Next steps for fresh water

Transcription

1 Next steps for fresh water SUBMISSION FORM The Government is seeking views on the way fresh water is managed in New Zealand. For more information about the Government s proposals read our Next steps for fresh water consultation document. Submissions close at 5.00pm on Friday 22 April Contents of submissions may be released to the public under the Official Information Act 1982 following requests to the Ministry for the Environment (including via ). Please advise if you have any objection to the release of any information contained in a submission and, in particular, which part(s) you consider should be withheld, together with the reason(s) for withholding the information. We will take into account all such objections when responding to requests for copies of, and information on, submissions to this consultation under the Official Information Act. The Privacy Act 1993 applies certain principles about the collection, use and disclosure of information about individuals by various agencies, including the Ministry for the Environment. It governs access by individuals to information about themselves held by agencies. Any personal information you supply to the Ministry in the course of making a submission will be used by the Ministry only in relation to the matters covered by this consultation. Please clearly indicate in your submission if you do not wish your name to be included in any summary of submissions that the Ministry may publish. Submission form The questions below are a guide only and all comments are welcome. You do not have to answer all the questions. To ensure your point of view is clearly understood, please explain your rationale and provide supporting evidence where appropriate. Contact information Name* Organisation (if applicable) Address Telephone Submitter type* Individual NGO Business / Industry Local government 1

2 Central government Iwi Other (please specify) * Questions marked with an asterisk are mandatory. Fresh water and our environment 1. Do you agree that overall water quality should be maintained or improved within a freshwater management unit rather than within a region? Why or why not? Yes No I believe overall water quality should be improved to its natural life supporting capacity and maintained in that state. If water is not owned and is borrowed for private gain it must be on the basis it is returned in the same state. Costs for restoration must be borne by the polluter or the wider community compensated. There are strong sentiments connected with our water ways of New Zealand characterised by a sense of stewardship - we do not inherit the earth from our parents - we borrow it from our children. Waterways that meet or exceed the swimmable standard must be protected and maintained at this level. Waterways that fail this standard must be improved to swimmable. The current wording of maintain or improve makes poor water quality acceptable. I expect water quality to be at least maintained everywhere. It is not acceptable to set a policy position of intentionally degrading some water bodies. Our land use and water resource use are integrated and interconnected. Increasing land intensification is not only increasing demands on freshwater quality, it is taxing soil quality. Dairy winter grazing is causing soil loss (wind & water erosion) and soil degradation (compaction and soil microbial loss). Our land use systems need to match soil and water resource biophysical limits and incorporate soil and water resource regeneration into our land management and business accounting systems as opposed to the current extractive models. Intergeneration thief. 2. How should the attributes be applied, or the values protected, in giving effect to the requirement to maintain or improve overall water quality? Please explain. From my experience living in a rural environment undergoing increasing land use intensification water quality attributes must include sediment, temperature, benthic cyanobacteria (toxic algae), and E.coli for human health and dissolved inorganic nitrogen, and phosphorus for ecosystem health along with Macroinvertebrate Community Index. The decline in water quality of local rivers and streams in the last years has been very noticeable in terms of over abstraction, incidence of algal blooms; high water temperatures; dewatering; dog deaths and human sickness. We now no longer picnic camp or swim in our valley floor rivers of our youth and childhood. As a child swimming and eeling in the local river was a given however now most of these are either clogged vegetated drains or significantly dewatered and totally dried out. Those that have reasonable flows seem to be missing the life and freshness of past river experiences. The most saddening aspect is we can't pass this experience on to our grandchildren unless we take them into 2

