SUBMISSION – Proposed Canterbury Land & Water Regional Plan (pLWRP)
Date:
Name of Submitter:
Postal Address:
Telephone:
E-mail:
04/10/12
Irrigation New Zealand Incorporated
6 Sonter Road, Wigram, Christchurch 8042
03 341 2225
acurtis@irrigationnz.co.nz
(Andrew Curtis CEO Irrigation NZ)
Overview
1. IrrigationNZ (INZ) is a national body that promotes excellence in irrigation throughout New
Zealand. INZ represents the interests of over 3,600 irrigators totaling 350,000ha of irrigation
(approximately 50% of NZ’s irrigated area), alongside the majority of irrigation service
providers (over 140 researchers, suppliers, installers and consultants). This unique
membership combination leads to a well balanced whole of industry approach to INZ’s
advocacy activities.
2. All INZ members businesses are founded on secure, on-going access to reliable water supply
– without this they, and the Canterbury economy, do not function. The national economy
would also be significantly impacted upon. INZ actively engages with its members on
planning issues, proactively facilitating a wider understanding of the relevant issues by all.
Key Points
Significance of Agriculture and Irrigation to the Canterbury Economy
3. INZ’s membership is dominated by Canterbury irrigators. This is because approximately 70%
of all irrigation in NZ occurs in Canterbury. Irrigation is therefore of regional and national
significance. In 2002/03 based on 425,000ha irrigation contributed 11% of farm gate GDP
(MAF 2004)1 - approximately 1% of national GDP. Since then the irrigated area has increased
by over 50% and INZ now conservatively estimates an 18% contribution to farm gate GDP approximately 2% of national GDP. Irrigation in Canterbury therefore represents a 1.4%
contribution to national GDP. Note: the above figures are farm gate based and do not take
1
The Economic Value of Irrigation In New Zealand, MAF Technical Paper No: 04/01
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INZ proposed Canterbury LWRP Submission 04/10/2010
account of the considerable flow-on community socio-economic benefits (processing and
related service industries).
4. Looking at the future national potential, based on the NZIER report of 20102, increasing
irrigable area by 350,000ha increases national GDP (farm gate) by 0.8%. It should be noted
that Canterbury is forecasted to provide over 250,000ha of the additional irrigable area.
5. A recent report by AERU3, based on 500,000ha of existing irrigation Canterbury with a
further 250,000ha added through the CWMS, demonstrates the Canterbury economy
receives an additional $2billion in revenue and just under 8,000 FTE’s from increased
irrigation. For New Zealand wide impacts these numbers rise to $3 billion in revenue and
over 8,000 FTEs.
6. The Aoraki Development Trust in 2004 undertook an Ex-post study of the Opuha Dams
impacts on the provincial economy and community4. In summary  Gross Farm Revenue x3 ($900 - $2,100/ha)
 Farm Expenditure x2 ($644 - $1,503/ha)
 Cash Farm Surplus x3 ($210 - $570/ha)
 Employment x2.5 (74 – 192 FTE’s)
 $41 million value added to the Timaru economy per annum
 480 additional FTE’s jobs created off farm
 Younger & better educated workforce
7. The Waitaki Development Board, in 2009, undertook a study of the Economic benefit to the
community of the North Otago Irrigation Scheme5. In summary 
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Gross Farm Revenue x3 ($2,100/ha - $6,500/ha)
Farm Expenditure x3 ($1,300/ha - $4,300/ha) – most to local economy
Cash Farm Surplus x3 ($700/ha - $2,200/ha)
Employment x2 (71 - 147 FTE’s) direct
Farmers spent $6,200/ha converting – most to local economy
8. From the data above, it is clear that irrigated agriculture is the main driver of the Canterbury
regions socio-economic well-being. The consequences of decisions that may adversely
impact upon the irrigation sector must therefore be carefully considered.
Water Transfers in Over Allocated Catchments
9. Better enabling the transfer of water in fully and over-allocated catchments is an important
mechanism for driving improved water use efficiency - one of the main targets of the CWMS.
Water use efficiency is a principle driver for the achievement of the region’s water quality
objectives (another CWMS target) as it is linked to reduced nutrient loss through reduced
drainage and/or surface run-off. It also decreases the region’s overall water infrastructure
requirements (in-take, storage and distribution), aiding both the hydrological achievability
2
The Economic Impact of Increased Irrigation, MAF 2010
Total Value of Irrigation land in Canterbury, AERU, 2012
4 The Opuha Dam: An ex post study of its impacts on the provincial economy and community, Aoraki Development Trust,
2006
5 The Economic Benefit to the Community of the North Otago Irrigation Scheme, Waitaki Development Board 2010
3
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INZ proposed Canterbury LWRP Submission 04/10/2010
and financial viability of improved water supply reliability and increased irrigated area (also
CWMS targets).
10. Water use efficiency can be broken into technical, allocative and dynamic components.
However it is dynamic efficiency (enabling water to move to its highest value use over time transfer) that is paramount. Enabling dynamic efficiency drives both allocative and technical
efficiency. Dynamic efficiency will in part help ensure the Canterbury region receives the
‘best value use and return’ from its ample water resources.
11. The differences between a temporary and permanent transfer need to be recognised and
provided for in the LWRP. Temporary transfers are of short duration (less than 5 years) and
may be between sites (property titles) or individuals. An example of a temporary transfer
would be cropping enterprises that lease ground due to crop health or exclusion
requirements transferring their water from one title to another for a limited number of
seasons. Permanent transfers encompass all other scenarios however, land sale related
transfers should be treated as an exception.
