Plan Change 7 and Plan Change 2 - What you need to know

Environment Canterbury has notified Plan Change 7 to the Canterbury Land & Water Regional Plan (CLWRP) and Plan Change 2 to the Waimakariri River Regional Plan (WRRP) for public submissions. Read the overview presentation (PDF File, 5.09MB) and the information below to find out more about what this might mean for you.

The period for submissions on proposed Plan Change 7 to the CLWRP and proposed Plan Change 2  to the WRRP is now closed.

 

What happened on 13 September?
What is Plan Change 7 to the Canterbury Land & Water Regional Plan about?

Plan Change (PC) 7 is a proposed plan change to the Canterbury Land & Water Regional Plan (CLWRP).

The LWRP sets out the planning framework for the management of land and water resources in Canterbury.

It is one of the key methods for implementing the Canterbury Water Management Strategy, a community-led collaborative approach to improve freshwater outcomes throughout the region.

PC7 is split into three parts (Parts A, B and C).

Part A

Part A is an ‘Omnibus’ change proposing amendments to region-wide provisions (policies, rules, maps and schedules).

Part A aims to:

  • Improve freshwater outcomes for Canterbury
  • Protect habitats of indigenous freshwater species
  • Enable consideration of Ngāi Tahu values in relation to a broader range of activities
  • Provide the use of managed aquifer recharge (a technique to improve the volume and quality of groundwater) across the region
  • Establish a new nutrient framework for commercial vegetable growing operations
  • Implement recommendations from the Hinds Drains Working Party.

Parts B and C

Parts B and C of PC7 relate to the Orari Temuka Opihi Pareora (OTOP) and Waimakariri sub-regions respectively.

These parts have been developed in collaboration with the Waimakariri and OTOP Zone Committees, and implement recommendations in the Zone Implementation Programme Addenda (ZIPAs).

Key changes introduced by Parts B and C include:

  • New water quality limits for groundwater and surface water
  • Requirements for farms to further reduce nitrogen losses over time
  • Increases to minimum flows for rivers and streams
  • A cap on the volume of water available for allocation
  • Requirements to exclude stock from a broader range of waterbodies.
What is Plan Change 2 to the Waimakariri River Regional Plan about?

Plan Change 2 (PC2) is a proposed plan change to the Waimakariri River Regional Plan (WRRP). The WRRP promotes sustainable management of surface water and hydraulically connected groundwater within the Waimakariri catchment.

PC2 is the first step in a move to bring all rules relating to the Waimakariri sub-region into a single planning document – the Land & Water Regional Plan (LWRP). The WRRP would continue to apply to activities within the main stem of the Waimakariri River, its upper catchment, and tributaries south of the mainstem.

Activities in the rest of the Waimakariri sub-region would instead be managed by the LWRP (including provisions in section 8 which apply specifically to the Waimakariri sub-region).

Can the Zone Implementation Programme Addendum for OTOP and Waimakariri be changed?

No. Once the ZIPAs have been accepted by Council they are final – this happened last December. There is now the opportunity to have your say on the content of the proposed plan changes through a public submission process.

What happens next?

Now the submission period has closed, a summary of the decisions requested will be prepared by Environment Canterbury staff and publicly notified for further submissions later this year.

Following this, a public hearing of submissions and evidence will happen. 

The hearing in front of an independent hearing panel is likely to be held during the first half of 2020.

The independent hearing panel will prepare a set of recommendations for Council to consider and potentially adopt as its decision.

Do the rules in proposed Plan Change 7 and proposed Plan Change 2 apply now?

The rules in both plan changes are now legally effective. However, new activities and those established before notification of the proposed plan changes (20 July 2019) are treated differently.

New activities

  • New activities must comply with rules in both the relevant operative plan and in the proposed plan changes.
  • If an activity cannot meet the requirements of a ‘permitted activity’ rule in both the operative plan and proposed plan changes, a resource consent will be required.

Existing activities

  • An existing activity is one that was established before notification of the proposed plan changes on 20 July 2019.
  • Where an existing activity is permitted under the operative plan, but requires a resource consent under rules in the proposed plan changes, the activity may continue without a resource consent up until 6 months after the plan change becomes operative. Certain criteria apply, including that the activity was lawfully established and there is no change in its scale, intensity or character.
Will the proposal for a new National Policy Statement for Freshwater Management (NPS) mean the plan changes will themselves need to be changed?

Not at this stage. The Government has released consultation material indicating changes it is considering making to the freshwater planning framework.

The consultation material has no statutory weight. The current National Policy Statement for Freshwater Management 2014 (amended in 2017) is the relevant National Policy Statement to which Plan Changes 7 and 2 must give effect.

If a new NPS is gazetted before the independent hearing panel delivers its recommendations on PC7/PC2, the panel will consider the contents and relevance of the NPS when preparing its recommendations.

 

Plan Change 7 is in 3 parts:

Omnibus (Part A)
Why is this needed?

The Land & Water Regional Plan (LWRP) has been operative for 7 years and there have been changes in that time which now need to be taken into account across the region.

Changes are proposed to make sure the LWRP responds to new directives from central government, emerging environmental issues, and changes in matters that are strategic priorities for Environment Canterbury.

Proposed changes to policies, rules and schedules cover the following key topic areas:

  • National Policy Statement for Freshwater Management
  • National Environmental Standards for Plantation Forestry
  • Ngāi Tahu outcomes
  • Habitats of indigenous freshwater species
  • Fish passage
  • Freshwater bathing
  • Commercial vegetable growing operations
  • Hinds Drains Working Party recommendations
  • Managed aquifer recharge
What changes are proposed?
Ngāi Tahu values

Part A introduces a new cultural outcome for lakes and rivers in Canterbury, with the objective that freshwater mahinga kai is abundant and safe to gather.

This outcome is delivered partly through new policies and rules which place restrictions on activities that that could reduce the quantity or quality of freshwater.

In addition, Part A of PC7 proposes to change 23 rules to enable decisionmakers to consider the potential effects of activities on Ngāi Tahu values and customary activities. Changes are also proposed to templates for Farm Environment Plans (Schedule 7) and Farm Management Plans (Schedule 7A).

The proposed changes would require farmers to identify all waipuna (springs) on their farm, and describe the actions they will implement to minimise effects on water quality.

Salmon spawning sites

The LWRP includes Schedule 17 which lists significant salmon spawning sites in Canterbury.

Part A of PC7 proposes to add 32 additional salmon spawning sites into Schedule 17, 22 of which are new sites located throughout Canterbury.

