BEFORE THE ENVIRONMENT COURT AT CHRISTCHURCH ENV-2010-CHC-115, 123, 124 AND 135 IN THE MATTER of Appeals pursuant to Section 120 of the

Resource Management Act 1991 BETWEEN WEST COAST ENT INC Appellant AND ROYAL FOREST AND BIRD PROTECTION SOCIETY OF NEW ZEALAND INC Appellant AND WHITE WATER NEW ZEALAND INC Appellant AND DIRECTOR GENERAL OF CONSERVATION Appellant AND WEST COAST REGIONAL COUNCIL AND BULLER DISTRICT COUNCIL Respondents ....Continued over leaf _____________________________________________________

STATEMENT OF EVIDENCE OF INGRID GERDA GRUNER

FOR DIRECTOR GENERAL OF CONSERVATION Dated: 15 May 2012

_____________________________________________________

_____________________________________________________

Department of Conservation, West Coast Tai o Poutini Conservancy Private Bag 701, Sewell Street HOKITIKA Ph 03 756 9100 Fax 03 756 9188 Counsel Acting: A Cameron, D van Mierlo

2

AND MERIDIAN ENERGY LIMITED Applicant AND FRIDA INTA Section 274 Party AND WHANAU PIHAWAI WEST –

RICHARD WAYNE BARBER AND IRI MAY BARBER MILNER

Section 274 Party AND J MacTAGGART Section 274 Party AND ORION ENERGY NZ LTD, ALPINE ENERGY LTD, MAIN POWER NZ LTD AND ELECTRICITY ASHBURTON LTD Section 274 Party AND NZ RAFTING INC Section 274 Party AND ANN SHERIDAN Section 274 Party AND BULLER ELECTRICITY Section 274 Party

3

TABLE OF CONTENTS 1. QUALIFICATIONS AND EXPERIENCE ...............................5

2. SCOPE OF EVIDENCE............................................................7

3. KEY FACTS AND OPINIONS.................................................7

4. SYSTEMATIC CONSERVATION PLANNING FOR

THE BULLER COAL PLATEAUX .........................................7

5. SYSTEMATIC CONSERVATION PLANNING.....................8

6. METHODS ..............................................................................10

Analysis Software ....................................................................10

Study Area ...............................................................................11

Data on Conservation Values...................................................12

Additional Analysis Features...................................................15

7. OUTPUTS................................................................................16

Scenario 1 – Biodiversity, without planning constraints;

Map 2 .......................................................................................17

Scenario 2 – Biodiversity, excluding consented areas;

Map 3 .......................................................................................17

Scenario 3 – Biodiversity and historic values, excluding

consented areas; Map 4............................................................18

Scenario 4 – Biodiversity and historic values, favouring

non-coal areas and public conservation land; Map 6...............19

Scenario 5 – Biodiversity and historic values, avoiding

coal resources; Map 8 ..............................................................20

8. CONCLUSIONS......................................................................21

REFERENCES ........................................................................24

APPENDIX 1...........................................................................27

APPENDIX 2...........................................................................28

APPENDIX 3...........................................................................29

APPENDIX 4...........................................................................30

APPENDIX 5...........................................................................31

APPENDIX 6...........................................................................32

APPENDIX 7...........................................................................33

APPENDIX 8...........................................................................34

4

APPENDIX 9...........................................................................35

1. QUALIFICATIONS AND EXPERIENCE

1.1. My full name is Ingrid Gerda Gruner.

1.2. I hold a Diploma in Biology (comparable to an MSc) from

Westfaelische Wilhelms University in Muenster, Germany,

and a PhD in Forestry, specialising in conservation

ecology, from the University of Canterbury, Christchurch,

New Zealand.

1.3. I am currently employed by the Department of

Conservation as Technical Support Officer, Ecosystems,

for the West Coast Conservancy. I have held this position

since 2008. Between 2004 and 2008, I was employed as

Conservancy Advisory Scientist, also for the West Coast

Conservancy. Prior to this, I worked for two years for

AgriQuality NZ, leading the South Island field verification

process for the second version of the New Zealand Land

Cover Database.

1.4. I am an ecologist with emphasis on plant and vegetation

ecology. During my time with the Department of

Conservation, I have also been involved in animal

conservation and ecology as well as visitor and recreation

management. Working for AgriQuality NZ, I acquired

skills in GIS and spatial analysis. I have published three

scientific papers.

