IN THE MATTER of the Resource Management Act 1991

AND

IN THE MATTER OF application for discharge of Wastewater to land

BY Council

Applicant

STATEMENT OF EVIDENCE OF BOYDEN EVANS ON BEHALF OF THE APPLICANT - LANDSCAPE

INTRODUCTION

1. My name is Boyden Henry Evans.

2. I am a NZILA Registered Landscape Architect and a Partner at Boffa Miskell Limited (“Boffa Miskell”), a -owned environmental planning and design consultancy.

3. My evidence addresses matters affecting landscape and visual amenity and on the natural character of the Waiwiri Stream. It is given in relation to the application for resource consents lodged by Horowhenua District Council ("HDC") for discharges of treated wastewater from the Levin Wastewater Treatment Plant ("LWWTP") to the Levin Wastewater Land Discharge (LWWLD) site known as “The Pot”. The proposal for which these consent applications are sought is referred to as 'the Project'.

EXECUTIVE SUMMARY

4. Effects of the proposal to discharge treated wastewater to The Pot as part of HDC's consent application ("the proposal") on landscape, visual amenity and natural character were not included as part of the range of matters that were originally assessed and lodged as part of the application. However, they were matters identified by Mr Hywel Edwards in the planning assessment that needed to be considered given provisions in the Horizons One Plan and that the Waiwiri Stream that adjoins The Pot is an ONF in the Horowhenua District Plan. In addition, the site lies adjacent to, but not within, Coastal ONFL (Horowhenua District Plan). The Coastal ONFL overlay includes the Hokio Beach Dune Fields ONFL as identified in the Horizons One Plan, which is described in Schedule G but is not spatially defined.

5. Having undertaken a review for HDC in 2011 of the technical report that identified potential outstanding natural features and landscapes (ONFLs), and subsequently a coastal natural character assessment in relation to New Zealand Coastal Policy Statement 2010 (NZCPS) for HDC, I am familiar with the area and the background to the inclusion of the various overlays and provisions in the District Plan and the Horizons One Plan.

6. Natural character provisions are addressed in the One Plan through Objective 6-2 and Policy 6-8. I have reviewed the technical assessment reports completed by others where they relate to landscape, visual amenity and natural character aspects and I have drawn on their findings and conclusions in preparing my evidence. I completed a site visit to The Pot and surrounding environs in July this year accompanied by a colleague and by Ms Sian Cass from Lowe Environmental Impact who is very familiar with The Pot site and the resource consent application.

7. The irrigation of wastewater from The Pot over the surrounding land has been occurring for around 27 years. The identification of outstanding natural features and landscapes and areas and an assessment of the natural character of the coastal environment in terms of the requirements of the NZCPS 2010 (described above) occurred relatively recently. At the time when the ONFL and coastal natural character were determined the irrigation of wastewater from The Pot was already being carried out. It formed part of the baseline assessment of natural character values of the Waiwiri Stream.

Page 2 8. My understanding from the assessments carried out by the specialists involved in the resource consent application is that the scale of change, in terms of the irrigation concept for the future discharge, is similar to the current activity in that it is by irrigation to land which passes through the soil and groundwater, ultimately reaching surface water. The Waiwiri Stream provides an important connection between Lake Papaitonga, and the coast. Both the Waiwiri Stream and lake Papaitonga are recognised as ONFLs in the Horowhenua District Plan. The Waiwiri Stream ONFL extends to 20m from each bank. Both the lake and stream have very high natural science, sensory and shared and recognised values, which warrant its status as an ONFL.

9. The Pot lies within the Coastal Environment landscape domain but not within the Coastal ONFL, the boundary of which is further west towards the coast. In the Horizons One Plan. The Pot lies adjacent to (but not within) the Hokio Beach Dune Fields ONFL. Based on the evidence of Dr Ausseil, Mr Douglass and Dr De Luca, and the limited change to the existing practices at The Pot, which were present when the coastal landscape assessments identifying the ONFLs occurred, I consider that the effects of the proposed activities on the outstanding landscapes, and coastal landscapes, is or low. Earthworks proposed are similar to what is currently operating at The Pot and will not have little if any effect on the Waiwiri Stream and its status as ONFL (which was identified with the operation of The Pot occurring).