12. Policy 4.73 and rule 5.107(5) are in part nonsensical and the latter arbitrary. Over-allocation,
as a first principle, should be dealt with through a catchment specific, inclusive approach. In
many catchments solutions will include the creation of ‘new water’ through water use
efficiency gains and infrastructure development. Confusing over allocation policies and rules
with those for transfer will create unintended outcomes for CWMS targets and must
therefore be avoided.
13. If an interim, generic method is required for dealing with transfer in over-allocated
catchments, it needs to be robust and equitable, whilst enabling dynamic, allocative and
technical efficiency gains. A better method than that proposed is to treat a consent as a
proportion within the limit and a proportion in excess of the limit. If there is no seasonal
volume, one should be applied based on the INZ recommendations made for schedule 10.
14. For a permanent transfer a consent holder would be required to surrender the proportion of
the consent that relates to their over allocation. For a temporary transfer the entire consent
should be able to be transferred provided it has a seasonal volume applied.
Nutrient Management Approach
Exclusion of Extensive Land Use Activities
15. INZ agrees with the pLWRP’s output based approach to nutrient management. This allows
for flexibility and innovation. However, INZ recommends that some additional input based
threshold rules (fertiliser use and property size for example) are applied to exclude activities
that pose little impact to the achievement of catchment freshwater objectives. Please note it
is important these land use activities are still accounted for, however this can be done more
efficiently and cost effectively through assumptions - instead of every property completing a
nutrient budget to determine whether they are below the 20kg/N/ha threshold. If a detailed
s32 cost-benefit analysis were undertaken it would become obvious a number more land
use activities should be excluded from nutrient budget and/or farm plan requirements. Such
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INZ proposed Canterbury LWRP Submission 04/10/2010
an approach would also help better deal with the considerable rural service industry
capability and capacity challenges that the pLWRP creates.
Emphasis on Nitrate
16. The pLWRP’s is very narrow-minded in its approach to water quality. In short it has a one
track nitrate focus. INZ agrees there are some areas where a focus on nitrate is appropriate.
Groundwater zones with no sensitive receiving waters (streams or lakes) where drinking
water quality (nitrate concentration) will be the water quality consideration for example.
However, for most of Canterbury the focus will need to be much wider - a combination of
nitrate, phosphate, sediment, microbial, temperature and habitat restoration. An inclusive
approach is the only means to effectively achieve the community set freshwater objectives.
Change of Land-Use
17. The current definition of ‘changed’ is problematic. Applying a volume of water threshold will
result in detrimental outcomes inconsistent with CWMS target (Water Use Efficiency and
Water Quality). Often the extra volume will be to improve reliability of supply and so will
improve environmental performance – enable a change to an ‘as and when’ irrigation
strategy as opposed to a ‘just in case. Improved reliability results in decreased water use and
drainage (nutrient losses). The irrigation component should therefore be removed. If an
irrigation component is to be included within the ‘changed ‘definition it should only relate to
additional irrigated area.
18. The 10% change in N loss is arbitrary. The percentage approach greater benefits those with
higher existing N losses, which is nonsensical. The measurement timeframe given is also
problematic and needs clarification. If input based thresholds are introduced this will avoid
the capture of scenarios like ‘a lifestyle block that has a record lambing year‘, alleviating
some issues. However, legitimate mixed cropping land use activities, with long-term crop
rotations (eight to ten years is common), that span multiple properties through lease hold
arrangement, must be better accounted for.
19. The time frame over which ‘changed’ is applied needs to be flexible to allow for a range of
land use activities. The error and uncertainty associated with the use of OVERSEER (stated as
+/-20%) also needs to be accounted for in the application of the definition. A combination
approach which combines a percentage threshold with a threshold number is therefore
recommended.
Audited Self Management (ASM)
20. For successful on-farm nutrient management the LWRP’s emphasis needs to be very much
focused on the implementation and uptake of industry ASM programmes. ASM programmes
provide an educative pathway for achieving water quality objectives. They can be easily
adapted to tackle the actual issues, they are collaborative, and importantly they focus on
achieving outcomes on the ground. They also combine audit, enforcement, monitoring and
adaption components to instil confidence in the catchment community.
21. A robust ASM programme must have:
 Strong governance with clearly defined roles and responsibilities;
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INZ proposed Canterbury LWRP Submission 04/10/2010
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Clear programme targets and objectives linked to the catchments freshwater objectives
and corresponding limits;
Transparent audit and reporting;
Corrective action and enforcement procedures;
Monitoring and adaption.
22. Successful ASM programmes have a two tier management system (a) An ASM programme must clearly set over-arching objectives and targets to be achieved
by its participants, efficiency of water use and nutrient discharge targets, for example.
The ASM governance group is responsible for setting these. The governance group is
also responsible for drawing up the agreement with the regulator (the community
representative) that clearly outlines roles and responsibilities. To integrate ASM
programmes within the regulatory framework, a catchments water quality objectives
and limits must be captured by the ASM programme – they become its objectives and
targets.
(b) Individual participants in an ASM programme develop a risk management plan (farm
plan) for their property. The plan identifies both sensitive areas (waterways, for
example) and management practices that create risk (irrigation on slopes, for example).