An additional nine sites that are currently listed in the Waimakariri River Regional Plan are proposed to be transferred to the LWRP.

The inclusion of these additional sites would mean additional restrictions applied to activities that could damage spawning sites. Restrictions include prohibiting access by farmed cattle, deer and pigs into salmon spawning sites.

Habitats of indigenous freshwater species

Habitats of 11 indigenous freshwater species (including native fish, mussels and crayfish) have been identified and will be included on the LWRP planning maps.

New policies require damage to indigenous habitats to be avoided, except where the adverse impacts can be offset through the creation of new habitats. Proposed changes restrict the types of activities that may occur as a permitted activity within a mapped habitat area.

Activities with the potential to cause direct damage to habitats (such as vegetation clearance and earthworks) or indirect damage (abstraction of water, for example), must obtain a resource consent and the effects of the proposal on the habitat will be considered and assessed.

Fish passage

New policies direct that safe passage of indigenous fish through instream structures and barriers is to be provided for. New in-stream structures are to be appropriately designed and constructed to enable safe fish passage, and users are encouraged to modify or remove existing barriers to fish passage.

Will the proposed changes relating to protection of indigenous freshwater species habitats and improved fish passage result in more consents being required?

Resource consents would be required for activities that occur within, or adjacent to mapped indigenous freshwater habitat areas.

In addition, activities which significantly compromise the values of a habitat (such as farmed cattle, deer or pigs in a habitat) would be prohibited.

Changes to provide for safe fish passage would not increase the number of resource consents required. However, if the installation of a structure in a river or lake requires a resource consent, there would be an expectation that the structure is designed and constructed to enable fish passage.

Additional information about freshwater fish habitat mapping

The below report ‘Mapping of non-migratory freshwater fish habitat fragment distributions’ is a reference document in the Plan Change 7 memo: Prioritisation of native aquatic species habitat for protection under the LWRP Omnibus plan change.

This report was not released as part of the supporting material when Plan Change 7 was notified. At the request of an interested party during the submission period, this has now been made available.

Download report 'Mapping of non-migratory freshwater fish habitat fragment distributions. New Zealand Department of Conservation P22' (PDF File, 4.63MB) – Dunn, N.R. (2019)

Freshwater bathing sites

What changes are proposed?

PC7 proposes to add an additional 64 freshwater bathing sites into Schedule 6 of the LWRP. Farmed cattle, deer and pigs would need to be excluded from waterbodies upstream of any freshwater bathing site listed in Schedule 6.

How were the freshwater bathing sites identified?

A combination of information sources were used to identify the new freshwater bathing sites. Sites included in Schedule 6 include those identified in the ‘River Values Assessment System’ report as having high recreational values, sites monitored as part of Environment Canterbury’s recreational water quality monitoring programme, and sites identified by zone committees as popular freshwater bathing sites.

Why do farmed cattle, deer and pigs need to be excluded from freshwater bathing sites? What are the associated costs of doing this?

Livestock can contribute to degraded water quality through increased sedimentation (from pugging and damage of the bed and banks), and can increase the risk of pathogens entering waterways.

The costs of excluding stock from waterways would depend on the topography of the location, and the method used to exclude the stock (such as full fence, hot-wire or alternative method).

Commercial vegetable growing
What’s the issue with commercial vegetable growing?

Unlike traditional farming enterprises such as dairy, sheep and beef operations, commercial vegetable growers frequently need to relocate their crops to new locations to prevent crop disease. Growers typically achieve this by rotating crops through a combination of permanently owned land and short-term lease.

The LWRP include rules to manage the impacts of farming activities (including commercial vegetable growing operations) on the environment. These rules include property-based nitrogen limits which restrict how much nitrogen may be leached from a property. The current rules allocate nitrogen based on land use from 2009 to 2013. The current framework poses two problems for growers:

  • Nitrogen loss rates for the 2009 – 2013 period may not be available if the land is no longer part of the commercial growing operation (for example, if the land was subject to a short-term lease).
  • New land available for lease often does not have a high enough nitrogen ‘baseline’ to accommodate ongoing operations.
How does Part A of PC7 address these issues?

Part A of PC7 proposes a new framework to manage nutrient losses from commercial vegetable growing operations. All commercial vegetable growing operators must obtain a land use consent for their activity, prepare and implement a Farm Environment Plan, and have that plan regularly audited.

Commercial vegetable growing operators must restrict the area of land used for the growing operation to an area that is no larger than that used during the 2009 – 2013 period. Growers must also demonstrate how they will achieve any nitrogen loss reductions required by a sub-region section of the plan.

Expansions of existing commercial vegetable growing operations, or the establishment of a new commercial vegetable growing operations may occur, but only if the grower can comply with nitrogen limits that apply to land at a new location.

If land that is used, or intended to be used, for commercial vegetable growing operations is located in a different sub-region or Nutrient Allocation Zone, growers have two options when applying for resource consent.

They could choose to lodge separate applications for each sub-region or Nutrient Allocation Zone that they grow in, or they could lodge one application for an operation that spans multiple sub-regions or Nutrient Allocation Zones.

The first option means only matters listed in Rule 5.42CB would be considered when a proposal is assessed, while under the second option a wider range of effects of the proposal may be considered.

Managed Aquifer Recharge
What is it? Where is it happening?

Managed Aquifer Recharge (MAR) systems allow high-quality clean water to infiltrate the ground to recharge groundwater and hydraulically connected surface waterbodies.

MAR systems are typically used to recharge aquifers subject to declining yields, address saltwater intrusion, or sustain/improve the functioning of ecosystems and the quality of groundwater.

Has MAR been tested? Is it working?

A MAR system has recently been trialled in Canterbury in Hinds/Hekeao using water sourced from the Rangitata River. The results to date have shown improvements in the quality of localised groundwater. A further 16 trial sites have been consented in the Mayfield-Hinds and Valetta catchments and a further two sites in the Waimakariri District.

Find out more about the MAR project and the completion of the third year of operation.

Why do MAR systems require a resource consent?

MAR systems involve large quantities of water being abstracted from surface water and discharged into groundwater. Oversight of these systems (by way of a resource consent) is required to ensure the potential adverse effect of these activities can be considered and managed.

Hinds Drains
Why are the Hinds Drains a specific focus of Part A of the plan change?

Part A responds to recommendations made by the Hinds Drains Working Party to the Ashburton Zone Committee. These recommendations were not available before the notification of Plan Change 2 to the LWRP (Hinds / Hekeao Plains Area).