10. In terms of natural character effects, the changes from the current discharge to the proposed future discharge from The Pot is assessed by Dr Ausseil in relation to the Waiwiri Stream to be similar to the existing discharges (with a reduction in nitrogen from The Pot proposed in the consent conditions). Dr Ausseil's opinion is that the proposal will not have more than minor adverse effects on water quality in the Waiwiri Stream. He also states that the current monitoring, which has limitations, shows no evidence of adverse effects from The Pot site on aquatic life or life-supporting capacity values of the Waiwiri Stream. In my opinion the proposal will not adversely affect the natural character of the Waiwiri Stream and, with the proposed 20m wide riparian planting, may over the long-term improve it (noting the lower reaches are presently mechanically harvested for weed control by Horizons).

QUALIFICATIONS AND EXPERIENCE

11. I have a Bachelor of Science in botany and pedology from Victoria University of and a post graduate Diploma in Landscape Architecture from Lincoln University. I am a Fellow of the New Zealand Landscape Architects (NZILA).

12. I have been a landscape consultant with Boffa Miskell since 1986 and have worked on a range of projects for corporate and private clients and for territorial authorities and government agencies in various parts of New Zealand. This work includes district and regional landscape assessments and resource studies, landscape and visual effects assessments, including preparation of visual simulations, for many types of development projects. These include infrastructure projects, such as quarries, new highways, wind farms, transmission lines, and rural lifestyle and residential subdivisions. I have also been involved in many site rehabilitation and revegetation projects and have prepared master plans and management plans for reserves and other areas.

13. I am familiar with the landscape of the area surrounding the site as I was part of the Boffa Miskell team engaged in 2011 by HDC to undertake a landscape evaluation of the eight ONLs and ONFs

Page 3 proposed in Plan Change 22 (PC22). The assessment was completed by another consultant but Boffa Miskell was commissioned by HDC to review and advise on the recommendations. Our findings and recommendations were produced in a report, Outstanding Natural Landscapes and Features Review in August 2011.

14. I was also part of the team of landscape architects and ecologists that carried out a natural character assessment of the coastal environment in response to the requirements of the NZCPS 2010. This assessment involved defining the inland extent of the coastal environment, subdivision of the coastal environment into sectors and assessing the level of natural character for each sector. Our findings were produced in Natural Character Assessment of the Horowhenua Coastal Environment in September 2012.

15. I was also involved in a study of the Horowhenua dune fields, the findings of which were produced in, Horowhenua dune fields geomorphological assessment: framework for the geomorphological classification of the portion of the West Wellington dune field within Horowhenua District, prepared by Dr Mike Sheppard and Boffa Miskell in June 2016.

16. In 2018-19 I was part of the NZTA Te Ahu a Turanga: Manawatu Tararua Highway team working on the designation for this project. This involved addressing natural character matters in relation to Objective 6(2) and Policy 6(8) in the Horizons One Plan.

CODE OF CONDUCT

17. I confirm that I have read the ‘Code of Conduct' for expert witnesses contained in the Environment Court Practice Note 2014. My evidence has been prepared in compliance with that Code. In particular, unless I state otherwise, this evidence is within my sphere of expertise and I have not omitted to consider material facts known to me that might alter or detract from the opinions I express.

SCOPE OF EVIDENCE

18. My evidence will:

(a) Outline the existing landscape features and natural character values of The Pot;

(b) Describe my assessment of potential effects on the natural character values of the Waiwiri Stream and the reasoning for these;

(c) Address any submissions on landscape/natural character matters;

(d) Proposed conditions of consent; and

(e) Conclusions.

BACKGROUND IN ROLE AND IN APPLICATION/PROJECT

19. I have not been involved in the preparation of any assessments or reports as part of the resource consent application. Following the lodgement of the application and as a result of matters raised by some submitters, I was asked to address landscape, visual amenity and natural character

Page 4 aspects given that treated wastewater is discharged to land at The Pot which neighbours the Waiwiri Stream catchment. The Waiwiri Stream is identified as an Outstanding Natural Feature (ONFL) in the Horowhenua District Plan.

