SOUTHLAND CONSERVATION BOARD TE ROOPU ATAWHAI 0 MURIHIKU

Transcription

1 SOUTHLAND CONSERVATION BOARD TE ROOPU ATAWHAI 0 MURIHIKU File: SBC JUL 2016 Form 5 : Submissions on a Publicly Notified Regional Plan under Clause 6 of Schedule 1 of the Resource Management Act 1991 Submission to Environment Southland on the proposed Southland Water and Land Plan Organisation*: Southland Conservation Board Postal Address : PO Box 743, Invercargill Postcode: Public hearing The Board wishes to be heard in support of our submission; and The Board would not be prepared to consider presenting our submission in a joint case with others making a similar submission at any hearing Trade Competition The Board could not gain an advantage in trade competition through this submission Role of the Southland Conservation Board and its authority to make this The role of Conservation Boards is set out in Section 6M of the Conservation Act Functions of Boards (1) The functions of each Board shall be- (a) To recommend the approval by the Conservation Authority of conservation strategies, and the review and amendment of such strategies, under the relevant enactments: (b) To approve conservation plans, and the review and amendment of such plans, under the relevant enactments: (c) To advise the Conservation Authority and the Director- General on the implementation of conservation strategies and conservation plans for areas within the jurisdiction of the Board: (d) To advise the Conservation Authority or the Director- General- (i) on any proposed change of status or classification of any area of national or international importance; and (ii) On any other conservation matter relating to any area within the jurisdiction of the Board: (e) [Repealed] (t) To liaise with any Fish and Game Council on matters within the jurisdiction of the Board: (g) To exercise such powers and functions as may be delegated to it by the Minister under this Act or any other Act. The Board's authority to make this submission lies within Section (d) (ii) above SERVICED BY THE DEPARTMENT OF CONSERVATION PO Box 743, Invercargill 9840 CUE on Don Building, 33 Don Street, Invercargill, New Zealand Telephone (03) , Fax (03)

2 General Submissions Any statutory plan should include a definition of the area covered by the Plan. The nearest that the draft Southland Water and Land Plan comes to this is at page 7 where it indicates under `Purpose of this Plan' that This Plan is intended to provide direction and guidance regarding the sustainable use, development and protection of water and land resources in the Southland region. The term 'Southland region' is not further defined. It is not clear whether the Plan covers the Southland planning region - which extends seaward to the 12 nautical mile territorial limit - or whether the Plan excludes the Coastal Marine Area and just covers the land areas of the Southland region (presumably, as defined under the Local Government Act). The Plan is based on a high standard of scientific research and reasoning insofar as it relates to the land areas of the Southland planning region, but the same level of scientific research and reasoning is not there to support any application of the Plan to the CMA. As the Plan stands, it would need to be taken into account in any assessment of environmental affects concerning any proposal in the CMA, and it is not structured to be a useful resource in that6 context. The Board's submission is that the area of jurisdiction of the Southland Water and Land Plan needs to be accurately defined in the Introduction to the Plan. I ID L) 11G The 'line of logic' of any plan written under the RMA needs to flow from the general to the specific - from the Issues, to the Objectives (resolving the issues), to the Policies (particular ways of resolving the issues) to the Rules (If you comply with the Rule, then by definition you have complied with the Policies and Objectives and addressed the Issue). The way the proposed Southland Water and Land Plan is formatted, this line of logic is not always clear. The Board's submission is that the final version of the Plan should be appropriately annotated so that the line of logic in the Plan is clear (e.g... for each Rule, the policies to which it relates should be referenced by number; for each policy, the relevant objectives and so on.) This will assist with clarity and consistency in decision-making. It takes several readings of the Plan to understand the concepts "Physiographic Zones," "Catchments", and "Freshwater Management Units" as they are developed in, and form the basis of, the Southland Water and Land Plan. The Board's submission is that it would assist understanding of the Plan if further explanatory comment could be included in the Introduction. The specific provisions to which our submission relates, our submission, and the decisions are: N.B. Sections quotes from the relevant documents are shown in italics. Recommended additions to the Plan are underlined. Recommended deletions are struck through threw-.. Where appropriate the Plan provision has been summarized in this submission. The Board's submission relates to the full provision in the Plan, however, not the summarized version in the table below. DOG

