Horizons and Otago Regional Councils: Management of freshwater resources.

New Zealand’s unique natural environment contributes to the country’s reputation for scenic beauty, recreational opportunities, and a “clean, green” image. However, the activities of people can affect the quality of our environment.

Sufficient quantities of clean freshwater are indispensable for the country’s future – whether for economic prosperity, human and ecosystem health, recreation, or cultural identity. (We use the term freshwater to include all water except geothermal and coastal water).

Regional councils are responsible under the Resource Management Act 1991 (RMA) for the management of freshwater resources in their regions.

We carried out a performance audit to assess how 2 regional councils – the Horizons Regional Council (the trading name of the Manawatu-Wanganui Regional Council) and the Otago Regional Council – are applying the RMA framework to manage the quality and quantity of freshwater resources in their regions.

We assessed 4 aspects of regional council activities in relation to freshwater management – planning, implementation, monitoring, and acting on information. One of the aims of our audit was to identify examples of good practice by the 2 councils, or where improvements could be made that would be useful for all regional councils.

Our key findings are similar for both the Horizons and Otago Regional Councils, and we consider that they are largely transferable to other regional councils.

Overall, we found that the Horizons and Otago Regional Councils have made good progress in some areas, such as planning and implementing water allocation frameworks, but improvements need to be made in other areas – particularly compliance and effectiveness and efficiency monitoring.

This summary sets out our key findings, key messages, and examples of good practice and innovation shown by the Horizons and Otago Regional Councils.


We assessed whether the Horizons and Otago Regional Councils’ planning documents (Regional Policy Statements and Regional Plans) provide adequate guidance for the management of freshwater in their respective regions. We considered whether the planning documents comply with the RMA, and if the councils assess plan objectives, policies, methods and Environmental Results Anticipated (ERAs) against best practice.

Key findings

Generally, the planning documents that we looked at met our expectations. Specifically, the 2 councils have made good progress in:

  • identifying environmental values related to water bodies in their regions;
  • developing a water allocation framework – including setting minimum flows on rivers where there is a high demand for water, and reflecting these flows in resource consents to take water; and
  • defining a range of policy instruments for the management of water resources in their regions.

However, the objectives included in both councils’ planning documents are not measurable, and many objectives did not provide a clear basis for setting policy direction. Where objectives are not specific:

  • council staff and stakeholders can be unsure of the linkages between how issues are being addressed by the policies and methods, and what the plans intend to achieve;
  • decision-makers could find it difficult to justify some resource consent conditions, or decisions to grant or decline resource consent applications;
  • resource consent applicants can be unsure about the requirements they need to meet, and what level of resource use is acceptable; and
  • stakeholders with an interest in environmental protection can be in doubt about what level of protection will be provided.

Objectives that are measurable provide a basis for:

  • determining whether progress is being made in achieving the objective; and
  • assessing whether the policies and methods that flow from the objective are effective and efficient.

The ERAs set out in the Horizons and Otago Regional Councils’ planning documents did not meet our expectations. Rather than a statement of what might be achieved within the lifespan of planning documents, many ERAs simply repeat the objectives, which adds little value.

While the councils had included the procedures for monitoring the effectiveness and efficiency of policies and methods in planning documents, these are not comprehensive, nor are they linked to the objectives and ERAs set out in the planning documents.

Key messages

Planning documents can be significantly improved by the inclusion of simply worded, measurable objectives that clearly set out what the plan intends to achieve, and specifically outline the environmental state sought.

When planning documents are being prepared, more thought needs to be given to the drafting of ERAs. Well-crafted ERAs that state what is intended to be achieved within the life of the plan can provide a solid basis for designing procedures for monitoring the effectiveness and efficiency of policies and methods.

In our view, procedures for monitoring the effectiveness and efficiency of policies and methods should be linked to specific policies and methods, and established during plan development.

Formal training on the content and purpose of planning documents for new and existing council staff should be provided to establish and maintain detailed knowledge of these documents and what they intend to achieve. A clearly understood relationship between issues, objectives, policies, and methods allows council staff to effectively write action plans to implement the policies and methods outlined in the Regional Plan. It also helps to ensure that the action taken will lead to progress in addressing the issues identified.

Examples of good practice and innovation at Horizons and Otago Regional Councils

Identification of environmental values is a key starting point for planning water management. We were pleased to see that both councils had identified environmental values for specific water bodies, and that these were included in planning documents.

Good progress has been made in the complex area of planning and implementing water allocation frameworks.


We considered the extent to which the 2 councils have implemented the policies and methods related to:

  • working with territorial authorities to manage water resources;
  • regulation, education initiatives, and economic instruments; and
  • increasing Māori participation and protection of mauri.

