Submission to Otago Regional Council Plan Change 7
The Otago Regional Council Plan Change 7 (Water Permits) deals with both the replacement of deemed permits and the replacement of expiring water permits that expire before 31 December 2025. The submission period closed on 4 May 2020. However, because Council notified the plan change, and then asked the government to call it in, there’ll be another whole round of submissions once the Environmental Protection Authority (EPA) renotifies it – all submissions (to either/both ORC and EPA) will have full appeal rights – but hearings will be in the Environment Court.
Federated Farmers has opposed PC7. In our view, it fails on tests of cost-effectiveness, fairness, adequate consultation, and consistency with existing policies. It introduces considerable uncertainty and costs for water users, who now face the choice of inadequate short-term (maximum 6-year) consents, or onerous hurdles and costs to try to get a non-complying activity consent, which even then can only be up to a maximum of 15 years. Water users needing a consent under PC7 need certainty around the ability to service financing and repay debts. What’s proposed hampers that certainty and the reliability of the water accessed, and doesn’t pose any real environmental improvements either.
to read the full submission click opposite