ORC Omnibus Plan Change - Plan Change 8 - Submission Reference no: 38 - EPA NZ
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ORC Omnibus Plan Change - Plan Change 8 Submission Reference no: 38 Ravensdown Limited (Ravensdown) (Anna Wilkes) Planz Consultants Limited (Planz) PO Box 1845 CHRISTCHURCH 8140 New Zealand Ph: 021 229 0439 anna.wilkes@ravensdown.co.nz Submitter Type: Not specified Source: Email Overall Notes: Clause Are you a trade competitor? Position I am a person who would not gain an advantage in trade competition through this submission Notes Clause What are you submitting on? You can submit on specific parts of Plan Change 8 or the whole plan change. Notes see submission Clause What is your view on the Plan Change 8 or the specific parts listed above? Please select one, if you have multiple views state clearly in the notes box below. Notes see submission Clause What decision would you like the Environment Court to make? Notes see submission Clause Do you wish to be heard in support of your submission? All submissions will be considered by the Environment Court. Please indicate if you wish to be heard in support of your submission. Position I wish to be heard in support of my submission Notes Clause Please indicate your choice(s) below. If you do not indicate your intention to call experts, you can change your mind later and decide to call experts to give evidence in relation to your submission, provided you do so in time to meet any procedural direction the Environment Court might make. Position If others make a similar submission I/we would consider presenting a joint case with them at a hearing Notes Clause Authority to act: Position I confirm I have the authority to sign this submission on behalf of the submitter Notes
From: Carmen Taylor
Sent: Monday, 17 August 2020 10:11 am
To: policy@orc.govt.nz; ORCplanchanges
Cc: Anna Wilkes
Subject: Submission (Ravensdown Limited) - ORC Plan Change (Omnibus)
Attachments: Ravensdown_Submission on Otago RC PC8 Discharge Management to RPW_FINAL
170820.pdf
Hi
Please find attached Ravensdown Limited’s submission on Proposed Plan Change 8 (Discharge Management) to the
Regional Plan: Water for Otago.
Regards, Carmen
Carmen Taylor - Associate
DDI: 03 929 1414 M: 021 312 781 E: carmen@planzconsultants.co.nz W: planzconsultants.co.nz
A: 8 Stafford Street, Dunedin 9016
Notice: The information in this email is confidential and is intended only for the use of the addressee named above. If you are not the intended recipient, you are hereby
copying or use of this information is strictly prohibited. If you have received this email in error, please reply to the author by return email, and delete the original message
Please consider the environment before printing this email.
1SUBMISSIONS ON
PROPOSED PLAN CHANGE 8 (DISCHARGE MANAGEMENT)
TO THE REGIONAL PLAN: WATER FOR OTAGO
TO: Environmental Protection Agency (EPA)
Private Bag 63002
Waterloo Quay
WELLINGTON 6140
Via email: ORCplanchanges@epa.govt.nz
AND
Otago Regional Council (Council)
Private Bag 1954
DUNEDIN 9054
Via email: policy@orc.govt.nz
SUBMITTER: Ravensdown Limited (Ravensdown)
292 Main South Road
PO Box 1059
CHRISTCHURCH 8140
Contact: Anna Wilkes
Environmental and Policy Manager
Mobile: 021 229 0439
Email: anna.wilkes@ravensdown.co.nz
ADDRESS FOR SERVICE: Planz Consultants Limited (Planz)
PO Box 1845
CHRISTCHURCH 8140
Contact: Carmen Taylor
Consultant Planner (Associate)
Mobile: 021 312 781
Email: carmen@planzconsultants.co.nz1. INTRODUCTION
Ravensdown Limited – Overview and Interests in the Otago Region
1.1 Ravensdown Limited (Ravensdown) is a farmer owned co-operative. Ravensdown’s goal is to
enable smarter farming for a better New Zealand. Given this goal, Ravensdown provides
products, namely fertiliser and agrochemicals (agrichemicals), expertise and technology to help
farmers reduce environmental impacts and to optimise value, or outputs, from their land.
1.2 Ravensdown, in deciding whether to participate in regional planning processes, considers
whether the plan, or proposed plan change, will achieve the purpose of the Resource
Management Act 1991 (RMA) while also evaluating whether the planning provisions will unduly
constrain its own activities (i.e., manufacturing, store sites and quarries) and/or the users of
their products (i.e., its farming shareholders).
1.3 In this context, the nature of Ravensdown’s interests in the Otago region includes the Dunedin
(Ravensbourne) manufacturing works, which is one of Ravensdown’s three manufacturing sites,
as well as four bulk stores located throughout the region in Oamaru, Milton, Balclutha and
Cromwell. In addition, through Ravensdown Environmental, Ravensdown assists its
shareholders and others to meet regional planning requirements through the provision of farm
environment services, which include nutrient loss and mitigation modelling (including Overseer
Nutrient Budgeting), Farm Environment Plan (FEP) development and associated resource
consent planning services.
1.4 Given the nature of Ravensdown’s activities in the region, Ravensdown seeks to ensure that the
Proposed Plan Change 8 (PC8) (Discharge Management) to the Regional Plan: Water for Otago
(Water Plan) will promote the sustainable management of natural and physical resources, in
this instance, the region’s land and water resources. This includes the ability to continue to use
and develop resources, including the rural land resource, while ensuring that the adverse effects
of activities are avoided, remedied or mitigated.
1.5 Given the above context, the provisions of PC8 are of interest to Ravensdown given its activities
in the region and the nature of farming activities undertaken by its farming shareholders in the
region, as outlined in paragraph 1.3 above. Therefore, in preparing this submission,
Ravensdown has focussed on the implications that the proposed amendments will have for its
bulk stores1 within the region, as well to the provisions which apply to the farming activities
undertaken by its farming shareholders in the region.
Overview of Submission
1.6 Ravensdown’s submission, given its key interests in the Otago region, understands that the
purpose of PC8 is to strengthen the management of particular activities to, at a minimum,
maintain water quality in Otago. This is achieved by strengthening the policy direction for
decision-makers in relation to a range of discharges, including stormwater and farming
activities, and by managing particular activities, via new/amended policies and rules, that are
1 While Ravensdown’s Dunedin (Ravensbourne) manufacturing works is located in the Otago region, the discharges from
the site (i.e., stormwater and treated wastewater) are to the Otago Harbour (coastal marine area) and these discharges are
regulated by the Regional Plan: Coastal for Otago. Therefore, the provisions of the Water Plan are not relevant to the
Ravensbourne site’s operations.
