Healthy Rivers; Plan Change 1
Who are the Stakeholders?

There has been much said and written about the Healthy Rivers project undertaken by the Waikato Regional Council (WRC) and the proposed plan change (PC1).

In all of the writing and discussion much mention is made of the “STAKEHOLDERS” in the process of developing PC1 and in the proposed implementation of it.

So my question is “Who are the Stakeholders”?

If the Regional Council is to be believed they are in fact the people represented by the members of the “Collaborative Stakeholder Group” (CSG) but in fact it was almost impossible for the CSG to actually truly represent the views of all of the people they represent simply because it is impossible under this system to consult with all of them.

In fact what happens is that the consultation is undertaken and because it is done it is taken as gospel that the outcomes are representative of the views of all of those people when in actual fact they are truly only representative of those who participated in the consultation meetings. No matter whatever the reason for not doing so, those that did not participate were in fact not represented.

Even some of those who are members of the various organisations that made up the CSG do not agree with the outcome of the CSG process and they have made that very clear. The process was supposed to be a collaborative one but in fact at end of the process, due to time constraints and the inability of all the members of the CSG to agree on an end result, it came down to a simple majority vote.

In fact one of the representatives on the CSG refused to be a part of the final decision making due to this very issue (“failure of the collaborative process”).

This was then also the outcome when the decision was made by the WRC to advertise the plan change and start the public consultation. The decision had to be made on the basis of the Chairperson’s casting vote as there was an even split for and against going ahead with the plan change in its current format.

The failure on the part of the WRC to have a process that is acceptable to all of the stakeholders is I believe also evident in the more than one thousand submissions from the public consultation process.

As to my initial question I believe the primary stakeholders in this whole process are two separate groups;

1. The beneficiary’s from the proposed plan change (every person affected by the water quality of the Waikato and Waipa rivers) and
2. The people who are going to have to implement the requirements of the proposed plan change (all those both urban and rural that cause or control an effect on the water quality).
In fact a large number of the members of the CSG were only representatives of stakeholders and therefore not true stakeholders, in that they will not have to actually take any direct actions and pay the costs of those actions, in relation to improving the actual water quality.

In my opinion the primary stakeholders in the process of implementing the outcomes of PC1 are the people that will have to act & fund that action to make improvements and without ensuring the support of each and every one of them then this process is doomed to fail right from the start.

For the improvements to the water quality set out in PC1 to be successfully implemented it will require each and every person who has a direct effect on the waterways by means of discharging contaminants to the waterways, to take ownership of the effects from their discharge and to take action to reduce that effect from their discharge by either reducing the discharge or reducing the harmful effects from the discharge.

This process of taking ownership of the problem and driving the solution should be driven from the bottom up based on good science, rather than trying to regulate a one size fits all top down solution. This bottom up solution driven by the primary stakeholders has been done in other regions around the country with good levels of success and this can happen in the Waikato Region as well.

Yes there needs to be some form of compulsion for those that believe they are above the law and don’t need to conform but the current proposal for a one size fits all model based on grandparenting the discharge of contaminants, monitored by a system (Overseer) that has a built in failure rate of +/- anywhere from 30% to 100% depending on the inputs, is not fit for purpose and in my opinion is simply absurd.

The grandparenting of the right to discharge contaminants based on this system opens the process up to the possibility of people gaming the system to gain an advantage with a corresponding adverse outcome in relation to the environment.

In this situation where the nitrogen reference point can result in huge financial impacts for the landowners then there is huge pressure and this type of gaming of the system can result. Current farm sales are already being hugely affected by the requirements of PC1 and this in conjunction with the land intensification rules in PC1 has resulted in approximately a 20% reduction in capital values.
Yes the improvement of the water quality can be achieved, but it will only happen if the primary stakeholders as described above, can afford to make it happen whilst still making a living and maintaining their asset value in their businesses.

We have now reached the ludicrous situation where the Waikato Regional Council are saying “no it’s not our plan it is the CSG’s plan” when in fact it is the WRC’s plan by law and it is their responsibility to manage the plan under the legislation. They have also said “no we have some issues with PC1 as well and in fact we are also submitting against parts of the plan” as if this lets them out of the decision making process (just pass the buck onto the hearings commissioners and let them deal with it).

The WRC got it wrong and have had to withdraw a large section of the region from the proposed plan change area because they failed to consult with one of the major Iwi groups in the region and this is only one of the reasons that I say “PC1 is not fit for purpose”.

It is time that the WRC showed some intestinal fortitude and put the plan change on hold until all of the issues can be solved to make it fit for purpose.

Currently it is my belief that people in WRC have developed such an entrenched attitude that they cannot see the wood for the trees and are frightened to reverse their original decision to advertise the plan change because they may be seen to have failed, when in fact if they were to put it on hold for further development to make it fit for purpose, this would be seen as good prudent decision making on behalf of the ratepayers.

Andy Loader
C0-Chairman P.L.U.G.
(Primary land Users Group)

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