Proposed changes to rules and regulations

About the draft material

The draft Plan for Otago is made up of proposed rules, regulations and policies for different activities, also known as 'chapters'. Please note the material on this web page about the new Land and Water Regional Plan (LWRP) has the status of draft.

The draft Plan is still being written and is yet to be completed and formally notified as the ‘proposed’ LWRP. The ‘proposed’ Plan will be available late 2024 when it is scheduled for ‘public notification’. On this web page, you will find information about the proposed rules and regulations that we are considering. We have received public feedback that let us know if people thought we were heading in the right direction before the ‘proposed’ LWRP is publicly notified.

The proposed new rules are designed to protect waterways for future generations.

If you are unsure of any particular terms in the below summaries, there is a glossary of terms.

Region-wide proposed new rules and regulations

The following proposed new rules and regulations for waterways would apply region-wide.

Click or tap on each section heading to expand and see the content.

Recent content updates:

26 September 2023:
- Added restricted discretionary criteria for use of existing structures that do not meet the permitted activity conditions
- Clarified how the Stock Exclusion Regulations 2020 apply to stock crossings.

The Beds of Lakes and Rivers chapter manages all works in, on, over or under the beds of lakes and rivers, including selected activities in the riparian margin (the strip of land that runs alongside a waterway). The activities captured include:

Use, maintenance, alteration or placement of flood protection and drainage infrastructure works
Use, maintenance, alteration, placement, and removal of structures in the bed
Bank reinstatement and reshaping of banks
Construction and maintenance of sediment traps
Reclamation, realignment, widening or deepening
Planting and removal of vegetation
Extraction of gravel
Other disturbances

The nature of works in the bed of lakes and rivers varies across the Otago region, as do the environments where those activities occur. The beds and margins of lakes and rivers in the region provide habitat for flora, fauna and valued mahika kai (food and resource gathering) and are an integral part of the natural character of the region.

This chapter does not manage damming and diversion in the bed, which is captured by the Damming and Diversion chapter.

Overview and key changes

The table below provides a high-level comparison of the operative Water Plan provisions with those included in the draft Beds of Lakes and Rivers chapter and highlights the key changes from the operative Water Plan.

Beds of Lakes and Rivers chapter of draft LWRP	Existing plan
Permitted activity framework
Key changes: Permitted activity rules capture similar activities, but have been refined to capture all associated disturbance, discharge, deposition, and land use requirements so that users do not need to consult multiple parts of the plan. Permitted activity criteria are similar to the Water Plan but have been simplified and aligned with other standard conditions in the LWRP. For example, conditions seek to ensure that: Activities do not cause erosion of the bed or banks Discharges comply with visual clarity standards after reasonable mixing No lawful water takes are adversely affected Sites are left in a tidy condition The roosting or nesting of indigenous birds is not disturbed Structures are not located within drinking water protection zones, habitats of threatened species, or outstanding water bodies (for some structures) and don’t interfere with existing navigation or legal public access There is no fuel storage or placement of hazardous substances on the bed If an archaeological site is unearthed, the accidental discovery protocol is applied There is no spread of pests. Use of existing structures are permitted if: They are lawfully established They are actively used If a change in use of the structure occurs, the effects of the new use are the same or similar in character, intensity, and scale as the preceding use They are maintained in a state of good repair They are not identified in an action plan as requiring remediation to provide for fish passage Any build-up of debris against the structure which may adversely affect flood risk, drainage capacity or bed or bank stability is removed as soon as practicable. If the activity does not comply with the above permitted activity conditions, a restricted discretionary activity will be required. ORC’s discretion will be restricted to the actual and potential environmental effects of not meeting the relevant conditions of the rule, the lapsing period and duration of the resource consent, review of the conditions of the resource consent, the need for a bond, and the collection, recording, monitoring, and provision of information about the exercise of the resource consent. Where possible, activities that are beneficial for water body health (for example sediment traps) will continue to be permitted if conditions are met. All suction dredge mining will require consent. No consent required for some bank reshaping (i.e., to repair flood damage). The new provision for bank reshaping makes it simpler to understand and provides greater clarity for how the activity should be completed. Stock crossing will be managed under the Stock Exclusion Regulations 2020. The person responsible must ensure that the stock are supervised and actively driven across the lake or wide river. This includes: not allowing stock closer than three meters from the edge of the bed of the lake or wide river unless the stock need to access the area to enter or exit a dedicated bridge or culvert. ensuring stock do not cross the same lake or wide river more than twice in any month.	The permitted activity rules are extensive, and provide a pathway for various types of activities in the beds of lakes and rivers, including: Use of structures Placement of small structures (e.g., lines, pipes, cables, fences), bridges and crossings Repair, maintenance, alteration, replacement, or reconstruction of structures Removal of structures Disturbance, discharge, and deposition associated with structures Bank reinstatement Vegetation planting and removal Sediment traps Gravel extraction Suction dredge mining Stock crossing.
General consenting requirements
Key changes: Activities that do not comply with permitted activity rules are generally classified as discretionary. Stronger policy guidance to inform decision-making on consent applications. This includes direction on: Recognising the value of structures and works in the bed where they provide for social and cultural well-being Providing for the disturbance of the bed of a lake or river in particular situations (e.g., where an activity maintains or enhances water quality, avoids works in water and discharges of sediment where practicable, avoids adverse effects on the health and well-being of water bodies and indigenous ecosystems, and avoids adverse effects on the integrity of nationally and regionally significant infrastructure and other lawfully established structures) Providing for the use, maintenance, alteration, replacement, and placement of structures in, on, under or over the bed of a lake or river in particular situations Matters to consider for resource consent applications for works in the bed of a lake or river or in a riparian margin Providing for flood protection and drainage infrastructure works where they maintain the integrity and function of existing flood protection and drainage infrastructure, maintain, or improve the flow carrying capacity of the river and do not induce erosion, unless this is intended for flood management purposes Matters to consider for resource consent applications for flood protection and drainage infrastructure works Avoiding the replacement or placement of hard protection structures in the bed of a lake or river unless they are for the purpose of maintaining or reducing the level of risk to people or communities, there are no other reasonable alternatives, and the placement would not result in an increase in risk to people and communities Encouraging works in the bed that provide for the restoration of lake or river extent and value Providing for the removal or planting of vegetation in particular situations Matters related to the maintenance of drains and modified water bodies Encouraging engagement with ORC prior to lodgment of any resource consent application to extract gravel and setting out the situations where extraction is provided for Improving the long-term management of Otago’s gravel resources Managing recovery from natural hazards Promoting activities that reduce the risk of exposure to natural hazards.	Most activities that do not comply with the permitted activity rules are classified as restricted discretionary. The matters of discretion are broad, and supporting policy direction is uncertain.
Flood protection and drainage infrastructure works
Key changes: Policy and rule pathways included that are specifically for flood protection and drainage infrastructure works undertaken by or on behalf of Council. Use and some maintenance of flood protection and drainage infrastructure works undertaken by persons other than Council is permitted (subject to similar conditions as outlined above for activities in beds). Any alteration, placement or replacement of flood protection and drainage infrastructure by or on behalf of Council requires consent.	No specific policy or rule direction for flood protection and drainage infrastructure works undertaken by or on behalf of ORC, so captured under general rule framework. Many works require consent.
Gravel extraction
Key changes: Reduced volume for permitted gravel extractions to 5 cubic metres in all rivers and lakes. Discretionary consent required for all other extractions. Clear policy direction on managing gravel extraction requiring: Extraction is not in areas where there is a deficit of gravel or where the activity may cause a deficit, and within a habitat of a threatened species The rate of extraction does not exceed the rate of gravel recharge, except where stored gravel is available for extraction Extraction does not cause or exacerbate erosion or instability and maintains or improves flood carrying capacity There is no processing of gravel in the bed The volume, extent and duration of the extraction is sustainable taking into account several factors Either the extraction is for the purpose of protecting or maintaining nationally or regionally significant infrastructure and local transport infrastructure that is in the bed and that there are no other reasonable alternatives to protect or maintain the nationally or regionally significant infrastructure or local transport infrastructure, or for flood hazard mitigation and it is undertaken by or on behalf of ORC exercising its powers under legislation in relation to flood control, or the application demonstrates the functional need and operational need for the extraction and that there are no other practical alternatives. Policy signalling development of catchment specific guidance and a Code of Practice which will describe good management practices for gravel extraction. This direction will be implemented by way of a future change to the Land and Water Regional Plan.	The permitted activity rule is very permissive and enables substantial gravel extraction for all rivers up to a volume of 20 cubic metres with no evidential basis for the volumes allowed. Limited policy direction to inform decision-making on consent applications for gravel extraction.

Damming and diversion manages dams, weirs, and diversions, including activities associated with their placement, maintenance, and removal. The activities captured include:

Damming and diversion of water
Placement, use, maintenance and removal of dams and weirs in the beds of lakes and rivers
Disturbance of the beds of lakes and rivers associated with dams and weirs
Discharge of water and contaminants associated with dams and weirs

Damming occurs throughout Otago for a range of purposes (such as providing drinking water, generating hydro-electric power, harvesting, and storing water, irrigation and treating stormwater). Dams in the region vary in size and age, and are in rivers, lakes, and wetlands (in-stream) and outside of these water bodies (off-stream). Weirs are also used to raise the level of water upstream or regulate its flow, and the diversion of water occurs in the region and involves redirecting the flow of water.

Overview and key changes

The table below provides a high-level comparison of the provisions of the operative Water Plan provisions with those included in the draft Damming and Diversion chapter and highlights the key changes from the operative Water Plan.

Damming and Diversion chapter of draft LWRP	Existing plan
Damming
Key changes: New definitions for different types of damming structures and activities that are aligned with national direction and the Building Act 2004. Separate rules for off-stream and in-stream dams and weirs. Separate rules for temporary and longer-term damming. Off-stream dams are permitted if: they are not classifiable dams they are not for the primary purpose of storing contaminants they are maintained in a state of good repair the water impounded by the dam is accounted for within a take limit they are not in a habitat of a threatened species, on contaminated land, or in an area with significant natural hazard risk they do not disturb roosting or nesting of indigenous birds they do not cause or exacerbate flooding, ponding, or erosion on any land or property owned or occupied by another person a map and as-built plans along with a producer statement are supplied to ORC within a one month of the construction of the dam if it impounds more than 1000 cubic metres of water. If the off-stream dam does not comply with the above permitted activity conditions, a discretionary consent will be required. Activities captured by the following rules include placement of the dam or weir, and any associated damming or diversion, use and disturbance of the bed of a lake or river, and discharge of water or contaminants into water. New temporary in-stream dams and weirs (in place for no longer than 30 days) are permitted if: for weirs, they are authorised under the National Environmental Standards for Freshwater (NES-F) they do not occur within an area where damming is prohibited (i.e., the same areas as the Water Plan where damming is prohibited by water conservation orders and legislation) the level of a lake or downstream flow of a river is not permanently reduced below an environmental flow or level as a result of the activity they do not frustrate or prevent the exercise of any lawful water take any bed disturbance does not cause erosion of the surrounding bed or banks any discharge complies with the visual clarity standards after reasonable mixing the passage of a desired fish species is not impeded they do not disturb the roosting or nesting of indigenous birds or occur in the habitat of a threatened species there is no fuel storage or placement of any hazardous substance on any part of the bed any plant, equipment, or machinery associated with the activity is free of pests the surrounding bed is returned as near as practicable to its original shape, area, depth, and gradient that existed prior to the works and the site is left tidy. If the temporary in-stream dam or weir does not comply with the above permitted activity conditions (except for where damming is prohibited), a discretionary consent will be required. New longer-term in-stream dams and weirs (in place for longer than 30 days) are a discretionary activity provided they are not located in an area where damming is prohibited. Activities captured by the following rules include use of the bed of a lake or river, damming or diversion of water and discharge of water or contaminants into water. Use of in-stream dams and weirs that existed on 1 July 2024 is permitted if: they are lawfully established and, for weirs, authorised under the NES-F they are maintained in a state of good repair they are not identified in an action plan as requiring remediation to provide for fish passage the volume of water impounded is less than 5,000 cubic metres the level of any lake or downstream flow in a river is not reduced below an environmental level or flow as a result of the activity. If the activity does not comply with the above permitted activity conditions, a discretionary consent will be required. Maintenance of lawfully established in-stream dams and weirs is permitted provided there is no increase in the volume of water impounded or the footprint of the dam or weir, and many of the same conditions as placement are met i.e., complying with environmental flows and levels, not affecting lawful water takes, not disturbing indigenous birds etc. If the activity is unable to comply with the permitted activity conditions, a discretionary consent will be required. Activities captured by the following rules include disturbance of the bed of a lake or river, discharge of water or contaminants, and damming or diversion associated with the removal. Removal of in-stream dams and weirs is permitted if: for a dam, it is not a classifiable dam where any part of the dam or weir remains in situ, nothing remains above the level of the bed there is no use of explosives it does not frustrate or prevent the exercise of a lawful water take it does not disturb the roosting or nesting of indigenous birds it does not occur in the habitat of threatened species it does not cause any permanent increase in the risk of flooding or erosion downstream it does not spread pests any discharge complies with the visual clarity standard after reasonable mixing there is no fuel storage or placement of any hazardous substance on any part of the bed the site is left tidy. Clear policy direction for restricting the construction of new in-stream dams and weirs but facilitating off-stream dams Clear policy direction on managing the effects of damming activities and recognising hydro-electricity generation.	Same rules apply to all damming activities regardless of location, type, or duration. Damming (whether or not it is off-stream or instream) is permitted if: the upstream catchment of the dam or weir is no greater than 50 hectares the water immediately upstream of the dam is no more than 3 metres deep and the volume of water stored by the dam is no more than 20,000 cubic metres no lawful water take is adversely affected any damming within a Regionally Significant Wetland was established prior to 2 July 2011 and does not damage fauna or native flora, or change its water levels / hydrological function no flooding of any other person’s property, erosion, land instability, sedimentation or property damage is caused it is not within the Waitaki catchment, or particular areas protected by water conservation orders and legislation. If the activity does not comply with the above permitted activity conditions, then consent is required (except where damming is prohibited). Activity status ranges from restricted discretionary to non-complying depending on what conditions can’t be met. Limited policy direction to guide the management of damming activities. Definitions are unclear. Provisions are not aligned with national direction and the Building Act 2004.
Diversion
Key changes: Definitions clarify that diverting water outside the bed of a water body, even if non-consumptive, is managed as a take and discharge of water rather than a diversion. Separate diversion rules supported by policy direction focusing on ensuring that fish passage is provided for, diversions are kept to the smallest practicable extent, and they have minor or transitory adverse effects on the environment. Diversion rules distinguish between diversions of water outside of the bed of a water body (e.g., to alleviate flooding) and those within a water body (e.g., to facilitate temporary works on a structure). Diversions where they occur fully outside of the bed of a lake or river are permitted if: they are for land drainage or alleviating flooding they are not on contaminated land they do not cause or exacerbate flooding, ponding or erosion of any land owned or occupied by another person they do not frustrate or prevent the exercise of any lawful water take they do not disturb the roosting or nesting of indigenous birds water levels or flows are not reduced in any aquifer, spring, river, lake, or natural inland wetland. Diversions within the bed of a lake or river are permitted if: they are not located in an area where diversions are prohibited, a habitat of a threatened species or the Waitaki catchment they are for enabling temporary works associated with a lawfully established structure, the protection, restoration, or enhancement of the ecosystem health, indigenous biodiversity, or hydrological functioning of water bodies, or maintaining the operation of lawfully established intake structures they are carried out completely within the bed of a lake or river they do not they do not cause or exacerbate flooding or erosion within any water body or property the level of any lake or downstream flow of any river is not reduced below an environmental level or flow they do not impede the passage of a desired fish species they do not disturb the roosting or nesting of indigenous birds they do not frustrate or prevent the exercise of any lawful water take the course of the water is returned to its natural course after completion of the activity, no later than one week after it occurs. If the activity does not comply with the above permitted activity conditions, a discretionary consent will be required (except where diversions are prohibited e.g., areas protected by water conservation orders or legislation and in Lake Tuakitoto as per the Water Plan).	Diversion rules bundled with damming rules. A diversion is permitted if: the size of the catchment upstream of the diversion is no greater than 50 hectares the water conveyed is from one part of any lake or river, or tributary, to another part of the same lake, river, or tributary no lawful take of water is adversely affected any diversion within a Regionally Significant Wetland was established prior to 2 July 2011 and the activity does not damage fauna or native flora, or change water levels or the hydrological function of a Regionally Significant Wetland no flooding of any other person’s property, erosion, land instability, sedimentation or property damage is caused the diversion is not within the Waitaki catchment, from Lake Tuakitoto at certain levels, or in particular areas protected by water conservation orders and legislation. Diversions for the purpose of land drainage are permitted if: the wetland conditions above are met the level of a lake or river is not lowered the diversion does not cause flooding of any other person’s property, erosion, land instability, sedimentation, or property damage. Diversions related to lawful structures are a permitted activity if: the wetland conditions above are met the course of the water remains in the bed of the water body and is returned to its normal course following completion of the activity no lawful take of water is adversely affected no erosion, land instability, sedimentation or property damage is caused. Diversion of water from water bodies not consistently managed as a ‘take of water.’
Associated activities
Key changes: All relevant activities associated with the damming or diversion of water; for example, disturbance of the bed of a lake or river, discharge of water or contaminants, and damming or diversion etc. are managed under the same rules in the DAM chapter and are permitted or consented along with the primary activity.	Multiple rules spread across different Water Plan chapters apply for various activities associated with damming and diversion e.g., structures, bed disturbance, discharges of water and contaminants etc.

