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56 Queen Street | PO Box 1268 | Palmerston North 4440 | New Zealand
P 06 353 7560 | [email protected] | goodearthmatters.com
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Project Ref: 27026 21 May 2019 Horizons Regional Council Private Bag 11025 Manawatu Mail Centre Palmerston North 4442 Attention: Fiona Morton Dear Fiona
TOKOMARU WATER APP-1994001425.01 RESPONSE TO S92 REQUEST FOR FURTHER INFORMATION
We refer to your request for further information dated 29 April 2019 with respect to the above application APP‐1994001425.01, being the application by Horowhenua District Council to renew its water take permit for supplying water to the Tokomaru community.
CONSULTATION UPDATE
At the time of lodgement, the AEE stated that consultation was occurring with the identified affected parties. We would like to take this opportunity to provide Regional Council with an update as to the consultation undertaken and outcomes subsequent to the lodgement date, as follows:
Department of Conservation has provided its written approval under s95E of the Resource Management Act. We understand that this has been forwarded to you directly by the Department of Conservation. A copy is attached for your records.
Tanenuiarangi Manawatū Incorporated have been consulted with and have provided a letter of support, as attached.
The District Health Board / Drinking Water Assessor has provided a letter of support for the application, as attached.
Council has engaged with Ngāti Whakatere and a Cultural Impact Assessment (CIA) has been commissioned. Work has commenced on the CIA and a site visit has been undertaken. The CIA is expected to be completed late June.
Consultation has been undertaken with Fish & Game Council. We have not yet received a response from Fish & Game.
S92 REQUEST FOR FURTHER INFORMATION - GENERAL COMMENTS
Prior to responding to the s92 request on an item‐by‐item basis, we would like to provide some general commentary as to the District Council's approach to the provision of storage and network management for the water supply scheme. Several of Regional Council's s92 request items are focused on the question as to the feasibility of providing more storage in order to minimise or avoid abstraction when the River is below minimum flow. The response to this question does rely on what is meant by "feasible". Quite clearly provision of additional storage is technically feasible, however, whether or not it is feasible for District Council to invest in the significant additional costs requires consideration of the Council's obligations under both the Resource Management Act
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(RMA) and the Local Government Act (LGA). The District Council understands that it needs to meet its obligations under the RMA independent of its LGA obligations. However, in doing so, it does need to be cognisant of its purpose under the LGA which is to "meet the current and future needs of communities for good‐quality local infrastructure … in a way that is most cost‐effective for households and businesses", where "good‐quality" is defined as being efficient, effective and appropriate to present and anticipated future circumstances1. For this consent application, obligations under the Health Act to "ensure that an adequate supply of drinking water is provided to each point of supply"2 are also relevant. Therefore, with respect to storage for the Tokomaru water supply, Council's approach is that it has already made significant recent investment in both treatment and storage, and additional storage is not warranted given the ecological effects assessment has identified that the effects of abstraction below minimum flow are no more than minor. To incur additional significant expenditure for more storage is therefore not considered necessary with respect to avoiding, remedying or mitigating adverse effects under the RMA, and would not be considered feasible in terms of the test required under the LGA to provide services in the most cost‐effective manner. The following item‐by‐item response to your request for further information provides the specific information requested to support this position. With respect to the requests for more detailed leakage assessments for the network, Council notes that this also needs to be considered in context of all of the water supply schemes managed by Council. The Council has a programme of network management, efficiency assessments and leak detection and repairs coordinated across the District. Its recent and ongoing focus is on those communities where there are known to be unexplained and / or high levels of unaccounted for water (eg Shannon) and across the main urban centre (Levin). It is considered that this is a more appropriate investment of Council's resources (both budgetary and skilled personnel) in this area, than would be a detailed network assessment of the Tokomaru water supply, particularly given that the overall water use (which includes any unaccounted for water) is within One Plan policy assessments of reasonable water use.
S92 REQUEST FOR FURTHER INFORMATION - ITEM BY ITEM RESPONSE
The following provides an item‐by‐item response to your requested information. Your request is repeated in bold with the response provided below each item.