1.5. With regard to the Buller Coal Plateaux, I have been

involved in conservation management issues in the area

over an extended period of time in my roles with the

Department of Conservation. My work there has included

the assessment of effects of mining proposals on public

conservation land, the review of expert ecological reports,

6

the provision of advice on Powelliphanta land snail

management and the provision of advice on mine

rehabilitation.

1.6. I am familiar with the Buller Coal Plateaux through

numerous field visits in connection with this work. I also

attained a general overview of vegetation patterns in the

area while mapping the Buller Coal Plateaux for the New

Zealand Land Cover Database. I have not undertaken any

field visits especially to investigate areas affected by the

proposed transmission line.

1.7. I am familiar with the transmission line proposal associated

with the Mokihinui Hydro Proposal (MHP) to the extent

that it crosses the Buller Coal Plateaux (which are

comprised of the Stockton Plateau and the Denniston

Plateau). I am not familiar with the details of the

transmission line construction or the MHP as it affects the

Mokihinui valley and wider catchment.

1.8. I have read the Environment Court’s Code of Conduct for

Expert Witnesses, and I agree to comply with it. I confirm

that the issues addressed in this brief of evidence are within

my area of expertise.

1.9. I have not omitted to consider material facts known to me

that might alter or detract from the opinions expressed. I

have specified where my opinion is based on limited or

partial information and identified any assumptions I have

made in forming my opinions.

1.10. In preparing this evidence, I have reviewed statements of

evidence of other witnesses giving evidence on behalf of

7

the Department of Conservation, namely those of Dr J.R.

Leathwick, Dr K.M. Lloyd and Ms K.J. Walker.

2. SCOPE OF EVIDENCE

2.1. My evidence will deal with the following:

A description of a project I am currently leading within the

Department to assist in identifying and mapping key areas

that would be required for a reserve network to achieve full

representation and long-term persistence of the full range

of conservation values on the Buller Coal Plateaux.

A consideration of the extent to which the proposed

transmission line for the MHP would intersect with these

key areas as identified and mapped to date within this

project.

3. KEY FACTS AND OPINIONS

3.1. The proposed MHP transmission line would likely affect

several areas of high priority for conservation management.

3.2. Further development impacting priority areas for

conservation management on the Buller Coal Plateaux,

including the MHP transmission line, should be deferred

until systematic conservation planning for the area has been

undertaken and a management strategy finalised.

4. SYSTEMATIC CONSERVATION PLANNING FOR THE BULLER COAL PLATEAUX

4.1. I am currently leading a project within the Department

exploring the use of a systematic conservation planning

approach (Margules & Pressey 2000) to the Buller Coal

8

Plateaux. The need for this project arose from the

increasing conflict between protection of conservation

values on the one hand and development proposals, in

particular for mining, on the other. The Department realised

that a continuation of its current case-by-case approach to

development proposals would likely lead to the long-term

loss of significant conservation values.

4.2. My evidence is based on outputs from this project to date.

At the time of writing this evidence, the project has not yet

been completed. Further analyses are likely, potentially

changing the picture provided in this evidence statement. I

will be in a position to update the Court on any such

changes. The anticipated timeframe for the project is for

completion by the end of June 2012. Dr Leathwick, who

also presents evidence on behalf of the Department of

Conservation, assisted with the design of the analyses

presented here.

4.3. In the following, I will briefly describe the principles of

systematic conservation planning, the analysis methods and

the data used for the project, and then step through the

analysis process to provide a better understanding of the

outputs. I will present different output scenarios, and put

them into the context of the proposed MHP transmission

line.

5. SYSTEMATIC CONSERVATION PLANNING

5.1. Systematic conservation planning is a relatively new

approach to conservation management. It aims at achieving

protection and persistence of the full range of conservation

values in an environment of conflicting human interests

9

and financial constraints (Margules & Pressey 2000;

Moilanen et al. 2009).

5.2. Systematic conservation planning has been widely used

internationally (e.g., Franco et al. 2009; Game et al. 2010;

Lehtomaki et al. 2009) and is meeting increasing interest in

New Zealand: For example, here, it has been used to

identify priorities for freshwater conservation (Leathwick et

al. 2010; Moilanen et al. 2008; see also evidence by Dr

Leathwick), for marine protection proposals (Leathwick et

al. 2006; Leathwick et al. 2008), and is most recently being

applied by the Department of Conservation to prioritise

conservation management to ensure protection of a full

range of New Zealand’s ecosystems (refer evidence of Dr

Leathwick).

