28 February 2011 - waikatoregion.govt.nz · the growth in demand and then secondly a gradual reduction in energy demand until it reaches a level that can be sustained by renewable

1

c/- Emma Wright

Environment Waikato

P.O. Box 4010

HAMILTON EAST.

28 February 2011

Chief Executive

Attention Policy Group

Environment Waikato

P.O. Box 4010

HAMILTON EAST

Dear Sirs,

Please find attached the submission of the Advisory Committee for the Waikato Regional

Environment to the Proposed Regional Policy Statement.

We thank you for the opportunity to participate. Our submission is sent by email due to time

constraints. Any queries please contact me directly on 07 864 7223 or by email at

[email protected].

Yours sincerely,

ADVISORY COMMITTEE FOR THE WAIKATO REGIONAL ENVIRONMENT

Joyce Birdsall

Chair

2

SUBMISSION FORM

Submission on the proposed

Waikato Regional Policy

Statement (November 2010)

Full Name of Submitter: Advisory Committee for the Waikato Regional

Environment.

Contact Person: Joyce Birdsall, chair

Full Postal Address: C/- 22A Paku Drive Tairua 3508 ph.07 864 7223

We do wish to be heard in support of our submission.

Total number of Pages 25

Signature

Date 28 February 2011

General Comments:

ACRE has been very impressed with the quality of this document. We acknowledge the

enormous amount of work that staff have put into its preparation and congratulate

them on a superb effort.

We are pleased to see the 100 year time frame and the intention to keep checking at

the five year level to see that policies are working. Given the rate of change in today’s

world the RPS and Regional and District Plans will need to be able to be changed quickly

to deal with policies that are not working or unforeseen occurrences.

We found the document clearly set out and particularly liked the boxes referring back to

the relevant objectives or issues. We realize it is not easy to group the various policies

3

under the appropriate chapters and we wonder if relevant policies in other chapters

could also be referenced in a similar way. Given the size of the document there will be a

tendency for members of the public to go to the relevant chapter and miss the policies

in others. For example, on initial reading of chapter 7 Coastal Marine area we found the

policies quite thin. However, reading the whole document we found policies in

Integrated Management, Built Environment, Indigenous Biodiversity, Landscape natural

character and amenity and others which covered some of the areas we felt were

missing.

ACRE is supportive of almost all of the issues, objectives and policies in the document

and our comments are mostly about areas where we felt some improvement in wording

is required.

Specific Comments

PART A ISSUES

Pg 1-1 Issue 1.1 State of Resources

ACRE agrees in part with this issue.

We recommend re-wording this issue to State of Natural Resources.

1st

Paragraph: Suggest changing the last sentence to read “…reduces our ability to

provide for the well-being of current and future generations.”

c) Change to: effects of sedimentation and nutrients in estuaries and harbours

and on marine ecosystems.

d) Change to: indigenous biodiversity decline including both loss and degradation of

natural ecosystems and indigenous species

e) Change to: increased demand for use of the Coastal Marine area for

aquaculture, energy development and sea floor mining.

The “potential for conflicts between activities” is not the issue, rather the increased

demand for use of the coastal marine area.

Pg 1-2 Issue 1.2 Effects of climate change

4


We recommend adding the following item:

c) increased risk for significant impacts to primary production resulting from

increased frequency and magnitude of extreme climatic events such as droughts,

frosts, heat waves, etc.

Pg 1-3 Issue 1.3 Providing for energy demand


Explanation

We would like to see discussion here about management of energy demand rather than

simply catering to ever increasing energy demand. This would require firstly a slowing of

the growth in demand and then secondly a gradual reduction in energy demand until it

reaches a level that can be sustained by renewable resources. Note that increases in

efficiency of energy use do not by themselves lead to a reduction in total energy used.

Increased energy efficiencies often lead to lower costs that can actually spur increased

energy use.

Pg 1-4 Issue 1.4 Managing the built environment


We suggest adding the following matter:

e) gradual depletion of mineral stocks that will eventually lead to increasing costs

and therefore reduced availability of essential mineral resources.

Issue 1.5 Relationship to tangata whenua with the environment (te

taiao)

Pg 1-5 ACRE agrees this issue.

