Proposed Land and Water Regional Plan
Further Submissions by The New Zealand Institute of Plant and Food Research Ltd.
Submitter
Plan Provision Further Submission
Support/Oppose
99 – “Oil Definition
of
Companies”
“Community or
Network Utility
Operator
Stormwater
System”
The submitter has also identified that the definition of Community or Support
Network Utility Operator Stormwater System unintentionally captures
companies. They suggest including the word “public” in the definition, Relief Sought – Accept Submission
to ensure that individual company systems are not caught.
point “D” in Schedule Four.
Plant and Food’s original submission identified that the definition of
“Community or Network Utility Operator Stormwater System” may
unintentionally capture companies or groups who have their own
stormwater systems, and the submission sought amendment to the
definition of “Community or Network Utility Operator Stormwater
System” on this basis. We consider that this submission provides a
method for addressing the original submission.
99 – Oil New Rules for The submitter seeks to address legacy discharges from sites which are
Companies
Contaminated
known to be contaminated. The Oil Companies are concerned that the
Land
general rule 5.6 would mean that all passive discharges from
contaminated sites would require a resource consent as they are not
otherwise permitted. It seeks to remedy this by introducing a
permitted framework for discharges from contaminated sites.
There is a possibility that Ecan could technically use Rule 5.6 to tidy up
legacy discharges, however this is considered to be unlikely as it would
require a significant amount of resources. However, there is merit in
this submission. Plant and Food suggest that Ecan carefully consider
the content of the proposed rules and whether the standards suggested
are appropriate for the nature of the discharge.
Page 1
Support in Part
Relief Sought – Accept submission
point “A-C” in Schedule Five to the
extent that it seeks
the
introduction of a permitted activity
framework for legacy discharges on
contaminated sites, but request
Ecan to consider whether the
proposed conditions are the most
appropriate way to determine
whether a discharge is permitted,
or whether there may be other
Submitter
Plan Provision Further Submission
Support/Oppose
suitable conditions
proposed new rule.
for
this
167
– Rule 5.7
Canterbury
Onsite
Regional
wastewater
Council
disposal
– This submitter seeks to include additional requirements for septic Oppose in part
tanks, including that the discharge shall not include any hazardous
waste. Hazardous waste is defined in the PLWRP as waste which Relief Sought – Reject part of the
includes bacteria and pathogens.
submission on Rule 5.7 which seeks
to include reference to hazardous
The purpose of a septic tank is to treat human effluent, however the waste.
discharge from these systems may have residual bacteria, and as such it
may not be possible to comply with this requirement, meaning that
there is potential for all septic tank discharges to require a consent.
167
– Rule 5.9
Canterbury
Onsite
Regional
wastewater
Council
disposal
– This submitter seeks to include additional requirements for septic Oppose in part
tanks, including that the discharge shall not include any hazardous
waste. Hazardous waste is defined in the PLWRP as waste which Relief Sought – Reject part of the
includes bacteria and pathogens.
submission on Rule 5.9 which seeks
to include reference to hazardous
The purpose of a septic tank is to treat human effluent, however the waste.
discharge from these systems may have residual bacteria, and as such it
may not be possible to comply with this requirement, meaning that
there is potential for all septic tank discharges to require a consent.
291
– New Objective
AgResearch
Ltd
Page 2
This submitter seeks to include the following new objective in the Support
PLWRP:
“The recognition that existing water takes contribute to social and Relief Sought – Accept submission
economic wellbeing and in some cases significant investment relies on point 4.0.
the continuation of those takes, including regionally and nationally
significant research facilities.”
The inclusion of this objective would assist research facilities, should
they apply for consent for renewals of water takes in future.
Submitter
Plan Provision Further Submission
Support/Oppose
291
– New Objective
AgResearch
Ltd
This submitter seeks to include the following new objective in the Support
PLWRP: “The recognition that existing discharge permits contribute to
the social and economic wellbeing and in some cases significant Relief Sought – Accept submission
investment relies on the continuation of those discharges, including point 5.0
regionally and nationally significant research facilities.” The inclusion of
this objective would assist research facilities, should they apply for
renewals of discharge permits in future.
291
– Rule 5.45
AgResearch
Farming
ltd
- This submission seeks to change the activity status of “changed” Support
farming activities which do not comply with the permitted activity
standards in rule 5.42 in the Red or Lake Nutrient Allocation Zones, Relief sought – Accept submission
from non-complying to discretionary.
point 18.0.
Plant and Food originally submitted to exempt rural research activities
from having to comply with these rules. However, should Plant and
Food’s rural research activities not be exempt from these rules, we
consider that a discretionary activity status would be more appropriate.
291
– Rule 5.48
AgResearch
Farming
ltd
- This submission seeks to change the activity status of farming activities Support
after July 2017 which do not comply with the permitted activity
standards in rule 5.46 in the Orange Nutrient Allocation Zones, from Relief Sought – Accept submission
discretionary to restricted discretionary.
point 19.0.
Plant and Food originally submitted to exempt rural research activities
from having to comply with these rules. However, should Plant and
Food’s rural research activities not be exempt from these rules, we
consider that a restricted discretionary activity status would be more
appropriate.
291
– Rule 5.49
AgResearch
ltd
Page 3
This submission seeks to change the activity status of farming activities Support
after July 2017 which do not comply with the permitted activity
standards in rule 5.46 in the Red or Lake Nutrient Allocation Zones, Relief Sought – Accept Submission
from non-complying to discretionary.
point 20.0.
Submitter
Plan Provision Further Submission
Support/Oppose
Plant and Food originally submitted to exempt rural research activities
from having to comply with these rules. However, should Plant and
Food’s rural research activities not be exempt from these rules, we
consider that a discretionary activity status would be more appropriate.
358 – Nga Rule 5.7 – OnRunanga of site wastewater
Canterbury
disposal
and
Te
Runanga o
Ngai Tahu
This submission seeks to require all existing septic tank discharges to Oppose
obtain a discharge consent as a controlled activity.
364 – Forest Various
and Bird
This submission seeks to introduce the requirement for a global
discharge permit to be obtained for all farming activities. This
requirement is considered to be unduly onerous and may penalise
farms which have only minor discharges and is not an effects-based
approach.
Page 4
Relief Sought – Reject submission
This requirement is considered to be unduly onerous.
The point relating to the activity status
environmental effects of septic tanks can be managed through of Rule 5.7.
permitted activity standards, including the relevant New Zealand
Standard, without the need for a resource consent.
Oppose
Relief Sought – Reject submission
points relating to the introduction
of a global farm discharge consent
(in relation to submission on rules
5.33, 5.34 and 5.37).