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4. Amount of water to be retained in water bodies

4.1 Introduction

This chapter summarises the Board's evaluation of the Plan techniques and provisions for:

defining the amount of water that must be retained in water bodies (the environmental flow and level regimes)
the review of existing resource consents to implement this.

In this chapter, the effectiveness, benefits and costs, and efficiency of the techniques and resulting provisions are examined. Consideration is given to the circumstances where there is uncertain or insufficient information. Based on this evaluation, having regard to efficiency and effectiveness, the Board's overall judgement of whether the techniques, and resulting provisions, are the most appropriate to achieve the objectives is recorded.

'Ramping rates' (rate of change when transitioning from one flow condition to another) do not form part of the environmental flow and level regime. The Board considers that these are appropriately handled through the consent processes.

For the purposes of clarification, the Board records that it considers that the setting of maximum lake levels is outside the primary function of the Plan, being the allocation of water.

Further, the National Water Conservation (Ahuriri River) Order 1990 sets provisions including allocation limits and environmental flows for the taking, using, damming and diverting water from the Ahuriri catchment. Consequently, the environmental flow and level regimes of the Plan do not apply to the water bodies subject to the water conservation order.

4.2 Defining the amount of water to be retained in water bodies

4.2.1 Introduction

Water to be retained in water bodies sustains the qualities of the environment of the Waitaki River and associated beds, margins, tributaries, islands, lakes, wetlands and aquifers.

Within the Plan in different circumstances different combinations of techniques are used to define the environmental flow and level regimes. In each circumstance, the combination of techniques defines the environmental flow and level regime. The individual techniques used are:

minimum flows and levels
flow-sharing
allocation limits
flushing flows.

Where groundwater is hydraulically connected to surface water, or in areas where the groundwater is shallow, it is subject to the relevant environmental flow and level regime for surface water.

4.2.2 Plan provisions

The relevant provisions of the Plan are:

Policies 1, 3, 4, 5, 6 and 7
Rules 2, 3, 12, 15, 16, 19 and 20.

4.2.3 Effectiveness

The Board's evaluation of the effectiveness of the techniques and provisions in the Plan defining the environmental flow and level regimes is summarised in Tables 6, 7 and 8 below. The techniques are evaluated independently of each other. In this circumstance, Objectives 1 and 2 are relevant to the evaluation.

Table 6: Effectiveness of the Plan techniques defining the environmental flow and level regimes - Objective 1

Technique	Objective 1	Effectiveness
Minimum flows and levels	Enables minimum flows and levels to be established through the Plan process. This enables a catchment-wide approach to be taken, recognising the interconnected nature of the river. Recognises the interconnectedness of the groundwater and surface water. In much of the catchment, water flows between surface water and groundwater. Recognises the relationship of Ngāi Tahu and their culture and traditions with the Waitaki catchment, a taonga, and its associated sites and wāhi tapu. Safeguards the life-supporting capacity and maintains people's appreciation and enjoyment of water bodies. Further, minimum flows and levels can be set to safeguard the integrity of the braided river system. Recognises natural lows flows and levels and the effect of these on the qualities of the Waitaki catchment. Enables the provision of water for an individual's reasonable domestic needs, the reasonable drinking-water needs of an individual's animals, and for fire-fighting needs. However, the effectiveness of this technique can be reduced by allocating water in a manner that allows water bodies to operate at the minimum flows and levels for a considerable period of time. This will adversely affect the life-supporting capacity of the water body and its ecosystems, and reduce people's appreciation and enjoyment of a naturally dynamic environment.	Moderate
Flow-sharing	Enables flow-sharing regimes to be established through the Plan process. This enables a catchment-wide approach to be taken, recognising the interconnected nature of the Waitaki catchment. Recognises the interconnectedness of the groundwater and surface water. In much of the catchment, water flows between surface water and groundwater. Flow-sharing allows the natural variations in water bodies to be mimicked. This safeguards life-supporting capacity and maintains people's appreciation and enjoyment of water bodies. Recognises the relationship of Ngāi Tahu and their culture and traditions with the Waitaki catchment, a taonga, and its associated sites and wāhi tapu. However, flow-sharing in isolation of other techniques may, in water-short times, result in the water necessary to sustain the values of the water body being extracted. If this occurs, adverse effects will result on the life-supporting capacity of the water body and its ecosystems, and on people's appreciation and enjoyment of a dynamic environment.	Moderate
Allocation limits	Enables allocation limits to be established through the Plan process. This enables a catchment-wide approach to be taken, recognising the interconnected nature of the Waitaki catchment. Recognises the interconnectedness of the groundwater and surface water. In much of the catchment, water flows between surface water and groundwater. Controls the maximum amount of water that can be allocated to activities from the water body. Consequently, allocation limits can have the effect of retaining water in the water body. This safeguards the life-supporting capacity and maintains people's appreciation and enjoyment of water bodies. Further, it recognises the relationship of Ngāi Tahu and their culture and traditions with the Waitaki catchment, a taonga, and its associated sites and wāhi tapu. However, allocation limits in isolation of other techniques may, in water-short times, result in the water necessary to sustain values of the water body being extracted. If this occurs, adverse effects will result on the life-supporting capacity of the water body and its ecosystems, and on people's appreciation and enjoyment of a dynamic environment. In catchments with no flow recorders, an allocation limit is the most practical part of an environmental flow and level regime to enforce.	Moderate
Flushing flows	Enables flushing flows to be established through the Plan process. This enables an integrated approach to be taken, recognising the interconnected nature of the Waitaki catchment. Flushing flows provide for variations in river flows by creating short periods of higher flows. These flow conditions assist in the movement of silt and removal of algae thereby sustaining the qualities of the Waitaki catchment. Flushing flows are only of benefit where medium level natural variations in the flows in the Waitaki catchment are dampened through the management of the river for hydro-electricity generation purposes.	Moderate

