Submission on Tukituki Catchment Proposal
1. Submitter Details
Name of organisation: Te Taiao Hawkes Bay Environment Forum
Contact: John Cheyne
Home Ph: 06 8589506
Mobile: 027 2059506
Physical address: 309 Racecourse Road, Waipukurau
Email: johncheyne@xtra.co.nz
2. Are you a trade competitor
Proposed Change 6
We are not a person who could gain an advantage in trade competition through this submission
Ruataniwha Water Storage Scheme
We are not a trade competitor of the applicants
3. How would you like to receive correspondence
By email please
4. Proposed Matters
NSP 13/02.001 Proposed Tukituki Plan Change 6
NSP 13/02.002 – NSP 13/02.019 Makaroro Dam Structure and associated intake facilities, water
distribution network, outfall structures, associated works, beach nourishment, CHBDC requirement
and resource consent, HDC resource consent
5.1 Comment on Proposed Plan Change 6
I oppose the proposal
Brief reason
The proposed plan change does not give effect to the Resource Management Act, National Policy
Statement for Freshwater Management 2011 and Hawkes Bay Regional Policy Statement in terms of
water quality and quantity issues, integrated and sustainable land management, protection of
biodiversity in the Tukituki River catchment.
Te Taiao Hawkes Bay Environment Forum made a submission on the Proposed Plan Change 6 to the
Hawkes Bay Regional Council on 30 May 2013. I wish that submission (Appendix 1) to be a
submission to the EPA for the Tukituki Catchment Proposal.
Further submissions on Plan Change 6 are made in Section 6 below.
5.2 Comment on the Ruataniwha Water Storage Scheme
I oppose the proposal
Brief Reason
The Ruataniwha Water Storage Scheme will impact adversely on the terrestrial and aquatic ecology,
environments, recreation, cultural, landscape, natural character and social values. There are also
inadequacies in the proposed mitigation and offset measures and alternatives assessment of other
dam sites together with combining water storage and land use changes. The economic benefits are
overstated and there is significant potential impact financially on the regions ratepayers.
5.3 Comments on specific parts of the Tukituki Catchment Proposal
Refer section 5.1 and 5.2 above
6. Proposal decision sought
Proposed Plan Change 6 - Approve with changes
Brief reason
In addition to the submission already filed with HBRC (Appendix 1), we seek the following changes:
6.1 Minimum water flows are increased and flat lining avoided
6.2 Land use intensification should require a resource consent, with criteria based on land use
capability and sustainable land management
6.3 Farm nutrient plans should be mandatory
6.4 The policies and objectives should include soil management as a means of achieving
sustainability
6.5 The methodology for monitoring water quality needs to focus on the 24 hour cycle
6.6 The objectives, policies and rules around water allocation need to focus sustainable land use and
efficiency of end use
6.7 The Rules in relation to riverbed management (root raking, gravel extraction) needs to be
amended to prevent adverse effects
6.8 The Plan needs to include Objectives, Policies and Rules to manage the downstream effects of
water quality on the estuarine and marine environment
6.9 Community values within the catchment need to be identified more accurately on maps at
sufficient scale so they can be readily interpreted and understood
6.10 The Implementation Plan attached to the requires amendment to reflect the changes above
Ruataniwha Water Storage Scheme – Decline
Brief reason
The Ruataniwha Water Storage Scheme will impact adversely on the terrestrial and aquatic ecology,
environments, recreation, cultural, landscape, natural character and social values. There are also
inadequacies in the proposed mitigation and offset measures and alternatives assessment of other
dam sites together with combining water storage and land use changes. The economic benefits are
overstated and there is significant potential impact financially on the regions ratepayers.
7. Do you wish to speak at the hearing
We wish to speak
8. Do you intend to provide expert evidence
Yes we will have expert witnesses
Name of witnesses – To be confirmed
9. Authority to act
J W Cheyne
Coordinator
Te Taiao Hawkes Bay Environment Forum
1 August 2013
Appendix 1
Te Taiao Hawkes Bay Environment Forum Submission to HBRC on Tukituki Plan Change
From:
Te Taiao Hawkes Bay Environment Forum
PO Box 305
Waipukurau 4242
30 May 2013
Contact person: John Cheyne (johncheyne@xtra.co.nz)
To:
Chief Executive
Hawkes Bay Regional Council
Private Bag 6006
Napier 4142
Submission on Tukituki Plan Change 6
1. Introduction
We thank the HBRC for the opportunity to comment on the draft Plan Change 6 and also to present
our submission in person to any hearing convened.
Te Taiao Hawkes Bay Environment Forum is an umbrella group formed by a number of
conservation/environmental groups in Hawkes Bay who care for our region and who wished to
achieve better environmental outcomes by improved coordination and sharing of information.
The group includes the three branches of Forest and Bird (Napier, Hastings-Havelock, Central
Hawkes Bay) Sustainable Hawkes Bay Trust, Bay Watch, Guardians Hawkes Bay Fisheries, Te Roopu
Kaitiaki O Te Wai Maori, Friends of the Tukituki River.
The principles that guide the group include:



