The chair of Te Runanga o Ngai Tahu says proposed reforms to freshwater management do not do enough to protect the taonga itself.
The paper calls for councils to have legal requirements to be more receptive to Maori environmental concerns.
Sir Mark Solomon welcomes this but thinks not enough is being done to protect the water.
He says management systems are needed that give people the right to protect Maori and community values, such as water for drinking and mahinga kai (gathering food).
Sir Mark says iwi must participate at every level when it comes to water issues, from decision making to economic outcomes.
He says it's about enshrining iwi involvement and giving it appropriate weight in a way that recognises the Treaty Partnership.
Submissions on the paper close on Monday 8 April.