9 April Tēnā koe

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1 Aoraki Environmental Consultancy Limited 9 April 2018 Tēnā koe Submission on the Timaru District Long Term Plan Please find attached a submission lodged by Aoraki Environmental Consultancy Limited to the Timaru Long Term Plan The contact for this submission is Alex Macdonald Alexmacdonald@aecltd.co.nz Phone: Physical Address Aoraki Environmental Consultancy Limited Level 1, 156 Stafford Street Timaru Postal Address: Aoraki Environmental Consultancy Limited P.O. Box 803 Timaru 7940 We wish to be heard at a hearing. Naku noa, Nā Alex Macdonald Environmental Planner

2 Introduction Vision 1. Ngāti Huirapa and their ancestors are mana whenua in the Timaru District and are represented by today Te Rūnanga o Arowhenua. 2. Te Rūnanga o Arowhenua is one of 18 papatipu rūnanga which together comprise the iwi authority of Te Rūnanga O Ngāi Tahu as set out in the Te Rūnanga o Ngāi Tahu Act The takwiā of Te Rūnanga o Arowhenua is described in the Te Rūnanga o Ngāi Tahu (Declaration of Membership) Order 2001 as centres on Arowhenua and extends from Rakaia to Waitaki, sharing interests with Ngāi Tūāhurirri ki Kaiapoi between Hakatere and Rakaia, and thence inland to Aoraki and the Main Divide. 4. As local authorities including Timaru District Council are Crown agencies, Te Rūnanga o Arowhenua considers its relationship with the Council should be one of partnership - reflecting at the District level the partnership between the Crown and Ngāi Tahu. 5. Aoraki Environmental Consultancy Ltd is an environmental company owned by Te Rūnanga o Arowhenua, which acts to support Te Rūnanga o Arowhenua in engagement with local government processes, and to support local authorities in discharging their statutory duties to Ngāi Tahu in the takiwā of Te Rūnanga o Arowhenua. 6. This submission recognizes that there are a number of projects of significance to mana whenua being consulted on in this Long Term Plan (LTP), including significant investment in infrastructure and community facilities, and the district plan review. As arguably one of the council s foundation documents, the LTP is an important vehicle for articulating the basis of the partnership between the Council and Te Rūnanga o Arowhenua and establishing the platform for ensuring that partnership is fostered in Council projects and processes. 7. We wish to be heard in support of our submission. 8. The LTP should recognize the significance of the Treaty relationship and the partnership that this represents. The philosophy of partnership should be embedded in all council policy, plans and projects and working with Te Rūnanga o Arowhenua or its mandated representative a core business function that is reflected throughout the Council s operations. 9. We ask that the Council s LTP include a section that acknowledges mana whenua of the Timaru District; the Council s statutory duties to Ngāi Tahu as mana whenua and the Crown s Treaty Partner; and the vision and strategy for how those duties can be discharged in a spirit of partnership across the Council s governance, regulatory and asset management functions and operations. We look forward to working with Council to finalize this part of the plan during the remainder of the LTP process. 10. We acknowledge that building a successful and enduring partnership between mana whenua and Timaru District Council will require proactive, on-going effort on the part of both the council and Te Rūnanga o Arowhenua or its mandated representatives. Consequently, we would expect to work with council staff early and often, and for this work to be an expected part of council processes. 11. The extent and nature of rūnanga engagement in any project or process may well vary depending on the nature of the project and the priorities of and resources available to Te Rūnanga o Arowhenua. However the foundation of partnership - which manifests itself in a commitment to early engagement with and providing meaningful opportunity for Te Rūnanga o Arowhenua to participate in the planning and decision-making on core council policy, projects, plans and processes, should be incorporated into the strategic objectives of the Submission on Timaru District Long Term Plan 9 April

3 Big issues council. We suggest the timeframes and resources needed to facilitate Te Rūnanga o Arowhenua engagement as a partner should be built into project planning for all Council s major projects. 12. Council has identified several big issues for this Long Term Plan. Issue 1: Water Supply 13. We support the LTP identifying the future supply of water for Timaru as a major issue, and we support the introduction of water metering to help people become more conscious of water consumption, whether or not a charging regime ensues. 14. We are concerned at the identification of options for water supply relying on the ability to take more water from the Pareora or Opihi rivers or hydraulically connected groundwater. While community drinking water supplies are given first order priority status in the Canterbury Water Management Strategy (CWMS) there are other activities which have equal status including the health of aquatic ecosystems and customary uses. Section 14(3)(b) of the RMA gives the right of an individual to take drinking and stockwater, but that is a right to an individual and has the caveat that the take does not have any adverse effects on the environment. 15. Taking more water from rivers that are fully allocated or already suffering from low flow issues in summers with low rainfall and little recharge, does not build a resilient drinking water sources for the District in anticipation of predicted effects of climate change. 16. The cost benefit analysis of the options at least in the public consultation document, does not include an analysis of effects of taking more water on the environment or on other users of the Pareora and Opihi River resources, including in stream uses and other abstractors. There is no commentary about potential legal, or planning issues associated with some of the options rather the discussion document reads as though all of these options are potentially available and the issue is the cost of the infrastructure to access and use them. 17. We also think it is important to clarify the language around water charges. The Council cannot charge people for water per se rather it can charge for the costs of providing, maintaining and upgrading infrastructure to take, convey and treat water under the Local Government Act Some councils calculate those charges based on the volume of water people use. It is important that people understand what they are and are not charged for when it comes to water and ongoing discussion over rights and ownership. Issues 2 and 3: Upgrade of the theatre and heritage facilities. 18. We do not have a position on the upgrades of these facilities, but the issue provides an opportunity to illustrate the point about heritage and partnership with Te Rūnanga o Arowhenua. We suggest a broader issue is how the cultural heritage of Timaru District is recognised and incorporated into the Council management of community assets, infrastructure and spaces and that includes the culture and heritage of those who occupied these lands pre-european settlement. Strategies can include commitments that if council proceeds with a new community facility or any upgrade project, it recognizes the role of mana whenua in the history of the District and considers where and how this can be incorporated into the project. 19. We also encourage the council to acknowledge and support Tuhituhi neherā (Maori rock art sites) in the District. Various sites are highly protected heritage sites and significant part of the heritage of South Canterbury. These sites require ongoing, proactive work, across multiple agencies to ensure their protection for future generations, and we encourage the Submission on Timaru District Long Term Plan 9 April