Submission on Proposed Plan Change 8 (Discharge Management) to the
Regional Plan: Water for Otago
Ravensdown Limited (17 August 2020) 2known to have adverse effects on water quality (i.e., including, of relevance to Ravensdown,
animal waste storage and discharge, intensive grazing, stock access to water).
1.7 Ravensdown supports the intent and aim of PC8, including the requirement for farming
activities to implement Good Management Practices (GMP), and the additional/new regulation
for some farming activities. In supporting PC8, Ravensdown also acknowledges that PC8 is an
‘interim’ plan change intended to address some specific issues in the region. In this context,
Ravensdown also acknowledges that Council will be notifying a new regional plan to manage
the region’s land and water resources in the near future.
1.8 While generally supporting PC8, through these submissions, Ravensdown seeks amendments
that enable Ravensdown, its bulk stores, its shareholders and the users of its products to
continue to use and develop resources in the region in a manner that continues to provide for
the sustainable management of natural and physical resources, including the region’s land and
water resource, while also ensuring that adverse effects on the environment are avoided,
remedied or mitigated.
1.9 While recognising the interim nature of PC8, Ravensdown’s considers that it is important that
PC8 endeavours to align with the relevant provisions of the recently gazetted national
instruments for healthy waterways, namely the National Policy Statement for Freshwater
Management 2020, the National Environmental Standards for Freshwater and the associated
regulations (e.g., the Resource Management (Stock Exclusion) Regulations 2020). Ravensdown
is working hard with its shareholders to get buy-in into the obligations arising from the various
national and regional statutory planning documents that are now coming into effect. For this
to be successful, it is important that national consistency with these requirements is achieved
where possible. While it is recognised that PC8 was developed prior to the these national
instruments coming into force, and while also recognising that these instruments do provide
time for some of the provisions to be incorporated into relevant regional planning provisions,
Ravensdown considers that where possible, and necessary, PC8 provisions should be amended
to align with these national planning instruments. Given this goal, many of the amendments
being sought by Ravensdown’s submission, as outlined in the table contained in Attachment A,
are being requested in order to achieve the desired consistency.
1.10 Ravensdown’s submissions on PC8 is structured as follows:
(a) Specific submission points on the provisions of PC8 to the Water Plan are contained in
the table provided in Attachment A;
(b) A conclusion, including the overarching reasons for the submission, is provided in Section
2.
2. CONCLUSION
2.1 Ravensdown generally supports PC8, subject to the amendments requested to address the
concerns raised within its submission. In relation to the provisions that Ravensdown has raised
Submission on Proposed Plan Change 8 (Discharge Management) to the
Regional Plan: Water for Otago
Ravensdown Limited (17 August 2020) 3concerns about, those provisions require amendment because, without amendment, those
provisions:
(a) will not promote sustainable management of resources and will not achieve the purpose
of the RMA;
(b) is contrary to Part 2 and other provisions of the RMA;
(c) will not enable the social and economic well-being of the community of the Otago region;
(d) will not meet the reasonably foreseeable needs of future generations;
(e) will not achieve integrated management of the effects of the use, development or
protection of the region’s land and water resources;
(f) will not enable the efficient use and development of Ravensdown’s assets and
operations, and of those resources which are dependent on, or benefit from,
Ravensdown’s assets and operations; and
(g) do not represent the most appropriate means of exercising Council’s functions, having
regard to the efficiency and effectiveness of the provisions relative to other means.
2.2 Ravensdown could not gain an advantage in trade competition through this submission.
2.3 Ravensdown wishes to be heard in support of its submissions.
2.4 If others are making a similar submission, Ravensdown will consider presenting a joint case with
them at the hearing.
Date: 17 August 2020
…………………………………..
Carmen Taylor
Consultant Planner (Associate)
Authorised to sign this submission on behalf of Ravensdown Limited
Submission on Proposed Plan Change 8 (Discharge Management) to the
Regional Plan: Water for Otago
Ravensdown Limited (17 August 2020) 4ATTACHMENT A – RAVENSDOWN LIMITED’S SUBMISSIONS ON PROPOSED PLAN CHANGE 8 (DISCHARGE MANAGEMENT) TO THE REGIONAL PLAN:
WATER FOR OTAGO
SUB. SUPPORT /
PC8 PROVISION PAGE COMMENTS RELIEF SOUGHT
REF. OPPOSE
PART A: DISCHARGE POLICIES
7.C - Policies for discharges of human sewage, hazardous substances, hazardous wastes, specified contaminants, and stormwater; and discharges from industrial or
trade premises and consented dams
1 Amended Policy 4 Support Section 7.C of the Regional Plan: Water for Otago Retain the amendments to Policy 7.C.5 as notified.
7.C.5 (Water Plan) contains policies related to discharges of
human sewage, hazardous substances and wastes,
specified contaminants, stormwater and discharges
from industrial or trade premises and consented
dams. PC8 proposes changes to these policies,
including Policy 7.C.5, on the basis that they do not
provide adequate direction to decision-makers when
making decisions on resource consent applications
for such discharges.
Ravensdown considers that the proposed
amendments to Policy 7.C.5 more clearly articulate
that the purpose of the requirements contained in
parts (a) to (c) of the policy is to minimise the adverse
effects associated with such discharges.
2 Amended Policy 5 Support As outlined above in relation to the proposed Retain the amendments to Policy 7.C.6 as notified.
7.C.6 and amendments to Policy 7.C.5, PC8 proposes changes to
Explanation Policy 7.C.6 to provide clear direction for decision-
makers making decisions on resource consent
applications for discharges from existing stormwater
reticulation systems.
In the context of this policy and given Ravensdown’s
area of interest, namely stormwater discharges from
its bulk stores in the region, Ravensdown supports
the proposed policy amendments. The amendments
Attachment A - Submissions on Proposed Plan Change 8 (Discharge Management) to the
Regional Plan: Water for Otago
Ravensdown Limited (17 August 2020) A1SUB. SUPPORT /
PC8 PROVISION PAGE COMMENTS RELIEF SOUGHT
REF. OPPOSE
clearly identify that the aim of the policy is to ensure
that the adverse effects on the environment from
existing reticulated stormwater systems are to be
reduced, and that measures are to be in place at
industrial or trade waste sites to ensure that the
contamination of stormwater is prevented. It is
considered that these approaches reflect best
practice.
7.D - Policies for discharges of water and contaminants, excluding those discharges provided for in 7.C
3 Amended Policy 6 and Support Section 7.D of the Water Plan contains policies Retain the amendments to Policy 7.D.5 as notified.
7.D.5 7 related to discharges of water and contaminants that
are not provided for by Section 7.C of the Water Plan.