Pg 1-6 Issue 1.6 Health and wellbeing of the Waikato River


ACRE wholeheartedly supports the co-governance of the Waikato River and the Waikato

River Bill. However, given the emphasis on the Waikato in section 2, we submit that this

5

issue 1.6 should be about all rivers, not simply the Waikato. The rivers of the Hauraki

Plains are equally stressed and development pressures have also impacted on them.

Issues facing the Waikato should not overshadow the very real issues for other rivers.

We suggest this issue and the explanation be reworded to encompass all rivers in the

region.

3 Objectives

Pg 3.1 3.1 Integrated Management

ACRE supports this objective.

We recommend the following change:

Add an additional item

f) The built environment including infrastructure.

The built environment has a significant impact and inter-relationship with the natural

environment.

Pg 3-1 3.2 Decision Making

ACRE supports in part this objective


Add an additional item at the beginning of the list

a) natural resources are limited and cannot be used faster than their natural rate of

regeneration

Pg 3-1 3.3 Health & Wellbeing of Waikato River


Pg 3-3 3.4 Energy



e) Change to: Avoids or minimizes adverse effects on natural and physical resources.

6

This is consistent with S5(2)(c) of the RMA.

Pg 3-4 3.5 Adapting to Climate Change



Add an additional item

g) primary production

Pg 3-4 3.6 Coastal Environment

ACRE supports in part this objective.


b) Again the issue of conflict between uses and values is addressed (see comments

issue 1.1). There are continual conflicts between uses and values whether use

takes place on land or in the coastal environment and we do not see the need to

raise this as an issue in the coastal environment.

Pg 3-5 3.7 Ecosystem Services


Ecosystem services are fundamental to all life but are not well understood by the

general public. ACRE would like to see this objective spelt out more clearly as follows:

Ecosystems are managed sustainability to insure the continued availability of services

required to meet the needs of both present and future generations. This includes

provisioning, regulating, and cultural services that humans use directly and the

supporting services that underpin them.

Pg 3-6 3.9 Efficient use of Resources

ACRE opposes this objective.

Continued use of any finite resource, no matter how efficient, means that eventually

that resource will be depleted. This is exemplified in the case of Lake Taupo, in which

the capacity of the watershed to receive nutrients and maintain water quality at a

7

desired level is limited. Hence the need for nutrient caps. We recommend changing the

objective as follows:

Sustainable Use of Natural Resources

Use and development of natural and physical resources occurs in a way and at a rate

that is sustainable based on our best understanding of natural rates of regeneration,

including efficient use and minimizing generation of waste.

Pg 3-6 3.10 Air Quality


Pg 3-7 3.11 Built Environment


Pg 3-7 3.12 Mauri and health of marine waters

ACRE opposes this objective.

Marine waters need to be given the same level of protection and enhancement as fresh

water bodies. This policy needs to be reworded along the same lines as objective 3.13

Change to: The mauri and health of marine waters is protected by:

a) Recognising and maintaining the following values:

i) natural character and natural functioning;

ii) health and functioning of biodiversity, ecosystems and habitats

iii)Harvesting of marine food species and kai moana that is safe to eat; and

iv) recreational values including swimming.

b) Protecting the value of all marine water bodies to preserve those with high values

and to ensure those already degraded are not subjected to further degradation.

c) The adverse cumulative effects of land use activities on water in the coastal marine

area are reduced.

d) providing the above values are not compromised, enabling people and communities to

provide for their social, economic and cultural wellbeing and for health and safety.

8

Pg 3-8 3.13 Mauri and health of Fresh Water Bodies


We agree with a) and b) and recommend the following changes to c) and d):

c) Change to: Protecting the values of all fresh water bodies to preserve those with

high values and to ensure those already degraded are not subjected to

further degradation.

We need to afford a degree of protection to already degraded water bodies as well to

ensure they are not degraded further.

d) Change to: providing the above values are not compromised, enabling people and

communities to provide for their social, economic and cultural wellbeing

and for health and safety.

Objective d) needs to be strengthened to ensure it does not negate all the values

expressed in a), b), and c).

Pg 3-8 to Objectives 3.14 to 3.25

3-13 ACRE supports all of these objectives.

PART B – POLICIES

4 Integrated Management

Pg 4-1 Policy 4.1 Integrated Approach

ACRE supports in part this policy and implementation methods.


a) Change to: Recognises the finite and inter-connected nature of natural and physical

resources (including spatially and temporally);

9

ACRE supports the submission of the Waikato Biodiversity Forum that this policy is

amended to include recognition of the value of working with community/landowners to

achieve integrated catchment management.

