Improving water allocation
The National Policy Statement for Freshwater Management 2014 brings change to the way councils manage freshwater. We need to set region-wide allocation limits, improve how we manage allocation of water and ensure it’s being used efficiently. As part of this work, Bay of Plenty Regional Council is making changes to the way we manage water allocation in the Regional Water and Land Plan.
These changes are needed to:
- Strengthen existing limits for water allocation
- Set the framework for action within local catchments on Water Management Areas
- Fix existing water allocation problems like unauthorised water takes and over-allocation
- Improve efficiency in managing water allocation and water use
- Collect better information about water use.
At this stage, the work we’re doing around the region-wide policies and rules is purely so we can get feedback from you. It’s an opportunity for you to tell us what you think about our proposals and influence how the plan is changed. We want you to let us know if we are on the right track before we begin the statutory process to make changes to our Regional Water and Land Plan early next year.
Following this, Water Management Area work will then take place – with water quantity and quality limits set at a local level with communities, tangata whenua and Councils. This work will result in further changes to the Water and Land Plan.
You can also download this information as a factsheet
Visit the Water Quantity Plan Change page for more information about the project.
What are the key issues to be addressed in a Region-wide Water Quantity Plan Change?
1. Creating a framework for Water Management Areas
As the Water Management Areas are set up, we want to make sure the work that takes place in them has a framework to guide them.
The Water Management Areas will be:
Identifying tangata whenua and community aspirations for water, including including deciding, at a water management area level, how much should be allocated for uses such as irrigation, municipal supply and dairy farming; and how much needs to remain in streams and aquifers,
- Identifying opportunities to incorporate matauranga and tikanga into fresh water management;
- Phasing out over-allocation, and
- Improving efficiency.
You can find out more about Water Management Areas on our website at www.boprc.govt.nz/freshwaterfutures
2. Providing for greater recognition of social, cultural and economic benefits of water
Our suggested changes aim to recognise the social, cultural and economic benefit of new and existing water takes for land development. It will also recognise the importance of water for marae, domestic or municipal water supplies.
3. Strengthening existing limits for allocation
Being clear about how much water is available for allocation is important for both people seeking to take water and for Council to know how much is still available. As the Water Management Areas are set up, communities and iwi will work together to finalise how much water should be allocated on a more localised basis. However, we still need to be clear about the water allocation limits in the meantime. We’re suggesting interim limits that will act as a ‘line in the sand’ until the local processes are complete. The interim limits show Council is taking a conservative approach to water allocation.
The key principles are that:
a) There is no change to the interim limits for surface water from what is already contained in the regional plan (except for the Waitahanui catchment which currently has a specific limit)
b) Interim groundwater allocation limits, based on the current practice of using the Proposed National Environmental Standard on ecological flows and water levels are identified because the regional plan doesn’t currently have numeric limits for groundwater allocation.
c) New policies for limited opportunities to take water above those interim limits, by either:
- water harvesting (high river flow takes), or
- lower reliability takes (agreeing to stop taking water when river flows are low), or
- bringing sufficient evidence that a higher level of allocation is justified.
These suggested changes mean that there will be greater clarity about the allocation limits for consent applicants and Council officers. Stricter consent processes will apply for new consent applications to take water in fully allocated catchments, including more information required from the consent applicant; and if granted, shorter consent terms and/or stricter conditions.
4. New draft rule for existing municipal water takes (city and district council water supplies)
We’re suggesting a new ‘controlled activity’ rule for municipal water supply takes to acknowledge the special role they have for communities. This would mean that all applications to renew consents for existing municipal takes must be granted. Council would reserve control over a number of matters, including measures to avoid adverse effects on mauri and tangata whenua values and interests.
This draft rule supports existing municipal supplies, but does not advantage applications for new municipal water supplies. For iwi, hapū and others with an interest in land and streams or aquifers with municipal takes, this rule limits the opportunity to influence future water allocation. Some people are concerned municipal supplies are used for irrigation or industrial uses. The suggested rule aims to require municipal suppliers to manage these more carefully when other water users have water restrictions.
What do you think?
Should existing consents for municipal water supply takes have guaranteed right of renewal? Are the Water Management Plan requirements in Schedule 14 of our suggested chganges adequate to ensure that municipal takes are efficient?
5. Streamlining the policy for water takes within Hydro Power Scheme catchments
By streamlining the existing policy relating to water takes within Hydroelectric Power Scheme Catchments, we hope to improve its clarity and readability. The existing constraints to new allocations above hydro schemes would remain (with the exception of water takes for milk cooling and dairy shed use).
6. Improving water accounting, including water metering, recording and reporting
We’re looking for more efficient allocation and use of water. While this is a requirement of the National Policy Statement for Freshwater Management, it is also vitally important for the future of our region. We need to ensure that we allocate water only where it is needed and that it will be used in a way that maximises the benefits of water use. Water user groups and other methods of sharing water are encouraged.
New metering and reporting rules for all consented takes will improve how we manage and account for water use. They are consistent with the Measuring and Reporting of Water Takes Regulations brought in by Central Government in 2010 and support the water accounting requirements of the National Policy Statement for Freshwater Management.
For these reasons:
- All consented water takes would have a water meter that records daily use. The cost of installing and maintaining a meter will be met by the water user.
- All takes larger than 5L/s will require electronic reporting of use e.g. telemetry, except where there are practical difficulties such as a lack of cell phone coverage.
