The stream in your neighbourhood, the river we drink, the water at the beach – Kāpiti, Porirua, Hutt, Wairarapa, Wellington: how clean is clean enough? How dirty is too dirty? Submissions close 15th!

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Here’s your submission guide for the water bits of Plan Change 1 (PC1 to its mates).  It’s some really big proposed changes to the Natural Resources Plan, AKA the Wellington Region’s rulebook for air, waterways, the coast, and soil.  

[Editor: shout-out to the anonymous nerds who’ve helped make this submission guide!]

• If you’re really time-poor, trust the kaupapa of Talk Wellington, and just want to whack in a helpful submission, scroll (way) down to the typing cat.
• If you want to be a bit more exploratory, read on through what’s changing, why it’s changing, the quality of the PC1 content, and why it’s important you make yourself heard.
• GW did a public webinar about this on Wednesday 6^th and the (excellent) presentation is here. Highly recommended.
• At the bottom we have a submission from TW reader Jonny Osborne. It’s a great read and great inspiration! 

If you’ve got submission tips for other bits of PC1 – like indigenous biodiversity – please put them in the comments. And please tip us off if you’d like to share a full submission or do something cool like host a submission party! 

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1. What’s changing? 

The water aspects of PC1 are bringing in much stronger environmental regulation of what we put in rivers, streams and the sea. 

For busy people who also care –  like you! –  two aspects are most important:

1. a suite of water objectives – big-picture what we want to achieve for our freshwater and coastal water. 

These are high-level, but there’s enough specifics that we can tell if we’re on track.

These are at the beginning of each whaitua (catchment) chapter: chapter 8 for Te Whanganui-a-Tara and 9 for Te Awarua-o-Porirua.

(Top tip: you can see the chapters by using the Outline button when looking at the PDF.

2. For specific areas of catchment and awa: How good the water situation is now, and how good want it to be.

This is presented in pairs of grades A-E for water quality, with a baseline grade +  target grade.

There’s a bunch of acronyms but essentially the formula is:

• for each logical chunk of catchment and waterway (AKA part Freshwater Management Unit or pFMU to friends), there’s a baseline attribute state (baseline for some dimension of water health like sediment, or pollutants, or ecological health – all these  measured with good practice science)
• And there’s the Target Attribute State (TAS): where we should be getting to on those dimensions of water health.
• The difference between them is the challenge ahead of us e.g. “stream is currently abysmal on attribute X and we’re aiming to eventually get it to pretty stuffed” or “beach Y is currently pretty good and we’re aiming to get it to Great”.
• There’s some baseline – target gaps which aren’t a gap: the challenge is simply “maintain”.  E.g. river A is just tolerable right now and we should keep it at just tolerable”

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You can get a good sense by looking at tables 8.2, 8.4 and 9.2, and the sediment reductions in Table 8 (fun fact: sediment is the most ecologically damaging pollutant in the arms of Te Awarua-o-Porirua.)

To get there quickly from the big main landing webpage, click on the full document (left picture). It’ll open in your web browser; if you’re on your phone, beware cos it’s a biggie. And then use the Outline button (right picture) that shows a document outline that lets you jump to chapters.

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Which catchment are you in?

For all of the things mapped, here (beware – you can go deep on this GIS, it’s got everything!)

There’s lots of other stuff but for those of us who don’t have decades of deep nerdy specialism in freshwater or coastal water, these are the most important. 

2. Why’s the water rulebook changing?

Because the current rules (and all their predecessors)  have let us make a real mess of our region’s waters – especially urban streams. And it’s pretty blindingly obvious: those current regulations are not working: our region’s water is getting sicker.  

Good change needs a whole suite of things to shift practices, attitudes, behaviour.

But worldwide, and throughout NZ’s history, nothing meaningful happens in the absence of sensible, well-pitched rules saying what’s Not OK and what’s OK.

All other things being equal… 

…without good rules, because humans are human and organisations are made of people, two things happen. 

