BEFORE THE BOARD OF INQUIRY

IN THE MATTER of the Resource Management Act 1991

AND

IN THE MATTER of a Board of Inquiry appointed under s 149J of the Resource Management Act 1991 to consider the application for resource consents by Watercare Services Ltd to increase abstraction of water from the Waikato River.

STATEMENT OF EVIDENCE OF MARTIN MOULD (WAIPA DC WATER SUPPLY) Dated 18 June 2021

Instructing Solicitor:

Michelle Hawthorne [email protected]

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INTRODUCTION

Qualifications and experience

1. My full name is Martin Mould.

2. I am the Water Services Manager for Waipā District Council (Waipā DC). I have been in this role for just over one year. My role covers all matters relating to Three Waters for the Waipā District, including strategic planning, asset management, and operations.

3. I have 20 years’ experience in the water industry in New Zealand, mainly within local government roles. I worked for Hamilton City Council (HCC) for 14 years in a range of roles within the water unit, including as City Development Manager. I was the Water Services Manager at Waikato District Council for 3 years. I also worked at WSP for two years as the National Waters Project Director.

4. I hold a Postgraduate Certificate in Management Studies from the University of Waikato (2013).

5. I am authorised by Waipā DC to provide evidence in these proceedings.

Code of Conduct

6. I have read the Environment Court Code of Conduct for expert witnesses contained in the Environment Court Practice Note 2014 and agree to comply with it. I confirm that the opinions expressed in this statement are within my area of expertise except where I state that I have relied on the evidence of other persons. I have not omitted to consider materials or facts known to me that might alter or detract from the opinions I have expressed. 2

Scope of evidence

7. My evidence will:

(a) Explain the population and growth context of the Waipā District;

(b) Describe Waipā DC’s water abstraction consent and its water supply network;

(c) Describe Waipā DC’s water demand management measures;

(d) Outline Waipā DC’s concerns about over-allocation of the Waikato River and the impacts that would arise if Waipā DC is unable to meet its medium and long-term growth needs; and

(e) Outline the outcome that Waipā DC seeks that would ensure that Auckland’s short-term needs are met but avoiding any detriment to the interests of the Waikato River iwi and Waipā DC’s obligation to supply water to the Waipā District in the medium and long-term.

SUMMARY OF EVIDENCE

8. Waipā DC is currently well served in terms of water supply. It has a consented take from the Waikato River of 45,286 cubic metres per day which is due to expire in 2049, and a take of 14,000 cubic metres per day from the Mangauika Stream on Mt Pirongia which becomes restricted to 4000 cubic meters per day by 2030.

9. The allocation from the Waikato River was established in 2018 when Waipā DC ‘rationalised’ its suite of consents, and its total allocation reduced from 63,700 cubic metres per day in that process. This reduction reflected the 3

medium term needs of Waipā DC, with estimated demand indicating that Waipā DC will have sufficient water to meet demand through to the expiry of its consent.

10. However, Waipā DC considers that a long-term approach needs to be taken when considering the efficient allocation of this resource. This is particularly important given the recent NPS-UD requirements affecting Waipā DC, and the impacts of growth anticipated within the Hamilton- Waikato Metropolitan Area (metro area or MSP area), as described in the evidence of Mr O’Dwyer for HCC.

11. That growth profile will see Waipā DC’s current population of approximately 58,800 grow to up to approximately 89,000 people. Despite the capacity available to Waipā DC under its existing consents, Waipā DC will inevitably need additional water over the longer-term.

12. Waipā DC seeks a win-win-win solution for all parties, which enables Watercare’s immediate needs to be met, but which enables Waipā DC to meet its long-term needs, with the wellbeing of the river being at the forefront of decisions.

13. In the evidence presented on behalf of HCC there are a range of planning techniques suggested to achieve this outcome, including restricting the term of the consent, requiring active steps in terms of securing alternative sources, and stepping down the take over time. Waipā DC supports this approach.

WAIPĀ DISTRICT

14. The Waipā District has a population of 58,000 people. The District is predominantly rural, covering an area of 1473.47 km2. Its two principal population centres are Cambridge (20,500) and Te Awamutu (13,100). The Waipā 2050 Growth Strategy (Waipā 2050) aims to ensure that the District remains a great place to live, work and play, well into the future. Waipā 4

2050 projects that by 2050, the District will be home to an additional 25,000 people beyond those resident as at 2018. Under the NIDEA 2021 HIGH projections, that population is anticipated to be 89,707 by 2065.

