The council investigated water takes in the Taieri catchment, upstream of Kokonga, during the 2008-09 irrigation season, finding 55% compliance.
Of the 135 takes, excluding irrigation companies, 90 were inspected in the Maniototo area between August and March to assess compliance of their location, purpose and metering conditions.
All were compliant with their purpose - 68 were used for irrigation, 57 for stock water and 10 for others such as domestic use.
Environmental services manager Martin King said in a report that when it came to location, 69% were compliant (within 100m of the map reference on the consent) and 22% were deemed compliant, even though they were more than 100m away as they were on the correct property and waterway.
However, three takes were non-compliant.
One water take was more than 100m out, on a different property and did not match up with any previous descriptions from mining privileges or resource consent applications.
Another three were not located correctly because of confusion over where they should be located.
The biggest cause of non-compliance was the lack of installed measuring devices and lack of record keeping, Mr King said.
Of the 41 consents which required monitoring of the water take and supplying records to the council, only 13 had a measuring device installed.
It was recommended that non-compliant consents be re-inspected after September 1 to assess compliance and "carry out enforcement action if necessary", Mr King said.
It was also recommended that issues of late provision of records be followed up, consent holders be required to install measurement devices by September 1, 2009 and that those with the most serious non-compliance have to apply for a variation or new consent.
Council resource management director Selva Selvarajah said at a recent committee meeting that while no legal action was being considered at this stage, the number of properties where the location had shifted substantially was a "significant concern", as was the number who did not have water meters.
While many of the consent holders were not required to have a meter, those with mining privileges were required, under the Water and Soil Conservation Act, to report their water use, he said.
Cr Duncan Butcher said given many of the takes originated from the 1800s when maps were often "crude pencil marks", 100m could be difficult to interpret.
"We need to look at all circumstances so that the 100m is not too arbitrary."
Mr King said the council did consider individual cases, but there were situations where takes were 2km out or in different catchments.
