Submission on Proposed Amendments to the National Policy Statement for Freshwater Management 2011

Water New Zealand is one of the foundation members of what became the Land and Water Forum (LAWF) and have been a full and active participant in the Small Group of that body since its inception. We concur with the bulk of the introductory comments in the discussion document, but would note and reiterate our previous concern that giving councils until 2030 to comply with the requirements of the NPS-FM would seem an inordinately long time.

The comments in Section 2 of the discussion document explaining the rationale for amending the NPS-FM would seem to support comments that have been made by numerous other parties for some time, namely the current institutional arrangements for water management in this country are less than optimal. As the discussion document notes, decisions are being made with insufficient information, community and iwi values are not being adequately recognised, there is unnecessary duplication of costly scientific investigations, there is an absence of national consistency in defining acceptable states of water quality, tangata whenua values for freshwater water are not adequately defined, and there is a need to monitor and address progress in achieving the desired objectives for freshwater management.

Elsewhere in Section 2 reference is made to the variability of, “resource pressures, capability, capacity, and data availability of regional councils”, and the differing approaches currently being taken in reference to accounting for contaminant sources. The document also reports that the 2012 survey of regional councils showed that, “All councils cited difficulties with ‘defining life-supporting capacity’ and seven (out of 16) councils cited uncertainty regarding the difference between numeric freshwater objectives and limits. Half of all councils cited issues with capability and capacity for resourcing the technical investigations and science required to inform freshwater objective and limit setting.”

These comments are viewed with considerable concern. Both Government and the general public have often stated their belief in the critical importance of freshwater and its management to society’s health and well-being, the environment it exists in, and the growth and prosperity of the nation at large.

If such comments were expressed in an official document such as this in reference to roading or the air transport system, they would very likely trigger a high level review of the overall management system, with serious questions asked over the capacity and capability of the existing regime to deliver policy objectives.