Download C/- Mr. Geoff Ackerley - Environment Canterbury

SAVE THE RIVERS MID-CANTERBURY INC.
SUBMISSION ON THE LAND AND WATER REGIONAL PLAN
Save the Mid-Canterbury would like to express its support for the overall intention of the plan.
Our organization has been actively involved with issues related to the protection and
enhancement of our local environment over an extended period of time and we hope that this
plan will result in the achievement of many of our objectives.
We would like to make the following points with respect to the Ashburton River, Section 13 of
the plan.
1. The Introduction (P1,2)
While we support the identification of priority outcomes for the Ashburton River we would
like to remind you that there are other waterways which also require the same level of
attention, for example the Hinds River.
While we are pleased with the provision of minimum flows we feel that the immediate
target needs to be 10 cumecs. We believe that the goal for the longer term minimum flow of
10,000L/s should be achieved in a shorter time frame than the year 2022 which is
mentioned later in this chapter. Save the Rivers Mid-Canterbury Inc. has made repeated
submissions which have suggested potential strategies which could be used to reach this
goal; these relate actions such as to closing stock water races, greater efficiency and the
more effective use of groundwater resources. We have consistently stated that the priority
consequences of such gains need to be the retention of more water in the Ashburton River.
We are not sure that plans to maintain flows in the North Branch of the Ashburton River are
realistic. It would be great if these could be achieved but this organization would like to
suggest that there is a need for a backup plan which could be implemented if North Branch
flows cannot be maintained.
While we have expressed some concerns about the trading of water permits we
acknowledge that there could be potential environmental gains if these result in the retention
of water in the river.
Save the Rivers Mid-Canterbury would like to challenge suggestions that the RDR should
be treated as a special case. This is considered to be a fairness issue. Our stance with respect
to RDR extractions from the Ashburton river is that as much water as possible should be
extracted from the Rangitata River before Ashburton extractions are considered.
As stated in past submissions we oppose on river storage, there is the potential for too much
environmental damage as the result of a dam on the river.
2. 13.2: Water Conservation Orders that apply to the Ashburton Sub-region area.
Save the Rivers Mid-Canterbury would like to make it clear that we want Water
Conservation Orders and the residual flows that they support to be upheld.
3. 13.4 Policies
13.4.1: Save the Rivers Mid-Canterbury would like to repeat our belief that, because they
are highly inefficient (4%-5% of the water consumed is for consented purposes and
this is not good in this day and age of efficient use) and the water quality in races is
not of high standard, stock water races should be closed. As a consequence gains in
water volumes should be kept in the Ashburton River. It needs to be remembered
that the Ashburton River has supported bird and fish life for thousands of years
while the RDR has been around for a much lesser period of time; taking care of the
river should be a priority.
13.4.2: We support this policy but believe that if replacement of a water permit for surface
water is considered then it should only be granted if there are no practical
alternatives.
13.4.3: We support this policy.
13.4.4: Our support for this policy would be dependent on an understanding that allocations
of the remaining 35 million cubic metres results in the return of more water to the
river.
14.4.5: We believe that the groundwater take should not be more than the corresponding
surface water take.
14.4.6: We support this policy.
14.4.7: We would like to repeat the earlier comment that the RDR should not be treated as a
special case. They need to be subject to SH1 minimum flows.
4. 13.5 Rules
Save the Rivers Mid-Canterbury would support the use of any rules which will result in
benefits to all interested parties but there would have to be an assurance that there are no
environmental costs. However monitoring procedures need to be put in place, with
appropriate consequences for those who break the rules.
5. 13.6 Allocation limits
Please refer to earlier comments about our concern that proposed North Branch flows are
experimental in nature and that they may not be realistic. A Plan B needs to be formulated.
This could involve the better use of groundwater, water storage, closure of the Mount
Somers stock water race and even having water conveyed by Greenstreet Irrigation to the
river.
It is felt that the provision of stated minimum flows should help keep the river mouth open,
a major consideration for our organization. If the river mouth stays opens the fishery will
improve and all species in that environment will have enhanced chances of survival. The
need to keep the river mouth open emphasizes the need to put water back into the river;
river mouth closure is a crime against the environment especially at times when, if the river
flowed naturally, the mouth would be open.
It is important when setting flows that thought is given as to how these will be achieved and
for the plan to have integrity. Every effort must be put into achieving the objective.
6. 13.8 High Naturalness Waterbodies
Save the Rivers Mid-Canterbury Inc have concerns about the accuracy of some of the
identified characteristics.
Lake Emily: This is an internationally renowned fishery for fontanalis trout yet this is not
recognized.
Maori Lakes: The ‘top’ lake contains rainbow trout and this is not stated. These lakes are
a well regarded fishery for local anglers and should be recognized as such.
Lake Camp: We are not sure that this lake can be classified as a high value habitat for eels.
Lake Roundabout: This is a recognized brown trout fishery.
Lake Mystery: Is not even mentioned.
7. We appreciate the need the need to set catchment load limits and, in particular, to manage
nitrate levels. Much of our lowland is red-carded and Ecan’s recognition of this is crucial.
We can see the value of working with communities to find ways to manage nutrient loads
going on to land and not into water. It is not a case of simply saying a management option
will not work, if a solution is not found then fertilizer applications should be reduced to
what should be regarded as safe levels. The community must work to find a solution and
ways to manage and monitor nutrient levels.
Save the Rivers Mid-Canterbury Inc. would like to make it clear that it is important that, no
matter what details are in the plan, residual flows are the main consideration and we need to
understand what the plan means in terms of these for the river. In our lifetimes we have seen
significant reductions in populations of various fish species and we look to the habitat, the
deterioration in the health of our streams both as to quality and quantity as the reasons. We
question societal values and where greed seems to be taking us. We believe our economy will
only survive if it is environmentally sustainable.
C/- Mr. Geoff Ackerley
77 Trevors Road
Ashburton
Ph 03-308-7718
E-mail: [email protected]
17st September 2012.