Part 6: What monitoring is performed?

Horizons and Otago Regional Councils: Management of freshwater resources.

In this Part, we examine how the Horizons and Otago Regional Councils undertake their monitoring obligations under the RMA, and any other freshwater monitoring initiatives that they carry out.

Regional councils’ monitoring obligations under section 35 of the RMA include:38

  • the state of the environment – which involves collecting information on the condition of the environment and key environmental pressures; usually against key indicators;
  • the exercise of resource consents – which involves checking compliance with consent conditions, the effectiveness of consent conditions, and monitoring the effect of activities on the environment; and
  • the effectiveness and efficiency of the policies, rules, and methods in the Regional Policy Statement and Regional Plans.

In addition, the planning framework under the Local Government Act 2002 requires local authorities to identify in their Long-Term Council Community Plan:

  • their activities;
  • the rationale they provide for their activities (including the community outcomes to which they contribute);
  • intended service levels; and
  • how performance will be measured.

In the annual report, a local authority must, in relation to each group of activities, describe any identified effects that any of their activities had on the social, economic, environmental, or cultural well-being of the community.39 Monitoring undertaken under the RMA will assist councils to describe the effects of their activities on the environment.

Apart from being a statutory requirement, monitoring is also a critical part of the planning process. Monitoring enables an organisation to check that it is achieving what it sets out to achieve, and provides information for use in decision-making.

Considerable resources are used to prepare planning documents; therefore, it is important to monitor progress towards objectives and the ERAs, and to assess how well policies and methods are working.

Effective monitoring can provide early warning of issues or problems so that they may be addressed before they become serious, costly, or irreversible.

Planning monitoring activities, and managing and sharing data

How is monitoring planned?

There are strong linkages between different types of monitoring. An integrated approach to designing and implementing a monitoring programme allows a regional council to consider the overall outcomes it is seeking with all of its monitoring requirements, to ensure that monitoring activities are not duplicated or overlooked.

It also allows a regional council to consider resources and address issues such as information management, data quality, collection, storage, use, access, and exchange of information, both within and outside the council.

Our expectations

We expected the selected 2 regional councils to have clear strategies for state of the environment, compliance, and effectiveness and efficiency monitoring. We also expected the councils to have a defined strategy for undertaking monitoring, which describes the outcomes sought from the monitoring information, and the linkages between the different types of monitoring.

Our findings

The Horizons Regional Council has a Regional Monitoring Strategy. However, it is incomplete and is not used by staff to guide monitoring activity. The Strategy does not include compliance monitoring, nor does it describe how data collected will be used to assess whether policies and methods are effective or efficient.

The Otago Regional Plan: Water states that a regional monitoring strategy will be prepared, but this has not yet occurred. The plan outlines monitoring techniques for determining the suitability and effectiveness of plan policies and objectives (see paragraph 4.119). Performance targets for compliance monitoring are set in the Council’s annual plan.

While the Otago Regional Council does not have a monitoring strategy, it does carry out an annual review of state of the environment monitoring requirements for water quality through the annual planning process.

In 2002, the Council reviewed its state of the environment surface water quality monitoring programme. The review examined the suitability of existing monitoring sites and parameters, the appropriateness and frequency of sampling, and the adequacy of data management processes.

Concluding remarks

While both councils had some form of monitoring strategy, neither comprehensively covered all the types of monitoring that we expected.

When writing objectives, policies, and methods, it is useful for regional council planners to think about how these will be implemented, how implementation can be measured, and how to determine whether the policy is having the desired effect. This leads to the development of ERAs that are closely linked to the monitoring strategy.

A monitoring strategy that includes all the types of monitoring required by regional councils (including state of the environment, compliance, complaints, and effectiveness and efficiency monitoring) should be developed as part of the planning document process.

How is data managed and shared?

Regional councils deal with a large volume of data that may be used for multiple purposes – for example, in looking for trends in the state of the environment, assessing the effect of a new activity, or determining non-compliance.

Agencies other than regional councils may have their own monitoring programmes. For example, the Department of Conservation and Fish and Game councils collect information as part of their own work programmes that can be useful to regional councils. Regional councils’ use of information collected by other agencies can avoid duplication in monitoring activities.

Our expectations

We expected that monitoring data would be available in a format that is usable and accessible to all regional council staff who need to use it.