What’s the issue? Shouldn’t abstractors be switching from groundwater to surface water rather than vice-versa?

The new provisions provide a more enabling framework for consent holders to substitute their existing surface water or stream depleting groundwater consents for deeper groundwater. This approach will enable a reduction in over-allocation in lowland streams.

Why has an extension for flow allocation limits been provided?

The Hinds Drains Working Party and the Ashburton Zone Committee recommended retaining the current minimum flow sites on the basis that managed aquifer recharge and targeted stream augmentation will probably have an influence on waterways. Those impacts need to be clearly established before minimum flow limits are set.

Orari Temuka Opihi Pareora (Part B)
How does Part B of PC7 ensure a safe supply of drinking water?

With new water quality limits for drinking water supplies that are consistent with the NZ Drinking Water Standards. In addition, Part B includes methods to maintain current good water quality, and improve degraded water quality over time.

How does the plan change improve water quality for recreational values?

The freshwater outcomes for the OTOP sub-region are set to maintain existing good water quality, or improve water quality where it is currently degraded. Improved water quality will mean that some rivers will meet national standards for swimmable contact recreation and improved habitat to encourage and enable mahinga kai gathering.

What does Part B of PC7 do to protect cultural values and provide for mahinga kai?

New polices are proposed to provide protection to wāhi tapu, wāhi taonga, nohoanga, waipuna and tuhituhi neherā.
In addition, a ‘Mātaitai Protection Zone’ and a ‘Rock Art Management Area’ have been identified and new restrictions imposed on activities within these zones/areas.

Farmers in these zones would need to obtain a land use consent for their farming activity, prepare and implement a Farm Environment Plan, and have that plan regularly audited.

How does Part B of PC7 improve outcomes for ecosystems?

New environmental flow and allocation regimes have been proposed for parts of the OTOP sub-region. Higher minimum are proposed to be introduced over time, which would ensure more water is retained in the river to provide for ecosystem values.

What effect will higher minimum flows have on abstractors?

An increase to minimum flows would reduce the reliability of water for abstractors. However, the introduction of new minimum flows have been staged, allowing time for irrigators and industry to adapt to proposed changes.

How close are the provisions to the Zone Committee’s Zone Implementation Programme Addendum (ZIPA)?

The provisions in Part B of PC7 substantially implement the recommendations in the OTOP Zone Committee’s ZIPA. Key differences between recommendations in the ZIPA and Part B of the plan change include:

  • The introduction of the ‘Mātaitai Protection Zone’ and ‘Rock Art Management Areas’. These areas had not been mapped at the time the ZIPA was prepared and have subsequently been introduced, together with additional restrictions on activities in these zones.
  • A revised management regime for management of surface water flows downstream of the Opuha Dam has been developed since the ZIPA was finalised. The framework aligns with the principles included in the ZIPA.
Ngāi Tahu culture
Why have rules been included to protect rock art? Isn’t there another way?

The OTOP sub-region has one of the highest densities of rock art sites in New Zealand. These sites are taonga (treasured/sacred) to Te Rūnanga o Arowhenua and Te Rūnanga o Waihao who actively contribute to their conservation and management.

Rock art is typically found on limestone outcrops and some activities (such as irrigation, discharges and land uses) can cause damage to rock art if not appropriately managed. Part B of PC7 would require farming activities with irrigation in the Rock Art Management Areas to obtain a resource consent. This process allows the potential effects of a farming activity to be assessed on a case-by-case basis.

Why is a Mātaitai Protection Zone proposed? Why do more restrictive rules apply to farming activities in these areas?

A Mātaitai Protection Zone is proposed, together with new restrictions on farming activities, to protect the quality of water around the mātaitai (customary fishing area). New rules require a resource consent and audited Farm Environment Plan for any farm in the zone that directly adjoins a surface waterbody and which carries out irrigation or winter grazing of cattle.

The Mātaitai Protection Zone also contains a predominance of waipuna (springs) which are taonga (treasured/sacred) to Ngāi Tahu. Waipuna are vulnerable to pollution, damage or destruction from a variety of activities. Protecting waipuna in the OTOP sub-region by including new restrictions on farming activities is important for protecting biodiversity and mahinga kai values.

Nutrient management
What’s the issue for OTOP?

Technical investigations have shown that freshwater quality across the sub-region generally meets water quality limits in the National Policy Statement for Freshwater Management (NPFSM) and the Drinking Water Standards for New Zealand. However, there are localised areas where elevated concentrations of nitrate-nitrogen have been detected in groundwater (referred to as ‘High Nitrogen Concentration Areas’).

Within these areas, farming activities would be required to further reduce their nitrogen losses over time. Reductions of 10% (for dairy) and 5% (for other farming activities) would be required by 2030, with a further 10% and 5% respectively by 2035.

Will more resource consents be required for farming activities in the OTOP Zone?

Yes. More farms would require a resource consent under proposed PC7. Irrigated farms within a Rock Art Management Area would be required to obtain a resource consent, as would farms in the Mātaitai Protection Zone with any irrigation or winter grazing of cattle or deer.

Where can I see the High Risk Runoff Phosphorus Zone?

The High Risk Runoff Phosphorus Zone (HRRPZ) is an operative Canterbury Land & Water Regional Plan (LWRP) map layer. Plan Change 7 (PC7) does not propose any changes to the extent of the HRRPZ so it is not in the notified PC7 maps.

How to view High Risk Runoff Phosphorus Zone Maps

Canterbury maps

You can view the maps on Canterbury Maps (click the ‘Add Data’ icon at the top, search “High Risk Runoff Phosphorus Zone” and then click to add the layer).

Instructions how to add layer

Download PDF

You can view the HRRPZ on the operative LWRP Planning Maps. Download the PDF map sheets.

Rivers and streams
What impact will Part B of PC7 have on minimum flows in rivers?

The Orari and Pareora Freshwater Management Units (FMUs) have recently been subject to plan changes that introduced revised surface water and allocation regimes. No significant changes to the allocation framework are proposed.

Within the Temuka and Opihi FMU, new environmental flow and allocation regimes are proposed, with stepped increases in minimum flows over time.

Will the plan change reduce problems with algae in our local rivers?

It is anticipated new the inclusion of higher minimum flows for rivers and additional restrictions on farming activities may help reduce algal blooms in rivers.

What does Part B of PC7 mean for the role of the Opihi Environmental Flow Release Advisory Group (OEFRAG)?

