11. NATURAL HAZARDS. Submitter 14 CPHWC. Support 28 INTAF. Oppose 54 STRAT. Oppose in part 54 STRAT GENERAL SUBMISSIONS ON NATURAL HAZARDS

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1 11. NATURAL HAZARDS GENERAL SUBMISSIONS ON NATURAL HAZARDS Decision Requested: 11.1 Submitter 14 CPHWC We agree that natural hazards pose a significant risk to the West Coast. Further submission (INTAF) Decision Requested: 11.2 Submitter 14 CPHWC Oppose 54 STRAT Furthermore, while we understand the Courts have said that Councils do not need to have regard to those activities that may accelerate climate change, it would be more prudent for an RPS to take steps to avoid enabling actions that will contribute to climate change. We are disappointed that the Regional Economic Development Plan, which links to the RPS and Regional and District Plans, has an action point to further develop mining on the West Coast. Further submission (INTAF) Further submission (STRAT) The climate change issue, insofar as New Zealand s contribution to the global response is concerned, is addressed under the Climate Change Response Act 2002, and not under the RMA. Noted The submitter does not provide any revised text for consideration. As required by Section 7 of the RMA, the Proposed RPS deals with the effects of climate change and not the causes, as is requested by the submitter. Other legislation deals with the causes. Mining is sanctioned nationally, with the extraction of minerals regulated by New Zealand Petroleum and Minerals, an arm of Government. Any moves to address climate change through restrictions on the mining industry need to be made at a national level. Decision Requested: 11.3 Submitter 14 CPHWC Oppose in part 54 STRAT The draft RPS s intention of preventing inappropriate building risk because of future costs to subsequent owners and Councils is sound. We question then why the RPS would allow for an activity which will have the same effect? Allowing people to continue to burn fossil fuels is also inappropriate as the costs and risks of doing so will also be passed on to people and Councils. We encourage Council to work to increase community awareness on the long-term effects of using fossil-fuels by providing up-to-date research regarding the burning of fossil fuels and climate change. Summary of s Natural Hazards

2 Further submission (INTAF) Further submission (STRAT) Opposed, with a qualification. The climate change issue, insofar as New Zealand s contribution to the global response is concerned, is addressed under the Climate Change Response Act 2002, and not under the RMA. There is no harm in education on the fossil fuels issue, provided the information is accurate and relevant. Reject As set out in Decision Requested 11.2 and repeated by the further submitter, the causes of climate change are dealt with in other pieces of legislation, not the RMA. Also refer to Decision Requested Decision Requested: 11.4 Submitter 18 EDS Concerns raised in Decisions Requested 9.82, 9.87, 9.91, [of the Coastal Chapter] are equally relevant to Natural Hazards Chapter. Further submission (ELWEP) I support the submission and relief sought. My reasons echo those advanced by EDS. in part Coastal hazards are a form of natural hazard and therefore when considering coastal hazards, it is necessary to read both Chapter 11 and Chapter 9 together. Specific responses have been provided to each of the Decisions Requested in the Coastal Environment Chapter. Many of the points raised relate to the NZCPS and it is noted that in many instances there is no equivalent national policy to be given effect to outside of the coastal environment. However, in order to make it clear how the Proposed RPS is to be used, a revision to this Chapter is suggested below. Additionally, Policy 4 of Chapter 9 is also related to Chapter 11, and therefore an amendment to the Related Policies is also recommended. Revised Text: Explanation to the Policies Hazards within the coastal environment are also addressed in Chapter 9: Coastal Environment, and these chapters should be read together when considering coastal hazards. Related Policies Policy 1 of Section 2 [Resource Management Issues of Significance to Poutini Ngāi Tahu]; Policy 2 and 5 of Section 4 [Resilient and Sustainable Communities]; Policy 3 of Section 6 [Regionally Significant Infrastructure]; Policy 3, 4 and 5 of Section 9 [Coastal Environment]. Decision Requested: 11.5 Submitter 26 HNZ The proposed RPS does not consider the impacts on historic heritage as a result of natural hazards. HNZ notes that the requirements to earthquake strengthen buildings under the provisions of the Building Act applies to Districts within the Region. These matters require a level of guidance and leadership from a number of parties. That the Natural Hazards chapter is revised to recognise the impact on historic heritage from natural hazards. Reject Summary of s Natural Hazards