Pg 4-1 4.1.2 Land use change

We are pleased to see the use of will manage in this policy and support clauses a), b)

and c). We recommend changing d) to:

d) Change to: Implementing rules for managing large scale land use change including:

We are concerned that the use of “investigating” signals a long period of policy

development prior to any effective management options being put in place. The adverse

effects of land use change and intensification are severe and are occurring now.

Pg 4-2 4.1.4 Plans and Strategies

a) ACRE is not sure what this actually achieves. An “appropriate scale of

management” is very subjective and open to all sorts of interpretations depending on

the viewpoint of the reader.

b) ACRE supports the proactive nature of b).

Pg 4-2 4.1.5 Environmental management plans

The development of environmental management plans and should be mandatory as

part of the resource consenting process. While such plans are particularly important for

farming, we support the development of plans for all land uses. Again we are concerned

that the use of “investigate the benefits of and options for” and “further investigated

and discussed as part of the review of the WRP” signal a very long time frame for what is

an important and urgent initiative.

Pg 4-2 4.1.6 Advocacy and education

a) to f) ACRE agrees with the educational values expressed. However this is a

very slow process and it may take a generation to change the thinking of

land users – time which we do not have. While the education process is

important a degree of compulsion will be necessary to ensure land use

practices are improved now.

10

g) We are pleased to see a commitment to becoming involved in the plan

submission processes of territorial authorities. We believe it is also

important that Environment Waikato submits to resource consents

where there is significant land use change particularly in coastal, sensitive

areas and where soils may be of high quality or contaminated.

Change to: making submissions on the long term plans, annual plans

and significant resource consent applications of territorial

authorities to seek the appropriate allocation of resources

to give effect to the RPS and protection to sensitive areas

Pg 4-2 4.1.7 Managing the coastal environment

This is a very important area not handled well by many territorial authorities. ACRE

supports the values listed but considers the use of “should” too soft. We note that

policy 4.1.8 uses “shall” and that would be more appropriate here. There has been

considerable pressure on the coastal environment in recent years and the wording in

this policy does not go far enough to give us any comfort that there will be any

improvement.

Pg 4-3 4.1.8 Identifying extent of the coastal environment

We particularly support the mapping of the coastal environment. Urgent action on

property level maps will greatly assist at Council and Environment Court hearings.

Pg 4-3 4.1.11 Economic Instruments

b) We particularly support remission policies where people “do the right thing.”

Pg 4-4 4.1.12 Offsite mitigation of adverse effects

ACRE suggests that this is an important method that requires a clear directive to local

authorities and therefore recommends that “should” be changed to “shall.”

Pg 4-4 4.1.14 Incorporating effects of climate change

While ACRE strongly agrees with the need to consider potential climate change, we

disagree with the use of “predicted” and citing specific values for temperature increase

and sea level rise. Climate change is dynamic and on-going and its severity and impacts

will depend on a host of factors including the degree of global response and

management of greenhouse gas production. Many impacts will not be driven by average

11

changes in temperature or sea level rise but increases in the magnitude and frequency

of extreme events such as heat waves, droughts, storms and storm surges, etc. There is

increasing risk from multiple shocks occurring simultaneously or in sequence, e.g.,

several years of drought in a row rather than one or maybe two. Overall there is

substantial uncertainty going forward. Therefore ACRE recommends rewording this

policy as follows:

Local authorities should, and regional and district plans shall, recognise and provide for the

possible effects of climate change, taking account of any national guidance and the best

available and current information, and having particular regard to:

a) projected changes in temperature (average, minimum, maximum), rainfall (average,

maximum, minimums, intensity), wind intensity and other weather-related events; and

b) projected changes in sea level, storm surges, and other coastal hazards.

Pg 4-4 4.1.15 Monitoring and information gathering

ACRE recommends the addition of another clause:

Make results of monitoring available to members of the public through regular updates

in community newspapers and Environment Waikato publications and website.

Pg 4-6 Policy 4.2 Collaborative approach

ACRE strongly supports this policy and implementation methods.


Pg 4-6 4.2.4 Joint planning

Amend to include a further item

f) Other rivers of the region and their catchments


ACRE supports this policy and implementation methods.