Strong sustainability
Interconnectedness of our key environmental issues
Dependence of social, cultural and economic well being on environmental well being
The group has identified the following keystone environmental issues for Hawkes Bay

Decline in quality of freshwater




Increasing demand for freshwater resulting in low summer flows in rivers and streams
Unsustainable land use
Declining indigenous biodiversity
Insufficient recognition of cultural values
2. Comments on Plan Change
2.1 Positive Aspects
There are a number of positive aspects to the proposed plan change and these include the provision
for greater protection of waterways by fencing and riparian planting, provision for nutrient
management plans, increase in minimum flows in the major rivers.
2.2 Values
Te Taiao Hawkes Bay Environment Forum members have a strong interest in the entire Tukituki
Catchment from its source to the sea and are committed to the land and water resources being
managed sustainably. Some live close to the Tukituki and Waipawa Rivers and many use these
waterways regularly.
We value these waterways and their tributaries for the following reasons:

Cultural and spiritual values – they provide a life force which helps meet the individual and
collective needs for both Maori and non Maori. The Mauri of these areas is important.

Life supporting capacity – this value occurs throughout the waterways and helps provide
important sites for plants, invertebrates, fish and birdlife

Food gathering – significant fishing (whitebait, smelt, tuna/eel, patiki/flounder, kahawai,
trout) and harvesting of watercress takes place from the mouth of the Tukituki River
upstream to the Ruahine Ranges