3 Historic heritage would be included under the definition of property and built environment and is therefore considered within the Natural Hazards Chapter. The submitter does not explain why it is necessary to single out historic heritage in this Chapter, and it is not clear what value would be added to the Chapter in doing so. The submitter may also wish to note the recommended changes to Chapter 4 in respect of historic heritage provisions (see Decision Requested 15.3 in particular). Decision Requested: 11.6 Submitter 28, 33 INTAF, KMCT Oppose 54 STRAT This chapter needs to show how global warming and climate change are both linked to economic activity, where the capacity of the biosphere to protect itself is being incrementally destroyed by not just the overuse of our natural resources but also the ways in which they are being used. Further submission (STRAT) The climate change issue, insofar as New Zealand s contribution to the global response is concerned, is addressed under the Climate Change Response Act 2002, and not under the RMA. Reject See Decision Requested and 11.2 as these reasons apply to this submission point. In particular, the submitter is referred to Sections 70A and 104E of the RMA that state.a regional council must not have regard to the effects of such a discharge on climate change. As this is a central government responsibility, there is no need to add provisions for addressing the causes of global warming and climate change in the Proposed RPS. Decision Requested: 11.7 Submitter 68 WDC Natural hazards have been identified as a significant resource management issue in the RPS and this is supported. There is growing understanding of the risks and effects of natural hazards and the importance of attempting to reduce the substantial effects that a natural event can have. The Westland District Council has been working on potential hazard controls in the Franz Josef area and attempting to control or reduce the effects of fault rupture during an Alpine Fault earthquake event. We expect that these kinds of attempts will be supported through the RPS. Noted The Proposed RPS supports the types of actions referenced by the submitter. No specific change to Chapter 11 is requested in this submission. Decision Requested: 11.8 Submitter 68 WDC It is also considered that in promoting the development of the region consideration needs to be given to those areas which are appropriate for development and will not be susceptible to significant natural hazards. A developer would expect to have this information readily available in considering the establishment of an activity. Summary of s Natural Hazards

4 Noted As set out in the Chapter, there is an increasing amount of information becoming available that shows which areas of the Region are susceptible to natural hazards. Information on the locations of hazards will be published and made use of as this information becomes available. Most natural hazards are, by their very nature, unpredictable. Research on natural hazards will be ongoing to ensure we can be as informed as possible in assessing likely risk, and this information will be shared widely. The submitter may also want to consider the changes recommended in response to Decision Requested and which may also be relevant to the points raised. The submitter has not requested any specific change in this submission point. BACKGROUND TO THE ISSUES Decision Requested: 11.9 Paragraph 3 - Support in part: Good natural hazard planning includes managing catchments as a whole including the coastal marine area in an integrated manner. For example indigenous vegetation removal in a steep catchment can result in large quantities of sediment entering water and increased flood flows. Climate change exacerbates these hazards for example more intense rainfall events. Amend Paragraph 3 to read:...this can exacerbate potential natural hazards. And Good planning is needed. This planning includes the integrated management of a catchment subject to natural hazards from the mountain tops, to and including the coast so that use and development do not exacerbate, for example, flood risk. Secondly good planning includes avoid locating inappropriate land uses in high risk areas. Further submission (ELWEP) We submit in support of that part of the submission by DOC relating to natural hazards.the WDC has submitted on relevant part of this submission. in part The Proposed RPS is designed to be a high-level, strategic document, and seeks to focus on the significant resource management issues facing the Region. Whilst the Council accepts the principles set out by the submitter as being of value, and acknowledges the importance of integrated management in the Proposed RPS (in the Coastal Environment, and Integrated Management and Cross Boundary Processes Chapters), they can be achieved in a simplified manner. Revised text to address the submitters point is suggested below. The further submitter s points (WDC) about development exacerbating natural hazards, and responsibility for hazard management, are addressed elsewhere in this Recommending Report, in particular Decision Requested 11.74, which suggests a revision to the Chapter to acknowledge the importance of integrated and collaborative work between organisations. Summary of s Natural Hazards

5 Revised Text Background to the Issues Paragraph 2: The West Coast has a range of high risk environments that are susceptible to natural hazards. The potential impacts of natural hazard events range from general nuisance to creating significant damage and loss of property and, in extreme cases, loss of lives. These can lead to high economic and social costs on the West Coast with significant consequences for public health and safety, agriculture, housing and infrastructure. Managing natural hazards takes a collaborative effort from a range of organisations including government, local government, crown agencies, infrastructure providers, businesses and local communities. [DR 11.60] Management of natural hazards should be undertaken in an integrated manner within catchments. Decision Requested: Oppose 21 FFNZ Paragraph 5 - Oppose in part: Peoples and communities health and safety is a requirement of s5 RMA. S106 RMA has specific requirement that consent authorities may refuse a consent application for a subdivision for an area subject to a range of natural hazards. In the coastal environment, this paragraph fails to implement NZCPS Amend Paragraph 5 by deleting the first sentence that states: Under the Resource Management Act (RMA),..against the risk to people, property infrastructure from natural hazard events. Further submission (ELWEP) We submit in support of that part of the submission by DOC relating to natural hazards. The WDC has submitted on relevant part of this submission. Further submission (FFNZ) While FFNZ is supportive of taking an integrated catchment approach to natural hazard planning, we are of the firm view that Part 2 of the RMA requires and overall balancing approach to be taken. Thus we would be concerned by the removal of this sentence. in part Provisions within the NZCPS are primarily given effect to in the Coastal Environment Chapter, and in response to Decision Requested 11.4 a revision to the text to make the linkages between the Chapter 9 (Coastal Environment) and Chapter 11 (Natural Hazards) is recommended which may address some of the submitter s concerns. The Coastal Environment chapter gives effect to the NZCPS policies for managing coastal hazard risk, however it does not mention the precautionary approach required by the NZCPS in the coastal environment. A reference to this should be added to Chapter 9 for completeness, as this approach underpins the Chapter 9 coastal hazard policies. See the Revised Text under Decision Requested It is unclear how the points that the submitter raises relate to their request to delete the first sentence of paragraph 5. The submitter s reasoning for deleting the sentence is generally unclear. Summary of s Natural Hazards

