Auckland Tauranga Wellington Christchurch PATTLE DELAMORE PARTNERS LTD Consent Variation to Take and Use Groundwater – Assessment of Environmental Effects Hurunui District Council solutions for your environment Consent Variation to Take and Use Groundwater - Assessment of Environmental Effects • Prepared for Hurunui District Council • April 2019 PATTLE DELAMORE PARTNERS LTD 295 Blenheim Road Tel +64 3 345 7100 Fax +64 3 345 7101 Upper Riccarton, Christchurch 8041 Website http://www.pdp.co.nz PO Box 389, Christchurch 8140, New Zealand Auckland Tauranga Wellington Christchurch C03890500R002_AEE ii HURUNUI DISTRICT COU NCIL - CONSENT VARIATION TO TAKE AND USE GROUND W A T E R - ASSESSMENT OF ENVIRO NMENTAL EFFECTS Table of Contents SECTION PAGE 1.0 Introduction 1 2.0 Description of Proposal 2 3.0 Planning Assessment 2 3.1 Resource Management Act 1991 2 4.0 Assessment of Environmental Effects 3 5.0 Proposed Consent Conditions 5 6.0 Consultation 5 7.0 Section 104 – Planning Matters 5 7.1 National Environmental Standards 6 7.2 National Policy Statement for Freshwater Management (NPS-FM) 7 7.3 Canterbury Water Management Strategy 7 7.4 Canterbury Regional Policy Statement 8 7.5 Canterbury Land and Water Regional Plan 9 7.6 Waimakariri District Plan 10 7.7 Hurunui District Plan 11 7.8 Iwi Management Plans 12 8.0 Part 2 of the Resource Management Act 13 9.0 Notification 14 10.0 Conclusions 14 11.0 References 15 Table of Tables Table 1: CRC161302 Abstraction Rates 4 C03890500R002_AEE P A T T L E DELAMORE PARTNERS LT D iii HURUNUI DIST RICT COUNCIL - CONSENT VARIATION TO TAKE AND USE GROUND W A T E R - ASSESSMENT OF ENVIRO NMENTAL EFFECTS Appendices Appendix A: Location of Bore Field Appendix B: Consent CRC161302 Appendix C: Example Hydrograph Appendix D: Water Supply Asset Management Strategy Appendix E: Water Restriction Management C03890500R002_AEE P A T T L E DELAMORE PARTNERS LT D 1 HURUNUI DISTRICT COU NCIL - CONSENT VARIATION TO TAKE AND USE GROUND W A T E R - ASSESSMENT OF ENVIRO NMENTAL EFFECTS 1.0 Introduction Pattle Delamore Partners Ltd (PDP) has been engaged by Hurunui District Council (HDC) to prepare an assessment of environmental effects arising from a consent variation to take groundwater from a bore field on the north bank of the Ashley River near Ashley Township, North Canterbury. Consent CRC161302 authorises HDC to take up to 70 L/s (6,000 m3/day) from seven shallow bores to supply potable water for the Ashley Area. Condition 4 of this consent and the associated water supply asset management strategy (attached to the consent) sets out measures to reduce the rate of take at certain trigger levels. The water supply asset management strategy for this consent defines four levels of restriction and at each level specific demand management measures are required. Community water supplies are not required to comply with the environmental flow and allocation regime provided a water supply strategy is in place and the water supply is managed so as to restrict the use of water from those supplies during periods of low flow. The four levels of restriction specified in the consent represent a range of flow conditions and require HDC to implement measures not just at low flows but also at higher flow levels. In addition, HDC have indicated that during some periods of the year Restriction Levels can change rapidly from day to day which makes it impractical (if not impossible) to implement the required measures at each trigger level. This consent variation proposes to remove some of the trigger levels specified in consent CRC161302. It is proposed to retain the low flow trigger level based on the A-block minimum flow for the Ashley River. No other changes are proposed to consent CRC161302. This consent variation has been prepared on behalf of HDC by PDP and includes: • Details of the proposed consent variation; • A description of relevant legal and planning matters; • A description of the existing environment; • An Assessment of Environmental Effects; The location of the bore field near the Ashley River is shown in Appendix A (Figure 1) and a copy of consent CRC 161302 is included in Appendix B. A copy of the HDC water supply asset management strategy is included in Appendix D which describes how water usage will be reduced at times of low flow. C03890500R002_AEE P A T T L E DELAMORE PARTNERS LT D 2 HURUNUI DISTRICT COU NCIL - CONSENT VARIATION TO T A K E A N D USE GROUNDWATER - ASSESSMENT OF ENVIRO NMENTAL EFFECTS 2.0 Description of Proposal As discussed in Section 1.0 HDC proposes to simplify/rationalise the number of Restriction Levels currently specified in the consent. The current Restriction Levels specified in the attachment of the consent (refer to Appendix B) are based on the A- B- and C-block minimum flows as specified in Table 7 of the Canterbury