SUBMISSION – Proposed Canterbury Land & Water Regional
Plan
[email protected]
Date: September 2012
Name of Submitter: Central Plains Water Ltd
Postal Address: 6 Sonter Road, Wigram, Christchurch 8042
Telephone: 03 9824267
Email: [email protected]
(Susan Goodfellow, Project Manager)
Overview:
Central Plains Water Limited (CPWL) is a shareholder owned Community Irrigation Scheme that has
recently obtained consents to take and use water from the Waimakariri River and Rakaia River to
irrigate 60,000ha within the Selwyn District, 30,000ha of which will be new irrigation.
CPWL are currently securing funding to build the first 20,000ha of the Scheme. Part of the
construction funding will involve a shareholder/farmer contribution in addition to external investors.
In the long term, the farmer/shareholders will own this scheme. Once the scheme is fully
operational, annual direct and indirect regional agricultural output is expected to increase by $264m
per annum. A proportion of this agricultural output is expected to be processed, which will generate
an additional $328m per annum, a combined increase of $592m per annum. The impact on wider
economic activity is assessed at approximately $1b to $1.4b per annum.
Export income from Canterbury’s rural sector already accounts directly and indirectly for 60-70% of
Christchurch’s economic activity. In addition, Canterbury farmers spend around $750 million every
year on goods and services provided by Christchurch businesses.
Direct plus indirect employment is estimated to increase by about 1130 jobs. 416 of these will come
from the expansion in farm output. A further 714 jobs will come from processing, transport and
related off farm activity.
A key factor to ensuring that the farmers invest in building this scheme is that they have certainty
around the future of farmer in the Selwyn Waihora Zone. The nutrient limit setting process that
CPWL management team have been actively involved in during 2012 has raised a wide range of
issues many of which adversely impact on the certainty of farming. The solution that Environment
Canterbury have developed to date as a result of this process relies on CPWL’s 30,000ha of new
irrigation (plus 30,000ha of existing irrigation) to deliver the environmental outcomes for the Zone,
including the following:




Transfer from use of groundwater to surface water for irrigation;
Increase flows in aquifers;
Increase flows in lowland streams; and
Improved farm management practices, Farm management plan implementation and
auditing requirements.
Farmer investment in the scheme is therefore very important to ensuring that the solution to the
nutrient problem within the Zone is achieved. Farmer investment can only occur if certainty around
the economic viability of a range of farm operations is well understood; and that any land use
consents obtained to undertake any farming activity is of a duration that allows farmers to invest
and see a return.
Submission - Key Points:
Importance of Agriculture and Irrigation to the Canterbury Economy
1. As per overview discussion
Change of Land-Use
1. The current definition of ‘changed’ is problematic. Applying a volume of water threshold will
result in detrimental outcomes inconsistent with CWMS target (Water Use Efficiency and
Water Quality). Often the extra volume will be to improve reliability of supply and so will
improve environmental performance – enable a change to an ‘as and when’ irrigation
strategy as opposed to a ‘just in case’. Improved reliability results in decreased water use
and drainage (nutrient losses). The irrigation component should therefore be removed. If an
irrigation component is to be included within the ‘changed ‘definition it should only relate to
additional irrigated area.
2. The 10% change in N loss is arbitrary. The percentage approach greater benefits those with
higher existing N losses, which is illogical. The measurement timeframe given is also
problematic and needs clarification. If input based thresholds are introduced this will avoid
the capture of scenarios like ‘a lifestyle block that has a record lambing year‘, alleviating
some issues. However, legitimate mixed cropping land use activities, with long-term crop
rotations (eight to ten years is common), that span multiple properties through lease hold
arrangement, must be better accounted for.
3. The time frame over which ‘changed’ is applied needs to be flexible to allow for a range of
land use activities. The error and uncertainty associated with the use of OVERSEER (stated as
+/-20%) also needs to be accounted for in the application of the definition. A combination
approach which combines a percentage threshold with a threshold number is therefore
recommended.
