Meridian Energy Limited

BEFORE THE CANTERBURY REGIONAL COUNCIL

IN THE MATTER of the Resource Management Act 1991

AND

IN THE MATTER of Proposed Plan Change 5 to the Canterbury Land and Water Regional Plan

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STATEMENT OF EVIDENCE JEFFREY ALLEN PAGE ON BEHALF OF MERIDIAN ENERGY LIMITED

22 JULY 2016 ______

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ANDERSON LLOYD Level 10, Otago House LAWYERS Cnr Moray Place & Princes DUNEDIN Street, Private Bag 1959, Solicitor: S W Christensen DUNEDIN 9054 ([email protected]) DX YX 10107 Tel 03 477 3973 Fax 03 477 3184 INTRODUCTION

Qualifications and Experience

2 My name is Jeffrey Allen Page.

3 I am employed by Meridian Energy Limited (“Meridian”) as its Environmental Strategy Manager. In this role I am responsible for managing a team focussed on obtaining, retaining and achieving compliance with the necessary statutory environmental authorisations for Meridian’s existing assets and new projects. As part of this role, I have a particular focus on the environmental management of the Waitaki Power Scheme. I have been employed by Meridian since October 2010.

4 I hold academic qualifications1, institute membership2 and experience3 as a professional resource management planner. I have provided expert evidence as part of many hearing processes, including before the Environment Court. I have also participated in a large number of resource management policy and plan development and implementation processes within Canterbury, including those relating to the Waitaki catchment.

5 I am not making this Statement as a planning expert. Rather, this statement is made as Meridian’s Environmental Strategy Manager. This means that this brief is a statement of fact as opposed to a statement of expert opinion.

Scope of Evidence

6 In my statement I outline:

(a) Meridian’s interest in water quality in the Waitaki Catchment;

(b) The circumstances in which adaptive management or monitoring and response conditions are applied in Upper Waitaki consent processes; and

7 In this evidence, when I use the term:

1 BSurv (dist) and MRRP (dist), Otago University 2 MNZPI 3 I have worked as a professional planner in a number of local government and private practice roles since 1992.

(a) “Waitaki Power Scheme” I mean the lakes, canals and infrastructure of the entire Scheme, irrespective of whether it is managed by Genesis Power Limited (Genesis) or Meridian. Ownership of the Waitaki Power Scheme is as follows:

(i) Genesis owns and operates the two Tekapo Power Stations, and associated canals, dams, lake control structures and other infrastructure, upstream of the tailrace of Tekapo B Power Station. These Power Stations are Tekapo A and Tekapo B.

(ii) Meridian owns and operates six Waitaki Power Stations, and associated canals, dams, lake control structures and other infrastructure, from Lake Pukaki downstream to the Waitaki Dam. These Power Stations are: Ohau A, Ohau B, Ohau C, Benmore, Aviemore and Waitaki.

Meridian’s interest in water quality

8 In this section of evidence I summarise Meridian’s interest in water quality within the Waitaki Catchment. This is to provide context for Meridian’s involvement in Plan Change 5.

9 The Waitaki Power Scheme has changed characteristics of water bodies in the Waitaki Catchment. In overview terms, as shown in Appendix 1:

(a) Natural lakes are now managed as storage lakes – Lakes Tekapo (raised), Pukaki (raised) and Ohau (operated largely within its natural range);

(b) Artificial lakes have been created by damming natural rivers – Lakes Ruataniwha (including the Wairepo Arm), Benmore, Aviemore and Waitaki;

(i) By diverting the main4 source flows, except for spill flows – Tekapo, Pukaki and Lower Ohau rivers

4 Flows from Lake Tekapo, Pukaki and Ohau (via Ruataniwha). Below these lakes, there are a number of important tributary flows, such as the Forks Stream in relation to the Tekapo River. In addition, these rivers are used to manage ‘spill’ from the lakes, receive water when gates are tested and to provide periodic flows for the purposes of recreation (kayaking).

(ii) By mixing water higher in the catchment than would have occurred naturally – Lakes Tekapo and Pukaki water is generally mixed in Lake Pukaki (at the Tekapo B Power Station tailrace) instead of the confluence of the Tekapo and Pukaki rivers, and Lakes Pukaki and Ohau water is mixed at the confluence of Pukaki and Ohau canals and the confluence of Ohau A tailrace and Upper Ohau River instead of at the confluence of the Waitaki River (now dammed) and Ohau River.

