Update after discussions with MDC staff in november 2022.

Dave, Don and Budyong met with Pere and Hans for a couple of hours. The meeting was very congenial, relaxed and informative. We got the impression that they also appreciated the opportunity to get together for an extended discussion. The primary focus of the meeting was to discuss issues relating to the Wairau aquifer and it’s management. We had produced a document that we sent in beforehand with a range of points highlighted from the Guidance on the National Objectives Framework of the National Policy Statement for Freshwater Management (NOF) and questions arising from those points. A copy is attached FYI.

In earlier communications with Peter Davidson, the MDC Groundwater Scientist, he referred to using “alternative approaches to managing seasonal and boundary effects”. The primary objective of our meeting was to try and get a better understanding of what alternative approaches are being considered by the policy makers. This is in relation to the question of how best to continue allocating and managing water extracted from the aquifer taking into account the ongoing declining trend caused by the identified reduction in recharge. It is important to note that research has also identified that water can pass through the aquifer in as little as three months which means it is a much more dynamic and variable storage reservoir than previously thought. Traditionally the management has been done by setting physical limits and currently the three smaller sectors of the aquifer, immediately adjacent to the springs, have level limits (metres above sea level) set in the Proposed Marlborough Environment Plan (pMEP) and the two larger, Lower Wairau and Recharge Sectors, have no limits set. Knowledge has improved considerably since 2016 when these limits were set in the pMEP. Water users from the three smaller sectors are appealing these limits and it seems they have a good case to not be treated differently from all other users of water from the aquifer. The proposed limits are likely to be removed. Pere highlighted that fact that Peter Davidson believes the aquifer should be seen as a huge underground reservoir that is big enough to be managed to meet the identified and allocated needs of water users in the area. The point was again made that the major issue with the aquifer is not with water use from it but rather with the declining recharge from the river.

So it appears that the answer to the question of what “alternative approaches to managing seasonal and boundary effects” are being considered is that setting aquifer level limits is not an effective way to manage the reservoir. The management tool is likely to simply be the total volume of water allowed to be consented from that FMU, which is calculated according to what the scientists believe the aquifer can reasonably provide on an ongoing basis. Regardless of water use the decline is expected to continue the same slow downwards trend, unless the recharge can be improved. It seems counter intuitive to manage the aquifer like this but its dynamic nature means it can also fill up very quickly with big flood events. It is very different, for instance, from the Southern Valleys aquifer where the water is at least a thousand years old and replenishes slowly. In the rainfall events this past July/August the monitoring bore at Conders Bend registered the highest aquifer level recorded since records began in 1982. The blue line on the graph below showing aquifer movements this year, illustrates how fast things can change. Effectively the aquifer was above ground level in low lying places at its peak and water pooled for several weeks before the aquifer slowly returned to lower levels. I witnessed this at the Crum’s property in Inkerman St just below the terrace in Renwick. You can also see by early November it had dropped to well below average for this time of year. One of the unavoidable consequences seems to be that the headwaters of the various springs, where water exits the aquifer at ground level, will continue to slowly recede and fluctuate as a visible manifestation of the changing aquifer levels.























This all highlights the big question. Can changes be made to river management that improve the recharge rate? There are already plans to remove some of the rock walls that have traditionally controlled the river flow within what were seen as acceptable parameters. The Gravel Bed River Research (GBR) has determined that the deep pools that form against these rock walls create the opportunity for water to flow back out of the aquifer during periods of low flow in the river. So, letting the river have more room between the existing stop banks is a first step in trying to slow the aquifer decline. Pere also informed us that the option of moving stop banks, again to give the river more room to move, is being considered. There are places like Conders Bend where MDC owns the land adjacent to the stop banks and this land is currently leased for grape growing. Using river management to increase the gravel levels in the river would also be advantageous, as those river bed gravels are important for holding and feeding water into the aquifer.