3 SOUTHLAND CONSERVATION BOARD TE ROOPU ATAWHAI 0 MURIHIKU TOPIC PLAN PROVISION PAGE SUBMISSION : DECISION SUPPORT/ OPPOSE/AMEN SOUGHT D AND REASON BACKGROUND Physiographic (Fact SUPPORT Maintain the Zones sheet) physiographic The physiographi The Board supports the zoning as the zones are a way of f science-based foundation to basis for the Plan. grouping areas of the Plan. Southland that have similar landform The Board considers that types and water. this zoning approach is an Southland ' s waters appropriate way of have a range of acknowledging conservation ` types ' or `varieties ' values and incorporating just like wine. Water them into decision making. composition varies according to where The Board is mindful of the it originates and the planning maxim to the effect materials it passes that if you get your water through. right, then it is likely that you're on to the big environmental issues. PU RPOSE OF THE PLAN Introduction Plan is intended to 7 SUPPORT No change is provide direction and guidance The Board supports the regarding the approach taken by sustainable use, Environment Southland. In development and so doing the Board notes protection of water that the Plan is based on a and land resources form of spatial planning at a regional scale. The Board favours this approach in that it creates an appropriate context for maintenance and enhancement of conservation values. ISSUES Water Quality Water is a 14 AMEND Amend the fundamental relevant resource The Board submits that the sentence. paragraph should be amended to read: "The Southland economy and lifestyle are based on rural production and servicing, fisheries, tourism, energy production and industrial processing, all of which rely on the availability

4 of good quality water. Maintenance of the conservation values of the Southland region also depends on the availability of water of high quality." The condition and integrity of the conservation estate and of conservation values relies on appropriate water quality and water uantit. Water Quantity The increasing 14 SUPPORT No change is demand for water,. and the link Reason: between water The Board submits in quality and water support of this precautionary quantity, are approach. In so doing, the acknowledged. A Board notes that plantation precautionary forestry can contribute approach is taken. significantly to the 'increasing demand for water' and for this reason may not be appropriate in some areas. Groundwater Consideration of the 15 AMEND Add the relevant impact of sentence. groundwater A further sentence is abstraction on needed: surface water is important Research to further characterize and quantify the aquifer resource of the region is necessary, and in the meantime a precautionary approach to water allocation from aquifers needs to be taken. The Plan notes that in March 2015 less than 50% of the groundwater primary allocation thresholds had been allocated... (But that) some aquifers are fully allocated. This points to a lack of knowledge about what is actually happening to the aquifers. Soil Resources The Plan notes the 15 SUPPORT No change is interrelationship. between soil quality The Board considers this is and structure, and an important point, well the effects of made in the Plan discharges. River and Lake The Plan notes that 16 AMEND 1. Include in