6 Decision Requested: Submitter 28, 33 INTAF, KMCT Oppose 54 STRAT Amend the Background to the Issues: The effects of climate change are addressed in this Section. The West Coast is expected to have both experiencing more severe and frequent extreme weather events, and expected to worsen in future decades. This can exacerbate potential natural hazards and good planning is needed to avoid locating inappropriate land uses in high risk areas... The management of natural hazards in New Zealand is under review. Following the Canterbury and Christchurch earthquakes the management of natural hazards is being reviewed through the government RMA reform proposals If enacted, and natural hazard management may will be elevated to a matter of national importance. Further submission (STRAT) There is no scientific evidence to suggest that the West Coast is in fact experiencing more severe and frequent extreme weather events as a consequence of human-caused climate change. To be clear, Straterra agrees that human-caused climate change is occurring, and that good forecasts can be made as to trends. At issue is that the current effects of climate change, insofar as weather is concerned, are unknown or unclear. in part In respect of the submitters first requested change to the paragraph, this sentence is based on evidence set out in a background document titled Managing Natural Hazard Risk in New Zealand Towards More Resilient Communities: A Thinkpiece (see in particular pg. 12). To amend the sentence in the manner reflected by the submitter would not reflect the evidence set out in this document. In relation to the second change proposed, it is accepted that the wording proposed is now out of date. Revised text is suggested below to address this point. Revised Text Background to the Issues Paragraph 6 The management of natural hazards in New Zealand is under review. Following the Canterbury and Christchurch earthquakes the management of natural hazards is being reviewed through the government RMA reform proposals If enacted, The management of significant risk from natural hazards has recently been natural hazard management will be elevated to a matter of national importance under Section 6 of the RMA, and is likely to be supported by a National Policy Statement in future. Future planning for natural hazards will require an adaptive management approach and flexibility to allow for new information and/or changing legislation. Decision Requested: Submitter 31 KAYEB Oppose 54 STRAT The paper reads as if climate change is in doubt, and that coal has a viable future. Climate change is happening now see occurrences such as Cyclone Ita and the inundation of Punakaiki and many Pacific Islands. And coal is a sunset industry it needs to be phased out. Rephrase possible climate change effects to impending and already occurring effects. And treat coal as the hasbeen it is. Further submission (STRAT) Coal is not a sunset industry. As matters stand West Coast coals will continue to be exported for steel-making, and will continue to be supplied for a wide range of domestic uses, e.g., the Universities of Canterbury and Otago for heating, and similarly for schools and hospitals in the South Island, dairy and other food processing, and many other industries in the South Island, e.g., wood, leather, wool processing, and hothouse horticulture. Reject Summary of s Natural Hazards

7 There is no reference to coal or mining in this Chapter. However, mining is sanctioned nationally, with the extraction of minerals regulated by New Zealand Petroleum and Minerals, an arm of Government. Any moves to address climate change through restrictions on the mining industry need to be made at a national level. ISSUE 1 Decision Requested: Support - Natural hazards are a very significant risk on the West Coast. Retain Issue 1 as notified. Further submission (ELWEP) We submit in support of that part of the submission by DOC relating to natural hazards. The WDC has submitted on relevant part of this submission. Decision Requested: Submitter 21 FFNZ Federated Farmers supports the issue proposed and considers that an appropriate focus does need to be on increasing public awareness of, and planning for, natural hazards to ensure communities become more resilient. That Council adopts the issue proposed. Decision Requested: Submitter 46 NZP&M Support The regionally significant resource management issues for the West Coast are substantively identified. Summary of s Natural Hazards

8 Retain without amendment. Decision Requested: Submitter 63 WCCB The WCCB are in agreement with statement 1. ISSUE 2 Decision Requested: Support - Increased public awareness and planning for natural hazards is required on the West Coast. Retain Issue 2 as notified. Further submission (ELWEP) We submit in support of that part of the submission by DOC relating to natural hazards. The WDC has submitted on relevant part of this submission. Decision Requested: Submitter 21 FFNZ Federated Farmers supports the issue proposed and consider that an appropriate focus does need to be on increasing public awareness of, and planning for, natural hazards to ensure communities become more resilient. Summary of s Natural Hazards

