Federated Farmers Feedback for Otago Regional Council Proposed Plan Change 1D - Minimum Flows

Federated Farmers supports Council’s approach to consultation prior to formal notification of the plan in 2018, particularly the clear, iterative and plan user focus of the process. However, we sound a note of caution on community expectations that consent applications with residual flows should seek to provide information on additional values. We underline the need to ensure that cost implications to the applicant should remain a critical consideration for Council, when considering what additional values may be included in residual flow processes.

Feedback

Should there be more flexibility in measuring residual flows under a water permit? Federated Farmers considers there is some merit in providing more flexibility for measuring residual flows, particularly if the emphasis is providing scope for group or collective takes. The Federation considers this flexibility should be ‘user demand driven’.

Are there any other values we should consider when setting a residual flow condition on a water permit? Federated Farmers considers there is some argument to consider reasonable downstream domestic and stock water usage through a residual flow process, and in some instances the contribution a residual flow will make to a minimum flow.If there is to be an inclusion of economic value, a move we consider a fraught and largely unjustified one for the minimum flow process, this should focus solely on the cost implications of the applicant farm losing access to water.However, we consider these additional values should be considered only on an ‘as required’ basis. Any proposed plan change should provide robust and exclusive justification for when and how these additional 

Would more guidance in the Water Plan be useful to determine what a residual flow level should be? Federated Farmers considers more guidance may be useful. Again we consider the primary focus should be on ensuring the information required through the minimum flow process should be absolutely required and objectively justified, and that the focus should be on ensuring the application process is efficient. This may include outlining instances where information is not required.

Do you think the residual flow provisions should be modified to be more flexible, and if so why? We agree the residual flow provisions should be modified to allow for greater flexibility around where residual flows are measured, and that greater provision should be made for group or collective takes. Again, we consider it is important that this flexibility is ‘user demand driven’.

For more, see the full feedback document