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In its submission to the ORC, the Queenstown Lakes District Council says it is of ''significant concern that the ORC has failed to take into account and plan for peak visitor numbers as opposed to average visitor numbers''.
The submission is signed by Mayor Jim Boult and chief executive Mike Theelen.
QLDC figures show that on an average day, the district has 24,861 visitors, and on a peak day 79,301.
Adding in the ''usually resident'' population of 38,048 gives a total peak-day population of 117,349.
Dunedin's usually resident population is 120,249.
The ORC is predicting a 2.6% annual increase in the Queenstown Lakes resident population and a 2.4% annual increase in visitor numbers.
Its 10-year plan does acknowledge the growth will impact on its ''level of activity'', particularly public transport, resource use, civil defence, environmental incidents and ''local democracy''.
But the QLDC's submission asks the ORC to ''revisit'' its population projections, replacing ''average visitor day numbers with peak numbers''.
''This will require the subsequent reassessment of all provisions planned for the [district] to ensure that sufficient resources and activities are planned and allocated to meet demand.
''If the ORC does not revisit the population projections, the premise for investment and level of service in the [district] will be flawed.
''This will place the achievement of key outcomes, goals and strategic priorities at significant risk.''
The submission also takes the ORC to task over ''inadequate'' emergency management provisions, with the ''entire'' Otago regional response group based in Dunedin and just one emergency management officer covering the Queenstown Lakes district.
''In the event of an Alpine Fault rupture, Queenstown Lakes district will be the most significantly impacted part of the Otago region.''
The QLDC submission also calls for more ORC involvement in wastewater schemes in smaller communities, in the provision of housing infrastructure and in the control of wilding pine.