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2. Overview of submissions

2.1 Breakdown of submissions, by type of submitter

A total of 135 submissions were received. The majority of these were received from three main groups:

  • 40 (30 per cent) from local government (territorial authorities, regional councils and unitary authorities)

  • 38 (28 per cent) from community groups and householders

  • 29 (22 per cent) from representatives of industries involved in or affected by on-site wastewater systems.

These three main groups and the remainder of submissions have been broken down into the categories outlined in table 1.

Table 1: Breakdown of submissions, by category of submitter

Category Number of submissions
Individual 28 (21%)
Territorial local authority
Industry − contractor
Regional council
Industry − consultant
Other industry
Community group
24 (18%)
13 (10%)
12 (9%)
10 (7%)
10 (7%)
10 (7%)
7 (5%)
Public health or DHB 7 (5%)
Government 5 (4%)
Iwi 4 (3%)
Unitary authority 4 (3%)
Small business (café, lodge, etc) 1 (1%)
Total 135

Notes: NGO = non-government organisation; DHB = district health board.

The single biggest group of submitters were individuals (21 per cent), followed by territorial local authorities (18 per cent), and industry − contractors (10 per cent).

Figure 2 presents the different categories of submitters by their proportion.

Figure 2: Proportion of submissions, by category


The pie chart shows the proportion of submissions by category of submitters in per cent. It conveys the information in table 1 in graphical form.


2.2 Breakdown of submissions, by position

The majority of submitters supported, in principle, the objective of addressing the problem of failing on-site wastewater systems. However, submitters differed in their views on the most appropriate way to achieve this policy objective, and also where the actual problems arise. Submissions ranged from full support for the standard as proposed, to opposition and a preference for a different method of addressing failing systems, through to the contention that there is no problem at all so no action is warranted.

Submissions have been grouped into five categories according to their position on the proposal:1

  • support – clear support was indicated for the proposed NES

  • conditional support – clear support was indicated for the proposed NES, but more than minor changes to the proposal were requested

  • neutral / not stated – no clear statement of support or opposition to the proposed NES was given, and this could not be determined from the content of the submission

  • conditional oppose – stating opposition to the proposed NES, but indicating that such opposition could be overcome by making specific changes to the proposal or by an alternative method of achieving the policy objective

  • oppose – clear opposition to the proposed standard was indicated.

Figure 3: Breakdown of submissions by position

The graph shows the number of submitters according to their position on the proposal:
14 submitters opposed, 13 conditionally opposed, 16 were neutral to, 80 conditionally supported and 12 supported the proposal.


The breakdown of submissions by position for the proposed NES shows that 92 submitters or 68 per cent supported the changes, either as proposed (9 per cent) or subject to specific changes being made (59 per cent). Twenty per cent of submitters opposed the NES, either completely (10 per cent), or opposed the proposals unless significant changes were made (10 per cent). A further 12 per cent did not indicate a position.

The breakdown of submissions by both position and submitter group is depicted in figure 4. This shows that the majority of local government submissions supported the proposal, especially those from regional councils and unitary authorities. Territorial local authorities expressed a wider range of views. The majority of community groups supported the proposals. Individual submitters, along with other groups (including industry consultants and iwi), expressed a range of views about the standards. For example, of the four iwi submitters, half supported the proposed NES while the other half opposed it.

Figure 4: Breakdown of submissions, by submitter type and position

The graph details the position (in number of submitters) according to the submitter type. Its information is canvassed in the table below:


Position Oppose Conditional oppose Neutral Conditional support Support total
Public health or DBH 0 0 0 6 1 7
NGO 1 1 0 5 0 7
Government 0 0 3 2 0 5
Unitary Authority 0 1 0 3 0 4
Regional Council 0 0 0 12 0 12
Territorial Local Authority 2 7 2 12 1 24
Small business 0 0 0 0 1 1
Other industry 1 1 0 6 2 10
Industry - contractor 0 0 3 7 3 13
Industry - consultant 0 2 3 4 1 10
Iwi 2 0 0 2 0 4
Community group 1 0 0 7 2 10
Individual 7 1 5 14 1 28


1  This assessment is fairly subjective as most submitters did not specifically indicate a position.