We thank the HBRC for the opportunity to comment on the draft Plan Change 6 and also to present our submission in person to any hearing convened.

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1 From: Te Taiao Hawkes Bay Environment Forum To: Chief Executive Hawkes Bay Regional Council Private Bag 6006 Napier 4142 Submission on Tukituki Plan Change 6 1. Introduction We thank the HBRC for the opportunity to comment on the draft Plan Change 6 and also to present our submission in person to any hearing convened. Te Taiao Hawkes Bay Environment Forum is an umbrella group formed by a number of conservation/environmental groups in Hawkes Bay who care for our region and who wished to achieve better environmental outcomes by improved coordination and sharing of information. The group includes the three branches of Forest and Bird (Napier, Hastings-Havelock, Central Hawkes Bay) Sustainable Hawkes Bay Trust, Bay Watch, Guardians Hawkes Bay Fisheries, Te Roopu Kaitiaki O Te Wai Maori, Friends of the Tukituki River. The principles that guide the group include: Strong sustainability Interconnectedness of our key environmental issues Dependence of social, cultural and economic well being on environmental well being The group has identified the following keystone environmental issues for Hawkes Bay Decline in quality of freshwater Increasing demand for freshwater resulting in low summer flows in rivers and streams Unsustainable land use Declining indigenous biodiversity Insufficient recognition of cultural values

2 2. Comments on Plan Change 2.1 Positive Aspects There are a number of positive aspects to the proposed plan change and these include the provision for greater protection of waterways by fencing and riparian planting, provision for nutrient management plans, increase in minimum flows in the major rivers. 2.2 Values Te Taiao Hawkes Bay Environment Forum members have a strong interest in the entire Tukituki Catchment from its source to the sea and are committed to the land and water resources being managed sustainably. Some live close to the Tukituki and Waipawa Rivers and many use these waterways regularly. We value these waterways and their tributaries for the following reasons: Cultural and spiritual values they provide a life force which helps meet the individual and collective needs for both Maori and non Maori. The Mauri of these areas is important. Life supporting capacity this value occurs throughout the waterways and helps provide important sites for plants, invertebrates, fish and birdlife Food gathering significant fishing (whitebait, smelt, tuna/eel, patiki/flounder, kahawai, trout) and harvesting of watercress takes place from the mouth of the Tukituki River upstream to the Ruahine Ranges Recreation a wide range of different activities (swimming, tubing, kayaking, picnicking, fishing, bird watching. walking and exercising pet dogs) takes place primarily on the major waterways (Tukituki and Waipawa Rivers). Significant stretches of these rivers are very accessible to the public because the HBRC has developed and maintained a very good network of public access points from the mouth upstream to SH 50. Waipawa and Waipukurau townships straddle these rivers which enables the residents to readily walk to the rivers. The above community values are very much dependent on good water quality and adequate summer flows. The rivers need to be managed for these values but unfortunately the plan does not adequately give effect to these values. This may partly arise by the values setting exercises completed by HBRC staff and other specialists being too coarse and broad brush to be effective. 1. The community values which should under pin the Tukituki catchment plan change should be reviewed and completed in more detail.

