LWRP consultation submission guide

Now is the time to make your voice heard

October 2023: The Otago Regional Council (ORC) is taking submissions on its soon-to-be-notified Land and Water Regional Plan (LWRP). The LWRP will replace the old water plan and will set targets for water quality, water quantity and manage human activities to achieve them.

These types of plans are in force for at least a decade. So, the direction the ORC sets now will reverberate for years to come.

This plan doesn't recognise anglers and hunters as much as it should. Water bodies in the region have degraded significantly across the past few decades, and the fisheries and waterfowl habitat with them. Many of us have seen this change first-hand. The proposed provisions of LWRP are an improvement on the old water plan but don’t go far enough to restore the health of those water bodies, wetlands and fisheries.

What’s more, the protection of sports fish and game populations, and the habitat they rely upon, is sidelined in the plan. This means that it’ll be harder to protect or restore a river or a wetland for the benefit of angling or hunting.

Now is the time to make your voice heard.

The ORC has a survey open for feedback on the plan until November 6. We think this is the best way to tell them what you want for the LWRP.

Unfortunately, the consultation material is long and complicated. But we’ve got you covered. Below are our top 8 tips for the consultation that’ll affect licence holders. If you agree, do the survey and tell the ORC your views on each subject.

Accessing the survey

First, open LWRP consultation page. From here, you can review the consultation material and access the survey.

When you’re ready to do the survey, open that page and select the part of the region you want to give feedback on. We suggest ‘Otago-wide’, or else you’ll need to do the survey once for every individual part of the region you want to submit on.

After that you’ll be presented with boxes to tick for the topics you want to give feedback on. For each box you tick you one or two simple questions. If you’re following our top 8 tips, we recommend you say something along the lines of:

1. No, the proposed new rules won’t work in your area.
2. Yes, there is a better way to achieve the outcomes.

Then, tell the ORC about each of the recommended subjects in your own words, using whichever feedback box seems most appropriate.

Top 8 tips

Here’s our top 8 tips about the consultation material that’ll affect licence holders. To make things easy, we’ve underlined the topic tick box label that’s relevant for each point and included a suggestion on what to say about it.

The list is in order of importance, from most to least.

1. The Values and Environmental Outcomes must support recreation, including angling and hunting. Water-based recreation is popular and should be supported explicitly, including by improving the proposed fishing value. It’s a part of who we are as a people - how we play, relax and feed ourselves. Also, being out in nature, eating from the wild, it contributes to our health. It keeps us fit and in good spirits.

2. The ORC must have certainty that the Primary Production topic will achieve the aims and outcomes of the plan will be met with the provisions they’re proposing. If the aim is for ecosystems to be in good health (which it is), we should have confidence that’ll be achieved. ORC reports in the media demonstrate that the ORC doesn’t know if good management practices they’re implementing in the LWRP will achieve ecosystem health. That’s not good enough. Where we don’t have certainty, the ORC needs to be more precautionary, including being clear that land use change may be a possibility.

3. Strongly support default minimum flows and take limits in the Environmental Flows and Limits (Water Quantity) topic. Water bodies are nothing without water. It doesn’t matter where you are in the region, all water bodies need basically the same thing – that we only abstract a small percentage of the available water and leave the majority in the water body. It’s not the end of the world if we need to deviate from the default in exceptional circumstance. But the ORC should make sure that if we do, the bespoke alternative we come up with is within cooee of those default limits.

4. The primary production or Earthworks and Drilling topics should require that any activity which leaves lots of bare soil should have an appropriate set back from water bodies. It doesn’t matter if it comes from earthworks, forestry, intensive winter grazing or cultivation, these are all high-risk activities for water bodies and should all have similar setbacks. Deposited sediment is the biggest risk for water bodies in Otago, so it’s essential we get it right. Research suggests that at least 10m on slopes less than 10 degrees and greater than 10m on slopes greater than 10 degrees (20m is good but it’d need to increase with slope) is a good rule of thumb. The LWRP proposes that new forestry implements wider setbacks from water bodies than that and those distances would be a robust way to protect water bodies if applied to all high-risk activities in the region.

5. The Environmental Flows and Limits (Water Quantity) identifies bespoke minimum flows and take limits for some catchments but doesn’t provide any supporting information on any of them but the Manuherekia. So it’s difficult to provide helpful feedback on most of those bespoke limits. On the Manuherekia, the 2,500l/s minimum flow is good but we shouldn’t have to wait 17 years to see a meaningful flow return. That’s putting it onto the next generation. Also, the proposed take limit would be no different than that set under the deemed permits. There should be a plan put in place to reduce the allocation to a level which will provide genuine protection for the river. The ORC needs to work collaboratively with statutory managers of the species, like Fish & Game, find a way to restore the Manuherekia in a more reasonable timeframe.

6. Our region has many Outstanding Water Bodies that support outstanding fishing or hunting opportunities – or any other recreation for that matter. Now is your chance to tell the ORC which water bodies you reckon are outstanding and should have a greater level of protection in the plan. List each one out so it’s painfully clear. 

7. The ORC must identify Primary Contact Sites in the LWRP, so they can make sure being in or around the water in those places won’t make people sick. This includes places that you like to hunt and fish. Tell the ORC about water bodies you like to hunt or fish, or know are popular for others. If you can’t tie it down to a specific spot, or don’t want to give away your secret spot, just tell them the general reach or water body that’s relevant. Make it clear to the ORC that fishing and hunting doesn’t just occur in one spot – anglers and hunters move along the water body.

8. Wetlands have been hit hard by development in Otago. We’ve got less than 25% of the original extent remaining. This makes our catchments flashier, with lower lows and more extreme floods. The ORC needs to get serious about improving the extent of wetlands and making sure that we don’t drain any more with controls on land drainage.