5 SOUTHLAND CONSERVATION BOARD TE ROOPU ATAWHAI 0 MURIHIKU Beds. activities on the the beds of rivers and 1. There needs to be a definitions lakes can have both definition of what is a definition positive and meant by `significant' for negative effects. in the context of significant `significant indigenous indigenous biodiversit biodiversity'. This Y-- could be included in 2. Include the definitions (the the words Board notes that wetlands, `significant de- lagoons vegetation' is defined) and fresh 2. The Board agrees water that use and activities estuaries on beds of lakes and in the rivers is a significant wording of issue. On the the Issue. assumption that the `region' does not include the CMA, then wetlands, lagoons and (fresh water) estuaries should be included. Indigenous The Plan notes that AMEND biodiversity substantial impacts Include a on ecosystems and The Board notes in particular paragraph on loss of significant (a) The loss of lowland aquatic weeds indigenous wetlands, with 90% of and their adverse biodiversity continue its original wetlands effect on to be significant now developed, biodiversity. issue, especially in resulting in loss of lowland areas productive habitats. (b) The negative impact of aquatic weeds (e.g. Didymo and La arosi hon PHYSIOGRAPHIC ZONES The Plan divides the SUPPORT No change is region into the following Physiographic identification of these zones Zones based on common attributes Alpine - all land that influence water quality is above 800m an appropriate foundation for Central Plains - the Water and Land Plan flat to gently undulating terraces in the lower reaches of the Aparima and Oreti catchments in Central Southland Gleyed - Areas that were once wetlands Bedrock/hill country

6 - rolling to steep land below 800m Lignite Marine Terraces - south coast and areas of eastern and western Southland Old Mataura - older higher terraces in the Mataura catchment Oxidising - Margins of major river systems Peat Wetlands - highly acidic peaty soils and a high water table Riverine - Margins of the major river systems The CMA AMEND. Exclude the CMA The Plan needs to address from the Plan OR the sea as a separate include "The Sea" physiographic zone if the as a separate jurisdiction of the Plan is physiographic include the CMA zone. REG ION-WID E OBJECTIVES Objective 1 Land and water and 22 SUPPORT No change is associated ecosystems are managed as integrated natural resources... Objective 2 Water and land is 22 SUPPORT No change is recognized as an enabler of the economic, social and cultural wellbeing of the region Objective 3 The mauri of water 22 SUPPORT No change is bodies provide for to hauora (health of the people, the environment and the water body) Objective 4 Tangata whenua 22 SUPPORT No change is values and interests are identified and reflected in Objective 5 Ngai Tahu have 22 SUPPORT No change is access to and customary use of...mahin a kai

7 SOUTHLAND CONSERVATION BOARD TE ROOPU ATAWHAI 0 MURIHIKU resources, nohoanga, mataitai and taipure Objective 6 There is no 22 SUPPORT No change is reduction in the quality of freshwater and water in estuaries and coastal lagoons Objective 7 Any further over- 22 SUPPORT No change is allocation of freshwater is avoided and existing over allocation is phased out... Objective 8 The quality of water SUPPORT No change is in aquifers is (maintained) and (improved where downgraded) Objective 9 The quantity of 23 SUPPORT No change is water...is managed so that aquatic The Board considers this to ecosystem health, be an especially significant life-supporting and important objective as it capacity, seeks to avoid the overoutstanding natural allocation of water that has features and adversely affected landscapes, conservation values in other recreational values, parts of New Zealand. natural character and historical heritage values are safeguarded (But that within these constraints) water is available to support the reasonable needs of people and communities Objective 10 The national 23 The Board does not wish to importance of the submit on this Objective. existing Manapouri Power scheme... is provided for and recognized Objective 11 Water is allocated 23 SUPPORT No change is and used efficiently - Objective 12 Groundwater levels 23 SUPPORT No change is and minimum surface water flows

8 where these are derived from groundwater, are maintained Objective 13 Enable the use and 23 SUPPORT No change is development of land and soils, provided The Board considers this to (a)...soil be an especially significant resource is and important objective as it not seeks to avoid the overirreversibly allocation of water and its degraded consequent adverse (b) Discharge of consequential effect on (significant conservation values. or cumulative) contaminant s is avoided (c) Adverse effects on ecosystems (including diversity and integrity of habitats), amenity values, cultural values and historic heritage values are avoided remedied or mitigated to ensure these values are maintained or enhanced Objective 14 The range and 23 SUPPORT No change is diversity of indigenous ecosystem types and habitats and their life-supporting capacity is maintained or enhanced. Objective 15 Taonga 23 SUPPORT No change is species... are recognized and provided for Objective 16 Public access to 24 AMEND Amend the river and lake beds Objective to read: is maintained... Public access to objective is generally river and lake