Consent Required for Discharge - Confirmation of Relevant Rule and Activity Status
You have advised in your letter that consent is required for the discharge of water to water as it is a discharge to a rare, threatened or at risk habitat, and that as a Site of Significance ‐ Aquatic the activity will be considered as a discretionary activity pursuant to Rule 13‐8. You further note that this is not an issue as consent for the discharge activity has been sought. We request confirmation of the activity status and applicable rule. Please note that our original assessment of this activity was that, as you note above, it is a discharge of water to water and therefore considered it to be a Permitted Activity under Rule 14‐12. However, in preparing the application, we consulted with Horizons on this matter and were advised that the activity would be considered a discharge of contaminants to water and therefore needed consent pursuant to Rule 14‐25 'Discharges of contaminants to a reach of a river or its bed with Schedule B Values of Natural State and Sites of Significance ‐ Aquatic' (refer email from Horizons Regional Council, Jasmine Mitchell 31/01/2019 attached to this letter). It is on this basis that the application included seeking consent for the discharge. Your letter now seems to be advising that the activity is considered a discharge of water to water as per our original assessment. However, you state that it requires consent under Rule 13‐8 as it is to a rare, threatened or at‐risk habitat because the water management zone has a value of Site of Significance ‐ Aquatic (SoS‐A). We note
1 Local Government Act, S10: Purpose of Local Government
2 Health Act, s69S: Duty of Suppliers in relation to provision of drinking water
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that Rule 13‐8 only refers to activities in some at‐risk habitats and does not apply to rare or threatened habitats. Can you please clarify how the Schedule B Value of SoS‐A requires that it be considered an at‐risk habitat? Our interpretation is there is nothing in Rule 13‐8 which states that SoS‐A is a trigger for application of that Rule. Rule 13‐8 relates only to at‐risk habitats (not rare or threatened), and the One Plan glossary defines At‐Risk Habitat as meaning "an area determined to be an at‐risk habitat in accordance with Schedule F and, for the avoidance of doubt, excludes any area in Table F.2(b)." Schedule F states that an at‐risk habitat is an area of vegetation or physical substrate which is a habitat type identified in Table F.1 as being At‐Risk and meets at least one of the criteria described in Table F.2(a) for the relevant habitat type. None of the habitat types in Table F.1 include streams or rivers. Horowhenua District Council's consultant freshwater ecologists, Aquanet Consulting, have also advised that they do not consider that the receiving environment is considered an At‐Risk habitat as defined in Schedule F. Therefore, can you please confirm the relevant activity (Discharge of water or discharge of contaminants) and the relevant rule for consideration of this activity. Regardless of the trigger for consent, the effect of the discharge to water has been assessed as having a de minimus effect on the Tokomaru River. We also note that the Department of Conservation has provided their written approval for the activity. These interpretation issues notwithstanding, the information requested has been provided below.
Discharge to Water
1. What are the pipes made from and how long does the water typically sit within these pipes before being discharged back out into the Tokomaru River?
The intake pipe (from the intake gallery) and the return discharge pipe are 100 mm nominal diameter PVC. As noted in the application, the total volume of water in the pipe is less than 1 m3. The outlet is a free outlet and therefore the return pipeline will drain under gravity and the return pipework (valve chamber to outlet) is not generally sitting full of water. The only water sitting in the pipework is therefore in the intake line (from the infiltration gallery to the valving on the discharge line). As noted in the application, the return line activates for a short period each time when the treatment plant starts. Telemetry on this system is currently limited to recording the % open for the return line valve, logging at generally 10‐15‐minute intervals. This shows that, the return line valve is generally opened (ie there is a return line discharge) at least once if not several times per day (refer Figure 1 below). Therefore, water is typically sitting within the pipes less than 24 hours before being discharged back to the River. For the data period available (as shown in Figure 1), there are 17% of the days (56 days) where the return line did not activate. The maximum number of consecutive days of non‐activation has been two days (ie 48 hours sitting), except for the following:
In November 2018, the return line did not activate between 11 and 13 November;
In January 2019, the return line did not activate between 5 and 13 January and between 18 and 22 January; and
In February 2019, the return line did not activate between 8 and 12 February.
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Figure 1 Number of Activations of Return Line per Day
2. By what means is the water discharged back into the River i.e. is it via a pipe outfall or some other structure?
The discharge is a simple pipe outfall above the water level, as shown in Figure 2 below. While not visible in the photograph, there is rock protection below the pipework to prevent scour and erosion.
Figure 2 Discharge outlet pipe
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3. Has any maintenance been required at the outfall structure – i.e. to remedy any scouring that has been caused by the discharge?