• Individually: the few ratbags and awful people will do despicable stuff like flagrant polluting. And the vast majority of people (who aren’t evil, just love the path of least resistance) will do “cheeky” or “yeah nah she’ll be right” things, like getting a little digger in to do the earthworks for our new sleepout and shed, and not bothering what happens when it rains; or taking a few years to get around to fixing the bit of the fence that’s letting the cows into the stream.  
• Collectively: it’s also bad. Without good rules that bring together good science with social licence (see para 19 here), our city and district councils get all “yeah, nah” about managing our collective wastewater and stormwater networks on our behalf. (Yes, local councils need resource consents from regional council to discharge pollutants (stormwater and wastewater) into streams and the coast – i.e. run a stormwater network and a wastewater network.)
  • Without such rules it’s much easier for them to shrug off, confuse or throw their hands up about doing a bad job of this.  It’s much easier for them – and us the voters – to let politicians spend money on other things, to design our new developments so they pollute heaps, to ignore mana whenua pleas to keep human waste out of water.  And the result: sicker and sicker streams, rivers, estuaries, harbours, beaches.

…but with good rules, because people are people and organisations are made of people, two things happen:

• individual people and businesses innovate, invest, and apply the best of human ingenuity to problem-solving how to do what we want without triggering the rules.  (The classic example is automotive manufacturing: in the EU, with strong regulations on fuel-efficiency and pollution, significant R&D and innovation have been applied to making profitable vehicles – so average cars in the EU are vastly higher-performing than those sold into Australasia. 
• WIth good rules, collectively, our whole system can get better (and not get worse.)  Good rules are a crucial tool in the toolbox for decision-makers trying to navigate tricky issues and make good calls on our behalf – like whether the impacts on our water of a proposed development, a new investment, a new policy will leave us better off or worse off overall.  

So for us as individuals and us collectively, we need the rules to be roughly right.  

For bonus points, your submission could also talk about the importance of properly enforcing the rules (crucial!), and also infrastructure funding (huge), and community environmental governance (massive), and appropriate funding of monitoring science (ginormous) … and… and…  

But the Natural Resources Plan Change 1 consultation is just the rulebook element.

3. How solid is what’s proposed in PC1?

This is the culmination of a shedload of work including some quite cool new processes. 

The bits of the rulebook covering two of the region’s catchments – Te Awarua-o-Porirua, and Te Whanganui-a-Tara – are special.  They are incorporating the Whaitua Implementation Plan (WIP) developed for that catchment’s water with a collaborative planning process.  

This is essentially a mahi tahi thing whereby rather than following the traditional process (“experts and wonks make up proposed rules, consultation happens, proposed rules changed, years of legal battles, bastardised rules come into effect”) councils can choose to do it differently: to collaboratively develop these rules with people who live, work, play, raise families in these catchments, and the iwi who hold mana whenua there. Whaitua are Wellington’s version of these and they have taken years of hard work. 

Community members (Whaitua Committees) have been steeped deeply in this stuff for months, and independently, professionally facilitated to come to consensus decisions about what’s in their WIP. Mana whenua participated and also produced their own documents to speak directly to their values. Each Whaitua process has got better at partnering with mana whenua.

Everyone in the region should know about whaitua, and feel quite stoked that they’ve happened, but the whaitua had so little comms from Greater Wellington (partly cos butastrophe, etc) that most people don’t have any idea. So, good news right under our noses: the content of PC1 for these catchments is the product of all this hammering-out. 

The objectives and the differences between baselines and targets have been much fought-over, and vast amounts of evidence have been provided making the argument for more or less change.

It will shape urban development and landuse, and that’s good.

