SUPPLEMENTARY SUBMISSION

Transcription

1 SUPPLEMENTARY SUBMISSION Name: Hawke s Bay Winegrowers Association Incorporated This is a submission on the Proposed Change 6, Tukituki River Catchment dated 24 April 2013, supplementary to a joint submission submitted in conjunction with us by Horticulture New Zealand. 1. Who we are: Hawke s Bay Winegrowers Association Inc. (HBWG) HBWG is the industry representative body for grapegrowers and winemakers in Hawke s Bay. All growers and wineries receive automatic membership through payment of industry levies. HBWG is affiliated to and receives most of its funding from New Zealand Winegrowers and has a local membership comprising 157 grapegrowers, 92 winemakers and a number of associate members. The wine sector is one of the largest intensive land-users in Hawke s Bay, comprising around 5000ha in production, predominantly on the Heretaunga Plains and mostly clustered around existing & ancient riverbeds, including the Tukituki. Annual grape production in Hawke s Bay is around 35,000T, the second-largest region after Marlborough. NZIER estimated that in 1998 our GDP contribution was $106.2m and we provided employment for 1596 FTE. HBWG carries out a range of services for its members including education, research, wine promotion, media hosting and advocacy and was formed in 2007 from the merger of the members of 2 longstanding local associations - Hawke s Bay Grapegrowers Association Inc. and Hawke s Bay Winemakers Inc.

2 Page 2 2. The specific areas on which we wish to comment are as follows: - TT1 Fresh Water Objectives - POL TT4 Implementing the Nitrate-Nitrogen Limits - POL TT7 Minimum Flow Limits - POL TT9 Implementing Minimum Flow and Allocation Limits - POL TT11 Managing Groundwater Takes Hydraulically Connected to Surface Water - POL TT14 Consent Categorisation and Durations - POL TT15 Water Measuring and Reporting Requirements 3. TT1 Fresh Water Objectives HBWG considers the Fresh Water Objectives are deficient in not including the preservation & enhancement of the life-supporting and food production capacities of the catchment. Much effort has been applied in recent years by the local territorial authorities towards protection of the soil resources, particularly in the Heretaunga Plains (of which Tukituki Water Management Zone 1 forms a part). Due to the summer-dry nature of Hawke s Bay s, preservation of the soil resource is of no benefit unless the water resources are also made available to allow full exploitation of the soils potential. Council s first priority should be to preserve existing production which supports regional economic activity and social well-being, rather than to compromise existing activities by chasing new developments. In Council s focus on Ruataniwha Plains throughout the development of PC6, Council has consistently overlooked the implications for the Lower Tukituki, which supports significant intensive horticulture and viticulture activities, which are major contributors to economic activity and social well-being, particularly as very significant employment providers. 4. POL TT4 Implementing the Nitrate-Nitrogen Limits HBWG considers that Council s proposals around nitrogen controls are highly speculative, as for most sectors outside of agriculture, information on actual N budgets in Hawke s Bay is not available as the research has not been done, so it is impossible to determine with any degree of certainty that NCE or leaching targets can be achieved, or that the research can be completed with the proposed timeframe. We consider the 1 July 2017 deadline for our sector to develop good practice leaching rates & NCEs too tight a timetable to complete the necessary science and engage with our membership to agree industry good practice. A more realistic timetable would be 5 years from implementation of the plan change, with a

3 Page 3 further 2 years thereafter for members to model their vineyards and a further 2 years beyond that to implement any necessary changes. (POL TT4 1. (c)) Furthermore, we think that the proposed rule in POL TT4 1 (f) is unfair and impractical in making an increase of 10% or more in the leaching rate a Restricted Discretionary Activity. This potentially penalises low leachers for trivial changes and also could be applied to make vineyard regrassing or redevelopment require resource consent, as the removal of a permanent vegetative sward for a season would likely trigger a percentage-significant increase in leaching. Requiring a resource consent in such circumstances, where the underlying land use remains unchanged, would be expensive, timeconsuming and pointless. Finally, we do not understand why Water Management Zone 1 is being assigned lower Nitrate-Nitrogen Limits & Targets than the upstream zones. This has the potential to exacerbate the risk that growers in the Lower Tukituki will be penalised by the behaviour of upstream farmers. 5. POL TT7 Minimum Flow Limits HBWG considers that a certainty of supply of less than 90% is untenable for existing growers and on that basis opposes any increase in the minimum flow at Red Bridge, unless it is accompanied by affordable access to supplementary water out of a community irrigation scheme. The current proposal has the potential to impact far more widely in the Lower Tukituki than Council has considered, both because they have underestimated the sensitivity of viticulture & horticulture to watering bans and because of the potential for groundwater users deemed linked to surface water not to be able to physically access stored water delivered by via the river, as is the proposed solution for Lower Tukituki surface water users. This has the potential to compromise large areas of Heretaunga Plains production in the Lower Tukituki corridor. 6. POL TT9 Implementing Minimum Flow and Allocation Limits HBWG broadly supports the proposal to move to seasonal allocation limits but questions the basis of calculation proposed. In particular, we think that limits based on anything less than 90% certainty of supply are unacceptable, so we question why the calculations in Schedule XVIII are based one 1:5 year crop water requirement.