(iii) By changing flow characteristics – Upper Ohau River and Lower Waitaki River;

(d) Smaller artificial water bodies have also been created – including Lake George Scott, Patterson Ponds, Lake Wardell, Lake Poaka, Lake Merino, Loch Cameron, Kellands Pond, Tomahawk Lagoon; and

(e) The above, together with the Waitaki Power Scheme canal system, has undoubtedly modified the contribution of surface water to groundwater and groundwater flows.

10 In the context of Plan Change 5, as outlined above Meridian influences water quality not by introducing contaminants into the environment, but by altering the path and timing of natural movement of water through the Waitaki Catchment.

11 In addition, other influences have emerged within the Catchment that relate to the achievement of water quality outcomes:

(a) Agricultural land use has intensified, resulting in increased nutrients in the receiving environment;

(b) Activities such as aquaculture have commenced and expanded, resulting in new and increased nutrients in the environment; and

12 Meridian’s operation of the Waitaki Power Scheme is both directly and indirectly influenced by water quality within the Catchment. The direct operational consequences of the changes in water quality arise from

5 Elodea, Lagarosiphon which first appeared in February 2003, and didymo which appeared in approximately 2006.

increased aquatic plant growth. This increases the costs of the management of the Waitaki Power Scheme through increased aquatic weed management and civil engineering responses (such as the installation and operation of further screens on intakes). At present Meridian:

(i) Manages and cleans intake screens in the Ohau B and C power stations. This activity has been undertaken since at least 2009. Currently, the top part of the screens are raked about 3 times per year by Meridian staff and the bottom part cleaned by contracted divers6 annually or less as need arises. It is estimated that approximately 5m3 of weed is removed from the Ohau B Station screens and 4m3 per year from the Ohau C screens. The annual cost of this activity is $30,000;

(ii) Is planning to replace and upgrade the Ohau B and C power stations screens. Aquatic weed is currently causing the screens to bend by creating water resistance, hence hydraulic pressure. This both shortens the life of the existing screens and represents an unacceptable failure risk of the screen breaking and debris being transported through generators. The replacement will provide for more effective screen cleaning. The cost of this project is currently estimated at $1.3M to $1.5M;

(iii) Undertakes removal of aquatic weed within its canals. Meridian is observing weed mats floating down its Ohau B and C canals, and increased weed presence in the Pukaki/Ohau Canals confluence area. Aquatic weed removal (generally by Diquat spraying, to date), began as a systematic programme in 2011, although more ad hoc activity occurred prior to this. Currently this has an annual cost of approximately $30,000 to $50,000;

(iv) Partners with Land Information New Zealand (LINZ) on a yearly basis to control lagarosiphon in Lake Benmore in order to avoid, or at least, slow its spread in relation to

6 This requires flow in the canals to be considerably reduced to create safe diving conditions.

Benmore, Aviemore and Waitaki Power stations. This partnership began in the mid-2000s. Currently this has an annual cost to Meridian of between $175,000 and $200,000; and

(v) In partnership with LINZ, Environment Canterbury and Genesis, is undertaking aquatic weed (including didymo) surveillance throughout the Upper Catchment. Currently this has an annual cost to Meridian of approximately $40,000.

13 Meridian is concerned that as water quality decreases, it may be required to change the way it manages7 river flows and lake levels in order to remedy or mitigate the consequences of degraded water quality, such as periphyton. It anticipates this may result in requirements for flushing flows and manipulation of water flows through lakes. Ultimately, this reduces generation potential and generation flexibility.

14 The indirect consequence is decreasing water quality may erode the community benefits of the Waitaki Power Scheme by decreasing the amenity, sports fishery habitat and recreation suitability of rivers and lakes. For Meridian, it is concerned that a diminishment of these local benefits may change the perception of what might be judged as a ‘fair’ outcome within the Catchment from the existence of the Waitaki Power Scheme.