Recreation – a wide range of different activities (swimming, tubing, kayaking, picnicking,
fishing, bird watching. walking and exercising pet dogs) takes place primarily on the major
waterways (Tukituki and Waipawa Rivers). Significant stretches of these rivers are very
accessible to the public because the HBRC has developed and maintained a very good
network of public access points from the mouth upstream to SH 50. Waipawa and
Waipukurau townships straddle these rivers which enables the residents to readily walk to
the rivers.
The above community values are very much dependent on good water quality and adequate
summer flows. The rivers need to be managed for these values but unfortunately the plan does not
adequately give effect to these values. This may partly arise by the values setting exercises
completed by HBRC staff and other specialists being too coarse and broad brush to be effective.
Recommendation:
1. The community values which should under pin the Tukituki catchment plan change should
be reviewed and completed in more detail.
2.3 Water Management Zones
The planning maps (Schedules XV, XVI, XVII) accompanying the Plan Change are too coarse and
broad and therefore unclear and difficult to follow. The water management zone map identifies five
zones. The boundaries of some of these zones appear to not follow catchment boundaries or
reaches of rivers. In particular the boundary between Zone 2 Ruataniwha North and Zone 3
Ruataniwha South appears to follow the Waipawa River. Management of water resources should
follow catchment and sub catchment boundaries and be sub divided into river reaches if need be.
The zone boundaries should also reflect the community values related to river stretches around
which the plan change should be framed.
Recommendation:
1
Catchment, sub catchment and river reach boundaries be used to establish zone boundaries
based around community values
2.4 Surface water quality limits and targets
The community values for the stretches of rivers should also under pin the water quality standards.
It should also be noted that community concerns about slime and algae in the rivers is not confined
to the Lower Tukituki Corridor (downstream of Tukituki and Waipawa confluence) as stated in a
number of HBRC reports but extends well upstream above SH 2 for both the Tukituki and Waipawa
Rivers.
Management opportunities for point and non-point source discharges should be managed through
regulations for water quality and quantity limits. Limits where appropriate, should be applied as
standards in the rules. In particular per hectare nitrogen should be applied to ensure land uses are
managed to achieve the instream DIN concentration which is set in order to control undesirable
periphyton blooms, cyanobacteria blooms and maintain macro-invertebrate health.
Some of the proposed limits and targets in Table 5.9.1B are inadequate. For example some of the
figures (limits and targets) proposed in the plan change for nitrate-nitrogen in the Tukituki and
Waipawa Rivers are 250 - 900% higher than current levels and appear to be set for toxicity to fish
and not limiting algae or safeguarding life supporting systems. Reducing phosphorus levels has
been identified in the plan change as a key to reducing algae and slime and appropriate standards
should also be set to achieve this. A standard maximum level of dissolved reactive phosphorus
(DRP) of 0.10 would better achieve the improvements sought in the plan change.
It should also be noted that algae problems are not just confined to the lower Tukituki but also occur
in the reaches of the Waipawa and Tukutuki between SH 50 and SH 2. In addition if the RWS dam
proceeds there is no ability to provide flushing flows in the Tukituki River upstream of the
confluence with the Waipawa River.
Water clarity indicators are too low and should be 5-10metres on the black disc measure. Macroinvertebrate community (MCI) levels should also be a minimum of 120.
There are also additional standards that should be included to provide a more comprehensive basis
for monitoring water quality. Current % figure for alert levels for Cyanobacteria is being reviewed
nationally and opinion is moving towards reducing the % from 60 to 50%.
Sediment cover should be set for all water bodies. N/a is not acceptable
Standards should be set based on river, reach or site specific community values and these standards
should be considered environmental bottom lines and should not be breached at flows below flood
flows.
Water quality limits should not allow degradation of water from its current state and must be
consistent with the purpose and principles of the RMA and NPS Freshwater.
Recommendations:
1. Table 5.9.1B be based on new zones adopted on a catchment, sub catchment and river
reaches basis.
2. Limits for water quality should be applied as standards in rules.
3.
A lower limit is adopted for nitrate nitrogen (SIN) in Table 5.9.1B
Zone 1, 2, 3 and 5 - 0.444mg/litre
Zone 4 - 0.070mg/litre
4. Additional water quality standards for pH, temperature, dissolved oxygen and E coli be
included in Table 5.9.1 B
5. The maximum cover (%) for Cyanobacteria in Table 5.9.1B reduced from 60% to 50% to
reflect current scientific opinion.
6. Sediment cover be set for all water bodies with <5% for trout spawning and pristine sites
and 10% for lower catchment sites
7. Water clarity be set at 5-10 metres
8. MCI be set at 120 minimum for all zones
2.5 Wetlands
Wetlands are important for a wide range of reasons including biodiversity, cultural and ecosystem
services. It is unclear how significant freshwater wetlands will be identified and how wetlands in
the Tukituki catchment relate to the Regional Policy Statement Change 5.
POL TT11 in this plan change says “… to generally manage the effects of groundwater takes on
surface water bodies, including wetlands.” How can this be achieved if we don’t know what
wetlands we have in the catchment and how significant they are? Reference is also made to
wetlands and lakes in Rule TT1.
There are less than 3% of freshwater wetlands remaining in the region (HBRC source) so all
remaining wetlands are significant. Wetlands are also an important part of the hydrological
processes in the catchment. HBRC staff has recently completed an inventory of wetlands in the
Tukituki catchment and this information should be useful in developing appropriates policies and
rules for the Tukituki catchment.
Recommendation:
1. All remaining freshwater wetlands in the Tukituki catchment recognised as being significant
and appropriate policies and rules included which will protect them.
2.6 Outstanding Waterbodies
There are a number of ecologically outstanding waterbodies in the Tukituki catchment that should
be listed in the Tukituki Plan Change 6. They are very important for a wide range of indigenous bird
species, many of which are classified as threatened, and a number of native fish species.
The waterbodies are:





Tukituki River
Makaretu River
Waipawa River
Makaroro River
Lake Hatuma
Recommendation:
1. A list of the above outstanding waterbodies included along with appropriate policies and
rules which will protect them.
We welcome the opportunity to present our submission in person and attend any pre-hearing
meetings.
Yours sincerely
John Cheyne
Coordinator
Te Taiao Hawkes Bay Environment Forum