5.3. The use of systematic conservation planning in the context

of the Buller Coal Plateaux aims at moving the Department

away from a case-by-case approach to development

proposals in the area. Systematic conservation planning

allows a look at the entire area and its conservation values

as a whole. Analyses can then identify which parts of the

area are of particular importance, if the aim is to protect a

representative and long-term viable sample of these values.

5.4. Systematic conservation planning also allows taking into

account other factors such as land status and, in the

example of the Buller Coal Plateaux, interests in coal

resources. Therefore, the aim of the current project is to

identify which areas on the Buller Coal Plateaux currently

provide the best opportunity to protect a representative and

long-term viable sample of the full range of conservation

values, while acknowledging current and potential future

interests in access to coal resources.

10

5.5. The current project does not necessarily supersede the

Protected Natural Areas Programme (PNAP) survey

previously undertaken for the Ngakawau Ecological

District (Overmars et al. 1998). The motivation for the

Ngakawau PNAP was principally the same as for the

current project, but the methods used were different. The

current project aims to assess a wider range of conservation

values and uses relatively new, quantitative and spatial

analysis methods. These methods allow the comparison of

a range of potential scenarios and provide a decision

support tool rather than producing one single, static

recommendation as in the PNAP survey report. Outputs

from the current project will need to be assessed and

evaluated using expert knowledge and other information on

values in the area, including that contained in the PNAP

survey report.

6. METHODS

Analysis Software

6.1. The analysis uses the software application Zonation

(Moilanen 2007; Moilanen et al. 2005,

http://www.helsinki.fi/bioscience/consplan/) which was

specifically developed for problems of systematic

conservation planning. Zonation works on spatial data sets,

i.e. a series of digital maps showing the geographic

distribution of conservation values in the area of interest.

6.2. The analysis starts by assuming that the entire area is

protected. Zonation then progressively reduces the area

under protection in a step-wise fashion, at each step

removing those parts of the area that contribute least to the

protection of conservation values. During the course of this

process a new map is created illustrating this step-wise

11

removal process, which translates into a ranking of the area

by conservation priority. Zonation also provides

information on the decline of individual conservation

values, calculated as the area under protection is

progressively reduced.

6.3. These outputs can be used to identify which parts of the

area of interest would best be protected to achieve

representativeness and persistence of the full range of

conservation values, assuming that only a proportion of the

area can be protected.

Study Area

6.4. The study area used in the analysis extends over the

Stockton and Denniston Plateaux south to the Te Kuha area

and includes the steep western slopes towards the coastal

flats as well as the western slopes of the Mt William Range

(Map 1). This area encompasses the unique landscapes and

conservation values of the Buller Coal Plateaux. The

Blackburn Pakihi to the east of the Stockton Plateau was

excluded because of its relatively high degree of

modification and the presence of comparable, unmodified

areas in the nearby Ngakawau and Orikaka Ecological

Areas (Overmars et al. 1998). Only the southern most 14.8

km of the proposed MHP transmission line are within the

study area.

12

Map 1. Study area for the Buller Coal Plateaux Systematic Conservation Planning project.

Data on Conservation Values

6.5. Ideally, the analysis would include data on the full range of

conservation values present on the Buller Coal Plateaux,

i.e. all biodiversity, historic, landscape, recreation and

13

cultural values. In practice, this approach is limited by the

availability of data. The following briefly discusses the

range of data layers used. These were compiled from

survey reports, field visits, expert knowledge and mapping

of aerial photography.

(a) Vegetation. The information on vegetation

types represents one of the key layers for

biodiversity. This is because of their inherent

biodiversity values, but also because they

function as surrogates for the distribution of

fauna species, where comprehensive data on

distribution are lacking. The extent to which

these vegetation types truly reflect the

distribution of other biodiversity throughout

the area is unknown; the use of surrogacy has

been widely criticised in the international

literature (e.g., Lombard et al. 2003; Pressey

2004), but it is currently the best we can do

with available data.

(b) Originally rare ecosystems. Originally rare

ecosystems are defined as ecosystems that

were rare before human colonisation, with a

total extent of less than 0.5% (<134,000ha) of

New Zealand’s total land area (Williams et al.

2007). Six originally rare ecosystems have

been identified on the Buller Coal Plateaux:

sandstone erosion pavements, boulderfields of

quartzose/acidic rock, cliffs and scarps of

quartzose/acidic rock, tarns, seepages and

pakihi. With the exception of cliffs and scarps

of quartzose/acidic rock, layers for all of these

ecosystems were included in the analysis.