9 SOUTHLAND CONSERVATION BOARD TE ROOPU ATAWHAI 0 MURIHIKU appropriate, however beds is provisions should be made maintained, for exceptions such as except where during the nesting season for restrictions on threatened birds. public access are necessary to protect or enhance biodiversity values and except in circumstances where public health and safety are at risk. Objective 17 The natural 24 AMEND Re-word the character values of Objective to read wetlands, rivers and The Board considers the The natural lakes... is protected word 'inappropriate' to be character values from inappropriate value-laden and weak in an of wetlands, rivers use and objective and policy context. and lakes...is development protected from The word incompatible would i be better. incompatible use and development Objective 18 All activities operate 24 SUPPORT No change is at `good environmental practice' or better...

10 (For ease of formatting, the Board's submissions on the Region-wide Policies starts as a new table). TOPIC PLAN PROVISION PAGE SUBMISSION : DECISION SUPPORT/OPPOSE/AME SOUGHT ND AND REASON REGION-WI DE POLICIES Ngai Tahu Enable papatipu 25 SUPPORT No change is Policies 1-3 runanga to participate; take This is an obligation under into account iwi the Treaty of Waitangi plans, Ngai Tahu ki Murihiku taonga sped es PHYSIOGRAPH Avoid, remedy or IC ZONE mitigate adverse POLICIES effects on water quality from contaminants b : Policy 4 Alpine Zone: 26 SUPPORT No change is Manage erosion, and adverse Erosion and overland flows effects on water are the main threats to quality arising from water quality in this zone. overland flow; prohibit dairy farming. Policy 5 Central Plains : 26 SUPPORT No change is Requiring good Contaminants transported practices with by artificial drainage and respect to deep drainage are the contaminants appropriate focus for which may be regulatory activity in this transported by zone artificial and deep drainage; Policy 6 Gleyed: Requiring 26 SUPPORT No change is good. practices with Contaminants transported respect to by artificial drainage and contaminants overland flow are the which may be appropriate focus for transported by regulatory activity in this artificial drainage zone and overland flow Policy 7 Bedrock/Hill 26 SUPPORT No change is country: Requiring. good Contaminants transported practices with by artificial drainage and respect to overland flow are the contaminants appropriate focus for which may be regulatory activity in this transported by zone artificial drainage

11 SOUTHLAND CONSERVATION BOARD TE ROOPU ATAWHAI 0 MURIHIKU and overland flow Policy 8 Lignite-Marine 27 SUPPORT No change is terraces. Requiring good Contaminants transported by artificial drainage and practices with overland flow are the respect to appropriate focus for contaminants regulatory activity in this which may be zone transported by artificial drainage and overland flow Policy 9 Old Mataura : 27 SUPPORT No change is Requiring good Deep drainage, and practices with avoiding exacerbating respect to effects from dairying and contaminants winter grazing are the which may be appropriate foci for transported by regulatory activity in this deep drainage. zone Strongly discourage additional dairy farming and additional intensive winter grazing Policy 10 Oxidizing: 27 SUPPORT No change is Requiring good Deep drainage, overland practices with flow and artificial drainage respect to are the appropriate foci for contaminants regulatory activity in this which may be zone transported by deep drainage, overland flow and artificial drainage Policy 11 Peat wetlands: 27 SUPPORT. No change is Requiring good Artificial drainage, deep practices with drainage and lateral respect to drainage are the contaminants appropriate foci for which may be regulatory activity in this transported via zone. artificial drainage, Some of the most at risk' deep drainage, and conservation areas in lateral drainage Southland are the remaining peat wetlands Policy 12 Riverine: 28 SUPPORT No change is Requiring good. Deep drainage and practices with overland flow are the respect to appropriate foci for contaminants re ulato activity in this

