Response 754374959

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5. If on behalf of an organisation, what is its name?

Name of organisation
Water Information Network Incorporated

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
Please explain your response here
Our members do not agree that SWRMA 2 is of sufficient scope to ameliorate the nitrate contamination of aquifers used for potable water supply.

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
Please explain your response here
With the proviso given above. Our members believe that a more exhaustive approach is required where nitrate contamination of WSA bores is demonstrated. For example the Richmond (Tasman) town bore-field is contaminated with nitrates to 10 - 12 mg / L nitrate-N, a phenomenon that Tasman District Council has for many years stated as being chiefly due to faeces from a pig-farm that closed down over 30 years ago and that was 5 km from the town bores as the crow flies! This is despite the fact that our Society has proven categorically to TDC that the water from the town bores contains no porcine dna!

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
A 5 metre setback is no more confusing than a 3 metre setback...

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

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
Our view is that the presence of contamination exceeding 10% of the maximum allowable under the Drinking Water Standards for that contaminant should trigger a bespoke SWRMA

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
Not sure - 5 years maybe

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
We don't see any insurmountable challenges. The long-term benefits outweigh the short-term challenges.

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

Please explain your response here
No opinion

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
They should be mapped as they register.

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
There should be further consideration. This is a matter of public health!

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
Please explain your response here
Our particular concern is groundwater sources, and managing a 5 m radius around each bore should present no difficulty.

13. For water suppliers, are there any other activities beyond intake maintenance/management that should be provided for?

Please explain your response here
No opinion

14. In and around freshwater, control of pest species (including aquatic pest species) may be necessary, including through physical control (removal, that may include bed disturbance) or chemical control (discharge).

Please explain your response here
No opinion - our concern is abstraction of groundwater

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
Contamination by nitrates, herbicides and pesticides.

16. In your view, how much will this proposal impact the current situation in your region?

Please explain your response here
There should be a sunset-clause on market-gardening and intensive pastoral farming within the SWRMA 2

17. Are there any other activities that should not be permitted within SWRMA 2?

Please explain your response here
Possibly controls on on-site sewage treatment within the SWRMA 2

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
See 15 above.

19. What other challenges do you see when making a consent application within SWRMA 2?

Please explain your response here
No opinion. Our concern is with water consumers not polluters,

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
No, but to reiterate, we feel that the definition of the SWRMA 2 is too restrictive in the case of aquifers.

21. What is your view on how to address issues with bores – should it be enough to amend the NZS 4411:2001 (with reference to that standard in the NES-DW), or should greater direction be given in the NES-DW itself?

Please explain your response here
We prefer amendment of the NZS. Then everybody can sing from the same songbook.

22. For existing bores: What is your view on requiring unused bores to be decommissioned?

Please explain your response here
Yes to the first question.... 5 years ?
No opinion on the 3rd question... we don't profess to have any expertise regarding the maintenance of bores.

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

Please explain your response here
If they have been shown to be a hazard then they should be banned.

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
No opinion really... We guess that the issue is that an aquifer can be affected by activities within more than one regional council (?). If that is the issue, then yes.

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
Yes

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

27. What activities do you believe the NES-DW should retrospectively apply to / not apply to, and why?

Please explain your response here
The use of fertiliser on arable land overlying vulnerable aquifers.

28. In your view, what are the key challenges and benefits to retrospective application?

Please explain your response here
A key challenge will be policing the rules and requirements.
The key benefits will be an improvement in public health.

29. Do you agree with the proposed list of criteria?

Please select one item
Yes
No
Unsure

30. What types of activity might pose a significant risk to a water supply in an accident, emergency, or other natural event?

Please explain your response here
No opinion

31. Do you think it is reasonable to require all activities with some potential to affect source water to undertake response planning, or just those with a higher risk (likelihood and consequence)?

Please explain your response here
Yes

32. Do you agree that resource users should engage with water suppliers in consenting matters, within SWRMA 1 and 2?

Please select one item
Yes
No
Unsure
Please explain your response here
Because the pollution of public water supplies is a matter of public health.

33. What hurdles do you see in promoting this engagement with water suppliers?

Please explain your response here
Inertia and obfuscation in order to justify the status quo.

34. What support might small water suppliers need to effectively engage in the consent process?

Please explain your response here
No opinion

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?
No opinion regarding regional councils, but our understanding is that regional plan rules are required under the RMA to be reviewed every 10 years. (?)
No, the effects of better source protection far outweigh the effects on regional councils.

The discussion document does not quantify the public health benefits of a reduction in nitrate contamination of potable water. These benefits were set out by the NZ College of Public Health Medicine in its submission to MfE on Action on Healthy Waterways.

36. In your view, how could the amendments to the NES-DW better align with farm plans?

Please explain your response here
The Stock Exclusion Regulations have very little effect on the aquifers underlying the Waimea Plain. Most of the pollution is caused by market gardening. Refer Fenemor

37. If you are a water supplier, do you think these amendments will affect your ability to supply water (positively or negatively)? Would they influence whether you continue to provide water?

Please explain your response here
N/a

38. If you are a resource user, do you think these amendments will affect how you currently use your land or undertake activities? Will you have to change how you do things as a result?

Please explain your response here
N/a

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
Four years sounds reasonable - otherwise no opinion

Provide further feedback

41. Do you have any other comments you wish to make?

Add your comments, ideas, and feedback here.
Addressing the nitrate contamination of groundwater is now urgent.