TE ANAU MANAPOURI WASTEWATER TREATMENT AREA.

Notice of Requirement for Designation. Section 168A of the Resource Management Act 1991

Site: 1701 Manapouri Te Anau Highway, Lot 2 DP 410687

Referring to application. 3 The site to which the Requirement Applies. Error: first paragraph first sentence, please clarify. 'for the discharge of treated wastewater from to land.'

Appropriate 150m buffers are to be provided for the existing homestead, located at 1725 Te Anau Manapouri Highway, and also the Te Anau Airport Manapouri.

There is no information on what the Council considers is an appropriate buffer, other than the distance from the homestead and airport facility. Does it include extensive planting of native vegetation?

4.1 Section 168A: Notice of Requirement of Territorial Authority Quote: 'The site was chosen for its flat topography, soil type and reasonable separation from residential activity.'

Questions arising from this statement: topography and soil type 1. have detailed studies been carried out proving exact flow charts in respect to: underlying soil and geology, and all land use activities upstream? 2. have possible nutrient concentrations been assessed in areas including the Kepler , Home Creek, and surrounding farmland? 3. is the soil structure suitable for nutrient stripping? If so, to what extent? 4. has there been any studies undertaken to help understand the processes that will possibly cause nutrient enrichment and algal problems in the surrounding catchment areas? 5. if spray irrigation proves to be too intense for the area, what procedures will the Council have in place to ensure flooding does not occur? 6. has the Council taken into account the number of existing residents living downstream from the proposed irrigation site that rely on Home Creek for their water supply? 7. bacterial levels in waterways are often highest after rainfall, a common source of bacteria is human wastewater discharge. We live in a high rain fall area, therefore this is a major concern.

Concern re statement 'reasonable separation from residential activity.' 1. The word reasonable does not give any assurance that the proposed 150m buffer is sufficient.

4.2 RMA Sections 5 – 8: Purposes and Principles

7.62 Permit to discharge contaminants The RMA definition of “waste” focuses on the change, or likely change to “physical, chemical or biological condition of water” and is therefore enough to encompass substances which might have only a minor impact on water quality. The Kepler Mire is the largest complex in NZ. It is internationally biologically significant because it is has the most extensive pool system of the string forms found in NZ.

We are not satisfied that this application addresses the environmental impact the spray irrigation will have on the Mire and surrounding waterways. S 107 (1) (c)-(g) of the RMA prohibits the granting of a discharge permit which is likely to give rise to any of the following effects in the receiving waters (c ) The production of any conspicuous oil or grease films, scums or foams... (d) Any conspicuous change in the colour or visual clarity; (e) Any emission of objectionable odour; (g) Any significant adverse effects on aquatic life.

4.3 Regional Policy Statements for Southland. If the water in Home Creek or Lake Manapouri is degraded we question the use of the words, “consistent with the rural provisions for social and cultural wellbeing.”

4.4 The Operative Southland District Plan Statement: “It will also be consistent with the public utility provisions as it will provide for the efficient operation and maintenance of a public work whilst avoiding, remedying or mitigating adverse effects on the environment.”

Clarification of 4.4 is covered under: 5 Assessment of Environmental Effects 5.1 Effects on Socio-Economic and Cultural Wellbeing We have covered our concerns under 4.1 and 4.2

5.2 Effects on Landscapes and Visual Amenity Only visual effects have been referred to. We agree that the site does not hold any significant landscape values, but effects on the Kepler Mire should be addressed.

5.4 Effects on Ecosystems The Kepler Mire is within the vicinity of proposed site.

5.6 Effects of Discharged We have covered our concerns under 4.1 and 4.2

Please clarify the statement: “The intention of this is to avoid the risk of reverse sensitivity effects and 'protect' the operation of the site.

5.7 Effects of natural hazards and hazardous Substances What chemicals may be used or stored on the site?

5.8 Summary of Effects It is the Council's responsibility to predict the environmental effects of their proposed scheme before it goes ahead. Approaching this proposal with vague and open ended statements does not give residents the confidence that all issues, outcomes, and other options have been fully explored.

Conclusion:

We are not convinced that this proposal is the best option for the disposal of wastewater for the Manapouri Te Anau district. The Notice of Requirement does not provide sufficient information on any aspects of the scheme. We do not know the size and number of the irrigators, how many pumps are required and will any noise be associated with them? Are there any back up plans if the site becomes saturated, if so they are not mentioned. What, if any, other options have been discussed or looked into? We request that these questions, together with other questions raised throughout this submission be replied to.

We are assuming that all matters not covered in this NOR will be fully covered when other relevant resource consents are applied for.

RUTH DALLEY and LANCE SHAW

P.O. Box 40 Manapouri 9643 [email protected]