These policies therefore apply to a range of activities,
including discharges from farming activities. PC8
proposes changes to these policies, including Policy
7.D.5, on the basis that they do not provide adequate
direction to decision-makers when making decisions
on resource consent applications for such discharges
(i.e., including Rule 12.C.3.2 which applies to
discharges not provided for by other rules in Section
12.C of the Water Plan).
Ravensdown considers that the proposed
amendments to this policy, while not changing the
requirements of the policy, do provide clarity on the
requirements for decision-makers. On this basis, the
proposed amendments are supported.
4 New Policy 7.D.6 7 Oppose in This policy is intended to provide clear direction for Amend Policy 7.D.6 as follows, with amendments
part decision-makers on the appropriate consent duration shown in shaded and double underlined or strike
for discharges from farming activities. The section 32 through text:
Report for PC8 identifies that restricting the duration When considering applications for resource
of farming activity resource consents for the consent for discharges of nitrogen under Rule
Attachment A - Submissions on Proposed Plan Change 8 (Discharge Management) to the
Regional Plan: Water for Otago
Ravensdown Limited (17 August 2020) A2SUB. SUPPORT /
PC8 PROVISION PAGE COMMENTS RELIEF SOUGHT
REF. OPPOSE
discharge of nitrogen to 10 years will assist Council in 12.C.3.2:
managing the transition to a new regional plan that is (a) Restrict the duration of resource consents to a
to be developed to give effect to the National Policy term of no more than 10 years, or include a
Statement for Freshwater Management 2020. review condition to reflect the same
Ravensdown recognises that providing for a co- timeframe; and
ordinated review of such resource use activities, as (b) Have particular regard to:
effectively proposed by this policy, can be (i) The water quality of the receiving water
advantageous, particularly for Council. However, body; and
from a resource user’s perspective, limiting consent
(ii) Any adverse effects on the natural or
durations, can be problematic. The time and costs
human use values of the receiving water
associated with gaining a resource consent can be
body as set out in Schedule 1; and
significant and being required to repeat such a
process within 10 years, particularly when the effects (iii) Any adverse effects on Kāi Tahu cultural
of an activity are minor or minimal, is unfair. Also, if and spiritual beliefs, values and uses; and
nitrogen loss mitigation measures that require (iv) The expected reduction in nitrogen
significant investment are proposed as part of a discharged over the term of the resource
resource consent application, for the applicant to be consent, particularly from changes to land
able to proceed with that investment they will require management practices or infrastructure;
the certainty and security around the ability to and
continue to farm. (iv) The administrative benefits of aligning the
For the above reasons, Ravensdown considers that expiry date with other resource consents
flexibility should be provided whereby a review for the same activity in the surrounding
condition that aligns with the requirement to area or catchment.
implement the requirements of a new regional plan is
also an option.
PART B: ANIMAL WASTE STORAGE AND APPLICATION
7.D - Policies for discharges of water and contaminants, excluding those discharges provided for in 7.C
5 New Policy 7.D.7 12 Support PC8 introduces policies, and associated rules and Retain Policy 7.D.7 as notified.
and schedules, to manage the storage component of
13 animal waste systems (i.e., the storage of faeces and
urine from animals) and associated application to
Attachment A - Submissions on Proposed Plan Change 8 (Discharge Management) to the
Regional Plan: Water for Otago
Ravensdown Limited (17 August 2020) A3SUB. SUPPORT /
PC8 PROVISION PAGE COMMENTS RELIEF SOUGHT
REF. OPPOSE
land. The section 32 Report outlines that while the
operative Water Plan contains permitted and
prohibited rules for the discharge of such wastes, the
Part B provisions of PC8 will improve the minimum
standards that apply to such activities and will also
bring the region into line with good practice that is
applied throughout New Zealand.
Ravensdown considers that this policy, as part of the
broader animal waste provisions of PC8, reflects
current national Good Management Practice (GMP)
approaches as applicable to this component of
farming activities.
6 New Policy 7.D.8 13 Support As outlined above in relation to Policy 7.D.7 (Sub. Ref. Retain Policy 7.D.8 as notified.
5), PC8 introduces a range of provisions to manage
the storage component of animal waste systems and
associated application to land. The section 32 Report
outlines that the Part B provisions of PC8 aim to
improve the minimum standards that apply to such
activities.
This policy is a component of these provisions, with
the aim of the policy being to identify that existing
animal waste storage systems, that do not meet the
minimum standards are now required to have in place
a plan, which can be staged, for achieving the
minimum standards (as outlined in proposed new
permitted activity Rule 14.7.1.1).
Ravensdown considers that the requirement for
existing animal waste systems to improve
performance to meet the new minimum standards is
an appropriate resource management response. It
reflects improved practices and ensures alignment
with nationally appropriate management
Attachment A - Submissions on Proposed Plan Change 8 (Discharge Management) to the
Regional Plan: Water for Otago
Ravensdown Limited (17 August 2020) A4SUB. SUPPORT /
PC8 PROVISION PAGE COMMENTS RELIEF SOUGHT
REF. OPPOSE
approaches, including the implementation of GMP,
for such systems. Ravensdown also considers that it
is appropriate to provide the farmers with time to
make the necessary improvements.
12.C – Other discharges / 12.C.0 - Prohibited activities: No resource consent will be granted
7 New Rule 12.C.0.4 17 Support in As outlined above, Part D of PC8 introduces a range Amend Rule 12.C.0.4 as follows, with amendments
part of provisions to manage the storage component of shown in shaded and double underlined or strike
animal waste systems and associated application to through text:
land. The discharge of animal waste from an animal
This rule, as a component of these provisions, waste system:
prohibits the discharges from animal waste systems if (i) To any lake, river or Regionally Significant
the discharge is: to or near the identified waterbodies Wetland; or
(Conditions (i) to (v)); if it causes ponding, is to frozen (ii) To any drain or water race that goes to a lake,
land or results in overland flow to water (Condition river, Regionally Significant Wetland or
(vi)); or, gives rise to the effects listed in Condition coastal marine area; or
(vii).