We also expected that regional councils would have explored opportunities for sharing information with other agencies, and would use this information where appropriate. In saying this, we recognise that monitoring programmes are often developed for specific purposes and it may not be possible for other parties to use the information.

Our findings

Internal data management

At both councils, compliance monitoring data was not in a format ready for use by staff because it:

  • was not stored in a consistent manner; or
  • had not been provided to the council by the consent-holder.

At the Otago Regional Council, it is possible for self-monitoring data to be entered into 1 of 2 databases, depending on its format.40

Both councils rely on scientific staff to supply data, or information derived from the data, to other parts of the council (for example, resource consents staff) as and when required. Consents staff told us that they get information from the scientists in a form that they can understand.

Stakeholders we spoke to in both regions were concerned that information was not shared sufficiently within each council – in particular, between the areas of the council administering the RMA and those undertaking engineering works. This can lead to situations such as the one when the Otago Regional Council served an infringement notice on itself when a contractor, working on the council’s behalf, carried out river control work that breached the Regional Plan: Water.

Sharing information between agencies

There was collaboration between each Council and the local Fish and Game council, universities, other regional councils, and the Department of Conservation. Specifically, information from the Department of Conservation and the Fish and Game council was used in both regions to identify environmental values for water bodies.

The Horizons Regional Council’s Regional Monitoring Strategy identifies sharing data and setting up joint projects with other agencies as cost-effective and efficient. The National Institute of Water and Atmospheric Research (NIWA) manages at least 1 rainfall site in the region, and an energy company operates some water flow sites.

In addition, the Horizons Regional Council has recently begun to monitor bathing water quality in collaboration with territorial authorities and the local District Health Board (see paragraphs 6.99-6.105).

Concluding remarks

Data management by both Horizons and Otago Regional Councils could be improved. In particular, compliance monitoring data is not stored in a consistent manner, nor is it readily available for use by staff.

Collection of monitoring data can be expensive and time-consuming, so it is important that it is stored in a consistent format and is readily available to those who need to use it. Without good information, council staff will not be able to effectively review and plan future activities – for example, targeted education or monitoring where problems are identified – or to amend planning documents where required.

Both councils were co-operating with other agencies to share information and collect monitoring data. Data-sharing and joint projects between agencies can be cost-effective and efficient. We support these initiatives.

State of the environment monitoring

State of the environment monitoring can provide early warning of environmental problems and show where environmental management has been effective. This monitoring informs decision-making by helping to determine the need for further action, and by indicating broadly where policies and actions can be improved or may need review.

We assessed the surface water quantity and quality monitoring undertaken by the selected 2 regional councils.

What water quantity monitoring is done?

Water quantity monitoring provides useful information for identifying pressures on water bodies, the cumulative effects of water takes, as well as being a measure for low flow or flood warnings.

Our expectations

We expected the 2 councils to undertake water quantity monitoring as part of their state of the environment monitoring.

Our findings

Both councils monitored river flows for rivers in their regions and provided up-to-date graphs and information on their websites, and by an automated telephone service. In addition to providing essential information for the management of resources and flood prevention, this service is also useful for stakeholders, including irrigators, recreational users, and others with an interest in the river.

While information related to river flows is comprehensive, both councils have less information about the volume of water taken or the rate of take during the exercise of resource consents, or as a permitted activity.

To address this issue, the Horizons Regional Council proposes to help large-water-take resource consent-holders fund the costs of installing and maintaining telemetry equipment. The Otago Regional Council is including monitoring requirements in resource consents as they come up for renewal in areas with high demand for water.

Both councils have concluded that permitted-activity water takes in water-short, or potentially water-short areas, are of growing concern. Because of the nature of permitted activities, it is difficult for the councils to know the extent of the water takes, and it is therefore difficult to determine the pressure that the takes are putting on water resources.

The Otago Regional Council is concerned about new property developments in water-short areas where there is a perception that water will be available to new residences through permitted-activity water takes from groundwater or surface water. In some parts of the region, water resources are not sufficient to support further development.

What water quality monitoring is done?

Regional councils monitor a set of parameters that represent the health of water bodies and look for any trends in these parameters. No single parameter, or set of parameters, is used to measure water quality throughout New Zealand, although many parameters are in common use.

