Clause 6 of Schedule 1 of the Resource Management Act 1991
Return your signed submission by 5.00pm Friday 5 October 2012 to:
Email to: mailroom@ecan.govt.nz
or fax 03) 365-3194
FOR OFFICE USE ONLY
Submitter ID:
Full Name: Orari Water Society Incorporated
Organisation*: Orari Water Society Incorporated
* the organisation that this submission is made on behalf of
Postal Address: c/ Haidee McCabe, 42 Wilfred Rd, RD 14, Cave
Phone (Hm):
Phone (Wk): 03 308 8587 extn 4
Phone (Cell): 021 686 008
Postcode: 7984
Email: haideemccabe@irricon.co.nz Fax:
Contact name and postal address for service of person making submission (if different from above) :
Trade Competition
Pursuant to Schedule 1 of the Resource Management Act 1991, a person who could gain an advantage in trade competition through the submission may make a submission only if directly affected by an effect of the proposed policy statement or plan that: a) adversely affects the environment; and b) does not relate to trade competition or the effects of trade competition.
Please tick the sentence that applies to you:
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If you have ticked this box please select one of the following:
I am directly affected by an effect of the subject matter of the submission
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Signature: pp Date: 5 th October 2012
(Signature of person making submission or person authorised to sign on behalf of person making the submission)
Please note:
(1) all information contained in a submission under the Resource Management Act 1991, including names and addresses for service, becomes public information.
I do not wish to be heard in support of my submission; or
I do wish to be heard in support of my submission; and if so,
I would be prepared to consider presenting your submission in a joint case with others making a similar submission at any hearing
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(1) The specific parts of the
Proposed Plan that my submission relates to are:
Sectio Subn &
Page # section
/ Point
Sectio n 14 -
Pg 1
Section
14
14 pg1
14
-
(2) My submission is that:
Support/
Oppose
Reason
Support The plan is supported in its current form by Orari Water Society
Incorporated (OWS) on the understanding that it will achieve the necessary level of 80% overall reliability for existing irrigators in this catchment while achieving realistic and appropriate freshwater objectives for the catchment. B water provides a further mechanism to improve reliability of supply to in the order of 90-95% with storage in the vicinity of
50,000-100,000 cubic metres stored on an averaged sized farm. Before any more stringent minimum flows and allocations are introduced, options must be available for the irrigators to achieve the above reliability of supply.
(3) I seek the following decision from
Environment Canterbury:
Any aspects of the plan or proposed changes to the plan that do not support or achieve the outcomes sought by OWS's are opposed.
Intro Support This introduction provides a good overview of the plan's formation by the
Orari Steering Committee, of which OWS was part of. This Committee has been supported by technical experts within ECan and also those engaged by OWS. In addition to steering group meetings there have been technical meetings for experts to debate matters related to surface and groundwater hydrology including the interaction at less than 30mtrs, minimum flow regimes and allocation issues. We consider this plan has been developed as best it can with the available scientific data, resources and timeframe
14
Maintain wording as notified
Support OWS is aware of the issues generated by implementing the Pareora plan, In the event ECan's testing of several
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14 - pg2 when the first consent application was processed under the Operative
Plan. Therefore, we have requested that ECan Investigating Officers, who process consents, carry out a number of test scenarios, to ensure the plan as written actually gives effect to the intent of the Steering Committee.
This needs to be commenced promptly so the information is available prior to the hearing and to support this submission.
Intro Support The first paragraph identifies the need for increased certainty around the science within the Orari catchment. This statement is fully supported by
OWS.
The difficulty was producing and getting acceptance of the hydrological model that could reliably predict environmental flows at the bottom of the catchment, from recorded river flow at the gorge and predicted irrigation demand. The complication was that three-quarters of catchment abstraction is from groundwater that intuitively should have a delayed and reduced effect and not an immediate and equivalent effect on stream water flows. This was a fundamental issue since stream flow improvement and on-farm financial impact from reduced irrigation reliability requires a sound and accepted hydrological model. After much debate it was agreed that the conjunctive use model was applicable and that it made use of the best information available at the time. This was qualified with the caveat that the current hydrological model requires further flow information to improve confidence in its predicted outcomes. The OWS requests that all surface water flow data and water metering in the catchment, including that from land within the Rangitata South Irrigation Limited scheme (RSIL), be reviewed at the end of three years from the plan becoming operative to coincide with the proposed increased step in environmental flows. The purpose of the review will be to ensure modelled environmental flows and reliability of abstraction used by the Steering Committee in 2012 reflect reality and if they do not, to further develop the relationship between consent scenarios identifies any problems with the practical application of the plan provisons to achieve the stated objectives which are supported by OWS, any necessary amendments are made to the plan's provisons to ensure the plan functions as intended
Maintain wording as notified and in addition provide for the following:
Develop a mechanism to review environmental flows and reliability of supply, as set out in the Plan (Section 14), within three years of becoming operative.
