Submission - Rosalie Snoyink

Transcription

1 IN THE MATTER of the Resource Management Act 1991 ( the Act ) AND IN THE MATTER of 6 applications by Mainpower New Zealand Limited, Rooney Holdings Ltd, Kakapo Brook Joint Venture Ltd and Rooney Farms Limited Submission - Rosalie Snoyink Introduction 1. My name is Rosalie Snoyink. I live in Glentunnel (mid Canterbury) but have a strong interest in the whole region when it comes to matters relating to Canterbury`s freshwater resource, its outstanding natural landscapes and features, and its indigenous biodiversity. 2. I frequently travel the Lewis Pass Highway between the East and West Coast so I am familiar with the application area. 3. Over the last 15 years I have submitted on a number of applications for resource consents to take and use water in Canterbury. I also submitted on the Hurunui Water Conservation Order, the amendments to the Rakaia Water Conservation Order and the Canterbury Land and Water Regional and Sub Regional Plans. 4. I oppose the applications because of the adverse effects on the environment. I consider the Kakapo Brook irrigation/ power generation proposals to be an inappropriate development in this part of the catchment.

2 Key Concerns The proposed hydro power generation 5. I don t believe the proposed hydro power is necessary. Recent analysis shows that national electricity demand has remained constant since Per household consumption has fallen for a variety of reasons. (Trends in Residential Consumption, Batstone and Reeve, August 2014). 6. NZ will have an abundance of power if the Tiwai Point smelter is closed. The current agreement expires in New Zealand already has as much electricity as it needs and closure of the smelter would release one seventh of New Zealand s capacity onto the market. (Radio NZ, 3 August 2015). 7. I am not sure why Hanmer needs an additional source? Are the power outages as a result of capacity or damage to supply lines? 8. North Canterbury will have an alternative supply when the consented Hurunui Water Project is up and running. I consider the proposed take from Kakapo Brook for hydro generation to be an inefficient use of water. Adverse effects on Kakapo Brook 9. I have read the s 42A report and agree with Ms Van Looy`s conclusion that water takes from Kakapo Brook are likely to generate a very high hydrological alteration to the flow regime of Kakapo Brook and The resulting flow regimes, particularly in dry years, are likely to generate a high risk on river ecology and hydrological functions. 10. The take is excessive and the degree of hydrological alteration is contrary to the objectives of the Land and Water Plan. It is totally inappropriate in this day and age to consent a water take which would likely flat line 750 metres of an alpine braided river for 85% of the year (para 133 S42A).

3 11. Kakapo Brook may flow through the applicant`s property but the river is not available solely for the applicant`s use. The water belongs to current and future generations of New Zealanders. 12. Effects on significant ecological values as a result of flat lining the river are not confined to a small section of Kakapo Brook but are likely to be observed throughout the full length of Kakapo Brook below the abstraction point and potentially the Hope River and Waiau River below the confluence. (Para 36 s42a Report, Dr Adrian Meredith). 13. Some of the native freshwater fish species at risk recorded in Kakapo Brook are longfin eel (At risk Declining), Alpine galaxias (At risk Naturally uncommon), Canterbury galaxias (At Risk Declining). 14. I have not seen a comprehensive survey of native birds using Kakapo Brook as nesting and feeding habitat but I note in Mr Grove s report that two at risk birds have been recorded i.e. the endemic Black fronted tern (Nationally endangered) and Banded dotterel (Threatened Nationally vulnerable). The endemic New Zealand Pipit has also been recorded. 15. Has there been a study of other riverbed terrestrial species that may be present in this location? Do we know what is there? 16. Ms Van Looy writes that Kakapo Brook is a natural state water body with no existing modification. The proposal is contrary to Policy of the CRPS as the natural character of Kakapo Brook will not be preserved. Adverse effects on wetlands 17. I am concerned at the continuing loss of wetlands and associated ecosystems. Over 90 percent of New Zealand s wetlands have been drained or filled. Our wetlands support a greater diversity of native birds, fish, invertebrates and plants than most

4 other habitats. Many wetland species are threatened with extinction. (National Wetland Trust of NZ). 18. There are four wetlands on the property which could be adversely affected by nutrient enrichment, sedimentation, reduction in flows, and proposed earthworks. Stock access also degrades wetland areas. 19. From the evidence I read the wetlands most at risk are the main Kakapo Brook Swamp, Lower and Upper Dismal Valley Swamps and the Lower Hope Escarpment Swamp. Lake Lorraine is also at risk because of its location down gradient of the proposed irrigation area. 20. Wherever intensive farming activities occur close to lakes and wetland areas water quality begins to decline. Recent Environment Canterbury water monitoring in some high country lakes showed that nearly all the 14 lakes monitored have deteriorated as a result of nutrients and phosphorous from intensified farming In my view the damage to Canterbury s freshwater ecosystems has largely been for the benefit of private interests, at the expense of the public interest. Decisions have been made based on short term economic gains resulting in long term and often irreparable environmental loss. 22. The Kakapo Brook irrigation/hydro proposals will not restore or enhance wetlands as required by the Canterbury Regional Policy Statement, Policy The proposal will not safeguard the life supporting capacity ecosystem processes, and indigenous species and their associated freshwater ecosystems, and mauri of water as required by the Canterbury Regional Policy Statement (CRPS) Objective