Specific management actions, to be used by an individual to manage their risks,
including nutrient discharge targets, are stated in the plan. This results in a list of
management actions an individual agrees to undertake in order to ‘do their bit’ in
achieving the catchments water quality objectives – a ‘social contract’.
Red Zone ‘non-complying’ activity status
23. Appendix 6 of the section 32 report acknowledges the crudeness of the process and the
coarseness of the spatial and temporal resolution used to set the regional water quality red,
orange and green zones. Unfortunately there seems to be a marked disconnect between
how the scientists set the water quality zones and the corresponding activity status applied
to each in the pLWRP.
24. Non-complying activity status for the red zone makes a presumption that the activity will
generally be unacceptable. This is not appropriate given the acknowledgments made around
the water quality assessments. Non-complying activity status cannot be justified. Restricted
discretionary activity status would be more appropriate. Alternatively the water quality
zones need defining with greater spatial and temporal resolution. Non-complying activity
status can then be appropriately applied.
Section 15 Discharge Allocations and the use of OVERSEER
25. The allocation of a discharge quantum, a nutrient discharge allowance (NDA) through
section 15 is often regarded, in the main by non-practitioners, as the best way to manage
within water quality limits. An NDA is allocated to a title and managed within using
traditional regulatory compliance enforcement. Transfer of all or part of the NDA may or
may not be allowed. This ‘allocation based’ approach has been used to manage and enforce
water quantity limits for decades. For quantity the measurement and enforcement of the
allocation is, in the main, easily achievable. However, for water quality there are multiple
challenges with the allocation and enforcement of an NDA at the farm scale:
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INZ proposed Canterbury LWRP Submission 04/10/2010
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Linking the discharge quantum to the water quality objectives. This is a particular
problem where multiple attenuation factors and time lags are present in a catchment or
within a farm.
The limitations of measurement and the complications this creates for enforcement. The
direct measurement of diffuse contaminant discharges, such as nitrate or sediment, is
not currently practical or cost effective. To overcome this, a modelled approach is used.
However, models have limitations (inputs and assumptions) resulting in error and
uncertainty. Enforcement must acknowledge this and can therefore be challenging.
Using one contaminant as a ‘catch all’. Many contaminants are too difficult to measure
or model. Contaminants interact with one another meaning there are multiple ways to
achieve a water quality objective. A focus on one contaminant will often create perverse
outcomes.
Creating a ‘numbers game’ rather than outcomes on the ground. ‘Numbers game’ means
the focus becomes subverted resulting in arguments as to the appropriateness of the
number or developing models that meet the number.
26. OVERSEER has become the default model for managing within water quality limits. INZ is
extremely supportive of the use of OVERSEER for its intended purpose – a management tool
to aid farmers in nutrient decision making – economic and environmental performance.
However, INZ has considerable concerns with the rapid application of OVERSEER to the
regulatory environment, particularly as a compliance and enforcement tool.
27. National protocols for the use of robust and consistent use of OVERSEER are urgently
needed. These will help set a framework for its more appropriate use in the regulatory
environment. OVERSEER also needs further development for both cropping and for
irrigation. However, OVERSEER’s limitations and assumptions must be recognised and
accounted for by regulators. OVERSEER is a long-term average model based on the
presumption of ‘Good Management Practice’. It will not account for the intricacies of actual
farm management practice.
28. Currently OVERSEER is a useful tool for policy development, informing the community as to
what current ‘Good Management Practice’ scenarios may achieve for specific environments.
For compliance it also gives a rough indication of annual average performance with the
assumption of ‘Good Management Practice’. However, it does not reflect actual
performance and thus could create perverse outcomes - reward poor performers and
penalise early adopters and innovators.
29. INZ is therefore supportive of the use of OVERSEER for the setting of management targets
contained within ASM programmes. In this instance the OVERSEER ‘outputs ‘can be verified
in the context of the farm practices being undertaken and a ‘confidence’ based adjustment
made accordingly.
30. INZ opposes OVERSEER’s use for the setting and enforcement of section 15 discharges
(NDA’s). INZ acknowledges that in the long-term OVERSEER may become well enough
developed that it could be used for this, but until this occurs, INZ will oppose its use for this.
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INZ proposed Canterbury LWRP Submission 04/10/2010
Specific Submission
Section 1
31. First paragraph, page 1-4 – The first paragraph states that “intensification of farming,
particularly with irrigation, has the potential to increase nutrient losses to water bodies”.
This statement is not true as Good Management Practice irrigation enables the better
management of water and nutrients. Reliable ‘just in time’ irrigation allows optimal
vegetative growth, maximising the uptake of nutrients from the root zone whilst minimising
drainage (nutrient loss). This allows an irrigated farming system to better perform to a
higher environmental standard than a similarly intensive rain-fed system.
Relief Sought: Amend
........intensification of farming has the potential to increase.......
32. 1.2.6 – Managing new and existing activities - The pLWRP requires that holders of existing
resource consents that expire and reapply be considered subject to Part 2 of the RMA. INZ
would like to see explicit reference made to Part 104(2A) of the RMA which states that “the
consent authority must have regard to the value of the investment of the existing consent
holder”.