4 council to continue to work with, and support, The Ngai Tahu Maori Rock Art Trust and Te Ana Maori Rock Art Centre given their mission to preserve this collection. Issue 4: Stormwater 20. Stormwater is a major issue of concern to Te Rūnanga o Arowhenua, and we have invested significant time and effort into working collaboratively with the council (and other agencies such as Environment Canterbury) to reach an acceptable outcome. This includes participating in zone committees and the Waitarako working group. 21. We are concerned that the options presented here will constrain or undermine the effort put into these collaborative processes, by limiting the funding Timaru District has available to achieve community agreed water quality outcomes. 22. We are also concerned that the cost benefit analysis of the options presented is quite narrow. It does not include potential costs to the environment and other uses and values of the District s waterways and coast of delaying stormwater management upgrades in options 2 and 3; nor the increased costs of the upgrades that will occur over time as construction prices and land values increase. 23. The LTP acknowledges that options 2 and 3 will put the Council out of step with central and regional government requirements. We believe this statement is a little light - our understanding is that options 2 and 3 fail to meet current regulatory requirements in the national and regional planning framework, and to that end are not options unless those frameworks change. Changing those planning frameworks is not something TDC can ensure. 24. Therefore we request that Council allocate sufficient funding to the work to be undertaken quickly and in a timeframe that is compliant with the current regulatory regime. This allows the timeframe for improvements to be set through the planning and consent processes with all the available information. It also allows council to avoid the risk of allocating insufficient resources, given the uncertain nature of these processes. Council Activities. 25. This section makes additional comments on some council activities, within the spirit of the vision described above. Democracy 26. The democracy section states that council will maintain relationships with district iwi. We do not agree maintain relationships with the District iwi is the best way to describe the partnership that Te Rūnanga o Arowhenua seeks with the Council as the Crown s agent in Timaru. There is only one iwi authority over most of the South Island and only two papatipu rūnanga who represent those who hold mana whenua over the Timaru District. In these circumstances generic terms like iwi are not needed but rather the relationship should be personalized in the way set out in the Introduction section of this submission. 27. We also request that the recognition of a partnership as described in the Vision Section of this submission is included as a strategic objective in the LTP and that this is implemented through a strategy that includes a commitment to strengthen the relationship across the broad ambit of council functions and processes, recognizing that the relationship can always be improved. District Planning and Environmental Services 28. The District Plan review is already underway and is a significant project, with expenditure over the next three years totaling approximately $3.27 million. This process and the associated expenditure as a necessary requirement of the council s functions under the Resource Management Act 1991 (RMA), and engagement with Te Rūnanga o Arowhenua is Submission on Timaru District Long Term Plan 9 April

5 necessary for the council to discharge its duties relating to the district plan review under the RMA, as well as its more generic duties in relation to Māori involvement in decision-making under the Local Government Act We request that continued efforts are undertaken by the council to support Te Rūnanga o Arowhenua s participation in this process as the representative of those holding mana whenua in the District and support that participation with a level of resourcing commensurate with the relatively tight timeframe and significant amount of work to be completed over the next three years. 29. We support the inclusion of a commitment to monitor land use consents, as monitoring supports the investment of time into the district plan process; and a commitment to monitor the state of the environment generally, (particularly in relation to biodiversity). Three waters 30. Key issues relating to three waters have already been identified above. Additionally, we request that council recognize that their assumption of greater responsibility in stormwater will likely require council to make a proactive commitment to monitoring sources of stormwater, either through existing mechanisms, or through dedicated funding, otherwise council will struggle to control inputs into the stormwater system (and therefore not meet output requirements). 31. Finally, we seek that the level of service relating to council compliance with its consents include a commitment to 100% compliance. We support the Council as an environmental regulator itself, in leading by example in relation to consent compliance. Submission on Timaru District Long Term Plan 9 April