This will ensure that any additional scientific data available from water metering and river flow records, obtained by ECan, verifies the modelling work carried out. At that time available water quality information should also be taken into account.
It is therefore, imperative that catchment flow monitoring sites are operative and collecting data. Consideration be given by
ECan staff to additional flow sites and additional scientific data to be gathered and analysed to support such a review.
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14.4 - pg2
14.4 14.4
14.4 - pg2
14.4.1 Support in part abstraction and river flow. In the event that new information does not support the model used by the Steering Committee there needs to be a mechanism to address this in a Plan review. Environmental flows proposed have been agreed to based on reliability of supply that has been modelled for abstractors, indicating at least 80% without storage. It is of critical importance that these predicted reliabilities are achieved, and if not, that there is some mechanism to rectify the situation by adjustment to the applicable minimum flows that reflect more robust and accurate data
The proposed plan states that these policies apply in addition to those set out in Section 4, of which there are 94.
Many of the Section 14 policies are based on what is notified in Section 4.
Given the plan is still evolving, if Section 4 policies change during the course of the plan becoming operative, then Section 14.4 of the plan may need to be altered to reflect any such changes. OWS would support changes to Section 4, and consequently, Section 14.4, where the changes will clarify and/or better support the outcomes sought by OWS
The members of the OWS who are involved in the RSIL scheme have reluctantly agreed to this policy being included in the plan. This policy needs to be given effect to carefully, as many farmers consider that potentially using Orari water early summer before low flows occur in late summer can mean that then the RSIL is used to take the pressure of the
Orari during late summer when the Orari River would most benefit. It should also be noted that not all farms are fully supported by RSIL shares therefore using Orari water early summer and changing to RSIL water during later summer, is the most effective way to minimise adverse effects on the Orari River. But priority at different times of the season need consideration as to what is best environmentally for the Orari River. It
To ensure simplicity in giving effect to this chapter and Section 4, cross-referencing of the relevant policies and rules is sought to be included within the plan.
The inclusion of necessary changes to the
Section 14 policies as a result of changes to Section 4 policies through this process where those changes will clarify, or better support the outcomes sought by OWS.
This policy is supported but it should possibly be clarified to ensure practicality of the situation is considered, as to when it is best to use RSIL water rather than
Orari. The end goal is that RSIL water is generally used in preference to Orari water and when the Orari River flows would most benefit from pressure on that resource being reduced.
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14.4 – pg2
14.4 – pg3
14.4 – pg3 does not necessarily mean using RSIL water first until that supply is exhausted but, particularly when the RSIL supply is insufficient to meet the users seasonal water needs, to prioritise its use when it can be of most environmental benefit
As above 14.4.2 Support in part
14.4.3 Support It is important that not only irrigators are required to reduce allocation and improve efficiency of use but all abstractors involved in over-allocated rivers including the TDC as stock and domestic water users.
14.4.4 Support This prevention of transfers of water is supported until a suitable allocation for those that are over-allocated are achieved.
As above
Maintain policy as notified and include within Table 15 the relevant flow rates referred to by this policy.
Maintain policy as notified but with the addition of the words "until overallocation is addressed, then transfers can again occur"
Maintain policy as notified 14.4 – pg3
14.4 – pg3
14.4 – pg3
14.4 - pg3
14.4.5 Support This policy is supported as it provides a mechanism for those adjacent the
Coopers Creek to relocate consents to closer to the Orari mainstem
14.4.6 Support This policy is a mechanism for all abstractions to consider their water requirements based on actual water metering data and efficiency
14.4.7 Support This policy is strongly supported as it is intended to encourage all users to operate within water user groups so that they can manage their own
14.4.8 Support in part restriction regimes. Groups should be able to manage their own flow restrictions to try and uphold stream flow levels above minimum flows for as long as possible. For those not willing to work within water user groups, it means harsher restrictions (less reliability of supply) with stepped restriction of 100%, 50% to full restrictions.