Table 7: Effectiveness of the Plan techniques defining the environmental flow and level regimes - Objective 2

Technique	Objective 2	Effectiveness
Minimum flows and levels	To the extent consistent with Objective 1, minimum flows and levels provide the opportunity to allocate water to activities supporting people and communities social, economic and cultural wellbeing and health and safety. Minimum flows and levels in the lower part of the Waitaki River influence the available operational management flexibility for the hydro-electricity generation system upstream of Waitaki Dam.	Moderate
Flow-sharing	To the extent consistent with Objective 1, flow-sharing enables a proportion of the water flows and levels to be allocated to activities supporting people and communities social, economic and cultural wellbeing and health and safety.	High
Allocation limits	To the extent consistent with Objective 1, allocation limits provide for the allocation of water for activities supporting people and communities social, economic and cultural wellbeing and health and safety.	High
Flushing flows	Water released for the purpose of flushing flows is not available to allocate to activities.	Low

Table 8: Overall effectiveness of the Plan techniques defining the environmental flow and level regimes

	Objective 1	Objective 2	Overall
Minimum flows and levels	Moderate	Moderate	Moderate
Flow-sharing	Moderate	High	Moderate
Allocation limits	Moderate	High	Moderate
Flushing flows	Moderate	Low	Moderate

In summary, it is the Board's judgement that all these techniques are, by themselves, of moderate effectiveness. However, under specific conditions, when two or more of these techniques are combined to reflect the resource management issues of a particular water body, the overall effectiveness will be high.

4.2.4 Benefits and costs

The Board's evaluation of the benefits and costs of the Plan techniques defining the environmental flow and level regimes is summarised in Table 9 below. Where a benefit or cost does not apply to all techniques, the relevant technique(s) are shown in brackets.

Table 9: Benefits and costs of Plan techniques defining the environmental flow and level regimes

