SUBMISSION ON AN APPLICATION

FOR A RESOURCE CONSENT

Resource Management Act 1991

 

Consent Authority:    Environment Canterbury (Canterbury Regional Council)

 

Consent Required:      

 

CRC061972

 

To take and use water from the Waimakariri River at a maximum rate of 40 cubic metres per second via the upper Waimakariri water intake system and the lower Waimakariri water intake system, for the purposes of irrigation of up to 60,000 hectares of land within the Scheme Area, for water storage, and for ancillary purposes associated with the operation of the Central Plains Water Enhancement Scheme. A consent with duration of 35 years is sought.

 

CRC061973

 

To take and use water from the Rakaia River at a maximum rate of 40 cubic metres per second via the Rakaia water intake system, for the purposes of irrigating up to 60,000 hectares of land within the Scheme Area, for water storage, and for ancillary purposes associated with the operation of the Central Plains Water Enhancement Scheme. A consent with a duration of 35 years is sought.

 

Applicant:                         Central Plains Water Trust and jointly Central Plains Water Trust and Ashburton Community Water Trust

 

Submission by:                 Medical Officer of Health

                                                Community and Public health

PO Box 1475

                                                CHRISTCHURCH

                                               

The Medical Officer of Health opposes the application of Central Plains Water Trust and jointly Central Plains Water Trust and Ashburton Community Water Trust.  The reasons for making this submission are:

  1. There is insufficient information on the overall health effects of the scheme.  A health impact assessment does not appear to have been carried out.
  2. We believe that the assumptions used for the likely land use following the implementation of the scheme are just one scenario.  Section 3 of the Resource Management Act, identifies that effects include cumulative future and potential effects of high probability or low probability, but with high potential impact.  Therefore a wide range of scenarios need to be assessed.
  3. The impact on private and public water supplies does not appear to have been properly assessed particularly in view of the current emphasis on proper catchment management.
  4. The scheme will cause increased leaching of contaminants such as microbes (including viruses) Nitrate-Nitrogen, Phosphates and pesticides, which may cause increases in the levels of these contaminants in groundwater.  Insufficient information has been given on the extent of the increases and the likely effects of these rises on health and the environment and possible mitigation measures.
  5. There is an insufficient assessment of the short and long-term disease issues that could arise from increased economic activity and changed land use e.g. emerging pathogens, and how these could be managed or mitigated.
  6. There will be spillover into the Christchurch Aquifer recharge zone. There is insufficient information on how this will affect the Christchurch water supply and what measures will be proposed in mitigation.
  7. There is insufficient information on the social effects arising from the scheme and any proposed mitigation measures.
  8. There is insufficient information on transport and road safety issues that will arise from increased economic activity and population growth.
  9. There is insufficient information regarding how increased effluent and waste from land use change and increased economic activity and population growth will be managed and what the effects of this on the environment will be.
  10. There is insufficient information on the potential effects on health and the environment from changing the factors which affect the rate of transport of contaminants, especially nitrate and microbes, to groundwater, e.g. method of irrigation and application rates, changes in groundwater level, groundwater mounding, groundwater flow patterns.

             

I wish the consent authority to make the following decision:

We request that the

1.      Canterbury Regional Council defer any consideration of this application until additional information is received and properly assessed or

2.      Canterbury Regional Council decline the application if no additional information is received or the information received is inadequate.

 

I have no objection to attending a pre-hearing meeting.

 

I wish to be heard in support of my submission.

 

 

 

 

Signed:                                     ...........................................................................

                                                for Medical Officer of Health

 

Dated:                                      18th August 2006

 

Address of Service:                 Community and Public Health

                                                PO Box 1475

                                                CHRISTCHURCH

                                                Telephone: (03) 3799 480 ext 825 Facsimile:  (03) 3796 125

 

Contact Person:                        Malcom Walker

                                                Health Protection Officer

 

Copy to:                                  Central Plains Water Trust

Central Plains Water Trust

Ashburton Community Water Trust