Policy 14.4.7 promotes the benefits of joining water user groups, where members of the group are able to pool their allocations during times of restriction, to make the most efficient distribution and use of water. In this situation some members of user groups may make use of other members’ allocations to continue to store water than if they had access only to their own restricted allocation. If not part of a water user group, individuals will
Maintain policy as notified
Maintain policy as notified
Support in part, with the addition of c) as follows:
(c) The water user group may access any unused water in the B allocation block for use by group members to ensure the
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14.4 – pg3
14.4 – pg3
14.4 – pg3 be subject to B block restrictions on a pro-rata basis.
It is suggested that in order to ensure an equitable use of B Block water, that water user groups can access the entire B Block water allocation. For instance, if an abstractor is not in a water user group and is not abstracting their consented water, then a water user group can access this allocation of water. Telemetry makes this option available.
14.4.9 Support The word “amount” should be replaced by “allocation”. As stated in initial sections, justification for a zone of conjunctive use was the most significant step in acceptance of environmental flows, allocation limits and reduced reliability of supply by the Orari community.
Much of this agreement is based on “goodwill” to a large extent rather than trying to analyse each consent in relation to specific hydraulic connection and therefore whether a minimum flow would apply under the usual assessments. It provides a fairness and equity amongst users. This agreement means the shallow groundwater catchment is managed as a whole “conjunctive zone” in the expectation that minimum flows will provide sufficient reliability of supply. Working collectively with all abstractions means a greater benefit environmentally to the river.
Furthermore given it is a conjunctive use zone, the provision for water user groups above the minimum flow regimes means depending on the varying effects of different abstractions, the group has their own ability to control how restrictions should apply.
14.4.10 Support In order for water users groups to work and manage restrictions effectively, it is key that all users utilise telemetry water metering
14.4.11 Support In order to ensure all water abstracted is utilised as efficiently as possible, it is essential that the industry standard of 80% water efficiency is achieved. This is considered to be an appropriate level given there is a lot of existing irrigation that may need improving even to meet this level. efficient and equitable use of the B allocation block
Maintain policy as notified but with minor correction.
Maintain policy as notified
Maintain policy as notified
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14.4 – pg3
14.4 – pg3
14.5 – pg4
14.4.12 Support This policy is supported as it facilitates diversion of water for out of stream storage subject to appropriate constraints
14.4.13 Support
14.5 in part
This policy means that with many ad-hoc minimum flows in the catchments, that abstractors can bring about consistency sooner if required by changing minimum flows to those consistent with the plan.
This is particularly important in the Coopers Creek catchment where there is inconsistency and a number of abstractors wish to change from the
Coopers Creek minimum flow to that of the Orari mainstem.
It is suggested that this policy is further expanded to clearly identify that this policy is intended for those situations where specific minimum flows on consents within smaller tributaries (such as Coopers and Petries), who may wish to change to the Orari mainstem minimum flow sooner than the review or by change of condition, are accommodated. It is intended that minimum flows developed in Table 15 can replace other ad-hoc minimum flows restrictions on these consents in smaller streams. At present the plan is unclear and it may mean that these consents would have two minimum flows; the current consent minimum flow with the addition of the mainstem minimum flow. This was not believed to be the intention and it is essential that the plan is clarified. The relief sought is intended to provide this clarification
Support This policy provides a process for abstractors to change current minimum flow conditions to be consistent with the Plan prior to Orari Catchment consents being reviewed.
The proposed plan states that these policies apply in addition to those set out in Section 5. Given the plan is still evolving, if Section 5 policies change during the course of the plan becoming operative, then Section 14.5 of the plan may need to be altered to reflect any such changes. OWS would support changes to Section 5, and consequently, Section 14.5, where the
Maintain policy as notified
Maintain policy as notified but with the addition of the following:
The minimum flows in Table 15 are intended to over-ride any other consent minimum flows within various tributaries of the catchment (see definitions) as per
Table 15 and with the addition of a supporting mechanism in the rules to achieve this policy. For example, the rules could provide that it will be a permitted activity to take water pursuant to the conditions of an existing consent to take from the relevant tributaries, but using the minimum flows prescribed for the
Orari mainstem as opposed to the minimum flow prescribed in the current consent conditions.