Specific Submission
Section 1
1. 1.2.6 – Managing new and existing activities - The Proposed Plan requires that any holders of
existing resource consents that expire and reapply be considered subject to Part 2 of the
RMA. CPWL would like to see explicit reference made to Part 104(2A) of the RMA which
states that “the consent authority must have regard to the value of the investment of the
existing consent holder”.
2. First paragraph, page 1-4 – The first paragraph states that “intensification of farming,
particularly with irrigation, has the potential to increase nutrient losses to water bodies”.
This statement is untrue as Good Management Practice irrigation enables the better
management of water and nutrients. Reliable ‘just in time’ irrigation allows optimal
vegetative growth, maximising the uptake of nutrients from the root zone whilst minimising
drainage (nutrient loss). This allows an irrigated farming system to better perform to a
higher environmental standard than a similarly intensive rain-fed system.
Relief Sought: Amend
........intensification of farming has the potential to increase.......
Objectives:
1. Objective 3.22 – It needs to be recognised that a range of methods, including regulatory,
non-regulatory, collective and individual based approaches will be used to achieve
community freshwater objectives through managing within limits.
Relief Sought: Amend
“Community outcomes for water quality and quantity are met through managing within
limits and by utilising a range of different methods so optimal outcomes are achieved”.
Policies:
1. Policy 4.50 (c) and (d) – These points are redundant. If required they should instead be
replaced with a reference to the resource consent being made consistent with the
corresponding flow regime, as set out in the catchment plan.
Relief Sought: Oppose and Delete
2. Policy 4.76 – CPWL opposes this policy. Farmers need certainty to operate. A consent period
of only 5 years is too short to provide the level of certainty that will allow farmers to invest
in on-farm infrastructure, or in regional infrastructure such as a community irrigation
scheme.
It is well proven short-term consents do not enable the level of investment required in farm
infrastructure to achieve the upper quartile of environmental performance. They are
therefore inconsistent with the CWMS targets – water use efficiency and water quality
objectives. Short duration consents will effectively create a block to any further
development in the red zone– debt financing will not be able to be sourced to fund the
mitigations required due to the increased level of risk.
Relief Sought: Oppose and Delete
Rules
1. Rule 5.46, 5.47, 5.48 and 5.49 – CPWL agrees with the approach of these policies however,
we question the logistics of achieving these, unless a greater number of input rules are
added to exclude the more extensive land use activities. Logistically it will take
approximately 1 year from the plans notification to provide a robust and consistent Farm
Plan template that can be rolled out. This then leaves 4 years to develop and implement
10,000-12,000 farm plans in Canterbury, when there is presently very limited capability and
capacity. It should also be noted Canterbury is not an island and this approach is now
commonly being adopted nationally which will lead to further capability and capacity issues.
A 7 – 10 year timeframe would be more realistic for the implementation of this policy.
Relief Sought: Amend
From 1st July 2020,.......
In Summary:
CPWL recognise, and support that improvements in farm practices around nutrient and
water management are required to ensure that the NPS objectives for Fresh Water are
achieved. The Proposed Land and Water Plan provides a pathway to achieving the NPS
Objectives for Fresh water. However, the policies and rules highlighted above have the
potential to adversely impact on the economic sustainability of the Selwyn Waihora Zone.
CPWL would like to see that any Nutrient Discharge Allowances established for farming
activities by the relative industries has sound economic analysis behind the numbers so that
impacts are thoroughly understood and verified prior to being adopted into the LWRP.
Section 11 of the Proposed LWRP lists the priority outcomes the Selwyn Waihora Zone
Committee have established for the Zone, the first being ‘Thriving Communities and
Sustainable Economies’.
Providing certainty to the farming community around the duration of land use and water
take and use consents is also key to ensuring the success of the Thriving Communities and
Sustainable Economies.
Rule 5.46 has potentially a significant impact on achieving the ‘Thriving Communities and
Sustainable Economies’ outcome for the Selwyn Waihora Zone.