(iii) To the bed of any lake, river or Regionally
While Ravensdown generally considers, with the Significant Wetland; or
exception of Condition (v), that the conditions
(iv) To any bore or soak hole; or
attached to this rule reflect best practice in terms of
circumstances where such discharges should not (v) To land within 50 metres of:
occur, and for this reason, this prohibited activity rule (a) Any lake, river or Regionally Significant
is generally supported. Wetland; or
Ravensdown’s concern with Condition (v) is the 50m (b) Any bore or soak hole; or
setback specified, particularly in the context of a (vi) To land in a manner that results in ponding or
prohibited activity rule, may mean that significant overland flow to water, including to frozen
areas of a farm may not be able to be used for the land; or
application of animal waste from an animal waste (vii) That results in any of the following effects in
system. While it is acknowledged that this condition receiving waters, after reasonable mixing:
reflects a similar condition (Condition (vi)) attached to (a) the production of conspicuous oil or grease
operative Rule 12.C.0.2, it is considered that the films, scums or foams, or floatable or
transfer to this condition into the new rule is not suspended materials; or
Attachment A - Submissions on Proposed Plan Change 8 (Discharge Management) to the
Regional Plan: Water for Otago
Ravensdown Limited (17 August 2020) A5SUB. SUPPORT /
PC8 PROVISION PAGE COMMENTS RELIEF SOUGHT
REF. OPPOSE
appropriate as Rule 12.C.0.2 relates to silage storage, (b) any conspicuous change in the colour or
composting process and the storage and treatment visual clarity; or
system associated with animal waste systems (i.e., (c) any emission of objectionable odour; or
not the discharge from such systems which are not (d) the rendering of fresh water unsuitable for
provided for by this proposed new rule). To provide consumption by farm animals; or
comparison:
(e) any significant adverse effects on aquatic
- the National Environment Standards for life;
Freshwater 2020 (NES-F) specifies a 5m setback
is a prohibited activity.
for livestock from waterbodies, including
wetlands, for permitted intensive winter grazing
(Regulation 26);
- the NES-F also specifies a 10m setback from
natural wetlands for vegetation clearance,
earthworks or land disturbance associated with
permitted arable and horticultural land use
(Regulation 50);
- The Resource Management (Stock Exclusion)
Regulations 2020 (Stock Exclusion Regs) specify a
3m setback for excluding stock from lakes and
rivers (Regulation 8); and
- In Canterbury, the discharge of animal effluent is
permitted provided it is not within 20m of a
surface water body or bore (Rule 5.35 of the
Canterbury Land and Water Regional Plan
(LWRP)).
In this context, it is considered that appropriate
setbacks for discharge activities should be identified
at the time a resource consent is sought, in the
context of the quality of the discharge, the nature of
the property where the discharge is occurring, and
the nature of sensitive activities on the property and
neighbouring the property. For this reason,
Attachment A - Submissions on Proposed Plan Change 8 (Discharge Management) to the
Regional Plan: Water for Otago
Ravensdown Limited (17 August 2020) A6SUB. SUPPORT /
PC8 PROVISION PAGE COMMENTS RELIEF SOUGHT
REF. OPPOSE
Ravensdown considers that Condition (v) should be
deleted.
12.C – Other discharges / 12.C.1 - Permitted activities: No resource consent required
8 New Rule 12.C.1.4 17 Support in This rule, as a component of the provisions contained Amend Rule 12.C.1.4 as follows, with amendments
part in Part D of PC8, permits the discharge of animal shown in shaded and double underlined or strike
waste to land subject to conditions. The conditions through text:
include: that the discharge is from an animal waste Notwithstanding any other rule in this Plan, the
system permitted by Rule 14.7.1.2 (i.e., that meets discharge of animal waste, or water containing
the minimum standards for such systems included in animal waste, from an animal waste system onto
the conditions of Rule 14.7.1.2 – refer to Sub. Ref. 11 or into land is a permitted activity providing:
below); the discharge is not prohibited by Rule (a) The animal waste system is permitted under
12.C.0.4 (refer to Sub. Ref. 7 above); and, the Rules 14.7.1.1 and 14.7.1.2 or a resource
discharge occurs within the property where the waste consent has been granted under Rule 14.7.2.1;
is generated and the discharge is setback from the and
property boundary by at least 50m.
(b) The discharge is not prohibited under Rule
Ravensdown considers that providing for the 12.C.0.4; and
discharges from animal waste systems as a permitted
(c) The discharge does not occur within 50 20
activity is an appropriate resource management
metres of the boundary of the property on
approach particularly given the constraints in place
which the animal waste is generated, or
through the conditions of this rule.
beyond that boundary.
However, it is considered that amendments are
required to this rule.
Firstly, this rule does not appropriately reflect the
land use rule hierarchy for animal waste systems (i.e.,
existing systems are a permitted activity subject to
complying with conditions, while new systems
require a controlled activity resource consent).
Secondly, in relation to Condition (c), as outlined
above in relation to Rule 12.C.0.4 (Sub. Ref. 7), 50m
from the property boundary is a large setback which
does not necessarily align with the potential effects of
Attachment A - Submissions on Proposed Plan Change 8 (Discharge Management) to the
Regional Plan: Water for Otago
Ravensdown Limited (17 August 2020) A7SUB. SUPPORT /
PC8 PROVISION PAGE COMMENTS RELIEF SOUGHT
REF. OPPOSE
the discharge. Based on operative permitted activity
rules that are in place in Canterbury for such
discharges, Ravensdown considers that 20m from the
property boundary is an appropriate setback for such
a permitted activity (refer to Condition 2(b) of the
Rule 5.35 of the LWRP).
12.C – Other discharges / 12.C.2 - Restricted discretionary activities: Resource consent required
9 New Rule 12.C.2.5 18 Support This rule, as a component of the provisions contained Amend Rule 12.C.2.5 as follows, with amendments
in Part D of PC8, provides for the discharge of animal shown in shaded and double underlined or strike
waste to land as a restricted discretionary activity through text:
where the discharge is not permitted by Rule The discharge of animal waste, or water
12.C.1.4, or prohibited by Rule 12.C.0.4. containing animal waste, from an animal waste
Ravensdown considers that restricted discretionary system onto or into land is a restricted
activity status for such discharges is appropriate. discretionary activity provided:
Ravensdown also considers that the matters of (a) The discharge is not prohibited under Rule
discretion also appropriately reflect the potential 12.C.0.2A 12.C.0.4; and
adverse effects that need to be considered when (b) The discharge is not permitted under Rule
assessing such applications. 12.C.1.4;
However, Ravensdown requests an amendment to In considering any resource consent under this
the rule, so that it refers to the correct prohibited rule, the Otago Regional Council will restrict the
activity rule (i.e., Rule 12.C.0.4, not Rule 12.C.0.2A – exercise of its discretion to the following:
there is no Rule 12.C.0.2A in PC8 or the operative
(i) The application depth and rate;
Water Plan).