3 the highcountry headwaters and then explain because of our poor land husbandry downstream we have degraded and contaminated the once fresh and life sustaining lower valley and plains rivers and water courses so they are no longer safe to swim in or sustain the natural aquatic flora and fauna. Of concern is that lack of faith and trust in our regional and district councils to actively manage fresh water quality on behalf of the wider community. They need to quantify and manage soil and water resource within their biophysical limits. In order to allow private commercial use of this environment sustaining and community resource, the full set of water quality attributes including Macroinvertebrate Community Index, dissolved inorganic nitrogen, and phosphorus must be applied along with monitoring and enforcement within catchments. 3. What is an appropriate way to include measures of macroinvertebrates in the National Policy Statement for Freshwater Management? What alternative measures could be used for monitoring ecosystem health? A good measure would be to invest dollar for dollar in waterways establishing and setting biophysical limits for water allocation, water quality restoration and research to the same level as government and regional and district council support/investment in irrigation subsidy schemes. Commercial use needs to move to accounting and factoring in freshwater regeneration into land resource use practises to biophysical limits for them to be truly sustainable in this land of finite resources. Our natural aquatic biodiversity needs clean, safe water. The Macroinvertebrate Community Index (MCI) is our most useful indication of the health of freshwater ecosystems. I support the inclusion of the MCI as a mandatory method for monitoring the wellbeing of freshwater life. 4. What information should be required in a request to include significant infrastructure in Appendix 3 of the National Policy Statement for Freshwater Management, and why would this information be important? the values that a regional council has identified in the FMU their impact on Te Mana o te Wai of a water body ongoing impacts on iwi/hapū rights and interests evidence of current water quality and sources of contaminants which FMUs, if any, breach any national bottom lines whether infrastructure contributes to any breaches. the range of options available to improve water quality. This is important in order sustain maintain and improve fresh water quality. 5. Do you agree with applying lake attributes and national bottom lines to intermittently closing or opening lakes or lagoons? Why or why not? Yes No These water features are vital components to sustaining our wetland flora and fauna biodiversity and contamination and degradation needs to be managed so these nature systems are sustained. 3

4 6. What information should be required in a request to list a water body in Appendix 4 of the National Policy Statement for Freshwater Management, and why would this information be important? 7. Do you agree with the proposed requirements and deadlines for excluding livestock from water bodies? Why or why not? Yes No Yes stock exclusion is essential to restoring fresh water quality. No they need shorter phase in and must include an appropriate buffer between the fence and the waterway as just excluding stock doesn't manage or mitigate non point source migration especially dissolved inorganic nitrogen, and phosphorus. Dairy support lead in needs to be reduced. An appropriate buffer is an adequate vegetated buffer to protect the life sustaining capacity of water bodies by preventing sedimentation, stabilise stream banks and prevent bank erosion, intercept non-point source pollutants carried by surface water runoff and remove the excess nitrogen, phosphorus and other substances that can pollute water bodies. Economic use of fresh water 8. Should standards for efficient water use be developed? Should standards for good management practices for diffuse nitrogen discharges be developed? Who should be involved in their development? When should they be applied to consents (eg, on consent expiry and/or on limit setting and/or permanent transfer)? This is a very complex question but the planning of natural water use must be guided by the following: Proper limit-setting for ecological health needs to occur before allocation of water is undertaken, so that allocation does not drive limit-setting. First order priority considerations: the environment, customary uses, community supplies and stock water; Second order priority considerations: recreation and amenity, irrigation, hydro. Good Management Practise (GMP) should apply to the whole range of land and water use practices as they part of integrated system that impact on the ecological health of freshwater systems. In this respect GMP was envisaged by Land and Water Forum (LAWF) as a fundamental requirement for all land and water users that would be implemented in all catchments. In terms of water management the government needs to fully implement all recommendations of the Land and Water Forum and involve them and the wider community engaged meaningfully in further water management as this is a community and national resource, otherwise this attempt at collaboration will be seen as a sham and ultimately abandoned as Fish and Game have done. The reengagement of F&G is vital as they are currently one of the few independent stewards and advocates for fresh water quality. Given the current and more recent levels of water quality 4

