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Statement of Evidence of Susan Goodfellow

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Statement of Evidence of Susan Goodfellow under: the Resource Management Act 1991 in the matter of: Proposed Plan Change 5 to the Canterbury Land and Water Regional Plan (PC 5) and: Central Plains Water Limited (Central Plains) Submitter C16C/30981 Further submitter C16C/72309 Statement of evidence of Susan Goodfellow Dated: 22 July 2016 REFERENCE: BG Williams ([email protected]) ADW Brent ([email protected]) 2 STATEMENT OF EVIDENCE OF SUSAN GOODFELLOW 1 My name is Susan Goodfellow. 2 I am the General Manager Environmental at Central Plains (Central Plains). 3 I have been involved with the development of the Central Plains Water Enhancement Scheme (the CPW Scheme) since early 2011. My roles have included: 3.1 leading the implementation of the resource consents, environmental compliance, and the stakeholder engagement processes for the CPW Scheme; and 3.2 overseeing the establishment and implementation of the farmer compliance regime (as required by inter alia the CPW Scheme’s resource consents to use and discharge water). This includes preparing Farm Management Plans and ensuring compliance with the CPW Scheme nutrient management regime. 4 In terms of my wider environmental experience, I have a Masters of Landscape Architecture and have over 20 years’ professional experience – 10 years of which was dedicated to working in an environmental consultancy on large scale infrastructure projects based in Asia. 5 Of direct relevance to this evidence I note that I project managed Central Plains’ submission for proposed Variation 1 (now Plan Change 1 (PC 1)) to the now operative Canterbury Land & Water Regional Plan (LWRP). I have also been responsible for Central Plains’ involvement in plan change 5 (PC5). SCOPE OF EVIDENCE 6 In my evidence I provide a summary of Central Plains’: 6.1 history; 6.2 existing discharge and landuse consents; and 6.3 concerns relating to the PC 5 regime and its relationship with the existing Central Plains consents. 100105496/846445.10 3 CENTRAL PLAINS’ HISTORY 7 Central Plains is the entity that has been licensed (by the Central Plains Water Trust) to oversee the development and operation of the CPW Scheme. 8 The resource consents held by Central Plains enable it to take water from the Rakaia and Waimakariri Rivers for the irrigation of 60,000 hectares within the Central Plains area. This area comprises the area broadly between the two rivers, State Highway 1 and the ranges that make up the Malvern Hills. A map of Central Plains command area is shown in Figure 1 below. Figure 1: Central Plains’ command area 9 Stage 1 of the CPW Scheme was completed for the 2015/16 irrigation season and enables the irrigation of approximately 20,000 hectares of farmland between the Rakaia and Hororata Rivers, i.e. much of the southern half of command area. Stage 1 takes water from the Rakaia River near the Rakaia gorge 10 The primary infrastructure associated with Stage 1 will also form a significant proportion of the primary infrastructure used for Stage 2+ (being essentially further irrigation between the Hororata and 100105496/846445.10 4 Waimakariri Rivers). Stages 2+ are already well advanced in terms of planning and consenting but not yet construction (with a further prospectus being issued and various workstreams underway). 11 Stage 2+ will irigate the area between the Hororata and Waimakariri Rivers downstream of about Racecourse Hill on SH73. Stage 2+ will be physically connected with Stage 1 and place a heavy reliance on Rakaia River water. Physically separate infrastructure will take water from the Waimakariri and Kowhai Rivers, near Sheffield. That infrastructure will irrigate the Sheffield Scheme area which extends down to Kimberley Road.1 Figure 2 below shows the areas I have described. Figure 2: Stages 1, 2+ and Sheffield parts of the CPW Scheme 12 When complete, the CPW Scheme will have been one of the largest construction projects to have been undertaken in the Canterbury Region. The full CPW Scheme will cost an estimated $385 million to build, and there will be considerable additional expenditure required for the development of irrigation infrastructure on each individual shareholder property. 1 Central Plains is actively consenting storage for that part of the scheme with the aim of delivering 95% supply reliability. 100105496/846445.10 5 13 Around half of Central Plains’ shareholders will use scheme water to replace (mainly) existing groundwater takes, with the balance being ‘new irrigation’ on dryland farms. The net result will be 60,000 ha of irrigated pasture, about half of it newly irrigated, with significantly reduced groundwater takes. 