(ii) Size and location of the disposal area,
including separation distances from lakes,
rivers, Regionally Significant Wetlands, bores,
soak holes, water supply for human
consumption and dwellings;
(iii) Measures to avoid, remedy or mitigate
adverse effects on water quality, taking into
account the nature and sensitivity of the
Attachment A - Submissions on Proposed Plan Change 8 (Discharge Management) to the
Regional Plan: Water for Otago
Ravensdown Limited (17 August 2020) A8SUB. SUPPORT /
PC8 PROVISION PAGE COMMENTS RELIEF SOUGHT
REF. OPPOSE
receiving environment;
(iv) Measures to avoid, remedy or mitigate
adverse effects on Kāi Tahu cultural and
spiritual beliefs, values and uses;
(v) Duration of consent and any review
conditions;
(vi) Quality of, and compliance with, a
management plan for the animal waste
system; and
(vii) Any information and monitoring
requirements.
NEW 14.7 – Animal Waste Systems / 14.7.1 – Permitted activities: No resource consent required
10 New Rule 14.7.1.1 20 Support This rule, as a component of the provisions contained Amend Rule 14.7.1.1 as follows, with amendments
and in Part D of PC8, provides for the use of land by shown in shaded and double underlined or strike
21 existing animal waste systems (i.e., including storage through text:
ponds and ancillary structures) subject to the The use of land for the use and maintenance of an
conditions. The conditions reflect the requirement animal waste system (including storage pond(s)
that there is no leakage from the system, that the and ancillary structures) that was constructed
system is operated in accordance with a management prior to 25 March 2020 is a permitted activity
plan (including a requirement to have contingency providing:
controls in place to prevent uncontrolled discharges (a) The storage pond is sized in accordance with
and to periodically test, by way of the Schedule 18 the Dairy Effluent Storage Calculator; and
drop test, that there is no leakage from the system);
(b) The storage pond is either:
and, if required by Council, written confirmation from
a ‘suitably qualified person’ is to be provided that (i) Fully lined with an impermeable synthetic
Conditions (a) to (c) of this permitted activity rule are liner and has a leak detection system
complied with. underlying the storage pond which is
inspected not less than monthly, there is no
Ravensdown considers that permitted activity status
evidence of any leakage, and a written
for the use of existing animal waste systems, subject
record is kept recording the results of each
to complying with the proposed conditions, is
inspection; or
appropriate as the conditions reflect minimum
Attachment A - Submissions on Proposed Plan Change 8 (Discharge Management) to the
Regional Plan: Water for Otago
Ravensdown Limited (17 August 2020) A9SUB. SUPPORT /
PC8 PROVISION PAGE COMMENTS RELIEF SOUGHT
REF. OPPOSE
standards for such systems. (ii) Of impervious concrete construction; or
While the rule is supported, Ravensdown considers (iii) An above-ground tank; or
that the note attached to this rule does not accurately (iv) Certified by a Suitably Qualified Person
refer to the proposed rules that apply to the within the last five years as:
discharges from such animal waste systems. (1) Structurally sound and without any
visual defects; and
(2) Meeting the relevant pond drop test
criteria in Schedule 18; and
(c) A management plan for the animal waste
system is prepared and implemented that
requires:
(i) Pond drop tests of the storage pond(s)
every three years; and
(ii) Implementation of contingency measures
to prevent the discharge of animal waste
to a surface water body, an artificial
watercourse, or the coastal marine area,
either directly or indirectly, in the event of
power outage or the failure of equipment;
and
(d) Upon written request by the Regional Council
a written statement or certificate from a
Suitably Qualified Person is provided to show
compliance with Conditions (a) to (c).
Note: Rule 14.7.1.1 does not manage discharges
of animal waste to land. Animal waste
systems that comply with Rule 14.7.1.1 will
require resource consent under Rule
12.C.2.5 for the Rules 12.C.0.4, 12.C.1.4
and 12.C.2.5 regulate the discharge of
animal waste to land from animal waste
Attachment A - Submissions on Proposed Plan Change 8 (Discharge Management) to the
Regional Plan: Water for Otago
Ravensdown Limited (17 August 2020) A10SUB. SUPPORT /
PC8 PROVISION PAGE COMMENTS RELIEF SOUGHT
REF. OPPOSE
systems.
11 New Rule 14.7.1.2 21 Support This rule, as a component of the provisions contained Retain Rule 14.7.1.2 as notified.
in Part D of PC8, provides for the use of land by
existing animal waste systems (i.e., including storage
ponds and ancillary structures) where the system
does not comply with Rule 14.7.1.1 (refer to Sub. Ref.
10 above) but where a resource consent does not yet
need to be sought, in accordance with discretionary
activity Rule 14.7.3.1 (refer to Sub. Ref. 13 below)
until between 6 months to 3 years after PC8 becomes
operative. The timeframe that applies to the need to
seek a resource consent is determined based on the
risk of the existing system (refer to Schedule 19 – Sub.
Ref. 14 below).
Ravensdown considers that providing for these
systems as a permitted activity, on an interim basis
and risk-based approach, is an appropriate resource
management approach. The proposed ‘staging’ of
the required resource consents should ensure that
personnel resources, both Councils and the
applicants, are available to undertake the necessary
work.
NEW 14.7 – Animal Waste Systems / 14.7.2 - Controlled activities: Resource consent required
12 New Rule 14.7.2.1 21 Support This rule, as a component of the provisions contained Retain Rule 14.7.2.1 as notified.
and in Part D of PC8, provides for the use of land for the
22 construction, use and maintenance of new animal
waste systems (i.e., including storage ponds and
ancillary structures) subject to conditions. The
conditions reflect the requirement that the system is
designed and certified in accordance with best
engineering practice, that there will be no leakage
Attachment A - Submissions on Proposed Plan Change 8 (Discharge Management) to the
Regional Plan: Water for Otago
Ravensdown Limited (17 August 2020) A11SUB. SUPPORT /
PC8 PROVISION PAGE COMMENTS RELIEF SOUGHT
REF. OPPOSE
from the system, that the system is appropriately
located within a property and that the system is
operated in accordance with a management plan
(including a requirement to have contingency
controls in place to prevent uncontrolled discharges
and to periodically test, by way of the Schedule 18
drop test, that there is no leakage from the system).
Ravensdown considers that controlled activity status
for the establishment of new animal waste systems,
subject to complying with the proposed conditions, is
appropriate as the conditions reflect minimum best
practice standards for such systems. In supporting
controlled activity status, Ravensdown recognises
that it is important that Council: need to have the
ability to determine whether the proposed system
represents best practice; have a record, by way of the
resource consent, of such systems in the region; and,
can monitor compliance with consent conditions.
Ravensdown also considers that the matters of
control also appropriately reflect the potential
adverse effects that need to be considered when
assessing such applications.
