In a comprehensive submission on the Natural Environment Bill and Planning Bill, IrrigationNZ emphasises that how the goals are framed will determine how the entire regime is interpreted - from national direction through to regional plans and consent decisions.
"The goals are the lens through which everything else will be read," says chief executive Karen Williams.
"If water use is framed primarily as something to be constrained, that signal will flow through the whole system. The legislation must clearly reflect that while water must be protected, it must also be responsibly used within environmental limits."
Williams says IrrigationNZ wants to see water storage and distribution infrastructure explicitly recognised alongside other essential infrastructure.
"Transport and energy networks are clearly recognised as essential, long-lived infrastructure. Water infrastructure deserves equal recognition. These are multi-decade investments that underpin food production, regional economies and community resilience. If we want water in the right place at the right time, that enabling infrastructure must be written into law."
Without storage and distribution systems, water cannot be captured when abundant and made available when scarce - limiting New Zealand's ability to manage flood risk, support environmental flows during dry periods, and maintain consistent food and fibre production.
While IrrigationNZ supports reform that delivers clarity, simplification and stronger environmental outcomes, the organisation says the legislation must actively manage economic and community benefits within environmental limits - not treat them as secondary considerations.
The 'How' Is Missing
The IrrigationNZ submission also raises concern that signficant operational detail has been deferred to secondary legislation and future national direction, alongside broad regulation-making powers.
"Too much of the 'how' is missing," says chief executive Karen Williams.
"Without clearer guardrails in primary legislation, future changes could materially shift how water is managed without full scrutiny. That undermines confidence for longlived infrastructure and intergenerational investment.”
IrrigationNZ represents nearly 5,000 members nationally, including irrigation schemes, irrigated food and fibre producers, and infrastructure operators responsible for billions of dollars in assets.
“For our sector, certainty is not a nice-to-have - it directly affects food security, regional resilience and investment decisions that span decades,” says Williams.
“We support reform. But the goals must embed balance at the top of the system. If they don’t, the reform will not operate as intended.”
Williams says New Zealand has a strategic advantage in water, but only if it is managed with foresight.
“Water is one of New Zealand’s shared strengths. Protecting it and using it responsibly are not competing ideas. They must sit together in legislation. If we get this right, the reform can deliver the balanced outcomes New Zealanders expect.”