5 AIR

Pg 5-1 to Policy 5.1 to 5.3

5-4 ACRE supports these policies and implementation methods.

12

6 Built Environment

Pg 6-1 Policy 6.1 Planned and co-ordinated development


However we feel the overall policy could be strengthened by including explicit

recognition that any long-term planning is uncertain and that planning for the built

environment is particularly dependent on assumptions of future population and

economic trends. The overall tenor of this section is one of expected increases in

population and development, i.e. continued growth. This may be true overall for the

region, but some towns or localities may experience population loss or economic

decline. Further long-term projections for New Zealand call for a stabilized population

within the next 100 years, or within the timeframe of the RPS. We would like to see the

policy revised to take into account change in general, rather than just growth.

Pg 6-1 6.1.4 District plan provisions for rural-residential development

We find the last sentence of this implementation method confusing and suggest

clarification.

Pg. 6-4 Policy 6.2 Planning for development in the coastal environment


Pg 6-6 Policy 6.3 Co-ordinating growth and infrastructure


We recommend the following qualification below:

Overall the policy should accommodate the possibility for both growth and decline, as

the latter may occur at the same time as the former in some places.

Pg 6-7 6.3.4 Urban growth outside of growth strategy areas

Delete this implementation method. Small scale urban development may be

appropriate and necessary to retain the viability of some small villages. Other policies in

the RPS will prevent urban sprawl and loss of high class soils etc.

13

Pg 6-9 Policy 6.5 Energy demand management

ACRE supports in part this policy and implementation method.

Within the RPS’s 100-year timeframe, we will need to transition to wholly renewable

energy resources, either as a result of a decrease of supply of non-renewable resources,

especially fossil fuels, and/or the need to reduce greenhouse gas emissions resulting

from energy use. This policy should recognise the need for that transition and be re-

written as follows:

Development should transition from use of non-renewable to renewable energy sources.

Achieving that transition should encompass various methods including reducing

transport energy demand, encouraging use of non-renewable energy sources including

re-use of waste materials, and promoting the efficient use of energy.

Pg 6-9 6.5.3 Development manuals and design codes

This implementation method reads as though development will be allowed and

encouraged provided it is consistent with 6.5. We recommend re-wording so that

consistency with 6.5 is encouraged, provided other development rules and methods are

complied with.

Pg 6-12 Policy 6.7 Access to Minerals


Minerals are finite resources. This policy should acknowledge that. We recommend the

following changes:

Add item: a) Mineral resources are finite and must be re-used as much as possible

Pg 6-12 6.7.1 Identification of mineral resources

Change to : Waikato Regional Council will seek to work with territorial authorities, iwi

authorities, relevant industry and other agencies to identify and map the

location of significant mineral resources except for those covered by

schedule 4 of the Mining Act.

Pg 6-13 Policy 6.8 Information collection


14

Achievement of the various policy objectives within the RPS will only be possible

through the on-going collection, analysis and dissemination of quality information. We

strongly advocate changing all these statements from “should” or “will” to “shall” to

guarantee that essential information is actually collected.

Pg 6-13 to Policy 6.9 to 6.18

6-22 ACRE supports these policy and implementation methods.

Additional Policy:

ACRE recommends an additional Policy for Shore Futures with accompanying

implementation methods.

7 Coastal Marine Area

Pg 7-1 Policy 7.1 Interests in the Coastal Marina area

ACRE opposes this policy and implementation methods.

This chapter seems particularly “thin” given the importance of the coastal environment

and the extensive coastline of the region, although we acknowledge some issues are

covered under other chapters. We would suggest a repeat of those policies here, or a

reference to where they can be found in other chapters. The emphasis is on the “use” of

the coastal marine area rather than ecosystem and natural character values. We

recommend a thorough review of this chapter in light of the recently released NZ

Coastal Policy Statement.

Pg 7-1 7.1.1 Allocation of space within the coastal marine area

The matters to which “particular regard will be had” are badly grouped and focus on the

“use” of the area rather than the protection of natural character or unique features of

the coastal environment.