9 That Council adopts the issue proposed. Decision Requested: Submitter 46 NZP&M Support The regionally significant resource management issues for the West Coast are substantively identified. Retain without amendment. The support is acknowledged Decision Requested: Submitter 63 WCCB Whilst the WCCB are in agreement with statement 2, is not clear what making communities more resilient will mean. Reject The Issue sets out, in broad terms, the significant resource management issue for the Region. In this sense, resilient can be assumed to have its dictionary definition ( able to withstand or recover quickly from difficult conditions ). The ways in which the Issue will be addressed, what this means for Plan users, and what this will look like environmentally, is described in the Objective, Policies, Methods and Anticipated Environmental Results. NEW ISSUE Decision Requested: Support in part 21 FFNZ Oppose 44 NZCC A new issue is required: The potential for inappropriate use and development to exacerbate natural hazards risk. An example includes clearing indigenous vegetation in hill catchments that have communities in their lower catchments located on flood plains or alluvial fans. Include the following issue: The potential for inappropriate use and development to exacerbate natural hazards risk. Further submission (ELWEP) Summary of s Natural Hazards

10 Further submission (FFNZ) FFNZ tentatively supports the inclusion of the issue, but we are concerned at the potentially wide ranging suite of activities which could be captured by this issue. FFNZ would welcome the opportunity to discuss how such an issue could be drafted. We submit in support of that part of the submission by DOC relating to natural hazards.the WDC has submitted on relevant part of this submission. Further submission (NZCC) We oppose the relief sought in all submission points. The reasons for this include, but are not limited to: - Departure from, and failure to consider, the provisions of the Resource Management Act 1991 (RMA). - The proposal by DOC could lead to the majority of the West Coast being considered as having significant values or areas. The as drafted and existing processes provide what is required by the RMA and s6 of the same. - Seeking of the avoiding effects where this is not required nor appropriate. - Misapplying the New Zealand Coastal Policy Statement 2010 (and King Salmon decision). - Trying to elevate land held under other Acts and require protection of these. - DOC Biodiversity Guidance is considered to be unworkable in its current format. - Conflict with other planning processing and functions. - Elevates all indigenous biodiversity and not just that considered significant. - It is not appropriate to try and prevent discharges to land. - All vegetation has the potential to assist with erosion and flood control. Elevating the protection of this type of vegetation on the basis of hazard mitigation is not believed to be appropriate. Existing planning documents provide for erosion and flood control with respect to vegetation clearance. - Results in the stifling and/or prevention of development where appropriate and where potential effects can be managed as provided for under the RMA. in part It is accepted that use and development can exacerbate the risk from natural hazards and that this is an issue experienced on the West Coast. It is for this reason that the Regional Land and Water Plan has clear rules controlling the size of area on moderately and steeply sloping land where vegetation can be disturbed or earthworks undertaken, for the prime purpose of reducing the risk of slope or land surface instability, subsidence, or other erosion. A new Issue is recommended to be inserted to address this. Objective 1 and Policy 2 cover this issue broadly, but additional explanation to Policy 2 is recommended to ensure this is clear. Revised text New Issue 3: Subdivision, use and development can contribute to natural hazard risk. Explanation to the Policies New paragraph 3: Subdivision, use and development that may cause or contribute to a natural hazard should be planned for. In some cases activities in an area may cause or contribute to a natural hazard affecting another area. For example, an upstream or inland land or river use can have downstream or downgradient hazard effects on other development. The risk of subdivision, use and development affecting or exacerbating a hazard risk elsewhere needs to be assessed in plan and consent processes. OBJECTIVE 1 Decision Requested: Summary of s Natural Hazards

11 Support - The objective is consistent with RMA. Retain Objective 1 as notified Further submission (ELWEP) We submit in support of that part of the submission by DOC relating to natural hazards.the WDC has submitted on relevant part of this submission. Decision Requested: Submitter 21 FFNZ We seek a balanced approach to natural hazards that recognizes the role of Councils in ensuring that financial (and other) risks to the West Coast community are minimised, without undue interference in the day to day activities of the West Coast people. As it is not always practically possible to avoid the risks and impacts of natural hazard events, we propose that the words are avoided or minimised in Objective 1 is substituted by should be minimised where practically and economically feasible, following cost/benefit analysis. That Council amends the wording of Objective 1 as follows (or similar): The risks and impacts of natural hazard events on people, communities, property, infrastructure and our regional economy are avoided or minimised should be minimised where practically and economically feasible following cost/benefit analysis. Reject Like the submitter, the Council also seeks to take a balanced approach to natural hazards. It is for this reason that the Objective provides an either/or provision. In the event that risks and impacts of natural hazards cannot be avoided because it is not practical or economically feasible to do so, the Objective will require the risks or impacts to be minimised. This is a sensible approach and takes into account the costs associated with developing land in a hazardprone area which can lead to a greater risk of harm to people, property and infrastructure. Decision Requested: Submitter 44 NZCC Support Objective 1. Nil Summary of s Natural Hazards