Benefits	Costs
Economic Assists decision making by providing a reasonable degree of long term certainty. Provides for economic benefit to be derived from operational management flexibility for hydro-electricity generation activities during periods of unfavourable climatic conditions (minimum flows and levels). Share of the water retained in the surface water bodies will generally be available to derive economic benefit from the generation of hydro-electricity, and from other activities that do not extract water. The reasonable water needs for fire-fighting can be met. Resource consent processes will require less information, resulting in reduced compliance costs.	Economic Compliance costs are incurred if existing resource consents are reviewed to impose new environmental flow and level regimes. Reduced flexibility to recognise the specific circumstances of the resource-consent application being considered. Unless the minimum flows and levels are reduced, less water will be reliably available for extractive activities (minimum flows and levels in combination with flow-sharing and allocation limits). Reduced flexibility as a plan change process would need to be initiated to change the environmental flow and level regimes applied to new consents if lower environmental flow and level regimes are deemed appropriate in the future.
Social Share of the water retained in the surface water bodies will be available for non-extractive recreation activities. Provides an opportunity for parties to contribute to the setting of the levels within a whole-catchment and integrated process. Existence values maintained (minimum flows and levels and flushing flows) or increased by flows in rivers being more natural (allocation limits and flow-sharing). Enables the provisions of water for an individual's reasonable drinking-water needs, the reasonable needs for their animals' drinking-water and the needs for fire-fighting (minimum flows and levels).	Social Reduced flexibility to meet changing community needs and aspirations as a plan change process would be required. Fewer secondary social wellbeing effects to communities may occur through a reduced amount of water being available to extractive uses (allocation limits and flow-sharing).
Cultural Recognises the relationship of Ngāi Tahu and their culture and traditions with the Waitaki River, a taonga, and its associated sites and wāhi tapu. Has particular regard to the kaitiakitanga of Ngāi Tahu.	Cultural
Environmental Recognises the intrinsic values and life-supporting capacity of the water body. Recognises the habitat values associated with the water body, including those habitats within the water body, at the margins of the water body (ie riparian areas) and in wetlands. Links between groundwater and surface water, and the importance of the water exchange which occurs, are recognised and provided for. Provides favourable conditions to protect the integrity of the groundwater system. Influence will increase over time as resource consents are reviewed, replaced or expire. Maintains conditions supporting the movement of silt and removal of algae (flushing flows). Provides for certainty of environmental outcomes (minimum flows and levels). Enables the enhancement of surface water habitats by mimicking natural flow variations (flow-sharing and allocation limits).	Environmental May result in habitat changes associated with changes in water flow regimes. Reduced flexibility as a plan change process would need to be initiated to change the environmental flow and level regimes applied to new consents if higher environmental flow and level regimes are deemed appropriate in the future. Habitat values can be degraded if minimum flow and level conditions occur for more than a short period of time (minimum flows and levels). Habitat values can be degraded when there is a significant abstraction of water (flow-sharing and allocation limits). The values within connected water bodies may be affected and degraded (minimum flows, flow-sharing and allocation limits).

Benefits

Costs

Economic

Assists decision making by providing a reasonable degree of long term certainty.

Provides for economic benefit to be derived from operational management flexibility for hydro-electricity generation activities during periods of unfavourable climatic conditions (minimum flows and levels).

Share of the water retained in the surface water bodies will generally be available to derive economic benefit from the generation of hydro-electricity, and from other activities that do not extract water.

The reasonable water needs for fire-fighting can be met.

Resource consent processes will require less information, resulting in reduced compliance costs.

Economic

Compliance costs are incurred if existing resource consents are reviewed to impose new environmental flow and level regimes.

Reduced flexibility to recognise the specific circumstances of the resource-consent application being considered.

Unless the minimum flows and levels are reduced, less water will be reliably available for extractive activities (minimum flows and levels in combination with flow-sharing and allocation limits).

Reduced flexibility as a plan change process would need to be initiated to change the environmental flow and level regimes applied to new consents if lower environmental flow and level regimes are deemed appropriate in the future.

Social

Share of the water retained in the surface water bodies will be available for non-extractive recreation activities.

Provides an opportunity for parties to contribute to the setting of the levels within a whole-catchment and integrated process.

Existence values maintained (minimum flows and levels and flushing flows) or increased by flows in rivers being more natural (allocation limits and flow-sharing).

Enables the provisions of water for an individual's reasonable drinking-water needs, the reasonable needs for their animals' drinking-water and the needs for fire-fighting (minimum flows and levels).

Social

Reduced flexibility to meet changing community needs and aspirations as a plan change process would be required.

Fewer secondary social wellbeing effects to communities may occur through a reduced amount of water being available to extractive uses (allocation limits and flow-sharing).

Cultural

Recognises the relationship of Ngāi Tahu and their culture and traditions with the Waitaki River, a taonga, and its associated sites and wāhi tapu.

Has particular regard to the kaitiakitanga of Ngāi Tahu.

Cultural

Environmental

Recognises the intrinsic values and life-supporting capacity of the water body.

Recognises the habitat values associated with the water body, including those habitats within the water body, at the margins of the water body (ie riparian areas) and in wetlands.

Links between groundwater and surface water, and the importance of the water exchange which occurs, are recognised and provided for.