Importantly, the PC1 changes make it harder to develop in greenfield: to take land that’s currently got stuff growing on it, and turn it into urban area. That’s exactly right because it’s been artificially, damagingly easy to develop in greenfields, which we invariably do in low density because our market is borked.  There are two big costs from low density greenfield to the public and future generations: 

1. the absolutely unavoidable damage to water quality and streams from turning “land with no urban stuff just plants” to “land with buildings drains sewers driveways roads treatment plants chimneys…”

2. once the newly-laid pipes (and roads) assets have been handed over to be the council’s responsibility, the decades and decades of subsidy that the rest of us pay for the upkeep and repair of that infrastructure. This happens because with our traditional suburban density never has enough revenue-generating activity per linear metre to cover the cost of keeping its loos flushing, its stormwater draining, its streets lit, its roads and footpaths maintained, and so on.

PC1 is doing just a little to bring home to developers the true costs to the public of building a low-density suburb in greenfield – and the costs of operating its infrastructure for the next 100+ years.  (Depressingly, some important folk in councils (which are currently subsidising such development with all our money) also seem to need this brought home to them.) 

If our towns grow via brownfield (doing more on already-urbanised land) instead of greenfield, because PC1 has nudged up the costs of greenfield development, it’s way better on both:

1. Those currently healthy streams in farmland, forest land, scrubland get to stay healthy. We can visit some of them and swim, picnic, wade, catch eels, even drink to our hearts’ content and our souls’ nourishment; others will just keep doing their valuable watery stuff, quietly and unseen.  

2. The new homes, businesses etc can have a vastly lower water footprint – and vastly lower emissions, transport burden, etc etc – when there’s more of them close together. This is because by doing lots more valuable stuff with each square km of land, density makes it wholly affordable to put in and run infrastructure and services that are far more sophisticated – and just reliably functional!  Those great water-sensitive urban designs, the sophisticated green infrastructure, the smart stormwater and wastewater management – it all becomes affordable with density.

Finally, there’s an analogy with farming: it’s currently artificially easy to do pastoral farming on Wellington’s erosion-prone land because the bad effects of farming there  – i.e. soil loss to erosion and sedimentation into our awa – are shared by everyone.  PC1 makes it a bit harder and more expensive to do pastoral farming and clearfell forestry on erosion-prone land, vs retiring it into native bush (good carbon farming) or doing something non-erosive like mānuka honey. 

Readers, what’s ended up in PC1 is fundamentally solid in NZ terms.

Finally, it’s always useful to look at other places and this gives us another reason why PC1 is fundamentally sound: it shows New Zealand is well behind the 8-ball on looking after our natural water, and that we should already be using lots of stuff that’s normal elsewhere. 

Despite only being urbanised for a bit over 150 years, we’re really trashing our waterways – yet even London, urbanised and blithely polluting the Thames for over 1,000 years, has turned the tide.   Cities like Berlin and Sydney, with far more difficult water situations than ours, are going at their water problems with both hands, and are decades ahead in normalising good water performance of their urban environments. 

We can do this.

4. Why do I need to make a submission?

Essentially there are four big reasons:

1. There’ll be lots of pushback, because we’ve had a history of letting people (us) get away with damaging our waters.

As we’re seeing with high-intensity dairy-farming outfits being blithe about polluting streams, it’s becoming less accepted by our society that our collective assets should be ruined by externalities – essentially just failures of our systems to make us behave according to our values.   As for Canterbury and Waikato dairy-farmers, so for suburbanites doing subdivisions, towns’ sewerage systems, and industrial activity.   (And for extensive pastoral farming on Wellington erosion prone land, it’s …just that).

 2. Counterintuitively, now’s the perfect time: when we’re in shock about pipes costs!

It’s especially important now because the parlous state of our three waters infrastructure is finally becoming clear and we the citizenry are reeling at the costs – and we’re understanding how we’ve got ourselves here.  But that’s exactly why now is the perfect time for Wellington to be setting the rules about “how dirty is too dirty, how clean is clean enough” for our rivers, streams, sea.

Excitingly, we’re now entertaining fundamentally different ideas about how to better arrange, fund, plan, deliver, maintain, operate three waters infrastructure – and the other key infrastructure of urban places. If we get the rules element right, the other work can then reconfigure other parts of the system to help deliver better water and better places.