12 Decision Requested: Submitter 61 TRUSTP Support 69 WESTP Trustpower supports recognition of the West Coast as having a range of high risk environments that are susceptible to natural hazards, and that measures need to be taken to minimise the potential impacts of natural hazard events. Retain Objective 1. Further submission (WESTP) Grant relief sought. It is appropriate to have an objective seeking to avoid or minimise risks and impacts of natural hazards. Decision Requested: Submitter 68 WDC A review of the provisions of the RPS identifies a strong objective relating to the need to increase community awareness, improving planning to reduce the susceptibility of the West Coast community, avoiding the need for protection works, and avoiding the adverse effects of climate change through the location and protection of new development. This provision is supported. The support is acknowledged POLICY 1 Decision Requested: Support in part - Improved planning should include adopting an integrated catchment management planning framework looking at the issues in the catchment as a whole from the headwaters of the catchment to and including the coastal environment. The coastal environment is included as for example gravel extraction in the lower part of a river may exacerbate coastal erosion or could reduce flooding. Amend Policy 1 to read: Reduce the susceptibility of the West Coast community and environment to natural hazards by improving planning in particular by adopting an integrated catchment planning framework, responsibility and community awareness for the avoidance and mitigation of natural hazards. Summary of s Natural Hazards

13 Further submission (ELWEP) We submit in support of that part of the submission by DOC relating to natural hazards.the WDC has submitted on relevant part of this submission. in part As set out in the response to Decision Requested 11.21, this issue is addressed broadly under Policy 2. It is recommended (under Decision Requested 11.21) that additional text is added to the Explanation to the Policies to make this clear. Decision Requested: Submitter 21 FFNZ We propose that the avoidance and mitigation is substituted with the mitigation of natural hazards where practically and economically feasible following cost/benefit analysis, to take account of the Council s inability to absolutely avoid natural hazard events from occurring. That Council amends the wording of Policy 1 as follows (or similar): Reduce the susceptibility of the West Coast community and environment to natural hazards by improving planning, responsibility and community awareness for the avoidance and mitigation of natural hazards where practically and economically feasible following cost/benefit analysis. Reject See Decision Requested The Policy does not seek to absolutely avoid natural hazard events, nor would it be possible to do so. This is acknowledged in the wording of the Policy where it seeks to reduce the susceptibility rather than avoid absolutely. Decision Requested: Submitter 44 NZCC Support Policy 1. Nil Decision Requested: Submitter 61 TRUSTP Support 69 WESTP Summary of s Natural Hazards

14 Trustpower supports recognition of the West Coast as having a range of high risk environments that are susceptible to natural hazards, and that measures need to be taken to minimise the potential impacts of natural hazard events. Retain Policy 1. Further submission (WESTP) Grant relief sought. Is an appropriate resource management policy. Decision Requested: Submitter 68 WDC A review of the provisions of the RPS identifies strong policies relating to the need to increase community awareness, improving planning to reduce the susceptibility of the West Coast community. This provision is supported. The support is acknowledged POLICY 2 Decision Requested: Support - Consistent with RMA and implements NZCPS Retain Policy 2 as notified. Further submission (ELWEP) We submit in support of that part of the submission by DOC relating to natural hazards.the WDC has submitted on Summary of s Natural Hazards

15 relevant part of this submission. in part In response to Decisions Requested and 11.36, some minor amendments are recommended to Policy 2. Decision Requested: Submitter 21 FFNZ We consider the wording within Policy 2 is too onerous. There will be occasions in which new subdivision, use and development can be located and/or designed in harmony with appropriate hazard protection works. We seek amendment to the wording on that basis. That Council amend Policy 2 wording as follows (or similar): New subdivision, use and development should be located and designed so that the need for hazard protection works is avoided or minimised. Where it is considered necessary, further development in hazard-prone areas will may be restricted. in part Given the significant risk to life and property resulting from natural hazards, it is considered necessary to take a robust approach to the management of development in areas where natural hazards are present. However, it is accepted than in some circumstances, development may be necessary and/or possible within an area where natural hazards are present. For this reason, part of the submitter s recommended revision is accepted, which ensures that the intent of the Policy is preserved, whilst introducing additional flexibility to recognise these specific circumstances. This revision, which seeks to balance the need to reduce risk whilst enabling people to provide for their social and economic wellbeing, follows through from the Objective of the Chapter and will therefore ensure the Objective is achieved. The second part of the submitter s request is not considered necessary as it would add no further clarity to the Policy. Revised text: Policy 2 New subdivision, use and development should be located and designed so that the need for hazard protection works is avoided or minimised. Where necessary and practicable [DR 11.36], further development in hazard-prone areas will be restricted. Decision Requested: Submitter 32 KIWIR KiwiRail support that new subdivision, use and development should be located and designed to avoid hazard protection works, as proposed in Policy 2. Retain provision in part In response to Decisions Requested and 11.36, some minor amendments are recommended to Policy 2. Decision Requested: Submitter 44 NZCC Support Policy 2. Nil Summary of s Natural Hazards