Recent content updates:

2 November 2023:
- Updated definition of existing permitted activity rule.

The Earthworks and Drilling chapter manages the disturbance of land and associated discharges. Activities captured include:

Earthworks and sediment run-off
Drilling
Bores
Site investigations for contaminated land

These activities have previously been managed by the Regional Plan: Water for Otago (Water Plan). Plan Change 8 (Urban Topics), which was made operative on 3 September 2022, introduced new rules to the Water Plan for managing sediment from earthworks for residential development.

This chapter does not manage stormwater or discharges from contaminated land. These are covered in the Stormwater and Other Discharges chapters, respectively.

Overview and key changes

The table below provides a high-level comparison of the existing Water Plan provisions and the draft Earthworks and Drilling chapter and highlights the key changes from the Water Plan.

Overview of the chapter, and key changes

The table below provides a high-level comparison of the existing Water Plan provisions and the draft EARTH chapter and highlights the key changes from the Water Plan.

Earthworks and Drilling chapter of draft LWRP	Existing plan
Earthworks
The existing permitted activity rule for earthworks now applies to all earthworks. For earthworks to be permitted, they must not: remain unstabilised after completion occur on contaminated land, or in a path of overland flow or flood plain, or in a drinking water protection zone allow soil or debris to enter a water body, a drain, an artificial watercourse, or the coastal marine area result in flooding, erosion, land instability, ponding, subsidence, or property damage beyond the boundary result in an exceedance of the receiving water standards after reasonable mixing discharge a hazardous substance discharge into any natural wetland or water body identified in a plan as containing mahika kai, wāhi tūpuna (sites of significance to iwi), inanga spawning area or an outstanding natural feature or landscape. Additional to these permitted activity conditions, the following conditions apply to slope, area, and setbacks: On a slope of less than 10° up to 2,500m² of earthworks in any consecutive 12-month period are permitted if setback at least 10m from a water body, a drain, an artificial watercourse, or the coastal marine area. OR On a slope greater than 10° up to 2,500m² of earthworks in any consecutive 12-month period are permitted if setback at least 50m from a water body, a drain, an artificial watercourse, or the coastal marine area. OR Earthworks between 2500 m² and 10,000 m² in any consecutive 12-month period are permitted if on a slope less than 10° and setback 50m from a water body, a drain, an artificial watercourse, or the coastal marine area. The setback distances in the above rules do not apply to earthworks for riparian planting. If the earthworks do not comply with the above permitted activity conditions, a discretionary consent will be required and, if granted, will require best practice sediment control measures to be undertaken in accordance with an erosion and sediment control plan.	Rule framework for managing sediment discharges from residential construction only. Earthworks are permitted if: area of exposed earth is no more than 2,500m2 (in any 12-month period) earthworks do not occur within 10 metres of a water body, water race, drain or Coastal Marine Area (CMA) earthworks do not occur on contaminated land soil and debris are prevented from entering a water body, water race, drain or CMA the earthworks do not cause flooding, erosion, or land instability. If earthworks do not meet all of the conditions listed above, a discretionary consent is required.
Drilling
Key changes: The drilling of land for purposes other than the construction of a bore is permitted if the drilling: does not penetrate an aquifer is more than 10 metres from a wetland is not on contaminated land is above the water table complies with the NZS 4411:2001 Environmental Standard for Drilling of Soil and Rock. The drilling of a new bore, or drilling to alter or replace an existing bore, will require controlled consent, which will be granted if: the bore is not located in the bed of lake or river, within 10 metre of a natural inland wetland or on contaminated land the bore does not damage or destroy threatened species habitat or places of significance to mana whenua the drilling is in accordance with NZS 4411:2001 Environmental Standard for Drilling of Soil and Rock there is no mixing of water from different aquifers. ORC will be able to set consent conditions on the following matters: location depth management and maintenance requirements method of drilling consent duration, review, bond, and record keeping requirements.	The drilling of land for purposes other than the construction of a bore is permitted if the drilling: is not over a groundwater protection zone the hole is sealed on completion The drilling of a new bore requires consent as a controlled activity. ORC must grant consent but may impose conditions relating to: the location of the bore the depth of the bore the management of the bore head and maintenance of the bore the method of drilling or excavation.
Bores
The use of an existing bore is permitted if: The bore head is maintained in accordance with section 2.5 of NZS 4411:2001 Environmental Standard for Drilling of Rock and Soil and prevents the entry of contaminants, uncontrolled leakage, and the mixing of water from different aquifers the bore has a functioning backflow prevention device fitted to the bore head there are no hazardous substances located within 20 metres of the bore records of maintenance and repairs are submitted to council within 10 working days. If an existing bore does not comply with the conditions above, a controlled consent must be sought which may require the bore to be repaired or altered to ensure groundwater quality is protected.	The use of an existing bore is currently not managed by the Water Plan.
Site investigation
The new framework supports the identification and recording of contaminated land by allowing site investigations to occur if they comply with the Contaminated Land Management Guidelines No. 1: Reporting on Contaminated Sites in New Zealand, (Ministry for the Environment, 2021), and are reported to ORC within 2 months of completion.	The disturbance of land for a site investigation to assess concentrations of hazardous substances is currently not managed by the Water Plan.

Recent content updates:

26 September 2023:
- Added information about the 7-day mean annual low flow and default minimum flows and take limits for rivers
- Clarified the definition of landholding for take limits for aquifers
- Added information about the approach for determining stream depletion where groundwater and surface water are connected
- Clarified the definition of paper allocation
- Clarified the definition of “stacking” of permitted water takes.

The Environmental Flows, Levels and Limits chapter of the draft Land and Water Regional Plan manages:

The setting of water quantity limits such as environmental flows and levels and take limits for all freshwater bodies in Otago
All takes and uses of freshwater, including policy direction on:
- Community water supply
- Hydro-electric generation activities
- Temporary takes, including dewatering
- Efficiency of water take, conveyance and use
- Mixing of water and use of rivers for conveyance
- Takes for storage
- Taking from artificial water bodies
- Non-consumptive takes
- Group management of take and use activities
- Transfers of water permits
- Measuring of takes
- Consent duration

Overview and key changes

The table below provides a high-level comparison of the existing Water Plan and the draft Environmental Flows, Levels and Limits chapter and highlights key changes from the Water Plan. The Freshwater Management Unit (FMU) chapter summaries contain the specific environmental flows and levels and limits for water bodies contained within each FMU.

The level of impact of the changes from the existing plan to the draft LWRP will vary across FMU and rohe (areas) in Otago depending on the circumstances of allocation and water uses in different water bodies.

Environmental Flows, Levels and Limits chapter of draft LWRP	Existing plan
River catchments
Environmental flows and take limits set for all rivers according to the following: Rivers with low hydrological modification will have default minimum flows and take limits based on a percentage of the 7-day mean annual low flow (MALF). This regime applies to the vast majority of rivers in Otago. The 7-day MALF is a flow statistic that provides an indication of how low the flow gets in a typical year. The lowest flow for each year is averaged across recorded years to estimate the MALF (Mean Annual Low Flow). Flows were averaged across 7-days before calculating the minimum for each year. Default minimum flows and take limits are the following: a take limit of 20% of 7-day MALF and minimum flow of 90% of 7-day MALF for a river catchment with a mean flow of 5 m3/s or less; and a take limit of 30% of 7-day MALF and a minimum flow of 80% of 7-day MALF for catchments with a mean flow of greater than 5 m3/s.   Rivers with higher hydrological modification will have bespoke take limits and minimum flows in the plan, based on site specific information for those catchments. For some rivers, often characterised by low to moderate hydrological modification and a small number of consented takes, interim take limits and minimum flows will be set according to the default method above. These will be implemented through the resource consent replacement process. However, prior to this resource consent replacement process taking place Council will assess whether there is a need to set bespoke minimum flows and take limits for these rivers through a plan change process. Better policy direction around the setting of site-specific environmental flow conditions on consents (in the current planning framework referred to as ‘residual flows’) to protect locally present or downstream values.	The Water Plan only has minimum flows for a limited number of catchments, and the approach for determining take limits is complex. Most take limits and environmental flows have not been determined in accordance with the requirements of the NPS-FM and are not consistent with Te Mana o te Wai. The Water Plan only allows for the consideration of a narrow set of values (ecology and natural character) when setting ‘residual flows’ at the point of take.
Lakes
New consented takes, diversions, damming or discharges of water from natural lakes and their upper catchment will be a prohibited activity. Takes from lakes will generally be included within a single take limit that applies to the lake as well as the river catchment that the lake is part of. This is consistent with a holistic and integrated management approach (ki uta ki tai - mountains to sea). The exception is lakes where a specific take limit and/or minimum level has been set such as some instream artificial lakes (e.g. Lakes Dunstan, Roxburgh, Onslow, Mahinerangi), and two natural lakes (Whakatipu and Wānaka), and natural lakes with an upper catchment that is highly modified through hydro-electricity generation, for example Lake Waipōuri.	The Water Plan does not set take limits for lakes in Otago. The Water Plan only sets environmental levels for one lake (Lake Tuakitoto), although there have been some water levels set for some lakes (e.g., Lakes Hawea, Dunstan and Roxburgh) through consent processes.
Groundwater
Environmental levels and take limits are set for taking water from different types of aquifers: Some mapped aquifers, for which robust and up-to-date technical information is available will have bespoke take limits. Other mapped aquifers will have a default take limit based on 35% of MAR. For aquifers not identified/mapped (such as fractured rock aquifers), the take limit will be 5% of the estimated annual average rainfall accumulation on the relevant landholding. Landholding in this context means 1 or more parcels of land (whether or not they are contiguous) that are managed as a single operation. Manage the connection between groundwater and surface water by: Removing the “100 metre rule” in the Water Plan Providing a clear method for determining stream depletion that is consistent with best practice in other regions. Under the proposed approach applicants will be required to calculate the proportion of the take that constitutes water drawn from nearby surface water bodies. Where a high proportion of pumped groundwater comes from surface water (i.e. high “stream depletion”) the groundwater take will be allocated from within the take limit that applies to the surface water body. This new approach will be based on the actual calculated effect of the groundwater take on surface water flows, rather than on the calculated distance from the stream.	The Water Plan sets take limits for aquifers that include: tailored limits and restriction levels for a small number of aquifers; and default limits for other aquifers based on 50% of the Mean Annual Recharge (MAR). The mean annual recharge is a statistical value based on the past climate, aquifer hydrology, soil properties, and other factors with direct influence over groundwater recharge. The Water Plan manages the connection between rivers, lakes and aquifers through: a complex method of determining the stream depletion effects from groundwater takes; and arbitrary rules where groundwater takes located within 100 metres of a river or lake are 100% allocated as surface water (elsewhere on this page referred to as the “100 metre rule”).
Avoiding over-allocation
Policy direction will be to avoid taking of water in excess of take limits. Prohibited activity rule for all new takes in excess of take limits, which is consistent with the requirements of the NPSFM.	The Water Plan does not recognise over-allocation of surface water but adjusts take limits in highly allocated catchments to reflect consented takes. The Water Plan prohibits new surface water takes from fully allocated catchments but does not prohibit new takes from fully allocated or over-allocated aquifers.  Highly allocated catchments are catchments where the combined consented allocation exceeds the specified take limit in the operative Water Plan or the default take limit of 50% of 7-day MALF applied in that Plan.
Phasing out over-allocation
Key changes: In region-wide provisions, two stage approach to phasing out existing over-allocation will include policy direction and mandatory rule conditions for the replacement of consents in over-allocated water bodies: Stage 1: Upon reconsenting of existing takes, remove paper allocation (paper allocation is any quantity of water that is allocated under a resource consent but that exceeds the actual (recorded) rate of take or volume of water taken by the consent holder), limit the rate of take/volume to the lesser of historic take or the rate/volume required based on guidelines for efficient use. Short duration for Stage 1 replacement consents. The use of short-term consents aligns with the direction set in the Natural and Built Environment Act (NBEA) that will be phased in over the coming years. Stage 2 (where required): Proportional reductions for the catchment where any reductions in allocation under stage 1 prove insufficient to meet the default take limits in the LWRP, with ability to consider an alternative environmental flow and level regime for those currently subject to default regimes. River catchments with bespoke take limits may have different requirements under the 2-staged approach: Stage 1 will seek to reduce water use where possible by requiring efficient use and removing paper allocation. The plan will also require all water users to work together to develop plans for a catchment-wide approach for achieving the environmental flows, and for phasing out/avoiding over-allocation within the proposed Otago Regional Policy Statement (pORPS) timeframes for achieving the long-term visions for different FMUs and rohe. Stage 2 will see the delivery and execution of the plans set up in Stage 1. However, if by the end of Stage 1 no plans have been developed and agreed upon among consent holders, proportional reductions will be required under Stage 2.	The Water Plan has sinking lid policies to reduce allocation that partly rely on voluntary actions and is not likely to reduce the consented allocation to environmentally sustainable levels.
Different types of freshwater takes
Clear rules and policies for managing the effects from different types of takes. This includes providing pathways for non-consumptive takes, secondary takes (previously known as augmented takes) and takes from artificial water bodies (previously known as retakes). Policies and rules that provide for the consented taking of water at higher flows (for storage) and which consider ecological requirements to ensure water bodies are not ‘flat-lined’ or their ecological processes are not impeded.	The Water Plan provides some policy direction for augmented takes and identifies non-consumptive takes by definition but does not have a clear framework for managing different types of takes. The Water Plan does not set any restriction on the taking of water above mean flow.
Specific activities
Provide overarching policy direction to manage: Compliance with environmental flows and levels Efficiency of take, conveyance and use Mixing of water Provide policy guidance for specific activities, including: Collective management (irrigation schemes and water user groups) Community supplies Hydro-electricity generation Temporary takes Non-consumptive takes Transfers from one site to another	No directive policy guidance for specific activities
Efficiency considerations
Clear policy direction to ensure all water storage, conveyance, take and use is reasonable and efficient for its intended use. Policies and rules that that require and determine the reasonable and efficient rates of take and volumes for common uses including: Animal drinking water Domestic supply Dairy shed supply Frost fighting Irrigation Policy direction to encourage takes from resilient sources (main stems of river catchments, lakes and groundwater where further allocation remains available), in preference to takes from tributaries and over-allocated rivers.	Limited policy direction on how to consider efficiency when assessing an application for a water take
Integrated management and group management of water takes
Effects on water quality associated with takes for primary production captured by other direction in the LWRP, including in the provisions regarding Freshwater Farm Plans in the Primary Production chapter. For other uses of water applications to take and use water can consider the effects of the end use of water including water quality. Policy support for irrigation schemes and the use of water user groups for sharing water in times of low flows.	No policy direction on how water quality effects from the take and use of water must be considered when assessing applications to take and use water. Provides for the use of Water Allocation Committees and Water Management Groups to manage water takes where there are restrictions, but limited direction on how these committees and groups operate.
Consideration of applications
Set clear policy direction on considerations for take and use of water and transfers. In addition to the Water Metering Regulations, require metering of small, consented takes, discharges from hydro-electric schemes and ‘residual’ flows. Consent durations will be determined considering the following: Timeframes for achieving the visions in the proposed Regional Policy Statement The allocation status of the catchment and any degradation (including with respect to the water quality of the catchment) that may exist Any FMU or rohe expiry dates that may apply (proposed FMU and rohe consent expiry dates are in the area-specific summary documents). Maximum durations of 10 years are proposed, with some exceptions allowed for (e.g. water takes associated with regionally or nationally significant infrastructure)	Limited guidance on how applications are to be considered, minimum consent requirements, measuring requirements, lapse periods. The Water Plan has a transfer policy that provides limited guidance for managing of site-to-site transfers and is open to interpretation. There are no specific rules for transfers. A consent duration policy that led to an expectation of long-term (35 year) consent durations
Rule framework
Permitted activity pathways for: Small takes for domestic supply and stock water only (not for commercial or economic uses) Temporary takes, including dewatering and aquifer testing Takes from artificial sources (e.g., water races and storage reservoirs) Takes into instream dams to enable transition to a consent framework Permitted activity takes are scaled based on the size of the water body. Permitted activity conditions include: Restriction on taking when minimum flow or minimum level has been reached, except for reasonable domestic use; fish are prevented from entering the intake Direction around avoiding the “stacking” of permitted water takes. The stacking of water takes involves a person taking from multiple locations on the same waterbody and on the same property via multiple pathways such as under s 14(3)(b) of the Resource Management Act 1991 and the permitted activity and consenting framework in the Water Plan. A clearer and simple rule framework for all other activities (taking from surface water, lakes and groundwater) with enabling consent pathways where takes are within take limits and comply with environmental flows and levels, including a specific consent pathway for community water supply and site to site transfers.	Permissive permitted activity framework that can enable multiple taking where there are different sources (groundwater and surface water) and provisions that apply. Complex framework with distinctions in considerations between the different rules not obvious – there are many restricted discretionary activities with wide matters of restriction. New temporary framework of short-term consents for replacement water permits introduced in 2020 (PC 7). No rule framework for transfers – consents are processed under s136 of the Resource Management Act 1991