Land and Water Regional Plan (CLWRP). Restrictions for the Ashley River are based on the flow recorded by ECan at the Ashley Gorge. A hydrograph for the Ashley River at the Gorge along with the different trigger levels specified in the water supply asset management strategy is included in Appendix C. This graph indicates that Restriction levels can change rapidly from day to day. For example, on 4 February 2018 there would have been no restrictions, with Level 1 restriction required on 5 February, Level 2 restrictions on 6 February and Level 3 restrictions on 8 February 2018. Thereafter, Level 1 restrictions would have applied on 12-13 February, and subsequently Level 3 restrictions from 14 February. Looking at the water restrictions management table this would have required a whole range of demand management measures to be put in place and changed over a very short period of time as well as continuous changes in the communication with the public via a range of communication methods (refer to final page on Appendix B). In summary at times of rapidly changing flow compliance with the consent is impractical if not impossible. In summary HDC proposes to remove condition 4(a) of consent CRC161302 and replace the “Water Restriction Management” outlined in Schedule CRC161302. The updated schedule is attached in Appendix E. It is considered that no other changes are required to the consent. Condition 5 c. allows for amendments to the “Water Restriction Management’’ detailed in Schedule CRC161302. The changes to the ‘’Water Restriction Management’’ schedule also include minor changes to the wording under column ‘’Demand Management During Restriction’’ and ‘’Method of Communication’’. For consistency the wording in the schedule has been updated to be in line with the wording in consent HDC consent CRC154223 (Balmoral Rural Water Supply). 3.0 Planning Assessment 3.1 Resource Management Act 1991 Section 14(2) of the RMA states that no person may take or use water unless it is allowed by Subsection (3). Subsection 14(3) states that a person is not prohibited by Subsection (2) from taking or using water if it is “expressly allowed by a national environmental standard, a rule in a regional plan as well as a rule in a proposed regional plan for the same region (if there is one), or a resource consent”. C03890500R002_AEE P A T T L E DELAMORE PARTNERS LT D 3 HURUNUI DISTRICT COU NCIL - CONSENT VARIATION TO TAKE AND USE GROUND W A T E R - ASSESSMENT OF ENVIRO NMENTAL EFFECTS The Applicant holds resource consent CRC161302 to take groundwater. It is proposed to vary the conditions of CRC161302, as outlined in Section 1.0. With respect to consent variations, Section 127 of the RMA states that: (3) “Sections 88 to 121 apply, with all necessary modifications, as if a. the application were an application for a resource consent for a discretionary activity; and b. the references to a resource consent and to the activity were references only to the change or cancellation of a condition and the effects of the change or cancellation respectively.” Therefore, the variation to CRC161302 is to be processed as a discretionary activity, and the consent authority is limited to assessing the difference in effects between the existing consented activity, and the effect (if any) of the change in activity. 4.0 Assessment of Environmental Effects The proposed variation to consent CRC161302 held by HDC constitutes mainly a change to bring the Restriction Levels in line with typical Restriction Levels for community supplies throughout Canterbury. Community supplies are generally only required to implement measures which reduce the take of water below the A - block minimum flow and not at higher (B- or C- block) minimum flow levels. For example the Water Restriction Management for the Balmoral Rural Water Supply specified in consent CRC154223 only requires HDC to implement measures to reduce water use when flows are below the A-block minimum flow. Bowden Environmental (2015) assessed the stream depletion effect of the bore field on the Ashley River and classified the stream depletion effect as ‘high’. As such minimum flow conditions are required for the consent. The current conditions of CRC161302 include minimum flow restrictions which are based on the A, B and C block minimum flows. The various restriction levels and corresponding flow rates in the Ashley River are summarised below in Table 1. The maximum consented abstraction rate under CRC161302, i.e. 70 L/s, is also expressed as a percentage of the river flow for the various restriction levels. C03890500R002_AEE P A T T L E DELAMORE PARTNERS LT D 4 HURUNUI DISTRICT COU NCIL - CONSENT VARIATION TO TAKE AND USE GROUND W A T E R - ASSESSMENT OF ENVIRO NMEN TAL EFFECTS Table 1: CRC161302 Abstraction Rates Restriction Flow Rates in Ashley Max.