15 In response to the above, and the allocation of water for increased agricultural intensification8, Meridian has worked to understand the potential for water quality change within the Upper Catchment. This includes:

(a) A 2005 study undertaken on the potential water quality impacts from irrigation development9;

(b) Within the Upper Catchment, in the period 2008 to 2013 Meridian commissioned NIWA to undertake three summer years of monitoring of water quality within key sites in the Upper

7 This would result in operational changes and may require one off infrastructure changes. 8 Within the Waitaki Catchment Water Allocation Regional Plan (2005). Above the Waitaki Dam, Meridian has actively supported and agreed to allow managed derogation to occur from its existing consents. 9 Jo Ellwood, Rob Potts, Matt Ryan (GPF) plus NIWA, GNS, AgResearch, HortResearch and Landcare Research (2005) Water Quality Impacts from Irrigation Development Upper Waitaki. Glasson Potts Flower Limited

Catchment10. This monitoring had two purposes. The first was to inform Meridian’s understanding of water quality for hearings of the Upper Waitaki Irrigation water permit applications. The second was to establish a baseline against which future water quality could be assessed;

(d) Commissioning NIWA to monitor the water quality impacts of salmon farms within its canals in 2012, 2015 and 2016.

16 Meridian participated in the development of Plan Change 5 through its pre-statutory and statutory phases. This includes making available water quantity and quality information to Environment Canterbury, as well as the results of various studies, and supporting Environment Canterbury's engagement of NIWA for the purposes of the modelling of Lake Benmore.

Upper Waitaki Irrigation consent processes – the feedback (monitoring and response) loop

17 In this section of evidence I describe the circumstances in which adaptive management or monitoring and response conditions are being applied in Upper Waitaki consent processes. The purpose of this is to provide context to Meridian’s submission on Policy 15B.4.20(d) and the evidence of Ms Dawson.

18 Meridian has participated in many of the Upper Waitaki irrigation water permit (s14 of the RMA) applications11 and other publicly notified applications that could result in water quality effects12 in order to protect its operations from significant changes in water quality.

19 The water permits granted13 as a result of the irrigation applications include a generally consistent set of conditions14 providing for the monitoring and response conditions described by Ms Dawson.

10 Sutherland, D. Kelly, G. & McDemott, H. Waitaki Water Quality (2013) 2008 – 2013 NIWA Client Report CHC2103-117.

11 Starting with the determination of those consent applications ‘called in’ through Schedule 2 of the Resource Management (Waitaki Catchment) Amendment Act 2004 12 For example the discharge permit for Mr McIntyre (Twizel Dairies) for dairy effluent 13 By the consent authority and on appeal.

20 In the local hearing Part A Catchment Wide Issues decision, the Hearings Panel was cautious to ensure that an adaptive management approach in consent conditions was not seen as a substitute for forming a view of whether the effects were appropriate in the Upper Catchment as a whole15. Following this Part A decision, and a series of caucusing and evidence processes, the common monitoring and response condition approach emerged within the decisions on the individual applications (the Part B Site Specific Decisions). This pattern of conditions has continued within the Consent Orders granted for those Part B decisions which were appealed and within subsequent consent application decisions.

21 Within the Upper Catchment there are now a significant number of consents with this pattern of monitoring and response conditions. To illustrate this, Appendix 2 of my evidence records those consents which I am aware with conditions that are similar to, or of the same kind, as is discussed by Ms Dawson. To develop Appendix 2 I have:

(a) Reviewed the consent orders resulting from appeals to the Part B decisions (I project manage these for Meridian);

(b) Reviewed the consent applications Meridian has been involved in subsequent to the Part B decisions (I also project manage these for Meridian); and

(c) Reviewed the Part B decisions not appealed or subsequently ‘overtaken’ that are listed on Environment Canterbury’s website16.

22 I attached in Appendix 3 an example consent, being that resulting from the consent order for the Five Rivers application. I do so because it is an example of both Lake Benmore and Lake Zone (Wairepo Arm and Kellands Pond) triggers, monitoring and response conditions. However, I do note this is atypical in that the conditions:

(a) Include groundwater triggers and responses; and

14 With the exception of replacement consents where the effects are minor or very small areas of new irrigation. See as an example, Birchwood Run Ltd Report and Decision of Hearing Commissioners Paul Rogers, Michael Bowden, Dr James Cooke and Edward Ellison Part B – Site Specific Decision Catchment Wide Issue (29 March 2012) 15 Report and Decision of Hearing Commissioners Paul Rogers, Michael Bowden, Dr James Cooke and Edward Ellison Part A – Catchment Wide Issue (22 November 2011), para 3.19 to 3.20 and 12.81 16 http://ecan.govt.nz/get-involved/consent-projects/waitaki-consents/upper-waitaki/Pages/decisions.aspx

(b) Include P triggers and responses in relation to Wairepo Arm; and

(d) Do not use the Irrigation Proportional Factor17 when applying the percentage reduction required of the nutrient discharge allowance (NDA).

