The Ngaruroro Water Conservation Order brings uncertainties that point to an untenable proposal, writes Federated Farmers Senior Policy Advisor Rhea Dasent.

Federated Farmers opposes the Ngaruroro Water Conservation Order because of the uncertainty it brings.

The order is uncertain in three ways: it dumps limits on the community with an accompanying regime to be worked out by someone else later; inconsistent units; and inconsistent timeframes.

The last two risk creating inequities between the people and communities of the area.

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The conservation order dumps a "top-down" target on to the region, which is then left up to our community and the Hawke's Bay Regional Council to try to figure out how to make it work in the real world.

Read more from Federated Farmers here.

This is the opposite to the usual Resource Management Act process, where a bottom-up approach is fostered, and the values of the local community are balanced, and practicality is a consideration.

One advantage being the applicants of the water conservation order, being Fish & Game, Forest & Bird, Ngati Hori Kohupatiki Marae, and others, is they only have to propose limits, and don't have to come up with a plan as to how we collectively can meet these in an equitable and practical way.

That task is left to the rest of us who actually live and work here, lumped with a WCO that we didn't need or ask for.

Not only is the potential regulatory regime unknown, but another uncertainty is the way the water conservation order proposes its limits are to be measured.

The limits in Schedule 5 use different units of measurement, and even vastly different timeframes.

The difference is stark between the upper catchment and the lower catchment areas, leading to confusion and inequities.

The water quality limits in the upper are measured using milligrams per litre, yet the lower are milligrams per cubic metre.

Timeframes also vary.

The upper has five-year median timeframes for some quality indicators, and a five-year maximum for others.

The lower catchment has a tighter timeframe of a one-year average, and even a strict "shall not exceed" for some quality indicators with no timeframe.

So many uncertainties point to an untenable proposal