There were several other interesting bits of information that came from our discussions. Hans talked about a decision he was involved with in the 1990’s that appears to have had a big part to play in directing land use in Marlborough to grape growing rather than dairying. This was when water allocation parameters were being set and many councils around the country decided to issue 30 year consents. He was advised by an economist that the best way to discourage dairying was to only issue 15 year consents, as banks were reluctant to loan on dairy conversions with the shorter consents for water use. The massive expansion of grape growing has been an outcome of this policy. We only have to look to Canterbury to see what has happened there with excessive dairy conversions on inappropriate soils and the difficulty they now have to try and turn around a whole industry so they can halt the environmental damage to their water. Any monoculture invites problems but at least our water in Marlborough is relatively healthy compared to many other areas of NZ due to the relatively low impacts of grape growing. It was also mentioned that there are only about 4,000 hectares of identified suitable grape growing land remaining in Marlborough so we are reaching the physical limits of what can be grown here. The recently retired MDC hydrologist Val Wadsworth, claimed that the water available from the Wairau River and aquifer is more than adequate to meet the needs of the water users in the valley as long as it is well managed. It was also mentioned that some of the big corporates involved in wine making are driving moves towards more sustainable grape growing and organics because of consumer pressure and better returns. They have the resources to make this happen and it seems reasonable to assume Wairau water quality will benefit from this development.

We also discussed monocultures and diversification. Pere asked me why I was concerned about our reliance on grape growing in Marlborough and my response was simply that I believed that too much reliance on one industry in any region reduces resilience if some unexpected disruption turns up. Hans said he agreed and has been trying to encourage land users in Marlborough to think about other possibilities for our soils and climate and believes there will be other crops that can give a good financial return and have low environmental impacts. Pine nuts is one local example showing promise.

Another bit of information was that MDC have commissioned NIWA to do a detailed analysis of sea level rise in Marlborough with more definition than that available in the recently released national database. This follows NIWA having completed such an analysis for the Nelson/Tasman region.

Finally there was also some discussion about challenges with involving local Maori in the Te Mana o te Wai process. For those who are not familiar with this central concept for fresh water management here is some information from the MfE factsheet -

“Te Mana o te Wai refers to the vital importance of water. When managing freshwater, it ensures the health and well-being of the water is protected and human health needs are provided for before enabling other uses of water. It expresses the special connection all New Zealanders have with freshwater. By protecting the health and well-being of our freshwater we protect the health and well-being of our people and environments. Through engagement and discussion, regional councils, communities and tangata whenua will determine how Te Mana o te Wai is applied locally in freshwater management. Te Mana o te Wai has been part of the National Policy Statement for Freshwater Management since 2014, though there are changes to how the concept is described and how it must be applied.”

The challenge MDC face is that local iwi other than Ngai Tahu have very limited resources to participate effectively in such consultation processes.

We have written to Pere and Hans with some follow up questions arising from our meeting and are currently waiting for their response.

Budyong, Don and Dave.

Here is a copy of the letter with the FOLLOW UP QUESTIONS sent to Pere and Hans on 09/11/2022.

Hi Pere and Hans,

Firstly we wish to thank you both for the opportunity to have our wide ranging discussion last week. We all found it very informative and useful and appreciated your openness and willingness to share your knowledge with us. We also appreciated that both of you have such a good big picture view of the world.

We have been putting together a report for CKM members on what we have learned but before we can complete it we are hoping you can give us clarification in writing on some points we are still unclear about. Our questions are in bold below.

Our understanding from the meeting is that it is likely after the pMEP appeals process that the existing level limits set in the Northern, Central and Urban sectors of the Wairau FMU will be removed.

We note on page 93 of the NOF it states -
"Take limits must:
• be expressed as a rule in the regional plan, and be set for every FMU
• achieve the flows and levels for an FMU. They should not allow flows or levels of water to fall below these.
• be expressed as a volume or rate of take, or both. For example: ‘No more than xx m3/s can be taken from this river from 1 November to 31 March’. Groundwater may be expressed as maximum annual volume taken.

Take limits must also:
• provide for flow or level variability that meets the needs of the water body from which the water is taken or diverted, and the needs of connected water bodies, and their associated ecosystems (eg, a groundwater take limit would not cause a permanent lowering of the groundwater levels, or reduce connected river flows below their environmental flow)"

1) Are we correct in thinking that the only likely limit for the whole Wairau Aquifer FMU will be a "maximum annual volume taken" as defined above?
2) Are we correct in assuming MDC believes the current annual limit of 73,006,000 M3 will "not cause a permanent lowering of the groundwater levels, or reduce connected river flows below their environmental flow"?