District Council has advised that maintenance of the outfall structure has not been necessary as the discharge flow rate is low enough not to cause scouring. Council is not seeking consent to undertake maintenance of the outfall structure. Should maintenance be required, appropriate consents will be sought from Horizons Regional Council if required.
4. Has any scenario modelling been undertaken looking at storage requirements such that no take below minimum flows are required?
Yes, scenario modelling was undertaken to identify the amount of storage required to avoid take below minimum flows. The modelling was based on the river flow data available for the last 10 years. This identified that in the five years where the river fell below minimum flow, there were 24‐47 days when the river was below minimum flow. To meet current demand (225‐250 m3/day), a total storage volume of 5,400‐11,750 m3 would be required to avoid abstraction at times of minimum flow. This is 10‐22 times the total volume of storage already provided in the scheme. To achieve the same result under the growth scenario, would require 8,500‐16,800 m3 of storage. The cost of such volumes of storage would be unaffordable for the community. Council installed a 200m3 timber storage tank in late 2017 at a cost of approximately $120,000. This tank brought the total storage volume at the water treatment plant to approximately 530m3, with a total storage asset value (book value) of approximately $500,000‐$600,000 excluding the land which the tanks occupy. The bulk storage that would be required is an order of magnitude greater than the storage already provided. It is acknowledged that unit rates (ie $/m3) for constructing such a large volume of bulk storage would be less than the unit rate for the currently installed storage. However, the cost of providing sufficient storage to avoid abstraction at times of minimum flow would still most likely be in excess of $1.5million3. For Tokomaru, such cost would equate in excess of $4,500 per connection. As discussed above, such a cost would be unaffordable and would not be considered feasible in terms of the District Council's obligations to provide cost‐effective infrastructure given that the abstraction below minimum flow has been assessed as having effects which are no more than minor.
5. Is it feasible to remove the need for a water take below minimum flows in most years? Please refer to our response under item 4 above. It is important to note that water is not taken below minimum flows in most years. In any given year there is only approximately 50% probability that flows below the minimum flow of 240 L/s will occur. In any given year, there is approximately 75% probability that when abstraction does occur below the minimum flow, it will occur for less than three percent of the time (3% of the time equates to a maximum of 11 days per year). That is, on average, in 2 out of 4 years there will not be an abstraction below minimum flow. In the third year, abstraction below minimum flow may be required up to 11 days per year. In the fourth year, extended minimum flow periods may occur for more than 11 days per year.
3 Eg Manawatu District Council has recently let a contract to construct a 10,000 m3 reservoir for the Feilding supply, with
tendered prices ranging from $1.8‐3.4million (https://www.stuff.co.nz/manawatu‐standard/news/111190809/feildings‐new‐18‐million‐reservoir‐to‐provide‐greater‐water‐security‐in‐an‐emergency)
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To provide sufficient storage to avoid the abstraction at minimum flow for up to 11 days per year (ie so that, on average 3 out of 4 years would not require abstraction below minimum flow) would still require storage volumes of 2,750 m3 for the current community and 4,000 m3 to service the future community. Such storage would have a ballpark cost of $1‐2million to provide. Given the infrequent abstraction of water below minimum flows, and for the cost/benefit reasons discussed above in Item 4, it is not considered feasible or reasonable to remove entirely the need for a water take below minimum flow.
6. What is feasible in terms of further storage? As above in Item 4 and Item 5, it is not considered feasible to provide any additional water storage at this time. An additional timber tank, at a cost of approximately $120,000 could provide up to 200 m3 of additional storage. This does not provide a meaningful volume of storage to be able to avoid abstraction at minimum flow. Further it would represent an unnecessary cost to the community and not recognise that this investment has already been undertaken by Council prior to seeking consent renewal. As discussed above, it is considered that additional storage is therefore not feasible given that the effects of the abstraction are no more than minor, water restrictions will be in place, and that additional costs could therefore not be justified in terms of meeting the cost‐effective test under the LGA.
7. Are there any stock water offtakes from the system (other than the small take identified for the public toilets etc.)? As there has been no mention of these in the demand assessment.
There are no direct stock water offtakes from the system. There are some rural properties that are provided with water supply as identified in the Water Use Assessment report attached as part of the application and that will undoubtedly include an element of water used for stock drinking water. Council does not have data with respect to numbers or type of stock that rely on water from the scheme. The rural properties which are serviced by the supply are metered with water meters read on a quarterly basis. The water meter data has been used in the Water Use Assessment report included with the application.
