Submission to "Next Steps for Freshwater"

Transcription

1 Submission to "Next Steps for Freshwater" Name of submitter: Paul Elwell-Sutton. Statement: 1.) I have lived in for the past 15 years. 2.) I am a retired trapper. 3.) I have no pecuniary interest in water management. 4.) I hold a B.Sc. in Animal Physiology from the University of Aberdeen, Scotland. Submission 1.)I seek that the national bottom line for water quality be established between fresh water objective states B and C, instead of between C and D. Reason: Fresh water suitable only for boating or wading is already a risk to human and environmental health, and can surely not comply with section 5(2)(b) of Part II of the RMA, which provides for "Safeguarding the lifesupporting capacity of air, water, soil, and ecosystems;". It is unacceptable to me that such a compromised water quality standard as contained in the NPS-FM can even be considered by government, and is a major betrayal of the values held by a great many New Zealanders. Exceptions to the minimum B state to apply exclusively to scheduled water bodies, as outlined in paragraph 4 of this submission. 2.)I strongly support the proposal to exclude stock from waterbodies, with the proviso that the all the proposed deadlines set out in Table 2 of the consultation document "Next steps for fresh water" 2016, be amended to 2020, apart from 2017 for dairy platforms. Reason: Contamination of fresh water with stock effluent is a serious and growing problem in New Zealand. The natural values of water bodies are compromised by this pollution. Those include ecosystem, recreational, aesthetic, cultural and spiritual values. Damage to riparian margins caused by stock results in increased erosion and high sediment loading in affected water bodies, and potentially destruction of habitat provided to terrestrial and aquatic native fauna by riparian vegetation.

2 Excluding stock from water bodies in the manner proposed complies with section 5(2)(c) of Part II of the RMA which provides for "Avoiding, remedying, or mitigating any adverse effects of activities on the environment". I maintain that a period of 3-4 years to exclude stock other than dairy platform cows, from water bodies, rather than up to 15 years, is ample time for compliance to be achieved, and that an overall deadline of 2020 is necessary, desirable and realistic. 3.)In connection with the exclusion of stock from water bodies, I support the need for riparian margins to be planted out with typically riparian, but noninvasive, vegetation and I oppose that measures be made available to circumvent that requirement. Reason: Riparian vegetation helps prevent bank erosion and consequent in stream sediment loading, as well as filtering nutrient runoff from grazing pasture. In addition, overhanging vegetation provides habitat for fish and other aquatic organisms, and assists in maintaining water temperatures and ecosystem health. It can also provide habitat and migration corridors for native birds. 4.)I also seek that where exclusion of stock from fresh water bodies in catchments located within UNESCO World Heritage Areas and/or National Parks is impossible or impractical, that that stock be removed immediately from those areas, and the land in question permanently retired from pastoral use. Freehold pastoral land to be purchased at government valuation, and the balance of the lease on leasehold land to be refunded. No further compensation to be offered or available. The water quality state in such bodies must comply with national objective A, while recognising that natural flood events may temporarily breach those standards. Reason: Catchments in UNESCO World Heritage Areas and National Parks invariably contain very high natural values, including intrinsic, ecological, biodiversity, scenic, cultural, spiritual and recreational values, all of which are integral to New Zealand's identity. New Zealand's National Parks and World Heritage Areas attract several million visitors to our country every year. This tourism is indisputably vital to New Zealand's economy as it contributes $10.6 billion annually, so protecting these areas and their water bodies is of paramount economic importance. River valleys and water bodies within these areas are generally most accessible to the public, so maintaining them free of stock damage from erosion, browse, or pollution is in our best economic interests. Damage from stock is a cumulative process, not easily discernable from one year to the next; however, when viewed over a period of decades, the negative effects on native vegetation, riparian margins, and water quality become apparent.

3 5.)I support the proposed mandatory use of the Macroinvertebrate Community Index (MCI) tool to assess fresh water quality. I do not believe in or support a principal alternative, although additional measures such as heavy metal or pesticide loadings can complement an MCI. Reason: The MCI is a fair and practical measure of ecological health and of the life-supporting capacity in fresh water, and gives effect to section 5(2)(b) of Part II of the RMA cited in paragraph 1 of this submission. 6.) I seek that all water bodies comply with the minimum freshwater objective state B, and that any which do not or cannot, be included into a schedule of non-compliant water bodies. Inclusion into a schedule set up to identify non-compliant water bodies must be subjected, prior to consideration for inclusion, to a rigorous and independently peer-reviewed ecological assessment by suitably qualified personnel, as well as an open, democratic and transparent public consultation process. Inclusion in such schedule must be an exception to the rule. The great majority of water bodies to maintain a water quality state of B or A, with A being the desirable objective. 7.)I submit that without a sound management vision and strategy in place to manage the human population of New Zealand, no environmental protection measures, including those applying to fresh water, can have a durable and significant effect. Reason: Without a stabilised human population, environmental protection measures are limited to reacting to demographic changes. Population management needs to be recognised as key to integrated environmental protection and management. 8.)Recognising that agency capture is an ongoing obstacle to effective environmental protection, especially with regard to some local body authorities such as the West Coast Regional Council (WCRC), I dispute that local councils "are in the best position to make decisions about managing fresh water in their region...". Local councils are frequently loaded with, for example, in the case of the West Coast councils, farmers, loggers and miners, and lack councillors or staff sympathetic to, or understanding of, the issues around environmental protection. It is unrealistic to expect satisfactory environmental outcomes from councils thus skewed towards extractive industries. I seek that national provisions be instated to guard against agency capture of central and local government through effective oversight by an independent and qualified commission. Additionally, councils must be adequately resourced to carry out their functions in fresh water management. This is partly a responsibility of central government, but cost recovery from water users, particularly in the