NEW 14.7 – Animal Waste Systems / 14.7.3 - Discretionary activities: Resource consent required
13 New Rule 14.7.3.1 22 Support This rule, as a component of the provisions contained Retain Rule 14.7.3.1 as notified.
and in Part D of PC8, provides for the use of land by animal
23 waste systems as a discretionary activity where the
activity is not permitted by Rules 14.7.1.1 or 14.7.1.2,
or provided for by Rule 14.7.2.1.
Ravensdown considers that discretionary activity
status for land use activities, given the rule hierarchy
proposed in PC8 for such activities, is appropriate.
Attachment A - Submissions on Proposed Plan Change 8 (Discharge Management) to the
Regional Plan: Water for Otago
Ravensdown Limited (17 August 2020) A12SUB. SUPPORT /
PC8 PROVISION PAGE COMMENTS RELIEF SOUGHT
REF. OPPOSE
Schedules
14 New Schedule 19 - 26 Support This schedule, as a component of the provisions Retain Schedule 19 as notified.
Schedule of and contained in Part D of PC8, fulfils two purposes.
progressive 27 Firstly, it describes the approach to be used to
implementation of calculate the days of storage available within existing
animal waste animal waste storage systems. Secondly, depending
storage on the days of storage available, and thus the
requirements potential risks to the environment associated with
limited storage, the schedule identifies the dates at
which a resource consent application must be sought
for animal storage systems which are not permitted
by Rule 14.7.1.1. The application dates are six months
after PC8 becomes operative for systems that have 10
days or less of storage available, or two or three years
after PC8 becomes operative (depending on the days
of storage).
As outlined above in relation to Rule 14.7.1.2 (refer to
Sub. Ref. 12 above), Ravensdown considers that
providing for existing animal waste systems that do
not meet minimum standards as a permitted activity,
on an interim basis and risk-based approach, is an
appropriate resource management approach. The
proposed ‘staging’ of the required resource consents
based on relative risk, as reflected by calculated
available days of storage, will ensure that personnel
resources, both Council’s and the applicant’s, are
available to undertake the necessary work.
21 - Glossary
15 Amended definition 29 Support in The operative definition, including the PC8 Amend the definition of ‘animal waste system’ as
– Animal waste part amendment, of ‘animal waste system’ is considered follows, with amendments shown in shaded and
system to generally reflect the nature of such systems. double underlined or strike through text:
Attachment A - Submissions on Proposed Plan Change 8 (Discharge Management) to the
Regional Plan: Water for Otago
Ravensdown Limited (17 August 2020) A13SUB. SUPPORT /
PC8 PROVISION PAGE COMMENTS RELIEF SOUGHT
REF. OPPOSE
However, given PC8’s rule framework whereby the Includes Means the collection, conveyance,
discharges from animal waste systems are regulated storage, or treatment, disposal or application of
separately from the land use aspects of such systems, liquid or solid animal waste.
and given the terminology used in the discharge rules,
Ravensdown considers that the definition should not
include the disposal or application aspects of animal
waste systems.
16 New definition – 29 Support The proposed definition of ‘suitably qualified person’ Amend the definition of ‘suitably qualified person’ as
Suitably Qualified refers to ‘the person’ needing to be appropriately follows, with amendments shown in shaded and
Person qualified, experienced and competent in the relevant double underlined or strike through text:
field of expertise. This reflects the normal A person that is has been assessed and approved
requirements that apply to qualified people or by the Otago Regional Council as being
experts. For this reason, Ravensdown supports the appropriately qualified, experienced and
proposed definition. competent in the relevant field of expertise.
However, Ravensdown considers that it is not
considered necessary for Council to assess and
approve the competency of various experts and for
this reason an amended definition has been
requested.
PART C: GOOD FARMING PRACTICES
7.D - Policies for discharges of water and contaminants, excluding those discharges provided for in 7.C
17 New Policy 7.D.9 33 Support PC8 seeks to introduce new provisions that establish Amend Policy 7.D.9 as follows, with amendments
and minimum standards, and requires implementation of shown in shaded and double underlined or strike
34 GMP, for farming activities. through text:
Ravensdown supports and encourages its Enable farming activities while reducing their
shareholders to adopt and implement GMP, as adverse environmental effects by:
provided for by part (a) of this policy, as a means of (a) Promoting the implementation of good
avoiding or mitigating environmental effects management practices (or better) to reduce
associated with farming activities (i.e., including the sediment and contaminant loss to water
potential loss of sediment and contaminants into bodies; and
waterbodies). Ravensdown also considers that the
Attachment A - Submissions on Proposed Plan Change 8 (Discharge Management) to the
Regional Plan: Water for Otago
Ravensdown Limited (17 August 2020) A14SUB. SUPPORT /
PC8 PROVISION PAGE COMMENTS RELIEF SOUGHT
REF. OPPOSE
activities identified in parts (b) to (e) of this policy (b) Managing stock access to water bodies to:
reflect potential high-risk practices where the (i) Progressively exclude stock from lakes,
application of GMP as well as regulation, as proposed wetlands, and continually flowing rivers;
by PC8, is appropriate. and
However, an amendment to the reference to (ii) Avoid significant adverse effects on water
‘intensive grazing’ is proposed for the reasons quality, bed and bank integrity and
outlined below in relation to the proposed ‘intensive stability, Kai Tahu values, and river and
grazing’ definition (Sub. Ref. 21). riparian ecosystems and habitats; and
(c) Setting minimum standards for intensive
winter grazing; and
(d) Managing the risk of sediment run off from
farming activities by:
(i) Implementing setbacks from water bodies
and establishing riparian margins, and
(ii) Limiting areas and duration of exposed
soil; and
(e) Promoting the identification and
management of critical source areas within
individual properties, to reduce the risk of
nutrient or microbial contamination and
sediment run-off.
21 - Glossary
18 New definition – 37 Support The PC8 definition for ‘critical source area’ is Amend the definition for ‘critical source area’ as
Critical source area supported as it reflects the current understanding of follows, with amendments shown in shaded and
such areas. While supporting the definition, an double underlined or strike through text:
amendment is requested to address a grammatical Means a landscape feature such as a gully, swale,
error within the definition. or depression that accumulates runoff from
adjacent flats and slopes and delivers it to surface
water bodyies such as rivers and lakes, artificial
waterways, and field tiles.
