DCC counsel Michael Garbett made the case on Monday that an overall plan for three waters assets should guide resource consent decisions.
Speaking to commissioners hearing submissions on the freshwater parts of the proposed Otago regional policy statement, Mr Garbett said it was important to recognise the three waters network around Dunedin was a complex one that had been established over the past 150 years.
"It is physically and financially impossible to upgrade all aspects of these systems at once," he said.
"Resource consents for components of these networks come up for renewal at various times in the future, depending on when they were granted, and their respective terms.
"A co-ordinated strategy ... is the best way to plan upgrades where they can best deliver results for the environment, mana whenua, DCC and its customers or ratepayers."
In its present 2021-31 long-term plan, $561 million in spending had been allotted to upgrade three waters assets over a 10 year period, he said.
Drinking water was provided to more than 40,000 properties through more than 50 resource consents.
Stormwater was reticulated from over 40,000 properties, discharges consented into the Otago Harbour, Pacific Ocean, and to land where it could enter Tomahawk Lagoon, he said.
Wastewater was reticulated from over 40,000 properties and treated in seven wastewater treatment plants that relied on 15 resource consents, he said.
If the regional council’s high-level planning documents referred to a co-ordinated strategy for the provision of three waters services it would ensure resource consent decisions took that strategy into account, he said.
Council three waters planning manager Zoe Moffat said the city council had been working on its system-wide three waters investment plan since 2019.
The council would plan for two more years of work before three waters reform took effect.
At that time, in 2025, three waters provision was due to be taken over by the water services provider now dubbed "Entity J", she said.
Additionally, Mr Garbett argued the city council’s water take for providing drinking water for the Dunedin area should be afforded a priority status.
As water that was provided to meet drinking-water standards, it related to the second tier of Te Mana o te Wai’s hierarchy of obligations, people’s health needs, he said.
The hearing continued in its fifth day with commissioners listening to submissions from City Forests, Contact Energy, Beef + Lamb New Zealand and Deer Industry New Zealand.
In June 2021, the council publicly notified its proposed regional policy statement.
However, a High Court decision required it to be separated into two parts — freshwater and non-freshwater.
The non-freshwater hearing has already taken place.
The freshwater hearing is in its second of two scheduled weeks.
The regional policy statement is a foundation document for the council’s land and water plan.
It is supposed to be operative before the land and water plan is notified.