DPR-0454 1 | P a g e CENTRAL PLAINS WATER LIMITED SUBMISSION ON PROPOSED SELWYN DISTRICT PLAN Form 5: Submissions on a Publicly Notified Proposed Policy Statement or Plan under Clause 6 of Schedule 1 of the Resource Management Act 1991 By email: [email protected] Full Name: Robyn Fitchett Organisation: Central Plains Water Limited Postal Address: PO Box 9424, Tower Junction, Christchurch 8149 Email: [email protected] Phone (DDI): 03 928 2916 Trade Competition Pursuant to Schedule 1 of the Resource Management Act 1991, a person who could gain an advantage in trade competition through the submission may make a submission only if directly affected by an effect of the proposed policy statement or plan that: a) adversely affects the environment; and b) does not relate to trade competition or the effects of trade competition. Please tick the sentence that applies to you: ☒ I could not gain an advantage in trade competition through this submission; or ☐ I could gain an advantage in trade competition through this submission. If you have ticked this box please select one of the following: ☐ I am directly affected by an effect of the subject matter of the submission ☐ I am not directly affected by an effect of the subject matter of the submission Signature: Date: 10 December 2020 (Signature of person making submission or person authorised to sign on behalf of person making the submission) Please note: (1) all information contained in a submission under the Resource Management Act 1991, including names and addresses for service, becomes public information. ☒ I do not wish to be heard in support of my submission; or ☐ I do wish to be heard in support of my submission; and ☐ I would be prepared to consider presenting my submission in a joint case with others making a similar submission at any hearing “Providing reliable and cost-effective water to achieve sustainable value” 2 | P a g e Submission A. Introduction A. Thank you for the opportunity to provide feedback on the proposed Selwyn District Plan1. 1. The Central Plains Water Enhancement Scheme2 provides water for community-scale irrigation, stockwater, firefighting, the Selwyn Near River Recharge Project, and some raw water supply to treatment works operated by Selwyn District Council. The water is provided by utilising run-of-river water from both the Rakaia, and Waimakariri rivers, supported by stored water from Lake Coleridge and a storage pond near Sheffield. The Scheme has capacity to provide water to an irrigable area of 60,000 hectares within a command area of over 100,000 hectares. This command area sits within the Canterbury Plains between the Southern Alps to the west, State Highway 1 to the east, the Waimakariri River to the north and the Rakaia River to the south. The total establishment cost of the scheme is in the order of $450 million (excluding on farm-costs). The scale of investment, and the increased productivity as a result of access to water, make the scheme significant to the Selwyn District, and arguably, the nation. 2. The Central Plains Water Trust3 was established jointly in 2003 by Christchurch City Council and Selwyn District Council to implement the Scheme. In July 2012, the Trust was granted resource consents from Environment Canterbury and Selwyn District Council to construct and operate the Scheme. The consents enable the Trust to take and use water for irrigation purposes as well as to construct and operate the Scheme. CPW as a company was subsequently established and is responsible for constructing and operating the Scheme, and for all consent compliance and reporting. For the purposes of this document, hereon the Trust and CPW are referred to collectively as CPW. 3. CPW is committed to creating sustainable value for its shareholders, employees, contractors, suppliers, business partners and the Selwyn District. To achieve this, CPW strives to be a leader in sustainable irrigation performance in New Zealand. 4. CPW works to ensure a net gain to the cultural and ecological health of the environment, which includes Lake Ellesmere/Te Waihora and its catchment. We work to achieve effective integrated management of land and water; and to develop, implement and maintain systems for sustainable management that drive continual improvement. With this we: a) Meet or exceed applicable legal requirements; b) Understand, uphold and respect cultural heritage, Ngāi Tahu values in relation to water, the natural environment and other taonga; c) Encourage efficient use of natural resources, including reducing and preventing pollution and improving aquifer volumes by reducing reliance on groundwater; d) Enhance biodiversity protection by assessing and considering ecological values; 1 Referred to as "the Plan" 2 Referred to as “the Scheme” 3 Referred