12 which may be zone. transported via deep drainage and overland flow Policy 13 Management of 29 AMEND Re-word the policy land use activities to read: and discharges: Protecting significant Manage land use indigenous biodiversity Manage land use activities and should also be a focus of activities and discharges... to of land use discharges... to land and water so activities and discharges. land and water so that water quality that water quality, and the health of significant humans, domestic indigenous animals and biodiversity and the aquatic life are health of humans, protected domestic animals and aquatic life are protected Policy 14 Preference for 29 SUPPORT No change is discharges to land in preference to In general, discharges to discharges to water land are likely to be more localized in their effects and if necessary more easily remediated than discharges to water Policy 15 Maintain and 30 SUPPORT No change is improve water quality - avoid The provisions of this policy discharges to water are an important part of bodies that will achieving incremental reduce water improvement in the water quality beyond the quality of the region. zone of reasonable mixing; avoid land use activities discharges to land that will reduce surface or groundwater quality; avoid discharges to artificial watercourses that will reduce water quality (in the receiving waters) Policy 16 (1) Policy 16 (1) seeks 30 AMEND Include: to minimize the The policy also needs to (c) Ensuring that effects on water refer to the potential for any approvals for from farming freshwater aquaculture to freshwater activities, and significantly and adversely aquaculture take focuses on affect water quality into account the discouraging dairy potential adverse farming or effect of

13 SOUTHLAND CONSERVATION BOARD TE ROOPU ATAWHAI 0 MURIHIKU intensive winter aguaculture on grazing in certain water quality and areas. include effective measures to avoid, remedy or mitigate that potential adverse effect. Policy 16 (2) Policy 16(2) will 30 SUPPORT No change is require all farming activities to either This provision is likely to implement a attract a great deal of Management Plan opposition and criticism, but or be listed on a if introduced in the right way register of can result in significant independently improvement in land audited self practices in areas where this needs to participants happen. Policy 17 Avoid adverse SUPPORT No change is effects on water quality from Effluent effluent systems should not be allowed to degrade water systems, and quality manage effluent systems and discharges from them effectively Policy 18 Stock exclusion 31 SUPPORT No change is from water bodies This may be one of the most obvious provisions in the Plan to the general public who are concerned about the state of the region's waterways. Better of riparian ecosystems and habitats will enhance the conservation values of the region. Policy B7 of the 32 SUPPORT No change is National Policy Statement for The Plan must give effect to Freshwater any national policy Management statement 2014 Policy 20 Management of SUPPORT No change is water resources: Manage the taking, Active of abstraction, use, water take is an essential damming or part of the Water and Land diversion of surface Plan water and groundwater so as to (achieve good

14 environmental outcomes (1) - (4)) Policy 21 Allocation of 33 SUPPORT No change is water: Manage the allocation of There are indications that water by (following over-allocation of water has a methodology to) occurred in other regions determine(ing) the and when this occurs it primary allocation seriously affects indigenous for confined biodiversity and aquifers, conservation values. determining (when) an aquifer is fully allocated, and enabling secondary allocation whist ensuring that longterm aquifer storage volumes are maintained and reliability of supply for existing users is not adversely affected Policy 22 Management of 33 SUPPORT No change is the effects of groundwater and Active of surface water use effects of groundwater and by avoiding surface water use to avoid allocating water to over-allocation is an the extent that the important dimension of the base flow is Plan depleted; ensuring that interference effects are acceptable, and (actively managing) groundwater abstractions Policy 23 Stream depletion SUPPORT No change is effects: Manage stream depletion Maintaining minimum water effects so that the flows is critically important cumulative effect to the long-term (stays within) any maintenance of allocation regime conservation values and (maintains prescribed minimum flows) Policy 24 Water abstraction 34 SUPPORT No change is for community water supply: The priority is reasonable (Priority is given to so long as provisions 1 (a) - provision of water (h) and 2 (a)-(b) are for community adhered to water supply

