Taranaki Regional Council has raised major concerns over the Government’s ‘Essential Freshwater’ package of policy proposals and regulation changes.
“We all want our waterways to be healthier,” says the Council Chair, David MacLeod. “However, we believe that as they stand, the Government’s proposals will bring significant costs and disruptions to the Taranaki community, for very little gain.
Key concerns outlined in the Council’s submission on the proposals include:
- One size does not fit all. Taranaki is unique in its geography and in the progress it’s made in maintaining and improving freshwater quality. Much of the new package would have unpredictable and likely only marginal environmental benefits, but would bring substantial adverse outcomes for community wellbeing.
- The focus should be on improving trends rather than setting limits. This would allow for natural differences regionally and nationally while halting the decline of water degradation. Regulation should only be used where there is a proven cause and effect and demonstrable benefit where it is applied.
- For Taranaki, there is no cost-benefit justification for the policy and regulation changes proposed by the Government
Mr MacLeod says the Taranaki community has collectively demonstrated strong commitment to improving freshwater health, taking carefully considered long-term action and spending millions of dollars on measures that have proven to be effective.
“Good environmental results are increasingly evident, and have been confirmed in independent assessments, he says. “These efforts and good waterway health trends will be continued through measures already signalled to and agreed by regional stakeholders in preparations for the next Regional Land and Water Plan.”
He says the Government’s package includes comprehensive and complex proposals that raise many issues, notably:
- Proposed nutrient limits are underpinned by questionable science. The scientific evidence suggests the ecological health of waterways is driven by a range of factors including nutrient levels, flow characteristics and physical habitat. These factors interact differently catchment by catchment, so national limits make little sense. The Government’s proposed limits would substantially restrict farm output for no clear benefit. This would threaten community wellbeing for uncertain and at best marginal environmental gains.
- The OVERSEER farm-management tool would be given a role it’s not suitable for. The Council shares the view of many experts and authorities, including the Parliamentary Commissioner for the Environment, that it is unfit for use as a regulatory tool, is highly inaccurate, remains unproven in many landscapes, and cannot reflect actual environmental impacts.
- National ‘one size fits all’ stock-exclusion rules would override Taranaki’s proven, successful, and much more comprehensive Riparian Management Programme, adding substantial cost for no obvious benefits.
- Farm and community viability and wellbeing would be at risk. The Government has not provided appropriate cost-benefit analyses. But the Council has found a very adverse impact on the viability of many farms is likely because of imposed reductions in fertiliser use and soil fertility, and thus stock numbers, even with a compliance timeframe of ‘a generation’ and social well-being of the wider community, urban as well as rural.
- The package as it stands would impose major costs for questionable gain. A Council-commissioned study indicates achieving the proposed Dissolved Inorganic Nitrogen limits alone would cost $100,000 a year for 33% of farms and $50,000 a year for 70% of farms. But Taranaki’s mountain-fed rivers are in the ‘A’ and ‘B’ bands for ecological health according to the Government’s own measures. Their ecological health has, with only rare exception, been stable or improving over the past decade or more. In terms of swimmability, our rivers are mostly in good or excellent health at the places and times most people swim.
“The evidence is clear to the Council: the proposed national interventions are neither credible nor necessary for this region,” says Mr MacLeod.