What do you think?
How reasonable is it for all consented takes to have a water meter installed and for all takes larger than 5 L/s to report water use electronically (e.g. telemetry)?
7. Changes to permitted takes
Some water takes don’t need a resource consent, either because they are permitted by a rule in a plan or because they are for household or stock drinking water. We’re not proposing to change rights for drinking water, which will remain a right that doesn’t need resource consent. We are suggesting a reduction in the amount able to be taken for other purposes without resource consent (water permit). These changes would improve our ability to manage and account for water.
What we’re suggesting is:
- No change to the right of an individual to take water for their stock drinking or household needs
- Reducing permitted groundwater takes from 35m3 to 15m3 per property per day. This is because in some places groundwater is becoming highly allocated and we need to better account for and ensure the efficiency of these takes.
- No change to the volume of permitted surface water takes – this would remain at 15m3/day.
- For both surface water and ground water takes, introducing new requirements around:
- Registering the take,
- Metering the take, on request – with the cost of installing and maintaining a meter being met by the water user, and
- Stopping users combining ground and surface water volumes on the same property.
- For groundwater takes caught by the reduced permitted limit, a consent will be needed. It will be processed as a controlled activity that must be granted. It would not require notification or consultation.
- Metering of drinking water takes would not be required, except where associated with a take for dairy shed wash down or milk cooling.
What do you think?
Do you support the reduction in the permitted groundwater limit from 35m3/day to 15m3/day? Should permitted activities by registered and, if requested, metered?
8. Special provisions for existing dairy shed use and unauthorised irrigators
Dairy shed use
Like many other Regional Council’s, we’ve become aware that as the size of dairy farms has grown, the amount of water they use has increased to a stage where many need a resource consent. Very few of the region’s dairy farmers have resource consent to take water for milk cooling or wash down, and we’re aware many exceed the permitted volumes.
To ensure that the dairy farmers who require resource consent have one, we’re looking to transition unauthorised takes for milk cooling and wash down greater than 15m3/day to resource consent via a time-limited consent process. These would be a controlled activity and must be granted.
The draft rules would only apply to existing takes and would expire within 12 months of the rule becoming operative.
You will not need to apply if:
- You use less than 15m3/property/day (herd of approximately 215 cows), or
- You already have a consent to take water (for example for pasture irrigation) and want to use part of this in the dairy shed, or
- You are connected to a municipal or other consented community water supply.
Any new dairy sheds or increases in water requirements of existing dairy sheds will need to go through the normal process to obtain resource consent.
What do you think?
Do you agree with the approach of special one-off provisions for existing dairy shed use? If not, why not? Can you identify other solutions? Should the dairy shed take applications be processed on a non-notified basis (without consultation)?
Horticultural industry representatives have raised the issue that some existing irrigators lack the necessary resource consents to take water. They have asked for a special opportunity to encourage and assist them to gain resource consent. For this reason, a new policy and rule have been developed. Unauthorised irrigators are not guaranteed a resource consent because this could unfairly impact on existing authorised users or the environment and make any existing over allocation worse.
The new provisions are intended to encourage unauthorised irrigators to come forward and will help ensure all water takes are known and accounted for.
The special provisions for irrigators would only apply for 12 months from the date the Proposed Plan Change is operative (anticipated for early 2016), after which any new applications would not have any special consideration.
What do you think?
Do you agree with the approach of special one-off provisions for and unauthorised irrigators? If not, why not? Can you identify other solutions?
To qualify for these special rules, applicants must prove that they had an existing take. In what ways could an applicant prove that they were an existing water user?
9. Managing takes at low flows or low aquifer levels
The Regional Water and Land Plan currently includes provisions relating to water takes at low flows. We’re suggesting introducing replacement policies to provide clarity around how water takes will be managed during low flows or low aquifer levels.
The following types of water takes would have priority during water restrictions:
- Water takes for domestic and sanitation needs
- Water takes for animal drinking needs (stock water)
- Non-consumptive takes (e.g. hydroelectric power schemes)
- Municipal water supplies
What do you think? Should other uses be given priority during water restrictions?
10. Future resource consent considerations
We are looking at some changes to requirements for resource consents to give effect to government requirements (Measurement and Reporting of Water Take Regulations 2010, the National Policy Statement Freshwater Management 2014), give effect to the Regional Policy Statement and to maximise the benefits we all get from water.
Our suggested changes include:
- Clarity that people applying for new consents or renewing expired consents will need to provide a comprehensive assessment to show that the take doesn’t cause unacceptable adverse effects, especially where the water is over allocated.
- A resource consent term of up to 10 years where the resource exceeds interim limits and up to 15 years for other water bodies.
- Acknowledgement that by 2027 we need to phase out over allocation.
- Priority to existing users priority over new users when their consent expires.
- A requirement for metering and daily reporting of all takes over 5 litres per second (unless this isn’t practical such as because cell phone coverage isn’t available).
- New requirements to ensure water is allocated and used efficiently, with a new schedule that lists reasonable and efficient use criteria.
- Identifying that where water is in short supply, options such as transferring water from another user, or stopping taking at times of low stream flow or sharing in a water user group can be opportunities to access water
- Council establishing a freshwater accounting system so that the amounts of water available or taken is readily available.
- A policy to support initiatives by local communities, sector groups or iwi to identify and evaluate options to enhance water availability.
Visit the Water Quantity Plan Change webpage to find out more about the project.