HEALTHY RIVERS
In November 2017 a statement was released by Vaughan Payne CEO of the Waikato Regional Council, which was headed:
Clarity needed in water discussion
This discussion paper was written in relation to the proposed plan change for cleaning up the Waikato and Waipa rivers and in it he stated as quoted below.
Quote:
“Healthy Rivers/Wai Ora: Proposed Waikato Regional Plan Change 1 was notified for public submissions by council in October last year. While council notified it, the policy was developed over two-and-a-half years using a Collaborative Stakeholder Group (CSG). Effectively council handed the policy writing pen to our community and the sectors and industries most affected by the goal of improving water quality. This process required a huge amount of deliberation, consultation, collaboration and finally consensus between all parties.”
So where has it gone wrong:
The WRC has spent approximately $23,000,000 to come up with a plan to improve the water quality in both the Waikato and Waipa rivers.
What have the ratepayers got for their money?
A plan which will end up with the farming industries and rural communities disappearing from the Waikato region in large numbers, very little improvement in water quality, an inability to produce enough food to give the population security of supply, an exporting of the environmental effects from horticulture in the region, and a divided rural community with different sectors of the rural industries arguing about the proposed plan instead of uniting to achieve a marked improvement in water quality.
How was the CSG developed?
The Waikato Regional Council staff selected 24 sector representatives to be in the Collaborative Stakeholders Group and also had numerous experts involved with the formation of the TAG (Technical Advisory Group). There has been much discussion amongst many of the stakeholders that they do not feel that they have had adequate representation through the use of the CSG for all stakeholders.
The CSG by the simple nature of the processes used in the deliberation, consultation, collaboration and finally consensus between all parties on the CSG, in the development of the proposed plan change, was not representative of all stakeholders by any stretch of the imagination.
In actual fact the process was not a collaborative one at all as in the end the CSG ran out of time to reach a consensus and the WRC received a report that was finally reached by a majority vote rather than the consensus opinion that it was originally set up to produce.
The CSG was solely representative of the bodies making up the group and all of the huge numbers of other stakeholders, not being part of those groups, were in effect not represented at all in the process.
In fact there are a large number of rural stakeholders, who although they are members of those groups that made up the CSG, that do not agree with the proposed plan change in its entirety.
This fact is evidenced by the thousands of rural stakeholders that have joined together in opposition to the proposed plan change in groups such as; Primary Land Users Group, Farmers For Positive Change, King Country River Care, Sustainable Vibrant Community Awareness Group, etc.
Whilst all of the above groups have agreed that they support improving the quality of the freshwater resources, they do not support the processes in the proposed plan change. Further evidence of this dissatisfaction with the proposed processes is shown in the huge number (over one thousand) of submissions that have been received during the public consultation process.
Failure of WRC to provide timely information relating to the implementation of the Proposed Plan Change resulted in the stakeholders being unable to make an informed submission on the plan change, and this combined with the almost non-existent scientific monitoring results & lack of adequate economic analysis, made a mockery of the public consultation process.
The CSG made an interpretation of the Vision and Strategy for the Waikato River introduced under Treaty settlement legislation that is to use their terminology, “Aspirational and Visionary”.
PC 1 uses an 80-year timeframe to achieve the water quality objectives and the timeframe is intergenerational and more aspirational than the national bottom lines set out in the National Policy Statement on Fresh Water Management.
There is a big difference between the WRC’s interpretation of the Vision & Strategy under PC1 and the Government’s National Policy Statement on Freshwater with the NPS requiring 90% of all rivers to be swimmable and PC1 requiring all rivers to be swimmable to the 95th percentile.
Based on the information that was currently available, the CSG concluded, full achievement of the Vision and Strategy by 2096 is likely to be costly and difficult. The 80-year timeframe recognises the ‘innovation gap’ that means full achievement of water quality requires technologies or practices that are not yet available or economically feasible.
Effectively what the WRC is doing with the proposed plan change is gambling with the Waikato Region and consequently, New Zealand’s economy that the technologies or practices will become available and be economically feasible.
Quote:
“We took this approach to create ownership and foster behaviour change at a community, sector and industry level. Those most affected need to own both the problems and the solutions. It means we all take responsibility and we all own the solutions.”
Vaughan Payne says that the WRC took this approach to create ownership and that those most affected need to own both the problems and the solutions, but they don’t actually know what the problems are and therefore the proposed solutions are seen as financial suicide by many of the most affected stakeholders with no basis in fact for their implementation and no measureable impact on water quality.
Using the publically available figures from the WRC and NIWA it can be seen that in relation to Nitrogen there are only fifteen of the seventy four sub-catchments in the Waikato region that are exceeding the final discharge levels in the eighty year plan.
There is no mention of the urban areas in the proposed plan change and yet on Monday the 29th May 2017, Nick Smith the then Environment Minister was quoted in the New Zealand Herald saying, as follows:
“People living in cities are just as responsible for polluting New Zealand’s rivers as farmers, Environmental Minister Nick Smith says.