Relief Sought: Amend
Add a reference to Part 104 (2A) of the RMA
Section 2
33. 2.6 Limits – There are a number of issues associated with the use of values/objectives in
Table 1 to form the basis for water quality limits in this plan:
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The values were developed with the aim of being aspirational but achievable;
Some hill-fed rivers are naturally enriched with P and other minerals and may not be
able to achieve the numeric limits set for hill-fed rivers;
The thresholds for periphyton indicators are conservative and will be naturally exceeded
by some upland rivers;
There is inconsistency in the application of QMCI thresholds, with thresholds indicating
good to excellent water quality set for the upland reaches of the main river groups, fair
to good quality set for the lower reaches of the main river groups and poor water quality
for urban streams.
The full cost and consequences of achieving the objectives has not been determined.
The objectives in Table 1 are aspirational and, in some instances, unachievable. They are
inconsistently applied with urban water bodies being treated much more leniently that rural
water bodies. The same standards should apply to all water bodies regardless of whether
they are urban or rural. In addition, it is essential that the full cost and consequences of
achieving water quality objectives is determined.
Any water quality limit setting by this plan should be done using objectives which are
achievable, appropriate for the water bodies concerned and consistently applied.
The Zone Committee collaborative approach is a more appropriate mechanism for the
establishment of catchment-scale freshwater outcomes and limits. The NPS for Freshwater
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INZ proposed Canterbury LWRP Submission 04/10/2010
Management requirement to set water quality limits could be met via the community-led
development of catchment-based plans. The NPS implementation timeframe would allow
for this. It is stated that councils may implement the requirements of the NPS by a
programme of time-limited stages, to be fully completed by 31st December 2030.
Therefore, water quality limits need not be set by this plan. If they are, then the limitations
of Table 1 (and the Nutrient Allocation Zones) need to be acknowledged. It needs to be
explicitly stated that it is the role Zone Committees to critically examine the default water
quality settings and recommend alternatives where appropriate.
Relief Sought: Amend
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Delete reference to Table 1 in its current form and refer to limits which are achievable
(in a cost-effective way), appropriate for the water bodies concerned and consistently
applied.
Acknowledge that the Zone Committee collaborative approach is a more appropriate
mechanism for the establishment of catchment-scale freshwater outcomes and limits,
with full understanding of their implications for the community.
State that it is the Zone Committees role to critically examine the default water quality
settings and recommend alternatives where appropriate, for incorporation into subregional plans.
Definitions – Relief Sought: Amend the definitions as below
34. Changed – Remove part 1 or instead relate to additional irrigated area. For part 2 it should
be rewritten as a combination of a percentage (20% - which is consistent with the error and
uncertainty associated with OVERSEER) combined with a number once a threshold is
reached to avoid rewarding poor performers (25kg/ha threshold with a +5kg/ha as the
maximum change. The explanation given in the Key Points section of INZ’s submission
justifies such an approach.
35. Efficiency – Add dynamic efficiency to the definition “.......and includes dynamic, technical
and allocative efficiency”.
36. EMS for Irrigation – This definition will need to be updated as the given methodology is
currently being updated to better account for the recent changes in the regulatory
environment. This is an INZ project, being undertaken by the same authors, and due for
completion in March 2013. The goal is now to have this work finalised before the LWRP
hearings.
37. Infrastructure – Part e) needs greater clarity. “A water supply distribution system, including
intake structures, storage, distribution structures, channels and pipes, and application
equipment”.
38. Irrigation – Irrigation is used for vegetative production - grass is grown for stock to consume!
“.......for the purpose of assisting with the production of vegetation on that land.......”
39. Profile Available Water – remove. The definition is no longer required with the changes INZ
has made to schedule 10 in its submission.
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INZ proposed Canterbury LWRP Submission 04/10/2010
40. Water body – make clear this does not include farm or irrigation races and storages
41. Add the following definitions under Water Permit Transfers
Temporary water permit transfers are of short duration, typically less than 5 years, and are
made between properties (titles) or individuals.
Permanent transfers encompass all other scenarios. However, they do not include land sale
related transfers of water permits.
Objectives
42. Objective 3.11 – This objective is unclear. It needs to be split into two objectives. However,
its content is supported.
Relief Sought: Amend
“Water is available for abstraction to support a variety of socio-economic activities”.
“Maximum socio-economic benefits are obtained from the efficient storage, distribution and
use of water available for abstraction”.
43. Objective 3.22 – It needs to be recognised that a range of methods, including regulatory,
non-regulatory, collective and individual based approaches will be used to achieve
community freshwater objectives through managing within limits.
Relief Sought: Amend
“Community outcomes for water quality and quantity are met through managing within
limits and by utilising a range of different methods so optimal outcomes are achieved”.
44. Add an additional Objective - The socio- economic importance of food and fibre production
to the Canterbury region and national economy needs to be recognised. This is consistent
with the CWMS Economic target.
Relief Sought: Add an objective
“The socio-economic contribution of sustainable food and fibre production within
Canterbury and nationally should be maintained and grown”.
Policies
45. Policy 4.1 – There are a number of issues associated with the use of values/objectives in
Table 1 to form the basis for water quality limits in this plan as outlined in the submission on
section 2.6
Relief Sought: Amend
Delete the reference to table 1 in its current form.
46. Policy 4.4 – The RMA and NPS Freshwater Management both require all values to be
balanced. The over arching basis of the CWMS, that INZ bought into, was a parallel
development philosophy that balanced the needs of communities. The priority approach
taken by the pLWRP is unhelpful and is not reflective the above.
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INZ proposed Canterbury LWRP Submission 04/10/2010
Relief sought: Oppose and Amend
Water is managed through the setting of freshwater objectives and managing within limits.