OEFRAG would still provide advice to Environment Canterbury on water shortage directions sought under section 329 of the Resource Management Act. Water shortage directions may be issued when there is a serious temporary shortage of water.

Are rules better than discretion in times of water shortage?

Yes. To date water shortage directions have been sought regularly and on a pre-emptive basis to prevent potential water shortages during the irrigation season.

The flow and allocation regime and minimum lake levels in the Opihi River Regional Plan (ORRP) are not appropriate if the community’s aspirations for the Opihi River are to be met. The proposed flow and allocation framework introduced by Part B of PC7 is considered a more effective method for managing releases of water from the Opuha Dam, while also ensuring community outcomes are achieved.

What changes are proposed for the Opihi / Temuka catchments?

In the Opihi Freshwater Management Unit (FMU) an alternative regime is proposed to manage releases of water from the Opuha Dam. Allocation of freshwater has been capped at current rates and partial restrictions are proposed to prevent minimum flows for the river from being breached.

The Temuka FMU is over-allocated and experiences high abstractive pressure. A range of flow and allocation regime is proposed with prohibitions on the transfer of water, increases to minimum flows for the Temuka River and its tributaries, and phasing out of over-allocation through reductions in allocation limits over time (at 3, 5 and 8 year intervals).

What is a ‘Mahinga Kai Enhancement’ allocation (cultural allocation) and why is it there?

The Temuka River is culturally significant to Ngāi Tahu. In recognition of this, an allocation of water (100 litres per second) has been reserved for activities that will enhance mahinga kai outcomes. The allocation would be available from 1 January 2035.

Where can I find water quality data for the Opihi and Temuka catchment?

The information below was not released as part of the supporting material when PC7 was notified. At the request of interested parties, this data has been made available during the submission period. The reports which were informed by this data are available under ‘Supporting documents and disciplines

Water Quality Data for the Opihi and Temuka Catchment

This folder contains the following raw data for the Opihi and Temuka Catchment:

Please also note that for sites that are part of NIWA’s national rivers water quality network this must be requested directly from NIWA or from LAWA.

Where can I find water quality data for Opihi River tributaries?

This document contains the availability data for Plan Change 7 flow regimes for the Opihi River tributaries. This is a daily time series of percent availability and has been extracted from the model.

This evaluation reflects the Zone Implementation Programme Addendum recommendations and is the data used in the technical reports. It does not account for the changes made to the alternative Opihi mainstem flow regime made in the final plan drafting and Schedule 1 consultation.

Data requests

The documents below were not part of the supporting documents and technical reports released when Plan Change 7 was notified.

Where interested parties have made requests for specific information throughout the submission period it has been made publicly available below.

Water quality data for the Opihi and Temuka Catchment

At the request of interested parties, this data has been made available during the submission period.

At the request of interested parties, Water Quality Data for the Opihi and Temuka Catchment has been made available during the submission period.

Below you can find the raw data for the Opihi and Temuka Catchment:

Please also note that for sites that are part of NIWA’s national rivers water quality network, this must be requested directly from NIWA or from LAWA.

Flow availability for the Opihi River

This document contains the availability data for Plan Change 7 flow regimes for the Opihi River tributaries. This is a daily time series of percent availability and has been extracted from the model.

This evaluation reflects the Zone Implementation Programme Addendum recommendations and is the data used in the technical reports. It does not account for the changes made to the alternative Opihi mainstem flow regime made in the final plan drafting and Schedule 1 consultation.

Lower Opihi River ecological flow assessment

This report is an assessment of the impact of flows in the Lower Opihi River on the habitats of aquatic species. It was finalised in August 2019 and did not inform the Section 32 Report or the proposed Plan Change.

 

Waimakariri (Part C)
How close are the provisions to recommendations in the Zone Implementation Programme Addendum (ZIPA)?

The provisions in Part C of PC7 generally implement the recommendations in the Waimakariri Zone Committee’s ZIPA. Key differences include:

  • Some allocation limits proposed in Part C of PC7 are different from those recommended in the ZIPA. The reason for this is that additional technical work was carried out after the ZIPA was finalised in December. This has informed the development of allocation limits.
  • A new zone – the ‘Ashley Estuary (Te Aka Aka) and Coastal Protection Zone’ has been introduced and additional restrictions on farming activities and discharges are proposed within this zone. These controls have been included to help with achieving water quality outcomes for the estuary.
Nitrate
What’s the story with nitrate, particularly in relation to Christchurch drinking water and health impacts?
How will PC7 address nitrate issues in groundwater?

Part C of PC7 proposes new nitrogen limits for surface water and groundwater in the Waimakariri sub-region. New rules are proposed to limit the amount of nitrate-nitrogen that enters groundwater. For more information on these proposed rules, see below.

Nutrient management

Part C of PC7 includes a framework to manage the diffuse loss of nutrients from farming activities. This is based on the region-wide ‘Red Zone’ framework, but has been modified to ensure outcomes for the Waimakariri sub-region are achieved.

Key differences include:

  • a reduction in the area of winter grazing of cattle allowed on a property as a permitted activity
  • requirements for audited Farm Environment Plans for a larger number of farms
  • establishment of a Nitrate Priority Area (and Sub-Areas A, B, C, D and E)
  • a requirement for farms in these areas to reduce nitrogen losses, in stages
What are the impacts for owners of lifestyle blocks?

Lifestyle block owners carrying out farming on small properties (less than 5ha in area) are permitted activities under the proposed framework.

Farms on properties over 5ha may still be permitted, provided they limit the areas used for irrigation and winter grazing of cattle in line with conditions in the proposed rules. Farmers who do not meet these requirements will need to obtain a land use consent, comply with property-based nitrogen limits and implement an audited Farm Environment Plan.

What nitrogen limits must farmers achieve?

Nitrogen limits only apply to farms which require a land use consent. Farms with a larger area of irrigation or winter grazing than is allowed under the permitted activity rules would need to comply with the ‘Baseline GMP Loss Rate’. The Baseline GMP Loss Rate is a nitrogen limit that reflects activities between 2009 and 2013, but which has been modified to take into account the implementation of Good Management Practice.

Further reductions in nitrogen loss (beyond the Baseline GMP Loss Rate) would be required at 10-year intervals, with the first stage of reduction required to be met by 1 January 2030. The number of stages of reduction required depends on which Nitrate Priority Sub-area the property is located in. The stages of reduction required for each sub-area are:

  • Sub-area A – 2 stages
  • Sub-area B – 3 stages
  • Sub-area C – 4 stages
  • Sub-area D – 5 stages
  • Sub-area E – 6 stages

The size of the reduction required depends on the type of farming being carried out. Dairy operations are required to reduce nitrogen losses by 15% (at each stage), while all other types of farming are required to reduce by 5% (at each stage).