Provides favourable conditions to protect the integrity of the groundwater system.

Influence will increase over time as resource consents are reviewed, replaced or expire.

Maintains conditions supporting the movement of silt and removal of algae (flushing flows).

Provides for certainty of environmental outcomes (minimum flows and levels).

Enables the enhancement of surface water habitats by mimicking natural flow variations (flow-sharing and allocation limits).

Environmental

May result in habitat changes associated with changes in water flow regimes.

Reduced flexibility as a plan change process would need to be initiated to change the environmental flow and level regimes applied to new consents if higher environmental flow and level regimes are deemed appropriate in the future.

Habitat values can be degraded if minimum flow and level conditions occur for more than a short period of time (minimum flows and levels).

Habitat values can be degraded when there is a significant abstraction of water (flow-sharing and allocation limits).

The values within connected water bodies may be affected and degraded (minimum flows, flow-sharing and allocation limits).

4.2.5 Efficiency

Following the consideration of the benefits and costs of the techniques defining the environmental flow and level regime, it is the Board's judgement that all of these techniques are, by themselves, of moderate efficiency. However, under specific conditions, when two or more of these techniques are combined to reflect the resource management issues of a particular water body, the overall efficiency will increase to high.

4.2.6 Uncertain or insufficient information

Section 32(4)(b) of the RMA requires the Board to take into account the risk of acting or not acting if there is uncertain or insufficient information. The Board considers that the information available is sufficient to provide a sound basis for its decisions. However, it is aware that there is a lack of specific knowledge, or varying degrees of knowledge, regarding the ecological values in many parts of the Waitaki catchment. In addition, the natural flows of many streams and rivers are not measured. In the absence of comprehensive investigation and assessment, the Board is conscious that the consequences of abstraction above the environmental flow and level regimes put in place may be to undermine, and detrimentally impact upon, existing ecological values. This could have a significant adverse effect to the natural, physical and ecological qualities and values associated with this environment, and, in turn, would result in costs on the environment. Alternatively, the environmental flow and level regimes could over-estimate the ecological values associated with the environment. While this would have positive benefits to the environment, the Board notes that this could result in opportunity costs to water users.

To not act would detrimentally impact upon the management of water takes. The Board, in setting environmental flow and level regimes on the basis of information at hand, has acted in such a way to reduce the cost and uncertainty to potential water extractors. By setting the environmental flow and level regimes at an identified level on the basis of the information at hand, the Board has minimised any potential risk to the ecological values.

If, with time, the environmental flow and level regimes cease to be appropriate, there is the ability to initiate a change to the Plan to address this. In addition, where resource consents to take water within the environmental flow and level regimes are to be treated as a non-complying activity, a degree of flexibility is provided, depending on the individual circumstances of the resource-consent application.

4.2.7 Appropriateness

The Board's evaluation of the effectiveness and efficiency of the techniques defining the environmental flow and level regimes within the Plan is summarised in Table 10 below.

Table 10: Summary of the effectiveness and efficiency of the Plan techniques defining the environmental flow and level regimes

	Effectiveness	Efficiency
Minimum flows and levels	Moderate	Moderate
Flow-sharing	Moderate	Moderate
Allocation limits	Moderate	Moderate
Flushing flows	Moderate	Moderate
Combinations	High	High

Having regard to this information, and taking into account the benefits and costs and the risk of acting due to insufficient information, it is the Board's judgement that the techniques used in the Plan defining the environmental flow and level regimes are the most appropriate to achieve the objectives of the Plan.

4.3 Review of existing environmental flow conditions in resource consents

4.3.1 Introduction

This section summarises the Board's evaluation of the provisions of the Plan relating to section 68(7) of the RMA. Section 68(7) of the RMA is as follows:

where a plan includes a rule relating to maximum or environmental levels or flows or rates of the use of water, or environmental standards of water quality, or air quality, or ranges of temperature or pressure of geothermal water, the plan may state -

(a) whether the rule shall affect, under section 130, the exercise of existing resource consents for activities which contravene the rule; and

(b) that the holders of resource consents may comply with the terms of the rule, or rules, in stages or over specified periods.

4.3.2 Plan provisions

The provisions of the Plan that relate to section 68(7) of the RMA are as follows:

Policies 2, 3, 4, 5, 6, 7, 8, 29, 30, 31, 32, 33, 35, 36, 37, 38, 39, 40, 41, 42, 43, 44, and 45
Rule 25.