3. There’ll be lots of pushback because housing

Expect lots of concern-trolling about “but we CAN’T possibly do better on water because there’s a housing crisis and we just need more homes, stat – and Kiwis want to live in greenfield suburbs!” This is, frankly, a BS argument. 

It’s high time New Zealand got better at infrastructure and the humble fiscal science of density simply can’t be overstated.  We’re stitching up ourselves – let alone our children and grandchildren – if we “fix” our housing crisis by building suburbs unable to wash their own face in infrastructure terms (one of many reasons why low-density greenfield is bad). We must give ourselves and our kids the benefits of better density, now! And PC1 helps.

4. There’ll be lots of wailing from councils because sewage

Councils (on our behalf) are amongst the Big Polluters thanks to all our poo flowing in (and out of) all our decrepit sewerage infrastructure and our messed-up stormwater infrastructure. There will be much concern from councils because – like us –  they’re reeling from the costs of fixing water infrastructure they’ve been Not Funding for decades (because we the voters hate being rated for things we can’t see). Councils’ general state of terror isn’t being helped by the government’s (hopefully temporary) pause on doing anything about it.

So councils may well call to defer implementation, to “cut us a break” – anything to put it off.  But the timing now is really important. There is no valid reason not to get the rules bit right, and it’s a linchpin for better systems for doing water infrastructure. The new systems we design for doing three waters better must grow up from the soil of solid, well-founded rules.

Four reasons why your voice raised in support, as a regular citizen, is so important!

5. Submission guide

Have a read if you like – there’s loads of info on the Regional Council’s website.

Or just go straight to the submissions page! Make your riff on the below, filling in their form here (beware it’s INTENSE) or sending them an email BY 5PM FRIDAY 15^TH DECEMBER!

[address:] regionalplan@gw.govt.nz

[Subject line:] Submission on PC1

[body text]:

Your Name, address, phone number

I won’t gain an advantage in trade [unless you will of course!]

I’m submitting as an individual [unless you are representing an organisation]

I’d like to speak to my submission [unless you don’t want to! Do note it has a huge impact on decisionmakers vs just writing in, it’s way easier than you think, and there’s lots of support]

[and your riff on the below. It’s important to be specific, but as a minimum just specify objectives, catchment/s and the Target Attribute States.]

I support PC1’s water elements: they’re an important first step.

I support the objectives for [insert catchments here – the catchments map is above]

I support the Target Attribute States proposed for [these catchments]. [If you think they should be even better, say so!]

I believe the inducement to do less on greenfield land and more on brownfield is good, is necessary to meet the objectives, and also helps us do better cities.

I believe the costs are important and our task is not to try and dodge them, push them back onto the environment, or kick the can down the road even further, but to problem-solve  together how best we can resource doing water better.

I encourage councils to collectively resource enforcement, science, and complementary policy tools like education, industrial water plans, community governance, and citizen water-care activity.

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For inspiration: A lovely personal submission from TW reader Jonny Osborne.

And don’t forget to share! 

This stuff is way complex and most people who care will be put off by its complexity. Encourage others – including kids! They’ll inherit all this so let’s do them a solid and make sure the rules bit is well-founded.  

Get your nerd on:

• Look up your favourite awa on LAWA!
• Read up on collaborative processes – success factors, and a Canterbury analysis  
• Read the Porirua and Te Whanganui-a Tara Whaitua implementation plans

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Image credits:

• Banner image: New Scientist
• Waiwhetu Stream mid 1970s – Te Ara Alexander Turnbull Library, Dominion Post Collection (PAColl-7327)
• Stormwater care art – Mt Cook School students
• Kaiwharawhara Stream – Maarten Holl | Dominion Post
• Bothamley Park sewage main works – Te Rā Nui (Eastern Porirua Development)
• Porirua Stream – Dizzy’s Folding Bike blog

Tags: freshwater, infrastructure, policy, regulation, science, water