Ms Simmonds has been calling for the answers since March.
In a report to be presented to councillors tomorrow, Mr Saunders said work on the section 32 report for the plan would take priority.
Work had begun on the latest report the minister had called for, he said.
But he further identified that the minister had not given the council a deadline for the further information she requested in a letter to the council this month.
"Staff are currently preparing a section 32 report in accordance with the approved project plan which is reported on monthly as part of the CEO’s report to council", Mr Saunders said.
"The section 32 report will be drafted to ensure it meets the requirements of the Resource Management [Act] (RMA).
"At this time staff are unable to draft a complete response to requests contained in the minister’s letters.
"At the completion of the section 32 report or at an earlier date as required by the minister, a response will be prepared for the consideration of council. Drafting of this response has commenced.
"This response will include all relevant information requested by the minister provided it is held by ORC."
New Zealand’s Quality Planning website (QP) said a section 32 report would evaluate the extent to which any objective in the plan was the most appropriate way to achieve the purpose of the RMA, identifying alternative policies and methods of achieving the objective and assessing the effectiveness, costs and benefits of alternative policies rules or methods.
It would also examine the risk of acting, or not acting if there was uncertainty or not enough information about the subject matter of the policies, rules, or other methods, QP said. It would further assess whether the council proposals were "the most appropriate given their likely effectiveness and their likely cost, relative to the benefit that would likely deliver".
Council staff are working towards a notification date of October 31 for the plan: this date was chosen by a majority of councillors in consultation with staff despite central government extending the notification date for all such plans to the end of 2027.
Several councillors who lost the vote at the time said the regional council was in effect giving the National government "the middle finger" after it had fallen into line for the previous environment minister, Labour’s David Parker.
Mr Parker began to engage the council in 2019 around its water planning framework.
Since late last year, Ms Simmonds has told the council she was concerned its present course of action would foist undue costs on ratepayers. Upcoming changes to the national policy statement for freshwater management should be taken into account, she said.
The council, in May, supplied the minister with a report on the costs, benefits and implications of its proposed plan.
Dollar figures related to the implementation of the plan did not feature in that report.
Farming groups have recently gained media attention after claiming the council’s plans could cost ratepayers hundreds of millions of dollars.
Picking up on media reports, Ms Simmonds on August 8 followed up a July 31 letter to the council and said after discussion with her ministerial colleagues, she remained concerned the council might be required to make changes to its plan once the new national freshwater policy statement was in place.
Staff will recommend tomorrow that councillors endorse setting up a meeting with the minister.