4.3.3 Effectiveness

The Board's evaluation of the effectiveness of the provisions in the Plan relating to section 68(7)(a) and (b) of the RMA is summarised in Tables 11 and 12 below. In this circumstance, Objectives 1, 3 and 4 are relevant to the evaluation.

Table 11: Effectiveness of the provisions in the Plan relating to section 68(7)(a) of the RMA

Objective	Section 68(7)(a) - affect existing resource consents	Effectiveness
1	If section 68(7)(a) is not used, environmental flow and level regimes specified by the rules of the Plan will not be applied to those parts of the Waitaki catchment that are either substantially, or fully, allocated until such time as the existing resource consents expire. For parts of the Waitaki catchment this is a considerable time in the future. This would delay the achievement of the outcomes sought in Objective 1. However, the actual implementation of this is reliant upon the actions of the Canterbury Regional Council, not the Board.	Moderate
3	The application of environmental flow and level regimes, within specified time-frames, recognises national and local benefits and beneficial and adverse effects on the environment.	High
4	Will create an incentive to use water with greater technical efficiency where existing consent-holders are required to restrict their take of water more often.	Low/Moderate
Overall effectiveness		Moderate

Table 12: Effectiveness of the provisions in the Plan relating to section 68(7)(b) of the RMA

Objective	Section 68(7)(b) - 7 years for Maerewhenua and 5 years for remainder	Effectiveness
1	Section 68(7)(b) provides the opportunity for the Board to state its expectation as to when the new environmental flow and level regimes will apply in order to achieve Objective 1. However, the actual implementation of this is reliant upon the actions of the Canterbury Regional Council, not the Board. The seven-year period for the Maerewhenua catchment reflects the existing pressures within the catchment and the significant values present, while recognising the time required in order for the necessary infrastructure and practice changes to occur. The five-year time-frame recognises the pressures within the rest of the Waitaki catchment, and thereby provides an appropriate time-frame for the necessary changes in infrastructure and practices.	Moderate
3	The use of Section 68(7)(b) provides for recognition of the relative environmental importance of the different environmental flow and level regimes when compared to the existing situation. The 5-year and 7-year periods recognise the existing investment, and provide reasonable time periods within which to undertake any future investment that may be required to comply with the new environmental flow and level regimes.	High
4	Provides time for existing water users to achieve greater technical efficiency where existing consent-holders will lose the right to take some water.	Moderate
Overall effectiveness		Moderate/High

4.3.4 Benefits and costs

The Board's evaluation on the benefits and costs of the provisions in the Plan relating to section 68(7)(a) and (b) of the RMA is summarised in Tables 13 and 14 below.

Table 13: Benefits and costs of the provisions in the Plan relating to section 68(7)(a) of the RMA

Benefits	Costs
Environmental Allows for the application of new environmental flow and level regimes on existing resource consents to avoid, remedy or mitigate adverse effects on the environment.	Environmental
Economic Any additional share of the water retained in surface water bodies will be available to derive economic benefit from hydro-electricity generation, except where environmental flow and level regime requirements prevent the diversion of water to electricity generation via existing or proposed canal systems, and for other activities that do not extract water (eg tourism facilities).	Economic May reduce the reliability and flexibility of existing consented water takes as a result of the loss, or reduction, of the right to take water at certain times of the year. Existing resource consent-holders' reasonable returns from existing investment may be reduced. Additional investment may be required by existing resource consent-holders to continue to obtain the existing level of benefit from the use of less reliable water. Compliance costs will be incurred by the Canterbury Regional Council, existing consent-holders and other parties participating in the process.
Social Provides for the new environmental flow and level regimes to be fairly applied.	Social Fewer secondary social wellbeing effects to communities may occur through a reduced amount of water being available to existing users.
Cultural Recognises the relationship of Ngāi Tahu and their culture and traditions with the Waitaki River, a taonga, and its associated sites and wāhi tapu. Has particular regard to the kaitiakitanga of Ngāi Tahu.	Cultural

Benefits

Costs

Environmental

Allows for the application of new environmental flow and level regimes on existing resource consents to avoid, remedy or mitigate adverse effects on the environment.