Change to:

Particular regard will be had to

a) Lack of understanding about some coastal processes and the

effects of activities on them.

b) Avoiding adverse effects, including cumulative effects on:

15

i) natural character, landscape values and wild or scenic areas.

ii) Species, habitats and ecosystems

iii) Marine water quality

iv) Open space and amenity values

v) areas of significance to tangata whenua

vi) Public access

vii) Existing/future marine transport corridors

c) Avoiding the effects of natural hazards

d) Changes predicted as a result of climate change

e) Opportunities for recreational access across a range of experiences

f) The functional necessity for activities to locate in the coastal marine area.

g) The existence of other like facilities in the locality.

h) Existing economic, cultural and social uses of the coastal marine area

i) Avoiding sprawling and sporadic development

j) The public benefit from any development in public space

k) Linking activities taking place in the marine area to land based infrastructure necessary

for its support and

l) Opportunities for electricity generation from renewable resources.

Pg 7-1 7.1.2 Crowns interest in the coastal marina area

Change to: The Regional Coastal Plan shall include provisions that ensure regard is

had to any available alternatives in relation to the coastal marine area for:

a) Reclamations

b) The removal of sand, shingle, shell or other natural materials for commercial

purposes

c) The rights to occupy foreshore, seabed or coastal water

ACRE does not feel that reference to applicants or proposed applications belong in the

RPS.

Pg 7-2 7.1.3 Occupation charging in the coastal marine area

Change to : …………with a varying scale of charges based on the degree of public

benefit or deprivation which would accrue from the activity.

Pg7-2 7.1.4 Aquaculture Strategy

This policy will need to be rewritten in light of the Government’s moves to rewrite

Regional Coastal Plans to reflect its economic agenda, and Environment Waikato’s

support for that agenda.

16

Pg.7-3 Policy 7.2 Marine water quality


We recommend the following changes:

Pg.7-3 7.2.1 Marine water types

Change to: The regional coastal plan shall:

a) identify types of marine waters based on their capacity to assimilate discharges

and establish water quality standards for each type.

ACRE does not accept that the criteria for establishing a water quality standard should

be its ability to assimilate discharges.

8 Fresh water bodies

Pg 8.1 Policy 8.1 Approach to managing water bodies


We recommend the following changes:

The implementation methods are about monitoring and establishing standards. We

would like to see an implementation method about the enhancement of water bodies,

not just the management of activities.

ACRE supports the recommendation of the Waikato Biodiversity forum that wetlands

have a separate specific policy given their significance in the Waikato region.

Pg 8.1 8.1.2 Establish water body standards

ACRE supports the establishment of water body standards. However, it is unclear from

this policy whether different standards will be established for different water bodies, or

whether there will be one standard against which all will be measured. It does seem

from the explanation at the end of the chapter that different standards will be used for

different water bodies. ACRE believes that all water bodies are of a high value and

deserve protection and enhancement. The standards should be high and the same for

all fresh water bodies and reflect the values in 3.13 a) irrespective of their current state.

17

Pg 8.1 8.1.3 Manage activities to achieve standards

We need better measures to quantify adverse effects of land use on water bodies and

actions to be taken where the quality or values of the water body are compromised.

Pg 8.1 8.1.5 Stakeholder involvement

The health of fresh water bodies is of national importance – effectively we are all

“stakeholders”. Policy 3.13 is about protecting the mauri and health of fresh water

bodies. While education programmes certainly have their place, regulatory

management may be necessary regardless of cost.

Pg 8.2 8.1.6 Information gathering

We are not sure how the council proposes to review land use trends. A different

approach from that presently being taken will be needed to gain information around

present and proposed land use activities. We would like to see this linked to the

provision of information where farmers are using over 60 units of n/ha. If more

information is requested at this point, then more relevant data will be able to be

obtained.

pg.8.3 Policy 8.2 High value water bodies


We offer the following qualification.

We believe that all water bodies are of high value and deserve protection and

enhancement. It is not appropriate that even our more degraded water bodies be

expected to assimilate further waste, even if in a degraded state at present. We

recognise the desire to give special protection to those with high values, but this risks a

trade off situation.

Pg. 8.4 Policy 8.3 All water bodies


We recommend the following qualifications and changes:

18

Pg. 8.4 8.3.3 Non point source discharges

a) This approach has not achieved the desired results to date.

b) Agree

c) Agree. This policy is essential and urgent. However, there is an unwillingness to

provide private land use information and we wonder how in practical terms this

will be achievable.

d) Agree

Pg.8-5 8.3.4 Establish allocation baselines

Partial cost of research and development should be provided by consent holders.