Attachment A - Submissions on Proposed Plan Change 8 (Discharge Management) to the
Regional Plan: Water for Otago
Ravensdown Limited (17 August 2020) A15SUB. SUPPORT /
PC8 PROVISION PAGE COMMENTS RELIEF SOUGHT
REF. OPPOSE
PART D: INTENSIVE GRAZING
NEW 14.6 – Rural Land Uses / 14.6.1 Permitted activities: No resource consent required
19 New Rule 14.6.1.1 41 Support in PC8 seeks to introduce new provisions that establish Amend Rule 14.6.1.1 as follows, with amendments
part minimum standards and GMPs for high-risk practices shown in shaded and double underlined or strike
that may have adverse effects on water quality. through text:
Intensive grazing is one of the identified high-risk The use of land for intensive winter grazing is a
practices in the Otago region. For this reason, PC8 permitted activity providing:
proposes this permitted activity rule for intensive (a) The total cumulative area of the landholding
grazing, and a discretionary activity rule (Rule used for intensive winter grazing is no greater
14.6.2.1 – refer to Sub. Ref. 20 below) where the than the lesser of:
conditions of the permitted activity are not complied
(i) 100 50 hectares; or
with.
(ii) 10% of the total cumulative area of the
As the NES-F also regulates ‘intensive winter grazing’
landholding.
(from 1 May 2021 – Regulation 2(2)(a)), and given
that regional plan rules can be more stringent (but (b) The grazing takes place on land with a mean
not less stringent) (Regulation 6 of the NES-F) slope of 10 degrees or less.
Ravensdown considers that this rule requires (c) There is no intensive winter grazing in any
amendment to ensure that it is consistent with, and critical source area; and
not less stringent than, the conditions of the (dc) Stock are progressively grazed (break-fed or
permitted activity regulation in the NES-F (Regulation block-fed) from the top of a slope to the
26). On this basis, Conditions (b) to (e) of bottom of a slope; and
Regulation26(4) and Regulation 26(7) of the NES-F (ed) A vegetated strip of at least 10 5 metres is
need to be included in Rule 14.6.1.1 (included as maintained between the intensively grazed
Conditions (b), amended (e), (f) and (g) of Rule area and any water body or drainage ditch,
14.6.1.1.). In addition, the permitted area for such and all stock are excluded from this strip
grazing needs to be consistent with the areas during intensive grazing.
permitted under Condition (a) of Regulation 26(4) of (f) the grazed paddock is re-planted as soon as
the NESF (as amended in Condition (a) of this rule). practicable, after the end of the grazing, but
In addition, as outlined in relation to the Rule 14.6.2.1 no later than 1 November in the same year.
and the proposed ‘intensive grazing’ definition (refer (g) pugging at any point must not be deeper than
to Sub. Refs. 20 and 21), Ravensdown considers that 20 cm and must not cover over more than 50%
Attachment A - Submissions on Proposed Plan Change 8 (Discharge Management) to the
Regional Plan: Water for Otago
Ravensdown Limited (17 August 2020) A16SUB. SUPPORT /
PC8 PROVISION PAGE COMMENTS RELIEF SOUGHT
REF. OPPOSE
the term ‘intensive winter grazing’ should be used of the paddock.
throughout these PC8 provisions. This term is
consistent with the NES-F.
NEW 14.6 – Rural Land Uses / 14.6.2 Discretionary activities: Resource consent required
20 New Rule 14.6.2.1 41 Support in The NES-F contains regulation (Regulation 27) that Amend Rule 14.6.2.1 as follows, with amendments
part requires ‘intensive winter grazing’ to seek resource shown in shaded and double underlined or strike
consent for a restricted discretionary activity, from 1 through text:
May 2021, where such activities do not comply with Except as provided by Rule 14.6.1.1, the use of
the permitted activity regulation for intensive winter land for intensive winter grazing is a restricted
grazing (Regulation 26). discretionary activity.
Given the consent hierarchy approach contained in In considering any resource consent under this
the NES-F for intensive winter grazing, Ravensdown rule, the Otago Regional Council will restrict the
considers that restricted discretionary activity status, exercise of its discretion to the following:
rather than discretionary activity status, should apply (i) The extent of intensive winter grazing and the
to intensive winter grazing activities that do not stock being grazed;
comply with the permitted activity rule (new Rule
(ii) Separation distances from lakes, rivers,
14.6.1.1 – refer to Sub. Ref. 19 above).
Regionally Significant Wetlands, bores, soak
In addition, as outlined in relation to the Rule 14.6.1.1 holes, water supply for human consumption
and the proposed ‘intensive grazing’ definition (refer and dwellings;
to Sub. Refs. 19 and 21), Ravensdown considers that
(iii) Measures to avoid, remedy or mitigate
the term ‘intensive winter grazing’ should be used
adverse effects on water quality, taking into
throughout these PC8 provisions. This term is
account the nature and sensitivity of the
consistent with the NES-F.
receiving environment;
(iv) Measures to avoid, remedy or mitigate
adverse effects on Kāi Tahu cultural and
spiritual beliefs, values and uses;
(v) Duration of consent and any review
conditions; and
(vi) Any information and monitoring
requirements.
Attachment A - Submissions on Proposed Plan Change 8 (Discharge Management) to the
Regional Plan: Water for Otago
Ravensdown Limited (17 August 2020) A17SUB. SUPPORT /
PC8 PROVISION PAGE COMMENTS RELIEF SOUGHT
REF. OPPOSE
21 - Glossary
21 New definition – 43 Oppose in The definition of ‘intensive grazing’ needs to be Amend the notified definition for ‘intensive
Intensive grazing part consistent with the definition contained in national grazing’ as follows, with amendments shown in
planning instruments under the RMA that apply to shaded and double underlined or strike through
farming activities. To that end, the definition for text: Means grazing of stock on forage crops
‘intensive winter grazing’ used in the NES-F should be (including brassica, beet and root vegetable
used within PC8. crops), excluding pasture and cereal crops.
Means grazing livestock on an annual forage crop
at any time in the period that begins on 1 May and
ends with the close of 30 September of the same
year.