8. Does the infiltration gallery require maintenance work either occasionally or regularly, such as movement of the gravel to allow increased water through‐flow etc.? If so, there may be consents required for works in the bed of the river (SOS‐A status).
Council officers have confirmed that no maintenance work is required for the intake gallery. The pump chamber is cleaned once per year, but this is outside of the bed of the river. No maintenance activities in the bed of the river are required. Council is not seeking consent to undertake maintenance of the infiltration gallery. Should maintenance be required, appropriate consents will be sought from Horizons Regional Council if required. The volume applied for is more than double the maximum daily use volume recorded to date. This is extremely difficult to justify as “efficient”, especially when the take is expected to continue below minimum flow. The “growth” justification in the application states that a district plan change will be required to allow for the growth and development that they are forecasting and using to justify the additional water requirement. While a volume of 864 m3/day (being the same as the existing consent) has been sought as the maximum consented take, this figure does not reflect the proposed abstraction regime for which consent is sought, and could be conditioned, as set out in Table 1.1 of the application. Table 1.1, states the following proposed abstraction regime:
90th percentile limit for the existing community: 330 m3/day (This provides for some fluctuation of day to day abstraction as required to maintain continuity of supply with storage fluctuations, and includes a "headroom" allowance to ensure that non‐compliance is not recorded due to short term variations in demand). This is approximately 10% above the maximum daily abstraction volume to date, not twice as implied above.
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90th percentile limit for the future community size: 430 m3/day (This is based on the projected growth along with the above consideration to provide for headroom to ensure non‐compliance is not recorded due to short term variations)
Maximum rate of take when the river is above minimum flow 10 L/s
Maximum rate of take when the river is below minimum flow 5 L/s
9. How does this sit with One Plan Policy 5‐12 d(vii) that states that for the allocation for water for growth, the growth must be allowed for in an operational plan, and reasonably forecast? This could mean that the additional water for the growth would be outside what would be considered reasonable because it does not meet these criteria.
Figure 4.2 of the AEE shows the growth areas and is repeated below.
Figure 3
Tokomaru Future Growth Areas (Figure 4.2 of AEE)
The growth areas to the north of the existing community are already zoned in the Operative District Plan.
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Council has recently updated its growth projections through the Growth Strategy 2040 process. As set out in that report4, the projections have been based on Statistics NZ data as well as research reports specific to the region and district (ie, NZIER Report on the Impact of the Roads of National Significance, and the Sense Partners report for Horowhenua District entitled "Horowhenua Socio‐Economic Projections". Both of these reports are available on the District Council's website). The research and statistical basis of the Growth Strategy 2040 report therefore means that the growth projections can be considered to be reasonably forecast. The Greenbelt Residential Zone (Green Block in above figure) is able to be developed at present. The Deferred Greenbelt Residential Zone (Light Blue Block in above figure) is also currently in the District Plan and could have its deferred status removed by a resolution of Council, rather than a plan change process. Therefore, both of these areas are consistent with One Plan Policy 5‐12 d(vii) in that they are zoned in the Operative District Plan and are reasonably forecast. They are both likely to be developed either fully or partially during the term of consent. The application does include an allowance for the growth areas included in Council's Growth Strategy 2040 that have not yet been zoned in the Operative District Plan. As noted above, this growth is reasonably forecast, and also likely to be developed either fully or partially during the term of consent. A Proposed Plan Change to rezone these areas in the District Plan is currently being developed and is expected to be notified later this year (tentatively August 2019). We note that there is some potential conflict between Policy 5‐12(d)(vii) and potential District Plan rezoning process in that, often, the ability to adequately service an area is a matter which is pivotal to the rezoning process. That is, the rezoning decision will consider whether or not there is sufficient consented capacity to service an area. However Policy 5‐12(d)(vii) hinders obtaining consent prior to a rezoning becoming Operative. The above notwithstanding, we acknowledge that the application needs to be assessed against Policy 5‐12(d)(vii) as it stands. In that regard, the Growth Strategy Areas are not able to be included in future demand calculations as per Policy 5‐12(d)(vii). We note that this is a matter of timing which has arisen due to the need to renew the water consent prior to the Plan Change being notified. If this is a concern for grant of consent, Council would accept conditions on consent which essentially preclude use of a portion of the allocated water until such time as the growth areas are included in an Operative Plan Change. Such an approach would be consistent with Policy 5‐12(d)(vii) and would not preclude any other users from accessing water given that the Water Management Sub‐Zone is under allocated and has core allocation available for allocation.
