Federated Farmers submission for proposed WCO for Te Waikoropupu Springs and associated water bodies
Federated Farmers is concerned that the WCO is in part an effort to circumvent a proposed plan change by Tasman District Council. A plan change is currently in the pipeline for the very catchment that the WCO is proposed, meaning that the majority of the applicants issues can be addressed in that process, with the added benefit of more robust consultation.
The applicants want all associated waterbodies to be included, yet have not sufficiently demonstrated that the identified values are of an outstanding level that warrant protection via
a WCO. To be considered outstanding, a value must have nationwide significance, yet the values such as recreational and habitat are not out of the ordinary on a national basis.
The application does not adequately consider the needs of the primary and secondary industries and the community under Section 207 of the Resource Management Act (RMA).
The WCO as sought will impose both unnecessary and unreasonable constraints to realising the area’s social, economic and environmental objectives. This leads to the conclusion that the WCO needs to be amended, because the application does not meet the purpose of s199 nor does it satisfy s207 of the RMA.
Executive Summary
- Federated Farmers opposes the extent of the WCO and seeks that it be amended.
- The applicants have not demonstrated that all the waterways contain nationally outstanding amenity and intrinsic values which warrant protection by way of a WCO.
- The WCO application undermines an existing plan change process for the Takaka catchment, which aims to address the complex water quality and quantity issues involving all sectors of the community including the applicants.
- 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 livelihood and economic use.
- The applicants scientific evidence is less than adequate.