What is a Comprehensive Stormwater Consent?

    TheBayofPlentyRegionalStormwaterStrategy2005aidsacollaborativeapproachbetween the Bay of Plenty Regional Council (BOPRC) and Western Bay of Plenty District Council (WBOPDC) within the Bay of Plenty to better manage urban stormwater in the district to improve water quality and protect our waterways.

    The strategy requiresTerritorial Authorities to obtain stormwater discharge consents for their urban areas in a comprehensive way and to establish Catchment Management Plans that describe any stormwater management initiatives and controls to be implemented.

    A Comprehensive Stormwater Consent (CSC) is an approval from the Bay of Plenty Regional Council to undertake any stormwater related activities for an entire urban catchment or a group of urban catchments for which the application was made.

    Western Bay of Plenty District Council was granted a CSC Authority for Omokoroa in 2005 and is currently applying for an other three urban catchment groups (Western, Central and Eastern Catchments)to cover the entire District.

    What is the purpose of this consultation process?

    A Comprehensive Stormwater Resource Consent (CSC) is being applied for by WBOPDC in order to better manage stormwater related activities.

    Stakeholders from a wide variety of interest groups have been identified and are invited to consult on the CSC Application and the associated draft Catchment Management Plan.

    The purpose of consultation includes:

    • Meeting the statutory requirements (to follow consultation processes defined in the RMA).
    • Communicating (to provide stakeholders with key messages of the consentprocess).
    • Informing (to provide balanced information to people who may be affected by the consent so that they understand the issues, any decisions to be made, to increase awareness of sustainable development and to empower the community over their immediate environment).
    • Listening (to learn how external parties view the project,
      its risks, impacts, opportunities and mitigation measures and to gain a better understanding of the cultural views and values within the catchment).
    • Identifying (to define resource management issues, potential effects and ways to resolve them).
    • Reporting (to document consultation activities and their outcomes).
    • Incorporating (to integrate stakeholder feedback in to the final CMP where appropriate).

    Why is WBOPDC applying for a Comprehensive Stormwater Consent?

    Currently WBOPDC holds over 200 stormwater related Resource Consents with BOPRC,
    all of which cover different activities, rules and monitoring requirements.They all have expiry dates and have to be renewed at different times. The cost and logistics of managing those multiple consents is draining valuable resources. With the CSC’s inplace,WBOPDC will only have to manage four stormwater related consents district wide, which is far more efficient.


    What is stormwater?

    Stormwater is water that originates during rainfall events. Rain water that does not soak into the ground where it falls becomes surface run-off.This run-off travels by gravity along natural flow paths in to waterways. Due to development, the natural flowpaths have been altered and now the majority of the urban stormwater is conveyed via manmade stormwater systems. Stormwater is of concern for two reasons, stormwater quantity issues and stormwater quality issues. If not managed correctly, the volume and timing of the surface run-off can create flooding. The run-off can also collect contaminants from the land it travels through to the waterways, which can result in water pollution.


    What is Stormwater Management?

    The term “stormwater management” covers all those activities that actually or potentially affect the quantity and quality of surface run-off and provide opportunities for avoiding or mitigating the adverse effects of stormwater on the receiving environment.

    Who is responsible for managing stormwater?

    We are all responsible for managing our own stormwater and ensuring that we protect the water quality of our local waterways by addressing any potential sources of pollution on our properties.

    However, there are a number of current statutory and regulatory requirements that deal with stormwater management and set out the overall responsibilities for managing stormwater.

    The main drivers are:

    • The Resource Management Act 1991 (RMA) whose purpose requires those with functions, powers and duties under it to drive the “sustainable management” of our natural resources (like soil and water) and physical resources (including stormwater assets).
    • The Local Government Act 2002 (LGA) which requires local authorities to take a “sustainable development” approach and take into account the social, economic and cultural interests of people and communities.
    • The Building Act 1991 (and consequently the Building Code) which requires that all building work is adequately protected from flooding and that the effects of new developments do not worsen any existing flooding downstream.

    The RMA (Part 4) sets out the functions, powers, and duties of central and local government.

    As such it gives the Regional Council:

    “(c) the control of the use of land for the purpose of -

    (i) soil conservation:

    (ii) the maintenance and enhancement of the quality of water in water bodies and coastal water:

    (iii) the maintenance of the quantity of water in water bodies and coastal water:

    (iiia) the maintenance and enhancement of ecosystems in water bodies and coastal water:

    (iv) the avoidance or mitigation of natural hazards:

    (v) the prevention or mitigation of any adverse effects of the storage, use, disposal, or     transportation of hazardous substances:

    (f) the control of discharges of contaminants into or onto land, air, or water and discharges of water into water:”

    In 2005 the BOPRC released the Bay of Plenty Regional Stormwater Strategy with the intent to better manage urban stormwater and protect our waterways.