10. In regard to the volume applied for versus known demand, have alternative systems been considered to provide the buffer you are seeking – namely storage?
Additional storage has been considered as an alternative but is not considered feasible as discussed in Items 4, 5 and 6 above. Alternatives have been considered as set out in Section 4.2 of the AEE. There are no other viable alternatives.
11. Is it possible, with the addition of further storage, to achieve a lower rate of take (or none) at low flow times? Would this be feasible?
With the addition of further storage, a lower rate of take (or none) could be achieved at minimum flow times. However, for reasons set out in the response to items 4, 5 and 6, additional storage is not considered feasible, nor necessary given that the ecological assessment has found that the effects of the abstraction below minimum flow are no more than minor. The Regional Council Senior Water Quantity Scientist, Raelene Mercer, has concerns over the method used for undertaking leakage losses in the system. A survey was undertaken for the Levin Water Supply and there is merit in using this approach again with this application. This could form part of a Demand Management Plan. In the meantime, she is working with the estimate of leakage provided, which is the estimated up to 33% of average demand.
4 https://www.horowhenua.govt.nz/Council/Plans‐Strategies/Horowhenua‐Growth‐Strategy‐2040
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12. Please undertake some further work around the rate of water taken for the trickle feed systems to help refine this estimate.
We note the concerns raised by Raelene Mercer, however with the meters currently in place, it is not possible to provide further definition as to the rate of water taken for the trickle feed systems. Unaccounted for water has been assessed based on night flow assessment and the estimate correlates with District Council's own assessment of leakage as reported in its 2017‐2018 Annual Report. Night flow assessment is a recognised method of assessment as detailed in Water New Zealand's Water Loss Guidelines, February 2010. In particular, that document notes that "night flow measurements can also be used to provide an alternative assessment of Real Losses, particularly in small districts where not all properties are metered". The estimates have been made with conservative assumptions meaning that the estimates are likely at the higher end of the likely range. While a survey has been undertaken for the Levin Water Supply the same approach is not considered appropriate or necessary in this instance. This is for reasons as described above, namely that Council is undertaking this work as a programme of network management, efficiency assessments and leak detection and repairs coordinated across the District. Recent and ongoing focus is on those communities where there are known to be unexplained and / or high levels of unaccounted for water (eg Shannon) and across the main urban centre (Levin). In implementing this programme, Council recognises that there are limited resources (both budgetary and skilled personnel) in this area and is targeting those resources at areas where there are known issues. While the estimates for Tokomaru have indicated 24‐30% unaccounted for water, this needs to be placed in the context that the overall community demand (ie actual demand plus leakage) is within the One Plan policy calculation for reasonable use. This implies that the actual leakage rates are likely less than estimated. The alternative conclusion would be that the actual water use in Tokomaru is significantly below what is provided for in the One Plan policy which is considered unlikely to be the case. We trust the above has satisfactorily addressed the questions raised. Yours faithfully
Annette Sweeney Encl: Department of Conservation s95E Approval TMI Letter of support District Health Board letter of support Email from Horizons re activity status of discharge (email from Jasmine Mitchell, 31 January 2019) cc: Horowhenua District Council Attention: David Clapperton, Rob Green
Department of Conservation Te Papa Atawhai DOC- 5915398 www.doc.govt.nz
DOC Ref: RC 000183
Date: 15/04/19
Horowhenua District Council
126 Oxford Street,
Levin 5510,
Dear Horowhenua District Council
Request for Approval: s95E Resource Management Act 1991
Water Permit, Horseshoe Bend, Tokomaru, Levin, 8/04/2019
I have considered your request for approval in terms of s95E of the RMA and am pleased to advise
that I grant my approval as an affected person.
My approval is granted on the basis that the proposal is as described, is for the purposes described,
and will have the effects on the Department of Conservation (Department)’s interests as described
in the application dated 8/04/2019.
This approval is limited to the likely adverse effects of the proposal on the Department’s interests
and should not be construed as approval to effects on the environment generally.
This approval is specific to the above application and is for the purposes of s95E of the RMA only. It
is not indicative of any associated concession or other statutory approval which may be required
from the Department in regard to this proposal.
This approval will be rendered null and void if the proposal to which it refers is changed between the
date of this approval and its consideration by the consent authority without referral back to me for
my further assessment.
Please be advised that the original of this letter has been sent to the consent authority for their
records.