In doing this the maintenance of the life supporting capacity of ecosystems, customary uses,
provision of community and stock water supplies, water for irrigation, food and fibre
production, hydro-electricity generation and other economic activities, and the maintenance
river flows and lake levels for recreational needs should all be considered.
47. Policy 4.6 – There needs to be clear provision for the renewal of existing consents. As
catchments in Canterbury do not have common expiry, there are equity issues if a literal
approach to this policy is adopted. It needs to be made clear exception that there is an
exception for consent renewals and that over-allocation should instead be dealt with
through a separate inclusive process.
Relief Sought : Oppose and Amend
Where a water quality or quantity limit is set in Section 6-15, new resource consents will
generally not be granted if the granting would cause the limit to be breached or further
over-allocation to occur.
48. Additional Policy - There needs to be a specific policy to set out the principles as to how
over-allocation is to be resolved. This should be contained in the strategic policies section on
page 4-1.
Relief Sought: Add the policy below
Where there is an over-allocation of water quantity or quality, an all inclusive, catchment
based approach, that recognises existing investment will be adopted for its resolution.
49. Policy 4.8 – Whilst INZ agrees with the need for a regional concept for water harvest, storage
and distribution. The current blueprint has to be recognised for what it is - a concept that
will change as more information comes to hand. To date there have been limited feasibility
investigations undertaken to (no detailed geotechnical investigations for example) which
creates limitations to both the regional concept and ZIP priority outcomes. They will both
change.
Relief Sought: Support in Part
Recognise that the regional concept, as set out in schedule 16 or the ZIP priority outcomes,
is evolving in real-time - as more feasibility information comes to hand.
50. Policy 4.11 (c) (v) – It is stated That any discharge of a contaminant into or onto land where
it may enter groundwater shall … (v) not have any adverse effects on the drinking water
quality of the groundwater, including any risk to public health. It is not possible for a
contaminant to have absolutely no effects. There needs to be clarification as to what any
adverse effects means in the context of this policy.
Relief Sought: Amend
not have adverse effects on the drinking water quality of the groundwater that pose risk to
public health.
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INZ proposed Canterbury LWRP Submission 04/10/2010
51. Policy 4.19 – It is not possible to prevent sedimentation of water bodies. Natural events
occur from time to time that will result in sedimentation regardless of the mitigation taken.
Relief Sought: Amend
Replace the word prevented with managed.
52. Policy 4.26 – Either accept the amended definition of Water body in the defining section of
specifically exclude irrigation and stock races from this policy. Livestock are commonly used
to graze races for vegetation control purposes.
Relief sort: Amend Policy or Alternatively the Definition of ‘Waterbody’
Add an exemption clause for irrigation and stock water races
53. Policy 4.27 – INZ runs the Farm Dairy Effluent (FDE) Design accreditation programme which
is underpinned by the FDE Design Code of Practice and Standards. INZ is very supportive and
promotes the uptake of best practice for FDE discharges.
Relief Sought: Support
54. Policy 4.28 – INZ is not supportive of the widespread implementation of nutrient discharge
allowances through section 15. As discussed in the key points, the tools available for setting
and managing nutrient discharge allowances have many assumptions and limitations that
must be considered. If applied in their current form they would create perverse outcomes in
the achievement of water quality objectives – the Lake Taupo case study provides a good
example of this. Instead nutrient management targets should be set and managed within an
Audited Self Management framework. INZ acknowledges that in the long-term the tools will
be better developed and allow for their use with setting and managing section 15 discharges
(nutrient discharge allowance). However, until such time INZ will oppose their use for this.
Relief Support: Oppose and Amend
....... and finally, introducing nutrient discharge targets within an Audited Self Management
framework, or other alternative methods, to achieve collaboratively.......
55. Policy 4.30 – INZ is supportive of this policy as it will give primary industries time to find
solutions for the current capability and capacity gaps facing the industry.
Relief Sought: Support
56. Policy 4.31, 4.32 and 4,34 – INZ has concerns as to the achievability of this policy. Firstly
there is more to the achievement of water quality objectives than nitrogen, this must be
recognised. Secondly as there is currently no accounting system for the various drivers of
water quality, how can a proposed activity demonstrate, when assessed in combination, it
will not prevent water quality outcomes being achieved?
Relief Sought: Amend
.......by demonstrating the discharges from the proposed activity will not prevent the water
quality outcomes of Policy 4.1 being achieved.
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INZ proposed Canterbury LWRP Submission 04/10/2010
57. Policy 4.36 – INZ recognises the importance of providing for existing marae, community,
hospitals and schools wastewater discharges. However, these activities should be subject to
a continuous improvement approach and Good Management Practice operation.
Relief Sought: Amend
....... to allow the following existing discharges, providing a continuous improvement and
Good Management Practice approach is implemented.......
58. Policy 4.46 – INZ supports the provision of community drinking water supplies not requiring
compliance with flow regimes, subject to continuous improvement in water use efficiency
and restrictions (garden watering and car washing for example) at times of low flow. Stock
water should also be included (for animal welfare issues) but again subject to improvement
in water use efficiency and restrictions as appropriate.
Relief Sort: Amend
....... for group, community drinking water or stock water supplies.......
....... provided the water supply has an active asset management plan that addresses water
use efficiency, and is managed to restrict.......