Pg.8-5 8.3.8 Industry self management

While we support collaboration with industry there is a level of public distrust of self

monitoring by industry, and it does not force any real change in behavior. We would like

to see more transparency in reporting of progress towards improvement.

Pg.8-8 Policy 8.4 Catchment based intervention


We recommend the following amendments to the implementation methods below:

Pg.8-8 8.4.1 Indentify catchments for specific intervention

ACRE submits that the words with the priorities for intervention consulted upon during

long term plan/annual plan process be removed. We do not see the reference to

consultation in other planning documents mentioned elsewhere in the RPS and would

not like to see the prioritization process delayed by consultation through them. The

sooner those living and working in a catchment are aware of possible interventions the

better. Add a timeframe or deadline for the assessment of catchments.

Pg.8-8 8.4.2 Process for identifying catchment management approach

We have concerns about the length of time it will take to gather the relevant

information, and the adverse effects that will continue while the assessing and analyzing

is being done. We refer to the issues around variation 5, where the barriers to effective

19

implementation have been the difficulty in procuring accurate information about farm

systems and intent.

Pg.8-11 Policy 8.6 Allocating Fresh water


It is critical that before water is allocated, it is assessed for its full range of values to all

stakeholders, and that stakeholders have some influence in the management of water.

Pg.8-12 8.6.2 Managing increasing water demand

We have some concerns about b). Previously authorized takes need to be reassessed to

ensure the need still exists and avoid over allocation.

9 Geothermal


The situation with Section 9 Geothermal significantly differs from other sections of the

RPS in that very comprehensive Regional Plans have recently been brought into place

following full stakeholder consultation and Court processes. ACRE would like to

congratulate EW on its achievements through this process and producing very effective

Regional Plans. As an over-riding document, the RPS has been compiled in a way that is

consistent with these plans and ACRE supports the policies therein with the one

exception below.

Pg.9-7 Policy 9.4 Development Geothermal systems


It is unfortunate that E.W. was prevented from obtaining a “single tapper” policy for

each Production Geothermal System. We wonder how this may be addressed in the

future at a higher level. EW has been forced to state that these systems need to be

managed where there is more than one consent holder. An integrated approach will be

hard to achieve and overseas systems run this way have encountered such problems as

resource allocation, responsibility for subsidence and effects of re-injection and

withholding of commercially sensitive information. A single tapper policy must

somehow be aimed for in the future.

20

Pg.10-1 Policy 10.1 Managing historic and cultural heritage


We recommend the following changes below:

Change to : Provide for the collaborative, consistent and integrated management and

protection of historic and cultural heritage resources.

Pg.10-1 10.1.2 Regional heritage inventory

d) Change to: be used to protect and monitor the condition and extent of heritage

resources over time.

11 Indigenous biodiversity

Pg 11-1 Policy 11.1 Maintain or enhance indigenous biodiversity


We recommend the following changes below:

d) Change to: The health and wellbeing of the Waikato River and its catchment, the

Firth of Thames and the Hauraki Gulf catchment

11.1.1 Maintain or enhance indigenous biodiversity

ACRE is pleased to see the use of “shall” in this implementation method.

Pg 1-2 11.1.3 Remediation and mitigation

ACRE supports the submission of the Waikato Biodiversity Forum that net gain and

improved ecological value should be the outcome of this method.

Pg 11-2 11.1.4 Plan development

This is an important policy which should be strengthened by the use of “shall” rather

than “should.”

21

Pg 11-2 11.1.6 Local indigenous biodiversity strategies

ACRE strongly supports this strategy, particularly mapping of areas of indigenous

biodiversity values on private as well as public land.

Pg 11-3 11.1.8 Natural Heritage inventory

ACRE supports a district wide natural heritage inventory and would like to see a linking

with other regions to provide a nation wide inventory over time.

Pg 11-4 Policy 11.2 Protect significant indigenous biodiversity



Pg 11-4 11.2.4 Identify threats to significant natural areas.

ACRE suggests that the wording of this method is changed to include volunteer and

community groups.

Change to: Waikato Regional Council will identify important threats to significant

natural areas and work with relevant agencies, volunteer and community

groups, and landowners to facilitate the management of these threats.




Pg 11-5 11.3.2 Education and advocacy

c) Change to: work with territorial authorities, landowners, tangata whenua,

community and volunteer groups and other relevant stakeholders etc.