14

(c) Powelliphanta land snails. The only fauna

species for which we have comprehensive

distributional data are the two species of

Powelliphanta land snails present on the

Buller Coal Plateaux, i.e. P. patrickensis and

P. augusta. Distribution maps for these

species were included as separate data layers

in the analysis.

(d) Freshwater streams. Streams were classified

into five stream types, according to their

topography and water chemistry. In addition,

we used a so-called ‘condition layer’ for

streams, which ranks them according to their

ecological integrity, favouring the protection

of those that are in good condition ahead of

those that have been degraded by human

activity.

(e) Historic values. Known above ground

historic values were mapped using aerial

photography and included in our analysis as a

series of map layers. It needs to be noted that

the Zonation software was primarily

developed for the analysis of data on

biodiversity features. However, the inclusion

of historic features in our analyses is

consistent with Zonation’s purpose and intent,

which is to identify parts of a landscape that

maximise the protection of a range of features

with differing geographic distributions. In our

analysis, historic values are treated in the

same way as species with limited geographical

15

distributions. Outputs seem to appropriately

include historic features.

(f) Landscape, recreation and cultural values.

The intent of the project is to also include

landscape, recreation and cultural values. This

has to date not been undertaken, i.e. the

interim outputs presented below exclude

consideration of these values.

Additional Analysis Features

6.6. Three additional analysis features are important to mention

for a better understanding of outputs. These are:

(a) The ability to put different weights onto the

conservation value layers. In our analysis,

highest weight was given to conservation

values that were deemed to be of (inter)

national significance, because they are unique

(endemic) to the Buller Coal Plateaux (e.g.,

Chionochloa juncea grassland, Powelliphanta

species). Intermediate weight was given to

features that are integral components of the

unique ecology of the Buller Coal Plateaux,

but are also found in other places (e.g., high

elevation beech forests and manuka scrub

above 600m asl). Lowest weight was given to

values that are not integral to the unique

ecology of the Plateaux. These features occur

mainly at lower altitude and are relatively

widespread elsewhere (e.g., rimu-hard beech

forest). For detailed discussions on the values

of the Buller Coal Plateaux and their

16

significance refer to other evidence presented

on behalf of the Department, e.g., that of Dr

K. Lloyd and Ms Walker.

(b) The ability to include algorithms that

encourage the identification of geographically

compact high-value sites, as opposed to

solutions in which high-value sites are

scattered across the landscape in a fragmented

pattern. Use of these techniques recognises the

ecological value of connectivity for the

functioning and persistence of species and

ecosystems.

(c) The ability to use ‘masks’ in the analysis to

forcibly exclude or include certain areas. This

allows the development of scenarios with

different sets of constraints, e.g., considering

mining that is already underway or to which

planning consent has been granted. This will

be further explained below.

7. OUTPUTS

7.1. The analysis outputs presented below are preliminary. The

project is a work in progress, and further analyses will be

undertaken, potentially changing the picture provided here.

Nonetheless, presentation of these outputs is still relevant

because they highlight the potential for the MHP

transmission line to impact on areas of high priority for

conservation management.

17

7.2. The maps illustrating the various scenarios use a graded

colour scheme from the lowest ranked areas in brown, over

yellow and green, to the highest priority areas in blue.

Scenario 1 – Biodiversity, without planning constraints; Map 2

7.3. This represents the most basic scenario, ranking the entire

landscape for its contribution to conservation outcomes,

with no constraints imposed by land status or presence of

coal resources. It shows that the highest ranked areas on the

Stockton Plateau are from the area around Mangatini

Stream south along the flanks of Mt Stockton over Fly

Creek and Plover Stream into the Cypress area and along

the western slopes of the Mt William Range to about Cedar

Creek Saddle. The proposed MHP transmission line would

more or less follow the western edge of this highly ranked

area. Other highly ranked areas on the Stockton Plateau are

just to the west of the Stockton escarpment (P. augusta

habitat) and slopes around Mt Frederick.

7.4. Developing a protection proposal based on this scenario

would be unrealistic, as some of the highly ranked areas

have already been consented for development, e.g. the

Cypress Stream area in the upper Waimangaroa catchment.