SUMMARY OF ACTIVITY

20. HDC is proposing modifications to the discharge of treated wastewater from the LWWTP. The current discharge area is at the western end of Hokio Sand Road and known as ‘The Pot.’ Wastewater transferred from LWWTP to The Pot is held in an infiltration pond prior to discharge via irrigation to an area, which until recently, was covered in pine trees and grass. The pine trees were harvested during 2018 and The Pot is currently being replanted with pine trees and native vegetation.

21. The resource consent application lodged with Horizons seeks consent to discharge (inclusive of different discharge rates and irrigation area) treated municipal wastewater to land at The Pot.

22. At a national level, Policy 23 of the NZCPS directs such discharges under the RMA decision making framework. This policy states that in managing discharge of human sewage, to not allow direct discharge without treatment, or the discharge of treated human sewage to water in the coastal environment unless there has been and adequate consideration of alternatives and is informed by an understanding of tangata whenua values. As explained in the evidence of Mr Douglass, the treated wastewater in the groundwater has yet to reach the coast and may take another 15 years to do so. Therefore, the passage through groundwater to the coast is very slow (some 45 odd years) and the dilution is significant. The evidence of Dr De Luca is that the activities at the Pot site are not having, and are unlikely to have in the future, any measurable effect on estuarine or open coastal marine ecological values.

23. While the discharge will only occur to land at The Pot site (designated in the District Plan for such purposes), Most of the wastewater that passes through the soil and enters groundwater will, over time, reach the Waiwiri Stream. Waiwiri Stream is not identified in the Horizons One Plan (the plan under which resource is sought) as an ONFL, however it is identified in the District Plan as an ONFL. The Waiwiri Stream connects Lake Papaitonga, which is also an ONFL in the District Plan, to the coast. This landscape and feature classification require, within the coastal environment, the need to protect outstanding natural character and outstanding natural features and landscapes of the Waiwiri stream from inappropriate use and development by ‘avoiding’ adverse effects (Policies 13 and 15 of the NZCPS). In other areas of the coastal environment natural character and natural features and landscapes is protected from inappropriate use and development by requiring significant adverse effects to be avoided. I understand that while avoid means "do not allow" the Supreme Court has said that activities with minor, or transitory, adverse effects may not need to be avoided.

THE SITE AND EXISTING ENVIRONMENT

24. The Pot is located within the Foxton Ecological District, a narrow coastal strip which runs from the Tangahoe River near Hawera, widening in the Foxton area and narrowing again to end at Paekākāriki in the south. The area is characterised by coastal dunes that have been formed by sand movement, many areas of which have been affected by human activities and settlement. The

Page 5 district now contains mostly farmland, exotic pine plantations and urban settlements. Natural areas with low levels of human modification identified as ONFLs in the area include dune lakes such as Lake Papaitonga and Lake Horowhenua. At a regional level, in the Horizons One Plan, The Pot lies adjacent to (but not within) the Hokio Beach Dune Fields ONFL.

25. At a district level, The Pot lies within the Rural Zone of the Horowhenua District Plan, which is subject to a number of map overlays, including those that identify Landscape Domains and ONFLs. In the situation where there are overlapping overlays, the most onerous provisions would be applied. The Pot lies within the Coastal Environment Domain. The Waiwiri Stream runs along the southern boundary of The Pot and the area of the stream and 20m from each bank are, together with Lake Papaitonga, classified as an ONFL in the District Plan, see Figure 1, HDC Overlays.

26. Key features of the Coastal Environment Domain are outlined in the Landscape Assessment of the Rural Environment of the Horowhenua District (October 2008), are contained in Appendix 1 of the District Plan which are set out below for ease of reference:

Landform

The dune systems result in a dynamic landscape, with the strong prevailing winds contributing to the constant movement of sand in the dunes near the coastal edge.

Inter-dunal hollows provide dune lakes and swamps where the water table is elevated; and the area also includes the estuaries for the District’s lakes.

Landcover

Apart from exotic forestry, land cover is restricted to sand dune species and exotic pastoral grasses. In the estuarine areas particularly, there are significant areas of indigenous vegetation which support a wide range of indigenous fauna. Similarly, the remnant wetland and kanuka/manuka forest also provide important habitats.

Landuse

Landuse in this area is restricted to exotic plantation forestry and some pastoral farming. There is increasing residential development in the coastal settlement areas…

Sensitivity

The uniqueness and dynamism of the coast and its processes result in a high level of sensitivity to modification.