It is sought that to ensure clarity and ease of giving effect to this chapter and Section
5 that cross-referencing of the relevant policies and rules is included
The inclusion of necessary changes as a result of changes to Section 5 through this process where those changes will clarify, or better support the outcomes sought by
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14.5 – pg4
14.5 – pg4
14.5 – pg4
14.5 – pg4
14.5 – pg4
14.6 – pg5 changes will clarify and/or better support the outcomes sought by OWS
14.5.1 Oppose At the time the plan was being developed, the Steering Committee was considering the largely technical issue of conditions on storage impoundments if they are to qualify as permitted activities, we did not have as a reference the proposed Land and Water Plan rules. OWS considers both sets of rules should align, with dams being permitted activities, which is not the case as notified in Section 5 rules as notified.
14.5.2 Support This rule recognises that to dam the Orari below the gorge is something that must go through high hurdles environmentally, hence the noncomplying status. However given this is an over-allocated catchment it is still a possibility should in the future, a viable option come to light that is also environmentally sustainable
14.5.3 Support The gorge and catchment upstream of this, are recognised as high naturalness areas. In addition the flow regime for the catchment below the gorge is dependent on flow leaving the gorge and any disruption to this flow could have unpredictable consequences.
14.5.4 Support In Coopers Creek there is potential environmental gain from transfer of permits to the Orari mainstem and this should be encouraged and provided for. Outside Coopers Creek the priority is to reduce allocation before permits can be transferred.
14.5.5 Support This rule makes provision for those in the Coopers Creek to be able to transfer permits given this is a real possibility for a number of abstractors to reduce the environmental impacts on Coopers Creek
14.6.1 Support Instream values are a key component of the flow-setting process – they set the context of the process and, ultimately, the significance of the values determines the level of allocation and minimum flow set. This must be considered in the context of these minimum flows that whilst they may not fully meet the NES guidelines, they do deal with the situation of existing allocation, providing for
OWS.
Support in part through the deletion of this rule to allow Rule 5.128 to apply as made operative through this process, provided that all the technical issues are resolved and it is a permitted activity status.
Maintain rule as notified
Maintain rule as notified
Maintain rule as notified
Maintain rule as notified
Maintain rule/table as notified, however if
Schedule 13 of the plan remains under its current wording using average rates for surface water, then the final allocation will need to be amended to reflect the
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maintenance and some improvement of instream values and reliability of supply to the existing irrigators.
OWS also recommend that the Golder Ecology report should further analyse the Upstream of Ohapi minimum flow site based on the flow regimes proposed in Table 15. The instream habitat modelling must be at flows close to the flows being modelled for calibration reasons.
This table effectively caps the existing allocation so no more consents can be granted within the catchment to escalate the current situation.
OWS has agreed to Table 15 proposed below on that basis that it is a “package” being considered to provide the required reliability of supply essential to irrigators. In the event that these minimum flow regimes should change through this process, then OWS would need to review the entire package to ensure that overall, it still provides the required reliability of supply. This is in terms of maximum allocation being used whereby average would be essential. Effective allocation would have to be considered whereby how to apply allocation in terms of the minimum flow regimes, as this has the potential to have a huge effect in terms of reliability of supply. operative Schedule 13. The table will need to be updated accordingly.
In addition, if any change is made to Table
15 as a result of the hearing process, the whole package of minimum flow regime, allocation and how this is applied contained in Table 15 would need to be reconsidered to ensure the outcomes sought by OWS are still achieved
Include within Table 15 the relevant flow rates referred to by policy 14.4.3.
Inclusion of the TDC stock and domestic water requirements as identified in
Policy 14.4.3 is also required to be incorporated into Table 15, so that the total catchment water allocation is accounted for, for future clarity.
Orari – Upstream Ohapi
Minimum Flows (A Permits):
Current: it was decided that irrigators need a fair lead in time to make onfarm changes as a result of increased minimum flows. Therefore the
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“current” minimum flow of 200 l/s was to remain until the Plan has been operative for 3 years. Those consents that currently do not have minimum flows, can be reviewed immediately to be consistent with the current minimum flow levels, which is a improvement environmentally for the river sooner than the 3 years.
