Actual and Reasonable Water Use – Preliminary Advice, December 2023

Posted By HBFA | December 22, 2023

In a nutshell, ‘Actual and Reasonable’ use is a maximum annual volume that will be specified on the water permit that the regional council is currently processing, and that number cannot be more than the volume specified on your expiring water permit, or a smaller amount if you applied for less water AND if either of these numbers are available, the smaller of these numbers then the maximum annual volume of water taken and recorded by an accurate water meter between May 2010 and May 2020; or for irrigation takes, the crop water requirement calculated using IRRICALC (which assumes 80% efficiency and a 95% reliability of supply).

So what does that mean in practice?

Irrigators that don’t have accurate water meter data from 2010-2020 will likely be allocated the smallest volume of water, of either what their expiring consent allowed, or the crop water demand calculated by IRRICALC. You can access it here: Irrigation Requirements (mycatchment.info)

Growers whose maximum annual water use between May 2010 and 2020 is less than the crop water demand calculated by IRRICALC, would likely be allocated the maximum annual volume taken.

Some growers may not be allocated the same volume of water they have been previously. Below are some examples of what your numbers could look like, and what that could mean for the volume of water you are allocated in your new water permit:

Why is this happening now?

Despite repeated requests from the Primary Sector to delay this until after Christmas when more support will be available to help everyone work through this, and what it means for them, HBRC have chosen to push ahead with this. Apparently, they are getting multiple requests to hurry up and make progress, and now that they have the information and a system for providing it, they believe the most transparent and useful thing they can do is to get it out to people as soon as they can.

What happens if I don’t agree with my actual and reasonable volume?

You need to go back to the council and explain why you don’t think your volume is appropriate. You don’t have to do this straight away, but when you do, you will need to explain why you think a bigger volume is appropriate in your case, and you will need to provide some evidence to explain/support the bigger volume. There will be many different scenarios, but here are a few to help start people’s thinking about reasons why they could potentially justify a bigger volume than the actual and reasonable number:

* Have you changed your crop/s and now grow crops that require more water?

* Did you have an old orchard and have redeveloped part/all of it, so have younger trees which require more water?

* Have you installed soil moisture monitoring equipment and use that information to guide your irrigation?

* Did you have telemetry installed early in the 2010s? There were some issues with data transfer between some of the early water meters and telemetry units that were installed. Water meters were accurate, but data recorded by the telemetry unit was in some cases an order of magnitude more (those were picked up by HBRC) but some may also be an order of magnitude less. If you think this might have impacted your water record, request your detailed water meter record from HBRC if you don’t have it easily accessible yourself and look to see if anything stands out as being odd.

* If you were impacted by the cyclone, council has indicated that they are willing to delay the impact of any reduction in water allocation. 3 years is the time period they have indicated they may be willing to delay. If this would help you, you would need to explain why – for example, your orchard has been removed, you have planted process crops as won’t be able to get rootstock for at least 3 years, so need to retain your full allocation.

Something to also be aware of is that Council has indicated that if you do not accept the actual and reasonable volume they have calculated that your application will be publicly notified, which will increase the consent processing cost compared an application that is not notified.

What happens if I am not sure if my number is ok?

Sit on it. Council won’t do anything until they hear back from you either way, so there is no rush to decide. Talk to people about it – neighbours etc who are going through the same process, industry people, product group people, the council. Ask questions and get as much information as you can to enable you to make an informed decision.

 If I accept my number, what consent term am I likely to get?

Council has indicated that it is likely to be 10 years, but there will be exceptions to this.

If I am happy with my proposed allocation what should I do?

Email the council on waterpermits@hbrc.govt.nz and confirm that you are happy with your actual and reasonable volume. Request draft consent conditions before your permit is issued so that you can see the whole proposed consent – all of the conditions, consent duration etc so that you know exactly what you are agreeing to.  Council has indicated that these applications will be processed non-notified, so they will just need to work through their internal process, and then your consent would be granted.

HBRC contact information

You can ring through and ask to speak to a Consents Officer about your Heretaunga Plains water take. The mainline is 06 835 9200. You can also email waterpermits@hbrc.govt.nz. And there is also FAQs and some further information on the website www.hbrc.govt.nz and then in the search box type #HPwatertake FAQ

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