Water quality parameters that are measured include:

  • chemical measures – for example, nutrients (nitrogen and phosphorous levels), hydrocarbons, pesticides, acidity or alkalinity, and organic wastes;
  • physical measurements – such as temperature, suspended solids, colour, and clarity; and
  • biological measures – including measures of indicator bacteria, viruses, and protozoa; the types of invertebrates – for example, insects, snails, and worms – present at a site, and the amount of periphyton (green slime) growth.

The interpretation of water quality information is not a straightforward activity. The water quality measured is often the consequence of complex interactions between a number of factors, and understanding the relationship between measured water quality and land use often requires specialised skills.

Our expectations

In terms of monitoring water quality, we expected the councils to:

  • identify suitable parameters for the region, or parts of the region;
  • perform regular monitoring of these parameters; and
  • ensure monitoring sites are representative of the region.

In the same way that there is no uniform set of water quality parameters that all regional councils measure, there is no standard benchmark to define when the level of a specific parameter should cause concern. The Australian and New Zealand Environment Conservation Council (ANZECC) provides guidance by specifying trigger levels above which environmental problems may arise.

We expected regional councils to:

  • have a benchmark of what an acceptable level is for each water parameter selected; and
  • analyse the data collected to determine trends in water quality.

Our findings

Both councils undertake regular water quality monitoring at a number of sites within their regions. This monitoring is generally related to the management purpose of the water body, or can be part of a targeted water quality investigation. Monitoring sites in both regions include those considered “pristine” and those affected by water-use activities.

The Horizons Regional Council uses a ranking system to rate water quality data from “very poor” to “excellent”, and also a method to rate how often a parameter at a site is at an acceptable level during a specified period. This data is used in the Council’s 2005 State of the Environment Report to describe the quality of the region’s rivers for a number of parameters, including suitability for contact recreation and nutrient enrichment. The thresholds used by the Horizons Regional Council relate to the ANZECC guidelines, international standards, or standards in the relevant regional plan.

The Otago Regional Council has identified benchmark levels for parameters measured, predominantly using the ANZECC guidelines for trigger levels. Water quality monitoring reports from the Otago Regional Council show trends in measured parameters over time.

The response to water quality data and the reporting of this information is discussed in Part 7.

Concluding remarks

State of the environment monitoring for water quantity by both councils includes frequent monitoring of river flows within each region. This provides essential information for the management of resources and flood prevention, and is useful for stakeholders, including irrigators, recreational users, and those with an interest in the river.

However, the councils have less information about the volume of water taken or the rate of take during the exercise of resource consents41, or as a permitted activity. This means the councils do not know how much water is actually being used in the region – they only know how much water is allowed by resource consents or as permitted activities.

This gap in information reduces the councils’ ability to manage the resource because some users may hold resource consents to take large volumes of water, but do not use it all. This means that more water is potentially available for allocation to other users, but the regional council cannot know how much. Both councils are now including conditions on resource consents to take water that will enable them to monitor the volume and rate of water taken.

Water quality monitoring is regularly undertaken by both councils at a number of sites within their regions – including sites considered pristine, and where contaminants are discharged or water quality is affected by non-point source discharges.

Both councils have set benchmarks or systems for assessing acceptability for each water parameter selected.

Compliance monitoring

Resource consent compliance monitoring ensures that any non-compliance with consent conditions is detected, and allows – where necessary – for appropriate action to be taken.

Compliance monitoring also gives stakeholders and the community confidence that resource consent conditions are being complied with, and gives consent-holders an incentive to comply with their consent conditions.

Assessing compliance with resource consents is undertaken through:

  • Requiring consent-holders to monitor their own discharges to water, or water take rates and volumes, and to send the results to the regional council. This is referred to as self-monitoring.
  • An on-site audit or inspection by regional council staff to check compliance with consent conditions. This can include the collection of a sample of discharges to verify the accuracy of self-monitoring results.
  • Analysis of water quality and quantity monitoring information collected through state of the environment monitoring downstream of a discharge to water, or a water take.

How do the councils assess compliance with resource consents?

The ability of the regional council to assess compliance with resource consent conditions, and to take action when non-compliance is detected, relies on well-crafted resource consent conditions.

Our expectations

We expected regional councils to:

  • issue resource consents with suitable conditions that can be monitored and are enforceable;
  • monitor resource consents; and
  • analyse resource consent data to determine compliance.