Environmental

Economic

Any additional share of the water retained in surface water bodies will be available to derive economic benefit from hydro-electricity generation, except where environmental flow and level regime requirements prevent the diversion of water to electricity generation via existing or proposed canal systems, and for other activities that do not extract water (eg tourism facilities).

Economic

May reduce the reliability and flexibility of existing consented water takes as a result of the loss, or reduction, of the right to take water at certain times of the year.

Existing resource consent-holders' reasonable returns from existing investment may be reduced.

Additional investment may be required by existing resource consent-holders to continue to obtain the existing level of benefit from the use of less reliable water.

Compliance costs will be incurred by the Canterbury Regional Council, existing consent-holders and other parties participating in the process.

Social

Provides for the new environmental flow and level regimes to be fairly applied.

Social

Fewer secondary social wellbeing effects to communities may occur through a reduced amount of water being available to existing users.

Cultural

Recognises the relationship of Ngāi Tahu and their culture and traditions with the Waitaki River, a taonga, and its associated sites and wāhi tapu.

Has particular regard to the kaitiakitanga of Ngāi Tahu.

Cultural

Table 14: Benefits and costs of the provisions in the Plan relating to section 68(7)(b) of the RMA

Benefits	Costs
Environmental Establishes a clear expectation as to when environmental flow and level regimes will be applied to existing resource consents in order to achieve environmental outcomes during the life of the Plan.	Environmental May slow the implementation of the new environmental flow and level regimes on existing resource consents, prolonging the adverse effects caused by the existing allocation regime.
Economic Allows existing investment regimes to be recognised in the application of the environmental flow and level regimes. Provides certainty as to when investment will be required and sufficient time to allow forward planning of that investment. Addresses the specific pressures of the Maerewhenua catchment.	Economic Compliance costs will be incurred by the Canterbury Regional Council, existing consent-holders and other parties participating in the process.
Social Establishes a clear expectation as to when environmental flow and level regimes will be applied to existing resource consents.	Social
Cultural Recognises the relationship of Ngāi Tahu and their culture and traditions with the Waitaki River, a taonga, and its associated sites and wāhi tapu. Has particular regard to the kaitiakitanga of Ngāi Tahu.	Cultural

Benefits

Costs

Environmental

Establishes a clear expectation as to when environmental flow and level regimes will be applied to existing resource consents in order to achieve environmental outcomes during the life of the Plan.

Environmental

May slow the implementation of the new environmental flow and level regimes on existing resource consents, prolonging the adverse effects caused by the existing allocation regime.

Economic

Allows existing investment regimes to be recognised in the application of the environmental flow and level regimes.

Provides certainty as to when investment will be required and sufficient time to allow forward planning of that investment.

Addresses the specific pressures of the Maerewhenua catchment.

Economic

Compliance costs will be incurred by the Canterbury Regional Council, existing consent-holders and other parties participating in the process.

Social

Establishes a clear expectation as to when environmental flow and level regimes will be applied to existing resource consents.

Social

Cultural

Recognises the relationship of Ngāi Tahu and their culture and traditions with the Waitaki River, a taonga, and its associated sites and wāhi tapu.

Has particular regard to the kaitiakitanga of Ngāi Tahu.

Cultural

4.3.5 Efficiency

Following the consideration of the benefits and costs of the provisions in the Plan relating to section 68(7)(a) and (b) of the RMA, it is the Board's judgement that:

the provisions relevant to section 68(7)(a) of the RMA are of moderate efficiency
the provisions relevant to the use of section 68(7)(b) of the RMA are of moderate/high efficiency.

4.3.6 Appropriateness

The Board's evaluation of the effectiveness and efficiency of the provisions in the Plan relating to section 68(7)(a) and (b) of the RMA is summarised in Table 15 below.

Table 15: Summary of the effectiveness and efficiency of the provisions in the Plan relating to section 68(7)(a) and (b) of the RMA

	Effectiveness	Efficiency
Section 68(7)(a)	Moderate	Moderate
Section 68(7)(b)	Moderate/High	Moderate/High

Having regard to this information, and taking into account the benefits and costs, it is the Board's judgement that the provisions in the Plan relating to section 68(7)(a) and (b) of the RMA are:

with respect to section 68(7)(a), the most appropriate to achieve the objectives of the Plan
with respect to section 68(7)(b), the most appropriate to achieve the objectives of the Plan.

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