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6. The restriction of water takes at times of low water flows and levels

6.1 Introduction

This chapter summarises the Board's evaluation of the provisions in the Plan relating to the reduction of water takes at times of low water flows and levels. Within this chapter the effectiveness, benefits and costs, and efficiency of these provisions are examined. Considerations relating to uncertain or insufficient information do not arise. Based on this evaluation, having regard to effectiveness and efficiency, the Board's overall judgement of whether the provisions are the most appropriate to achieve the objectives is recorded.

6.2 Plan provisions

The relevant provisions of the Plan are:

Policies 20, 23, 24, 25, 26, 27, 35, 45 and 46
Rules 2, 3, 7, 15, 16, 17, 18, 19, 20 and 24.

6.3 Effectiveness

The Board's evaluation of the effectiveness of the provisions in the Plan relating to the reduction of water takes at times of low water flows and levels is summarised in Table 37 below. In this circumstance, Objectives 3 and 5 are relevant to the evaluation.

Table 37: Effectiveness of the provisions in the Plan relating to the restriction of water takes at times of low water flows and levels

Objective	Provisions	Effectiveness
3	Allocating water to essential domestic uses, essential animal drinking needs, maintaining fire-fighting capacity and the processing and storage of perishable produce in times of restriction due to low flows and levels (excluding Lakes Tekapo, Pūkaki and Ōhau) and the flow-sharing requirements recognises the significant local benefits created by these activities which are derived from small volumes of water. Allocating water from Lakes Tekapo, Pūkaki and Ōhau for town and community water supplies, stock drinking-water, tourism and recreation facilities, maintaining fire-fighting capacity and the processing and storage of perishable produce in times of low lake levels recognises the significant local benefits created by these activities and negligible effect of these water takes on lake levels. Giving priority to integrated schemes in which water is used for more than one purpose reflects the national and local benefits of the multiple use of water. Implementation of this priority will occur through the assessment of resource-consent applications.	Moderate/High
5	Essential domestic needs, essential animal drinking needs, maintaining fire-fighting capacity and the processing and storage of perishable produce are exempt from the minimum flow and level and flow-sharing regimes and therefore are not subject to restriction in times of low water availability. This provides for the practical sharing of water in times of restriction by prioritising important water uses requiring small amounts of water, while for reasons of fariness, limiting the amount of water to the minimum essential for that activity. With respect to Lakes Tekapo, Pūkaki and Ōhau, town and community water supplies, stock drinking-water, tourism and recreation facilities, maintaining fire-fighting capacity and the processing and storage of perishable produce are exempt from the minimum lake levels. This provides for the practical sharing of water by recognising the negligible effect of takes for these activities on lake levels, and for reasons of fairness, the high degree of management of lake levels for hydro-electricity generation. The reliability of supply provided for in the Lower Waitaki River (downstream of Waitaki Dam) reflects that flows downstream of Waitaki Dam depend on the flows released by the consent-holder for Waitaki Dam, particularly in times of low flows. Existing consented water takes maintain their current reliability. New resource consents are to be provided a high level of reliability up to the allocation limit. The restrictions will be applied through the assessment of resource consent applications. Priority bands for run-of-river reliability are identified in the policies for the tributary water bodies. The specific conditions applying at time of low flow will be applied on a consent by consent basis. The approach of using water-user groups allows restriction methods to be amended to suit the particular circumstances (within overall limits) if agreement can be reached, enhancing the practicality of the regime. The restriction regime may only be applied to existing resource consents by the consent authority in accordance with section 68(7) of the RMA - such a review is at the discretion of the consent authority. Consequently, existing and new resource consents may be subject to different restriction regimes.	Moderate
Overall Effectiveness	Moderate

Objective

Provisions

Effectiveness

Allocating water to essential domestic uses, essential animal drinking needs, maintaining fire-fighting capacity and the processing and storage of perishable produce in times of restriction due to low flows and levels (excluding Lakes Tekapo, Pūkaki and Ōhau) and the flow-sharing requirements recognises the significant local benefits created by these activities which are derived from small volumes of water.