5 degradation, more commercial water user investment in water quality restoration is required along with a more precautionary approach over further private water use. ECAN government commissioners have clearly undermined faith and trust in Government motives by managing water resource exploitation for a select group for private gain, at the expense of the environment and wider community who rely on this drinking water, swimming and the nature aesthetics of our water ways. Environment needs and customary uses, community supplies and stock water; are the first order priority and then recreation (swimming in particular) followed by renewable electricity generation before any private irrigation or other commercial use. The major issue in the document is the lack of discussion on water ownership and pricing. This is needed while allowing trading is a good idea, we need to recognise that the rights to use water are owned (via consents) and any trading should be implemented in tandem with a resource rental on the owners of water use consents but subject to limit setting and subservient to the above first order priorities. Discussion on pricing and ownership on water needs to be held. At this stage my view is a price on water will influence effective and efficient water use. Ashburton District Council plans to sell 40 billion litres of pure water from an over-allocated catchment to a water bottling company in a time of drought; Oravida has a consent to 146 million litres of ground water a year and the regional council says Oravida pays an annual compliance charge of around $500. Oravida markets the water at $1.60 a litre, meaning if all 146 million litres were sold it could be worth $233 million a year. These are public resources being plundered for private gain. We need a system to ensure that we actually benefit from our own resources and at all time meet first order priorities. Funding for freshwater improvement should not be used to subsidise irrigation, at least until the externalities of intensive farming and water extraction have been dealt with by appropriate pricing. Farm business plans and accounting must account for externalities of intensive farming and water extraction so environmental and freshwater quality management are not socialised to those not benefiting from commercial gain from a natural community resource. 9. Do you support easier transfer of consents? Do you think the changes outlined in Proposal 2.4 would better enable transfers? What other changes would better enable transfers? Yes but as above and only after achieving water quality restoration to levels that sustain the natural aquatic biodiversity of water ways and first order priorities are met. 10. How should the Government help councils and communities address over-allocation for water quality and water quantity? Should it provide guidance, rules or something else (please specify)? Research and invest in water quality planning, allocation of assimilative capacity (nutrient loads) need to occur in the context of effective environmental limits that are set to protect ecological health. Provide direction in the NPS as to how limits and targets must be incorporated into Plans. This would need to specify that activities that do not comply with a limit or are not consistent with achievement of a target are to be treated as non-complying or prohibited activities. The government for effective freshwater resource management needs to ensure first order priority considerations for the : the environment, customary uses, community supplies and stock water are met and invest in fresh water science, monitoring, management and enforcement in regards allocation and sustainable resource regeneration from the commercial fresh water users. 5

6 11. Should councils have greater flexibility in how they meet the costs of improving freshwater management? For example, by recovering costs from water users and those who discharge to water? Please provide examples. We support the use of cost recovery from consent holders but believe this should be broadened to include a resource rental to pay for fresh water clean ups. User pays. As the former prime minister Sir Geoffrey Palmer says in relation to natural resource use, The polluters don't pay and those who are harmed by the pollution aren't compensated.'' Iwi rights and interests in fresh water 12. How can the Government help councils and communities to better interpret and apply Te Mana o te Wai in their region? The health and well-being of our water bodies is integral to the health and well-being of our land and other resources (including fisheries, flora and fauna) and to our health and wellbeing both as communities and as a nation. For me the health of our water ways is like the health of our blood arteries reflecting on the health of our body and land. 13. Should councils be required to identify and record iwi/hapū relationships with freshwater bodies, and how should they do it? We support the inclusion of iwi in consultation and note that iwi values are very close to those of ours on swimmability and food gathering. Iwi rights over water also need to be resolved as part of the general issue of water ownership 14. What would support councils and iwi/hapū to engage about their values for freshwater bodies? 15. What are your views on the proposal for a new rohe-based agreement between iwi and councils for natural resource management? What type of support would be helpful for councils and iwi to implement these to enable better iwi/hapū engagement in natural resource planning and decision-making? 16. What are your views of the proposed amendments to water conservation orders? Outline any issues you see with the process and protection afforded by water conservation orders? I am strongly opposed to allowing the Minister for the Environment to delay an application for a Water Conservation Order. WCOs are about protecting outstanding features of water bodies. If those outstanding features exist then clearly they shouldn't be undermined by a planning process which is required to protect them anyway. Amend the existing process to allow relevant iwi engagement. Otherwise retain the existing process. 17. If you are involved with a marae or live in a papakāinga, does it have access to clean, safe drinking water? What would improve access to clean, safe drinking water for your marae or papakāinga? 6

7 Freshwater funding 18. Do you agree with the proposed criteria for the Freshwater Improvement Fund? Why or why not? I believe the user/polluter should pay other wise our freshwater resource is not valued and its quality sustained. Other comments 19. Do you have any further comments you wish to make about the Government s proposals? Our fresh water resource must be able to support a good standard of ecological health. That standard also equates to being safe for humans to swim, play, and gather food from. Ko te wai te ora ngā mea katoa - Water is the life giver of all things. Thank you for the opportunity to submit. 7

8 Releasing submissions Your submission may be released under the Official Information Act 1982 and may be published on the Ministry s website. Unless you clearly specify otherwise in your submission, we will consider that you have consented to website posting of both your submission and your name. Please check this box if you would like your name, address, and any personal details withheld. Note that the name, , and submitter type fields are mandatory for you to make your submission. When your submission is complete If you are ing your submission, send it to watersubmissions@mfe.govt.nz as a: PDF Microsoft Word document (2003 or later version). If you are posting your submission, send it to Freshwater Consultation 2016, Ministry for the Environment, PO Box 10362, Wellington Submissions close at 5.00pm on Friday 22 April