Council chairman Stephen Woodhead is urging farmers and other water users to deal with that permit backlog sooner rather than later.
"The deadline is the deadline," Mr Woodhead said.
Getting consents organised in a timely way would give farmers "certainty" about their water supply consent. That certainty was ultimately critical for planning and running a farming business, he said.
"From a business owner’s perspective, I can’t stress enough the need for certainty" and dealing with the consent issue, he said.
Such deemed permits arose from 19th-century gold-mining operations, but by 2021 they must be either surrendered, or replaced by updated consents under the Resource Management Act, or they will expire.
An expiry could deprive current permit-holders of the right to draw water.
Figures tabled at a council regulatory committee meeting in November show that 402 deemed permits remained to be dealt with, as of early November — down from 458 permits in April 2014.
These figures highlight the challenge ahead, and show that if permit numbers came down at only a similar rate to the past two and a-half years — by about 50 — a backlog of several hundred permits would remain when the deadline was reached.
These figures also indicate that deemed permits would have to be dealt with at more than three times the current rate, in order to meet the deadline.
An updated Water Users’ Handbook, issued by the ORC in April and available online via www.orc.govt.nz, urges water users to apply for updated consents by November 1, 2020, rather than waiting until the 11th hour.
Errors or incomplete information in a consent application submitted after the start of November 2020 could result in the right to take water being lost.
A November report by director policy planning and resource management Fraser McRae showed deemed permit numbers were "slowly decreasing", through the impact of water measuring regulations, and some cancellations, surrenders and consent replacement.
Mr Woodhead did not want to see irrigators and the ORC "getting into a situation" where matters had been left too late, and there was insufficient time to deal with the potentially complex issues involved.
"If you start the process too late you potentially run the risk of limiting the various options," he said.
At a recent council meeting, councillors heard suggestions that some water users were receiving legal advice, often, apparently from North Island lawyers, to delay updating the permits.
The meeting heard ORC staff had been networking positively with Otago lawyers over deemed permit issues.Council staff have been helping to develop collaborative groups of water users, and to communicate permit requirements.
Mr Woodhead was optimistic the permit backlog could be cleared and said many farmers were working collaboratively towards meeting the deadline.
He said there was no need to panic, but "there’s still 400 to go".
