The second half of the irrigation season has presented many challenges with the Scheme being on restriction since early January. Continued periods of restrictions tend to identify bottle necks within the race network, and the Operations team have worked feverishly over the past months to reduce the impact these pose. Once again, we are grateful to those Shareholders with on-farm storage ponds who draw on their own water resources to allow other Shareholders who are reliant on run-of-river to continue irrigating. This demonstrates that the ‘cooperative spirit’ is alive and well across the Scheme.
From experience we know that adding automated gates and gauging weirs at strategic points across the Scheme assists significantly in improving the management of water flow. We are planning to add another five automated gates and a similar number of gauging weirs during the coming “off season”.
WIL Sub-Regional Planning Process and Preparation for Submissions
WIL has been actively involved from the outset in representing Shareholder interests during the sub-regional planning process. In September, the Waimakariri Water Zone Committee (WZC) released the Draft Zone Implementation Programme Addendum (ZIPA) and on 21 December 2019 they released their final version. As reported in the December newsletter, WIL provided feedback to the ZIPA through a formal submission, and this can be found by visiting https://www.wil.co.nz/environment/zipa-feedback/
On 19 February 2019 the Board held a workshop to discuss the core outcomes that should be sought as a part of WIL’s involvement in the sub-regional planning process – i.e. what ‘success might look like’. We also discussed the workstreams that would be required to assist in preparation for the formal sub-regional planning process.
In direct response to the ZIPA, we see WIL working towards a position where the Scheme is seen as a core part of the ‘solutions package’ for the catchment. Currently the ZIPA is heavily weighted towards identifying farming as being the cause of elevated nitrate levels and has proposed changes in farm practices as the solution to reducing those nitrate levels.
An important part in preparing the submission is to agree on a starting point from which nitrogen loss is measured. WIL is of the view this should be the consented limit set in the Discharge Consent CRC184861A issued on 4 September 2018. The next step is for WIL to agree on a nitrate loss regime that is achievable for Shareholders over the next 10 years, with further reductions beyond that date being met through an adaptive management process based on actual evidence versus modelling projections.
An update of the workstreams involved in preparing WIL’s submission can be found by visiting https://www.wil.co.nz/environment/zipa-feedback/
Changes to Overseer
In February this year the OVERSEER software service has been reconfigured and is now called OVERSEER FM. There are two key changes to the service. The first is the introduction of a $200 annual user fee per nutrient budget (NB). The second change is that unlike the existing model, where one farm can have multiple NB’s, under OVERSEER FM each farm can have only one NB at any one time.
Within the OVERSEER FM service for each farm there is provision to have different levels of functionality. These levels are:
There is a provision within OVERSEER FM allowing for farmers to belong to an Organisation, and this facility is relevant to farmers that are part of an irrigation scheme. As WIL is the holder of the Discharge Consent, it is important that WIL has Organisation status to enable WIL to meet its consent requirements. This will allow WIL to act as the ‘Administrator’ which will include setting up and managing the account for all WIL farms with FEP’s.
WIL is currently arranging help for Shareholders to make the changeover to OVERSEER FM which will require all previous NB’s that have been provided to WIL to be entered into OVERSEER FM to ensure the historical data is not lost. It is vitally important that you do not set up an account with an organisation other than WIL. Paul Reese will be in contact with you individually over the next month with more detail on how to organise the changeover of your account to the new platform.
Annual Nutrient Budgets
As part of Consent CRC 184861 (To Discharge Contaminants to Land) WIL is required to report to ECan the total annual loss of nitrogen from all properties within the Scheme, and on the annual average nitrogen loss to water for each property listed in Schedule A and Schedule B.
In agreement with ECan, WIL is only required to prepare annual NB’s on properties with over 20 hectares under irrigation which is the threshold point for an FEP. There are 108 such properties on the Scheme.
WIL is required to report annually on 30 November on nutrient losses. Unfortunately, for the past 3 years there has only been a response rate of between 50% and 60% for properties within the Scheme. This is WIL’s only available data collection tool to meet targets and track loss reductions, and this simply cannot be achieved with the poor response rate we have had to date.
We are not meeting our Consent requirements, and it is only a matter of time before we will be recorded as “non-compliant”. NB’s that are being received also show inconsistencies in data collection and inputs. None of this is helpful, particularly when WIL is trying to put together a compelling case to ECan and other regulators.
In the initial years, despite Shareholders best efforts, there were not enough registered OVERSEER practitioners to complete the NB’s, however, this is now not the case. In the past WIL has not stressed the importance of getting the NB’s completed and receipted in a timely manner, but more emphasis needs to be placed on this. As a comparison, some irrigation schemes are making delivery of irrigation water subject to the NB’s being completed at least 2 months prior to the individual scheme’s consent reporting date.
The current compliance regime is totally reliant on NB’s as the basis of measurement for recording Nitrogen Loss at a catchment wide level. The associated consent risk to WIL is too high not to take this matter seriously. The upcoming Plan Change will require all properties in the next 10 years to make significant Nitrogen loss reductions. This means that the ‘load’ recorded today will be our starting point, so it is important that the individual NB’s used to make up the aggregate Nitrogen load for the Scheme are prepared on the same basis.
WIL has previously discussed with Shareholders that we believe the most effective way of resolving this issue is going out to a single provider to complete the NB’s for all FEP farms across the Scheme. This will help provide consistency and accuracy, and ensure the NB’s are completed on time. We recognise that Shareholders have existing relationships and taking this option away might be considered a step too far. However, doing nothing is not resolving the issue.
WIL is considering going out to the market with a transparent ‘Request for Proposal (RFP) for a single provider solution under a competitive tender. However, other possible options available are:
It is important that we have the support of Shareholders on this matter. In early April in a separate correspondence, we will be inviting Shareholders to provide comment on the single provider solution as well as other options.
At a minimum WIL is considering introducing a policy making the delivery of irrigation water subject to the annual NB being completed by 1 September of each year.
WIL has just finished running a series of workshops asking Shareholders to share their experiences using the Regen service. The meetings were well attended, and the feedback received was constructive. Independent facilitator Christina Robb will compile a report based on the feedback received, and this report will be sent out to Shareholders in the coming weeks along with our proposed action plan.
WIL have negotiated a contract with Water Strategies to continue Paul’s services to WIL as its Environmental Manager, and therefore it is business as usual.
Paul will be supported by Elenore Dumaine who is acting as Environmental Administrator for Water Strategies. Elenore will carry out the audit correspondence and notifications to support the auditors. All communications will still come from the firstname.lastname@example.org email.
Paul will be concentrating on providing Shareholders with support ahead of audits and in other areas to help farmers to meet and exceed GMP. Dugald McLean will continue to complete audits and will be assisted by other ECan certified auditors.
If you have any questions or suggestions about this newsletter, please do not hesitate to contact me on 0220 869986 or at email@example.com