12 August
2016
Fire
Services Review
Department
of Internal Affairs
PO
Box 805
Wellington
6140
By
email: fireservicestransition@dia.govt.nz
Submission: Discussion
Document - Proposed Regulations to Support FENZ Bill
- 1.Water New Zealand (“Water New
Zealand”) appreciates the opportunity to provide a submission on the above
discussion document.
- 2.Water New Zealand is a national
not-for-profit organisation which promotes the sustainable management and
development of New Zealand’s three waters (freshwater, wastewater and storm
water).Water New Zealand is the
country's largest water industry body, providing leadership and support in the
water sector through advocacy, collaboration and professional development. Its
1,500 members are drawn from all areas of the water management industry
including regional councils and territorial authorities, consultants,
suppliers, government agencies, academia and scientists.
- 3.The District and City Councils
who in part make up our membership are providers of water supply in reticulated
urban environments, and have an existing relationship with the New Zealand Fire
Service with regard to their use of the water system for fire-fighting.
Proposed Regulations for Levy
Exemptions
- 4.The Association supports
retaining the levy exemption for “any
water reticulation pipe” under Schedule 3 of the Fire Services Act 1975.
(Item 10 page 17 of the discussion document).
Local Committees and Local Planning
- 5.The FENZ Bill provides little
detail about who will be represented on a local committee. Given that
territorial local authorities are predominantly responsible for the provision
of reticulated water to fight fires in urban environments it is surprising that
they are not specified in the legislation as being a core member of any local
committee.
- 6.We suggest that the nomination
and appointment process for committees is a matter that should be regulated;
including a requirement that a representative of the relevant local territorial
local authority be a member of every committee.
- 7.Who and how people are
appointed to local committees should not be left to be decided by operational
policy.
- 8.It is unclear whether the FENZ
legislation and the associated regulations/code of practice will seek to
establish a degree of consistency in approach to the operations of FENZ in
relation to the reticulated networks which Councils operate. While we can see
there will be some need to reflect the needs of local stakeholders, wherever
possible we would like to think that there is a consistency in approach –
especially in terms of technical requirements.
- 9.The advice we are receiving is
that the existing Code of Practice is problematic for many councils to comply
with, particularly large scale subdivision developments. A review is needed.
Functions of the Local
Committees
- 10.In our view the functions of
local committees needs to be consistent across the country and as such should
be provided for in regulation.
- 11.In our submission on the FENZ
Bill we expressed concern that in post emergency situations there did not
appear to be any process for FENZ and territorial local authorities/civil
defence and emergency management services to decide the priority for water use –
ie. Fire-fighting or provision of essential drinking water.
- 12.We suggest that one of the
functions of a local committee should be to provide advice on this matter in
the development of FENZ’s national strategy, and in the development and
finalisation of local fire plans.
Development of Fire
Plans
- 13.The Association supports Option
2 in relation to the development of what a fire plan must cover. That is, the
main matters a fire plan must cover should be set in regulation – but should
allow a plan to take a broader focus as the local circumstances demand.
- 14.We would like the regulations
to require FENZ to undertake “integrated emergency management” with the
relevant territorial local authority or civil defence and emergency response
agency in relation to the development of fire plans.
Consultation on Fire
Plans
- 15.The Association believes that a
regulated approach to the development of fire plans is appropriate, but that
any consultation is targeted. We doubt that mandatory public consultation will
add much to the detail of local fire plans. They could be made available for
public input, but the requirement to neither consult nor give effect to public
submissions should be provided for. The development of these plans is a
technical issue and should be left to those with relevant expertise.
Further Consultation
- 16.Water New Zealand would like to
be kept engaged in the development of these regulations as they progress.
Sincerely
John
Pfahlert
Chief
Executive