What are the Lower Waitaki River Management Society's main
issues with the proposed Plan Change?
- 1. Lowering the allowable minimum flow provisions
from 150 cumecs in the current Plan to 102cumecs
for summer months, the environmental impacts and how
the river and braids will look after a period of 10days at 102cumecs.
The Section 32 report (Appendix 3 under rationale) makes it clear that
the major issue is "how existing consents to take water will be
addressed give the conditions of the consents that have been granted"
after the plan become operative above the 150min flow. So the Society
feel that this proposed Plan Change is being primarily driven by Ecan
who want to avoid a legal stouch with irrigators.
We feel that this is not a sound reason to radically change the central
tenet of a Regional Allocation Plan. Moreover, Ryder in the
S32 report is insisting it is appropriate to quantify the extent of
"water shortage" using data back to 1932 rather than after the dams etc
were filled from 1979. The Society contests this and
therefore the level of hardship for Meridian to make good for reliable
irrigation. The Zone committee have been disingenuous in
publicly insisting this is not a lowering of the minimum flow and the
community has every right to be angry about this. Indeed,
Ryder and others repeatedly refer to a "change in minimum flow" in
their assessments in the s32 report.
- 2. The Society feels that the process of Plan
development under special legislation was a robust process involving
wide community participation to pro-actively
come up with bulk allocations for the 3 main activities to work within
and to optimise the allocation between National and local interest.
That broad framework was to provide certainty for the future and avoid
the mistakes we are making with endless piecemeal allocation.
So this Plan is not your average plan! We feel that abandoning the
minimum flow in the Plan (at the behest of 10? selected Zone Committee
laypeople compared to about 1,300 submitters to the draft WRP) is not
nearly as democatic or well founded. We fear it will just
open the door again to the same old process of endless river
degradation and makes a mockery of the WRP process that Society members
and the wider community put so much faith in.
- 3. Reapportionment of up to 10cumecs
for transfer from the Waitaki to augment the
waterways of South Canterbury and how this might be technically
achieved and managed. This is being promoted under
the banner of "Mahinga Kai Enhancement Allocation". The
Society feels again that this is not the full story and that it is
primarily to provide dilution to enable dairy intensification and
bywash facility for the Hunter Downs scheme. Based on the
adverse water quality impacts that have accompanied extensitve
irrigated dairying elsewhere what net environmental benefit will
actually occur if it enables similar intensification in South
Canterbury. Would this water not be better earmarked for
environmental enhancement and future generations in the Waitaki
- 4. A new allocation of
50Mm3 allocated from the environment
for irrigation in the mid river section between Kurow and Black point.
Ecan also mucked up allocation process here so to what extent is it
necessary? While its true that this does not need to directly
impact key instantaneous flows, it does represent
an additional instantaneous flow of 3.2cumecs over 6mths so will (all
else being equal) increase the frequency when flows delivered from
Meridian will result in flows below 150cumecs in the lower
river. Some additional allocation may be appropriate but it
needs to be recognised as a further take from the river.
- 5. All parties agree that the frequency of
is rare and limited when it occurs (significant 1:15 years in Ryder
report) so the Society maintains that it is no big hardship for
Meridian to just provide reliable water to all irrigators and retain
the 150cumec minimum flow. The additional
of storage/flow flexibility provided Meridian by a 5m lower minimum
water level in Lake Pukaki represents a vastly greater quantity of
water than anything they need to provide to make good any "shortage" to
fully meet irrigation demand. This additonal storage was
provided by Plan Change 1.
- 6. Change Hydrogeneration from a discretionary to
discretionary activity and what it means can not be
considered on Resource Consent renewal. Groups
trying to uphold environmental standards are weak enough in
the face of commercial interests without undermining the scope for
submissions on consent renewals. The Plan Change would move
beyond discretion any change of flow regime in future, even if
environmental effects (eg bird predation or didymo) were becoming
problematic under the existing regime. Moreover, Meridian is
no longer purely in public ownership.
- 7. The society can support the introduction of a
"reasonable use test" for using water for irrigation purposes and
the inclusion of the tributaries of the Awakino river in the allocation
limit. It may be possible for the Society to support some
additional annual allocation in the midriver section.
ECan are making a big thing in the S32 report about the wide support
the Zone Committee have for the changes and how collaboratively they
have worked. That is not the Society's experience as they
have not managed to influence anything in the proposed Plan Change over
the last 2 years or so. We also think that many in the
community would be concerned and wish to submit to uphold the
current flow regime if they knew what was actually going on.
Submissions are due on the 22 August.
(prepared by DM, posted by JA - August 7, 2014)