*Paper allocation is any quantity of water that is allocated under a resource consent but that exceeds the actual (recorded) rate of take or volume of water taken by the consent.

The Other Discharges chapter of the draft LWRP includes rules and provisions to effectively manage a range of specific discharges that do not neatly fit into other chapters in the plan. Discharges of contaminants and water into the environment (either directly to water or to land) can adversely affect the health of soils and water, as well as the health of the ecosystems they support.

Overview and key changes

The table below provides a high-level comparison of the existing Water and Waste Plan provisions with those included in the draft Other Discharges chapter and highlights the key changes from the status quo.

Other Discharges chapter of draft LWRP	Existing plan
Discharges of agrichemicals
Discharges of agrichemicals to land are permitted if they are: Approved under Hazardous Substances and New Organisms (HSNO) and used in accordance with the approval Not discharged within a drinking water protection zone or 20 metres of a river, lake, wetland, the coastal marine area, or any bore Undertaken in accordance with NZS8409:2021 Management of Agrichemicals. Discharges of agrichemicals to water are permitted if they: Are approved under HSNO, not classified as hazardous for aquatic environments, and used in accordance with the approval After reasonable mixing, meet specified receiving water standards Not discharged to a drinking water protection zone, mātaitai reserve, or taiāpure Are undertaken in accordance with NZS8409:2021 Management of Agrichemicals. If permitted activity conditions are not met, the discharge requires consent as a discretionary activity.	Discharges of agrichemicals (herbicides) to land are permitted if they are: Authorised for use in NZ and used in accordance with the authorisation Undertaken in accordance with any manufacturers’ directions For the purpose of controlling plants and the use does not exceed the quantity, concentration or rate required Reasonable measures are undertaken to minimise direct discharges to water bodies, drains, water races and the coastal marine area Do not adversely affect lawful takes of water One week prior, dischargers notify people taking water for domestic supply and consent holders for water takes within one kilometre of the discharge, and the community via public notice where any discharge will occur into a river, lake, or Regionally Significant Wetland Do not damage fauna or native flora in any Regionally Significant Wetland. Discharges of agrichemicals (herbicides) to water are permitted if they are: Authorised for use in NZ and used in accordance with the authorisation Undertaken in accordance with any manufacturers’ directions and carried out by a person who holds a GROWSAFE Registered Chemical Applicator certificate Applied in gel form For the purpose of controlling aquatic plants and the use does not exceed the quantity, concentration or rate required Do not adversely affect lawful takes of water One week prior, dischargers notify people taking water for domestic supply and consent holders for water takes within one kilometre of the discharge, and the community via public notice where any discharge will occur into a river, lake, or Regionally Significant Wetland. If permitted activity conditions are not met, the discharge requires consent as a discretionary activity.
Discharges of vertebrate toxic agents (pesticides)
Does not manage discharges of brodifacoum, rotenone, or sodium fluoroacetate (1080) as these are managed by the Resource Management (Exemption) Regulations 2017 Discharges of vertebrate toxic agents to land are permitted if they: Approved under HSNO and used in accordance with the approval Not discharged within a drinking water protection zone or 20 metres of a river, lake, the coastal marine area, or any bore Undertaken in accordance with manufacturer’s directions. Discharges to water, and discharges to land that do not meet the permitted activity conditions, require consent as a discretionary activity.	Does not recognise that some discharges are managed under the Resource Management (Exemption) Regulations 2017 Discharges of vertebrate toxic agents (pesticides) to land are permitted if they are: Authorised for use in NZ and used in accordance with the authorisation Undertaken in accordance with any manufacturers’ directions For the purpose of controlling animals, plants or other organisms and the use does not exceed the quantity, concentration or rate required Not discharged to water bodies, drains, water races or the coastal marine area Do not damage fauna or native flora in any Regionally Significant Wetland. Discharges to water, and discharges to land that do not meet the permitted activity conditions, require consent as a discretionary activity.
Dust suppressants
Discharges of dust suppressants to land are permitted if they meet the same conditions as the current rule, except that the controls on visual changes in the receiving water is replaced with a condition requiring the discharge to be: Not within a drinking water protection zone Not within 20 metres of a lake, river, coastal marine area, or a bore. Discharges to land that do not comply with the conditions above, and are not of waste oil, are managed the same way as the Waste Plan Discharges to water are a discretionary activity, addressing a gap in the Waste Plan provisions Discharges of waste oil to land or water continue to be prohibited.	Under the Waste Plan, discharges of dust suppressants to land are permitted if: They are not a hazardous substance (including waste oil) They are approved under HSNO and used in accordance with the approval. They do not produce an objectionable odour, conspicuous oil or grease film, scum, or foam in any surface water body They do not result in ponding or overland flow. Discharges to land that do not meet the conditions above and do not contain waste oil require consent as a discretionary activity Discharges of waste oil to land or water are prohibited.
Tracer dye
Discharges of tracer dye to water are a controlled activity if they: Are not a hazardous substance Are approved under HSNO, not classified as hazardous for aquatic environments, and used in accordance with the approval After reasonable mixing, meet specified receiving water standards Not discharged to a drinking water protection zone, mātaitai reserve, or taiāpure. The Council’s control is limited to: Volume, type, and concentration of the dye Timing, duration, and method of discharge Any notification requirements. If the controlled activity conditions are not met, the discharge requires consent as a discretionary activity.	Discharges of tracer dye to water are a controlled activity if they are chemically inert, non-radioactive, and non-toxic The Council’s control is limited to: Adverse effects on identified natural and human use values, natural character, and amenity values of any affected water bodies Adverse effects on existing lawful takes Location, timing, and nature of the discharge Duration, information, monitoring, and bond requirements, and review conditions. If the controlled activity conditions are not met, the discharge requires consent as a discretionary activity.
Discharges of swimming and spa pool water
Discharges of swimming or spa pool water to land are permitted if: The water has not been treated with chemicals in the 14 days prior to discharge The water does not contain disinfectants, antiseptics, residual flocculants, sodium chloride more than 3500 grams per cubic metre, or residual chlorine or bromine above detection levels The discharge is not within a drinking water protection zone or 20 metres of a river, lake, the coastal marine area, or any bore Filter backwash does not enter a reticulated stormwater network Prior to discharge, the temperature of the water is ambient The discharge does not cause flooding, erosion, land instability, sedimentation, or property damage, or result in ponding or overland flow. Discharges to water, and discharges to land that do not meet the conditions above, require consent as a discretionary activity.	Discharges of swimming pool water to water or to land are permitted if: The discharge does not contain faecal coliforms at greater concentrations than that of the receiving water, or that would cause the receiving water to exceed 150 CFU* per 100 millilitres (after reasonable mixing) *CFU stands for Colony Forming Units. A colony-forming unit is where a colony of microbes grow from one single microbe. It is a measuring method that allows a scientist to examine a sample under a microscope and count the number of viable bacteria in a 100ml sample of water. The water does not contain disinfectants, antiseptics, pesticides, residual flocculants (except for aluminium at acid-soluble aluminium concentrations less than 0.1 grams per cubic metre), or free or residual chlorine at the point the discharge enters any surface water body or mean high water springs, human sewage, or any hazardous substances The discharge does not, after reasonable mixing: increase the temperature of the receiving water by more than 3 degrees Celsius, and does not cause the temperature of the receiving water to be above 25 degrees Celsius increase the suspended solids levels in the receiving water by more than 10 grams per cubic metre change the pH of the receiving water by more than 0.5 pH units give rise to any significant adverse effect on aquatic life. The discharge does not cause flooding of any other person’s property, erosion, land instability, sedimentation, or property damage There is no change to the water level range or hydrological function of any Regionally Significant Wetland There is no damage to fauna, or New Zealand native flora, in or on any Regionally Significant Wetland. If permitted activity conditions are not met, the discharge requires consent as a discretionary activity.
Discharges from water treatment and filter backwash
Discharges from the purging of instruments used in water treatment, the use of portable potable water treatment units, or filter backwash to land are permitted if they: Do not enter a reticulated stormwater network Are not within a drinking water protection zone or 20 metres of a river, lake, the coastal marine area, or any bore Do not exceed 3 cubic metres per day Do not contain a chlorine concentration of more than 2 milligrams per litre Have a pH measurement of between 6 and 8 Do not cause flooding, erosion, land instability, sedimentation, or property damage, or result in ponding or overland flow. Discharges to water, and discharges to land that do not meet the conditions above, required consent as a discretionary activity.	Not specifically managed under the Water or Waste Plans. If the discharge contains a hazardous substance, it will require consent as a discretionary activity. Otherwise, the discharge will be managed under the catch-all rules (discussed below).
Discharges from emergency firefighting training
Discharges to land or water as a result of fire training activities undertaken by Fire and Emergency NZ (FENZ) are permitted if: They do not occur for more than 2 continuous hours in a 24-hour period. The discharge is not onto the same area of land more frequently than once every three months. The person undertaking the discharge must be an employee or volunteer of FENZ. FENZ maintains a register with locations and dates of discharges. It does not cause flooding, erosion, land instability, sedimentation, or property damage, or result in ponding or overland flow. Discharges that do not meet the conditions above require consent as a restricted discretionary activity. The Council’s discretion is limited to: Volume, type, and concentration of the dye Timing, duration, and method of discharge, Any notification requirements.	Not specifically managed under the Water or Waste Plans. If the discharge contains a hazardous substance, it will require consent as a discretionary activity. Otherwise, the discharge will be managed under the catch-all rules (discussed below).
Discharges of water used for holding live organisms
Discharges of water and contaminants used for holding live organisms to water or to land are permitted if: They do not contain any pests, unwanted organisms, or hazardous substances They will not introduce live aquatic life to a water body where the species is not already present or increase the population of an undesirable fish species If the discharge is to water, it complies with specified receiving water standards after reasonable mixing and is not within a drinking water protection zone, mātaitai reserve, or taiāpure (a coastal fishing area of special significance to iwi) If the discharge is to land, it is not within a drinking water protection zone, or 20 metres of a lake, river, the coastal marine area, or a bore It does not cause flooding, erosion, land instability, sedimentation, or property damage, or result in ponding or overland flow. Discharges that do not meet the conditions above require consent as a discretionary activity.	Discharges of water used for holding live organisms to water or to land are permitted if: There is no change to the water level range or hydrological function of any Regionally Significant Wetland There is no damage to fauna, or New Zealand native flora, in or on any Regionally Significant Wetland No contaminant has been added that is toxic to the aquatic life of the receiving water body The discharge does not contain pest plant material (as identified in the Pest Management Strategy for Otago 2001) The discharge does not increase the natural temperature of the receiving waters, after reasonable mixing, by more than 3 degrees Celsius, and does not cause the temperature of the receiving water, after reasonable mixing, to rise above 25 degrees Celsius The discharge does not increase the suspended solids levels in the receiving water, after reasonable mixing, by more than 10 grams per cubic metre The discharge does not, after reasonable mixing, give rise to any significant adverse effect on aquatic life The discharge does not cause flooding of any other person’s property, erosion, land instability, sedimentation, or property damage. Discharges that do not meet the conditions above require consent as a discretionary activity.
Passive discharges from contaminated land
Passive discharges from contaminated land (including closed landfills) to land are a controlled activity if: A site investigation report has been provided to the Council Either the site investigation report or water quality sampling shows that groundwater meets the Drinking Water Standards for NZ, the Australia and NZ Guidelines for Fresh and Marine Water Quality at the level of 90% protection of species, and for concentrations of petroleum hydrocarbons the Guidelines for Assessing and managing Petroleum Hydrocarbon Contaminated Sites in NZ At any point where groundwater exits to surface water, the discharge does not produce any conspicuous oil or grease films, scums, foams, floatable or suspended materials, or change in visual clarity. The Council’s control is limited to: The need for remediation Monitoring, including methodology and frequency Methods to prevent land disturbance or other activity that may increase the potential for contaminants to be discharged from the site The need for, and contents, adequacy and implementation of a remedial action plan, site management plan, validation report, and/or an ongoing site management plan prepared in accordance with Contaminated Land Management Guidelines No. 1: Reporting on Contaminated Sites in New Zealand For closed landfills, the extent to which monitoring is consistent with A Guide for the Management of Closing and Closed Landfills in New Zealand. Discharges that do not meet the conditions above require consent as a discretionary activity.	Not managed under the Water or Waste Plans.
Cemeteries
Use of land for a cemetery that is closed or operating on 30 June 2024 and any associated discharge to water or land is a permitted activity Use of land for a new cemetery or part of a cemetery not operating on 30 June 2024, and any associated discharge to land, is a permitted activity if the land is not: At risk from coastal erosion or frequent flooding Within 100 metres of a water body, the coastal marine area, or a bore Within a drinking water protection zone Less than 3 metres above groundwater On contaminated or potentially contaminated land Significant to mana whenua. The use of land and associated discharge that does not comply with the conditions above requires consent as a discretionary activity.	Not managed under the Water or Waste Plans.
Major hazard facilities
Use of land for a major hazard facility (as defined in HSNO) is a controlled activity if: It is a lower tier major hazard facility It is not within 100 metres of a water body, artificial watercourse, or the coastal marine area It is not within a drinking water protection zone It is not within 50 metres of a bore A management plan for preventing the unauthorised discharge of contaminants to land or water is prepared and implemented. The Council’s control is restricted to: The location of the facility, including in relation to water bodies and coastal water The quality, content, and implementation of the management plan. The use of land that does not comply with the conditions above requires consent as a discretionary activity.	Use of land for the operation of facilities for the treatment or disposal of hazardous wastes and any associated discharge to land or water is a discretionary activity This overlaps with HSNO functions.
Discharges not managed elsewhere
Unless managed elsewhere, discharges to land or water are permitted if they: Do not contain any hazardous substances, pests, pest agents, unwanted organisms, or organisms of interest Do not introduce live aquatic life to a water body where the species is not already present or increase the population of an undesirable fish species Do not alter the natural course of a water body or its bed or change the water level range or hydrological function of a natural inland wetland Do not cause flooding, erosion, land instability, sedimentation, or property damage, or result in ponding or overland flow Are not from or into contaminated land or directly into groundwater If the discharge is to water, it complies with the receiving water standards after reasonable mixing and is not within a drinking water protection zone, mātaitai reserve, or taiāpure If the discharge is to land, it is not within a drinking water protection zone or 20 metres of a lake, river, coastal marine area, or a bore. Discharges to land or water that do not comply with the conditions above require consent as a discretionary activity.	Unless managed elsewhere, discharges to land or water are permitted if they: Do not result in flooding, erosion, land instability or property damage Do not discharge water from one catchment to water in another catchment Do not change the water level range or hydrological function of any Regionally Significant Wetland If the discharge enters water in any lake, river, wetland or the coastal marine area (or enters a water race or drain that goes to those waters), the discharge does not result in a conspicuous change in colour or visual clarity, or a noticeable increase in local sedimentation, does not have floatable or suspended organic materials and does not have an odour, oil or grease film, scum or foam From 1 April 2026, if water flows fall below the reference flow, the discharge does not exceed specified discharge thresholds. Discharges to land or water that do not comply with the above conditions above require resource consent as a restricted discretionary activity if they are: Not otherwise prohibited Only for a period of up to five years Do not result in flooding, erosion, land instability or property damage Do not discharge water from one catchment to water in another catchment Do not change the water level range or hydrological function of any Regionally Significant Wetland Not previously authorised under the rule. The Council’s discretion is limited to the nature, type, volume, frequency, and location of the discharge; the concentration and loading of contaminants in the discharge; the staged timeframe for meeting the permitted activity conditions, and a wide range of adverse effects associated with the discharge Discharges to land or water that do not comply with the conditions above require consent as a discretionary activity unless they are prohibited Discharges to water that produce an objectionable odour, or a conspicuous oil or grease film, scum, or foam in any lake, river, or Regionally Significant Wetland; or drain or water race that flows to a lake, river, Regionally Significant Wetland, or coastal marine area; or bore or soak hole are prohibited activities.