5 Adverse effects on the landscape 24. Another key concern is the landscape change occurring in the high country as a result of land intensification. The Plains landscapes are nearly all modified. Over recent years the landscape change from dry grasslands to green exotic pasture, mostly for dairy conversions, has been dramatic.large areas of the Canterbury plains have been denuded. Native vegetation, shelter hedges and trees have been removed to make way for intensive farming and its associated irrigation infrastructure (intakes, pumps, pipes, canals, powerlines, centre pivots, fences, tracks and buildings). Intensive farming has industrialised parts of the Canterbury landscape. 25. The degradation of the Plains landscapes makes our high country landscapes even more precious as people seek out NZ s natural, wild and scenic places for tourism, recreation and general well-being. 26. Glynn Wye Station is one of the `gateway stations` to the Southern Alps. It is located within the Lake Sumner - Lewis Pass region which has been identified as an area of Outstanding Natural Feature and Landscape (ONL/F) in the Canterbury Regional Landscape Study Review, July Glynn Wye is an iconic high country station, with a mix of dry tussock grasslands, grey shrub lands (matagouri and manuka) and alpine vegetation. Although some parts of the station are modified the property sits well within the context of an outstanding natural landscape. 28. While the proposed physical structures viewed from the highway will degrade important landscape values I think views from the road should not be the only consideration. There will be other higher vantage points, and aerial views of the development. It creates an inequitable situation for landowners whose properties are clearly visible to the travelling public. The view from the highway does nothing to protect the biodiversity. Just because you can t see it doesn t make it acceptable or appropriate.

6 29. The proposal is contrary to Objective of the Canterbury Regional Policy Statement (CRPS) which seeks to identify and protect outstanding natural features and landscapes from inappropriate development (my emphasis). Glynn Wye is included in Zone A of the Hurunui Waiau Development Zones which classifies it as area inappropriate for further development and land intensification practices. Adverse effects on biodiversity 30. As intensive farming moves from the Plains, which is now virtually stripped of native bio diversity, to the foothills and intermontane valleys and basin floors in the high country, the loss of native bio diversity continues. I have witnessed several incidences of the clearance of tussock grasslands and matagouri shrublands being cleared to make way for fodder crops. These dryland ecosystems are irreparably destroyed. 31. Looking at the big picture New Zealand is one of 25 countries classified as a global bio diversity hotspot, based on exceptional concentrations of endemic species and undergoing exceptional loss of habitat. Global Biodiversity Hotspots Myers et al 2000 NATURE

7 32. Among our plants, 289 are threatened and 749 are at risk, meaning they are likely to be extinct within the next century. This is nearly 40 percent of the total number of New Zealand s native plant species. Native freshwater fish have suffered even greater declines, with 74 percent currently at risk or threatened. Of the 417 bird species still present in New Zealand (56 species are already extinct) over 40 percent are now threatened or at risk (Dr Marie Brown, Vanishing Nature 2015). 33. One of the threats to biodiversity from these proposals is the potential effect of increased nutrients and other contaminants leaching to freshwater ecosystems. The applicant claims there will be no increase in nitrogen and possibly a reduction. If this is so, it will be an exception. In my view there are too many uncertainties in the predicted models. 34. With irrigation the low intensity farming historically practised on Glynn Wye station (sheep, beef and deer) may in future give way to intensive farming activities such as dairy and dairy support, with higher stock numbers, higher volumes of effluent, and increased inputs of nitrogen, phosphorous and other pollutants. 35. Mr Rooney claims in his evidence (paras 45 52) that irrigation provides significant ecological benefits. With all due respect I consider that irrigation is one of the main causes of biodiversity loss as dryland areas of indigenous vegetation are cleared, cultivated, fertilised and watered. Native plants give way to exotic grasses, dryland species of flora and fauna disappear. 36. Bird species are attracted to artificial ponds and canals but these cannot be claimed as ecological enhancement. There is no substitute for nature. 37. Dryland ecosystems especially are destroyed irreparably by cultivation and irrigation. Aquatic ecosystems are destroyed by abstraction, drainage and nutrient enrichment.

8 38. Again, taking the big picture view, nutrient enrichment of our waterways is problematic the length and breadth of the country. Nitrogen is now a major planetary pollutant, with widespread impacts on human health, ecosystem health and biodiversity. Three boundaries (in red) have been exceeded: Climate Change, Rate of Biodiversity Loss, and Nitrogen. NATURE/Vol.461/24 September 2009 (Rockstrom et al) The unique thing about NZ s biodiversity is that it is diverse. Biodiversity builds resilience into ecosystems. There needs to be a shift away from the current industrial farming model of monoculture which is the opposite of Bio Diversity.

9 40. New Zealand has dryland and aquatic ecosystems that have evolved over millions of years. So many of our species are endemic, and they have been here a very long time. That long time is known as deep time endemism. (eg Robust grasshopper, Brachapsis robustus, first identified in the Mackenzie Basin in 1963, has changed little in 100 million years. Braided River Field Guide 2001 Department of Conservation). Indigenous species of flora and fauna still wait to be discovered. Conclusion 41. Most of our lowland rivers and streams are polluted. So far water quality in the high country has been protected by less intensive farming methods. 42. The proposal if consented will add to the incremental change and overall loss of water quality, biodiversity and landscape integrity. Business as usual provides only for ongoing loss. 43. Under the RMA adverse effects are to be avoided as determined in the recent Environmental Defence Society v NZ King Salmon decision. 44. The proposals are inconsistent with the purpose of the RMA to promote sustainable management of natural and physical resources as required in Part 2, Section 5. (2) (a), (b) and (c). 45. The proposals are inconsistent with Part 2, Section 6 (a), (b) and (c) that provides for the preservation of natural character of lakes and rivers, the protection of Outstanding Natural Features and Landscapes, and the protection of significant indigenous vegetation and significant habitats of indigenous fauna. I request the applications be declined

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