WAIPĀ IN THE NATIONAL CONTEXT

15. The importance of the District in the broader national context has been recognised through the creation of the Future Proof Urban Growth Partnership, which is a collaboration between all local councils in the Waikato Region, and also with the Crown and Iwi. The Future Proof Partnership was created on 15 August 2019 and also includes representatives from Auckland Council, Franklin Local Board, and Auckland/Hauraki Iwi to reflect the Crown’s commitment to the Hamilton to Auckland Corridor Plan (H2A Plan) that was completed in 2019. The Hamilton to Auckland Corridor (H2A corridor) and the H2A Plan is explained in detail in the evidence of Mr O’Dwyer. Since the reconstitution of that partnership, the focus of effort has been on implementing the H2A Plan, with emphasis on developing a Hamilton-Waikato Metropolitan Spatial Plan (MSP) and a Waikato Sub-Regional Three Waters Project.

HAMILTON TO AUCKLAND CORRIDOR PLAN

16. Despite its title, the H2A corridor extends south of Hamilton City, into Cambridge to the south-east along SH1, and into Te Awamutu to the south- west along SH3. Accordingly, these population centres within the Waipā District are key components of the overall H2A corridor.

HAMILTON-WAIKATO METROPOLITAN SPATIAL PLAN

17. The MSP is the first joint spatial plan for the metro area prepared by iwi, the Crown, and local government partners under the Future Proof Partnership. The metro area extends from Taupiri in the north to Te 5

Awamutu and Cambridge in the south. The MSP takes a longer view of growth in this metropolitan area and plans for a future scenario in which 500,000 people reside. The growth projections identified in Waipā 2050 are incorporated within the MSP.

WAIPĀ DC’S GROWTH OBLIGATIONS

18. Under the National Policy Statement on Urban Development 2020 (NPS- UD), Waipā DC is a Tier 1 local authority and sits within the Tier 1 urban environment of Hamilton. In addition to the requirements placed on Hamilton to make provision for 31,900 homes by 2048, the NPS-UD requires that Waipā DC make provision for 13,900 homes by 2048.

19. The NPS-UD also requires Waipā DC to provide enough business land for the retail, commercial, and industrial sectors. The 2017 housing and business capacity assessment report found that an additional 189,000m2 of retail and 650,000m2 of industrial gross floor area would be required by 2048.

GROWTH IN THE METRO SPATIAL PLAN (MSP) CONTEXT

20. The projected growth identified within the broad geographic area of the MSP extends to 500,000 people over the medium to long-term (within the next 30 to 100 years). I refer to and rely on the evidence of Mr O’Dwyer for HCC which sets out the detail relating to the MSP.

21. Access to water is critical to the growth identified in Mr O’Dwyer’s evidence. In the event that a new and separate waters entity is created in the future, access to potable water will not only be required to service growth within each district’s territorial boundary, but also beyond those boundaries to the full extent of the MSP area. In this way Waipā DC’s 6

position on water allocation and future demand is very much aligned with that of HCC.

WATER SUPPLY IN WAIPĀ DISTRICT

Waipā DC’s water take consent

22. In 2018, Waipā DC rationalised its existing suite of five water takes (104054, 110442, 110444, 124967 and 124968) down to three. Those existing five water takes amounted to a cumulative allocation of 63,700 cubic metres per day. As a result of that process, WRC combined water takes 104054, 110442, 110444 into a single consent, and reduced the total cumulative allocation to 45,286 cubic metres per day. Under that process, WRC granted Waipā DC a new 30-year consent to extract water from three points within the Waikato River for municipal supply (Waipā consent). The Waipā consent expires in 2049. The consent evaluation report records that:

These significant reductions are commensurate with the applicant’s obligations as a municipal water supplier for the Cambridge, Pukerimu and Te Awamutu communities, embody equity principles and represent a contemporary and more efficient approach to water allocation.

23. Through this process, Waipā DC responsibly acknowledged that the existing allocation of 63,700 cubic metres per day was well beyond its short to medium-term needs, and 18,414 cubic metres per day was returned to the allocable flow of the River, to be efficiently applied elsewhere. This represents a sustainable approach to the resource, and one which Waipā DC wishes to see reflected in the approach the Board takes to the Watercare application.

24. That is not to say that Waipā DC will not ever require that water again and taking account of the NPS-UD, the recently developed MSP, and other associated growth strategies, it is evident that this anticipated population 7

growth within the Waipā District will place pressure on the existing allocation and will eventually lead to a situation where further allocation is required.

25. The Waipā consent, in combination with consents 124967 and 124968, enable a total combined daily net take volume which, subject to seasonal restrictions, must not exceed 45,286 cubic metres per day. During the low demand season of May through July, this amount must not exceed 33,500 cubic metres per day, and between January through April, and August through December, this amount must not exceed 41,000 cubic metres per day.