Our findings

Writing resource consent conditions that can be monitored and enforced

Of the resource consents that we considered, the older consents issued by the Horizons and Otago Regional Councils for surface water takes did not include conditions that would enable the councils to obtain information about the volume of water the consent-holder was taking. Most of the more recently issued water take consents allow the councils to obtain the relevant information.

Compliance staff of both councils have an opportunity to comment on resource consent conditions written by consents’ staff or contractors, to ensure that these are measurable, practical, and enforceable.

Monitoring compliance with consents to take water

We checked monitoring records for 22 resource consents to take water from the Rangitikei River in the Manawatu-Wanganui region. Horizons Regional Council staff had been persistent in following up the non-return of self-monitoring data. However, very few consent-holders had provided the data.

In late 2004, the Horizons Regional Council assessed the operation of its regional plan that sets a minimum flow for the Oroua River. The review found that:

  • less than half of the consent-holders comply with any of the conditions to supply water-take monitoring records;
  • some consent-holders were not aware that they had to send in self-monitoring data; and
  • the Council’s own record-keeping is poor, with water-use consent information spread through a number of different electronic and paper filing systems.

The review has highlighted a number of significant issues for the Horizons Regional Council’s compliance monitoring. Lessons learned from the review can feed into development of a compliance regime under the water allocation policy.

There were significant gaps in how the Otago Regional Council monitors compliance with surface water takes. For example:

  • some consent-holders do not submit the required self-monitoring data to the Council;
  • self-monitoring data sent to the Council is largely unchecked; and
  • of the consents we looked at, there have been no compliance inspections or audits of water take consent-holders.

As described in paragraph 6.22, the compliance monitoring data is not readily accessible to compliance staff.

For the most part, the Otago Regional Council is not monitoring consents to take water, so it has no way of knowing how much water is taken from the river by individual consent-holders, or whether these consent-holders are taking much less or much more water than their resource consents allow.

With the Regional Plan: Water becoming operative, the Council has taken action to ensure that compliance monitoring data will be available. It is formally reviewing resource consents on the Kakanui River, and setting conditions that require consent-holders to install systems that will automatically measure and telemeter water-take data to the Council.

The Regional Plan: Water includes a policy to include monitoring conditions on any new or renewed resource consents for water takes.

Monitoring compliance with consents to discharge contaminants to water

In the Manawatu-Wanganui region, we examined 10 resource consents to discharge contaminants into the Manawatu River. Of these:

  • The Horizons Regional Council considers that 4 are “major discharges” – 2 of these have been monitored 4 times a year42;
  • at least 1 inspection had been undertaken for 5; and
  • no compliance monitoring had been undertaken for 3.

In addition, some discharge consents for the Manawatu River contain requirements to monitor specific parameters for which no monitoring method exists – for example, “change in hue” and “photosynthetically active radiation”. Consequently, these parameters have not been monitored.

We looked at the Otago Regional Council’s compliance monitoring of 15 discharges to surface water, which included 5 discharges of treated sewage. We found that:

  • There were no self-monitoring requirements, or monitoring by the Council for 8 of the resource consents.
  • The remaining 7 consents required self-monitoring, but for 6 of these consents not all data had been received, or the data had been received but had not been analysed. The Otago Regional Council has performed its own monitoring of most, but not all, of the 7 consents.

The Otago Regional Council considers that most significant resource consents to discharge contaminants to water are monitored. It undertook a compliance review in 2004 to outline the different types of activities and how they should be monitored.

The compliance review established that all discharges should be subject to regular monitoring, and that 18 sites should be subject to self-monitoring and audit. Of the 15 resource consents that we analysed, one was in this self-monitoring and auditing category. The most recent audit of this consent showed that it was non-compliant, and the subsequent self-monitoring data received by the Otago Regional Council had not been analysed.

As stated previously, the Otago Regional Council includes performance targets for compliance monitoring in its annual plan. In 2003-04, most targets relevant to the monitoring of consents to discharge contaminants to water were not met. For example, 90% of self-monitoring data was not reviewed within 1 month, and not all noncompliance identified through self-monitoring was followed up.

At the time of our audit, staff were focussing compliance activities on wastewater treatment plants, and resource consent activities with potentially significant adverse effects on the environment.

Some stakeholders took the view that the Otago Regional Council did not employ sufficient staff to address compliance issues. The Council has now recruited more compliance staff.