3yrs from Operative Plan: A huge amount of time was spent modelling and working through this regime proposed. It was a balance of between what was required environmentally to that required to maintain reliability of supply to abstractors. At 80% reliability of supply without storage meant it was still viable for smaller irrigators, yet there is the option for more “serious irrigators” to consider storage in order to obtain improved reliabilities as required.
2040: This is really just a vision that is consistent with the NPS. However much more scientific data and evidence would be required before any such vision was implemented in a future plan. It must consider that this is a “conjunctive use zone” within the allocation and that the Orari main stem is naturally ephemeral
Allocation (A Permits)
Current: This allocation is based on all existing consents within the catchment using maximum rates for surface water and based on degree of hydraulic connection for groundwater. Schedule 13 specifies average rates for surface water whereas we were told during developing the Orari chapter that it was to be maximum rates. The final allocation needs to be determined in accordance with the final Schedule 13
3yrs from Operative Plan: This reduction in allocation is a first attempt at
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reducing over-allocation within the catchment.
2040: This is really just a vision that is consistent with the NPS. However much more scientific data and evidence would be required before any such vision was implemented in a future plan.
Minimum Flows (B Permits)
3yrs from Operative Plan: With increasing minimum flow restrictions which will decrease reliability of supply to existing irrigators, a B Block meant there were potentially options available to overcome this. The minimum flow was selected upon an accepted formula for determining the B permit minimum flow, which provides protection for A permit holders, and the river. This is “2 x the A permit minimum flow at 3 yrs from operative + 2x the A permit allocation at 3 year from operative”.
With the provision of this B Block it means that existing users with a reliability of supply of 80% with the inclusion of realistically sized storage, can get to reliability of supply in the order of 90-95%
2040: the same minimum flow was applied here, however this vision must be considered in the context of additional scientific date and analysis.
Allocation (B Permits)
3yrs from Operative Plan: This was an agreed value.
2040: the same allocation was applied here, however this vision must be considered in the context of additional scientific date and analysis
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14.6 – pg5
14.6 – pg5
14.6.1 Support Ohapi Creek at Houstons
Minimum Flow: The current minimum flow is recommended to remain.
This flow was set as a result of Environment Court mediation and has worked well over the past 15 years. The Ohapi catchment will have a conjunctive use zone so that abstractors taking from shallow groundwater will be tied to the minimum flow where currently they are not.
Allocation: This allocation is based on all existing consents within the catchment using maximum rates for surface water and based on degree of hydraulic connection for groundwater. Schedule 13 specifies average rates for surface water whereas we were told during developing the Orari chapter that it was to be maximum rate of take. The final allocations needs to be determined in accordance with the final Schedule 13
The Golder ecological report supported retaining the status quo, however the ecological work was not as robust as it could be. The instream habitat modelling was attempted however we consider ECan need to undertake further instream habitat modelling to robustly support the minimum flow regime and allocation proposed.
14.6.1 Support Rhodes Stream at Parke Rd
Minimum flow and allocation: OWS support retention of current allocation and minimum flow as there is insufficient flow data to consider alternatives. The ecological report supported retaining the status quo until data is available. However it is essential that the required hydrological information is gathered so that effective ecological assessments can then be carried out to set a future minimum flow.
Maintain rule/table as notified, however if
Schedule 13 of the plan remains under its current wording using average rates for surface water, then the final allocation will need to be amended to reflect the operative Schedule 13. The table will need to be updated accordingly.
In addition, if any change is made to Table
15 as a result of the hearing process, the whole package of minimum flow regime, allocation and how this is applied contained in Table 15 would need to be reconsidered to ensure the outcomes sought by OWS are still achieved.
Maintain rule/table as notified, however if
Schedule 13 of the plan remains under its current wording using average rates for surface water, then the final allocation will need to be amended to reflect the operative Schedule 13. The table will need to be updated accordingly.
In addition, if any change is made to Table
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14 - 6
14 - 6
14 - 6
14.6.2
14.8
Definiti ons
Support
Support
Support the allocation limits
Support
Support The definitions included within this plan are an important element and are supported
15 as a result of the hearing process, the whole package of minimum flow regime, allocation and how this is applied contained in Table 15 would need to be reconsidered to ensure the outcomes sought by OWS are still achieved.
Maintain wording as notified
Maintain wording as notified
Maintain wording as notified
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