We also considered how the councils ensure that their policies and methods are implemented.

Key findings

Improvements could be made in the way the councils and their respective territorial authorities interact to maintain and enhance water quality and quantity. In particular, regional councils and territorial authorities need to work together to ensure that:

  • new subdivision development takes account of water availability and natural hazards; and
  • the effects of stormwater and leachate from on-site wastewater treatment on water quality are avoided, remedied, or reduced.

Some small rural territorial authorities are continuing to discharge sewage effluent into rivers that is of a quality inconsistent with regional council policies to improve water quality. However, financial constraints or funding priorities can prevent these territorial authorities from upgrading wastewater treatment plants to improve the quality of effluent discharged.

Regulations controlling the point source discharge of contaminants into rivers, streams and lakes have been less effective in improving water quality because of the effect of non-point source discharges on water quality. Agricultural activities are a significant cause of non-point source pollution.

Both the Horizons and Otago Regional Councils provide environmental grants for wetland protection and enhancement, and for riparian management. These grants can encourage community groups and individuals to undertake projects to maintain or enhance water resources that might not be possible without financial assistance. If the community wants better water quality or wetland and biodiversity protection, then these grants can be a useful way of enhancing the environment in these areas.

The majority of education initiatives outlined in both councils’ planning documents have been implemented, and stakeholders generally considered that the advice provided by council staff was of a high standard. Education programmes were most effective when the regional councils and community groups worked together to achieve common goals.

While the Otago Regional Council has made good progress in ensuring the local iwi authority and affected runanga are involved in the resource consent process, the Horizons Regional Council has taken few steps to increase Māori participation or protect mauri. Of the Horizons Regional Council assessments of resource consent applications to discharge contaminants to water that we looked at, most did not include any reference to protection and enhancement of mauri. There was no mention of tangata whenua concerns, even when consents dealt with the discharge of human effluent.

Key messages

Where communities want improved sewage effluent quality, consideration should be given to investigating alternative effluent disposal methods or funding sources for wastewater treatment plant upgrades.

It may be timely (as councils prepare second generation planning documents) for regional councils and territorial authorities to review procedures for permitting intensive agricultural activities where there are likely to be significant effects on water quality.

Where water quality is significantly degraded, or likely to become degraded, by non-point source discharges, it may be necessary for regional councils to regulate to reduce the effects of these discharges, or to strengthen the regulation that exists. This may include (but is not limited to) requiring nutrient budgeting, reduced fertiliser application, or the planting of riparian margins.

Introducing or strengthening rules to address the effects of non-point source discharges could usefully be supported by education to ensure that people understand the reasons for taking a regulatory approach, and financial incentives to help change behaviour.

Regional councils and territorial authorities could effectively collaborate to provide education initiatives – in particular, those related to efficiency of water use and preventing stormwater contamination.

The RMA establishes the relationship of Māori and their culture and traditions with their ancestral lands, water, sites, wāhi tapu, and other taonga as a matter of national importance. In addition, many regional plans make reference to the protection of mauri. Accordingly, whether or not iwi make submissions on consents, regional councils should consider these issues as part of the resource consent process, particularly for resource consents to discharge treated human effluent to water.

Understanding Māori values related to resource management is a key competence for council staff involved in developing resource management policy, making resource consent decisions, and designing monitoring programmes.

When planning documents become operative, the community can rightly expect that the policies and methods outlined in the plans will be implemented. To provide assurance that this is happening, councils need to monitor progress towards implementation, and report this progress – for example, to senior managers or a council committee.

When writing objectives, policies, and methods, it is useful for regional council planners to think about how they will be implemented, how that implementation can be measured, and how it will be determined whether the policy is having the desired effect. Action plans that assign responsibility for individual tasks may be required.

Examples of good practice and innovation at Horizons and Otago Regional Councils

The Horizons Regional Council:

  • provides advice on sustainable land management at no cost. This is an incentive for landowners to implement council suggestions;
  • uses a good range of economic instruments, including transferable water permits, and reduced compliance inspection fees for consent-holders who comply with their consent conditions; and
  • is including conditions in territorial authority consents to take water for community supply, which require the territorial authority to prepare a plan for achieving the efficient use of water in the district or city.

The Otago Regional Council:

  • provides educational catchment programmes, which are a good example of the gains that can be made when regional councils and communities co-ordinate their efforts;
  • has implemented, or is in the process of implementing, the majority of policies and methods that we looked at in its Regional Plan: Water. As the plan became operative in early 2004, this is a significant achievement; and
  • provided a comprehensive programme of training and information about the Regional Plan: Water to staff and the community as the plan became operative.


We examined how the 2 councils plan and perform the monitoring activities required under the RMA, including state of the environment monitoring, monitoring compliance with resource consent conditions, and monitoring the effectiveness and efficiency of policies and methods.