Recent content updates:

5 October 2023:
- Added definition for Feedlot
- Added definition for Sacrifice paddock
- Added definition for Stockholding area
26 September 2023:
- Added examples for feedlot construction standards, types of agricultural waste and types of waste able to be disposed of in farm landfills.

Some farming activities and practices are currently managed under the provisions of the operative Regional Plan: Water for Otago (the Water Plan), although a small number of farming activities (e.g., silage, offal pits and farm landfills) are also managed under the Regional Plan: Waste for Otago (Waste Plan).

The Primary Production chapter of the draft Land and Water Regional Plan manages farming activities and practices that are likely to impact water quality, and the planting of forestry, and includes:

A range of farming land uses that have the potential to cause adverse effects on water quality
A policy framework for freshwater farm plans
A policy and rule framework for managing the planting of plantation and permanent forestry

The provisions covered in the above are proposed to be region-wide.

Different tools for different places

The nature of farming activity varies widely across the Otago region, as do the environments within which those activities occur. Therefore, the draft LWRP also contains a suite of tools that may be applied depending on the need for reductions of different contaminants and the timeframe within which those reductions need to be applied. These are proposed to be applied at an FMU/rohe level and the time frames are set by the environmental outcomes for each FMU. This is covered in the FMU/rohe chapters below. The FMU/rohe summaries and this summary should be read together.

Some discharges that may be associated with farming activities (such as discharges of agrichemicals or sediment discharges from earthworks) are not managed in this chapter. They are addressed in the Earthworks and Drilling and Other Discharges chapters respectively.

Freshwater farm plans

A freshwater farm plan is a new tool introduced in the Government’s Essential Freshwater package, to help reduce impacts on freshwater. Freshwater farm plans are certified plans that help farmers figure out how well they are doing in keeping water clean and the land healthy. Each farmer will make a plan that says what steps they will take to identify, manage and reduce any adverse impact of farming on the freshwater environment.

Overview and key changes

The table below provides a high-level comparison of the provisions of the operative Water and Waste Plans with the provisions in the Primary Production chapter of the draft LWRP and highlights the key changes from the Water and Waste Plans.

Primary Production chapter of draft LWRP

Existing plan

Permitted activity framework

The provisions for effluent storage and application (introduced as a result of PC8) are carried over from the operative Water Plan.

New rules permit the use of land and associated discharges for:

Feedlots, feed pads and stockholding areas – subject to conditions, including;
- 50 metre setback from a wetland, the Coastal Marine Area (CMA), or the bed of a lake or river; and
- 20 metre setback from a bore or soak hole; and
- Not within a critical source area (CSA), above subsurface drainage or in a drinking water protection zone; and
- Standards for construction, e.g. for smaller/young cattle a base of 400mm of bark, woodchip or similar material and for older/larger cattle, sealed and effluent collected and disposed of in accordance with effluent rules.

Sacrifice paddocks – subject to conditions, including:
- Restrictions on slope (10 degrees or less), time used (max. 60 days per year) and size (5 hectares for landholdings less than 500 hectares or 1% or 30 hectares for landholdings greater than 500 hectares, whichever is lesser)
- Not within a critical source area (CSA) or in forage crop
- 20 metre setback from a wetland, open drain, bore, soak hole, CMA, or bed of lake or river
- 50 metre setback from sensitive water bodies (including outstanding water body)
- Requirement to revegetate as soon as practicable (where significant de-vegetation has occurred)

Paddocks used for pasture-based wintering – subject to conditions, including:
- Not within a critical source area (CSA)
- 10 metre setback from wetland, open drain, bore, soak hole, CMA, or bed of lake or river
  20 metre setback from sensitive water bodies (including outstanding water body)
- Requirement to revegetate as soon as practicable (where significant de-vegetation has occurred)

Silage storage, offal pits – subject to conditions, including:

Either a 250 cubic metre or 500 cubic metre volume restriction (silage only)
Preventing liquid from the activity entering a surface water body (silage only)
Preventing animal access
Preventing rain (silage only) and surface runoff entering the pit or stack
50 metre setback from wetland, open drain, bore, soak hole, CMA, or bed of lake or river
Not in drinking water protection zone, CSA or flood prone area.

Farm landfills:
- Where no local authority collection is available, and the landholding is more than 50 kilometres from the nearest transfer station
- Landholding is greater than 20 hectares
- Maximum volume of the pit is 50 cubic metres
- Preventing surface runoff entering the pit
- Restrictions on type of refuse discharged, e.g. must be from the property the pit is located on and not include agrichemicals (or their containers), agricultural plastic wrap, septic tank sludge, dairy farm sludge or animal carcasses
- Setbacks from wetland, open drain, bore, soak hole, CMA, or bed of lake or river (50 metres for farm landfills, 20 metres for discharge of agricultural waste)
- Not in drinking water protection zone, CSA
- Pit is covered over to a depth of 0.5 metres when no longer in use.

Agricultural Waste:

- Restrictions on type of waste discharged, e.g. must not contain any hazardous substance or any waste from a human effluent treatment process
- Application depth of less than 50 millimetres
- Setbacks from wetland, open drain, bore, soak hole, CMA, or bed of lake or river (50 metres for farm landfills, 20 metres for discharge of agricultural waste)
- Not in drinking water protection zone, CSA.

Strengthened permitted activity rule for the discharge of fertiliser – subject to conditions, including:

- No direct discharge into wetland, open drain, bore, soak hole, CMA, lake or river
- No discharge when soil moisture exceeds field capacity
- 3 metre setback from bed of lake or river or wetland.

Restrict intensification of land use:

- Discretionary consent required for conversion to a higher intensity land use (only granting consent where it will result in a decrease to the contaminant loads in the catchment) including:
- Consent required for conversion to dairy farm or dairy support land;

- Consent required for conversion of forestry land to pastoral land use;
- Consent required for increase in area of land irrigated.

Historically there are no land use provisions in the Water Plan managing farming activities, meaning these activities have been permitted activities in accordance with section 9 of the RMA. Any discharges associated with these activities are managed by the general discharge provisions in section 12 of the Plan.

Plan Change 8 (PC8) introduced a suite of rules managing animal effluent storage and application to land. The management framework seeks to permit existing facilities that meet good practice standards or are lower risk to the environment and require resource consent for others. It requires resource consents for discharges of liquid animal effluent to land. The implementation of these provisions is staged over a three-year period that commenced in June 2022.

Some farming activities, silage, offal pits and farm landfills, are also managed through the Waste Plan. The permitted activity conditions for these activities are out of date and do not align with current good management practice.

General consenting requirements

PC8 provisions being carried over.

If permitted activity conditions cannot be met, the activity requires a discretionary consent, with stronger policy guidance to inform consent applications.

Where they do not comply with the permitted activity rules, most activities are classified as restricted discretionary. The matters of discretion are broad, and supporting policy direction is uncertain.

PC8 has a controlled activity status for the construction, use and maintenance of animal effluent storage facilities provided conditions are met. If conditions cannot be met, the activity is discretionary. All discharges of animal effluent will be restricted discretionary, once the timeframes in Appendix 19 have been reached and all animal effluent storage facilities are either permitted or consented.

Freshwater Farm Plans

Clear policy direction to ensure that the actions proposed in FWFPs are focussed on meeting desired environmental outcomes.

Permitted activity pathway that allows for the effects of some activities to be managed in accordance with certified FWFPs as an alternative to a consenting pathway.

These activities include:

feedlots and stockholding areas
sacrifice paddocks
pasture based wintering

Some information requirements, in addition to the FWFP actions plans, to be submitted to Council. Information to be provided includes stocking rate, area of arable farming and crop type, fertiliser use, imported supplementary feed utilised, effective farming area, outputs from the nutrient budget or nutrient risk assessment, area of intensive winter grazing, duration of intensive winter grazing, crop type and stocking rate, and area of pasture wintering, stocking rate and kgs per hectare DM of supplementary feed.

Freshwater Farm Plans (FWFP) are not included in the Water Plan.

Planting of plantation and permanent forestry

Any existing Water Plan provisions that are more stringent than the NES-PF will be retained. This stringency relates to the management of discharges to water, and some works in the bed of lakes, rivers and wetlands.

Plantation forestry will be a permitted activity where it is less than 10 hectares in area, and the setbacks below are met:

	Slope < 10 degrees	Slope > 10 degrees
River	20 metres	50 metres
Lake	20 metres	50 metres
Wetland	20 metres	50 metres
CMA	50 metres	100 metres

Permanent forestry will be a permitted activity where only indigenous species are planted, and the setbacks below are met:

	Slope < 10 degrees	Slope > 10 degrees
River	20 metres	50 metres
Lake	20 metres	50 metres
Wetland	20 metres	50 metres
CMA	50 metres	100 metres

Where a resource consent is required for plantation or permanent forestry, it is typically a restricted discretionary activity and the matters for discretion include effects on water quantity, effects on water quality, management of wilding trees, and effects on freshwater and freshwater ecosystems.

It is anticipated that most exotic forestry planting will require resource consent, while indigenous forestry is enabled.

The operative Water Plan does not currently contain specific provisions for the management of the planting of plantation or permanent forestry. However, there are some rules or conditions of rules in the operative Water Plan (rules for managing discharge to water) that apply in addition to the National Environmental Standard for Plantation Forestry (NES-PF).

The NES-PF manages the planting of plantation forestry, but the setbacks to water bodies are relatively small (5-10 metres for rivers and wetlands, 30 metres for the coastal marine area), and there is no consideration of effects on water quantity where a resource consent is required.

The Stormwater Management chapter manages discharges of stormwater: rainwater and meltwater runoff from surfaces such as roofs, driveways, carparks, and roads. Urban areas, with numerous buildings and paved surfaces, face challenges because the water cannot permeate the ground, leading to potential flooding and contamination of the receiving environment – rivers, lakes, and the sea.

The chapter manages discharges from:

Reticulated stormwater networks; and
Non-network stormwater discharges.

These discharges have previously been managed by the Regional Plan: Water for Otago (Water Plan). Plan Change 8 (operative from 9 July 2022) improved the policy direction for stormwater by requiring progressive reduction of sewage overflows in stormwater, and measures to control the quantity and quality of stormwater to reflect current best practice, to contribute towards improving water quality in the Otago Region.

This chapter does not manage stormwater from construction and earthworks, which is managed in the Earthworks chapter.

Overview and key changes

The table below provides a high-level comparison of the existing Water Plan provisions with those included in the draft Stormwater chapter and highlights the key changes from the Water Plan.

Stormwater chapter of draft LWRP	Existing plan
Network discharges
Key changes: Owners/operators of reticulated stormwater systems will require a 5-year consent [controlled] to continue discharging stormwater from an existing reticulated system into water Owner/operators of reticulated stormwater systems will have 5 years to map their network and put in place a monitoring programme before applying for a network consent [discretionary] Network consent conditions will require progressive network upgrades until water quality outcomes are met, as a matter of discretion Network consent conditions will require a stormwater management plan to manage the quality and quantity of stormwater being discharged, as a matter of discretion.	It is permitted to discharge stormwater from a reticulated system to water, if: There is no sewage in the stormwater The discharge is not into a wetland The discharge does not cause flooding The discharge does not cause significant visual pollution.
Non-network discharges
Key changes: New rule framework will capture non-network discharges from roads, carparks, roofs, and any other modified surface The first permitted activity condition is that stormwater discharges must be connected to a stormwater network if there is one available Stormwater discharges are permitted if they do not cause flooding come from contaminated land occur in a drinking water protection zone come from land used for industrial or commercial activities exceed quality requirements Stormwater discharges which do not meet the permitted activity conditions above will require a discretionary consent.	It is permitted to discharge stormwater from a road which is not connected to a stormwater system, if: the discharge does not cause flooding, erosion, or property damage the discharge does not cause significant visual pollution.