If you have any questions regarding this approval, please contact [email protected]
Yours sincerely
Marie Long
Director Planning, Permissions and Land
Te Mauri o Rangitāne o Manawatū (Council of Elders) Tanenuiarangi Manawatū Incorporated (Iwi Authority)
Phone: (06) 353 1881 Fax: (06) 353 1880 Email: [email protected] Website: www.tmi.maori.nz
Best Care (Whakapai Hauora) Charitable Trust Piki Kotuku Te Awhi Hinengaro Kia Ora FM 89.8 (Health/Social/Promotion Services) (Mental Health & Addictions Services) (Iwi Radio Station)
Phone: (06) 35 36385 Phone: (06) 353 1884 Phone: (06) 353 1881
Fax: (06) 353 1883 Fax: (06) 353 1885 Studio: (06) 353 1882
Email: [email protected] Email: [email protected] Fax: (06) 353 1880
Website: www.whakapaihauora.maori.nz Website: www.whakapaihauora.maori.nz Website: www.kiaorafm898.maori.nz
Te Hotu Manawa o Rangitāne o Manawatū Marae Physical Address: 140-140 Maxwells Line, Palmerston North
Postal Address: PO Box 1341, Palmerston North
Annette Sweeny
Good Earth Matters
56 Queen Street, Palmerston North 4410
Regarding Tokomaru Municipal Water Take
Tena koe Annette
Ngā mihi nui ki a koutou i roto i ngā tini āhuatanga o te wā nei.
This letter is to confirm that Good Earth Matters have consulted with Tanenuiarangi Manawatū Incorporated
regarding the consent to renew Tokomaru Municipal Water Take. We are supportive of this activity and endorse
the consent renewal.
Nāku noa
Siobhan Lynch- Karaitiana
Environmental Planner
Tanenuiarangi Manawatū Incorporated
027 342 8400
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Kylie Mills
From: Jasmine Mitchell <[email protected]>Sent: Thursday, 31 January 2019 9:05 AMTo: Emma HilderinkSubject: RE: S124 RMA Exercise of resource consent while applying for new consent - Tokomaru Public
Water Supply
Morning Emma In short I think this will need a consent under Rule 14‐25 as this stretch of the Tokomaru River has a Site of Significance – Aquatic Value for banded kokopu, redfin bully and koaro. Any questions please let me know. Kind regards Jasmine
From: Emma Hilderink <[email protected]> Sent: Tuesday, 22 January 2019 2:49 PM To: Jasmine Mitchell <[email protected]> Subject: FW: S124 RMA Exercise of resource consent while applying for new consent ‐ Tokomaru Public Water Supply Hi Jasmine, Hope you had an awesome summer break. We are busy preparing the consent application at the moment and I have a query I am hoping you can answer for me. Currently, HDC’s infiltration gallery feeds water into a manhole pump chamber by the edge of river and is then pumped to treatment plant via the flow meter / telemetry housing approx. 100m from the intake. Online turbidity meters are located at the flow meter site and if the turbidity is too high for effective drinking water treatment (> 2 NTU), the intake is shut‐down and the water in the pipeline between intake and turbidity meter is bypassed back in to the River (discharge volume approx. 785 litres). The distance of the discharge line to the infiltration gallery is approx. 100m. I would like to know whether the discharge of this high turbidity water back to the river at times of high flow requires discretionary consent under Rule 14‐25 or Rule 16‐13, or whether the discharge is a permitted activity under Rule 14‐12 Discharges of Water to Water, or if some other rule applies? Kind regards, Emma
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From: Emma Hilderink Sent: Tuesday, 4 December 2018 10:52 a.m. To: 'Jasmine Mitchell' <[email protected]> Subject: S124 RMA Exercise of resource consent while applying for new consent ‐ Tokomaru Public Water Supply Morena Jasmine, We are currently preparing a resource consent application on behalf of HDC for the renewal of their public water supply take from the Tokomaru River. Their current resource consent expires on 1 July 2019 (ref 4507), see attached. We would like to apply to Council for a 3 month extension to lodge the consent renewal application which would allow HDC to continue to operate under the existing consent until a new consent is granted or declined. The reasons being to allow time for ecological effects assessment at times of low flow over this summer (to meet low flow conditions and also due to availability of Aquanet to complete this work), as well as to undertake consultation with iwi. Can you please let us know if Council agrees to the extension. Happy to discuss any of the above with you further.
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Kind regards Emma
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