15 SOUTHLAND CONSERVATION BOARD TE ROOPU ATAWHAI 0 MURIHIKU subject to provisos 1 (a) - (h) and 2 (a) - (b) Policy 25 Priority takes: 34 AMEND Re-word the Policy When issuing a to include: water shortage In certain circumstances it direction, may be appropriate to give (6) supporting Environment priority to conservation communitie Southland will give needs, even at a time of s of priority to water shortage significant (1) reasonable indigenous domestic biodiversity needs (2) reasonable animal drinking needs (3) fire fighting purposes (4) public health needs; or (5) animal welfare needs Policy 26 Renewable 35 (No comment) energy Policy 27 Bore construction 35 (No comment) and Policy 28 Structures and 35 SUPPORT No change is bed disturbance activities of The inclusion of `significant rivers... and lakes; indigenous biodiversity' as Manage structures an element of this policy is and bed important. disturbance activities so as to avoid remedy or mitigate adverse effects on (1) -(2) ; (3) significant indigenous biodiversity; (4) - (12) Policy 29 Provide for the 35 AMEND Provide for the extraction of extraction of gravel in a way The Board has difficulty with gravel in a way that avoids, the use of the word "or" at that avoids, remedies or the end of (1) and (2). remedies or mitigates adverse These provisions need not mitigates adverse effects on rivers be mutually exclusive effects on rivers and their margins and their margins and and (1) maintains (6) maintains or or enhances enhances

16 aquatic or aquatic or riparian riparian habitat, or habitat, er (2) ensures no and long term (7) ensures no net loss of long term habitat in net loss of the river habitat in channel the river and flood channel plain, or and flood (3) maintains plain, or or and enhances flood (8) maintains protection, or erosion enhances control or flood the integrity protection, of physical erosion resources, control or the integrit y (4) does not of physical adversely resources, affect the and cultural (9) does not values adversely associated affect the with the cultural river, values including associated mahinga kai with the and taonga river, species including habitat, mahinga kai mataitai and taonga and species taiapure, habitat, and mataitai (5) does not and adversely taiapure, affect and recreational (10) doe values s not adversely affect recreational values Policy 30 Drainage 36 SUPPORT No change is Maintenance: Ensure that It is important to ensure that drainage drainage works are managed in such a way as activities... are to address effect on the managed in such a aquatic environment way that either

17 SOUTHLAND CONSERVATION BOARD TE ROOPU ATAWHAI 0 MURIHIKU avoids, remedies or mitigates adverse effects on the aquatic environment, or maintains or enhances habitat value Policy 31 Whitebait stands : 36 SUPPORT No change is Restrict allocation of space for Further proliferation of whitebait stands... whitebait stands is not compatible with conservation values Policy 32 Protect 36 SUPPORT No change is significant indigenous Protection and vegetation and enhancement of significant habitat: Protect indigenous biodiversity will significant have a positive impact on indigenous soil health and water vegetation and quality. significant habitats of indigenous fauna to improve soil health, water quality, and ecosystem health Policy 33 Adverse effects 36 SUPPORT No change is on wetlands Prevent the Protection and reduction in area, enhancement of remaining function and quality wetlands is a conservation of wetlands, priority in the Southland including through region drainage and vegetation removal Policy 34 Restoration of 36 SUPPORT No change is existing wetlands and the creation Opportunities for better of wetlands: of storm water Recognize the flows through creation of importance of wetlands should be actively wetlands and encouraged. Improvements indigenous in water quality and biodiversity, biodiversity are likely to particularly the result. potential to improve water quality, through encouraging (1) Maintenance and restoration of existing wetlands... (2) Establishment of wetland areas...

