From: Mary Sparrow To: Mailroom Mailbox Subject: Re: Hearing Submission to PC7 from Mary Sparrow and the Sparrow Family Trust Date: Thursday, 16 July 2020 10:38:23 am Attachments: Sparrow hearing submission.docx Hello Please find the attached hearing submission Regards Mary Sparrow BEFORE THE HEARING PANEL OF THE CANTERBURY REGIONAL COUNCIL Under: the Resource Management Act 1991 In the matter of: Proposed Plan Change 7 (PC7) to the Canterbury Land and Water Regional Plan (CLWRP) Statement of evidence of Mary Sparrow and the Sparrow Family Trust (Submitter No. 133) Dated: 14 July, 2020 1 My name is Mary Sparrow (MA Political Science, University of Canterbury). I am an independent social researcher. 2 From 2001 to 2015 I worked for the Waimakariri District Council, initially as a policy planner and finally its principal policy analyst. 3 While working for the Waimakariri District Council I was involved with the development of the Canterbury Water Management Strategy document as a member of the Official’s Group, and then as the Council’s officer supporting the Waimakariri Zone Committee until I resigned from the Council in September 2015. 4 More recently, I was a member of the Environment Canterbury technical team responsible for preparing the social impact assessment of the Zone Implementation Addendum in collaboration with Dr. Nick Taylor. 5 I am a member of the New Zealand Association for Impact Assessment 6 I have lived on my 50 hectare property to the west of Ohoka since 1979, and have held an irrigation consent in partnership with my late husband since 1982. 7 The two matters that are the subject of my submission relate to my interest in the plan as a landowner and groundwater irrigation consent holder, and as a policy analyst with an interest in monitoring. 8 Policy 8.4.25 Page 66 My submission requested the addition of further criteria to be taken into consideration when reviewing applications for the renewal of groundwater consents in catchments that are deemed to be “over allocated”. My main concern is that the focus on the amounts of water previously taken could be unduly restrictive, especially if the review is undertaken after a period of reasonably high and well distributed annual rainfall. Under such conditions the amounts of water drawn for irrigation are likely to be low compared with those used during dryer seasons. 9 The management of a property will influence the volume and pattern of take. If the recent land use has not involved irrigating early in the season, for example, because of the desire to take the first cut of silage/bailage before commencing irrigation the amount of water used has been less than when the property was used to rear bull beef or a part of our neighbour’s milking platform. 10 While it is clear that constraints on the amount of water taken from ground may be necessary to achieve environmental outcomes, it is also undesirable for unnecessary constraints to be imposed because of restricted criteria to be taken into account when renewing groundwater takes. 11 In view of the particular circumstances in some parts of the Waimakariri/Ashley plain, it is also desirable for the characteristics of the availability of groundwater in each locality to be taken into account. Environment Canterbury adopted the Eyre Groundwater Allocation Zone, which covers most of the plain, and it has assessed as being over allocated. 12 My property is some 5 kilometres to the west of Ohoka, an area which is a long way from the southern boundary of the allocation zone, which is the Waimakariri River. The groundwater monitoring which has been undertaken by Environment Canterbury shows that the pattern of groundwater movement over time varies across the zone. 13 The following graph shows the groundwater movement measured by Environment Canterbury in a Swannanoa well M35/0143. This is the monitor which I regard as a good indicator of the groundwater situation in the vicinity of my property to the west of Ohoka. Of particular interest with respect to well M35/143 is the pattern of groundwater movement since the commencement of the WIL scheme in 2000, which has shown less volatility than during the years prior to 2000. 