Overview

The threatened species topic:

manages the effects of activities on the habitats of threatened species
applies the National Objectives Framework to the threatened species compulsory value

The Otago region has a rich and varied freshwater biodiversity. Some of this biodiversity has been lost or degraded due to adverse effects from introduced species, human activities, and ongoing resource use and development. Many of Otago’s freshwater species are threatened with extinction, and little is known of their habitats, threats, distributions, and the actions needed to recover from the threat of extinction.

Threatened species of Otago

The NPS-FM 2020 defines threatened species to mean any indigenous species of flora or fauna that:

relies on water bodies for at least part of its life cycle; and
meets the criteria for nationally critical, nationally endangered, or nationally vulnerable species in the New Zealand Threat Classification System Manual.

Regional councils are required to:

identify the location of habitats of threatened species in regional plans.
set an environmental outcome for threatened species in each FMU and include the outcome as an objective in the plan. The objective must be such that the effectiveness of regional policy statements and plans can be assessed against it; and
when achieved, fulfil relevant long-term visions set for the region.
identify attributes relevant to achieving the outcome, set targets for those attributes and identify how the outcome and target states will be achieved. This may include rules in regional plans, methods in action plans, methods in regional pest management plans, or some combination of these.

The LWRP will protect threatened species and their habitats by:

ensuring that to the greatest extent practicable, the temporary or permanent fragmentation, reduction in size, or degradation of the ecological integrity of the habitats of threatened species is avoided; and
manage adverse effects on threatened species and their habitats by applying the effects management hierarchy (in relation to indigenous biodiversity).
continuing to gather information on the threats and habitats to threatened species, including by mapping habitats.

For the LWRP, a list of 140 candidate species were assessed against the threatened species definition and refined to a list of 78 species of threatened species. The 78 threatened species include plants, fish, birds, a bat, and invertebrates that are reliant on water bodies in Otago and are listed below.

You can also see the locations of threatened species in the map below. You can zoom in and view the various threatened species in an Otago area(s).

The areas with threatened species are depicted in a orange-like colour.

When you have zoomed in and selected an area, threatened species information will appear.

if browsing from a mobile device, after zooming in and selecting an area, select the box icon (next to the 'X' icon) to view the species in the area.

iFrames are not supported on this page.

Threatened freshwater-dependent species of Otago:

Scientific name	Common name(s)
Plants
Althenia bilocularis
Amphibromus fluitans	Water brome
Brachyscome linearis
Cardamine mutabilis
Carex capillacea	Sedge
Carex cirrhosa	Curly Sedge
Carex rubicunda	Sedge
Carex strictissima	Bastard grass, hook sedge
Chaerophyllum colensoi var. delicatulum (CHR 73872; Hauhungaroa Range)	mountain myrrh
Chenopodium detestans	New Zealand fish-guts plant
Coprosma obconica
Crassula multicaulis
Crassula peduncularis
Eryngium vesiculosum	Sea holly, coastal eryngo
Euchiton ensifer	Creeping Cudweed
Gratiola concinna
Hypericum rubicundulum
Juncus pauciflorus	leafless rush
Korthalsella salicornioides	Mistletoe, dwarf mistletoe, leafless mistletoe
Lagenophora montana	papataniwha
Leptospermum scoparium var. scoparium	manuka, tea tree, kahikatoa
Libertia peregrinans	New Zealand iris, mikoikoi
Lophomyrtus obcordata	Rohutu, New Zealand myrtle
Mazus novaezeelandiae subsp. impolitus f. impolitus	dwarf musk/matt leaved mazus
Melicytus flexuosus
Metrosideros diffusa	white rata
Metrosideros umbellata	Southern rata
Myosurus minimus subsp. novae-zelandiae	New Zealand mousetail, bearded mousetail
Neomyrtus pedunculata	Rohutu, myrtle
Ourisia modesta	Creeping Foxglove
Pittosporum obcordatum	Heart-leaved kohuhu
Puccinellia raroflorens	Saltgrass
Ranunculus brevis
Ranunculus recens
Ranunculus ternatifolius
Tetrachondra hamiltonii
Triglochin palustris	marsh arrow grass
Trithuria brevistyla
Wurmbea novae-zelandiae
Bats
Chalinolobus tuberculatus	Long-tailed bat
Birds
Anas superciliosa	grey duck, pārera,
Ardea modesta	white heron, kōtuku,
Botaurus poiciloptilus	Australasian bittern, matuku hūrepo,
Chlidonias albostriatus	black-fronted tern, tarapirohe, tarapiroe
Egretta sacra sacra	reef heron, matuku moana,
Himantopus novaezelandiae	black stilt, kakī,
Hydroprogne caspia	Caspian tern, taranui,
Hymenolaimus malacorhynchos	whio, blue duck, whio, kōwhiowhio (Ngāi Tahu), kowhiowhio, blue duck, mountain duck, blue mountain duck
Podiceps cristatus australis	Australasian crested grebe, southern crested grebe, great crested grebe, pūteketeke, puteketeke, kamana, kāmana
Fish
Galaxias "Nevis"	Nevis galaxias (Nevis River)
Galaxias "Pomahaka"	Pomahaka galaxias (Pomahaka River)
Galaxias "southern"	Southern flathead galaxias (Southland, Otago)
Galaxias "species D"	Clutha flathead galaxias (Clutha River)
Galaxias "Teviot"	Teviot flathead galaxias (Teviot River)
Galaxias aff. paucispondylus "Manuherikia"	Alpine galaxias (Manuherikia River)
Galaxias aff. paucispondylus "Southland"	Alpine galaxias (Southland)
Galaxias anomalus	Central Otago roundhead galaxias
Galaxias cobitinis	Lowland longjaw galaxias (Kākaunui River)
Galaxias depressiceps	Taieri flathead galaxias
Galaxias eldoni	Eldon’s galaxias
Galaxias gollumoides	Gollum galaxias
Galaxias pullus	Dusky galaxias
Geotria australis	Lamprey
Neochanna burrowsius	Canterbury mudfish
Invertebrates
Maoricrambus oncobolus	Moth
Edpercivalia tahatika	caddisfly
Eulimnadia marplesi	clam shrimp
Kiwisaldula laelaps	shore bug
Nesoperla patricki	stonefly
Oeconesus angustus	caddisfly
Olinga fumosa	caddis
Pseudoeconesus n. sp. T	caddisfly
Pseudoeconesus paludis	caddisfly
Taraperla johnsi	stonefly
Vesicaperla trilinea	stonefly
Zelandobius crawfordi	stonefly
Zelandobius edwardsi	stonefly
Zelandobius mariae	stonefly

The Solid Waste Management chapter manages the disposal of certain types of solid waste to land in circumstances where it may enter water. The types of wastes captured by the provisions of this chapter include discharges from:

Landfills
Clean fill material
Organic waste

The disposal of these types of solid waste is currently managed by the Regional Plan: Waste for Otago (Waste Plan). Plan Change 1 (PC1) to the Waste Plan (operative from 9 July 2022) strengthened the policy direction for establishing and managing certain classes of landfill to reflect current best practice and to contribute towards improving water quality in the Otago Region.

This chapter does not manage liquid wastes (managed through Other Discharges), or agricultural waste and farm landfills (managed through Primary Production).

Overview and key changes

The table below provides a high-level comparison of the provisions of the operative Waste Plan with those included in the draft Solid Waste Management chapter and highlights the key changes from the Waste Plan.

Solid Waste Management chapter of draft LWRP	Existing plan
Landfill
Closed landfills Existing approach generally retained with some amendments. Key changes: Policy direction requiring the identification and remediation (if practicable) of closed landfills at risk of erosion/inundation No requirement to obtain consent for closed landfills if monitoring over 20 years shows contaminant levels are within 10% of background levels If the above conditions are not met, a controlled consent will be required.	Closed landfills do not require a consent if closed before 1991. Closed landfills require a consent and a closure plan if closed after 1991.
Existing and new landfills No changes. PC1 introduced management in accordance with Waste Management Institute New Zealand’s Technical Guidelines for Disposal to Land (October 2022), which is considered best practice, therefore no changes are needed.	Existing and new landfills Existing and new landfills require a discretionary consent and must comply with Waste Management Institute New Zealand’s Technical Guidelines for Disposal to Land (October 2022).
Clean fill
Key changes: No consent needed if the discharge meets specific requirements including: Setback 20 metres from water bodies and bores Not in a drinking water protection zone Less than 250 cubic metres per site per year The material must contain the same or lower levels of and naturally occurring contaminants (such as arsenic) as the area of deposition. If the above permitted activity conditions are not met, a discretionary consent is required.	No consent needed provided no sediment enters water. If sediment enters the water, a discretionary consent is needed.
Organic waste (green waste and compost)
Key changes: One rule framework for all organic waste. New definition: “organic waste: biodegradable vegetative material which includes compost and green waste and does not include any sewage, greywater, industrial or trade waste or agricultural waste.” No consent needed if the discharge meets specific requirements, including: Setback 20 metres from surface water, coast, bores Setback 10 metres from any neighbouring dwelling Less than 250 cubic metres total organic waste No stock access Not in a stormwater flow path Leachate must not enter water. If the permitted activity conditions are not met, a discretionary consent is required.	No consent is needed for the disposal of green waste if no leachate enters a water body. If the permitted activity conditions are not met, a discretionary consent is required. No consent is needed for the disposal of compost if 51% of the material is generated from the same property. If the permitted activity conditions are not met, a discretionary consent is required.

Solid Waste Management chapter of draft LWRP

Existing plan

Landfill

Closed landfills

Existing approach generally retained with some amendments.

Key changes:

Policy direction requiring the identification and remediation (if practicable) of closed landfills at risk of erosion/inundation
No requirement to obtain consent for closed landfills if monitoring over 20 years shows contaminant levels are within 10% of background levels
If the above conditions are not met, a controlled consent will be required.

Closed landfills do not require a consent if closed before 1991.

Closed landfills require a consent and a closure plan if closed after 1991.

Existing and new landfills

No changes. PC1 introduced management in accordance with Waste Management Institute New Zealand’s Technical Guidelines for Disposal to Land (October 2022), which is considered best practice, therefore no changes are needed.

Existing and new landfills

Existing and new landfills require a discretionary consent and must comply with Waste Management Institute New Zealand’s Technical Guidelines for Disposal to Land (October 2022).

Clean fill

Key changes:

No consent needed if the discharge meets specific requirements including:

Setback 20 metres from water bodies and bores
Not in a drinking water protection zone
Less than 250 cubic metres per site per year
The material must contain the same or lower levels of and naturally occurring contaminants (such as arsenic) as the area of deposition.

If the above permitted activity conditions are not met, a discretionary consent is required.

No consent needed provided no sediment enters water. If sediment enters the water, a discretionary consent is needed.

Organic waste (green waste and compost)

Key changes:

One rule framework for all organic waste.
New definition: “organic waste: biodegradable vegetative material which includes compost and green waste and does not include any sewage, greywater, industrial or trade waste or agricultural waste.”
No consent needed if the discharge meets specific requirements, including:
- Setback 20 metres from surface water, coast, bores
- Setback 10 metres from any neighbouring dwelling
- Less than 250 cubic metres total organic waste
- No stock access
- Not in a stormwater flow path
- Leachate must not enter water.

If the permitted activity conditions are not met, a discretionary consent is required.

No consent is needed for the disposal of green waste if no leachate enters a water body. If the permitted activity conditions are not met, a discretionary consent is required.

No consent is needed for the disposal of compost if 51% of the material is generated from the same property. If the permitted activity conditions are not met, a discretionary consent is required.

Recent content updates:

26 September 2023:
- Added clarification of soil types and flooding zones for existing and new on-site wastewater disposal.

The Wastewater Management chapter manages discharges from the treatment of sewage, greywater, and industrial and trade waste. The discharges captured include those from:

Reticulated wastewater systems (community and municipal systems)
Biosolids
Industrial and trade waste
Onsite systems including:
- Onsite wastewater treatment systems (septic tanks)
- Pit toilets (long drops)
- Composting toilets

These discharges have previously been managed by the Regional Plan: Water for Otago (Water Plan). Plan Change 8 (operative from 9 July 2022) improved the policy direction for reticulated wastewater to prefer discharges to land over discharges to water, and to reflect current best practice to contribute towards improving water quality in the Otago Region.

This chapter does not manage animal effluent, which is managed in the Primary Production chapters, or vegetative compos, which is managed in the Solid Waste Management chapter.

Overview of the chapter, and key changes

The table below provides a high-level comparison of the existing plan provisions and the draft Wastewater chapter and highlights the key changes from the Regional Plan: Water for Otago.

