the programme and with the issues identified. Additional emphasis on urban water issues and water use efficiency was suggested. Submitters from the forestry sector sought recognition of the benefits of forestry for water quality, and a greater focus on a whole-catchment approach with integrated land and water management. They were also concerned to ensure no restrictions are imposed on interception of rainfall by trees. Submitters from central government departments focused on transport and urban water issues (including stormwater), and recreation.

Many of the submitters from other organisations were generally supportive of the intent of the programme. Many of the submitters were supportive of the underpinning principle, that local government should retain responsibility for water management and decision-making, with greater support and direction from central government. Submitters noted a very strong focus on regional councils, and that actions involving other groups (for example, industry and community groups) should be explored.

Submitters were generally supportive of collaborative approaches, comprehensive awareness raising campaigns, and incentives for local communities to find local solutions. Submitters would like clarity around the role of central government in water management, more co-ordination between regional and district councils, and effective consultation with Māori.

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