nof submission submission to ministry for the environment re: amendments to the national policy...

8/13/2019 NOF Submission Submission to Ministry for the Environment Re: Amendments to the National Policy Statement fo

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Submission to Ministry for the EnvironmentRe: Amendments to the National Policy Statement for Freshwater

Management 2011, and specifically the National ObjectivesFramework

Andrew GawithPO Box 19218Wellington 6149Email:[email protected]: 027 4511 417

While the following submission focuses on sections 4.3 and 4.4 of theproposed amendments to the National Policy Statement for FreshwaterManagement 2011 (NPS FM), we make two general but importantobservations about the proposed amendments.

Firstly, the NPS FM requires Regional Councils, in setting their freshwaterobjectives, to maintain or improve overall water quality within their region.

That sounds reassuring, but in fact it is grossly misleading.

In practice the proposed Framework allows Councils to set attributes thatwould permit a significant deterioration in water quality in some watermanagement units so long as there were offsetting improvements in othermanagement units within the region. Its not clear how these offsets would beaudited and indeed whether water management units are sufficientlyindependent to make the measurement, definition and maintenance of suchoffsets credible.

We recommend that Councils be required to maintain or improve water quality

in every management unit. To be clear, (and also consistent with the generalmessage in NPS FM) no offsetting would be permitted.

If the government wants to retain wriggle room it could state that a Council, inexceptional circumstances, may permit a deterioration in water quality, but inso doing it would be required to be very public about the permitteddeterioration, the reasons for allowing it, who will benefit and what the likelylong-term costs will be for water quality and the environment.

Secondly, there appears to be a relatively narrow view taken on the economicvalue of waterways. The overriding impression is that the objectives accept as

necessary a trade off between the economic returns we can achieve by
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exploiting our rivers and lakes (mainly for agriculture, but energy as well) andthe social and environmental benefits we enjoy from having clean waterways.

The economic benefits that can be derived from our waterways are not justthose captured by farmers, especially dairy farmers, and power companies.

There are a number of important long-term economic benefits from improvingour waterways and ideally returning many more of them to closer to theirnatural state. Tourism (both international and domestic), and nationalbranding depend on the quality and sustainability of our environment. Nationalbrandingas was made clear by the Prime Minister in justifying thegovernments direct investment in foreign filmmaking in New Zealand is amajor contribution to GDP via tourism as well as the price premia for productsmade in an environmentally sustainable way.

The economic impact modelling that has been undertaken suggests that in

Southland dairy cow numbers can increase while maintaining or improvingwater quality. That seems unlikely.

It is not obvious from the NPS-FM proposed amendment document that anyaccount has been taken of the potential costs to our economy of destroyingthe integrity of the 100% Pure brand that has been so successful instimulating visitor numbers; nor the cost of undermining the clean-greenimage that has been so important in marketing our agricultural exports.

We recommend the government releases the full details of the economicimpact modelling that has been undertaken so that it can be peer reviewed.


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Proposed amendments to the NPS-FM: Compulsory values

Q25. Do you agree that ecosystem health should be a compulsory value?YesComment

Our major concern is that this value is worded in such a way as to appeal tomost people because they will interpret it as meeting their perception ofecosystem health. Who would not endorse the idea of healthy ecosystems?

To the extent that ecosystem health is defined at all, it requires Councils toavoid chronic effects such as high temperatures, low oxygen, changes infreshwater chemistry, high sediment levels, or algal blooms. Other importantmatters are toxic effects of contaminants, and the essential habitat needs ofthe flora and fauna. In almost like suggesting that an ecosystem is healthy aslong as it is not dead! A more truthful way of stating this compulsory value ascurrently defined would be that ecosystem health should not be seriously

impaired. Such as statement would of course attract considerable scrutiny,but as worded the Minister and the Ministry have sought to minimise suchscrutiny.

Q26. Do you agree that human health for secondary contact recreation (suchas boating and wading) should be a compulsory value?NoCommentThe compulsory value for human health should be for primary contactrecreation. The policy statement makes it clear that Objectives can and will belong term. Requiring Councils to aim for rivers and lakes clean enough toswim in would be consistent with maintaining or improving water qualityeventually all waterways would be safe to swim in. Furthermore it wouldsupport the wider and longer-term economic benefits of healthy waterways.

Q27. Do you think there should be more compulsory values? If so, whatshould they be, and why? What attributes should be associated with them?

Yes.

Comment

Human health for primary contact recreation should replace the secondarycontact compulsory value and be a long-term (20 year) compulsory value for a

high proportion (90%) of all rivers.


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Proposed amendments to the NPS-FM: National bottom line

Q28. Should there be numeric bottom lines for attributes of the compulsoryvalues?No

CommentNumeric bottom lines are an invitation to let water quality decline. Rather thanbottom lines, and also to back up the broad requirement in the NPS FM tomaintain or improve water quality, we recommend that the government setsnumeric improvements goals and timelines for each attribute.

Q29. Do you agree with the proposed level at which bottom lines would be setfor each attribute of ecosystem health? If not, at what level should they beset?NoThe proposed numeric standards permit a significant decline in water quality

given that Councils can allow some management units to deteriorate so longas others improve achieving as a minimum stable water quality across theregion if such a concept has any credible meaning.

The proposed nitrate bottom lines allow waterways to hover just above toxiclevels. That is a much weaker standard than most of our major waterways arecurrently at and would allow Councils to invite farmers to continue convertingland to dairying using existing farm management practices.

We recommend that if there are to be bottom lines they be set for eachwaterway at their current level, but with the proviso that there should benumeric improvements goals and timelines for each attribute.

30. Do you agree with the proposed level at which bottom lines would be setfor each attribute of human health for secondary contact recreation? If not, atwhat level should they be set?NoSee comments in response to Q29.

31. Do you agree that transitional arrangements should be provided to allowcouncils and communities to set objectives below a national bottom line for a

short time?YesBut such transitional arrangements should be in conjunction with minimumrates of improvement as set by the government for each attribute. Moreover,any Council using this transitional arrangement would be required topublicise the any permitted deterioration, the reasons for allowing it, who willbenefit and what the likely long-term costs will be for water quality and theenvironment. Transparency is paramount.

nof submission submission to ministry for the environment re: amendments to the national policy...

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