We understand the annual extraction limit in Appendix 6 was set when the pMEP was released in 2016. Subsequent information coming from the GBR research (in particular the isotopic research) has provided evidence that the reservoir volume is smaller than initially believed.
To quote from the report to the Environment Committee on Aug 29th, 2019.
"A new method has for the first time verified the age of Wairau Aquifer groundwater at less than 1 year meaning the reservoir volume is small.
This means that for the critical well levels and associated groundwater fed spring flows, the aquifer is never more than several months away from receding to MEP environmental thresholds."

If this assessment is correct, it raises another question for us.

3) Does this mean the annual extraction limit of 73,006,000 M3 set in 2016, before the isotopic research, might now need downward adjustment?

It seems to us that the need for an accurate assessment of the total volume of the aquifer is critical if we are considering having a regime where there are no level limits set in the aquifer and we rely on the annual volume limit as our only control on extraction.

4) How confident are we that our current assessment of the total aquifer volume is accurate?
5) What is the average total volume assessment?

It would be very helpful for us to know so we have an idea of what proportion 76,000,000 m3 is of the total available. We understand the concept of imagining the aquifer like a bucket where the level goes up and down. So, is it 5% of the bucket or 40% for instance? We realise this total will vary considerably for different times of the flood/drought cycle and that water is constantly flowing through the aquifer.
Our primary concern is in regard to what impacts there might be on the aquifer and its associated river and spring flows when we have aquifer water users taking their full allocations during an extended multi year drought that climate change projections indicate is becoming more likely. The emptier the bucket becomes the greater the impact will be from extracting 76,000,000 m3 annually.
We accept that the full allocation is not normally extracted each year but presumably we do need to imagine worse case scenarios.

Do we have accurate information at this point in time to inform us how empty the bucket might get in such a multi year drought scenario?
In other words would several years of removal of 76,000,000 m3/year, with annual recharge volumes lower than extraction and springs outflows combined, result in unacceptable lowering of the aquifer?
How can we meet the requirements of the NOF without having a clear definition of how empty the bucket can get before extraction is halted?

Thanks for your help. It is appreciated. Budyong, Dave and Don. (for CKM)

Response received from Pere Hawes on 22/11/2022.

Good morning Budyong, Dave and Donald.
 
Apologies for the delay in response. My team has had some Environment Court reporting timeframes that had to take priority.
 
It was a pleasure meeting with you all recently to discuss the Wairau Aquifer and its management.
 
I think the best way to respond to your questions is to not actually answer them at this point in time. That is not intended to be obstructive gents, but merely reflects that the Council is yet to make any decision with respect to the current PMEP take limit (or other limit) for the Wairau Aquifer. As described to you at our meeting, policy development is a process of navigation as we respond to new information and changing community expectations. We continue to work with our hydrology and ecology teams to better understand the dynamic nature of the recharge mechanism for the Wairau Aquifer. Until that work is complete, and we have greater certainty regarding the resilience of the aquifer, it is best not to formally speculate on possible management outcomes. I say this because we have a process to work through to implement the National Objectives Framework and that work also involves future engagement with tangata whenua iwi and the community. The feedback received through these processes will be influential in setting a management outcome for the Wairau Aquifer.
 
Similarly, in terms of the current limits for the Spring Sector, the appeals on these limits must go through a process of Court led mediation and we will not know the outcome of that process until well into the New Year.
 
I have forwarded your letter to Peter Davidson so that he is aware of the questions you pose. He may be able to answer some of the questions from a hydrology perspective. Peter, Hans and I understand the risks of relying upon a take limit for the Wairau Aquifer only and we will be considering the effectiveness and efficiency of other forms of limit as part of the process once the management objective is clear.
 
We did candidly describe possible trajectories for this work in person so that you got an appreciation of the complexity of the work we are undertaking and the implications for the resource, resource users and mauri/natural character of the water bodies.
 
Thank you for your ongoing interest in this topic and please keep in touch so that we can provide updates as the work progresses. Rest assured the questions that the CKM are asking are also the questions that we have.
 
Kind regards
 
Pere Hawes
Manager Environmental Policy
Marlborough District Council

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