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Trustpower Limited, Private Bag 12023, Tauranga 3143, New Zealand Trustpower.Co.Nz From: Shelby Managh To: Mailroom Mailbox Subject: Proposed Plan Change 7 to the LWRP Submission Date: Thursday, 12 September 2019 1:07:54 PM To whom it may concern, Please find attached to this email Trustpowers submission on proposed Plan Change 7 to the Canterbury LWRP. Thanks Shelby Managh Environmental Advisor - Policy Trustpower M 027 269 9488 E [email protected] Trustpower Limited, Private Bag 12023, Tauranga 3143, New Zealand trustpower.co.nz The contents of this email and any attachments are confidential and may be privileged. If you are not the intended recipient, you may not use, copy or disclose this email or its attachments. Please notify the sender immediately by e-mail if you have received this e-mail in error and delete both emails from your system. It is your responsibility to check this email and any attachments for viruses or other harmful code before opening or sending on. Trustpower Limited and its subsidiaries (collectively, Trustpower) accepts no responsibility for any such virus or any effects of a virus on your systems or data. Trustpower does not endorse anything in this email that is not related to its official business. Please think of the environment before printing this email. rrrust . ' powerm Proposed Plan Change 7 A submission to the Canterbury Regional Council September 2019 Trustpower Submission 1 September 2019 SUBMISSIONS ON PROPOSED CHANGE 7 TO THE CANTERBURY LAND AND WATER REGIONAL PLAN UNDER CLAUSE 6 OF THE FIRST SCHEDULE TO THE RESOURCE MANAGEMENT ACT 1991 To: Canterbury Regional Council Email: [email protected] Submission on: Proposed Plan Change 7 – Part A Submitter name: Trustpower Limited Address for service: Trustpower Limited Private Bag 12023 TAURANGA 3143 Att: Nicola Foran Phone: 021 908 951 Email: [email protected] Trustpower Limited (“Trustpower”) makes the following submission to the Environment Canterbury Regional Council on Proposed Plan Change 7 to the Canterbury Land and Water Regional Plan (“PC7”). Trustpower’s submission on the individual provisions of PC7 is set out in the attached document. Trustpower could not gain an advantage in trade competition through this submission. Trustpower would like to be heard in support of its submission. If others make a similar submission, Trustpower would be prepared to consider a joint case. Signature: Nicola Foran For, and on behalf of, Trustpower Limited Dated: 12 September 2019 Trustpower Submission 2 September 2019 1.0 Introduction and Overview 1.1 Trustpower is a New Zealand based renewable electricity generator and multi product retailer, offering electricity, gas and telecommunication services. With a history dating back to 1915, Trustpower’s electricity generation portfolio consists of 19 hydro-electric power schemes (“HEPS”) throughout New Zealand. Within the Canterbury Region, Trustpower owns and operates the Coleridge HEPS, a 40 MW station, and the Highbank and Montalto HEPS, a combined 28 MW scheme. 1.2 Trustpower is committed to responsible and effective energy generation and to applying industry best practice to these activities. Trustpower acknowledges the importance of the environment, in particular the aquatic environment, to its continued operations, and has adopted a set of environmental policies which encourage the practical minimisation of any adverse environmental impacts associated with the company’s activities. Trustpower is also active in various environmental initiatives within the vicinity of its generation assets. 1.3 Trustpower has also successfully developed the Lake Coleridge Project by augmenting the use of the Coleridge HEPS in a staged manner so that water stored in the lake is able to be utilised for enhancing irrigation reliability on the Canterbury Plains, as well as additional hydro-electricity generation. This was achieved by Trustpower successfully varying the Nation Water Conservation (Rakaia River) Order 1988 (“Rakaia WCO”) in 2013 to enable the future consenting, construction, and operation of the Lake Coleridge Project. 2.0 Trustpower’s Unique Portfolio 2.1 A number of Trustpower’s electricity generation schemes are embedded into the local energy supply network and form a vital element in sustainable energy supply within New Zealand. The location and scale of Trustpower schemes, along with a commitment to local supply (so as to ensure that electricity is consumed as close as possible to where it is generated) is a key and somewhat unique feature of Trustpower’s generation philosophy and portfolio. 2.2 Trustpower differs from other electricity generators in the following ways: Its assets are typically moderate in scale and output; The schemes are relatively numerous and complex; The capital investment in individual schemes is modest in comparison to other large generators; and The schemes are spread throughout a number of districts and regions in New Zealand often serving provincial areas where other large generators are not present. 