    BOPRC also provides significant direction through planning documents like the Bay of Plenty Regional Policy Statement, Bay of Plenty Regional Coastal Environment Plan and the Bay of Plenty Regional Water and Land Plan, which state objectives and rules in regards to stormwater management.

    BOPRC’s technical guidelines are designed to help local authorities as well as private property owners to better manage their stormwater. Hence, stormwater management can be divided into public stormwater systems and private stormwater systems.

    What is a public stormwater system?

    There are a number of public stormwater systems which WBOPDC is responsible for. These systems provide for the collection and conveyance of stormwater from roads and developed areas.

    Typically run-off from urban areas (such as roads, driveways and properties) is collected via kerb and channel and catchpits. It is then conveyed through a limited piped network and/or open drains to discharge to land, streams or coastal margins.

    These systems are designed to manage stormwater quantity and prevent flooding to an agreed level of service.

    In recent years the public stormwater systems have also been designed to manage stormwater quality. The public assets now include swales, retention ponds and wetlands.

    All public stormwater systems have to comply with the requirements of BOPRC’s planning documents and may require a Resource Consent.

    The Comprehensive Stormwater Consent Application is for all public stormwater systems within the identified urban catchment areas and includes some of the private stormwater systems (see below).

    What is a private stormwater system?

    A private stormwater system is where stormwater is managed and disposed of by the property owner.  Run-off is collected on-site and either fed into the public stormwater system (where it exists) or
    discharged directly to streams or ground soakage.Private stormwater run-off may be reduced where roof water is collected for drinking water or other purposes.Private properties also need to comply with the requirements of BOPRC’s planning documents.

    A private stormwater system which is discharging to the public stormwater system also needs
    to comply with any Resource Consent rules of that system.The Comprehensive Stormwater Consent will set out area based rules rather than outfall-based rules, which is currently the case.

    If your property lies within the identified urban catchment areas and discharges into the public stormwater system, then the stormwater run-off from your property will be included within the CSC.  However,WBOPDC will produce a Stormwater Bylaw which will outline the rules to comply with, once the CSC has been granted.

    The CSC will not authorise any private stormwater discharge that does not enter the public
    stormwater system.Should these private stormwater discharges exceed the trigger values of
    BOPRC’s planning documents, then an independent Resource Consent from the BOPRC has to be applied for by the property owner.

    Properties with industrial land-use will have to apply for independent Resource Consent from
    the Regional Council prior to discharge. Proof of compliance with the Resource Consent has to be forwarded to WBOPDC’s Compliance team if the discharge feeds in to a public stormwater system.

    What is a Catchment Management Plan?

    Catchment Management Plans (CMP) are non-statutory plans, which can be prepared to manage stormwater related issues within a catchment.

    The CMP’s identify:

    • Relevant information about the urban catchment in question.
    • Water Quantity Management Issues.
    • Water Quality Management Issues.
    • Values/Threats to community interests (e.g. environmental, social, cultural and economic).

    These provisions will be given effect through the CSC process and the findings may be incorporated in the District Plan, Asset Management Plan and/or Annual Plan and potentially in the Development Code.

    An extensive planning process has been undertaken for the preparation of the Draft CMP’s, which incorporates the following:

    • Describes the scope/purpose of the CMP.
    • Identifies Stormwater Related Activities to be covered/excluded from the CSC.
    • Identifies management objectives.
    • Identifies the legislative background and key stakeholders.
    • Describes the catchment.
    • Identifies existing catchment conditions.
    • Identifies values of the catchment.
    • Identifies threats to these values.
    • Identifies management issues/causes.
    • Identifies potential management options.
    • Presents recommendation for performance monitoring.

    What are we doing to plan for current an future demand?

    WBOPDC has taken a proactive approach and is proposing to review the hydraulic models for each urban area to analyse the current and future capacity needs of the public stormwater systems based on the agreed Level of Service over the next five years.

    The results will be used to identify any capital and renewal projects necessary to remedy maintenance and capacity issues.

    What impact has the CSC on my property?

    The day to day management of the existing public stormwater assets will remain the same, however there will be increased planning and monitoring as part of the CSC. Once planning has concluded there might be a need for additional assets in order to fulfil the agreed level of service, as well as improve the stormwater quality.

    The main changes are around the enforcement of responsibilities for, and controls of the urban stormwater. As such the Regional Council will give more powers to WBOPDC, but this will require increased monitoring of stormwater quantity and quality by both organisations. WBOPDC will have to ensure that private stormwater management systems (if they discharge into the public system) comply with the requirements of the CSC. This will be achieved through a new stormwater bylaw.

    What is the financial impact?

    The reduced number of consents will provide some cost savings to Council. Regardless of the CSC there will be costs associated with the management of stormwater quality, which previously had not been a core focus. Council has already allocated funds in their Long Term Plan for stormwater quality improvements.