16 in part In response to Decisions Requested and 11.36, some minor amendments are recommended to Policy 2. Decision Requested: Submitter 61 TRUSTP Support 60 TRANSP Trustpower supports recognition of the West Coast as having a range of high risk environments that are susceptible to natural hazards, and that measures need to be taken to minimise the potential impacts of natural hazard events. However, Trustpower considers that recognition should also be given to the inability of some types of facilities to be removed from hazard areas, such as the need for HEPS to be located near water resources. This issue is acknowledged to some extent within Policy 4, but it is considered necessary to amend Policy 2 (and the subsequent explanation) so as to avoid any internal inconsistency in this regard. Amend Policy 2: New subdivision, use and development should be located and designed so that the need for hazard protection works is avoided, where practicable. Where necessary, further development in hazard-prone areas will be restricted, unless regionally significant infrastructure demonstrates a locational/functional constraint. Further submission (TRANSP) In its submission Transpower supported policy 2 as the policy recognises the role and importance of some activities within the coastal environment. The amendments sought by Trustpower are supported as they explicitly recognise the locational and functional constraints that can be imposed on regionally significant infrastructure. Alternately, Transport would support the wording proposed in submission point in part In respect of the first amendment suggested by the submitter, it is considered that the point has been addressed in response to Decision Requested In respect of the submitter s second point, it is acknowledged, that in some instances development may be required in hazard-prone areas. A simplified change to the wording of Policy 2 is suggested in order to allow for this and a note is added to the Explanation to Policy 2 to make it clear how the Policy should be applied. Revised Text: Policy 2 New subdivision, use and development should be located and designed so that the need for hazard protection works is avoided or minimised. [DR 11.33] Where necessary and practicable, further development in hazard-prone areas will be restricted. Explanation to the Policies Policy 2 recognises that through appropriate planning, the need for protection works can be avoided by siting new subdivision, use and development away from existing or potential natural hazards. Research on natural hazards is ongoing. This information may indicate that in places where development has already occurred these areas may be susceptible to natural hazards. In such cases, further permanent development may need to be restricted to reduce additional risk to people or property. However, avoiding development in hazard prone areas may not be practicable in all instances, as some types of development are limited in where they can be located to function effectively. Decision Requested: Submitter 69 WESTP Support 60 TRANSP Support 61 TRUSTP Oppose in part. Whilst the general avoidance of natural hazards is a sound practice where possible there may be instances where for technical and operational reasons network utilities and regionally significant infrastructure are located in or adjacent to hazard prone areas, particularly given the dynamic nature and topography of the West Coast Summary of s Natural Hazards

17 Region and the servicing needs and requirements of communities throughout the region. It is accepted that sound risk management is required for utilities to ensure that the servicing of the community is maintained, particularly during hazard events. For example the location of extensive lines networks within the region will inevitably result in location of infrastructure in or adjacent to hazard prone areas, or the requirements of hydro-electricity generation activities will by their nature require location adjacent to potential hazards. Whilst avoidance can be provided for as far as possible through sound infrastructure planning and design Policy 2 does not currently identify that there may be instances where, for technical or operational reasons, network utilities and regionally significant infrastructure will be required to plan for risk and remedy or mitigate the effects of natural hazards. Amend Policy 2 to read: New subdivision, use and development should be located and designed so that the need for hazard protection is avoided Where necessary, further development in hazard prone areas will be restricted. In cases where network utilities and regionally significant infrastructure cannot avoid natural hazards for technical and operational reasons measures to remedy or mitigate the effects of natural hazards will be required to be provided for. Further submission (TRANSP) In its submission Transpower supported policy 2 as the policy recognises the role and importance of some activities within the coastal environment. The amendment is supported as it explicitly recognises the locational and functional constraints that can be imposed on regionally significant infrastructure in area of natural hazards. Alternately, Transpower would support the wording proposed in submission point Further submission (TRUSTP) Trustpower supports the amendments sought to recognise that the technical and operational constraints of regionally significant infrastructure are such that natural hazards may not be able to be avoided in all situations. in part The submitter s points have been addressed by changes recommended in response to Decision Requested and POLICY 3 Decision Requested: Submitter 14 CPHWC We support the policy to avoid and mitigate the adverse effects on the environment arising from climate change by providing for development and protection of the built environment. It is prudent to avoid development and use in high risk areas and to plan for provision of essential life-line utilities. Decision Requested: Support - Consistent with RMA. Summary of s Natural Hazards