14 The benefits of irrigation in the Central Plains area are, and will be, considerable. Economic assessments undertaken previously have suggested that in 2020, the direct effect of the additional 30,000 new hectares of irrigated land on the Canterbury and New Zealand economy will be $158.63 million of additional revenue, with 465 additional full-time equivalent jobs. Significant indirect effects are also predicted.2 15 Delivering Stages 2+ and Sheffield, and realising these benefits requires certainty in terms of the framework provided by PC 1 and PC 5. 16 Key regulatory drivers that will affect Stage 2+ and Sheffield include: 16.1 the nutrient management regime that applies to conversion of farms within the Central Plains’ Stage 2+ scheme area from dryland to irrigated farms, including a confirmed nitrogen allocation for 30,000ha of new irrigation (i.e. how PC 5 lets Central Plains use the 979 Tonnes/year allocated to it in PC 1); and 16.2 the level of certainty PC 5 delivers in the long run, in particular through certainty that we can continue to incentivise farmers to buy-in to the Scheme. The viability of both conversion and continuing irrigated operations is critical to Central Plains maintaining and attracting new shareholder farmers. 17 For those reasons, and as expanded later in my evidence, Central Plains is absolutely committed to requiring good management practice from its shareholder farmers, and a number of features of its existing resource consents reflect that commitment. EXISTING DISCHARGE AND LANDUSE CONSENTS 18 Central Plains (through Central Plains Water Trust) already holds all of the core consents necessary to take water for the irrigation of all 60,000 hectares planned for irrigation by the CPW Scheme. 2 Economic Value of Potential irrigation in Canterbury Saunders and Saunders (2012) – as included in the evidence of Dr Caroline Mary Saunders to the Plan Change 1 (PC 1) hearing process. 100105496/846445.10 6 19 Obtaining the main CPW Scheme consents took over ten years, with the first applications lodged in 2001 and the process finishing in early 2012 after all appeals and priority challenges were resolved. The process included various appeals and declarations in the Environment Court, High Court, Court of Appeal and Supreme Court. 20 Today, the CPW Scheme is underpinned by two core or ‘umbrella’ consents, including a water use consent and a nitrogen discharge/land use consent (CRC165680 and CRC165686 respectively). I discuss each consent below, and a copy of each consent is attached to my evidence at Annexure 1. CRC165680 21 CRC165680 (the Use Consent) replaces an earlier consent CRC061973 (the Original Use Consent). This is the CPW Scheme’s ‘umbrella’ water permit to use water and applies to the Command Area shown in Figure 3. Figure 3: Plan CRC165680B Scheme Command Area 22 Water used under the Use Consent cannot be used by a farmer unless they provide Central Plains with a written undertaking, via the Scheme’s Water Use Agreements, that they will comply with the 100105496/846445.10 7 conditions of the consent, and those of CRC156686 (the Discharge Consent, discussed below).3 23 The Use Consent sets a scheme-wide maximum water application rate and a combined annual volume for the concurrent use of ground and surface water, along with a suite of monitoring obligations.4 24 The Original Use Consent contained requirements for farm management plans and reporting on those. The current Use Consent contains parallel concepts and requirements, but the actual content of Farm Environment Plans (FEPs) and reporting has been shifted into the Discharge Consent (discussed below). 25 This leaves the Use Consent with more high-level requirements including inter alia that: 25.1 farmers will be required to take all practical steps not to irrigate beyond field capacity;5 and 25.2 that water supplied under the consent shall not exceed certain application rates.6 26 Importantly, however, the Use Consent also stops Central Plains from supplying water: 26.1 to “any farm or group of farms” where that farm or farms are causing “significant adverse localised effects” resulting in, for example, breaches of standards in the relevant planning framework;7 and 26.2 to farms that have, on a specified audit methodology, received two consecutive C or D FEP audit grades (although there is a limited exception to failures over effluent management objectives before 1 July 2019).8 27 The Use Consent therefore places important high level constraints on the CPW Scheme’s use of water. It effectively ensures that a farmer’s ability to be supplied by Central Plains is wholly dependent on preparing, producing, maintaining and implementing an FEP, and 3 CRC165680, condition 3. 4 CRC165680, condition 4 – 6. 5 CRC165680, Condition 5. 6 CRC165680, Condition 6. 7 CRC165680, Condition 9. 8 CRC 165680, Condition 10. 100105496/846445.10 8 on running an operation that will not cause any significant localised adverse effects. CRC165686 28 CRC165686 (the Discharge Consent) has been the CPW Scheme’s ‘umbrella’ nutrient discharge consent since 6 April 2016. It applies to the area shown in Figure 4, and expires on 25 July 2047. It is Central Plains’ first discharge consent.
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