59. Policy 4.47 (a) – INZ is accepting of the status quo for existing community and drinking water
supplies, subject to an asset management plan that addresses water use efficiency and
management restrictions in times of low flow (as per policy 4.46 above). However in
catchments that are fully or over allocated existing lawfully established rights must not be
derogated by further allocation of stock or domestic water supply. Such an approach will
also ensure all parties attentions are focused on working together to find solutions for overallocation.
Relief Sought: Oppose and Delete
60. Policy 4.48 – INZ is supportive of this policy as it encourages hydro-generators and irrigation
schemes to adopt a culture of continuous improvement through modernisation.
Relief Sought: Support
61. Policy 4.50 (a), (c) and (d) – These points are unnecessary. There is no need for a seasonal or
annual allocation limit on a take to storage. If the storage is not full it should be allowed to
be filled within the bounds of the catchment plans flow regime and resource consent site
specific take conditions. Points (c) and (d) should instead be replaced with a reference to the
resource consent being made consistent with the corresponding flow regime, as set out in
the catchment plan.
Relief Sought: Oppose and Delete
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INZ proposed Canterbury LWRP Submission 04/10/2010
62. Policy 4.51 – INZ supports water measurement and the use of telemetry but questions the
arbitrary 30l/s threshold. INZ has not been able to find the justification for it in the s32
report? Consistency with the Water Measurement regulation thresholds may provide a
better approach - 20l/s. However, exceptions should be allowed for in scenarios (such as
remote hill country) where there is significant cost involved in implementing telemetry.
Relief Sought: Amend
Change 30 l/s to 20 l/s and provide exclusions for exceptional circumstances.
63. Policy 4.64 – Plantation forestry is proven to adversely impact upon the hydrology of
catchments over a short timeframe, particularly in low rainfall catchments. INZ therefore
supports this policy
Relief Sought: Support
64. Policy 4.67 (b) – INZ is not supportive of defining an irrigation season within a policy.
Irrigation should be able to be applied at anytime providing it is justified (there is a soil water
deficit and the soil temperature allows for plant growth). There are also reasons to apply
irrigation for other beneficial uses, for example, frost protection, activating herbicides and
this should be allowed for.
Relief Sought: Oppose and Delete
65. Policy 4.70 – A scheme currently looking at making efficiency gains through pressure piping (gains in
water use efficiency – a CWMS target) would be adversely affected by this policy as the act of piping
will result in a loss of groundwater recharge (previously unlined open channel races).
Relief Sought: Amend
Systems to convey or apply water are designed to maximise efficient use of water, including the
improvement over time of existing systems.
66. Policy 4.71 and 4. 72 – INZ is supportive of the need for the transfer of water permits. The
reasons for this were discussed in the key points.
Relief Sought: Support
67. Policy 4.73 – The differences between a temporary and permanent transfer need to be
recognised and provided for in this policy transfers as a result of land sales also need to be
accounted for. Temporary transfers are of short duration (less than 5 years) and may be
between sites (property titles) or individuals. Permanent transfers encompass all other
scenarios however, land sale related transfers should be treated as an exception.
Over-allocation, as a first principle, should be dealt with through a catchment specific,
inclusive approach. In many catchments the solution will include the creation of ‘new water’
through water use efficiency gains and infrastructure development. Confusing over
allocation policies and with those for transfer of permits will create unintended outcomes
for the CWMS targets and must be avoided. INZ has suggested an over-allocation policy be
added to the strategic policies.
If an interim, generic method is required for dealing with transfer in over-allocated
catchments, it needs to be robust and equitable, whilst enabling dynamic, allocative and
technical efficiency gains. An appropriate proportional surrender approach for permanent
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INZ proposed Canterbury LWRP Submission 04/10/2010
transfers not related to an irrigation scheme may be justified. However, for temporary
transfers it is not.
Relief Sort: Amend and Add Temporary and Permanent Transfer Definitions to Section 2
.......irrigation scheme or is for a temporary transfer, in all other instances, except for
transfers associated with land sales, enable the transfer of water provided there is a
surrender of an appropriate proportion of the allocated water.......
68. Policy 4.76 – INZ opposes this policy. It is well proven short-term consents do not enable the
level of investment required in farm infrastructure to achieve the upper quartile of
environmental performance. They are therefore inconsistent with the CWMS targets – water
use efficiency and water quality objectives. Short duration consents will effectively create a
block to any further development in the red zone– debt financing will not be able to be
sourced to fund the mitigations required due to the increased level of risk.
Relief Sought: Oppose and Delete
69. Policy 4.86 – For some intake structures maintenance works may have no alternative but to
be carried out in flowing water, for example work is frequently required on irrigation and
stock intakes after a fresh. For smaller rivers the impact of this may be considered as more
than minor, even though the work is of very short duration.
Relief Sought: Amend
Amend the policy to make provision for works around existing intake structures to continue
to be legitimately and easily undertaken after freshes.
Rules
70. Rule 5.39 – As discussed in the key points section of this submission, achieving the
community water quality outcomes for most catchments in Canterbury will involve a whole
of farm management approach, as opposed to a limited focus on Nitrogen. It therefore be
more appropriate if nutrient budget records were kept as opposed to only nitrogen losses.
Relief Sought: Amend
An annual nutrient budget, for the period from 1st July in one year to the 30th June in the
following, is undertaken using OVERSEER and kept, and is available to the CRC upon request.