Why are the nitrogen loss reductions proposed in stages?

A staged approach to the reductions takes into account the feasibility of achieving the required reductions and the economic impacts these reductions would have on a farmer.

Will the reductions be sufficient to achieve community outcomes/expectations?

Detailed modelling indicates that the proposed reductions are sufficient to achieve the nitrogen limits included in the plan change.

Farming groups are saying the nitrogen loss reductions for 2030 are unachievable. How will farmers achieve future nitrogen loss reductions beyond 2030?

Reducing nitrogen losses below the Baseline GMP Loss Rate will be challenging for some landowners. However, economic assessments indicate that these reductions are achievable, and it is anticipated that advances in technology and development of future mitigations will farmers to achieve these reductions.

How will irrigation companies be impacted by the proposed nutrient management framework?

All farms, including those which have their nitrogen losses managed by an irrigation scheme, would be required to comply with the nutrient management framework in Part C of PC7, including requirements to reduce nitrogen losses in the Nitrate Priority Area.

How will PC7 ensure there’s a safe supply of drinking water in the Waimakariri zone?

PC7 proposes water quality limits for drinking water supplies that are consistent with the NZ Drinking Water Standards. In addition, rules in the region-wide section of the LWRP restrict the type of activities that may happen with the protection zone of a Community Drinking Water Supply or a private bore. The nutrient management framework is expected to contribute to reductions in nitrate concentrations in drinking water over time.

What is the Nitrate Priority Area (NPA)?
The Nitrate Priority Area (NPA) is a defined area within the Waimakariri sub-region where reductions in nitrogen loss from farming activities are required beyond the Baseline GMP loss rate.
Why is the NPA needed?
The NPA is needed to manage nitrate loss from land to achieve the proposed nitrate concentration limits and targets for downstream receiving water bodies (surface water and groundwater receptors). The nitrate limits and targets are set to maintain existing good water quality or improve water quality where it is currently degraded.
How was the NPA boundary drawn?
The NPA boundary was drawn to include the following areas:
  • Groundwater recharge zones for large community supply wells (more than 5000 people) and for community and private water supply wells where nitrate concentrations are projected to exceed half the maximum acceptable value for nitrate in drinking water
  • Groundwater recharge zone for the deep Christchurch aquifers
  • Surface water catchments that generally drain to ground (for example, the Eyre River)
  • Silverstream catchment where the surface water nitrate concentration is above the national bottom line.

The boundary was adjusted to align with:

  • Local paddock or property boundaries
  • Proposed Waimakariri sub-region boundary

The boundary excludes:

  • Areas of poorly drained soils (unless these are included in the approach outlined above); and
  • Ashley River / Rakahuri catchment where runoff contaminants (sediment, phosphorus, or microbiological contaminants) are having the greatest impact on surface water quality and where nitrate toxicity effects are limited.
What are the Nitrate Priority Sub-areas?
The Nitrate Priority Area is divided into five sub-areas (A – E). Each sub-area requires a different number of staged reductions in nitrogen losses to achieve the nitrate limit or target in the receiving waterbody (receptor).
  • Each stage of reduction covers a 10-year period
  • The starting point for reductions in nitrate loss is generally the property’s Baseline GMP loss rate
  • The number of stages of nitrate loss reduction for each property depends on the downstream receptor that farm affects (illustrated in Map 1 and summarised in Table 1 below)
  • All sub-areas require at least two stages of nitrate loss reduction beyond Baseline GMP
Why are the Nitrate Priority Sub-areas needed?
These sub-areas are needed because the reductions in nitrogen losses required to achieve the nitrate limits and targets are not the same across the Nitrate Priority Area.
How were the Nitrate Priority Sub-areas drawn?
  • We looked at the projected nitrate concentration for each receptor under the Current Pathways Scenario.
  • We compared the projected nitrate concentration to the nitrate concentration recommended in the Zone Implementation Programme Addendum.
  • We calculated the nitrate loss reductions in the groundwater recharge area for each receptor needed to achieve the proposed nitrate concentration limits and targets.
  • The calculated number of nitrate loss reduction stages were based on the reductions required for dairy land use activities (15% reduction every 10 years) and other land use activities (5% reductions every 10 years) and the total area they cover within the groundwater recharge zones for each receptor. The calculations exclude land use activities that meet the permitted activity rules.
  • Based on this comparison the number of 10-year reduction stages was calculated for each receptor.
  • The number of stages per receptor was allocated to the receptor’s groundwater recharge zone if it (partly) falls within the Nitrogen Priority Area.
  • Where groundwater recharge zones overlap, the highest number of required 10-year stages was allocated to the consented property.
  • The five sub-areas were based on the highest number of required 10-year stages; for example, sub-area A needs 1.5 to 2.4 reduction stages, which is rounded to 2 stages and sub-area B needs 2.5 to 3.4 reductions stages, which is rounded to 3 stages.
  • The required total nitrate loss reduction is shared among all properties that don’t meet the permitted activity rules within the sub-area. If the total area of properties requiring a land use consent within the sub-area is relatively low (relative to other sub-areas), the number of stages of reduction will be greater.
  • Reductions only apply to farming activities that require resource consent where the reduction for each stage is greater than 3 kg/ha for dairy and 1 kg/ha for other farming activities

More information:

Map 1 – Nitrate Priority Sub-areas

NPA reduction 10 years stage

Table 1 – Stages of nitrate loss reduction per sub-area by cumulative percentage reductions and dates by which these are to be achieved

Nitrate Priority Area Sub-area
(see planning maps)
Farming type By 1 January 2030 By 1 January 2040 By 1 January 2050 By 1 January 2060 By 1 January 2070 By 1 January 2080 
Sub-area A Dairy 15% 30%
  Other 5% 10%
Sub-area B Dairy 15% 30% 45% 
  Other 5% 10% 15% 
Sub-area C Dairy 15% 30%  45%  60% 
  Other 5% 10% 15%  20% 
Sub-area D Dairy 15% 30% 45%  60%  75% 
  Other 5% 10% 15%  20%  25% 
Sub-area E Dairy 15% 30%  45%  60%  75%  90%
  Other 5% 10% 15%  20%  25%  30% 

 

Do the proposed nitrate loss reductions in Table 8-9 (in Plan Change 7 to the Land and Water Regional Plan - section 8) help to maintain nitrate concentrations in the Christchurch aquifer? 

