Her report on council compliance, monitoring and enforcement provides an insight into how the 16 regional councils and unitary authorities enforce the act.
“Overall, the report outlines how we are just doing the same job in 16 different ways around the country.
“However, the same sort of breach should be treated with the same severity across the country.
“An offender should not be able to do something at one end of the country and not be prosecuted while being prosecuted for the same thing at the other end.”
She suggests a more standardised approach to compliance, monitoring and enforcement definitions and practices nationally to improve consistency and allow better comparisons on councils’ performances.
However, she acknowledges the most frequent offence is illegal discharge to waterways, which can differ in sensitivity.
“But we can allow for regional differences like waterway types and soil quality.”
She is heartened to know the act is up for discussion and there has been some progress on some aspects, partly as a result of better dairy effluent management throughout the country.
“There is also some more movement to standardisation using Ministry for the Environment guidelines for best practice. This will help bring a slow merger nationally.”
Doole said the report also highlights having boots on the ground is essential for efficient enforcement.
There is a wide spread in the numbers of enforcement staff across the country, ranging from only 0.03 per 1000 people in Wellington to 0.31 in Taranaki.
“It is hard to know what enough is and numbers per 1000 is a crude measure.
“I was surprised at the degree of difference and you find councils with the higher numbers were more effective at meeting their compliance, monitoring and enforcement requirements.
“The sign of good compliance is having a reasonable chance of detection.”
With most regions wrestling with plan changes to better manage water resources it will help if councils try to work changes in enforcement methods into those plan changes, she said.
“So often we go through these changes then compliance becomes almost a bolt-on, an afterthought.
“Councils need to shift to a model that recognises every plan change will bring different compliance demands.”
She tried to tell it like it is to councils in the report and has been impressed with the level of support from them.
“The councils came up with this idea and it was a brave thing for them to do.”
Doole thinks the report might become an annual review providing valuable benchmarks to councils on their performance.