14 This pattern of groundwater movement differs somewhat from the groundwater movement in another Environment Canterbury monitor well located close to Tram and Jeffs Drain Roads in Clarkville (well M35/0637), which is also in the Eyre Allocation Zone. 15 Well L35/0051, the full record for which is below, is located to the south-west of the Eyre Allocation Zone, at 3869 South Eyre Road, fluctuates within a narrower range and does not show the marked variations between wet and dry years apparent in wells to the east and north-east of the allocation zone. 16 These well records provide an illustration differences in movement of groundwater across the Waimakariri/Ashley plain, and it would be reasonable for these to be taken into account when assessing the reductions in take required across the Eyre Allocation Zone to address its over allocation.1 1 Map of Environment Canterbury’s groundwater monitoring wells in the Waimakariri Zone 18 Policy 8.4.35 page 70 My submission requested the addition of (e) to Policy 8.4.35 which addresses monitoring to state: “the results of specific investigations undertaken to identify the effects of legacy and local issues impacting on ground and or surface water nitrate-nitrogen levels, and how these can be mitigated. This submission reflects my concern that while some issues were taken into account while developing the provisions for the Waimakariri Zone in Plan Change 7, and I consider the next 10 years provide an opportunity to fine-tune the plan. 19 As far as gaining a better understanding of the factors influencing the nitrate- nitrogen levels in the area’s ground water, it would appear important to consider the impact of land uses over many years have had. The attachment contains a paper which provides an overview of previous land uses that I prepared for the Ecan Technical Team. 20 An early examples of quite intensive land use, is that in the Swannanoa area there was significant grain growing to support the emerging settlement of Christchurch as early as the 1870, and some cropping persists in this area today. 21 The land on the northern bank of the Waimakariri River that was sold by Mr. Spencer-Bower to the Crown in 1928 had not been developed. This is the area that became the site of the Eyrewell Forest, and is now being converted to dairying or dairy support and beef production. 22 The Cust area is identified by the Plan Change as particularly sensitive and it is one where local issues are relevant. It is an area where close attention needs to be paid to both local and legacy issues is needed. 23 In 1999 Environment Canterbury submitted against on a Proposed Waimakariri District Plan change that would have allowed the intensification of settlement at Cust, because it was an unsewered community. In the 1990s Environment Canterbury’s groundwater scientists had measured elevated nitrate levels down gradient from unsewered rural communities, and its planners were anxious to limit the intensification of settlement at Cust for that reason. 24 Also, prior to the commencement of the WIL irrigation scheme, the existence of elevated nitrates in the Bennetts area to the west of Cust was recognised. It is understood that the inappropriate storage of pig effluent may have contributed to this situation. I offer a set of graphs of the nitrate readings in key wells in the Bennetts/Cust area to illustrate the situation that has prevailed since 1999/2000.2 Well M35/4757 - Bennetts 7.6 7.5 7.4 7.4 7.3 7.3 7.3 7.3 7.3 7.2 7.1 7.0 7.0 7.0 7.0 6.9 6.8 6.8 6.8 6.7 6.7 nitrogen Mg/L 6.6 6.6 6.6 - 6.6 6.5 6.4 Nitrate 6.2 6.0 Year 2 Map identifying the location of wells in the Waimakariri Zone monitored for water quality M35/5869 Howsons Road - west of Cust 16.0 13.6 14.0 12.8 12.7 12.0 10.0 9.8 9.7 9.3 10.0 8.4 8.8 8.8 7.6 7.9 7.8 8.0 6.8 7.2 8.0 6.1 6.7 6.5 6.5 5.3 6.0 4.0 Nitrate Nitrogen mg/L 2.0 0.0 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 Year Well M35/8567 - Cust 14.0 12.2 11.6 12.1 12.0 10.8 9.9 9.9 9.6 9.8 9.8 9.6 9.3 10.0 8.9 8.6 8.2 7.7 8.0 8.0 7.0 6.7 6.1 6.0 5.9 6.0 4.0 Nitrate Notrogen mg/L 2.0 0.0 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 Year M35/6295 - 1139 Oxford Road, Springbank 18.00 16.10 16.00 14.20 14.90 14.00 11.60 11.50 11.90 12.00 10.90 10.6011.1010.60 11.0010.60 11.00 10.00 10.20 10.20 10.20 9.60 10.00 8.80 8.30 8.50 8.00 6.00 4.00 Nitrate Nitrogen mg/L 2.00 0.00 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 Year 25 The Bennetts well has been monitored since 1988, and in an assessment undertaken for the Waimakariri District Council in 2008 the median for the period 1988 – 2006 was 7.15 and the maximum 8.7 and the trend was “decreasing”.3 For the period 2000 – 2019 the median is 7.00 and the maximum 7.5, which would suggest that the nitrate-nitrogen level in this well is continuing to decline, albeit gradually.