Water quality monitoring points

23 Meridian submitted seeking a new monitoring point for Wairepo Arm18 and an alternative monitoring point for Kellands Pond19. I have shown these on a map in Appendix 4, together with other monitoring points I am aware of in these locations.

24 The Wairepo Arm monitoring location is sought in conjunction with new water quality limits. This location is the same as specified on the Five Rivers consent order (See Appendix 3, Condition 102) and West Edge consent order (CRC01229120). I note that McIntyre dairy effluent consent order (CRC12181421) and Mount Cook Alpine Salmon consent (CRC15560422) specify a different mid-lake location, closer to Lake Ruataniwha.

25 For Kellands Pond, PC523 specifies an edge-lake location for monitoring. Meridian submitted seeking a mid-lake location. This location is the same as is used in the Five Rivers consent order (See Appendix 3, Condition 102). I note that the McIntyre dairy effluent consent (CRC12181424) monitoring location is an edge-lake location, but different to that within PC5.

26 For completeness, I record that Meridian has also sought a new monitoring location for Lake Ruataniwha in conjunction with new water

17 Irrigation Area divided by Property Area

18 NZTM 1366937 5090850 19 NZTM 1365979 5090899 20 Condition 71 – NZMS 260 H38:769-525 (converted to NZTM 1367237 5090850)

21 Condition 32 – NZMS 260 H38:7720-5262 (converted to NZTM 1367238 5090970)

22 Condition 16(a)(iii) - BZ15:6723-9097 (NZMS 260 H38:7720-5262) (converted to NZTM 1367238 5090970)

23 Table 15B(d) – 2275898 5652428 (converted to NZTM 1365935 5090778) 24 Condition 26(b) – NZMS 260 H38:7580-5220 (converted to NMTM 1365837 5090549)

quality limits, being the general location of “Ruataniwha Dam”. To my knowledge there is no established monitoring point for this lake.

Jeffrey Allen Page

22 July 2016

Appendix 1: Overview of the Upper Waitaki

Lake Tekapo (Raised storage)

Lake Pukaki (Raised storage) Lake George Scott Tekapo/ (Artificial) Pukaki water mixing Tekapo Canal Patterson Pond (Artificial) Lake Wardel (Artificial) Tekapo River Lake Poaka (Lake Tekapo (Artificial) inflows diverted)

Lake Merino (Artificial) Loch Cameron Pukaki Canal (Artificial) Lake Ohau (Storage) Ohau Pukaki Canal River (Diverted) Lake Lower Ohau Ruataniwha River (Artificial) (Diverted)

Upper Ohau Pukaki/ River Ohau Tomahawk (Controlled) water Lagoon mixing (Artificial)

Ohau B/C Canals Kellands Pond Haldon Arm and Wairepo Arm (Artificial) Lake Benmore (Artificial)

Ahuriri Arm

Lake Aveimore (Artificial)

Lake Waitaki (Artificial)

Appendix 2: Examples of consents with monitoring and response conditions

ECISION 25 CONSENT D ADAPTIVE MANAGEMENT RECEIVING AME N 26 TYPE TYPE ENVIRONMENT

OTHER GROUND BENMORE RIVERS LAKES WATER

Irishmans Creek Water Station Limited permit – CO No No Yes No (CRC011845) irrigation

Killermount Station Water Limited permit – CO Yes No Yes No (CRC041777) irrigation

Dunstan Peaks Water Limited permit – CO Yes No Yes No (CRC011361) irrigation

Yes

Five Rivers Limited Water (Wairepo permit – CO Yes Arm Yes Yes (CRC061154) irrigation Kellands Pond)

Falconer and others Water [Peak Valley] permit – CO Yes No Yes No irrigation (CRC060253)

Water Anderson permit – CO Yes No Yes No (CRC012019) irrigation

Water Bog Roy permit – CO Yes No Yes No (CRC012017) irrigation

Ellis Lea Farms 2000 Limited & others Water [Government Race] permit – CO Yes No Yes No irrigation (CRC991473)