PC7 does not set nitrate limits for the Christchurch aquifer. A concentration of 3.8 mg/L of nitrate nitrogen was defined as an indicative target for the deep Christchurch aquifer to determine the actions required to maintain the quality of groundwater in the Christchurch aquifer system.  View the table in the question above 'How were the Nitrate Priority Sub-areas drawn?'.

To meet this indicative target, some land in the modelled Christchurch aquifer recharge area within the Waimakariri zone (referred to as the “interzone area” - NPA) is required to reduce nitrate loss rates beyond Baseline GMP under the proposed plan change.

A concentration of 3.8 mg/L is higher than the current average measured concentration of 0.6 mg/L. The decision to use 3.8 mg/L was based on consideration by the Christchurch West Melton and Waimakariri Zone Committees of the environmental benefits and economic impacts of a range of possible indicative nitrate concentration targets.

Did the Waimakariri Zone Committee or Environment Canterbury consider an option that describes the nitrate loss reductions required to maintain current nitrate concentrations in the Christchurch aquifer?

A “dryland farming” scenario was explored which assessed the nitrate concentrations in Christchurch that could be expected if all the land in the interzone area were converted to a land use consistent with typical dryland farming nitrate loss rates.

The economic impact of this scenario was assessed.

See Economics reports:

Several other nitrate loss reduction rates were also explored such as 10% beyond Baseline GMP.

Is there an options version of PC7 Table 8-7 and Table 8-9 which considers maintaining the water quality of the Christchurch aquifer system?
No. This process sets limits for water bodies in the Waimakariri zone, so does not set limits for Christchurch. Nutrient loss reduction targets have been proposed for the Christchurch aquifer recharge area north of the river to help to maintain Christchurch aquifer water quality.
Has a nitrate limit been proposed for the Waimakariri River?
No. The Zone Committee recommended that measures should be put in place to maintain the current nitrate concentration in the river in terms of the nitrate losses from the Waimakariri zone.
The proposed measures include applying the LWRP “red zone” rules (together with a lower consent threshold) to all land within the Waimakariri zone, in order to prevent increases in nitrate loss rates.
Steady state versus a transient flow model: was a transient flow model developed and how may this affect the modelling estimates of interzone groundwater flow, nutrient flux?
No transient model was developed; all simulations were steady state. This approach was reviewed and agreed upon with our external review panel on the basis that a single deterministic transient model would be less informative in the decision-making process than a steady-state model accompanied by information on the potential range of uncertainty around model projections.
However, as part of the validation process, a simulation was run using the optimised model with a dryland farming land surface recharge rate. We compared the difference in model water levels between the status quo model and the dryland farming model and found that water levels in some areas were 5 metres lower and in some cases up to 10 metres lower under the dryland simulation.
This difference was broadly similar to groundwater level monitoring records from before and after the development of the Waimakariri Irrigation Ltd irrigation scheme.
How long does the modelled groundwater flow beneath the Waimakariri River take from the Waimakariri Plains source areas?
Pages 47 and 68 of the Nitrate Options and Solutions Assessment report provide information on how age tracer data were used to provide an illustration of Christchurch aquifer nitrate concentrations over time.
We did not run any numerical model simulations to estimate travel times because our model was not designed for this purpose and very little data are available upon which to base some of the key hydraulic parameters for transport time simulations.
Was any age distribution data used for receptors within the Waimakariri zone?
Yes. These are documented in the Nitrate Options and Solutions Assessment report.
What are the estimated increases in nutrient concentrations in the Christchurch aquifer due to the activities on the Waimakariri Plains and timing of mitigation?
See Figure 4-4 (page 68) and 5-7 (page 97) of the Nitrate Options and Solutions Assessment report.
Is there flux occurring from groundwater to the Waimakariri River (above and below the gorge) and has this been included in the nutrient management/discharge zones and mitigation options?
Some of the Waimakariri River nitrogen load originates from Waimakariri zone – for example, some 30 tonnes from the northern tributary Smiths Creek. A stronger set of nutrient management rules is proposed to prevent further intensification in the Waimakariri River catchment.

Additional information provided during the submission period

Below you can find data request made by the public during the submission period. Below data was not released as part of the supporting material when proposed Plan Change 7 was notified.

At the request of interested parties during the submission period, this has now been made available.

If you have any questions in regards to any of the data please contact customer services.

Data requests

1. Look Up table for Waimakariri nitrate modelling

The look up table below was not released as part of the supporting material when proposed Plan Change 7 was notified. At the request of an interested party during the submission period, this has now been made available.

The look up table reflects the adjustments described in Section 2.4.3 of “Preparation of land use and nitrogen-loss data for the Waimakariri Zone limit-setting process” (Lilburne et al, 2019), and only includes the look up table rows associated with Matrix of Good Management Practice Overseer files – the rows describing the arable, sheep, beef and deer, and dairy land uses.

Waimakariri modelling

The two reports below were not released as part of the supporting material when proposed Plan Change 7 was notified. At the request of an interested party during the submission period, these have now been made available.

2. Nitrogen concentrations

A request was made by the Waimakariri Primary Industry Network Group quarterly meeting held on 23 August 2019 for a table that sets out, for each waterbody (including groundwater) the current measured nitrate concentration, predicted nitrate concentration (under Current Pathways) and the predicted nitrate concentration under proposed Plan Change 7 provisions.

Compiling all the data into one table is difficult because groundwater and surface water have different data sources and assumptions. However, we have provided the relevant information for private water supply well areas, Waimakariri District Council (WDC) community supply wells, Christchurch deep aquifer areas and surface water bodies in the following tables.

These tables were collated from tables included in the Waimakariri Land and Water Solutions Programme Options and Solutions Assessment Nitrate Management report (Kreleger and Etheridge, 2019, Environment Canterbury). We note that the predicted nitrate concentration under Plan Change 7 included in the following table is the target nitrate concentrations provided in Plan Change 7.

Regarding the request that the table identify the trend of concentrations, nitrate concentration trends for surface water bodies were calculated and are included in the tables.

Trends in nitrate concentration for the private water supply areas and the WDC community supply wells were not calculated. Monitoring results for the Christchurch deep aquifer show that nitrate concentrations are increasing over time, but remain very low - between 0.1-0.8 mg/L.