Scenario 2 – Biodiversity, excluding consented areas; Map 3

7.5. This is a more realistic scenario as it excludes areas already

consented for development. In the analysis a mask was

used forcing Zonation to remove these consented areas

first1. As a consequence, previously highly ranked areas,

1 Areas excluded to date because of existing consents are: Solid Energy’s Stockton Coal

Mining Licence, Cypress Mine, Stockton No 2 South, Rockies Mine, and the Kawatiri

Energy hydro development.

18

e.g., in the vicinity of Fly Creek, Plover Stream and

Cypress Stream are now allocated a low priority (= brown

colouring), reflecting the impending loss of all biodiversity

values in these areas. Otherwise, areas east of the

transmission line remain highly ranked, but an area south

of Webb Stream is now more highly ranked and the

proposed transmission line would bisect this area. In

addition, a very highly ranked area containing a red tussock

fen is now prominent at the southern end of the

transmission line. The exact location of this fen in relation

to the proposed transmission line has not been assessed in

the field.

Scenario 3 – Biodiversity and historic values, excluding

consented areas; Map 4

7.6. In Scenario 3 we expand the previous analysis by taking

into account both, biodiversity and historic values.

Inclusion of historic values subtly alters the distribution of

highly ranked areas to include important historic features,

e.g., the Stockton electric loco line. Because of this, the

area to the west of the transmission line along Burma Road

is now also highly ranked.

7.7. Protection of the most highly ranked 30% of the study

area2, based on this scenario, would require setting aside

for conservation the areas shown on Map 5. Several of

these highly ranked areas would be affected by the

proposed transmission line reducing their value for

conservation.

2 The figure of 30% is used here for illustrative purposes only, to highlight high priority

areas. This does not imply that protection of these areas would be appropriate or sufficient

in the context of a protection proposal for the Buller Coal Plateaux.

19

7.8. Scenario 3 is still optimistic. In reality further constraints

are likely to be brought forward by various stakeholders.

Not all of the area is public conservation land; some areas

are held by Land Information New Zealand

(LINZ)/Ministry for Economic Development (MED), i.e.

this land is not necessarily held for conservation purposes.

The presence of coal resources off and on public

conservation land is likely to add another constraint to the

achievability of protection proposals.

Scenario 4 – Biodiversity and historic values, favouring non-coal

areas and public conservation land; Map 6

7.9. Scenario 4 takes both of the constraints described above

into account. This was implemented in the analysis by

using a mask that removes areas already mined or

consented for development first (as in Scenario 2 and 3),

followed by areas likely to have coal resources beneath

them. The latter were removed sequentially starting with

areas on LINZ/MED land, followed by areas on

stewardship land, and then removing coal resource areas in

existing conservation reserves and Ecological Areas3.

Areas known to be free of coal resources, irrespective of

land tenure or status, were retained until last, and as a

consequence have the highest rankings. In this scenario the

proposed transmission line does not affect any highly

ranked areas except for a small area along Mangatini

Stream. Most areas along the transmission line are ranked

intermediate (green to yellow).

3 The sequence of removal of areas with likely coal resources is based on the level of

control the Department has concerning mining development, depending on land tenure and

status. The sequence does not reflect relative ecological value of these areas.

20

7.10. The most highly ranked 30% under this scenario are shown

on Map 7. Very few-high value areas are identified for the

Plateaux proper, and protection is now focussed mainly on

tracts of forest on the plateau fringes. Only one large area

on the Denniston Plateau remains that has been identified

as bearing no coal.

7.11. While this scenario would maximise the availability of coal

resources, it would also deliver a substantial reduction in

the protection of biodiversity. Under the previous Scenario

3, setting aside the top ranked 30% of land for conservation

would protect at least 11% of the extent of all biodiversity

features and at least 21% of the extent of those features

deemed to be of (inter-)national significance. By contrast,

under this Scenario 4, several conservation features would

be lost entirely or reduced to below 5% of their current

extent, including several deemed to be of (inter-)national

significance (e.g., sandstone erosion pavements and tarns).

This means, while Scenario 4 would strongly accommodate

mining interests, it would deliver substantially lower

conservation outcomes than Scenario 3.

Scenario 5 – Biodiversity and historic values, avoiding coal

resources; Map 8

7.12. A further scenario is provided by an analysis that allows the

ranking of the remaining area independent of land tenure or

status, but aims at avoiding coal resources. This is achieved

by giving likely coal resources a negative weight in the

analysis. To reflect the high value given to coal resources

by stakeholders, we used the same level of weight as for

distinct and (inter-)nationally significant conservation

values.

