NZFSS submission on Action for Healthy Waterways

NZFSS recently presented a submission to the Ministry for the Environment on the Action for Healthy Waterways package. A summary of our submission is presented below, with the full submission available here.


The New Zealand Freshwater Sciences Society (NZFSS) support the intention of the draft National Statement for Freshwater Management (NPS FM), the proposed NES Freshwater and the draft s360 Stock Exclusion Regulations to improve the management of freshwater to support critical values. Our submission provided the collective view and advice of Society members on the following aspects of the three policy instruments:

Summary of key issues:

  1. Support the overarching management of freshwater under Te Mana o te Wai and the for the waterbody first, then the essential needs of people and then other uses.
  2. That the term water body includes surface water bodies and ground water bodies.
  3. Support the requirement for environmental outcomes to be clearly stated in regional plans.
  4. Strongly support the inclusion of threatened species habitats, mahinga kai and tangata whenua values as national compulsory values.
  5. Strongly support the broadening and addition of attributes and bottom lines for ecosystem health as national attributes.
  6. Support the inclusion of macroinvertebrates as national attributes.
  7. Support the inclusion of fish as national attributes.
  8. Support the inclusion of sediment as national attributes.
  9. Support the inclusion of dissolved nutrients (DIN and DRP) as national attributes.
  10. Support the broader national attributes for dissolved oxygen.
  11. Support the new lake attributes for dissolved oxygen and macrophytes.
  12. Support the inclusion of ecosystem metabolism as a critical component of ecosystem health (e.g., ecological processes) and consider development of a robust national bottom line (NBL) would be more useful than a trend.
  13. Improvement in water quality for Human health and primary contact are supported, although further work is needed to holistically manage water bodies for primary contact.
  14. Consider that benthic cyanobacteria and periphyton cover attributes for rivers should be included as national attributes.
  15. Consider that action plans should be required to be part of regional plans and limits to achieve an environmental outcome or target attribute state must sit within the objectives, policies and rules of a regional plan.
  16. Consider that the water quantity directions should be clarified and redrafted.
  17. Consider that the wording of the draft NPS FM is overly focussed on trend (e.g., deterioration) in preference to addressing degraded state and that the importance of state and trend need to be more clearly expressed noting concern with the current state baseline of 2020 locking in existing degradation.
  18. Consider the framework for components of ecosystem health (Clapcott et al. 2018) is a useful addition to the NPS FM, noting concern over reporting a single number.
  19. Support the intention to halt the loss and deterioration of wetlands, noting that small wetlands on private land which are difficult to identify and map are most at threat.
  20. Consider that the Wetland Condition Index and Wetland Extent attributes need to be included as national attributes.
  21. Support the intention to halt the loss of streams from reclamation, noting that net loss of stream length and habitat quantum should also be addressed.
  22. Support the intention to improve fish passage.
  23. Consider that īnanga spawning habitats and the spawning habitats of other indigenous fish (including access to them) should be protected in the same manner as wetlands.
  24. Do not support a blanket exclusion of large hydro schemes from national bottom lines (NBL).
  25. Support national requirements for farm environment plans (FEPs), noting that these need to be based on science and evidence that links environmental outcomes effectively to FEPs.
  26. Support stock exclusion from waterbodies and setbacks, noting that streams less than 1m wide and headwaters are extremely important in the management of water quality and ecosystem health.
  27. Support the intention to manage intensive land use and winter grazing.
  28. Consider the linkages between lakes, rivers, groundwater and estuaries are not strong enough in the draft NPS FM.
  29. Consider that our knowledge is incomplete with respect to the effectiveness of land management practices to improve water quality at the catchment scale which needs urgent prioritisation and funded.
  30. Support the urgent need to better manage freshwater for ecosystem health and water quality but highlight that there may not be sufficient technical capacity to support rapid plan making by 2025.
  31. Consider there is an urgent need to build capacity nationally for farm environment planners and auditors to be appropriately skilled or qualified in freshwater science, ecology and sustainable land management practices.
  32. Consider there is an urgent need to build capacity nationally for skilled and qualified people to measure and monitor the environment to support regional councils and communities.
  33. Consider that the language, terminology and structure of the draft NPS FM and proposed NES freshwater require significant further work to enable clear and consistent implementation.

We have provided a more detailed discussion and, where possible, scientific evidence to support our views for each of the key themes in the full submission (available here). Additional matters with respect to definitions and recommended changes to some of the wording are also included, following the discussion of these key themes.