FEEDBACK
TELEPHONE 0800 327 646 I WEBSITE WWW.FEDFARM.ORG.NZ
___________________________________________________________________________
To:
Tasman District Council
Submission on:
Feedback on Gravel Management Issues in Tasman District
From:
Nelson and Golden Province of Federated Farmers of New Zealand
Date:
18 January 2013
Contact:
Michael Bennett
Policy Advisor
Federated Farmers of New Zealand
PO Box 1992
Christchurch
P: 03 357 9452
M: 027 551 1629
E: mbennett@fedfarm.org.nz
FEEDBACK ON GRAVEL MANAGEMENT ISSUES IN TASMAN DISTRICT
1. Introduction
1.1. Federated Farmers welcomes the opportunity to provide feedback on gravel
management issues in Tasman District.
1.2. Federated Farmers are particularly interested in gravel management because of the
manner in which excessive accumulation of gravel can contribute to flooding
hazards, loss of land, damage to infrastructure, and threats to the safety of people
and livestock during floods. Most farmers are affected by these issues to some
extent or other and it is imperative that Councils utilise the tools available to them in
an efficient, timely, and effective manner to manage gravel to reduce flooding risk.
1.3. Communication has greatly improved over the past year and Federated Farmers
members are grateful for the efforts made to achieve this – which includes this
survey. Communication will not solve the problem, but it is essential to managing
internal Council processes and keeping community stress and distress to acceptable
levels when dealing with issues that impinge on the livelihood and safety of people
and communities.
2. Problem Definition
2.1. Does the paper provide a fair description of the problem?
2.2. If not, what are the problems or the issues as you see them?
2.3. Federated Farmers does not see that the paper provides a full description of the
problem because there is too much of a focus on gravel extraction and not enough
on managing gravel to mitigate flood risk. Gravel extraction is but one part of the
problem. The wider issue relates to bank erosion and sedimentation, loss of land,
and threats to infrastructure and safety of people and the role of extraction,
relocation of gravel, facilitating movement of gravel, or other actions by the Council
or others in reducing risks
3. The Approach
3.1. Is the approach that is planned to address the issues a reasonable one?
3.2. What do you suggest could be changed about the approach?
3.3. What is the result that you seek?
3.4. The approach that is being planned needs to provide for activities in the beds of
rivers to reduce flood hazard risk as a first priority. There must be minimal regulatory
barriers to machinery movement, relocation or deposition and other activities,
including in the wetted part of the bed, as part of regular maintenance, to facilitate
movement of gravel to where it is needed and to mitigate problems with bank erosion
or threats to infrastructure after floods. Gravel extraction is a secondary issue that
sits under this primary purpose.
4. Principles
4.1. Are these principles ones that you agree with?
4.2. If not, what do you think should be deleted, added or changed?
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4.3. Federated Farmers are not satisfied with the Principles because they are not clear.
The sentence River managers recognise the interplay between both water flows and
gravel movement in river systems does not directly specify the roles and
responsibilities of river managers. Clear statements of roles and responsibilities are
essential because river managers are faced with a complex decision making
environment (both in a social and regulatory sense). Unclear roles and
responsibilities can put staff in an untenable position and are likely to result in a
reversion to paralysis and poor communication in the future.
4.4. Suggested roles and responsibilities, to include in the ‘principles’ section are:
 Communicate effectively and in a fair and principled manner with people and
communities potentially affected by flood hazards, as well as with other
internal and external parties;
 Safeguard the property and personal safety of persons potentially affected by
flood events or deposition or erosion within rivers, including acting proactively
to prevent bank erosion, bed degradation, and minimising flood hazards;
 Exercise best judgement to manage apparent problems based on the
information available while having due consideration to downstream land
occupiers.
Roles and responsibilities of river managers require careful consideration as they
will underpin the long term success or failure of the proposed policy changes.
4.5 Federated Farmers is mostly satisfied with the list of ‘typical interventions’, but does
not see that it is realistic to ‘avoid’ bed degradation – this is an impossibility. A better
goal would be ‘act to prevent bed degradation’.
5. Policy and Regulation
5.1. Is there anything about the policy framework in the TRMP that you would want
Council to rethink and if so, what is it?
5.2. The global consent (and the policy framework that supports it) should enable the
river managers to efficiently and effectively undertake river works to achieve their
roles and responsibilities, as outlined in the list of ‘typical interventions’:
 Keep gravel mobile;
 Allow high flows to spread across full active channel early in flood events;
 ‘Even out’ the bed profile;
 Increase the flood capacity;
 Minimise lateral erosion with hard structures or live plating;
 Relocate gravel from upstream to mimic nature;
 Avoid (Act to prevent) bed degradation;
 Minimise cost.