Our Current State of Groundwater Quality in the Waimakariri CWMS zone report (Scott et al., 2016, Environment Canterbury) noted that groundwater nitrate concentrations in two of our long-term monitoring wells, at Eyrewell and Ohoka, are increasing.

Concentrations have increased from around 6.5 mg/L to 7.5 mg/L nitrate at our monitoring site in Ohoka and from 4.5 to 7 mg/L at Eyrewell over the past 10 years. Data from the Springbank monitoring well near the Cust River show a decreasing trend in nitrate concentrations from nearly 16 mg/L to below the drinking-water Maximum Acceptable Value (MAV). Nitrate concentrations are generally increasing in the Kaiapoi River catchment.

The report further notes that a declining or increasing nitrate trend should be interpreted with caution, and within the context of the other processes (such as climate variability and lag times) which affect groundwater and stream nitrate concentrations.

GMP and Current Pathways – Nitrate modelling results for Private Well Supply Areas (PWSAs)

Adjusted from Table 4-8 Nitrate management report (Kreleger and Etheridge, 2019)

Concentrations are presented in 50th percentile model results, with 5th and 95th percentile results between brackets.

Private Well Supply Areas Current measured Nitrate-N (mg/L) Current pathways calculated Nitrate-N (mg/L) PC7 Nitrate-N target(mg/L) Predicted Nitrate-N under PC7 (mg/L)
Clarkville 4.4 8.2 5.65 5.65
  (0.5 – 9.4) (5.0-11.7)    
Cust 4.4 6.7 5.65 5.65
  (0.05 – 8.8) (3.9-9.7)    
Eyreton (shallow) 5.2 12.3 5.65 5.65
  (0.6 – 9.6) (8.3-16.6)    
Eyreton (deep) 5.2 15.2 5.65 5.65
  (0.6 – 9.6) (7.4-24.0)    
Fernside 3.7 4.9 5.65 <4.9
  (0.04 – 8.8) (2.2-7.8)    
North East Eyrewell (shallow) 3.6 4.9 5.65 5.65
  (0.7 – 7.0) (2.5-13.6)    
North East Eyrewell (deep) 3.6 6.6 5.65 5.65
  (0.7 – 7.0) (4.0-11.5)    
Flaxton 4.4 3.5 5.65 <3.5
  (0.05 – 8.8) (2.0-6.3)    
Horellville 3.7 4.6 5.65 <4.6
  (0.04 – 8.8) (2.2-7.2)    
Mandeville 4.4 4.8 5.65 <4.8
  (0.05 – 8.8) (2.3-8.9)    
North West Eyrewell (shallow) 3.6 6.3 5.65 5.65
  (0.7 – 7.0) (2.0-12.5)    
North West Eyrewell (deep) 3.6 7.7 5.65 5.65
  (0.7 – 7.0) (2.1-14.5)    
Ohoka (shallow) 4.4 6.3 5.65 5.65
  (0.05 – 8.8) (4.0-8.7)    
Ohoka (deep) 4.4 7.5 5.65 5.65
  (0.05 – 8.8) (4.4-10.9)    
Rangiora 0.5 2.7 5.65 <2.7
  (0.3 – 0.7) (0.4-6.7)    
Springbank 3.7 6.6 5.65 5.65
  (0.04 – 8.8) (4.0-9.5)    
Summerhill 3.7 6.6 5.65 5.65
  (0.04 – 8.8) (5.0-16.1)    
Swannanoa (shallow) 3.7 7.1 5.65 5.65
  (0.04 – 8.8) (3.0-12.1)    
Swannanoa (deep) 4.4 8.4 5.65 5.65
  (0.05 – 8.8) (4.4-12.5)    
Waikuku 0.8 1.3 5.65 <1.3
  (0.03 – 3.8) (0.6-3.5)    
West Eyreton (shallow) 3.7 5.6 5.65 <5.6
  (0.04 – 8.8) (2.8-11.1)    
West Eyreton (deep) 3.7 6.3 5.65 5.65
  (0.04 – 8.8) (3.7-9.3)    
Woodend - Tuahiwi 0.8 2.8 5.65 <2.8
  (0.03 – 3.8) (0.8-6.4)    

3. Particle tracking modelling

The modelling files below were not released as part of the supporting material when proposed Plan Change 7 was notified. At the request of an interested party during the submission period, these have now been made available. The reports which this modelling informed are available under ‘Supporting documents and disciplines’.

What is NetCDF as a groundwater model output format?

The USGS MODFLOW code has become the most widely used groundwater flow code throughout the world since its release in 1989. Because MODFLOW is a plain FORTRAN code with no graphical user interface (GUI) or visualisation capabilities, model results visualisation and analysis is usually done with commercial or open-source packages, and self-made FORTRAN snippets.

The output format of MODFLOW is a FORTRAN binary which may vary depending on compilers and platforms. NetCDF, on the other hand, is a standardised, sharable and compact format which can be read and visualised with numerous free and commercial packages including R. It is also possible to embed useful geospatial information like coordinates, projection and grid discretisation in the NetCDF which are absent in the FORTRAN binary.

Using NetCDF as a standard model output format would allow modelers and non-modelers to easily share, visualise and plot model results using readily available software (R, ArcGIS, MS Excel, Paraview, GRASS GIS, SAGA GIS...etc). NetCDF is a particularly good format for storing large, multidimensional datasets.

Many NetCDF tools were designed for the climate community, whose datasets are often orders of magnitude larger than datasets typically used in groundwater modeling. In this study R was used to generate a NetCDF file from a MODFLOW binary output and example analyses and visualisations were implemented. R has extensive statistical and plotting capabilities which are available to the user once MODFLOW outputs are available in NetCDF format.

Source: The case for NetCDF as a groundwater model output format using R: Example using USGS MODFLOW
Authors: Coulibaly, K. M.; Barnes, M.; Barnes, D.
Affiliation: AA (Schlumberger Water Services, Fort Myers, FL, USA; kcoulibaly2@slb.com), AB (Chesapeake Research Consortium, Chesapeake, MD, USA; mbarnes@chesapeakebay.net), AC (Schlumberger Water Services, Fort Myers, FL, USA; davb@alum.mit.edu)
Publication: American Geophysical Union, Fall Meeting 2011, abstract id. H11B-1059

4. Nitrate loading

The folder below was not released as part of the supporting material when proposed Plan Change 7 was notified. At the request of an interested party during the submission period the raster products showing estimates of diffuse nitrate (N) losses and drainage rates beneath the root zone, for the current, Plan Change 5 and Zone Implementation Programme Addendum scenarios described in Lilburne et al. (2019) have been made available.