21

7.13. In this scenario, the area east of the Stockton CML is again

highly ranked. The transmission line would bisect highly

ranked areas in the north, and again south of Webb Stream.

The distribution of the top 30% (Map 9) is similar to

Scenario 3, but some on-coal areas are avoided. Under this

scenario a minimum of 12% of the extent of all biodiversity

values would be maintained, and at least 19% of the extent

of those values deemed (inter-)nationally significant. This

means the overall conservation benefit would be

comparable to Scenario 3. 80% of the coal resource would

remain accessible.

8. CONCLUSIONS

8.1. Currently, there is no certainty that the high conservation

values of the Buller Coal Plateaux will persist, given the

current and likely future interest in coal resources. Even

off-coal areas are targeted by developers to provide space

for, e.g., infrastructure or overburden dumps. The analysis

described above is intended to initiate and support a

discussion process between interested parties aiming to

reach agreement on a protection proposal that allows for

the achievement of at least some conservation goals

through the withholding of some high-value areas from

development.

8.2. The scenarios presented above show options for such a

proposal from the idealistic through to the pragmatic and

pessimistic. Discussions with stakeholders have not yet

begun. The outcome is therefore unknown. The decision

about the proposed transmission line may have to be made

in this uncertain environment. However, the scenarios

presented above highlight that some areas along the

22

proposed transmission line route are likely to be of

particular interest for conservation management.

8.3. An overlay of all the top ranked 30% for scenarios 2, 3 and

5 illustrates these areas based on analysis results to date

(Map 10). Scenario 1 was excluded from this combined

map because it includes some areas that are already

consented. Scenario 4 was excluded because of the

inadequacy of its conservation outcomes.

8.4. The MHP transmission line would bisect areas of high

conservation interest in the north of the project study area,

i.e. in the Mangatini Stream area to the east of Burma

Road, and further south, to the east of Mt Frederick and

south of Webb Stream.

8.5. While outcomes for the Buller Coal Plateaux are uncertain,

considering the high conservation value of the area and the

strong interest by mining companies, it would be premature

to impact on any of the high priority areas identified in this

analysis before an overall strategy for protection and

development of the Plateaux is finalised. Otherwise,

currently possible beneficial outcomes for the Buller Coal

Plateaux may be precluded.

8.6. If further development cannot be deferred until a strategy

for the Buller Coal Plateaux has been finalised, it should be

focussed on areas that are ranked as relatively low priority

in the analyses. This is the case, in particular, for the

proposed MHP transmission line, as this development is

not spatially fixed. Coal resources and associated coal

mines cannot be moved; the transmission line could

potentially be constructed along a different route.

23

8.7. The analysis results presented above are preliminary. It is

anticipated that the project described in this evidence will

be completed over the next two months, and the final

project outputs will then be available.

24

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physical and physiognomic framework. New Zealand Journal

of Ecology 31:119-128.

27

APPENDIX 1

Map 2. Scenario 1: based on biodiversity values only, with no constraints on

land availability. Colours indicate the relative priority, with blue

indicating highest priority, over teal, green and yellow to brown,

indicating lowest priority. The proposed transmission line route is

indicated by a dark red line.

28

APPENDIX 2

Map 3. Scenario 2: based on biodiversity values only, with areas already

consented for development masked and removed before areas that

are not consented.

29

APPENDIX 3

Map 4. Scenario 3: based on biodiversity and historic values, with areas

already consented for development masked and removed before

areas that are not consented.

30

APPENDIX 4

Map 5. The 30% most highly ranked areas under Scenario 3.

31

APPENDIX 5

Map 6. Scenario 4: based on biodiversity and historic values, removal mask

enforcing the following removal order: first areas already consented

for development, then areas with likely coal resources on

LINZ/MED land, then areas with likely coal resources on

stewardship land, then areas with likely coal resources in

conservation reserves and Ecological Areas, last areas without coal

resources.

32

APPENDIX 6

Map 7. The 30% most highly ranked areas under Scenario 4.

33

APPENDIX 7

Map 8. Scenario 5: based on biodiversity and historic values, and including

coal resources as value layer (with negative weight).

34

APPENDIX 8

Map 9. The 30% most highly ranked areas under Scenario 5.

35

APPENDIX 9

Map 10. The 30% most highly ranked areas under Scenarios 2, 3 and 5

combined.