This is Dr Julia Talbot-Jones's individual submission to the Ministry for the Environment
The state of freshwater in New Zealand is in decline. This is increasingly well documented in Ministry reports and other government documents. For this reason, I am generally supportive of the more comprehensive direction proposed for freshwater management in the Discussion Document. However, the current proposal is far from the significant reforms initially promised in the political discourse. Instead the updated NPS-FM and proposed NES-FW represent marginal changes to existing policies – the new NES essentially providing a stop-gap until the NPS-FM becomes operative in 2025-2030.
In saying that, I recognise the complexity associated with freshwater reform in New Zealand and applaud the Government’s commitment to improving the quality of New Zealand’s water systems. I particularly support the decision to place the health and wellbeing of the water at the centre of decision-making (Te Mana o te Wai), the moratorium on further wetland clearance, and the implementation of standards that help avoid further environmental degradation.
I also support the decision to create exceptions for five of the largest hydroelectricity schemes, but do not recommend creating exceptions for the Tongariro Power Development due to mana and mauri of both the Whanganui and Waikato river systems that feed into the Tongariro Scheme.
I strongly support the establishment of an independent water commission.
I do express some concern about the lack of economic analysis accompanying this suite of proposals. Economics can help shine a light on the relative social, cultural, environmental, and economic impacts of various policy options to ensure that what is being proposed is efficient, cost-effective, and equitable. The absence of any economic analysis suggests that some of the potential impacts of the proposed changes have not yet been considered or quantified, which could lead to unintended consequences.
The remainder of the submission will expand on this overview and indicate where both the evident strengths of the new proposal lie, as well as outlining recommendations for improvement. Both the strengths and opportunities will be examined using a water economics and policy lens.