A readme file provides some metadata linking the raster files to the modelled scenarios and outputs.

 

Water allocation and minimum flows
How will Part C of PC7 ensure a reliable source of water is available in the Waimakariri zone?

New flow and allocation regimes are proposed for a range of surface water bodies in the zone. In general, the revised regimes impose higher minimum flows for surface waterbodies, and as a consequence reliability of supply for water abstractors would probably reduce.

However, Part C of PC7 also sets aside an allocation of water for abstractors that surrender their stream-depleting groundwater or surface water takes in exchange for a deep groundwater take. The availability of this allocation is expected to limit any potential adverse impacts on reliability.

What is the ‘Mahinga Kai’ allocation of water available for?

An allocation of water has been reserved from the Ashley River / Rakahuri, Cam River / Ruataniwha and Silverstream rivers in recognition of the cultural significance of these waterbodies. The allocation is available for activities that will enhance mahinga kai outcomes.

How will Part C of PC7 improve waterways?

Freshwater outcomes proposed for the Waimakariri sub-region are set to maintain current water quality where is good, and improve water quality where it is currently degraded. Improved water quality would mean some rivers in the sub-region would meet national standards for contact recreation, and improvements to habitat would enable further opportunities for customary use and gathering of mahinga kai.

What is Targeted Stream Augmentation and how does it improve outcomes for rivers?

Targeted stream augmentation (TSI) is a system for controlled release of water to improve river and stream flows. Part C of PC7 introduces a regulatory framework that is more enabling than the existing region-wide provisions for TSI.

Augmentation of surface water bodies can provide significant environmental benefits by increasing river flows and reducing concentrations of contaminants.

A key issue with enabling TSI is finding an appropriate source of water to discharge into the subject waterbody, particularly when a number of waterbodies within the Waimakariri sub-region are over-allocated.

Part C of PC7 allows an application for resource consent to be made to take and use water for targeted stream augmentation in over-allocated catchments. In general, the taking of water in an over-allocated catchment would be prohibited, but a pathway has been provided for this particular use in recognition of the overall benefits TSI provides.

Groundwater Flow Model Request

The modelling scripts below were not released as part of the supporting material when PC7 was notified. At the request of interested parties, these have been made available during the submission period. The groundwater flow modelling informed technical reports which are available under ‘Supporting documents and disciplines’.

The model was built and run using the FloPy package in Python code. The model files for the groundwater flow model are located in a zip file via the link below. The information also contains a readme file that explains what the files are.

Download the model files

Ashley Estuary (Te Aka Aka) and Coastal Protection Zone
Why is the Ashley Estuary (Te Aka Aka) and Coastal Protection Zone important and why do additional restrictions apply to farming activities in this zone?

The Ashley Estuary (Te Aka Aka) is a highly sensitive environment. There is high potential for the estuary to become eutrophic, unless additional land use and discharge controls are imposed. Further, significant cultural values are associated with the Ashley Estuary (Te Aka Aka) and Coastal Protection Zone, and additional management responses are necessary to achieve mahinga kai outcomes.

The new rule framework would require farms in the zone larger than 5ha that have winter grazing and/or are irrigated and directly adjoin a surface waterbody to obtain a land use consent to farm. This approach would ensure that the farm is subject to a Farm Environment Plan and regular auditing in order to assess the effectiveness of any measures implemented on farm to reduce contaminant contributions to surface waterbodies.

New policies are also proposed that require discharges of contaminants to surface water to be avoided (where practicable), and where avoidance is not practicable, for the best practicable option to be implemented in order to minimise loss of contaminants.

Map of Coastal Protection Zone

The Ashley Estuary (Te Aka Aka) and Coastal Protection Zone is defined in the LWRP planning maps and shown in the figure below. You can access an electronic version of proposed changes to the Planning Maps here.

Ashley Estuary (Te Aka Aka) and Coastal protection Zone

Will additional resource consents be required in the Ashley Estuary (Te Aka Aka) Zone and Coastal Protection Zone?

It is estimated that the new farming rules proposed by Part C of PC7 would result in an additional 50 land use consents being required (compared with the region-wide rule requirements).

Stock exclusion
What are the new stock exclusion rules for Waimakariri? How do these compare with rules in other zones?

Part C of PC7 extends the region-wide provisions for stock exclusion to include permanently or intermittently flowing springs (waipuna) or open drains and artificial water courses that have surface water in them which discharge into a lake, river or wetland.

Part C of PC7 prohibits access by farmed cattle, deer and pigs into open drains and artificial watercourses (including but not restricted to irrigation canals and water races) within the Ashley-Waimakariri Plains Area. The Area is defined as land that is below 350m above sea level, which is the flatter and more intensively farmed part of the Waimakariri sub-region.

Other sub-region sections of the LWRP (including Selwyn Waihora, Ashburton and South Coastal Canterbury Streams) include similar restrictions to ensure improvements in water quality are achieved.

Consent Reviews
Does the Waimakariri part of PC7 require consents to be reviewed?

New policies would direct a review of surface water or stream-depleting groundwater takes that have ‘direct’ or ‘high’ stream depletion effects. Proposed timeframes for reviews are 31 December 2027 (Ashley River /Rakahuri Freshwater Management Unit) and 31 December 2029 (Northern Waimakariri Tributaries Freshwater Management Unit).

Why are consent reviews being proposed?
The Resource Management Act allows Environment Canterbury to initiate a review of resource consents when a regional plan has been made operative, or where there are adverse environmental effects.

Part C of PC7 introduces new requirements for the take and use of surface water and groundwater, including new minimum flows and partial restrictions. However, these minimum flows don’t automatically apply to existing resource consents. New limits introduced by a plan change can only be applied when a resource consent expires, when a new consent is sought, or through a consent review.

Waiting for consents to expire would mean it could take many years before all consents are aligned with new minimum flow requirements. This would slow achievement of ecological benefits and create inequity between abstractors, with some abstractors subject to higher minimum flows before others are.

Why does the Waimakariri part of PC7 propose common expiry dates for resource consents?

Common expiry dates ensure all consents in a catchment expire on the same day. This approach enables co-ordinated and integrated planning.

A common expiry date of 2037 is proposed for all resource consents for the use of land / or discharge of nutrients from a farming activity, or the take and use of water. After 2037, consents are proposed to have a 10-year consent duration. These dates align consents with plan review cycles, taking into account realistic timeframes for plans to be made operative following notification.