Key findings

Neither council has produced a monitoring strategy that includes and integrates all the types of monitoring that are required by the RMA.

Both Horizons and Otago Regional Councils regularly undertake state of the environment monitoring for water quality and quantity at a range of sites in their regions. The councils have set threshold limits for acceptable levels for each water quality parameter that they measure. The water quantity information that is collected is useful for stakeholders, including irrigators, recreational users, and those with an interest in the river.

The 2 councils have less information about the volume or rate of water taken during the exercise of resource consents, or as a permitted activity. This means neither council knows how much water is actually being used in their 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 their water resource because some users may hold consents to take large volumes of water, but do not use all of it. This means that more water is potentially available for allocation to other users, but the councils cannot know how much. Both councils are working towards remedying this problem.

There were significant gaps in how compliance monitoring is undertaken at both councils. Specifically, many holders of resource consents to take water fail to send in self-monitoring results, and there is little scrutiny of these results if the councils do receive them.

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.

In addition, compliance data collected by both councils is not stored in a consistent manner and may not be readily accessible to staff. Collection of monitoring data can be expensive and time-consuming, so it is important that relevant information is 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.

Monitoring the effectiveness and efficiency of policies and methods is limited. The Horizons Regional Council does no effectiveness and efficiency monitoring. The Otago Regional Council has done some effectiveness and efficiency monitoring but has not linked it back to specific policies and methods.

Key messages

Monitoring strategies should be prepared as part of the plan development process. An integrated approach to designing and implementing a monitoring programme allows a regional council to:

  • consider its plan objectives, with all of its monitoring requirements, and establish strong linkages between monitoring activities, ERAs, and effectiveness and efficiency monitoring;
  • ensure that monitoring activities are not duplicated or overlooked;
  • consider the resources required; and
  • address issues such as information management, data quality collection, storage, use, access, and exchange of information, both within and outside the council.

All policies and methods, including non-regulatory policies and methods, need to be assessed for effectiveness and efficiency, and procedures for doing this need to be detailed at the time a planning document is developed and included in monitoring strategies.

Effectiveness and efficiency monitoring is essential to determine which parts of planning documents are achieving the desired goals, and which are not – and therefore where improvements are required. With new requirements to publicly report the results of this monitoring at least every 5 years, councils will need to improve the way in which they plan and carry out effectiveness and efficiency monitoring.

Compliance monitoring should be planned and implemented to ensure that communities receive assurance that plans and consent conditions are in effect, and that there is an incentive for consent-holders to make the effort to comply.

Example of good practice and innovation at Horizons and Otago Regional Councils

Both councils operate systems to record staff suggestions for improvements to planning documents. These are good initiatives and useful to policy staff when preparing new policies and plans.

Acting on information and informing communities

We examined how the 2 councils respond to:

  • non-compliance with resource consents;
  • complaints and environmental incidents; and
  • monitoring data.

We also looked at how the councils provide information to their communities.

Key findings

Both councils had taken action in response to monitoring information, including the development of targeted education programmes and new policies. Council staff have the opportunity to provide input into plan improvement processes.

Both councils accept that enforcement action is appropriate where consent-holders do not comply with consent conditions, and are not willing to change their practices or are repeat offenders.

Each council operates a pollution hotline so people can tell the council about environmental pollution or an accidental spill. However, stakeholders in both regions were concerned that the regional council did not always respond promptly to pollution complaints. Some stakeholders also commented that the council did not inform them about the result of an investigation resulting from a complaint they had made.

Both councils had published State of the Environment Reports, but neither council had reported publicly on whether ERAs and objectives were achieved.

Key messages

Taking enforcement action where consent-holders do not comply with resource consent conditions, and are not willing to change their practices or are repeat offenders, is a valuable mechanism for signalling to the community which activities the regional council considers are unacceptable.

Responding to complaints is part of the “public face” of regional councils. Where members of the community perceive that regional councils are not fulfilling this role, they can become frustrated and lose faith in the council’s ability to protect the environment. This, along with reducing the negative effects of environmental incidents, is an important reason to promptly respond to and investigate pollution incidents.

Reports to councillors and senior management on responses to non-compliance should include information on the follow-up action taken to ensure that the noncompliance will not continue.

Information on progress toward, or achievement of, ERAs and objectives should be provided in regional councils’ effectiveness and efficiency monitoring reports.

We consider that councils should be responsive to the information requirements of their communities. This includes providing a final copy of resource consents to affected parties, and information on compliance monitoring and responses to environmental incidents where appropriate.

Example of good practice and innovation at Horizons and Otago Regional Councils

Both councils provide up-to-date graphs and information on their websites about river levels and flows.

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