PART E: STOCK ACCESS TO WATER
13.5 - Alteration of the bed of a lake or river, or of a Regionally Significant Wetland / 13.5.1 - Permitted activities: No resource consent required
22 Amended Rule 47 Support in As acknowledged previously in this submission, PC8 Amend Rule 13.5.1.8A as follows, with amendments
13.5.1.8A and part seeks to introduce new provisions that establish shown in shaded and double underlined or strike
48 minimum standards and GMPs for high-risk practices through text:
that may have adverse effects on water quality. Stock The disturbance of the bed of any lake or river, or
access to water is one of the identified high-risk any Regionally Significant Wetland by livestock,
practices in the Otago region. For this reason, PC8 excluding intentional driving of livestock, and any
proposes an amendment to this permitted activity resulting discharge or deposition of bed material,
rule that requires the exclusion of dairy cattle and is a permitted activity, providing it does not:
pigs, from specific waterbodies, by 2022. Where the (a) It does not
requirements of proposed Condition (b) of this rule
(i) Involve feeding out on that bed or wetland;
are not complied with, operative discretionary
or
activity rules (Rules 13.5.3.1 or 13.5.3.2) of the Water
Plan trigger the need to seek a resource consent. It is (bii) Cause or induce noticeable slumping,
noted that the proposed rule amendments, reflects pugging or erosion; or
the aim of proposed new Policy 7.D.9 (refer to Sub. (ciii) Result in a visual change in colour or
Ref. 17 above) that applies to farming activities. clarity of water; or
It is noted that the Stock Exclusion Regs, salso (div) Damage fauna, or New Zealand native
regulates stock access to lakes, rivers and wetlands, flora, in or on any Regionally Significant
Attachment A - Submissions on Proposed Plan Change 8 (Discharge Management) to the
Regional Plan: Water for Otago
Ravensdown Limited (17 August 2020) A18SUB. SUPPORT /
PC8 PROVISION PAGE COMMENTS RELIEF SOUGHT
REF. OPPOSE
with restrictions applying for some stock, depending Wetland; and
on the slope of the land, from either 1 July 2023 (b) From 1 July 2022:
and/or 1 July 2025. These regulations are mandatory (i) All dairy cattle and pigs are excluded from
requirements and regional plan rules can not be less the beds of lakes, continually flowing rivers
stringent than these regulations. wider than 1 metre and Regionally
The stock access restrictions incorporated into Rule Significant Wetlands; and
13.5.1.8A(b) reflect Regulation 3(1) of the Stock (ii) where stock are excluded under (i), a
Exclusion Regs, which requires all dairy cattle and pigs setback of five at least three metres from
to be excluded from the specified waterbodies, with the beds of lakes, continually flowing rivers
associated setback, by 1 July 2023. Given this national wider than 1 metre and Regionally
direction, Ravensdown supports this rule, including Significant Wetlands is implemented.
the requirement that this restriction applies a year
Note: 1. For the purposes of Rule 13.5.1.8A(b), a
earlier in the Otago region (i.e., 2022).
continually flowing river is considered
However, Ravensdown considers that amendments to be wider than 1 metre if the river is
to this rule are required to ensure that consistent wider than 1 metre at any point within
approaches are applied nationally, and to ensure that the boundary of a landholding at its
undue confusion does not arise in the farming annual fullest flow without
community. In this context, the amended rule, to be overtopping its banks.
consistent with the Stock Exclusion Regs, should
2. For the purposes of Rule
specify that 3m, not 5m, setbacks are required, the
13.5.1.8A(b)(ii), setbacks are measured
setbacks apply from the banks of the river and that
from the edge of the fullest extent of
averaging of the setbacks across a property does not
the wetted bed of a lake or the edge of
apply.
the banks river wider than 1 metre or
In addition, it is considered that the reference to 2022 the defined area of a Regionally
in this rule is not specific enough (i.e., when in 2022 Significant Wetland and are averaged
does the rule apply). Ravensdown considers that the across the landholding.
rule should apply from 1 July 2022, which is one year
before the similar Stock Exclusion Regs coming into
force.
Attachment A - Submissions on Proposed Plan Change 8 (Discharge Management) to the
Regional Plan: Water for Otago
Ravensdown Limited (17 August 2020) A19SUB. SUPPORT /
PC8 PROVISION PAGE COMMENTS RELIEF SOUGHT
REF. OPPOSE
21 - Glossary
23 New definition – 50 Oppose in The definition of ‘dairy cattle’ needs to be consistent Amend the notified definition for ‘dairy cattle’ as
Dairy cattle part with the definition contained in national planning follows, with amendments shown in shaded and
instruments under the RMA that apply to farming double underlined or strike through text:
activities. To that end, the definition for ‘dairy cattle’ Means cattle farmed for milk production and
used in the NES-F should be used within PC8. includes dairy cows, weaned and unweaned
calves of dairy cows, and non-milking dairy cattle
such as youngstock and bulls.
(a) means cattle farmed for producing milk; and
(b) includes—
(i) any bull on the farm whose purpose is
mating with those cattle; and
(ii) unweaned calves of those cattle; but
(c) does not include dairy support cattle.
PART F: SEDIMENT TRAPS
13.5 - Alteration of the bed of a lake or river, or of a Regionally Significant Wetland / 13.5.1 - Permitted activities: No resource consent required
24 New Rule 13.5.1.10 53 Support As already traversed within this submission, PC8 Retain Rule 13.5.1.10 as notified.
and seeks to introduce new provisions that establish
54 minimum standards and GMPs for high-risk practices
that may have adverse effects on water quality. One
of the farming related potential adverse effects on
water quality arises from sediment loss into
waterbodies.
Given this issue, PC8 seeks to incentivise landowners,
by providing this permitted activity rule, with the
ability to install in-stream sediment traps in
ephemeral or intermittently flowing waterbodies as a
means of stopping sediment loss into waterbodies.
Where the conditions of this rule are not complied
with, an operative discretionary activity rule (Rule
Attachment A - Submissions on Proposed Plan Change 8 (Discharge Management) to the
Regional Plan: Water for Otago
Ravensdown Limited (17 August 2020) A20SUB. SUPPORT /
PC8 PROVISION PAGE COMMENTS RELIEF SOUGHT
REF. OPPOSE
13.5.3.1) of the Water Plan would trigger the need to
seek a resource consent for the construction of any
such sediment traps.
Ravensdown supports the inclusion of this permitted
activity rule as it provides landowners, including
farmers, with the ability to implement sediment traps
as one of a potential toolbox of mitigation measures
that reflect GMP without the need to seek a specific
resource consent. Ravensdown also considers that
the conditions attached to this proposed permitted
activity rule place appropriate bounds around the
nature and extent of such activities.
21 - Glossary
25 New definition – 57 Support Given the proposed inclusion of the above permitted Amend the notified definition for ‘sediment trap’ as
sediment trap activity rule (Rule 13.5.1.10 – Sub. Ref. 24), providing follows, with amendments shown in shaded and
a definition for ‘sediment trap’ is considered double underlined or strike through text:
appropriate. Ravensdown considers, subject to a An excavated area in the bed of an ephemeral or
minor grammatical correction, that the definition intermittently flowing river designed and
appropriately describes the nature and purpose of constructed solely for the purpose of slowing
such facilities. water velocity to allow sediments to drop from the
water column.
Attachment A - Submissions on Proposed Plan Change 8 (Discharge Management) to the
Regional Plan: Water for Otago
Ravensdown Limited (17 August 2020) A21You can also read