City-dwellers needed to “take a look in the mirror” and check their own contribution to water quality instead of criticising farmers about freshwater, he told an audience in Wellington today.
He cited the Ministry for the Environment’s reporting on freshwater, which showed that the average E.coli level in urban areas was 400 parts per 100 ml. In farmland, the average E.Coli level was 180 parts per 100ml, in forestry land it was 50 parts and in national parks it was 20 parts.
“I give those figures because it is too easy for urban New Zealanders to point the finger at rural New Zealand and say this is all your problem,” Smith said.
“My message to them is have a look in the mirror.”
If people in cities were going to demand that farmers needed to improve their environmental record, they had to “confront the fact” that old, leaky sewerage pipes or diffuse pollution from urban areas also contributed to poor water quality.”
PC1 is focused entirely on the rural landowners in relation to mitigation of the detrimental effects on the waterways.
How can this possibly be seen as creating ownership with those most affected owning both the problems and the solutions, and all taking responsibility and owning the solutions?
The requirements on rural landowners for both stock exclusion and land use restrictions are going to be enforced forthwith with no consideration that in some circumstances, current farming will become less viable and this will increase farmer’s inability to service their debt loading and end with farmers forced from the land.
Quote:
“The plan seeks to address the four contaminants causing problems for the rivers and lakes of the Waikato and Waipā catchments. Nitrogen is one of them. The others are sediment, bacteria, and phosphorus.”
39per cent of Nitrogen and 55 per cent of Phosphorus come from other sources than farming. The facts are that, yes, farming is a contributor, but it is not alone. What about these other sources?
If the decline of rural communities as predicted, and the increased growth of the main centres is correct (and this is exacerbated as expected under the enactment of PC1), then pollution from these other sources (e.g. stormwater and effluent discharge from urban areas) are only going to grow as a percentage of the total discharges
From the current council figures, we know that 7 per cent of the N and 18 per cent of the P comes from point sources and the balance (32 per cent N and 37 per cent P) is from natural sources.
PC 1 places emphasis on managing N, almost to the exclusion of all the other contaminants. This introduces the need for farm-level “Nitrogen Reference Points” (NRP) calculated using the “Overseer” nutrient management model (or any other approved model).
Overseer was developed as an expert system to inform nutrient management decisions at the farm level. As with any model attempting to describe biological processes, it’s predicted outputs are subject to errors. For example the minimum error (CV, coefficient of variation) in the predicted rate of nitrogen leaching from Overseer is about 30% but it can be much higher (>100%) if the incorrect input data is used, inadvertently or otherwise.
PC 1 proposes to set absolute discharge limits for N (Nitrogen Reference Points, NRP) for each farm. The ‘errors’ in Overseer mean that there will always be uncertainty as to whether the specific N discharge limit is met or otherwise. Litigation is a likely outcome.
PC 1 proposes to allocate N loadings at the farm level based on the predicted N leaching losses calculated by Overseer for the two seasons 2014/15 and 2015/16, taking the higher of the two estimates. This system is crude, unfair and inequitable because it rewards the least efficient N users.
Applying a one size fits all rule to nitrogen loss through the Nitrogen Reference Point (‘NRP’) is not the most appropriate approach as it fails to take into account the significant differences that apply compared to other parts of the catchment and as a result the different costs and benefits compared to elsewhere. The effect of enforcing existing NRP’s will place a ‘cap’ on rural production and development, effectively discouraging the unrealized potential of the region.
There is very little mention of other contaminants in the proposed plan change other than to try and partially address sediment levels through stock exclusion rules.
There is no mention of the effects from the pest fishes in the rivers such as Koi Carp etc.
When they feed they stir up the bottom of ponds, lakes and rivers, muddying the water and destroying native plant and fish habitat. Koi carp are opportunistic omnivores, which means they eat a wide range of food, including insects, fish eggs, juvenile fish of other species and a diverse range of plants and other organic matter.
Koi Carp produce on average fourteen times their own body weight of sediment per year through the method of feeding that they use.
It is estimated that there are approximately five hundred thousand tonnes of pest fishes in both the lower Waikato and Waipa Rivers and they will produce approximately seven million tonnes of sediment per year.
They feed like a vacuum cleaner, sucking up everything and blowing out what isn’t wanted. Aquatic plants are dislodged in the process and are unlikely to re-establish. Koi carp cause habitat loss for plants, native fish, invertebrates and waterfowl.
This feeding method contributes hugely to the erosion of the river banks and consequently the release of phosphorus into the waterways.
Many people are unaware of the damage done to our waterways by pest fish. Introduced fish have spread into the wild, become pests and are threatening New Zealand’s freshwater species and environments by:
Without addressing the pest fish issues it will be impossible to achieve the desired outcomes as set out in the proposed plan change.