6. Consents
6.1. What can the Council do to improve the process for applying for and obtaining
resource consents for gravel relocation or removal?
6.2. Any changes to the global consent or the policy framework that supports it must be
carefully developed with common sense and balance key objectives. Ideally the
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needs and concerns of all interested parties will be made clear and discussed openly
prior to consent preparation.
6.3. A better system of allocating gravel should also be considered. The current system
of allocating gravel based on permits is inefficient and does not assist gravel
management because available gravel is often not conveniently located. We are
aware of several instances, both within and outside Tasman District where regulatory
barriers to gravel extraction have resulted in gravel operators purchasing farms for
the express purpose of quarrying for gravel when an adequate gravel resource sits
unutilised in the regions rivers.
6.4. Federated Farmers suggests that the Council increase its level of control over the
gravel resource by including gravel extraction in the global consent. Extractable
gravel can then be tendered as it comes available. Advantages of this type of system
include:
 It will be more efficient than the current system which is reactive and does not
always align the needs of those who extract gravel with environmental
outcomes.
 It would be more efficient because there will be only one consent with
associated administration cost.
 It will be more effective because it will enable the Council to vary management
in response to changes to the river or build ups of gravel that require action.
 It will be more efficient because tenderers may agree to undertake works to
remediate the river bed as part of the conditions of the ‘entitlement’ that they
receive, saving the Council from having to undertake these works.
6.5. Any such system should be managed to avoid problems, for example it would be
unfair to allocate all extractable gravel in Tasman District to a single industry player
as a bulk tender.
7. Information about Gravel – State of Knowledge
7.1. What should the Council do, if anything, to increase its knowledge about the
gravel resources of the district, especially relating to sustainable yields for
abstraction?
7.2. Do you think that the environmental, regulatory and river assets arms of the
Council are working together to improve knowledge about the gravel
resources and its sustainable management?
7.3. If not, how can we do better?
7.4. The key issue for the community is not the quantity of the gravel resource, but the
movement of gravel and the way that changes to the river impact on people.
7.5. The Council needs to continually improve knowledge of management interventions
that pose minimal risk to the intrinsic values of rivers and yet are efficient and
effective ways to maintain the integrity of the river system while providing for the
wellbeing and safety of those who live and work near rivers. One example may be
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the approach of ripping gravel to facilitate natural movement downstream being
undertaken by Hawkes Bay Regional Council, which appears to be an efficient and
effective means to reduce flood hazard risk, while still allowing natural river
dynamics.
8. River Works and Gravel
8.1. How do you think the needs of the river asset managers, landowners and the
contracting industry could be better met in relation to the process for
obtaining consents to relocate or remove gravel?
8.2. Communication is key to success because the regulatory environment is complex
and a resource consent may not always deliver the best result. This applies to
external and internal communication.
8.3. A freer regime – in particular for emergency works carried out after floods need to be
specifically provided for where further damage to land or infrastructure or public
endangerment is likely. It makes absolutely no sense to stop someone from
relocating gravel within a bed to protect a bank, when subsequent soil erosion will
cause a worse overall environmental effect, not to mention endangerment to health
and safety and damage to property.
8.4. Ideally very few resource consents should be required to relocate or remove gravel
outside the scope of the global consent, which should cover off the vast majority of
activities that river managers need to undertake to meet roles and responsibilities.
Key activities that should be provided for include works within the wetted part of the
bed, repair or protection of banks, and sustainable gravel extraction.
9. Fees and Charges
9.1. Do you think Council’s fees and charges are an incentive or disincentive to
good gravel management?
9.2. How could the Council’s fees and charges regime be managed to produce
better outcomes for those people who want to take gravel?
9.3. Federated Farmers has no position on fees to extract gravel other than that where a
direct benefit to a defined user occur, costs should lie with the applicant rather than
the general ratepayer.
9.4. We also note that if gravel extraction was part of the Council’s global gravel
management consent, there would be no issue with fees and charges because there
would be no consents to abstract gravel – instead costs would be recovered or offset
through the tendering process.
10. ABOUT FEDERATED FARMERS
10.1. Federated Farmers of New Zealand is a primary sector organisation that represents
farming and other rural businesses. Federated Farmers has a long and proud
history of representing the needs and interests of New Zealand farmers.
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10.2. The Federation aims to add value to its members’ farming business. Our key
strategic outcomes include the need for New Zealand to provide an economic and
social environment within which:
10.2.1. Our members may operate their business in a fair and flexible commercial
environment;
10.2.2. Our members' families and their staff have access to services essential to
the needs of the rural community; and
10.2.3. Our members adopt responsible management and environmental practices.
Sue Brown
Dairy Chair
Golden Bay Province
Federated Farmers of New Zealand
Gavin O’Donnell
Provincial President
Nelson Province
Federated Farmers of New Zealand
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