Proposed Plan Change 3 to the Waitaki Catchment Water Allocation - PDF document

Submission & Presentation to the Commissioners at the Hearings for Proposed Plan Change 3 to the Waitaki Catchment Water Allocation Regional Plan 25 June 2015 ================== 1. Name: John Anderson of Hilderthorpe, Oamaru. Quals: MSc(hons) Chemistry (Vic, NZ) Work: Taught Science, Chemistry, Computing in Secondary Schools; Computing to degree level at Southern Inst of Tech. 2. I am a current member of the Lower Waitaki River Management Society (LWRMS). I am motivated to submit not only because I support their submission, but because I have an interest in the emotional connections we all have with environment, and because I feel a duty of care for the environment on behalf of generations to follow 3. My submission of August 2014 has the following points (which I mean to amplify): 3.1 Removal of water from a river is not "sustainable management" of that river. 3.2 There may be enough water for everyone - provided allocated usage is efficient. 3.3 The reason advanced for the Plan Change 3 ("security of supply") while scoring points with irrigators manages to read badly for others. 3.4 Recreational use of the Lower Waitaki is paid lip-service. 3.5 Ryder has presented an extensive ecological impact report which ignores much of the damage already done to the Waitaki River ecosystem. -------------------------- 3.1. Minimum flow to sustain the Waitaki River. 3.1.1. What minimum flow? Although the only recorded flow of the Lower Waitaki River is made at Kurow, I

assume that the minimum flow under discussion is at or near the SH1 road bridge. While many issues have been discussed relating to the core feature of a river, it is the minimum flow which defines the river more than any other factor. ca2005 - 230 cumecs proposed ca2006 - 150 cumecs set (Aqua) ca2008 - 150 cumecs defended (NBTS) These figures (if not accurate) illustrate that (a) this is the fourth time that a minimum low flow is discussed (b) a possible plateau for 150 cumecs has been reached. 3.1.2. The Plan (proposed for Change 3 as described in S32 Report) is WCWARP (Waitaki Catchment Water Allocation Regional Plan) which specifies a minimum flow of 150 cumecs for the Lower Waitaki, and the change is to reduce this minimum flow to 102 cumecs. The Plan maintains that a flow of 102 cumecs would be infrequent as this flow will only occur during infrequent "low flow" years (p 7 S32 Report June 2014) I disagree that “low-flow” years will be infrequent. Any year could be a candidate for a "low flow" year so that 102 cumecs becomes the new minimum flow whenever security of supply requires it. Every year irrigators will require security of supply. The LWRMS identified minimum flow as the single most important characteristic of the Lower Waitaki. The figure of 150 cumecs was established at some cost, measured in dollars and citizens' time and energy. The Plan incorporates this figure and should be given a chance to work. 3.1.3 Ecan manages the Waitaki River in a sustainable way for the benefit of all. 3.1.3.1 Water Consents and Economic Uses Water for irrigation and other needs is allocated based on needs. Water consent applications for an area given to land-use eg dairying are currently checked against estimates of soil-water retention (eg soil PAW = soil profile available water) and

existing rainfall. Farmers will make an effort to maximise their allocated water and without some restraint the water available for allocation could be less than desired. Farmers late to the picnic may miss out and I wonder if there has been a stampede. 3.1.3.2 Meridian Energy dams discharge for their own needs not irrigators. Subject to the supply of water from the watersheds, and the demand from its users, the flow from Meridian Energy's dams into the Lower Waitaki can be expected to maximise income for Meridian. This usually means good down-river flows but can mean restricted flow when demand is low, or to make the most of high spot prices, and/or to allow lakes to recharge. Other users will find it hard to predict flow patterns. Meridian, while bound by consent conditions, will focus on generation of electricity to optimum levels – until 2025 when consent reviews take place, I believe. 3.1.3.3. Selling water – who owns the water? One issue that concerns me is Meridian won a consent to divert water from the Waitaki (NBTS) and this consent is being treated as an asset by HDI (Hunter Downs Irrigation). The HDI Offer Document refers to their "option to buy the water consent" from its current partner Meridian Energy. See http://www.hunterdownsirrigation.co.nz/uploads/2/3/1/6/23161336/hdil_offer_document_qa.pdf There does not seem to be a purchase of infrastructure but simply a paper transaction in which Meridian is selling water as an asset. What will Meridian charge per litre of Lake Tekapo when proposals to irrigate the Upper Pareora are discussed? 3.1.3.4. Ecan manages to some extent the recreational use of the Waitaki river. In managing the environment of the Waitaki River, the regional council should be in tune with those who seek recreation on or by the river. To me it seems that the group most directly affected by a lower minimum flow in the Lower Waitaki river are the boating/fishing users. This group would have members around the world. On the other hand many local campers can and do enjoy the river just for what it is. The feelings that

such folk have seem to be shared by people some distance away from the Waitaki. The LWRMS have found this through campaigns using the Internet. 3.1.3.5 Ecan manages the environment of the Waitaki River. The council has a clear mandate of care for the environment which it shares with the Otago Regional Council in the Lower Waitaki river and flood plains. (a) Water quality issues: Councils throughout NZ have had to cope with demands on water and increasingly intensive farming of livestock which creates drainwater pollution issues. Water is not labelled in the diagram below but it is implied by the arrows. Use enough water for Plant Uptake (X) but too little for Leaching (Y) and you have efficient usage, and lower pollution issues. (b) Flora/fauna issues : In partnership with DoC, councils deal with the problem of

declining native species and increasing weeds/predators. This might be a minor issue in the light of the Ryder report but this report only looks at the effect of reducing river flow on populations of declining desirable species. More in 3.5.1. As human intervention is the most likely way forward to halting/reversing declining populations the issues of river flow includes one of human safety. For example, as people/rangers/volunteers cross river channels to see to breeding bird colonies, low flows encourage risky wading. Ecan helps with their “River Report Infoline” which enables cellphone updates on river flow data but the data provided is minimal and could be much improved. Meridian should have an important role here, but they seem to be retreating from hourly averages to 24 hour averages which would be less useful. 3.2 There should be enough water for current needs if usage is efficient. The geography of the Waitaki catchment and the dry land farming of adjacent South Canterbury and North Otago makes for a simple first-order calculation, using annual average river flow, which is interesting. (See Appendix 1). Showing a possibility of a higher equivalent “rainfall” than Southland it demonstrates why water appears to be abundant The problem is that the flow from Meridian's dam is anything but average and water demand does not match. As the mismatch is huge (on average about 122 cumecs), there is a lot of scope for adjustment by downstreams abstractors. The LWRMS submission covers this is more detail, I believe. 3.2.1 Variability of water supply. Under-supply is the problem that water consent holders fear. As the Waitaki is controlled by Meridian - a company which profits most from maximum flow-through - the lack of flow hurts more than the irrigators. Lack of flow stems from lack of water storage as precipitation in the alps and/or the lakes. It could be worse as no clear trend can be seen from climate change except for gross melting of glaciers. Continuity of