Wastewater chapter of draft LWRP	Existing plan
Reticulated wastewater (municipal and privately owned and operated networks)
Existing systems Key changes: Discretionary consent needed for existing discharges to water and land After 2045 is will be prohibited to: discharge wastewater into water discharge untreated wastewater onto land where it may enter water (i.e., sewage overflows).	Existing systems A discretionary consent needed, with policy direction preferring discharges to land over discharges to water
New systems Key changes: Discretionary consent needed to discharge treated wastewater to land Prohibited to discharge untreated wastewater to land where it may enter water (i.e., sewage overflows) Prohibited to discharge treated or untreated wastewater to water.	New systems A discretionary consent needed, with policy direction preferring discharges to land over discharges to water
Biosolids New rule framework Biosolids definition: “sludge derived from a wastewater treatment plant that has been treated and/or stabilised to the extent that it is able to be safely and beneficially applied to land.” No permitted activity rule Restricted discretionary consent needed for discharge to land, and discretion is restricted to: Treatment and quality Land uses of site and adjacent sites Soil type and capacity Rate and management of application Storage and handling Setbacks from water, bores, boundaries Information requirements.	Biosolids Not managed in the Water Plan
Industrial and trade waste
No consent needed to discharge to land, if the discharge meets all the following permitted activity conditions: less than 5 cubic metres per day (volume) less than 5 millimetres per day (rate) not hazardous more than 50 metres from any water, bore or property boundary not resulting in ponding, flooding or sedimentation within an industrial zone. If the activity does not meet all the permitted activity conditions, a discretionary consent is required.	The discharge of industrial and trade waste to water or land requires discretionary consent.
Onsite wastewater (septic tanks)
Key changes: If there is an available reticulated wastewater system available, discharges from any (existing or new) onsite system are not permitted. Existing systems Existing systems are permitted if the discharge is: More than 50 metres from the coast, surface water or drain More than 100 metres from a bore Not in a drinking water protection zone Not within 0.6 metres of groundwater in most soils (soils classified as Category 2-6 in accordance with the New Zealand Standard AS/NZS 1547:2012 – On-site Domestic Wastewater Management) Not within 2 metres of groundwater in gravel soils (soils classified as Category 1 in accordance with the New Zealand Standard AS/NZS 1547:2012 – On-site Domestic Wastewater Management) Not on a slope greater than 30 percent grade for sub surface drip irrigation disposal systems Not on a slope greater than 10 percent grade for all other systems Not in a zone subject to flooding (subject to flooding at a frequency of: greater than 1 in 100 years for any primary treatment system; or greater than 1 in 20 years for all other treatment systems.) Not containing chemical toilet waste or hazardous substances. If the above conditions are not met, the discharge requires a discretionary consent. New systems New systems are permitted if the discharge is: Less than 2000 litres per day On a site larger than 2 hectares More than 50 metres from the coast, surface water or drain More than 100 metres from a bore Not in a drinking water protection zone Not within 0.6 metres of groundwater in most soils (soils classified as Category 2-6 in accordance with the New Zealand Standard AS/NZS 1547:2012 – On-site Domestic Wastewater Management) Not within 2 metres of groundwater in gravel soils (soils classified as Category 1 in accordance with the New Zealand Standard AS/NZS 1547:2012 – On-site Domestic Wastewater Management) Not on a slope greater than 30 percent grade for sub surface drip irrigation disposal systems Not on a slope greater than 10 percent grade for all other systems Not in a zone subject to flooding (subject to flooding at a frequency of: greater than 1 in 100 years for any primary treatment system; or greater than 1 in 20 years for all other treatment systems.) Not containing chemical toilet waste or hazardous substances. If the above conditions are not met, the discharge requires a discretionary consent.	If the system was installed before 1998, no consent is needed if: Discharge does not directly enter water Discharge does not enter another property or cause flooding of another person’s property, erosion, land instability, sedimentation or property damage. If the above conditions are not met, the system requires a discretionary consent. If the system was installed after 1998, consent is required if: The discharge exceeds 2000 litres per day The discharge occurs in a groundwater protection zone The discharge occurs within 50 metres of a surface water body or bore There is a direct discharge to groundwater, drain or water race The discharge enters another property or causes flooding of another person’s property, erosion, land instability, sedimentation or property damage. If the above conditions are not met, the discharge requires a discretionary consent.
Pit toilets (long drops) No consent needed for existing pit toilet if: setback 50 metres from coast, surface water, bores outside a drinking water protection zone at least 1 metre above groundwater operated and maintained to avoid the leakage of sewage above ground. If the above conditions are not met, the discharge requires a discretionary consent. No consent needed for new pit toilet if: located on a section over 20 hectares setback 50 metres from coast, surface water, bores outside a drinking water protection zone at least 2 metres above groundwater operated and maintained to avoid the leakage of sewage above ground. If the above conditions are not met, the discharge requires a discretionary consent.	Pit toilets (long drops) Discharges from pit toilets constructed before 1998 are permitted. Discharges from pit toilets constructed after 1998 are permitted if the discharge is: Further than 50 metres form surface water or a bore. Outside a groundwater protection zone Not directly entering groundwater. If the above conditions are not met, the discharge requires a discretionary consent.
Composting toilets No consent needed to discharge to land if: material is composted for 12 months prior to discharge the land is not used for food crops setback 50 metres from surface water, coast, bores material is discharged outside a drinking water protection zone. If the above conditions are not met, the discharge requires a discretionary consent.	Not managed in Water Plan.
Onsite greywater No consent required to discharge to land if: the greywater system complies with the Building Act the discharge is via a sub-surface land application system and does not exceed 15 millimetres per day the greywater system filters the discharge and does not allow it to store for more than 12 hours the discharge does not contain sewage or a hazardous waste the discharge does not result in ponding or flooding the discharge is not within 50 metres of surface water or coast the discharge is not within a drinking water protection zone. If the activity does not meet the permitted activity conditions, a discretionary consent is required.	Onsite greywater Managed as “sullage” under the Water Plan Permitted to discharge to water as long was quality and temperature are not affected If the activity does not meet the permitted activity conditions, a discretionary consent is required.

Wastewater chapter of draft LWRP

Existing plan

Reticulated wastewater (municipal and privately owned and operated networks)

Existing systems

Key changes:

Discretionary consent needed for existing discharges to water and land
After 2045 is will be prohibited to:
- discharge wastewater into water
- discharge untreated wastewater onto land where it may enter water (i.e., sewage overflows).

Existing systems

A discretionary consent needed, with policy direction preferring discharges to land over discharges to water

New systems

Key changes:

Discretionary consent needed to discharge treated wastewater to land
Prohibited to discharge untreated wastewater to land where it may enter water (i.e., sewage overflows)
Prohibited to discharge treated or untreated wastewater to water.

New systems

A discretionary consent needed, with policy direction preferring discharges to land over discharges to water

Biosolids

New rule framework
Biosolids definition: “sludge derived from a wastewater treatment plant that has been treated and/or stabilised to the extent that it is able to be safely and beneficially applied to land.”
No permitted activity rule
Restricted discretionary consent needed for discharge to land, and discretion is restricted to:
- Treatment and quality
- Land uses of site and adjacent sites
- Soil type and capacity
- Rate and management of application
- Storage and handling
- Setbacks from water, bores, boundaries
- Information requirements.

Biosolids

Not managed in the Water Plan

Industrial and trade waste

No consent needed to discharge to land, if the discharge meets all the following permitted activity conditions:

- less than 5 cubic metres per day (volume)
- less than 5 millimetres per day (rate)
- not hazardous
- more than 50 metres from any water, bore or property boundary
- not resulting in ponding, flooding or sedimentation
- within an industrial zone.

If the activity does not meet all the permitted activity conditions, a discretionary consent is required.

The discharge of industrial and trade waste to water or land requires discretionary consent.

Onsite wastewater (septic tanks)

Key changes:

If there is an available reticulated wastewater system available, discharges from any (existing or new) onsite system are not permitted.

Existing systems

Existing systems are permitted if the discharge is:

More than 50 metres from the coast, surface water or drain
More than 100 metres from a bore
Not in a drinking water protection zone
Not within 0.6 metres of groundwater in most soils (soils classified as Category 2-6 in accordance with the New Zealand Standard AS/NZS 1547:2012 – On-site Domestic Wastewater Management)
Not within 2 metres of groundwater in gravel soils (soils classified as Category 1 in accordance with the New Zealand Standard AS/NZS 1547:2012 – On-site Domestic Wastewater Management)
Not on a slope greater than 30 percent grade for sub surface drip irrigation disposal systems
Not on a slope greater than 10 percent grade for all other systems
Not in a zone subject to flooding (subject to flooding at a frequency of: greater than 1 in 100 years for any primary treatment system; or greater than 1 in 20 years for all other treatment systems.)
Not containing chemical toilet waste or hazardous substances.

If the above conditions are not met, the discharge requires a discretionary consent.

New systems

New systems are permitted if the discharge is:

Less than 2000 litres per day
On a site larger than 2 hectares
More than 50 metres from the coast, surface water or drain
More than 100 metres from a bore
Not in a drinking water protection zone
Not within 0.6 metres of groundwater in most soils (soils classified as Category 2-6 in accordance with the New Zealand Standard AS/NZS 1547:2012 – On-site Domestic Wastewater Management)
Not within 2 metres of groundwater in gravel soils (soils classified as Category 1 in accordance with the New Zealand Standard AS/NZS 1547:2012 – On-site Domestic Wastewater Management)
Not on a slope greater than 30 percent grade for sub surface drip irrigation disposal systems
Not on a slope greater than 10 percent grade for all other systems
Not in a zone subject to flooding (subject to flooding at a frequency of: greater than 1 in 100 years for any primary treatment system; or greater than 1 in 20 years for all other treatment systems.)
Not containing chemical toilet waste or hazardous substances.

If the above conditions are not met, the discharge requires a discretionary consent.

If the system was installed before 1998, no consent is needed if:

Discharge does not directly enter water
Discharge does not enter another property or cause flooding of another person’s property, erosion, land instability, sedimentation or property damage.

If the above conditions are not met, the system requires a discretionary consent.

If the system was installed after 1998, consent is required if:

The discharge exceeds 2000 litres per day
The discharge occurs in a groundwater protection zone
The discharge occurs within 50 metres of a surface water body or bore
There is a direct discharge to groundwater, drain or water race
The discharge enters another property or causes flooding of another person’s property, erosion, land instability, sedimentation or property damage.

If the above conditions are not met, the discharge requires a discretionary consent.

Pit toilets (long drops)

No consent needed for existing pit toilet if:

setback 50 metres from coast, surface water, bores
outside a drinking water protection zone
at least 1 metre above groundwater
operated and maintained to avoid the leakage of sewage above ground.

If the above conditions are not met, the discharge requires a discretionary consent.

No consent needed for new pit toilet if:

located on a section over 20 hectares
setback 50 metres from coast, surface water, bores
outside a drinking water protection zone
at least 2 metres above groundwater
operated and maintained to avoid the leakage of sewage above ground.

If the above conditions are not met, the discharge requires a discretionary consent.

Pit toilets (long drops)

Discharges from pit toilets constructed before 1998 are permitted.

Discharges from pit toilets constructed after 1998 are permitted if the discharge is:

Further than 50 metres form surface water or a bore.
Outside a groundwater protection zone
Not directly entering groundwater.

If the above conditions are not met, the discharge requires a discretionary consent.

Composting toilets

No consent needed to discharge to land if:

- material is composted for 12 months prior to discharge
- the land is not used for food crops
- setback 50 metres from surface water, coast, bores
- material is discharged outside a drinking water protection zone.

If the above conditions are not met, the discharge requires a discretionary consent.

Not managed in Water Plan.

Onsite greywater

No consent required to discharge to land if:

the greywater system complies with the Building Act
the discharge is via a sub-surface land application system and does not exceed 15 millimetres per day
the greywater system filters the discharge and does not allow it to store for more than 12 hours
the discharge does not contain sewage or a hazardous waste
the discharge does not result in ponding or flooding
the discharge is not within 50 metres of surface water or coast
the discharge is not within a drinking water protection zone.

If the activity does not meet the permitted activity conditions, a discretionary consent is required.

Onsite greywater

Managed as “sullage” under the Water Plan
Permitted to discharge to water as long was quality and temperature are not affected
If the activity does not meet the permitted activity conditions, a discretionary consent is required.

The Wetlands chapter manages activities in or near wetlands (including ‘natural inland wetlands’ as they are defined in the National Policy Statement for Freshwater Management 2020, but also wetlands more broadly). The chapter works in conjunction with the controls on natural inland wetlands in the National Environmental Standard for Freshwater (NES-F), which includes controls on the removal of vegetation, earthworks, drainage, and discharges into natural inland wetlands, and the Resource Management (Stock Exclusion) Regulations 2020. The majority of controls on wetlands are included in the national documents. The Wetlands chapter has two additional controls:

For natural wetlands that require stock exclusion under the Resource Management (Stock Exclusion) Regulations 2020, all heavy livestock are required to be excluded.
Potentially destructive activities, like cultivation and spraying, are controlled for a wider range of wetlands than those protected under the NES-F.

Otago has a diverse range of wetlands. These provide valuable habitat for flora, fauna and valued mahika kai, and are an integral part of the natural character of the region. Wetlands and wetland values are sensitive to loss from a range of activities.

The creation of new wetlands is supported, and new wetlands are likely to have wide ranging benefits for water quality, biodiversity and natural hazard reduction.

Alongside the development of provisions for managing wetlands in the draft Land and Water Regional Plan, the Otago Regional Council is undertaking the identification and mapping of wetlands as required by the NPSFM.

Overview and key changes

For natural inland wetlands, the provisions of the Resource Management (Stock Exclusion) Regulations 2020 and the NES-F apply. The plan can be more stringent, but these regulations provide a range of compulsory protections.

The table below provides a high-level comparison of the existing provisions of the operative Water Plan, the NES-F, the Resource Management (Stock Exclusion) Regulations 2020 and the draft WET chapter in the draft LWRP highlighting the key differences.

Wetlands chapter of draft LWRP	Existing NES-F and Stock Exclusion Regulations and Water Plan
Wetland types
The proposed rules define a wider range of natural wetlands and require resource consent for activities that that are likely to permanently destroy them. The activities that will require a restricted discretionary resource consent in this wider range of natural wetlands are: all kinds of cultivation herbicide spraying, other than spot-spraying with hand-held, non-motorised equipment earthworks other than minor works such as installing fenceposts and utility lines installing new sub-surface drainage and open drains. The natural wetlands included in the above controls are the full range of wetlands, but excludes constructed wetlands and wet pasture, areas where water temporarily ponds after rain, or pasture containing patches of rushes. Stock are not required to be excluded from this wider range of natural wetlands but are from natural inland wetlands (see row below). This wider range of natural wetlands are included in the definition of ‘critical source area’. This has two implications: the natural wetlands, as critical source areas, are required to be specifically managed under Freshwater Farm Plans. intensive winter grazing and sacrifice paddocks on them are restricted.	The NES-F manages ‘natural inland wetlands’ only. The definition of ‘natural inland wetlands’ excludes any wetland that has more than 50% of exotic pasture species and is within an area of pasture used for grazing, unless the wetland is located with a habitat of a threatened species. Identifying and mapping wetlands under this definition has proven difficult and resource and time consuming. This leaves many wetlands unprotected, more so in advance of any on-site inspection and mapping.
Stock exclusion
In addition to cattle, pigs and deer, other heavy livestock, such as horses, but not sheep or goats, are also required to be excluded from natural inland wetlands. A discretionary activity resource consent can be sought for access to natural inland wetlands by these additional livestock types. However, cattle, pigs and deer are managed by the Stock Exclusion Regulations and those regulations do not provide a resource consent option. There continue to be no stock exclusion requirements for sheep or goats.	The Stock Exclusion Regulations require cattle, pigs and deer to be excluded from natural inland wetlands on low slope land by July 2025 and on any slope if it is a wetland specifically listed in a regional or district plan or supports a population of threatened species.
Regionally significant wetlands
The existing Regionally Significant Wetlands will continue to be mapped, and the mapping will be updated as the mapping of wetlands that the Council is undertaking is completed. These existing Regionally Significant Wetlands will be managed under the NES-F and Stock Exclusion Regulations where they are natural inland wetlands, and under the rules restricting cultivation, herbicide spraying, earthworks and new drainage, along with Freshwater Farm Plans, for other natural wetlands.	These are mapped and some specific controls apply. These controls have largely been superseded by the NES-F and the Stock Exclusion Regulations.

Proposed new rules and regulations for individual FMU/rohe

We have:

Identified key areas (Freshwater Management Units or FMU and rohe)
Identified the values that apply to each FMU and rohe
Set environmental outcomes for each value for each FMU and rohe
Worked out how to measure progress toward those environmental outcomes by looking at various attributes like water cleanliness and natural habitat health.

Select the FMU or rohe you are interested in to view the proposed new rules and regulations for the specific area.

If you are unsure of any particular terms, there is a glossary of terms.

Please note: we are updating the material regularly to improve clarity.

Clutha/Mata-au

The Clutha/Mata-au in Otago is the largest area for managing freshwater. It's divided into five smaller zones called "rohe" to better involve local communities in decisions.

Dunstan Rohe

Within the Clutha Mata-Au FMU, the Dunstan Rohe runs from the outlets of lakes Wānaka, Whakatipu and Hāwea down to Clyde Dam and includes the Kawarau, Nevis, Shotover, Upper Clutha/Mata-au, Hāwea, Cardrona, Arrow, and Lindis Rivers.

Lower Clutha Rohe

Within the Clutha Mata-Au FMU, the Lower Clutha Rohe includes the Pomahaka catchment, as well as several other river catchments that feed the Clutha/Mata-au.

Manuherekia Rohe (Area)

Within the Clutha Mata-Au FMU, the Manuherekia Rohe is based on the catchment area of the Manuherekia River.

Roxburgh Rohe

Within the Clutha Mata-Au FMU, the Roxburgh Rohe extends from the Clyde Dam to Beaumont, and covers Alexandra, Clyde, and Roxburgh.

