Freshwater quality limits- submission to Taranaki Regional Council

I recently submitted to the Policy and Planning committee meeting held on 5th September at Taranaki Regional Council. I raised the following matters with the Council.

I advocated for the live streaming of Taranaki Regional Council meetings similar to New Plymouth District Council. I felt this would give opportunity for a wider group of constituents to potentially engage in the democratic process given Taranaki Regional Council is the local government authority for the whole of Taranaki, the meetings are often mid-morning, and are held in Stratford.

I expressed my concern Taranaki Regional Council (TRC) is developing freshwater quality parameters at a regional level ahead of the development of national parameters despite the first and foremost recommendation of the commissioned report prepared by NIWA on their behalf to wait. (Item 5:Developing freshwater quality limits for Taranaki)

The preamble to this item acknowledges the government is currently working on a ‘National Objective Framework’ (NOF) with national working parties populating the framework with a range of parameters that can be used at a regional level. This will help set numeric freshwater limits for all water bodies so freshwater quality can be maintained.The national approach does not to encourage regions to go ahead of the NOF but to follow it. This does not appear to be the case with TRC.

If the council staff is going to promulgate Niwa’s recommended limits as an interim measure it is concerning to consider E.coli (pg.42).  NIWA states “contact recreation guidelines for microbial pollution are being adopted consistently by councils and are recommended here.” According to NIWA standards range from between 250 to 550 across the different regions (other than TRC) and MFE and MOH. However it appears Taranaki Regional Council is advocating an E.coli count of 1000 as a parameter for recommended water quality standards in Taranaki (Table 2).

Taranaki Regional Council has disputed the Ministry for the Environment’s parameters for freshwater quality. Yet 4 regional councils and the Ministry of Health also endorse 550 or a lower rate as a precautionary approach according to NIWA. Parameters of 1000 for E.coli are representative of animal drinking and secondary contact recreation guidelines.

The other issue raised in this item is the lowering of MCI values. Taranaki Regional Council appears to be endorsing the degradation of our rivers and streams.  Setting water quality standards at 88-100 and 76-89 in the middle to lower reaches as acceptable in Taranaki is extremely concerning considering Stark’s classification that this is poor or fair. This feels like the council are suggesting that degraded waterways are the ‘new normal’.

I find it very disturbing Taranaki Regional Council is endorsing a draft short report from NIWA without the full technical report being completed.  There is little meaningful scientific discussion in the NIWA draft to support the changes to the E.coli or MCI parameters. I believe TRC needs to continue to follow the lead of Ministry for Environment, Ministry of Health and several other councils by maintaining E.coli and MCI parameters representative of the national trend.

http://www.trc.govt.nz/assets/Uploads/pp0509public.pdf

http://www.trc.govt.nz/assets/Publications/state-of-the-environment-monitoring/environmental-monitoring-technical-reports/994763.pdf