Allocating water from Lakes Tekapo, Pūkaki and Ōhau for town and community water supplies, stock drinking-water, tourism and recreation facilities, maintaining fire-fighting capacity and the processing and storage of perishable produce in times of low lake levels recognises the significant local benefits created by these activities and negligible effect of these water takes on lake levels.

Giving priority to integrated schemes in which water is used for more than one purpose reflects the national and local benefits of the multiple use of water. Implementation of this priority will occur through the assessment of resource-consent applications.

Moderate/High

Essential domestic needs, essential animal drinking needs, maintaining fire-fighting capacity and the processing and storage of perishable produce are exempt from the minimum flow and level and flow-sharing regimes and therefore are not subject to restriction in times of low water availability. This provides for the practical sharing of water in times of restriction by prioritising important water uses requiring small amounts of water, while for reasons of fariness, limiting the amount of water to the minimum essential for that activity.

With respect to Lakes Tekapo, Pūkaki and Ōhau, town and community water supplies, stock drinking-water, tourism and recreation facilities, maintaining fire-fighting capacity and the processing and storage of perishable produce are exempt from the minimum lake levels. This provides for the practical sharing of water by recognising the negligible effect of takes for these activities on lake levels, and for reasons of fairness, the high degree of management of lake levels for hydro-electricity generation.

The reliability of supply provided for in the Lower Waitaki River (downstream of Waitaki Dam) reflects that flows downstream of Waitaki Dam depend on the flows released by the consent-holder for Waitaki Dam, particularly in times of low flows. Existing consented water takes maintain their current reliability. New resource consents are to be provided a high level of reliability up to the allocation limit.

The restrictions will be applied through the assessment of resource consent applications. Priority bands for run-of-river reliability are identified in the policies for the tributary water bodies. The specific conditions applying at time of low flow will be applied on a consent by consent basis.

The approach of using water-user groups allows restriction methods to be amended to suit the particular circumstances (within overall limits) if agreement can be reached, enhancing the practicality of the regime.

The restriction regime may only be applied to existing resource consents by the consent authority in accordance with section 68(7) of the RMA - such a review is at the discretion of the consent authority. Consequently, existing and new resource consents may be subject to different restriction regimes.

Moderate

Overall Effectiveness

Moderate

6.4 Benefits and costs

The Board's evaluation on the benefits and costs of the provisions in the Plan relating to the restriction of water takes at times of low water flows and levels is summarised in Table 38 below.

Table 38: Benefits and costs of the provisions in the Plan relating to the restriction of water takes at times of low water flows and levels

Benefits	Costs
Environmental The extent of the effect on the wider environment is unknown as it is dependent on the use of the water, and the specific circumstances of the use.	Environmental The extent of the effect on the wider environment is unknown as it is dependent on the use of the water, and the specific circumstances of the use. Potential site specific adverse effects of taking water for essential domestic uses, essential animal drinking needs, maintaining fire-fighting capacity and for the processing and storage of perishable produce in times of restriction.
Economic Run-of-river reliability of existing resource consents is not affected beyond that specified in those consents, unless these are reviewed by the consent authority. Reliability of existing resource consents to take water downstream of Waitaki Dam is not affected. Up to the allocation limit specified in the Plan, a high level of reliability is provided for new consents to take and use water downstream of Waitaki Dam. The restriction regime is certain. Provides flexibility as water sharing can be adapted through water-user groups. By seeking that priority is given to integrated schemes, opportunities for more users to derive increased economic benefits exist. Enhanced opportunity to derive economic benefit from hydro-electricity generation in times of low hydro storage. Provides opportunity to derive economic benefit from the water in Lakes Tekapo, Pūkaki and Ōhau from takes for town and community water supplies, and tourism and recreation facilities. Provides opportunity to derive economic benefit from the processing of perishable agricultural and horticultural produce that otherwise would be spoilt, significantly reduced in value, or require transportation to alternative processing facilities. Provides opportunity to derive economic benefit from essential animal drinking needs and maintaining fire-fighting capacity.	Economic Water may not be available to the most economically efficient use. Additional expenditure may be required by individuals/organisations taking water to comply with the restriction regime. Compliance costs will be incurred by the Canterbury Regional Council and resource consent-holders. Opportunity cost attached to consent-holders due to exceptions being provided for essential domestic uses, essential animal drinking needs, and fire-fighting.
Social Retains and enhances secondary social wellbeing effects derived from consented water takes downstream of Waitaki Dam. The approach is fair for all with consents within the priority bands (except essential domestic uses, essential animal drinking needs, maintaining fire-fighting capacity and the processing of perishable produce). Provides for secondary social wellbeing effects from takes for town and community water supplies, tourism and recreation facilities (Lakes Tekapo, Pūkaki and Ōhau). Provides for social wellbeing effects from essential domestic uses, essential animal drinking needs, maintaining fire-fighting capacity at times of low water availability. Provides for secondary social wellbeing effects from the processing of perishable produce.	Social Reduced social wellbeing effects through the sharing of water restrictions if water is not efficiently used.

