The purpose of this report is to provide an evaluation of the proposed National Policy Statement for Freshwater Management in accordance with section 32 of the RMA. This NPS has the potential to affect every district and regional plan, and ultimately a number of stakeholders and water users. The NPS provides high-level direction on what the Government and the Minister want to achieve with respect to freshwater outcomes. A key test is whether, on balance, the NPS will deliver a range of benefits to all New Zealanders that outweigh the costs associated with a 'tougher' policy framework.
The NPS identifies three significant resource management issues:
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increasing demands on freshwater resources
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reduced or declining water quality
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uncertainties over the impacts of climate change on freshwater systems.
In terms of addressing these issues, the first key conclusion is that the existing framework of district and regional plans and regional policy statements is not delivering the desired environmental results. This status quo framework may improve over time, and some regions will continue to be ahead of others in terms of their policy framework and approach to implementation. However, even with an evolution in regional and district plans, there remains a significant risk to the sustainable management of freshwater resources, and therefore further national direction is needed to address the issues identified above.
The NPS includes nine objectives and nine policies to address the resource management issues. A review of the objectives concludes that the nine objectives proposed are the most appropriate way to achieve the purpose of the Act. Furthermore, the objectives help the Government achieve the outcomes set out in the Sustainable Water Programme of Action. This is not to say that further refinement of the objectives is not possible through the public Board of Inquiry process, but for the purpose of notification of the NPS, the intent of the objectives is clear, and they will provide national guidance for decision-makers and those councils preparing regional and district plans. In this sense, the section 32 review process is not yet complete, but this report marks the completion of the process to date.
The high-level nature of the NPS makes quantification of costs and benefits in real dollar terms unfeasible. This report has identified a range of costs and benefits, which are summarised in the following table relative to the social, economic and environmental and cultural outcomes.
Table 17: Overall summary of costs and benefits
| Environmental costs | Environmental benefits |
|---|---|
| Diversion from other regional priorities (opportunity cost of not pursuing something else) | Less environmental damage Healthier in-stream ecology Less risk in setting environmental flows, as these can be reviewed regularly Greater water efficiency, and more water available for environmental flows Delayed need for the construction of major water projects due to more efficient use Ecological values protected |
| Social costs | Social benefits |
| Increased cost of urban development (leading to affordability issues) Loss of employment where access to water is reduced Loss of regional discretion to have a lower standard | New Zealand’s clean green image is maintained Recreational opportunities are maintained or improved Greater direction to communities All rivers in New Zealand are swimmable The community is engaged More employment in the recreation and tourism sectors Certainty to the community, particularly in terms of protection for freshwater values Greater awareness of water as a finite resource |
| Cultural costs | Cultural benefits |
| Loss of rangatiratanga (Māori feel lack of control) Requires people to change existing cultural practices Possible lack of emphasis on fishable water quality for customary fisheries | Enhancement of kaitiakitanga − protecting the environment Maintain ability for cultural and customary uses of water and of customary fisheries Cultural values recognised Recognition of a wider range of the cultural importance all New Zealanders place on fresh water |
| Economic costs | Economic benefits |
| Increased regulatory costs to local and central government Additional long-term planning costs to councils Increased compliance costs to all consent holders Direct economic costs imposed on production Reduced flexibility in land management Increased production costs in some locations Restricted land-use opportunity for development Loss of ability to trade off different uses of land and water Increased costs of monitoring and review Loss of potential investment in land development Imposed costs to council to consult with the community Impact on existing land uses in terms of longer-term certainty More costs to permit holders and regulators Potential for greater water charges for consumers (internalising externalities) Cost to regulators to have environmental flows in place Could involve stricter environmental flows in places where the focus has been on ecological flows only | New Zealand has a more marketable product on the world stage Increased tourism Reduced cost of water treatment Reduced environmental remediation costs Improved aquaculture and marine quality Opportunity for advancement of technological mitigation technologies Reduced regulatory costs for setting water quality standards More efficient planning for infrastructure Increased certainty of costs Ease of consenting projects that are aligned with the regional policy statements Stopping projects that are inconsistent with regional policy statements Greater resilience to climate change Improved certainty for economic users, because the NPS clearly specifies the available allocation Enables resource consent applications to be processed in a straightforward manner (provides clear guidance to the resource consent decision-making process) |
Overall, the evaluation concludes that the NPS will provide, on balance, significant benefits to New Zealand’s freshwater resources, and by implication, to New Zealanders. Some stakeholders will undoubtedly carry a greater proportion of the costs associated with the NPS than others. These stakeholders will initially be regional and district councils. These costs are identified in this NPS, and in the context of the overall benefits are considered to be acceptable.
Other stakeholders disadvantaged are those who are contributing to the problems associated with degraded water quality and over-allocation. While each case will be taken on its merits, the principles of internalising costs, or in some instances 'polluter pays', is a well accepted part of resource management in New Zealand.
The key issue will be the timeframe over which these costs are attributed or incurred. The NPS does identify timeframes for specific planning activity (which apply to district and regional councils, monitoring, and ultimately to achieving water quality objectives by 2035. While many New Zealanders would perhaps prefer to see this target date brought forward, a 25-plus year programme to improve water quality, allocation and flows appears to be pragmatic and practical. The NPS of course does not discount the possibility that some communities will want to take more action sooner.
Given the evaluation presented in this report, it is concluded that the NPS meets the tests of section 32 of the Act, and, furthermore, will promote the sustainable management of natural and physical resources.
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6. Conclusions
July 2008
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