18 Petain Policy 3 as notified. Further submission (ELWEP) We submit in support of that part of the submission by DOC relating to natural hazards. The WDC has submitted on relevant part of this submission. The support is acknowledged Decision Requested: Submitter 44 NZCC Support Policy 3. Nil Decision Requested: Submitter 61 TRUSTP Trustpower supports recognition of the West Coast as having a range of high risk environments that are susceptible to natural hazards, and that measures need to be taken to minimise the potential impacts of natural hazard events. Retain Policy 3. Decision Requested: Submitter 68 WDC A review of the provisions of the RPS identifies strong policies relating to avoiding the need for protection works, and avoiding the adverse effects of climate change through the location and protection of new development. This provision is supported. Summary of s Natural Hazards

19 The support is acknowledged POLICY 4 Decision Requested: Oppose 21 FFNZ Support in part - Consistent with RMA. The response to hazards needs to be in a whole of catchment including the associated coastal environment integrated planning approach. Response to individual requests for individual proposals to protect private property can have adverse effects on neighbouring properties. Retain Policy 4 as notified with the following inclusion: A new a) A whole of catchment including associated coastal environment integrated planning approach. The levels of risk and the likely increase in disaster or risk potential. Further submission (ELWEP) We submit in support of that part of the submission by DOC relating to natural hazards. The WDC has submitted on relevant part of this submission. Further submission (FFNZ) While FFNZ is supportive of integrated catchment management and whole of catchment approaches, we remain concerned that the amendment to this policy could have some unintended consequences by requiring quite extensive assessments for a discrete issue. Reject This point is considered sufficiently addressed by the existing wording of Policy 2. However, when assessing the effects of works designed to modify natural hazard processes, criterion a) of Policy 4 requires risk, and increased risk potential to be considered, and this could include risks associated with other hazards elsewhere that would be exacerbated by the works proposed. The submitter may also wish to refer to Decision Requested 11.4 which recommends additional wording be added to the Explanation to the Policies, to make clear how the Proposed RPS deals with hazards in the coastal environment. Summary of s Natural Hazards

20 Decision Requested: Submitter 32 KIWIR KiwiRail support that the Council s preference is for soft engineering rather than hard engineering structures to manage the risk from natural hazards. KiwiRail also support the policy recognition that sometimes hard engineering structures are required. This is particularly recognised through Policy 4(d) where the practicalities of alternatives or relocation are required to be considered. The rail network is not easily able to be relocated, however still passes through areas of the region that are susceptible to natural hazards. Council recognition of the constraints around the network at the time that consideration of the upgrade and maintenance of the asset occurs is therefore supported by KiwiRail. Retain provision Decision Requested: Submitter 44 NZCC Support Policy 4. Nil Decision Requested: Submitter 61 TRUSTP Support 69 WESTP Trustpower supports recognition of the West Coast as having a range of high risk environments that are susceptible to natural hazards, and that measures need to be taken to minimise the potential impacts of natural hazard events. Retain Policy 4. Further submission (WESTP) Grant relief sought. Is an appropriate resource management policy. EXPLANATION TO THE POLICIES Decision Requested: Summary of s Natural Hazards

21 Policy 1: Support in part - Improved planning should include adopting an integrated catchment management planning framework looking at the issues in the catchment as a whole from the headwaters of the catchment to and including the coastal environment. Amend the explanation to Policy 1 to read: Policy 1 seeks to increase awareness of hazard risks and the adoption of an integrated catchment management planning framework with appropriate building controls, including avoiding inappropriate development in hazard prone areas and in areas which will exacerbate natural hazards, to reduce the susceptibility of the West Coast community to the adverse effects of natural hazards. Further submission (ELWEP) We submit in support of that part of the submission by DOC relating to natural hazards. The WDC has submitted on relevant part of this submission. in part This point is addressed by the changes recommended in response to Decisions Requested 11.9 and which also apply to this submission point. Decision Requested: Policy 2: Support - Consistent with RMA and implements NZCPS Retain the explanation to Policy 2 as notified. Further submission (ELWEP) We submit in support of that part of the submission by DOC relating to natural hazards. The WDC has submitted on relevant part of this submission. Summary of s Natural Hazards

22 in part However, in response to Decisions Requested and additional text is proposed to be added to the Policy 2 Explanation. Decision Requested: Policy 3: Support - Consistent with RMA and implements NZCPS Retain the explanation to Policy 3 as notified. Further submission (ELWEP) We submit in support of that part of the submission by DOC relating to natural hazards. The WDC has submitted on relevant part of this submission. Decision Requested: Oppose 21 FFNZ Policy 4: Support in part - An Integrated catchment management plan will identify situations where modifying the environment to reduce susceptibility to natural hazards will produce benefits. Retain the Explanation to Policy 4 as notified with the following amendment: Policy 4 recognises that there will be an integrated catchment planning process will be used to manage the catchment including any affected part of the coastal environment as a whole. This process will result in the development of a plan and will identify situations where modifying the environment... Summary of s Natural Hazards