North Otago FMU

The North Otago Freshwater Management Unit (FMU) covers about 296,000 hectares and extends from Waitaki Bridge down through Oamaru, Moeraki, and Palmerston townships to the bottom of the southern branch of the Waikouaiti River.

Taiari/Taieri FMU

The Taiari/Taieri Freshwater Management Unit (FMU) covers the entire Taiari/Taieri River catchment, reaching from Taiari/Taieri Mouth across the Taiari/Taieri Plain into the Strath Taiari/Taieri and Maniototo Basins.

Upper Lakes Rohe

Within the Clutha Mata-Au FMU, the Upper Lakes Rohe covers the lakes of Whakatipu, Wānaka and Hāwea, from their tributaries to their outlets and is around 7,000 square kilometres.

Dunedin & Coast FMU

The Dunedin & Coast Freshwater Management Unit (FMU) spans over 1,000 square kilometres and runs from just south of Karitane down to the mouth of the Clutha/Mata-Au.

Catlins FMU

The Catlins Freshwater Management Unit (FMU) is located along the southern coast of Otago.

Strategic Policy Direction

The Land and freshwater chapter focuses on:

Achieving the long-term visions and environmental outcomes for Freshwater Management Units (FMUs) / rohe.
Managing resources in a way that provides for:

- Mana whenua kaitiakitaka (Māori Environmental Management) and rakatirataka (leadership)
- The social, economic, and cultural well-being of Otago’s people and communities
- Nationally and regionally significant infrastructure, including renewable electricity
- Land use and development, including on highly productive land.

Protecting the values of outstanding water bodies and the natural character of all water bodies, including their form and function.
Implementing mandatory direction set by the NPSFM on:

- Avoiding the loss of extent and values of rivers, lakes, and natural inland wetlands
- providing for passage of desired fish species and impeding passage for undesired fish species.

Requiring activities to use good environmental practice.
Outlining the principles for avoiding and phasing out over-allocation, including:

- considering the needs of both present and future generations
- recognising the investment of existing uses and provision for new opportunities
ensuring allocation and use of resources is efficient.

Setting direction on managing discharges, including:

- preferring discharges to land over discharges to water
- requiring action to be taken to reduce the impact of the discharge
- ensuring consents for discharges assist with achieving FMU and rohe environmental outcomes.

When setting consent terms, considering FMU or rohe timeframes and the need to implement any future changes to the plan.
Recognising the national and regional benefits of renewable electricity generation, including by maintaining generation capacity and operational flexibility and allowing for ongoing maintenance and operation of schemes.
Managing both new and existing activities in areas subject to natural hazard risk so that the level of risk is not increased.

The strategic direction in the draft LWRP is a significant shift from comparable direction in the Water Plan. The key issues with the current state, and drivers for change, include:

The foundation of the operative Water Plan is out of step with the NPSFM

The objectives and policies of the Water Plan focus on ‘balancing’ resource use against protection of those resources, which has been replaced by the concept of Te Mana o te Wai and the hierarchy of obligations. This is a fundamental shift from the philosophy that underpinned the Water Plan when it was written.

The operative Water Plan does not adequately provide for the integrated management of natural resources

The Water Plan focuses primarily on water and contains little direction on managing the land uses that contribute to freshwater issues, particularly for water quality and ecosystem health. There is also limited recognition of the relationships between fresh and coastal water, and ground and surface water.

The operative Water Plan does not give effect to mandatory direction in the NPSFM

A suite of mandatory policies is required to be included in regional plans by the NPSFM. These apply to many different activities and therefore need to be part of the strategic direction of the plan.

The operative Water Plan does not recognise the increasing impacts of climate change

The Water Plan does not specifically address climate change or the future impacts on water availability in some parts of the region. This will be increasingly important for decision-making over the life of the plan.

The operative Water Plan does not adequately address Kāi Tahu cultural values and interests

The well-being of mahika kai (food and resource gathering) and taoka (treasures), and protection of other cultural values is rarely given effect to in environmental policy or decision-making processes under the operative Water Plan and these considerations are often compromised in favour of other values, including economic values.

LWRP Glossary

Term	Definition
7-day mean annual low flow (MALF)	The average, for a number of years, of the lowest average flow over seven consecutive days in each year. The lowest average flow over seven consecutive days in each year is determined by calculating the average flow over seven consecutive days for every seven consecutive day period in the year and choosing the lowest.
Agrichemical	Any substance whether inorganic or organic, man-made or naturally occurring, modified or in its original state, that is used to eradicate, modify, or control flora and fauna. For the purpose of this Plan, it includes agricultural compounds, but excludes oral nutrition compounds, vertebrate toxic agents, and fertilisers.
Agricultural solid waste	Agricultural waste that exhibits the properties of a solid, e.g., it can be stacked and hold a definite angle of repose. For the purposes of the Plan, if any waste does not meet the definition of agricultural solid waste it is treated as agricultural liquid waste.
Agricultural waste	The waste from the customary and generally accepted activities, practices, and procedures that farmers and producers adopt, use, or engage in during the production and preparation for market of poultry, livestock, and associated farm products; and in the production and harvesting of agricultural crops that include agronomic, horticultural, silvicultural, viticultural and aquaculture activities. In addition, winery wastewater and grape marc constitutes agricultural waste.
Animal effluent storage facility	A pond, tank, or structure primarily used for the containment or storage of animal effluent, but excludes any ancillary structures for the collection, conveyance, or treatment of liquid or solid animal effluent, such as sumps, stone traps and weeping walls.
Animal effluent system	The collection, storage, or treatment, of liquid or solid animal effluent.
Aquifer pump testing	A test made by pumping a well for a period of time and observing the change in water level or pressure in the aquifer. A pumping test may be used to determine the capacity of the well, the hydraulic characteristic of the aquifer or any interference effects.
Artificial water course	A watercourse that is deliberately created by human action (including an irrigation canal, water supply race, canal for the supply of water for electricity power generation, farm drainage canal, drain, or duck pond) provided that it is not part of a water body or a modified watercourse.
Available reticulated wastewater system	A community or municipal reticulated wastewater system which: (1) passes within 30 metres of the property boundary: or, (2) passes 60 metres of the closest building on a property; and (3) the system has existed in that location for more than 12 months.
Biosolids	Sludge derived from a wastewater treatment plant that has been treated and/or stabilised to the extent that it is able to be safely and beneficially applied to land.
Cascading hazards	Where the occurrence of one natural hazard is likely to trigger another natural hazard event e.g., an earthquake triggering a landslide which dams a river causing flooding.
Classifiable dam	A dam that: (a) has a height of 4 or more metres and stores 20,000 or more cubic metres volume of water or other fluid; or (b) has a height of 1 or more metres and stores 40,000 or more cubic metres volume of water or other fluid. For the purpose of this definition: (a) the height of the dam is the vertical distance from the crest of the dam and must be measured: (i) in the case of a dam across a water body, from the natural bed of the water body at the lowest downstream outside limit of the dam; and (ii) in the case of a dam not across a water body, from the lowest elevation at the outside limit of the dam; and (iii) in the case of a canal, from the invert of the canal; and (b) in measuring a dam’s stored volume, the stored volume of water or other fluid does not include: (i) in the case of a dam across a water body, water or fluid that is lower than the natural ground level at the lowest downstream outside limit of the dam; and (ii) in the case of a dam not across a water body, water or fluid that is lower than the natural ground level at the lowest elevation at the outside limit of the dam; and (iii) in the case of a canal where the canal invert (the lowest point of the inside of the canal structure that stores water or fluid) is below the natural ground level, water or fluid that is lower than the natural ground level at the lowest elevation at the outside limit of the canal structure.
Climate change adaptation	The process of adjustment to actual or expected climate and its effects.
Climate change mitigation	A human intervention to reduce the sources of, or enhance the sinks of, greenhouse gases.
Closed landfill	Any landfill that no longer accepts solid waste for disposal.
Community water supply	Water taken and used primarily to supply drinking water to users via a reticulated system, with water also supplied for other purposes including institutional, industrial, and commercial processing, cultivation, and production of food and beverages and fibre, animal drinking water purposes, amenity irrigation use and fire-fighting activities. The supply of domestic water must constitute at least 50% of the water supplied.
Composting toilet	A toilet system that uses a predominantly aerobic processing system that treats human excreta, typically with no water, via composting or managed aerobic decomposition.
Construction phase stormwater	Water, sediment, and entrained contaminants resulting from precipitation on exposed or unstabilised land and which arises from construction or demolition activities, or the development of land.
Controlled lake	A lake that is located within the bed of a river where the outflow of the lake is controlled by artificial means.
Cross-mixing	The introduction of water from one water body into another water body, where there is no natural connection between those water bodies.
Cultivation	Preparing land for growing pasture or a crop by mechanical tillage, direct drilling, herbicide spraying, or herbicide spraying followed by over-sowing for pasture or forage crops (colloquially referred to as ‘spray and pray’), but excludes: (a) herbicide spraying undertaken solely for the control of pest plant species. (b) herbicide spraying for the establishment or maintenance of plantation forestry; and (c) stick raking or slash raking associated with a plantation forest
Dairy Effluent Storage Calculator	The Dairy Effluent Storage Calculator available from http://www.dairynzdesc.co.nz
Dam	A structure used or to be used for the purpose of impounding water (and any substances dissolved in, suspended, or otherwise combined with the water) or water body.
Damming	The activity of impounding water (and any substances dissolved in, suspended in or otherwise combined with the water).
Dewatering	The abstraction of groundwater so as to lower the water table: (a) for the period of time required to enable excavation, construction, maintenance, or geotechnical work to proceed in the dewatered area; or (b) to sustain a lower localised water table.
Diversion	The purposeful redirecting of water flow from its natural or existing direction of flow. For the purposes of this Plan, taking water from the bed of any water body, even if only for a short distance before it is returned, is considered a take and discharge.
Drilling	A method of boring a hole into the ground predominantly by rotating, percussive or washing action. Excludes excavation of pits by digging, blasting or other forms of excavation, driven posts or driven solid pile.
Effects management hierarchy (in relation to indigenous biodiversity)	The effects management hierarchy set out in ECO-P6 of the ORPS.
Effects management hierarchy (in relation to natural inland wetlands and rivers)	The effects management hierarchy set out in LF-FW-P13A of the ORPS.
Environmental flows and levels	Any minimum flows, management flows, environmental levels and minimum levels identified in this Plan that apply to a waterbody.
Environmental level	The water levels, when measured at the relevant water level monitoring site, within which a lake must be maintained, and may include minimum levels and maximum operating levels.
Existing resource consent	1. resource consent which has been given effect to 2. resource consent which has not been given effect to and has not lapsed; and 3. an expired resource consent continuing to be exercised under s124 of the RMA.
Feedlot	This has the same meaning as in the National Environmental Standards for Freshwater 2020: A stockholding area where cattle — (a) are kept for at least 80 days in any 6-month period; and (b) are fed exclusively by hand or machine.
Flood protection and drainage infrastructure	Any infrastructure owned or managed by ORC exercising its powers, functions and duties under the Soil Conservation and Rivers Control Act 1941, the Land Drainage Act 1908, or the Local Government Act 1974, in relation to flood control and drainage.
Flood protection and drainage infrastructure works	Any works undertaken by or on behalf of ORC for the purpose of establishing, maintaining, altering, or removing any flood protection and drainage infrastructure.
Fractured rock aquifers	An aquifer which stores and transmits water through crevices, joints and fractures in an otherwise impervious rock mass, as shown in [a map to come].
Freshwater Management Units (FMUs) and rohe	Otago is divided into five Freshwater Management Units (FMUs). An FMU is a water body or multiple water bodies of a manageable size where freshwater objectives and limits will be set. Rohe means ‘area’ in te reo, and is used to define distinct areas within larger FMUs.
Hāpua (lagoon)	A pool of water, lagoon, pond.
Hard protection structure	Within the coastal environment, this has the same meaning as in the Glossary of the New Zealand Coastal Policy Statement 2010 as set out below: Includes a seawall, rock revetment, groyne, breakwater, stop bank, retaining wall or comparable structure or modification to the seabed, foreshore or coastal land that has the primary purpose or effect of protecting an activity from a coastal hazard, including erosion. Outside the coastal environment, this means any structure that has the primary purpose of natural hazard risk mitigation, including: dams, weirs, riprap, stop banks, carriageways, groynes, or reservoirs.
Hazardous Substances and New Organisms (HSNO) Act	The Hazardous Substances and New Organisms (HSNO) Act is a law that manages the risks that hazardous substances and new organisms pose to the health and safety of people and communities and the New Zealand environment.
In-stream dam	Any dam which is located in part or in whole in, on, under or over the bed of a lake or river, or within a natural inland wetland.
Indigenous vegetation	Vascular and non-vascular plants that, in relation to a particular area, are native to the ecological district1 or freshwater or marine bioregion in which that area is located.
Kaitiakitaka	Māori Environmental Management.
Ki uta ki tai	The Land and Water Regional Plan will be based on a whole-of-catchment approach - ki uta ki tai - from the mountains to the sea.
Lawfully established	Established in accordance with and compliant with the Resource Management Act 1991 or any former legislation at the time of establishment.
Line	A wire or conductor (including a fibre optic cable) used or intended to be used for telecommunications or the transmission of electricity.
Liquid animal effluent	Faeces and urine from land-based animals, including associated process water, wash-down water, contaminants and sludge but excluding solid animal effluent. For the purposes of this definition, it does not include incidental animal effluent present in livestock processing waste streams.
Mahika kai	Gathering of food and natural materials by Kāi Tahu whānui in accordance with tikaka, the places where those resources are gathered, and the work, methods and cultural activities involved in obtaining them.
Main stem	In relation to rivers, the rivers identified in [a schedule to come] of this Plan and applies from the source of that course to the sea or confluence with another main stem but excludes any tributary.
Management flow	The flow, when measured at the relevant flow monitoring site, at which the taking of water from a water body is subject to reductions.
Mātaitai reserve	Mātaitai reserves are identified traditional fishing grounds tangata whenua have a special relationship with.
Minimum flow	The flow, when measured at the relevant water flow monitoring site, at which the taking of water from a water body must cease.
Minimum level	The water level, when measured at the relevant water level monitoring site, at which the taking of water from a water body must cease.
Modified watercourse	A water body that has been modified, channelled, or straightened for land drainage or other purposes.
National Environmental Standards for Freshwater (NES-F)	National Environmental Standards for Freshwater (NES-F). The standards regulate activities that pose risks to the health of freshwater and freshwater ecosystems.
National Objectives Framework (NOF)	The National Objectives Framework (NOF) sets the necessary values, outcomes and specific attributes required to meet the hierarchy of obligations and local definitions of Te Mana o Te Wai, and enable long-term visions to be realised.
National Policy Statement on Freshwater Management (NPS-FM)	The Government’s National Policy Statement on Freshwater Management (NPS-FM) 2020 gives effect to new protection we must give to our waterways.
Natural lake	A lake that is not a controlled lake or an off-stream artificial lake.
Non-consumptive take	A take of water from a water body where the same volume of water is returned:    (a) to the same water body; and  (b) at the same time or within a timeframe as near as practicable to when the take is operating.
Off-stream artificial lake	A lake that is located outside of the bed of a river and that is not part of a water body.
Off-stream dam	Any dam of which no part is located in, on, under or over the bed of a lake or river, or within a natural inland wetland.
On-site wastewater treatment system	A system that receives wastewater or sewage from a single landholding and treats and applies the wastewater or sewage to a land application system on the same property.
Organic waste	Biodegradable vegetative material which includes compost and green waste and does not include any sewage, greywater, industrial or trade waste or agricultural waste.
Paper Allocation/Paper Water	Paper allocation is any quantity of water that is allocated under a resource consent but that exceeds the actual (recorded) rate of take or volume of water taken by the consent.
Pasture-based wintering	Break feeding cattle, other than lactating dairy cows, on pasture between 1 May and 30 September inclusive where supplementary feed offered is more than 10,000 kgDM/ha (fresh weight (grams) x dry matter percentage (as a decimal) x hectares).
Permanent forest or permanent forestry	A forest deliberately established (including through planting or facilitated regeneration) without any intention to harvest, including for the purpose of creating a biological carbon sink, that: (a) comprises an area of at least 1 hectare of continuous forest cover, but (b) does not include: (i) plantation forestry; (ii) forest species in urban areas; or (iii) nurseries and seed orchards; or (iv) trees grown for fruit or nuts; or (v) willows and poplars space planted for soil conservation purposes.
Pit toilet	A hole in the ground used for the disposal of sewage, also referred to as a long drop or pit latrine.
Plan Change 1 (PC1)	Plan Change 1 amended the Regional Plan: Waste for Otago by: prohibiting the use of waste oil as a dust suppressant and encouraging the use of other safer alternatives, and improving the policy direction for establishing and managing certain classes of landfill so that it reflects current best practice to contribute towards improving water quality in the Otago Region.
Plan Change 8 (PC8)	Plan Change 8 made a range of amendments to the current water and waste plan provisions to better manage specific urban and rural activities, known to be contributing to water quality issues in parts of Otago. The rural discharge provisions made operative are set out in the following parts of Plan Change 8: Part A: Discharge policies Part B: Animal waste storage and application Part C: Good farming practices Part D: Intensive grazing Part E: Stock access to water Part F: Sediment traps Part G: Sediment from earthworks for residential development Part H: Nationally or regionally important infrastructure
Potentially contaminated	Part of a site where an activity or industry described in the Ministry for the Environment’s Hazardous Activities and Industries List (October 2011) has been or is being undertaken on it or where it is more likely than not that such an activity or industry is being or has been undertaken on it, but excludes any site where a detailed site investigation has been completed and reported and which demonstrates that any contaminants in or on the site are at, or below, background concentrations.
Proposed Otago Regional Policy Statement 2021 (pORPS)	The Proposed Otago Regional Policy Statement 2021 (pORPS) sets the direction for future management of Otago's natural and physical resources.
Rakatirataka	Leadership, authority, and decision-making powers.
Reasonable mixing	The mixing that occurs in a mixing zone as defined in APP[RWS] of this Plan.
Regionally significant infrastructure	(1) roads classified as being of regional importance in accordance with the One Network Framework, (2) electricity sub-transmission infrastructure, (3) renewable electricity generation facilities that connect with the local distribution network but not including renewable electricity generation facilities designed and operated principally for supplying a single premise or facility, (4) telecommunication and radiocommunication facilities as respectively defined in section 5 of the Telecommunications Act 2001 and in section 2 of the Radiocommunications Act 1989, (5) facilities for public transport, including terminals and stations, (6) the following airports: Dunedin, Queenstown, Wānaka, Alexandra, Balclutha, Cromwell, Ōamaru, Taiari. (7) navigation infrastructure associated with airports and commercial ports which are nationally or regionally significant, (8) defence facilities for defence purposes in accordance with the Defence Act 1990, (9) community drinking water abstraction, supply treatment and distribution infrastructure that provides no fewer than 25 households with drinking water for not less than 90 days each calendar year, and community water supply abstraction, treatment and distribution infrastructure (excluding delivery systems or infrastructure primarily deployed for the delivery of water for irrigation of land or rural agricultural drinking-water supplies) (10) community stormwater infrastructure, (11) wastewater and sewage collection, treatment and disposal infrastructure serving no fewer than 25 households, (11A) oil terminals, bulk fuel storage and supply infrastructure, and ancillary pipelines at Port Chalmers and Dunedin, and (12) Otago Regional Council’s hazard mitigation works including flood protection infrastructure and drainage schemes. For the avoidance of doubt, any infrastructure identified as nationally significant infrastructure is also regionally significant infrastructure.
Regionally Significant Wetland	A Regionally Significant Wetland is any wetland that has one or more of the following values: Habitat for nationally or internationally rare or threatened species or communities Critical habitat for the life cycles of indigenous fauna which are dependent on wetlands High diversity of wetland habitat types High degree of naturalness Wetland scarce in Otago in terms of its ecological or physical character Wetland which is highly valued by Kāi Tahu for cultural and spiritual beliefs, values and uses, including wāhi taoka (treasured place or valued possession) and mahika kai (food and resource gathering) High diversity of indigenous flora and fauna Regionally significant wetland habitat of waterfowl Significant hydrological values including maintaining water quality or low flows, or reducing flood flows Any wetland over 800 metres above sea level (alpine wetlands).
Reticulated wastewater system	A wastewater treatment plant and the attached network of structures including pipes and pump stations owned and operated by a group, institution, territorial authority or company that primarily treats wastewater from more than one site.
Riparian margin	The land within 10 metres of the bed of a lake or continually flowing river (measured horizontally).
Sacrifice Paddock	This as the same meaning as in the National Environmental Standards for Freshwater 2020: An area on which — (a) cattle are repeatedly, but temporarily, contained (typically during extended periods of wet weather); and (b) the resulting damage caused to the soil by pugging is so severe as to require resowing with pasture species.
Secondary take	The taking of water that has previously been taken from one water body and discharged to another, for the purpose of supplying the secondary take.
Sediment trap	An excavated or bunded area in a critical source area or the bed of river that is not continually flowing that is designed and constructed solely for the purpose of allowing sediment to drop from the water column.
Site-specific river flow	The flow that must be maintained below a surface water take point.
Solid animal effluent	Solid excreta from land-based animals that cannot be pumped and sprayed, including bedding material and manure, but does not include dead animals or animal parts.
Stockholding area	It has the same meaning as in the National Environmental Standards for Freshwater 2020: (a) an area for holding cattle at a density that means pasture or other vegetative ground cover cannot be maintained (for example, feed pads, winter pads, standoff pads, and loafing pads); but (b) does not include an area used for pastoral purposes that is in the nature of a stockyard, milking shed, wintering barn, or sacrifice paddock.
Stormwater network	An interconnected system of pipes, open channels, treatment devices and ancillary structures which are operated by a territorial authority, network utility operator, company or collective and used for collecting, conveying, diverting, storing, treating, or discharging stormwater.
Stormwater sub-catchment	An area of land defined for the purposes of managing the quantity and quality of stormwater.
Taiāpure	A coastal fishing area of special significance to iwi.
Taoka/Wāhi taoka	A treasured place or valued possession.
Te Mana o te Wai	Te Mana o te Wai - the vital importance and health of our water - is a national policy emphasising that the health of our waterways must come first, above all else.
Vertebrate toxic agent	A trade name product used to control, kill, or limit the viability of vertebrate pests (such as rabbits, possums, and rodents), including products that have a negative effect on reproduction but do not include attractant or repellent substances that are not toxic.
Wāhi tūpuna	Landscapes and places that embody the relationship of mana whenua and their culture and traditions with their ancestral lands, water, sites, wāhi tapu and other taoka.
Waste	Has the same meaning as in the Waste Minimisation Act 2008 as set out below: (a) means anything disposed of or discarded; and (b) includes a type of waste that is defined by its composition or source (for example, organic waste, electronic waste, or construction and demolition waste); and (c) to avoid doubt, includes any component or element of diverted material, if the component or element is disposed of or discarded
Waste oil	Any oil that has been refined from crude oil, or any synthetic hydrocarbon oil, that has been used, and as a result of such use, has become unsuitable for its original purpose due to the presence of impurities or contaminants or the loss of original properties.
Weir	An open-topped structure across the full width of any lake or river that: (a) alters the water level and the flow characteristics of the water; and (b) allows water to flow passively through or over top.