No matter what impact PC1 has on the water quality in both the Waikato and Waipa Rivers, as long as the pest fishes are allowed to multiply virtually unhindered, the both rivers will rapidly become unswimable and unfishable due to the effects of the pest fishes (sediment from feeding methods and predation of all other species & the vegetation that creates their breeding grounds).
Quote:“The resulting plan takes us on just the first decade of an 80-year journey to restore and protect the health of our rivers. We are collectively required to do so under the Government’s national policy statement on freshwater, and Te Ture Whaimana o Te Awa o Waikato, the Vision and Strategy for the Waikato River introduced under Treaty settlement legislation. In short to do nothing is not an option, other regions have already implemented plan changes for water quality and our plan change has balanced the environmental, economic and social implications.”
This statement in itself implies that there is an option to do nothing being promoted, and this is just not true.
I do not know of anyone who is promoting a do nothing option.
In fact what is the main thrust of all the protest against PC1 that I have seen and read, is that the improvement in water quality is fully supported but the proposed process is wrong and will do more damage to the country than it will fix.
For this reason the proposal is to use a sub-catchment management system based on good scientific monitoring to identify the worst performing sub-catchments and then target those areas thereby giving better overall results in water quality in a shorter timeframe and with less collateral damage to the rural and national economy.
For hill country farmers this proposed plan change is not an eighty year journey as they are required to comply with all stock exclusion provisions in the first ten years and for many of them this is a financial burden that they will not be able to afford.
The current PC1 proposal is creating severe levels of stress for a large number of farmers in the Waikato Region along with financial pressures and this has the effect of creating further opportunities for instances of harm generated from the social and economic pressures being suffered by them. This is backed up by evidence of the increase in calls to the Rural Support Trust from farmers who are having difficulties in coping with the proposed changes.
Two independent reports indicated that compliance costs likely to be faced by typical low input dry-stock farms will be in the magnitude of several hundred thousand dollars. This is well beyond the means of many of these family businesses, and when combined with the forecast reduction in capital farm value due to land use restrictions and the proposed N-capping system, the proposed set of rules will be catastrophic for the entire dry-stock industry. This is causing a huge amount of stress as farmers are just now beginning to understand the magnitude of the costs they will face.
The current understanding is that achieving water quality restoration requires a considerable amount of land to be changed from land uses with moderate and high intensity of discharges to land use with lower discharges (e.g. through reforestation).
The non-complying activity status for land use intensification is excessively conservative and will have unintended consequences.
Restricting land use change on a broad scale across the Waikato and Waipa catchments is unjustified. Land use flexibility is fundamental to sustainable primary production enterprises and especially in relation to food production, where the enterprise must be able to respond to the demands of an increasing population.
In relation to horticulture the result of the proposed changes means that effectively there is no expansion of any horticultural production within the Waikato/Waipa catchments from this point (public notification of PC1, October 2016) forward. This will (due to expanding population) eventually have the end result of transferring food production (and any consequent environmental effects) to other areas outside of these catchments.
Quote:
“Urban communities and manufacturers have been working on solutions to address these contaminants and others from point sources like factories and sewage treatment facilities for at least the last four decades. These are already regulated by the existing Waikato Regional Plan. They need resource consent, and must be treated to a high standard. Urban ratepayers across the region are currently spending in excess of $60 million dollars a year to achieve this.”
This statement in itself is true but does not mention that the farming industry has been working on solutions also and the stock exclusion through fencing of 95 percent of waterways is a classic example of that work being effective.
It also fails to mention that the WRC have costed the requirements of the proposed plan change at $500 to $600 million dollars per year for the eighty year time frame of the proposed plan change implementation with most of these costs in the first instance being born by the farming industries.
People living in cities are just as responsible for polluting New Zealand’s rivers as farmers, said the then Environmental Minister Nick Smith in May 2017.
City-dwellers needed to “take a look in the mirror” and check their own contribution to water quality instead of criticising farmers about freshwater.
It is too easy for urban New Zealanders to point the finger at rural New Zealand and say this is all your problem,” Smith said.
“My message to them is have a look in the mirror.”
If people in cities were going to demand that farmers needed to improve their environmental record, they had to “confront the fact” that old, leaky sewerage pipes or diffuse pollution from urban areas also contributed to poor water quality.
In the whole of the documentation for the proposed plan change there is a severe lack of any scientific analysis to support the proposed processes and in fact analysis that has been completed since the plan change was advertised has shown that some of the contentions in the plan change are wrong in fact.
The economic analysis carried out by the Waikato University School of Business shows that the proposed plan change will create a forty percent increase in farmer’s debt loading on average and this increase in debt loading is likely to cause many of these farmers to walk off the land.
This does not need to happen. If we use much better scientific monitoring of water quality levels on a sub-catchment basis, we will be able to identify the problem areas and target resources to those areas to achieve a greater improvement in water quality overall in a much shorter timeframe.
Andy Loader
Co-Chair P.L.U.G.
(Primary Land Users Group)