23 Further submission (ELWEP) We submit in support of that part of the submission by DOC relating to natural hazards. The WDC has submitted on relevant part of this submission. Further submission (FFNZ) While FFNZ is supportive of integrated catchment management and whole of catchment approaches, we remain concerned that the amendment to this policy could have some unintended consequences by requiring quite extensive assessments for a discrete issue. in part This point is addressed by the changes recommended in response to Decisions Requested 11.9 and which also apply to this submission point. Decision Requested: Submitter 61 TRUSTP Support 60 TRANSP Trustpower supports recognition of the West Coast as having a range of high risk environments that are susceptible to natural hazards, and that measures need to be taken to minimise the potential impacts of natural hazard events. However, Trustpower considers that recognition should also be given to the inability of some types of facilities to be removed from hazard areas, such as the need for HEPS to be located near water resources. This issue is acknowledged to some extent within Policy 4, but it is considered necessary to amend Policy 2 (and the subsequent explanation) so as to avoid any internal inconsistency in this regard. Amend the Explanation to the Policies: Policy 2 recognises that through appropriate planning, the need for protection works can be avoided by siting new subdivision, use and development away from existing or potential natural hazards. Research on natural hazards is ongoing. This information may indicate that in places where development has already occurred these areas may be susceptible to natural hazards. In such cases, further permanent development may need to be restricted to reduce additional risk to people or property. However, it is recognised that it may not be practicable to require all activities, such as regionally significant infrastructure, to locate away from hazard areas due to their locational/functional requirements. Further submission (TRANSP) In its submission Transpower supported policy 2 as the policy recognises the role and importance of some activities within the coastal environment. The amendments sought by Trustpower are supported as they explicitly recognise the locational and functional constraints that can be imposed on regionally significant infrastructure. Alternately, Transpower would support the wording proposed in submission point in part In response to another point made by the submitter, amendments are recommended under Decision Requested that address this submission point. Summary of s Natural Hazards

24 Decision Requested: Submitter 69 WESTP Support 60 TRANSP Oppose 61 TRUSTP Oppose in part. Having amended proposed Policy 2 it is important to amend the explanation to clarify the matter. Amend the 2nd paragraph to read: Policy 2 recognises that through appropriate planning, the need... to reduce risk to people and property. Whilst it is preferable to avoid natural hazards where possible it is accepted that there will be instances where network utilities and regionally significant infrastructure by their nature will be located in or adjacent to natural hazards. Given the importance of network utilities and regionally significant infrastructure to the wellbeing of the community it is important that risks are soundly assessed and appropriate measures to remedy or mitigate the effects of natural hazards are put in place to ensure the ongoing functioning of utilities to service, and for the benefit of, the community. Further submission (TRANSP) The insertion of additional wording within the explanation is supported as it recognises the sought policy changes to Policy 2. Alternately, Transpower would support the wording proposed in submission point Further submission (TRUSTP) Trustpower supports the amendments sought to recognise that the technical and operational constraints of regionally significant infrastructure are such that natural hazards may not be able to be avoided in all situations. in part In response to a point made by another submitter, amendments are recommended under Decision Requested that address this submission point. METHOD 1 Decision Requested: Submitter 14 CPHWC Although we support the method of increasing community awareness regarding natural hazard mitigation and preparation we remind Council that many people on the West Coast are economically unable to take more than a few basic steps to prepare for a large hazard event. This, along with the many visitors that will need to be catered for, will impact on the required level of Civil Defence Emergency planning and response. Noted The submitters point is acknowledged and understood. Increasing understanding and public awareness of natural hazards is not just about reducing the impact of natural hazards, it is also about understanding how to be ready, how to respond and how to recover from a natural hazard event (the four R s referred to in the explanation to Policy 1). Decision Requested: Summary of s Natural Hazards

25 Support as public awareness of hazards ensures community involvement when managing use and development that is affected by natural hazards. Retain Method 1 as notified. Further submission (ELWEP) We submit in support of that part of the submission by DOC relating to natural hazards. The WDC has submitted on relevant part of this submission. Decision Requested: Submitter 21 FFNZ That Council adopts proposed Method. Decision Requested: Submitter 28, 33 INTAF, KMCT The WCRC needs to be more pro-active on climate change, and actually acknowledge that it is with us now, as the extant RPS does. Amend Method 1: Increase understanding and public awareness of natural hazards, including the potential influence of climate change on natural hazard events. Reject As set out in the explanatory text relating to Policy 3, there remains uncertainty over the possibility, extent and timing of climate change effects. This Method, and the Chapter generally, do not seek to suggest that climate change does not exist, nor that it is not having any effects at present. Instead, the Method seeks to acknowledge that more will be known in future as new evidence becomes available. The Policy seeks to ensure that we are ready to respond to climate change in future as we become more aware of its effects. Summary of s Natural Hazards