Benefits

Costs

Environmental

The extent of the effect on the wider environment is unknown as it is dependent on the use of the water, and the specific circumstances of the use.

Environmental

The extent of the effect on the wider environment is unknown as it is dependent on the use of the water, and the specific circumstances of the use.

Potential site specific adverse effects of taking water for essential domestic uses, essential animal drinking needs, maintaining fire-fighting capacity and for the processing and storage of perishable produce in times of restriction.

Economic

Run-of-river reliability of existing resource consents is not affected beyond that specified in those consents, unless these are reviewed by the consent authority.

Reliability of existing resource consents to take water downstream of Waitaki Dam is not affected.

Up to the allocation limit specified in the Plan, a high level of reliability is provided for new consents to take and use water downstream of Waitaki Dam.

The restriction regime is certain.

Provides flexibility as water sharing can be adapted through water-user groups.

By seeking that priority is given to integrated schemes, opportunities for more users to derive increased economic benefits exist.

Enhanced opportunity to derive economic benefit from hydro-electricity generation in times of low hydro storage.

Provides opportunity to derive economic benefit from the water in Lakes Tekapo, Pūkaki and Ōhau from takes for town and community water supplies, and tourism and recreation facilities.

Provides opportunity to derive economic benefit from the processing of perishable agricultural and horticultural produce that otherwise would be spoilt, significantly reduced in value, or require transportation to alternative processing facilities.

Provides opportunity to derive economic benefit from essential animal drinking needs and maintaining fire-fighting capacity.

Economic

Water may not be available to the most economically efficient use.

Additional expenditure may be required by individuals/organisations taking water to comply with the restriction regime.

Compliance costs will be incurred by the Canterbury Regional Council and resource consent-holders.

Opportunity cost attached to consent-holders due to exceptions being provided for essential domestic uses, essential animal drinking needs, and fire-fighting.

Social

Retains and enhances secondary social wellbeing effects derived from consented water takes downstream of Waitaki Dam.

The approach is fair for all with consents within the priority bands (except essential domestic uses, essential animal drinking needs, maintaining fire-fighting capacity and the processing of perishable produce).

Provides for secondary social wellbeing effects from takes for town and community water supplies, tourism and recreation facilities (Lakes Tekapo, Pūkaki and Ōhau).

Provides for social wellbeing effects from essential domestic uses, essential animal drinking needs, maintaining fire-fighting capacity at times of low water availability.

Provides for secondary social wellbeing effects from the processing of perishable produce.

Social

Reduced social wellbeing effects through the sharing of water restrictions if water is not efficiently used.

6.5 Efficiency

Following the consideration of the benefits and costs of the provisions in the Plan relating to the restriction of water takes at times of low water flows and levels, it is the Board's judgement that the provisions are of moderate efficiency.

6.6 Appropriateness

The Board's evaluation of the effectiveness and efficiency of the provisions in the Plan relating to the restriction of water takes at times of low water flows and levels is summarised in Table 39 below.

Table 39: Summary of the effectiveness and efficiency of the provisions in the Plan relating to the restriction of water takes at times of low water flows and levels

Provisions	Effectiveness	Efficiency
Restriction of water takes	Moderate	Moderate

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 the restriction of water takes at times of low water flows and levels are the most appropriate to achieve the objectives of the Plan.

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