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5 Sediment and E. Coli reduce ecosystem health, human health,

livestock health and make swimming and fishing difficult and

unpleasant.

6 Lack of shade and excess nutrients contribute to the growth of

weed and algal blooms, which can also make swimming andfishing difficult and unpleasant and algal blooms

(cyanobacteria to be precise) may in some cases contribute to

the creation of poisonous cyanotoxins.

7 Depending on local conditions, it may take decades or even

centuries to see the impacts of current practices on water

quality.

8 The Macroinvertebrate Index is a better indicator of ecosystem

health than any one nutrient variable.

9 In recent decades the amount of human sewage and industrial

waste that has gone into waterways has reduced.

10 The increased intensity of farming, which is particularly

evident in the dairy sector, is the most likely cause of any

continuing degradation.

11 More intensive farming is being made possible by increased

irrigation.

12 There are a variety of ways of mitigating the impact of farming

on water quality, depending on local circumstances. Some of

these, such as reduced intensity or precision agriculture, can

have a neutral or even positive impact on farm profit. It is also

possible to mitigate the effects of high intensity farming, such

as with feed pads and wintering sheds in the case of dairy, but

this is likely to increase farming costs.

13 NOF is a valuable start in establishing a framework for

freshwater management but there is considerable scope forimprovement if it is to be effective in improving the

management of all water bodies. There is an urgent need to

develop the NOF further.

14 When considered individually  each of the NOF bottom lines

(where they exist) is adequate to prevent waterways from

reaching a state of irreversible degradation.

15 The approach taken in NOF does not account for the composite 

effects of water attributes.

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16 Composite effects may trigger an unexpected and irreversible

ecosystem collapse.

17 Ensuring the NOF assists communities in the process of setting

limits that are appropriate for a particular water body but also

reflect complex interconnections between waterways (such asrivers, lakes, wetlands, estuaries and groundwater) is a

challenge facing those designing the NOF.

18 In principle using adaptive management is the best way to

manage freshwater.

19 To be effective, adaptive management requires comprehensive

and timely monitoring of water quality, land use, off-takes and

discharges and a reliable understanding of the ecological

processes at work within catchments.

20 In practice, many catchments will not have the level of

information required for adaptive management, so managers

will have to be precautionary in the way they manage their

waterways.

21 Given the current wording of the draft amendment to the NPS-

FM that includes the NOF with the exception of ‘outstanding

water bodies’, ‘significant values of wetlands’ and ‘degraded’

water bodies that have been ‘over-allocated’, it is unclear

what protection the NPS-FM provides for water bodies withwater quality above the bottom line. As it currently stands

NPS-FM Objective A2 (“the overall quality of fresh waterwithin a region is maintained or improved”) could be seen asallowing deterioration in some attributes within a waterway ,

or deterioration in water quality within a catchment  (providing

on average there is no deterioration within the region). This

uncertainty regarding the intent of the NPS-FM with its Draft

Amendments will unnecessarily obstruct its implementation.

22 Please indicate whether you are comfortable having yourname used as being involved in this process. No

statements will be attributed to individuals.