18 (3) offsetting peak flows and assisting with flood control Policy 35 Discharge waste 36 (No comment) and clean fill appropriately... Policy 36 Manage land 36 (No comment) contamination Policy 37 Climate Change 37 SUPPORT No change is Environment Southland is right to take into account the effects of climate change including the potential for more variable and extreme weather patterns Policy 38 Natural Hazards 37 CONSIDERATION O F RESOURCE CONSENT APPLICATIONS Policies The Board does not wish to comment, other than to note the role of the Board as a statutory body which should be consulted on matters within its authority and jurisdiction. FRESHWATER MANAGEMENT UNIT PROCESS POLICIES Policies AMEND Amend Policy 46 The Board considers that (first bullet point) to the first bullet point under clarify as follows: Policy 46 needs to be amended to clarify which Fiordland 'islands' the Policy is and the referring to. islands (!define Apart from this, the Board which does not wish to comment, islands) other than to note that these provisions for further refinement of the way fresh water is managed appear to be appropriate The Board's submission focuses on the Objectives and Policies. If an activity complies with the Rules, then it follows that it will also comply with the objective and policies. If it does not comply with the Rules as a permitted activity and resource consent is required, then the objectives and policies are the criteria against which any resource consent application will be assessed.

19 SOUTHLAND CONSERVATION BOARD TE ROOPU ATAWHAI 0 MURIHIKU The Board wishes to submit only on the following rules: TOPIC PLAN PROVISION PAGE SUBMISSION : DECISION SUPPORT/OPPOSE/AME SOUGHT ND AND REASON Rule 9 Discharge of 44 AMEND Include Use of agrichemicals As the Plan stands, it would chemicals for the onto or into not be a Permitted Activity control of pest surface water to use chemicals - because plants along they would not be waterways o to `agrichemicals' - to kill assist in the plant pests along development of waterways for conservation riparian areas along outcomes or to assist in the the margins of development of riparian waterways as a areas along the margins of discretionary waterways. It is not clear activity, in a where such an activity separate Rule if would fit within the Plan, necessary. and the Board suggests that provision should be made for it as a discretionary activity. Rule 15 Discharge of 46 AMEND Amend (vi) to read: Storm water While the Board supports (vi) For discharges the thrust of the rule, to land, the provision (vi) should be discharge does not amended to the effect that cause flooding, flooding, erosion or land erosion, or land instability should not be instability to any caused to any property other person's (which includes public as property. well as pri ate property). Rule 18 Discharge of 47 AMEND Add a provision to water from The Board supports the Rule 18 to impose purging of thrust of the Rule, but a condition (e) to instruments at a submits that temperature ensure that any water treatment should also be controlled increase in plant temperature form this activity is controlled Rule 19 Discharge of 48 AMEND Add a provision to water associated The Board supports the Rule 19 to impose with water thrust of the Rule, but a condition (d) to treatment submits that temperature ensure that any purposes should also be controlled increase in temperature form this activity is controlled Rule 74 Wetlands 97 SUPPORT No change is The Board sees the maintenance and enhancement of wetlands

20 as a conservation priority. This may require their being fenced in order to give effect to Rule 74(C) Rule 79 High Country 101 AMEND OR CLARIFY The aerial extent of Burning The USB Flash Drive Zones A, B and C supplied by Environment needs to be Southland (to consultants) clarified across the containing the Maps which whole region. form part of the Plan includes only one map in (If the maps have the section Map Series 6 not been widely or which does not cover the properly 'published' whole region. It is thus not a further immediately clear whether opportunity to "Zone C" (where use of submit may be land for the burning of necessary.) vegetation is to be a permitted activity) covers the lowland peat areas. By inference, it may do. The Board submits that the damaging fires that have occurred in the past in some of the southern peatlands are sufficient evidence that fire in these areas should be regulated. Other matters: The board wishes to submit as follows: TOPIC PLAN PROVISION PAGE SUBMISSION : DECISION SUPPORT/OPPOSE/AME SOUGHT ND AND REASON Appendices Appendix E 155 AMEND Clarify what is meant There needs to be a by 'Natural State clarification of what is Waters". meant by "Natural State Waters" in this context DOG