Minor adjustments to some compliance inspection frequencies
It is proposed to amend the inspection frequencies for two compliance categories, specifically the physical site visit component. These changes affect only Schedule 2A Variable (also known as Actual and Reasonable) compliance categories (refer to Table 2 below).
The proposed changes reflect the risk associated with each compliance category, based on officer experience and compliance reporting data. Since these are currently on an actual and reasonable basis, the impact of this change is relatively minor.
Each of the compliance categories proposed for amendment also have a high Performance Monitoring (PM) component to them. The proposed changes do not affect the PM management component of the monitoring.
Table 2 - Compliance inspection frequency proposed changes
| Schedule 2A - Consents subject to variable compliance monitoring charges | |||||
| Compliance Category | Code | Current Frequency | Proposed Frequency | Description | Rationale |
| Consumptive Water use with 5 or more Abstraction Points with Manual or Telemetry Water Use Record Submission, or any Consumptive Water Use with additional use management | CWMX | As required | 5 yearly | Water use record compliance on a regular basis and additional or more frequent compliance monitoring e.g. when flow restrictions require cease-take compliance, or non-concurrent use, water quality sampling etc. | These takes are still monitored closely though the submission of regular PM records and reports. A five-yearly inspection frequency is consistent with most other consumptive water take consents. Although manual records generate more staff time spent on administration, it does not impact the onsite performance of the individual abstraction points. Therefore, it is considered appropriate to align the site inspection frequency of this category with the telemetered takes i.e. 5 yearly. |
| Hydro Dams | Hydro | 1 yearly | 3-5 yearly | Large hydro schemes are generally well managed, however, impact of non-compliance can be very significant. | Hydro schemes infrastructure is closely monitored and managed by the scheme owners. Compliance site inspections rarely highlight onsite issues. All hydro schemes have a heavy PM reporting burden, which are closely monitored by the compliance team. Therefore, it is considered appropriate to reduce the site inspection frequency of this category down to 3-5 yearly. |