Guide to different activity types

Permitted

No consent needed if the conditions are met

A permitted activity can be carried out without the need for a resource consent so long as it complies with any requirements, conditions and permissions specified in the plan.

Controlled

Consent always granted and conditions are restricted

A controlled activity requires a resource consent before it can be carried out. The council can impose conditions on the consent, but only for those matters over which the council has reserved control.

Restricted discretionary

Consent needed and conditions are restricted

A restricted discretionary activity requires a resource consent before it can be carried out. The consent authority can exercise discretion as to whether or not to grant consent, and to impose conditions, but only in respect of those matters over which it has restricted its discretion in the plan or over which discretion is restricted in national environmental standards or other regulations.

Discretionary

Consent needed and conditions are not restricted

A discretionary activity requires a resource consent before it can be carried out. The consent authority can exercise full discretion as to whether or not to grant consent and as to what conditions to impose on the consent if granted.

Non-complying

Consent needed and conditions are not restricted

A non-complying activity requires a resource consent before it can be carried out. A resource consent can be granted for a non-complying activity, but first the applicant must establish that the adverse effects of the activity on the environment will be minor or that the activity will not be contrary to the objectives of the plan.

Prohibited

Not allowed

A prohibited activity may not be carried out. In addition, no resource consent can be sought or granted to authorise the activity.

Frequently asked questions (FAQs)

Additional FAQs from drop-in discussions

Below are answers to questions that were frequently asked at our drop-in discussions.

There are a wide range of setback requirements in the draft plan. The setbacks vary, depending on the kind of activity, the level of risk, and the level of environmental improvement required. In general, they ensure that activities or structures that pose a risk to water quality (such as discharges of effluent to land, cultivation, or wastewater treatment plants) do not take place or are not established in a location that is too close to waterbodies.

For farming activities, one of the biggest sources of contaminants is overland flow of water into waterbodies, when that water contains, or has the opportunity to pick up sediment, dung and other contaminants. A setback (preferably vegetated), usually varying in width depending on the slope, is one way to filter out these contaminants. Some higher-risk activities, such as intensive winter grazing and sacrifice paddocks, have large areas of exposed soil in winter, and are a high risk of sediment and dung getting into waterbodies, unless there is some separation.

Typical setbacks for farming activities are:

General stock exclusion: No change from Stock Exclusion Regulations (generally 3 metres).
Intensive Winter Grazing: No change from National Environmental Standard for Freshwater (generally 5 metres.
FMUs where sediment and E.coli are an issue (Taiari, Dunedin and Coast, Catlins FMUs and Lower Clutha rohe): On low slope land – livestock must be excluded 10 metres from the beds of lakes and rivers over 1m wide, 3 metres for all other rivers. This applies to all livestock, including sheep. Where there are existing stock exclusion fences there is a 10yr lead-in period.
FMUs where sediment and phosphorus are an issue (Taiari, Dunedin and Coast FMUs, Dunstan, Manuherekia, Roxburgh rohe): setbacks for cultivation - 5m for land with a slope less than 10 degrees, 10m for 10-20 degrees (no-till permitted within setbacks and for over 20 degrees).

For forestry planting, the setbacks are intended to provide for some protection of water quality at all stages of the forestry process, acknowledging that if trees are setback from waterbodies, related activities, such as harvesting are less likely to occur close to waterbodies. The setbacks will also protect waterbodies from some of the effects of standing trees, such as shading. Within the setback, riparian planting will be able to occur. At this stage the setbacks are 20m for forestry on slopes less than 10 degrees and 50m for above 10 degrees.

We are looking at ways that the setbacks can be refined, while still providing the environmental improvements required and are keen for your feedback on this. For example, this may come with greater emphasis on critical source areas for farming activities, or slash and sediment management for forestry.

The way the rules have been designed mean that if you can't or don't want to meet the setbacks, you can apply for consent to undertake your activity closer than the setbacks state. The consent would put mitigations in place to ensure the risk was adequately managed. We are also looking into whether a Freshwater Farm Plan can be used as an alternative to some of these setback requirements – your feedback on the ways this could work is sought.

Who can I contact for further information?

If you have questions that couldn’t be answered today or you want to get in contact with Otago Regional Council, please feel free to call us on 0800 474 082 and ask for the Land and Water Policy team, or email policy@orc.govt.nz.

Sacrifice paddock is defined in the National Environmental Standards for Freshwater (NES): as an area on which —

(a) cattle are repeatedly, but temporarily, contained (typically during extended periods of wet weather); and

(b) the resulting damage caused to the soil by pugging is so severe as to require resowing with pasture species

The rule has been included because it is an activity that is highlighted in the NES, and in the Environment Court considering Southland’s plan.

Sacrifice paddocks are used to reduce soil damage on large areas of the farm and minimise other risks to the environment and animal welfare. The use of sacrifice paddocks is infrequent and for short periods of time (i.e. as a planned back-up option for bad weather or other circumstances).

Risks associated with sacrifice paddocks are similar to those of intensive winter grazing and pasture-based wintering – pugging, run-off into waterways, devegetation, loss of soil armouring and delays to pasture regrowth.

The time limit (the use of a sacrifice paddock should not exceed a total of more than 60 days in any 12month period) is based on the fifth interim decision of the Environment Court (23 December 2022) on the proposed Southland Water and Land Plan. It is understood that sacrifice paddocks are not used consistently over long periods of time (then it would become pasture-based wintering). Similarly, the size limit (5 ha for landholdings less than 500ha, or 1% or up to 30ha for landholdings greater than 500ha, whichever is lesser) is based on the Southland Environment Court Decision.

We are keen to understand if sacrifice paddocks are always part of an intensive winter grazing operation and can be managed as part of that existing consenting process, or if there is a better way of managing the activity.

We are also keen to hear if the time limits and/or size restrictions are workable for Otago.

Who can I contact for further information?

Questions regarding area-specific rules for dairying

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About the draft material

​Region-wide proposed new rules and regulations

Bed of Lakes and Rivers

Damming and Diversion

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Overview of the chapter, and key changes

Environmental Flows and Limits (Water Quantity)

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Different tools for different places

Freshwater farm plans

Overview and key changes

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Threatened species of Otago

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Overview and key changes

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Clutha/Mata-au

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North Otago FMU

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Frequently asked questions (FAQs)

Why do we need a new Land and Water Regional Plan?

What is Te Mana o te Wai?

How has ORC worked in partnership with mana whenua/iwi on the draft Land and Water Regional Plan?

What are Freshwater Management Units (FMUs) and rohe?

How can the public stay up to date?

Are we making the entire LWRP draft plan public during this round of engagement?

What happened to the feedback that was provided in previous engagement with the community?

What is the next stage in the LWRP?

What do people do if they don’t agree with the draft LWRP?

How has ORC taken an economic lens to development of draft LWRP?

When does the online survey close?

Additional FAQs from drop-in discussions

If I can’t meet the permitted activity rules, do I have to stop doing my activity?

Who can I contact for further information?

Do you think ORC should consider including more activities within the Freshwater Farm Plan, instead of needing separate resource consents for them?

Who can I contact for further information?

Do the setbacks from waterbodies for the activities you undertake make sense? What works/doesn’t work for them on your property?

Who can I contact for further information?

We want to manage silage because of the effects on water quality from runoff. We have suggested two sizes of silage storage (both pits & above ground stacks) and are keen to understand how the suggested sizes – either 250m³ or 500m³ – would impact your farming operation?

Who can I contact for further information?

Why does the draft plan have a rule for a sacrifice paddock when it’s a key part of a winter grazing operation that possibly already has a consent?

Who can I contact for further information?

Why does the draft plan include the phrase “pasture-based wintering”?

Region-wide proposed new rules and regulations

Proposed new rules and regulations for individual FMU/rohe

Strategic Policy Direction