Federated Farmers Submission on the Greater Wellington Proposed Natural Resources Plan
Key areas of support: Federated Farmers strongly support the ongoing commitment to non-regulatory partnerships supported by funding recently approved in the Longterm Plan. We agree that priorities for partnership investments should include:
- Coordination and land management advisory services in priority catchments
- Restoration of sites highly valued for biodiversity and other values, including investment in riparian management and wetlands
- Provision of Land Management advisory services to enable beneficial activities, eg, river crossings; develop agreed practice for contentious areas, eg, drain cleaning; and to extend one-on-one advisory services to willing landowners outside priority catchments.
Key areas of concern: We register our very strong concern that the quality of cost-benefit analysis in the section 32 (s32) reports is manifestly inadequate across critical areas of the pNRP. We strongly recommend a s32 report for Primary Production is prepared prior to the hearing to inform proper consideration by the Hearing Panel.
We register our very strong concern that the pNRP seeks to pre-empt the whaitua in two critical areas:
- Water quality: proposing numeric objectives for improvement un-informed by NPS requirements for iterative analysis of options and achievability; and narrative objectives aspiring to “reference state”, with the “interpretation” of these objectives relying on documents outside the pNRP
- Water quantity: proposing that currently operative allocations be substituted with “default” formula for environmental and recreational values, again un-supported by any analysis of options or implications.
GWRC proposed Natural Resources Plan – further submission 2016
Supporting or opposing submissions from other parties, eg:
Opposing a submission that all water bodies be swimmable by 2030. The pNRP appropriately signals priorities for whaitua attention - principally the sandy beaches and stony-bottom rivers with public access which are the known popular swimming areas – and which may be extended to other waterbodies prioritised for swimming within the whaitua. Timeframes should be set by whaitua, informed by whaitua priorities and supported by whaitua-specific understanding of key issues impacting on swimmability (eg, flood flows, willows, access); the practicalities and costs of achievement; and any balancing of values needed (eg, ducks upstream of swimming holes).