to as “the Trust” “Providing reliable and cost-effective water to achieve sustainable value” 3 | P a g e e) Engage regularly, openly and honestly with people affected by the Scheme and take their views into account in decision making; f) Develop partnerships that foster sustainability in the local communities and enhance economic benefits; g) Frequently review the Scheme’s performance and report to shareholders, the Trust and Regional Council; and h) Ensure compliance with our consent conditions by requiring a high level of water use efficiency, good management farming practices, water quality and quantity monitoring, environmental enhancement funds and various groups and committees overseeing the performance of the Scheme. 5. For CPW, sustainability is about ensuring that the Scheme is viable and contributes lasting benefits to society on a social, environmental, ethical and economic level. To this end, the Scheme infrastructure could be modified (subject to consents) to deliver water for other purposes, such as urban development and further recharge projects. CPW are also investigating the possibility of a water storage facility fed from the existing Headrace Canal to increase the Scheme reliability. 6. Accordingly, CPW has a direct interest in the development of an effective, clear and precise Plan for the Selwyn District. 7. For ease of use, we have structured our primary submissions in the order that the topic appears within the discussion document. Accordingly, these submissions are structured as follows: B. The specific provisions of the proposed Plan that this submission relates to and the decisions sought from Council, are as detailed in the table in Section B below. C. The outcomes sought and the wording used is a suggestion only. Where a suggestion is proposed it is with the intention of 'or words to that effect'. The outcomes sought may require consequential changes to the proposed Plan, including Objectives, Policies, or other rules, or restructuring of the Plan, or parts thereof, to give effect to the relief sought. We welcome the opportunity to further discuss any of the points with Selwyn District Council, should you wish for more information. For any inquiries relating to this feedback please contact Robyn Fitchett on 03 928 2916, or [email protected]. Yours faithfully, Robyn Fitchett Legal Counsel Central Plains Water Limited DD. 03 928 2916 Email. [email protected] “Providing reliable and cost-effective water to achieve sustainable value” 4 | P a g e B. Feedback Specific Provision in the Proposed Plan Submission Decision sought from Selwyn District Council Part 1: Introduction and General Provisions / Interpretation Definition of Important Infrastructure Support this definition. Retain clause k. of the definition of "Important Infrastructure" k. Public and community-scale irrigation and stockwater infrastructure Definition of Minor Utility Structure Support this definition. Retain clause i. of the definition of "Minor Utility Structure" i. irrigation supply offtake points Definition of Network Utility Operator CPW supports the inclusion of a definition Retain clause d. of the definition of "Network for "Network Utility Operator" in accordance Utility Operator" Has the same meaning as in section 166 of the RMA with the RMA on the basis that CPW is means a person who – distributing irrigation water for supply and d. undertakes or proposes to undertake the distribution therefore is captured by the definition. of water for supply (including irrigation); Definition of Reverse Sensitivity Support with amendment. Reverse Amend the definition of "Reverse Sensitivity" Sensitivity is also applicable to existing CPW as follows: The potential for an approved (whether by consent or structures, which may be affected by The potential for an approved (whether by designation), existing or permitted activity to be earthworks. consent or designation), existing or permitted compromised, constrained, or curtailed by the more activity or structure to be compromised, recent establishment or alteration of another activity constrained, or curtailed by the more recent which may be sensitive to the actual, potential or establishment or alteration of another activity which may be sensitive to the actual, potential “Providing reliable and cost-effective water to achieve sustainable value” 5 | P a g e Specific Provision in the Proposed Plan Submission Decision sought from Selwyn District Council perceived adverse environmental effects generated by or perceived adverse environmental effects an approved, existing or permitted activity. generated by an approved, existing or permitted activity or structure. Part 2: District Wide Matters / Energy, Infrastructure and Transport EI – Policies Support. These objectives