71. Rule 5.40 – Lake Zones where there is no change should be treated in the same manner as
other farming activities in Canterbury prior to the threshold date for change. The reasoning
for this is the lack of capability and capacity within the service industries. Farm
Environmental Plans need to be robust and consistent throughout Canterbury if the
approach is to be accepted. Rule 5.40 should therefore be deleted.
Relief Sought: Oppose and Delete
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INZ proposed Canterbury LWRP Submission 04/10/2010
72. Rule 5.41 – INZ is supportive of the non-notified approach in this policy. However matter 4 is
unnecessary as it is already covered by matters 1-3.
Relief Sought: Amend
Delete Matter 4
73. Rule 5.43 – As per rule 5.41 a non-notified approach is appropriate for this policy. The
expertise lies with relevant industry body, expert consultants and the CRC for the robust
assessment of an application. It is therefore not appropriate to notify the consent and create
unwarranted cost to the applicant. The establishment of a ‘best practice’ advisory panel
would be a more appropriate and robust method for the processing of land use change
applications prior to the threshold date. Also, matter 4 is unnecessary as it is already
covered by matters 1-3.
Relief Sought: Amend
Add Notification paragraph as per rule 5.41 and delete matter 4.
74. Rules 5.44 and 5.45 – As per rule 5.43 a non-notified approach is appropriate for these
policies. The expertise lies with relevant industry body, expert consultants and the CRC for
the robust assessment of an application. It is therefore not appropriate to notify the consent
and create unwarranted cost to the applicant. The establishment of a ‘best practice’ advisory
panel would be a more appropriate and robust method for the processing of land use
change applications prior to the threshold date.
Relief Sought: Amend
Add Notification paragraph as per rule 5.41
75. Rule 5.45 – As discussed in the key points of the submission, appendix 6 of the scetion32
report depicts how the water quality zones were delineated. At best these are coarse
assumptions both temporally and spatially. Non-complying activity status for the red zone
makes a presumption that the activity will generally be unacceptable. This is not appropriate
given the crudeness of the water quality assessments. Non-complying activity status cannot
be justified. Discretionary activity status would be more appropriate. Alternatively the water
quality zones need defining with greater spatial and temporal resolution. Non-complying
activity status can then be more appropriately applied.
Relief Sought: Amend
Change Activity status for red zones to discretionary
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INZ proposed Canterbury LWRP Submission 04/10/2010
76. Rule 5.46, 5.47, 5.48 and 5.49 – INZ agrees with the approach of these policies however, we
question the logistics of achieving these, unless a greater number of input rules are added to
exclude the more extensive land use activities. Logistically it will take approximately 1 year
from the plans notification to provide a robust and consistent Farm Plan template that can
be rolled out. This then leaves 4 years to develop and implement 10,000-12,000 farm plans
in Canterbury, when there is presently very limited capability and capacity. It should also be
noted Canterbury is not an island and this approach is now commonly being adopted
nationally which will lead to further capability and capacity issues. A 7 – 10 year timeframe
would be more realistic for the implementation of this policy.
Relief Sought: Amend
From 1st July 2020,.......
77. Additional Rule – INZ suggests that an additional threshold based input rule would be
beneficial to exclude extensive farming activities from Farm Plan requirements. This would
make the proceeding policies far more achievable. However, for accounting purposes, all
activities should be made to complete nutrient budgets.
Relief Sort: Add a rule based on the above
78. Rule 5.78 – INZ agrees with this rule but condition 3 needs to be rewritten as it is unclear.
Relief Sought: Rewrite
79. 5.96 (1) – INZ questions why a seasonal or annual volume is required on takes with
conditions that relate to a flow regime in a plan and with a maximum rate of take? Water
quality rules will now drive water use efficiency – excessive irrigation results in high nitrogen
leaching rates. On-farm storage opportunities (takes to storage) should not be foreclosed as
they will provide reliability and enable an efficient as and when approach to irrigation.
Relief Sought: Amend
....... any rate of take or the flow regime as set in Sections 6-15
80. Rule 5.96, 5.99 and 5.101 – Limited notification to affected parties only should be added to
these rules. There is no need for public notification as the planning process (setting the limit)
has already reflected the community values. This amendment will also help put the focus
squarely on the plan process and move away from the consent led process of old.
Relief Sought: Amend
Add a limited notification clause to each rule.
81. 5.107 (5) – As discussed in the key points section of this submission, better enabling the
transfer of water in fully and over-allocated catchments is an important mechanism for
driving improved water use efficiency and achieving water quality objectives. Rule 5.107(5)
is arbitrary - no justification can be found in the section32 analysis for the numbers given.
Over-allocation, as a first principle, should be dealt with through a catchment specific,
inclusive approach. Confusing over allocation policies and rules with those for transfer will
create unintended outcomes for CWMS targets and must therefore be avoided.
Relief Sort: Oppose and Delete
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INZ proposed Canterbury LWRP Submission 04/10/2010
82. Rules 5.109, 110 & 111 – As per Policy 4.64, plantation forestry is proven to adversely impact
upon the hydrology of catchments over a short timeframe, particularly in low rainfall
catchments. INZ therefore supports this rule.
