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

• f 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

supply for both Meridian and irrigators is aided by drawing down Pukaki as proposed in Plan Change 3. 3.2.2 Efficiency of water usage. The word "efficient" is mentioned 33 times in PC3. Everyone looks to an efficient

• peration as it is synonymous with maximum profit. But to get a more efficient
• peration there are greater initial costs. As more and more Waitaki water is allocated,

pressure builds on existing irrigation schemes to be more efficient. Races need lining and more buffer ponds need building and races need finer control to minimise bywash. Pressure is on farmers to get it right also (See Appendix 2). Current users should continue move towards more efficient water usage before regulation and water rating charges demand it. 3.3 Change of plan is "not a good look". A well-thrashed-out Plan needs to be changed again? This must be embarassing for all involved. The Plan is due for Review in 2016 so there will be another look at the whole thing. At least I believe there have been attempts to consult the Community. Why does it feel as though economic interests trump everything else? 3.3.1 There are some who maintain that any fresh water flowing out to sea is wasteful. This is an extreme view which could be matched by a statement that you should make do with the rainfall that you get. I think that the LWRMS takes a balanced view which deserves everybody's support. 3.3.2 There are others who maintain that it would be bad to watch river water flowing

• ut to sea when they have used up their water allocation in a dry year. Such folk may

have a point but only if they have been efficient in their use of their allocated water.

3.3.3 Many have a strong emotional response to lowering of river flow levels. Visions

• f the Lower Waitaki being reduced to a stormwater drain would be abhorrent to most

people including irrigators. I look for a reasoned, clearly managed, balanced approach by Ecan. 3.4 Recreation on the Lower Waitaki. There are more recreational users than boating and fishing. Recreation can also cover conservation efforts which are current and others which may occur in the future eg trail- bike and/or mountain bike riding. The "look" of Plan Change 3 would be improved if recreational users were expressly considered. Recreational users would also find an enhanced “River Report Infoline” helpful. 3.4.1 The Plan examines recreational use and specifically addresses boating and fishing. The effect of low flows on boating seems to ignore that previously usable channels may be too shallow for boating. The Plan dwells on the very real problem of Didymo

• instead. Fishing is already hampered by this algae.

3.4.2 There is no mention of salmon-rearing. Perhaps lower minimum flows may not affect this operations unduly. Salmon rearing depends on capture at shallow breeding area which may disappear. (I read that wetland conservators need not worry about wetlands diminishing and I hope that is true). 3.4.3 Off-road cycle trails are becoming more common. Trails exist beside many rivers throughout the country already and the Waitaki could easily offer this kind of recreation. 3.5 The environmental damage is largely ignored.

It is not that a lower minimum flow will have negligible harm. It is that harm has already been done. There are many native species under threat of extinction and human intervention is needed. 3.5.1 Ryder (S32 Report Appendix 4) may be correct in his reported statement (p 22 Report) that there is likely to be a "a slight increase to the risk of bird predation in dry years". A too-simple interpretation of this could be as follows: presently if 100 predators are faced with a swim perhaps 90 will attempt it to feed on island-dwelling bird-life, and, under new low-flows with channels shallower and slower maybe 92 would attempt the swim. The increase is slight but the predation is heavy anyway. 3.5.2 Ryder records bird experts observing that "quite small flows appearing to deter predators" (p 58 Ryder Appendix). It depends on how hungry they are, I believe. An angler has observed a feral cat swim out to an island to hunt. Maybe the "experts" have hedgehogs in mind? 3.5.3 On a positive note, it is good that the ecology of the Lower Waitaki river has received some consideration again recently. Ecan and DoC and some community groups such as the LWRMS have what could be a combined interest in reversing the decline in braided-river bird populations. They deserve assistance from the groups looking for economic gain from the Waitaki R. Appendix 1 – A simple calculation. (1) The distance from Oamaru to Timaru is 80 km. Oamaru to Palmerston is 50 km. From the coast to non-irrigable foothill country inland the average distance is about 40

• km. Take the Oamaru-Timaru area as a rectangle, the Oamaru-Palmerston area as a

triangle (= half a rectangle 40 x 50 km) and the area is 4200 sq km. Take the soil as like that of Southland. Average rainfall in this area is about 50 mm and in Southland it is about 1000 mm. (2) The Lower Waitaki river has an average annual flow of 364 cumecs and we could

take (364-150=214) cumecs for irrigation and other supply. Consumption of water from the Waitaki catchment by irrigation has been determined at 99% of all consumption. (Ref: Tonkin & Taylor 2005 p8). We can look at 212 cumecs excess flow as an annual rainfall supplement to be added to average actual rainfall to give total rainfall for the year in the area considered. (3) 212 cumecs equates to 212 x 60 x 60 x 24 x 365 = 6,690,000,000 cu m per year. Divide this figure by 4,200 x 1000 x 1000 sq m and the "depth" of rainfall over the area calculated in 1 above = 1.59 m = 1590 mm. This is 60% more than Southland rainfall. (4)Since there is about 90 cumecs required for irrigation, there is 212-90=122 cumecs (on average) non-allocated water to consider (with 150 cumecs left in the river)! Why cannot irrigators and Meridian manage this excess without requiring a further 48 cumecs? Smarter use of available water can mean that minimum flow actually works. Appendix 2. - Efficiency and irrigation method – no room for error? Least efficient to most is the progression of border-dyke to centre-pivot travelling arm water booms to fixed irrigation systems. It may be also a progression from cheapest to most expensive when it comes to watering. The last system is in use in horticulture where profits per hectare have the potential to be greatest. Farmers could justify fixed irrigation if fertiliser application and nitrate control is also in the mix. Fertigation is the word and urea application is in mind. It is not the only fertiliser for grass growth but urea added to soils provides nitrogen for grass growth and for leachates. I read that losses to the air also occur via ammonia nitrogen (up to 30-40% of applied urea - Edmeades). A fixed fertigation system (like a tree of adapted K-lines) could both apply urea solutions followed by water until moisture levels are reached (feedback from buried detectors). A paddock could be "swept" using solenoid controlled valves on watering lines and then swept again as moisture levels abate. Pivot irrigators provide a torrential

downpour every week or so. After such a downpour it is no wonder that N-levels exceed the 20 kg/ha/yr limit to be imposed by Ecan. Smart watering is available for pivot irrigators at extra cost but I still wonder if the sums are done properly to start with. If the sums are not done properly then the farm may need more money from the bank. A change in farming from owner-operator mixed-sheep dryland farm to fully irrigated dairy operation can involve a substantial loan from a bank that does not necessarily care if ownership is in New Zealand or not. Even so the farm ownership will most likely pass into a corporate structure even when the corporation is family owned and operated. Not many people in this country would enjoy seeing ownership (and profits) pass to an

• verseas-based owner. This could occur when equity vanishes through the sums not

being done properly and the receivers come in. On the other hand, many current farmers are doing very well after converting to an irrigated dairy operation and quite a few have expanded operations accordingly. It is to be hoped that with smart management all irrigators can use enough water and leave the environment in good shape as well. =========================