3 2.3 Water Management Zones The planning maps (Schedules XV, XVI, XVII) accompanying the Plan Change are too coarse and broad and therefore unclear and difficult to follow. The water management zone map identifies five zones. The boundaries of some of these zones appear to not follow catchment boundaries or reaches of rivers. In particular the boundary between Zone 2 Ruataniwha North and Zone 3 Ruataniwha South appears to follow the Waipawa River. Management of water resources should follow catchment and sub catchment boundaries and be sub divided into river reaches if need be. The zone boundaries should also reflect the community values related to river stretches around which the plan change should be framed. 1 Catchment, sub catchment and river reach boundaries be used to establish zone boundaries based around community values 2.4 Surface water quality limits and targets The community values for the stretches of rivers should also under pin the water quality standards. It should also be noted that community concerns about slime and algae in the rivers is not confined to the Lower Tukituki Corridor (downstream of Tukituki and Waipawa confluence) as stated in a number of HBRC reports but extends well upstream above SH 2 for both the Tukituki and Waipawa Rivers. Management opportunities for point and non-point source discharges should be managed through regulations for water quality and quantity limits. Limits where appropriate, should be applied as standards in the rules. In particular per hectare nitrogen should be applied to ensure land uses are managed to achieve the instream DIN concentration which is set in order to control undesirable periphyton blooms, cyanobacteria blooms and maintain macro-invertebrate health. Some of the proposed limits and targets in Table 5.9.1B are inadequate. For example some of the figures (limits and targets) proposed in the plan change for nitrate-nitrogen in the Tukituki and Waipawa Rivers are % higher than current levels and appear to be set for toxicity to fish and not limiting algae or safeguarding life supporting systems. Reducing phosphorus levels has been identified in the plan change as a key to reducing algae and slime and appropriate standards should also be set to achieve this. A standard maximum level of dissolved reactive phosphorus (DRP) of 0.10 would better achieve the improvements sought in the plan change. It should also be noted that algae problems are not just confined to the lower Tukituki but also occur in the reaches of the Waipawa and Tukutuki between SH 50 and SH 2. In addition if the RWS dam proceeds there is no ability to provide flushing flows in the Tukituki River upstream of the confluence with the Waipawa River. Water clarity indicators are too low and should be 5-10metres on the black disc measure. Macroinvertebrate community (MCI) levels should also be a minimum of 120.

4 There are also additional standards that should be included to provide a more comprehensive basis for monitoring water quality. Current % figure for alert levels for Cyanobacteria is being reviewed nationally and opinion is moving towards reducing the % from 60 to 50%. Sediment cover should be set for all water bodies. N/a is not acceptable Standards should be set based on river, reach or site specific community values and these standards should be considered environmental bottom lines and should not be breached at flows below flood flows. Water quality limits should not allow degradation of water from its current state and must be consistent with the purpose and principles of the RMA and NPS Freshwater. Recommendations: 1. Table 5.9.1B be based on new zones adopted on a catchment, sub catchment and river reaches basis. 2. Limits for water quality should be applied as standards in rules. 3. A lower limit is adopted for nitrate nitrogen (SIN) in Table 5.9.1B Zone 1, 2, 3 and mg/litre Zone mg/litre 4. Additional water quality standards for ph, temperature, dissolved oxygen and E coli be included in Table B 5. The maximum cover (%) for Cyanobacteria in Table 5.9.1B reduced from 60% to 50% to reflect current scientific opinion. 6. Sediment cover be set for all water bodies with <5% for trout spawning and pristine sites and 10% for lower catchment sites 7. Water clarity be set at 5-10 metres 8. MCI be set at 120 minimum for all zones 2.5 Wetlands Wetlands are important for a wide range of reasons including biodiversity, cultural and ecosystem services. It is unclear how significant freshwater wetlands will be identified and how wetlands in the Tukituki catchment relate to the Regional Policy Statement Change 5. POL TT11 in this plan change says to generally manage the effects of groundwater takes on surface water bodies, including wetlands. How can this be achieved if we don t know what

5 wetlands we have in the catchment and how significant they are? Reference is also made to wetlands and lakes in Rule TT1. There are less than 3% of freshwater wetlands remaining in the region (HBRC source) so all remaining wetlands are significant. Wetlands are also an important part of the hydrological processes in the catchment. HBRC staff has recently completed an inventory of wetlands in the Tukituki catchment and this information should be useful in developing appropriates policies and rules for the Tukituki catchment. 1. All remaining freshwater wetlands in the Tukituki catchment recognised as being significant and appropriate policies and rules included which will protect them. 2.6 Outstanding Waterbodies There are a number of ecologically outstanding waterbodies in the Tukituki catchment that should be listed in the Tukituki Plan Change 6. They are very important for a wide range of indigenous bird species, many of which are classified as threatened, and a number of native fish species. The waterbodies are: Tukituki River Makaretu River Waipawa River Makaroro River Lake Hatuma 1. A list of the above outstanding waterbodies included along with appropriate policies and rules which will protect them. We welcome the opportunity to present our submission in person and attend any pre-hearing meetings. Yours sincerely John Cheyne Coordinator Te Taiao Hawkes Bay Environment Forum