Glentanner Water [Catherine Fields] permit – ECan Yes No No No (CRC163408) irrigation)

Yes M Horo Water permit – CO Yes (Wairepo Yes No (CRC042022) irrigation Arm)

25 Where these relate to a consent order, the name and CRC number are as recorded in the consent order. 26 CO = Consent Order, ECan = consent authority local decision

DECISION 25 CONSENT ADAPTIVE MANAGEMENT RECEIVING AME N 26 TYPE TYPE ENVIRONMENT

OTHER GROUND BENMORE RIVERS LAKES WATER

McAughtrie Water permit – CO Yes No Yes No (CRC011940) irrigation

Waitangi Water permit – CO No27 No Yes No (CRC030944) irrigation

Grays Hill Water permit – CO Yes No Yes No (CRC042661) irrigation

Totora Water permit – CO Yes No Yes No (CRC020584) irrigation

Upper Waitaki Community Irrigation Water Company permit – CO No No No No irrigation (CRC01128)28

S J B Munro Water permit – CO No29 No No No (CRC060938) irrigation

Bellfield Water permit – CO Yes No Yes No (CRC011987) irrigation

Otamatapaio Water permit – ECan No No No No (CRC155509) irrigation

Otamatapaio Water permit – ECan Yes No No No (CRC155512) irrigation

Otamatapaio Water permit – ECan Yes No No No (CRC161485) irrigation

Twin Peaks Water permit – CO Yes No Yes No (CRC063564) irrigation

Water Otematata permit – CO Yes No Yes No (CRC041033) irrigation

27 Receiving environment is Lake Aviemore 28 Receiving environment is Lower Waitaki River (below the Waitaki Dam) 29 Receiving environment is Lake Aviemore

DECISION 25 CONSENT ADAPTIVE MANAGEMENT RECEIVING AME N 26 TYPE TYPE ENVIRONMENT

OTHER GROUND BENMORE RIVERS LAKES WATER

Classic Properties Water permit – CO Yes No Yes No (CRC063106) irrigation

West Water Yes Edge/Birchwood permit – CO No (Wairepo Yes No (CRC012291) irrigation Arm)

Yes Discharg McIntyre Dairies e permit (Wairepo – dairy CO Yes Arm No No (CRC121814) shed effluent Kellands Pond)

Discharg e permit Mount Cook Alpine – Yes Salmon contamin ECan Yes (Wairepo No No (CRC155604 ants from Arm Salmon farm

Bendrose Water (CRC155429 and permit – ECan Yes No Yes No CRC155422) irrigation

Black Forest Water permit – ECan Yes No No No (CRC164826) irrigation

Haldon Station Water permit – ECan Yes No No No (CRC144880) irrigation

Glenmore Station Water permit – ECan No No Yes No (CRC052502) irrigation

Aviemore Station Water (CRC041031 and permit – ECan No No No No CRC083692) irrigation

Otematata Station Water permit – ECan (?) No No No No (CRC020355) irrigation

Otematata Station Water (CRC041033) permit – ECan (?) Yes No Yes No irrigation

DECISION 25 CONSENT ADAPTIVE MANAGEMENT RECEIVING AME N 26 TYPE TYPE ENVIRONMENT

OTHER GROUND BENMORE RIVERS LAKES WATER

Graham Water [Te Akatarawa 30 permit – ECan No No No No Station] irrigation (CRC161635)

30 Receiving environment is Lake Aviemore

Appendix 3: Five Rivers Limited v Canterbury Regional Council (Env- 2011-CHC-136) Consent Order, 22 September 2014

Appendix 4: Kellands Pond and Wairepo Arm water quality monitoring points

Map Reference: NZMG E 2275898 N 5652428 Map Reference: NZMS 260 H38:7720-5262 (PC5, Table (15B(d)) (From McIntyre diary effluent consent and Mount Cook Alpine Salmon consent) Map Reference: NZTM E 1365979 N 5090899 (Meridian submission, from Five Rivers) )consent)

Wairepo Arm Kellands Pond

Map Reference: NZTM E 1366937 N 5090850 (Meridian submission, from Five Rivers consent) Map Reference: NZMS H38: 7580-5220 (McIntyre diary effluent consent)