Concluding remarks

The compliance staff of both councils have an opportunity to comment on resource consent conditions written by another part of the Council, to ensure that the conditions are measurable, practical, and enforceable.

The involvement of compliance staff in assessing the practical aspects of monitoring and enforcing resource consent conditions is a valuable step in resource consent processing, and helps to provide a strong basis for monitoring and enforcing consents.

It would be useful for regional councils to discuss compliance with consent-holders when resource consents are granted, to ensure that consent-holders are aware of what is required.

There are significant gaps in how compliance monitoring is undertaken at both councils. Specifically, many water take consent-holders fail to send in self-monitoring results on the rate and volume of water taken, and there is little scrutiny of these results if the councils do receive them. In addition, compliance monitoring data is not easily accessible and may be stored in different formats and databases.

In both regions, there was no monitoring for some resource consents to discharge contaminants to water. Further, in Otago, self-monitoring data was not reviewed promptly. This means that non-compliance and potential or actual adverse effects may not be detected (and thus addressed) early. Lack of monitoring, or lack of analysis of self-monitoring data, means there are gaps in the information that the regional council holds in relation to discharges to water.

A lack of monitoring of compliance with resource consent conditions significantly weakens the RMA planning and resource consent process.

People who make submissions on planning documents and resource consents put in a considerable amount of time and effort to establish plan provisions and consent conditions that they consider will protect their area of interest, and then agree to the conditions in good faith. When these are not monitored, the community receives no assurance that plans and resource consent conditions are in effect, and there is less incentive for consent-holders to make the effort to comply.

Monitoring the effectiveness and efficiency of policies and methods

Monitoring the effectiveness and efficiency of policies and methods is a means of determining how well plans are working in practice. It builds on state of the environment monitoring, and can be complemented by resource consent compliance monitoring. Effectiveness and efficiency monitoring is useful for identifying possible changes and improvements in policy statements and plans.

Councils are required to publicly report the results of effectiveness and efficiency monitoring at least every 5 years.

How do the councils monitor effectiveness and efficiency?

Good monitoring of effectiveness and efficiency would require a specific monitoring approach for each policy and method, and should be linked to the objectives and ERAs in planning documents.

Our expectations

We expected that the councils would have developed and implemented processes for monitoring the effectiveness and efficiency of the policies and methods specified in planning documents.

Our findings

The Horizons Regional Council does not carry out effectiveness and efficiency monitoring. The Regional Policy Statement states that key indicators for monitoring the suitability and effectiveness of policies and plans will be identified, but this has not occurred.

Horizons Regional Council staff told us that they are struggling with monitoring the effectiveness and efficiency of policies, rules, and methods, and that they have no process for this.

The Otago Regional Council has implemented some of its methods for monitoring the effectiveness and efficiency of the Regional Plan: Water – for example, it assessed the effectiveness of its catchment education programmes. Monitoring information has been used to assess which rivers are high priorities for setting minimum flows, and to tailor catchment-based monitoring programmes.

However, the Otago Regional Council’s effectiveness and efficiency monitoring is not linked to specific policies and methods. Because the Otago Regional Council’s objectives and ERAs are broad rather than specific and monitoring is not targeted at specific policies and methods, it is not clear how this monitoring will be analysed to determine the effectiveness and efficiency of policies and methods.

Neither council has sought feedback from stakeholders about the effectiveness and efficiency of its policies and methods.

Concluding remarks

Both councils need to improve the way in which they plan and carry out effectiveness and efficiency monitoring, particularly now that they are required to publicly report the results of this monitoring at least every 5 years.

Effectiveness and efficiency monitoring is essential to determining which parts of planning documents are achieving the desired goals and which are not, and therefore where improvements are required.

All policies and methods, including non-regulatory policies and methods, need to be assessed and procedures for doing this devised at the time a planning document is developed. Procedures for effectiveness and efficiency monitoring should be part of a monitoring strategy.

Regional councils could receive valuable feedback from stakeholders about whether they consider council policies and methods are effective or efficient.

Monitoring bathing water quality

During the summer months, water at bathing beaches (including rivers) can be regularly monitored to determine the risk to swimmers and other recreational users of water of developing an illness caused by bacterial pathogens – for example, E. coli.

The Ministry for the Environment’s Microbiological Water Quality Guidelines for Marine and Freshwater Recreational Areas recommends a framework for the roles and responsibilities of various entities, including regional councils, for performing this monitoring. The guidelines suggest that regional councils undertake the monitoring and inform the Medical Officer of Health and territorial authorities if alert or action levels are reached.

