Submissions

Federated Farmers Participation in the Ngaruroro and Clive Rivers Water Conservation Order in the Hawkes Bay Region

Federated Farmers opposes the Water Conservation Orders because we are tasked by our members to ensure that the interests of those people and communities who rely on the Region's water resources are adequately recognised and provided for.  

There are about 850 farms within the Ngaruroro and Clive River catchment.Federated Farmers are concerned that the water conservation order is a redundant process that has been superseded by the National Policy Statement for Freshwater Management, and that plan changes are a superior method for managing a region’s water resources. A plan change is currently in the pipeline for the very catchment that the Water Conservation Order is proposed, meaning that all the applicant’s issues can be addressed in that process, with the added benefit of more robust consultation.   

The applications (re-notified in July/August 2018), do not adequately consider the needs of the community and we believe, the WCO as sought, will impose both unnecessary and unreasonable constraints to the district’s social, economic and environmental objectives.

This leads to the conclusion that the Water Conservation Order needs to be declined, because the application does not meet the purpose of s.199, nor does it satisfy s.207, of the Resource Management Act 1991. 

Federated Farmers have lodged expert evidence opposing the Water Conservation Order Application for the Ngaruroro and Clive Rivers. Copies of our evidence are available for download from the links on this page.

 

The Special Tribunal that has been appointed by the EPA to hear the submissions and evidence, will convene in Napier toward the end of February 2019. Federated Farmers are in the process of confirming our hearing time and date with the EPA. Federated Farmers members who wish to attend the hearing as members of the public in support of our submission should contact Peter Matich pmatich@fedfarm.org.nz  0800 327 646 for further details.


Summary of our submission points:

• Federated Farmers oppose the application for the Water Conservation Order (‘WCO’) and seek that the application be declined. 
• WCOs are an outmoded instrument that have been superseded by the National Policy Statement for Freshwater Management (NPS-FM).
• The values and characteristics that are able to be considered by a WCO are limited by RMA s.199, whereas a plan change under the NPS-FM is able to consider a wider range of values more reflective of the community. 
• The applicant has not demonstrated that the subject waterways contain outstanding (at a national level), amenity and intrinsic values which warrant protection by way of a WCO.
• The WCO application undermines an existing collaborative process for the same catchment, which aims to address the complex water quality and quantity issues, involving all sectors of the community including  the applicants.
• A plan change for the subject catchment is currently in development, which will address all the factors that the WCO application intends, with the added benefit of being a more robust process. 
• The consultation process has been insufficient.
• The application fails to adequately consider the needs of primary and secondary industries and the community.
• The application fails to sufficiently recognise and provide for the taking and use of water for domestic and animal drinking supply, and for food, beverage and fibre production. 
• It will have the undesirable effect of prejudicing the values-setting process in the TANK plan change.

 

For more information, see the full submissions on this page.