3.0 Trustpower’s General Submission 3.1 Trustpower is interested in this plan change for the implications which the indigenous freshwater species habitat layer means for a number of our structures and corresponding activities at Lake Coleridge. 3.2 The Coleridge Hydro-Electric Power Scheme diverts water from the Harper and Wilberforce Rivers, through canals, into Lake Coleridge. Intake structures for the power Trustpower Submission 3 September 2019 station are located at the south-eastern end of the Lake. The Coleridge Power Station discharges water back into the Rakaia River. 3.3 The Coleridge HEPS utilises a range of structures to support its ongoing operation, and also to provide valuable real time monitoring information on hydrological conditions. This data is also used to demonstrate compliance with the associated resource consents, and ensure adverse effects on the environment are minimised. 3.4 For Trustpower, it is critical that these monitoring structures are able to be maintained so that they can continue to provide hydrological data. In addition, on occasion new monitoring structures need to be installed to provide additional information or to replace redundant structures. 3.5 Trustpower’s specific relief sought in relation to this submission is detailed in Section 4 below. 3,6 For more information on the structures and monitoring installations used in Lake Coleridge, please refer to Appendix B. This gives details and photographs of the structures associated with the Coleridge HEPS. Trustpower Submission 4 September 2019 4.0 Relief Sought by Trustpower Chapter & Proposed Provision Trustpower’s Relief Sought (additions underlined, Trustpower’s Submission Provision Position deletions struck through) Definitions: Indigenous Freshwater Species Habitat Support Trustpower supports the addition of this definition Retain as notified. that outlines which indigenous freshwater species New means an area identified as are being provided for in the Indigenous ‘Indigenous Freshwater Species Definition of Freshwater Species Habitat layer identified in the Habitat’ on the Planning Maps, and Indigenous Planning Maps. which provides habitat for at least one Freshwater of the freshwater species listed below: Species 1. Giant kōkopu/Taiwharu (Galaxias Habitat argenteus) 2. Lowland longjaw galaxias (Waitaki) (Galaxias cobitinis) 3. Canterbury mudfish/Kōwaro (Neochanna burrowsius) 4. Bignose galaxias (Galaxias macronasus) 5. Upland longjaw galaxias (Galaxias prognathus) 6. Upland longjaw galaxias (Waitaki) (Galaxias prognathus) 7. Shortjaw kōkopu (Galaxias postvectis) 8. Northern flathead galaxias (Species N (undescribed)) 9. Lamprey/Kanakana (Geotria australis) Trustpower Submission 5 September 2019 Chapter & Proposed Provision Trustpower’s Relief Sought (additions underlined, Trustpower’s Submission Provision Position deletions struck through) 10. Freshwater crayfish/Kekewai (Paranephrops zealandicus) 11. Freshwater mussel/Kākahi (Echyridella menziesi) Abstraction 4.61 A Preserve indigenous biological Support in Trustpower supports the intent of this policy in Amend as follows: diversity within water bodies by Part providing for both freshwater habitat values and of Water a. by refusing any application to take requiring applications to abstract the needs of the community. water that would reduce the area or surface water or stream depleting Policy 4.61A Renewable electricity generation (“REG”) activities compromise the values of the groundwater to assess the potential are of national significance with national, regional, Indigenous Freshwater Species Habitat, effects, including cumulative effects, and local benefits. The National Policy Statement except for an application to take water of the proposed abstraction on any for Renewable Electricity Generation (“NPS-REG”) for a community water supply or an Indigenous Freshwater Species directs decision makers to recognise and provide existing hydro-electric power scheme; Habitat, and: for the maintenance or increase in electricity and generation capacity and security of electricity a. by refusing any application to take supply. It also directs decision makers to have b. if the application is to take water for water that would reduce the area or particular regard to the maintenance of a community water supply or an compromise the values of the generation output of existing REG activities by way existing hydro-electric power scheme Indigenous Freshwater of maintaining operational capacity. and the take would reduce the area or Species Habitat, except for an compromise the values of the
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