Relief Sought: Support
83. Rules 5.129 and 5.132 – Rule BLR2 in the NRRP allowed the use of structures built before
November 2010 to be permitted, providing conditions 1-4 were complied with, and
maintained providing conditions 5-7 were complied with. In the pLWRP larger structures are
now given either controlled or discretionary activity status. This imposes unnecessary cost
and constraints on structures that have been in service and well managed for a number of
years, particularly for irrigation scheme intakes and irrigation-hydroelectricity dams. The
Dams and Damming rules should therefore be made consistent with the NRRP. These rules
have already been through considerable due process
Relief Sought: Amend
Amend Rules 5.128 to allow for the previous permitted activities of the NRRP or alternativelt
create a new rule as per Rule BLR2 in the NRRP.
Schedules
73 Schedule 2 – INZ is supportive of the move away from the prescription of mesh size and
instead the new focus on approach and sweep velocities alongside design of bypass. Recent
field work INZ has undertaken in partnership with CRC, DoC and Fish & Game has shown the
importance of each of the above to fish screen design.
Relief Sought: Support
74 Schedule 8 – The stated intention in Rule 5.46 is that Schedule 8 will be populated with
values which define the upper limit for nitrate discharges for farming activities.
The aim of the farming (nutrient management) rules must be to improve the environmental
performance of primary industries. For individuals this must be reasonable given their
current performance (some will already be performing at best-practice level) and able to be
achieved in a cost effective manner.
Because thinking is evolving along with increased information and improved understanding
of relevant processes, flexibility must be retained as to what the values in Schedule 8
represent and how they are to be used. This is crucial in order to deliver improved
performance and meet the environmental objectives of this proposed plan.
INZ believes that a key function of Schedule 8 is to provide a definition of Good
Management Practice. INZ is committed to working with ECan and other primary sector
stakeholders to define Good Management Practice, INZ’s focus will be centred on the
irrigation component of it. Any definition of Good Management Parctice should be based
on productive, profitable farms and should include all critical factors relevant to water
quality outcomes. It is essential that the definition is not solely focused on nitrate. In some
instances this will result in the needless imposition of costly constraints which have no
beneficial impact on water quality outcomes. Nitrate is not always the critical factor
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INZ proposed Canterbury LWRP Submission 04/10/2010
influencing those outcomes. A definition of Good Management Practice must include at the
very least the management of nitrate, phosphate, faecal and sediment contaminants.
75 Schedule 8 should:





Provide good management practice targets.
Take a systems approach to individual farms and to catchments with inter-related land
uses.
Provide flexibility to allow for the adjustment of farming systems.
Provide for focus on critical environmental factors (present focus solely on N will not
work in catchments where some other factor, such as P, is having most influence on
environmental indicators).
Allow for 90% of farms to be a permitted activity post-2017.
A table of rigid limits may not deliver overall improvement in water quality outcomes and
would have serious shortcomings, including the following:



It would not provide for the complexity of farming systems (depending on how and at
what level they are set).
It would not provide flexibility to allow for the adjustment of farming systems.
There is a lack of sufficiently precise tools for the purpose of assessing compliance
(OVERSEER estimates are +/-20% and based on ‘Good Management Practice).
Relief Sought: Amend
Develop Schedule 8 as outlined in the above submission. The key points are:






Retain flexibility as to what the values in Schedule 8 represent and how they are to be
used because thinking is evolving along with increased information and improved
understanding of relevant processes.
Aim to improve the environmental performance of primary industries - for individuals
this must be reasonable and able to be achieved in a cost effective manner.
Define good practice based on productive, profitable farms.
Focus on all critical factors relevant to water quality outcomes (at least N, P & sediment).
Provide flexibility to allow for the adjustment of farming systems.
Allow for 90% of farms to be a permitted activity post-2017.
76 Schedule 10 – INZ is supportive of a reasonable use test being applied to the activity of
using water for irrigation. However, the schedule needs to be amended. Firstly a list of over
arching criteria should be listed  Technical Efficiency – An irrigation application efficiency of 80%
 Timeframe – A nominal irrigation season of 1st September to 30th April
 Reliability – a demand scenario of 9 out of 10 years
The system capacity criteria should be removed. System capacity does not influence how
much water a land use activity needs, it reflects the ability of an irrigator to keep up, and is
influenced by the risk an individual is prepared to take. Also crops such as grapes and
stonefruit do not require a system capacity of 4 - 6.5mm/day!
There should be two methods available for the reasonable use test –
Method (1) Records of past use that are adjusted for Reliability and Technical Efficiency.
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INZ proposed Canterbury LWRP Submission 04/10/2010
Method (2) The use of an approved method that meets the following criteria. A set of
criteria were drawn up between Federated Farmers, INZ and ECan to find a way through the
previous NRRP WQN9 debacle! INZ has attached the ECan internal memo that contains the
set of criteria used to test and approve IRRICALC. We suggest this is included in schedule 10.
Relief Sought: Amend Schedule 10 as above
77 Schedule 16 – INZ is supportive of the inclusion of this schedule, but it needs to be
recognised that it the map will date rapidly, particularly once ground truthed feasibility
information becomes available. INZ notes the map includes no Tekapo to South Canterbury
option for movement of water across zones, this should be added. If the option for
Rangitata water moving south is shown to be unfeasible, the water from Tekapo to South
Canterbury option will then have to be further investigated.
Relief Sought: Support and Amend
Add the Tekapo to South Canterbury water movement option so the map is inclusive of all
potential water supply options for Canterbury.
INZ Submission Ends
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INZ proposed Canterbury LWRP Submission 04/10/2010