4 commercial sectors, should be mandatory in order to avoid providing hidden subsidies to those sectors. 9.)I conditionally support the Freshwater Management Unit (FMU) concept, but only if it cannot be used as a tool to allow fresh water quality deterioration in other parts of a jurisdiction located outside of the FMU, while providing a consequently fraudulent impression of region-wide water quality improvement. FMUs must only be used to act synergistically across a region in order to attain total regional water quality improvement. An FMU may apply only to a catchment in order to facilitate monitoring and management. 10.)Regarding the Land and Water Forum (LAWF), I submit that its composition must be made up of, in equal numbers, recreationalists, fresh water ecologists and industry representatives, with the chair to be a demonstrably independent, impartial and well-informed person. Reason: It is critically important for the LAWF to be free of agency capture in order to reach balanced and wise water quality decisions. 11.) Regarding compliance monitoring, I support a mix of financial incentives such as rates relief and free advice, and enforcement, to ensure compliance with fresh water protection legislation. Relying on voluntary compliance and self-monitoring may work to some extent, but cannot ensure the necessary degree of compliance with water quality regulations. Local authorities must be adequately resourced to carry out their fresh water management functions through cost recovery and central government support. 12.)I agree with the proposal to apply lake attributes and national bottom lines to intermittently closing and opening lakes and lagoons (ICOLLs). Reason: The ecology of ICOLLS is specialised and often provides breeding, roosting and foraging habitat for a wide range of fresh water and sea birds. Furthermore, such lakes and lagoons are commonly used for recreational activities such as bird watching, fishing, swimming and duck shooting. It is surely important that the minimum water quality in these water bodies meet state B in the national objectives table, and thus comply with the relevant Part II provisions of the RMA. 13.)Regarding productive use of fresh water, I wish to advise that fresh water supporting a healthy ecosystem is already highly productive in that it meets the needs of some of the other plants and animals with which we share this planet and which, through their wellbeing, support us in countless measurable and immeasurable ways through what are known as ecosystem services, which are provided free of charge.

5 The narrow view of productivity based on human use of water is as misguided and obsolete as the once-held beliefs that the earth was flat, or that the sun revolved around the earth. In this century it is time for us to dump the anthropocentric view of life, and wake to the understanding that we form a part of the complex web of life, which has no centre, and in which interdependence is fundamental to life. With that understanding will come a normal inclination to live in symbiosis with the natural world and curb our propensity to consume, pollute and breed. 14.)I strongly oppose the proposed transfer of water and discharge allowances. Reason: This proposal is similar to the Emissions Trading Scheme (ETS) and will fail to improve water quality and quantity outcomes, just as the ETS has failed to reduce greenhouse gas emissions, all the while creating a fortune-making carbon trading market. The proposal will allow business as usual for some water users, while creating a lucrative water trading market, with no ultimate overall improvement in water quality or quantity across New Zealand. This proposal will also expedite and facilitate the full scale privatisation of fresh water in New Zealand. Only by prohibiting the transfer of water and discharge allowances can real progress be made in efficient water use. 15.) I submit that standards for diffuse nitrogen discharges be developed to ensure a bottom line water quality B state, that those standards be sciencebased and developed by soil, water, agricultural research and climate science institutions. I also submit that those standards extend to include the other common diffuse pollutants off agricultural land, such as phosphates. Once in place, those standards to be applied to all existing consent holders within 2 years. Compensation in the form of tax rebates or rates relief may apply on a case by case basis. Reason: Diffuse pollutants off agricultural land are a major concern in New Zealand, and have the potential for widespread eutrophication of water bodies, rendering them unfit to support normal healthy aquatic ecosystems, and unfit for human use. Controlling them is of vital importance to our collective and continuing wellbeing. 16.)I strongly support the concept of "Te mana o te wai". Reason: My own views on water align precisely with the concept of "Te mana o te wai" and the position that nobody owns fresh water in New Zealand, but that water is an entity in its own right. This concept has the potential to protect fresh water from the rapacity of the current economic system.

6 17.)I broadly support the proposals for iwi participation in decision-making and planning affecting fresh water. Reason: The proposals give effect to the statutory rights set out in the Treaty of Waitangi for Maori. Political will on the part of local bodies is essential for proper recognition of those rights, while good peer-reviewed research into fresh water issues is needed for effective and equable collaboration between iwi and local bodies. 18.)Regarding Water Conservation Orders (WCOs), planning processes must not be able to stymie WCO applications, otherwise planning and consent applications could be used strategically to block a legitimate WCO application. 19.) I question the level of government funding for fresh water clean ups and protection because it seems very modest in the scheme of things and declining, while government seems bent on generously funding irrigation projects under the guise of collateral environmental benefits. 20.)I support in principle the proposed Fresh Water Improvement Fund. Reason: The proposal seems reasonable and workable, and the sentiments therein laudable. Whether the fund remains a rhetorical PR exercise remains to be seen. It will be essential to demonstrate results. End of Submission. Paul Elwell-Sutton. 18/4/2016.