Submission on proposed Changes to the NPS-FM and NES-F (including wetlands)

The NZKGI Submission on Amendments to the NPS‑FM and NES‑F supports the government’s proposed refinements to wetland regulations but highlights a practical issue for kiwifruit growers caused by the current drafting of Regulation 54. Because irrigation and frost‑protection water can be discharged within 100 m of mapped or potential wetlands, some applications are being treated as non-compliant despite negligible environmental risk. NZKGI argues this approach is disproportionate given existing consent conditions, growers’ strong incentives to avoid over‑watering, and the limited likelihood of adverse hydrological or biodiversity effects. The submission endorses the recommended changes to ensure water discharges are only regulated where actual environmental effects are likely, and seeks additional clarifying wording so that benign irrigation‑related discharges default to regional plan rules rather than NES‑F restrictions.