Pg11-6 Policy 11.4 Safeguard coastal/marine ecosystems


22

Pg 11-8 11A Criteria for determining significance of indigenous biodiversity

ACRE suggests that Criterion 4 be amended to use the Land Environments of New

Zealand (LENZ) framework as the primary framework for assessing representativeness of

indigenous vegetation and habitats.

Both the National Guidelines for Protection of Indigenous Biodiversity on Private Land

and the proposed National Policy Statement on Indigenous Biodiversity use LENZ as their

representativeness framework. The proposed RPS continues to use Ecological Regions

and Districts as the framework for assessing representativeness. For consistency and

also future proofing (assuming the national policy statement will be adopted), the RPS

should use LENZ as well.

We also suggest including an additional criteria from the Draft Otorohanga District plan -

Role played by vegetation in reducing natural hazards (especially landslips) and

contributing to water and soil conservation.

Pg 12-1 12 Landscape, natural character and amenity


We are particularly pleased to see the emphasis on cumulative effects in the policy and

explanation. We recommend the following change:

Pg 12-1 12.1.2 Identify local outstanding natural features and landscapes

It seems it is not possible to comply with policy 12.1.1 without undertaking this

assessment. We therefore submit that the wording be changed to Territorial authorities

shall undertake a district wide assessment etc.

Pg 12-2 to Policy 12.2 to Policy 12.6

12.6 ACRE strongly supports these policies and implementation methods.

Pg 12-8 12A Outstanding natural features and landscapes

ACRE strongly supports the inclusion of the description and maps of outstanding natural

features and landscape.

23

We agree with the submission of the Waikato Biodiversity Forum that some outstanding

areas are missing such as limestone/karst landscape, peat lake landscapes,

Kawhia/Aotea harbours, geothermal landscape e.g. Craters of the Moon/Wairakei.

13 Natural Hazards

Pg 13-1 Policy 13.1 Natural Hazard risk management approach

ACRE supports this policy and the implementation methods.

Pg 13-1 Regional natural hazards forum

We consider the establishment of this forum an excellent idea.

Pg 13-3 Policy 13.2 Manage activities to reduce the risks from natural hazards


We offer the following qualification:

Most of the implementation methods apply to coastal and flood inundation. However,

particularly in the Coromandel Peninsula the most common natural hazard during high

rainfall events is land slips on steep sections which endanger properties. ACRE suggests

controls to prevent building on steep unstable hillsides, or below such hillsides. (This

may need to be at a property level as the whole area may not necessarily be a hazard

zone.

14 Soils

Pg 14-1 Policy 14.1 Maintain or enhance the values of the soil resource


Pg 14-2 Policy 14.2 High class soils


Protection of our high class soils is extremely important and this policy is a good step

forward. We think it will be necessary for the Regional Council to be involved beyond

the provision of information, to prevent inappropriate subdivision. We are surprised

that Environment Waikato is responsible for peat soils but not high class soils.

24

Pg 14-3 Policy 14.3 Soil contaminants


Pg 14-4 Policy 14.4 Contaminated land


We recommend the following change below:

Pg 14-4 14.4.1 District plans

We suggest a change be considered to require a soil assessment prior to any

development or subdivision of land. There have been a number of incidences in NZ

where contamination has been discovered after subdivision. A land owner may not

divulge or even be aware of contamination prior to land use change.

Pg 14-5 Policy 14.5 Peat Soils


PART C

15 Monitoring and evaluation

Pg 15-1 15.1 General


15.2 Review existing procedures for monitoring

We assume that the “alignment of monitoring data collection effort” refers to alignment

with territorial authorities and DOC. Local environment groups are an underused

resource and provided with the right resources could make a significant contribution to

the collection of data.

25

Pg 15-2 15.4 Environmental results anticipated

The listing of the environmental results gives a clear vision for the region and we

strongly support this policy. We anticipate that as each of these matters is translated

into Regional and District Plans a series of actions will be included which provide

remedial actions where the trend is the wrong way.

Pg 15-6 15.5 Giving effect to the Regional Policy Statement

We are pleased to see that policies will be reviewed every five years. This is an

important step.

Documents

28 February 2011 - waikatoregion.govt.nz · the growth in demand and then secondly a gradual reduction in energy demand until it reaches a level that can be sustained by renewable