The guidelines require that samples be tested for E.coli weekly from November to March at any sites designated as “beaches”, with daily sampling if a result exceeds a set value. If 2 consecutive results exceed the limit, the public should be warned (by signage or media advertising) that beaches are not safe for swimming.

Our expectations

We expected that regional councils would participate in bathing water quality monitoring carried out in the region by an agency or a group of agencies.

Our findings

From late 2004, the Horizons Regional Council, in collaboration with the local District Health Board and territorial authorities, began monitoring bathing water quality throughout the region and reported the results on its website.

The Otago Regional Council considers that it does not have a statutory responsibility to monitor bathing water quality. At present, no agency in the Otago region undertakes this monitoring, and the public is given no information about whether or not it is safe to swim in the region’s rivers.

Concluding remarks

The monitoring of bathing water quality is important. People want to know where and when it is safe – or not – to swim. We consider that in regions where this monitoring is currently not being done, the regional council, territorial authorities, and the District Health Board need to agree on who will co-ordinate, fund, and carry out this monitoring.

Iwi involvement in monitoring

While not a statutory requirement, monitoring activities may also draw on cultural values associated with water and the close relationship that Māori have with, and extensive knowledge of, waters in their tribal areas.

The Horizons Regional Council’s Manawatu Catchment Plan states that the Council will provide opportunities for tangata whenua to be involved in monitoring water quality in the Manawatu catchment through the resource consent process and joint monitoring activities. It also states that the Council will assist tangata whenua to establish water quality monitoring initiatives (including financial assistance).

The Otago Regional Plan: Water notes that it may develop joint initiatives with parties such as Kai Tahu to monitor key aspects of Otago’s water environment.

Our expectations

We expected that regional councils would have considered cultural monitoring where iwi had expressed a desire for it, and that policies and methods involving joint monitoring with tangata whenua would be implemented.

Our findings

An iwi representative we spoke to in the Manawatu-Wanganui region expressed a desire to be involved in monitoring activities. Some resource consents granted by the Horizons Regional Council allow for an iwi representative to be present when compliance monitoring samples are collected, and for the results of this monitoring to be sent to the iwi.

One resource consent on which iwi had made a submission required a territorial authority to submit a cultural monitoring programme to the Horizons Regional Council within 3 months of the consent, and to implement it in conjunction with local iwi within 2 months of it being completed. At the time of our audit, this condition had not been complied with.

The Horizons Regional Council does not operate a cultural monitoring programme.

In the Otago region, Kai Tahu has already established cultural indicators for the Taieri and Kakanui rivers through participation in the Ministry for the Environment’s cultural indicators’ project.43 The methodologies in this report have not yet been co-ordinated with the Otago Regional Council’s monitoring programme. However, they are being discussed by Kai Tahu and the Council.

Concluding remarks

Planning documents in both regions contain mechanisms for involving tangata whenua in monitoring activities. To date, neither the Horizons nor the Otago Regional Council operates programmes with iwi for monitoring cultural values.

Cultural monitoring and joint monitoring programmes can be a means of building trust and strengthening relationships between regional council staff and iwi. Involvement in cultural monitoring can also encourage iwi participation in resource management matters.

In addition, the data that is collected can complement data collected through scientific methods, and help regional council staff to appreciate Māori cultural values in relation to water resource management.

38: Section 35 of the RMA also includes a requirement to monitor the exercise of any functions, powers, or duties delegated or transferred by councils. We have not considered this type of monitoring as part of this report.

39: Clause 15(d), Schedule 10 of the Local Government Act 2002. For the majority of councils, this requirement will apply for the first time to the annual report for the year ending 30 June 2005.

40: Electronic data from commercial laboratories can be downloaded into the Environmental Quality Database, and data in other formats is entered intermittently into the Compliance Database.

41: Issues around a lack of information about volumes and rates of water taken by consent-holders are discussed in paragraphs 6.63-6.70.

42: The Manawatu Catchment Water Quality Regional Plan specifies that compliance monitoring of all “major discharges” and all discharges of human sewage to the Manawatu River will be undertaken at least 4 times a year.

43: A Cultural Health Index for Streams and Waterways: Indicators for recognising and expressing Maori values, Ministry for the Environment, 2003.

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