26. Waipā DC’s peak water abstraction stands at 28,088 cubic metres per day. Its current peak abstraction for 2019-20 stands at 22,366 cubic metres per day.

Waipā DC water supply network

27. Waipā DC supplies water to more than 14,000 properties in Cambridge, Karapiro, Kihikihi, Ohaupo, Pirongia, Pukerimu, Te Awamutu and selected rural areas through one of four water schemes.

28. Waipā DC’s water supply is fed by six sources and is split into thirteen water supply areas (6 urban and 7 rural). While the levels of service in urban (on demand, firefighting capability) and rural (restricted supply) areas differ, all water supply area customers are provided with potable drinking water, with supply and demand being managed to ensure prudent use of water.

29. The Cambridge Water Supply Scheme sources water from the Waikato River. The Kihikihi Water Supply Scheme sources water from two bores, one at Hall Street and the other at Church Street. The Pukerimu Water Supply Scheme sources water from the Waikato River. 8

30. The Te Awamutu Water Supply Scheme has sourced water from the Mangauika Stream on Mt Pirongia and from a bore on Frontier Road. However, abstraction from the stream has had a detrimental effect on its health and ecological systems. For that reason, Waipā DC has invested $36M in infrastructure to support transferring the water supply to Te Awamutu from the Mangauika Stream and the bore to the Waikato River. The consent reduces from 14,000 cubic metres per day from 4,000 cubic metres per day in 2030. These 4,000 cubic metres per day is in addition to the volume taken from the Waikato River referred to in paragraph 25 above.

31. Waipā DC has seven water treatment plants that process all of the District’s water. 2018/19 figures for peak production capacity at each of the treatment plants are as follows:

a) Karāpiro Water Treatment Plant’s peak production capacity is 13,557 cubic metres per day.

b) Alpha Street Treatment Plant’s peak production capacity is 2,431 cubic metres per day.

c) Parallel Road / Pukerimu Water Treatment Plant’s peak production is 5,688 cubic metres per day. A new plant is currently being constructed which has a design capacity of 16,000 cubic metres per day.

d) Te Tahi Water Treatment Plant’s peak production is 9,547 cubic metres per day.

e) Frontier Road Water Treatment Plant’s peak production capacity is 1,886 cubic metres per day. 9

f) Kihikihi Water Treatment Plant’s peak production capacity is 1,567 cubic metres per day.

32. Waipā DC has 16 water reservoirs. The total storage equates to 28,100 cubic metres.

WATER DEMAND MANAGEMENT

Water meters

33. In the last four years, Waipā DC has invested heavily to implement universal metering across our connected communities. These have contributed to an overall reduction in water demand per household, demonstrating Waipā’s commitment to ensuring that we are managing our scarce resources well.

Smart Water

34. Waipā District and Hamilton City also have a shared services entity - Smart Water - which is focussed on water demand management education within our communities. Smart Water includes an Alert Level System which is implemented when there are issues with water supply. The Alert Level System encourages members of the community to voluntarily reduce their consumption of water through specific restrictions from, at one end, Alert Level 1 which restricts sprinkler use to 6-8am and 6-8pm, through to Alert Level 4, at the other end which restricts the use of outdoor water systems at all times. The Alert Level System is usually activated during the summer months and high demand periods. 10

WATER DEMAND PROJECTIONS AND WAIPĀ DC’S CONCERNS

35. Based on current population projections, Waipā DC has sufficient water available to accommodate the projected growth in the District between now and 2049, when the current Waipā consent expires. However, it is clear that after 2049 a renewed consent will be required which will need to extend the allocation beyond 45,000 cubic metres per day in order to address growth demands beyond that timeframe.

36. These figures highlight that Waipā DC has an interest in the ongoing allocation of water from the Waikato River. By allocating additional water to Watercare as sought, this may impact Waipā DC’s ability to obtain a renewed and extended water take consent as required to service the growing population of, not just the Waipā District, but also the MSP area.

37. Waipā DC considers that the tension which exists between the needs of Auckland and those of the MSP area, can be resolved in a way that serves both the Auckland and Waikato joint interests. Clearly Watercare has an immediate need for water in the short-term. Waipā DC’s need for additional water allocation is likely to arise in the medium to long-term. Accordingly, Waipā DC seeks a solution which sees the immediate needs of Auckland met, while preserving allocable flow for the medium to long-term to enable Waipā DC to meet its needs over this extended timeframe.

38. In support of its submission on Watercare’s application, Waipā DC adopts and supports all of the evidence presented on behalf of HCC. Waipā DC supports the relief identified in the evidence filed on behalf of HCC.

Martin Mould 18 June 2021