Response 1031810758

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1. What is your name?

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Jeremy Dunningham

Section 2: Proposal 1 - How at-risk source water areas are delineated

1. Domestic and international evidence suggests that delineating three at-risk areas is a good approach for protecting sources of drinking water. Do you think this is a good approach for protecting our source waters?

Please select one item
Yes
No
Unsure

2. In your view, is the method to determine each SWRMA, for each type of water body, the best option?

Please select one item
Yes
No
Unsure

3. For lakes, do you agree that SWRMA 2 should include the entire lake area?

Please select one item
Yes
No
Unsure

4. SWRMA 1 for lakes and rivers is proposed to extend 5 metres into land from the river/lake edge. This contrasts with 3 metre setback requirement of the Resource Management (Stock Exclusion) Regulations 2020. SWRMA 1 is proposed to be used as a basis for controlling activities close to source water intakes, and applies to a wide range of activities. Do you think these differing setbacks will cause confusion or result in other challenges?

Please select one item
Yes
No
Unsure
Please explain your response here
Which piece of legislation will take prominence? As review of the RMA is on the table in future, opportunity should be taken then to write in the 5 metre standard

5. There is evidence suggesting that a 10–30-metre radius around source water bores is a preferable way to delineate the area where activities would be heavily restricted (SWRMA 1). However, expert advice suggests a 5-metre radius is the most workable option. Do you agree that a 5-metre radius around a source water bore gives enough protection?

Please select one item
Yes
No
Unsure
Why or why not? If not, what alternative would you suggest?
It is too close as a standard, given the varying soil types we have, with permeability range differences

6. While water takes from complex spring systems or wetlands may require a bespoke SWRMA to ensure consideration of any contamination pathways present, a default method is necessary to ensure interim protection. Do you think a default method is practicable in most situations?

Please select one item
Yes
No
Unsure
Please explain your response here
No, I don't have much faith in regional councils, often dominated by agricultural interests representatives. I prefer a nationally established default standard, which leaves no room for " interpretation ".

7. How long do you think is necessary for regional councils to delineate SWRMAs for currently registered water supplies in each region using the default method?

Please explain your response here
This will require appropriate consultation and feedback, so 12 months seems adequate

8. What challenges do you foresee in delineating SWRMAs, when previously unregistered supplies are registered with Taumata Arowai (see Proposal 3 for more details)?

Please explain your response here
As above, consultation between all parties will be necessary to avoid cross purposes

9. What support could enable regional councils to delineate SWRMAs within shorter timeframes?

Please explain your response here
Government special funding would enable regional Councils to employ suitable staff to implement and monitor

10. Do you think consideration should be given to mapping currently unregistered supplies as they register (but before the four-year deadline provided under the Water Services Act), or do you think that waiting and mapping them all at the same time is a better approach?

Please explain your response here
To maintain consistency across regions and nationally, it seems logical to process this in one time frame

11. If a regional council has already established local/regional source water protection zones through a consultative process, should there be provision to retain that existing protection zone as a bespoke method without further consultation or consideration against new national direction?

Please explain your response here
This depends on whether the locally agreed protection zones aim higher or lower than the proposed national standards. If higher, well and good but if lower, then clearly they will be inadequate

Section 2: Proposal 2 - How activities that pose risks to source water are regulated or managed

12. Do you think national direction on activities within SWRMA 1 is necessary?

Please select one item
Yes
No
Unsure

15. Do you think national direction on activities within SWRMA 2 is necessary?

Please select one item
Yes
No
Unsure
If so, what activities should it address? Please explain your response here
The proposed ban on synthetic nitrogen fertilizer aimed at SWRM1 should extend to SWRM2&3.

18. The original intent of SWRMA 2 was to manage microbial contamination. However, there are indications that protections against other contaminants may be required. What contaminants do you think should be controlled in SWRMA 2?

Please explain your response here
Nitrogen nitrate levels need to be lowered by limitations on the amount of synthetic fertilizer applied per hectare

20. Do you think any additional controls, other than broad consideration of the effects of the activity on source water, are required in SWRMA 3?

Please explain your response here
As per SWRM2, I suggest the ban on synthetic nitrogen fertilizer be applied to this catchment

23. What is your view on prohibiting below-ground bore heads?

Please explain your response here
The Havelock North debacle should ensure that below ground boreheads are prohibited

24. Regional councils are responsible for control of the use of land for the purpose of maintenance and enhancement of the quality of water in water bodies (RMA section 30(1)(c)(ii)). Do you think territorial authorities have a role in land management over aquifers, and if so, what is that role?

Please explain your response here
The role is important as such bodies have people on the ground who know the local conditions and the local users. Significantly extra funding via central government should be available to ensure that councils have the resources necessary to carry out such work. This is because councils covering areas with a smaller rating base cannot meet the costs of appropriate management

25. It is not clear which approach might be best for ensuring risk to vulnerable aquifers is appropriately managed. Do you think that an NES-DW is the right tool for addressing this? If not, what approach might be better?

Please explain your response here
NES-DW is the right tool, as it should maintain national standards

26. Would it be helpful if guidance on vulnerable aquifers was provided to support freshwater planning as the NPS-FM is given effect?

Please select one item
Yes
No
Unsure

35. A National Environmental Standard is a regulation under the Resource Management Act 1991 (RMA) that requires, among other things, that regional councils make changes to their regional plan rules. Making these changes can add costs (eg, financial, administrative) for regional councils. In your view, how might regional councils be affected by the NES-DW’s new requirements to change regional plan rules?

Do these effects outweigh the expected benefits of better source water protection?
As before, such changes will cost regional Councils, and those less well resourced will require financial assistance from central government

Section 2: Proposal 3 - Protecting all registered water supplies

39. Do you think the protections of the NES-DW should apply to all registered water supplies?

Please select one item
Yes
No
Unsure

40. The WSA has a registration timeframe of four years for currently unregistered supplies. Do you agree with aligning application of the NES-DW with the WSA? If not, why? In your view, what are the challenges resulting from including these newly registered supplies within the NES-DW framework?

Please explain your response here
I agree with aligning NES-DW and the WSA