4 Page 4 Also we think that there needs to be an opportunity during the process of conversion to seasonal allocation limits, for obvious errors and significant shortfalls in consents to be resolved through a special hearings committee. 7. POL TT11 Managing Groundwater Takes Hydraulically Connected to Surface Water HBWG considers that the approach proposed is highly unreasonable. It appears to place a very high burden of proof & thus expense on individual consent holders, whereas we believe that the science around linkages between groundwater & surfacewater should be address co-operatively via the existing S. 36 Water Science Charges, as we believe was Council s undertaking when the charges were introduced. We think that a method that requires a combination of 100 days of continuous pumping, along with a threshold for effect of 1L/s is too low an effect threshold to warrant implementation of surface water-linked restrictions and such a policy may have the unintended consequence of deterring migration of takes from surfacewater to groundwater. The method is also unrealistic because it does not accurately reflect how water is used and should be reviewed to be more reflective of irrigation practise for the activity in question. 8. POL TT14 Consent Categorisation and Durations We question the justification in POLTT14 1. (c) in restricting renewal of consents to 5 years, given that the requirement is that Allocation Limits have not been exceeded. Assuming they haven t, we cannot see the point of such short consents, unless it is to further incentivise uptake of the Ruataniwha storage scheme (which approach we wouldn t support anyway). 9. POL TT15 Water Measuring and Reporting Requirements HBWG is concerned that Council is biased towards the requirement for telemetry, as a perceived means of easy enforcement, at consent holder expense. Council consistently underestimates and ignores the significant additional capital and operating expense that telemetry imposes on consent holders, over and above manual reporting. HBWG considers that telemetry is most appropriate in global or shared consenting situations and for very large consents, where immediate information is of some value in managing regional water resources. For the most part, HBWG considers that weekly information, submitted monthly, should provide Council with sufficient information in an acceptable timeframe for appropriate stewardship of the resource. We are concerned that POL TT15

5 Page 5 1. (g) (vii) will be used arbitrarily by Council as a catch-all to extend the scope of telemetry more widely. I wish to be heard in support of this submission. DATED at Hastings this 31st day of May 2013 Xan Harding Vice Chairman, Hawke s Bay Winegrowers Association Inc.

6 SUPPLEMENTARY SUBMISSION Name: Hawke s Bay Winegrowers Association Incorporated This is a submission on the Proposed Change 6, Tukituki River Catchment dated 24 April 2013, supplementary to a joint submission submitted in conjunction with us by Horticulture New Zealand. 1. Who we are: Hawke s Bay Winegrowers Association Inc. (HBWG) HBWG is the industry representative body for grapegrowers and winemakers in Hawke s Bay. All growers and wineries receive automatic membership through payment of industry levies. HBWG is affiliated to and receives most of its funding from New Zealand Winegrowers and has a local membership comprising 157 grapegrowers, 92 winemakers and a number of associate members. The wine sector is one of the largest intensive land-users in Hawke s Bay, comprising around 5000ha in production, predominantly on the Heretaunga Plains and mostly clustered around existing & ancient riverbeds, including the Tukituki. Annual grape production in Hawke s Bay is around 35,000T, the second-largest region after Marlborough. NZIER estimated that in 1998 our GDP contribution was $106.2m and we provided employment for 1596 FTE. HBWG carries out a range of services for its members including education, research, wine promotion, media hosting and advocacy and was formed in 2007 from the merger of the members of 2 longstanding local associations - Hawke s Bay Grapegrowers Association Inc. and Hawke s Bay Winemakers Inc.

7 Page 2 2. The specific areas on which we wish to provide further comment are as follows: - POL TT11 Managing Groundwater Takes Hydraulically Connected to Surface Water 3. POL TT11 Managing Groundwater Takes Hydraulically Connected to Surface Water HBWG has already submitted that the approach proposed is highly unreasonable, places a very high burden of proof & thus expense on individual consent holders and should be address co-operatively via the existing S. 36 Water Science Charges. We would like to provide further comment as follows: 1. We are very concerned that HBRC has broken its promise made to primary sector representatives in 2012 that Lower Tuki Tuki Groundwater would be excluded from PC 6 and dealt with separately. Concerns were raised by the primary sector during consultations to understand the scope of PC 6 & specifically whether only surfacewater takes and those currently considered to be surfacewater-depleting groundwater takes were included. Industry was advised that groundwater takes not currently deemed surfacewater-depleting would be excluded. Based on that assurance, consultation with affected parties was focussed on a relatively small number of surfacewater takes on the Lower Tuki Tuki, involving multiple meetings with HBRC Councillors & senior HBRC staff representatives, which resulted in an acknowledgement by HBRC that a solution needed to be found to mitigate the impact on these takes, potentially involving access to water from the Ruataniwha scheme. We were therefore justifiably shocked to discover that proposed POL TT11 operates to include all groundwater takes in the lower Tuki Tuki and we regard this as a broken promise by HBRC. 2. We now understand that a number of vineyards in the Lower Tuki Tuki holding groundwater consents are now captured by PC 6, may be considered surfacewaterdepleting & therefore faced with significant costs to assess the degree of linkage & potentially subject to river low-flow irrigation bans. Current estimate is that around 200ha of vineyard could be affected, around 1500T of fruit, translating to $15m of wine sales at risk. This clearly demonstrates that HBRC s economic impact analysis has been hopelessly inadequate.

8 Page 3 3. For our members already depending on surface water takes, we are concerned that PC 6 contains no provisions that would allow them affordable access to supplementary water out of a community irrigation scheme during low-flow periods. 4. For our members that use groundwater that may be deemed surfacewaterdepleting, we are concerned that they would be more severely impacted by PC 6 than surfacewater users, as they will not have the existing infrastructure to access Scheme water out of the river. 5. For these reasons we oppose POL TT11 as currently drafted. 6. For the same reasons, we oppose any increase in the low flows at Red Bridge without affordable access for lower Tuki Tuki consent holders to supplementary water out of a community irrigation scheme. I wish to be heard in support of this submission. DATED at Hastings this 2nd day of August 2013 Xan Harding Vice Chairman, Hawke s Bay Winegrowers Association Inc.