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2 Approach to the summary of submissions

2.1 General approach

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.

2.2 Topic analysis

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?
Q5 – Time bound/limit for interim levels Time limit
Implementation costs
How to implement?
Q6 – Inclusion of existing consents within allocation limits Apply to existing consents
Renewals (and clawback)
Clawback through regional plan
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