27. Key features of the Coastal Lakes Domain are described as:

Landform

Most of this domain consist of parabolic dune field topography, which extends in a latitudinal fashion over 10km inland. It tends to be of the younger dune building phase, which results in the dune fields extending less of a distance inland, but the topography is no less distinctive than that found in the Foxton Dunefields Domain.

The natural hydrology within this domain is complex and dynamic, although extensive modification has occurred through the creation of deep channelled drains. Meandering streams and contiguous wetlands maintain their natural patterning under the grid-like drain system. Despite the drainage systems, the elevated water table allows the remaining wetland areas to function naturally and provide habitats for a range of indigenous flora and fauna.

There are a number of freshwater dune lakes in this domain, two of which - Waipunahau (Lake Horowhenua) and Waiwiri (Lake Papaitonga) - are significant natural features which have high historical and cultural values…

Page 6 Landcover

Much of the dunefield near the coast has been planted for extensive commercial forestry production. A mix of scattered small-scale forests occur on the residual dunes while pastoral activities are undertaken on the low and inter-dunal areas.

The Lake Papaitonga scenic reserve is a significant habitat for indigenous flora and fauna. The remnant bush areas scattered throughout the area and the functioning wetland swamps also provide habitat for indigenous fauna.

Landuse

The domain includes extensive areas of pastoral grazing which tends to occur mainly on the inter-dunal flats. The dunes themselves are generally utilised for exotic forestry and for the location of dwellings associated with farming activities…

Sensitivity

The dune system in this domain, including the lakes, presents high value in landscape terms and therefore requires consideration as to the effects of development and changes to the landform.

28. The Outstanding Natural Landscapes and Features Review (“the Review”) prepared by Boffa Miskell for HDC in 2011 provides an evaluation of the landscape attributes which give Lake Papaitonga and the Waiwiri Stream its Outstanding status in the District Plan. The proposed Plan Change 22 which sought the creation of ONFLs initially only identified the area of Lake Papaitonga as an ONFL, but the subsequent review revised the boundary to include the Waiwiri Stream and the area 20m from its banks. The Review describes the lake and stream as follows:

Lake Papaitonga (61.8 ha), also known as Waiwiri, is a dune lake surrounded by indigenous forest, which together makes up the 122ha Papaitonga Scenic Reserve administered by the Department of Conservation. The Lake contains two islands, Motukiwi and Motungarara; these were previously named Papaitonga and Papawhaerangi. Motungarara is an artificial island created by Muaupoko in 1820.

The Waiwiri Stream is the outlet to the lake and crosses the 4.8 km of sand plains and farmland to the coast. Lake Papaitonga and Waiwiri Stream are highly interdependent in terms of their hydrological balance and ecological health. For , the lake and stream are inextricably linked as components of one system, connecting the lake and sea, and providing for the seasonal migration of fish. Consequently, both landscape features are considered to form a single ONFL.

29. Collectively, the review considers that the lake and stream have very high natural science, sensory and shared and recognised values which warrant its status as an ONFL.

30. In the Horizons One Plan, the site lies adjacent to (but not within) the Hokio Beach Dune Fields ONFL. ‘Values’ of this area are listed in the One Plan – item n) under Schedule G. The values for the area are fairly broad, and are defined as:

(a) Visual and scenic characteristics, particularly its special coastal landscape features;

(b) Coastal geological processes;

(c) Ecological value, particularly the , Whangaehu, Turakina, Rangitikei, Akitio, Ohau, Waikawa and Manawatu River estuaries as habitats for indigenous fauna;

(d) Recreational value;

Page 7 (e) Significance to tangata whenua;

(f) Scientific and educational values; and

(g) Historic heritage, in particular historical importance, archaeological sites and high potential for archaeological site discovery.

31. Within the One Plan, the areas of Schedule G are not mapped. The area of the Hokio Beach Dunes is included in the One Plan Review and comprises an area of dunes around 250m (but in some areas up to 1km) inland from the coast, covering the area which lies between the western boundary of The Pot and the Coast.

32. The One Plan defines Coastal Foredune as being “the strip of land between the Coastal Marine Area and a line roughly parallel with the beach, extending 200m inland of the first line of vegetation.” The Coastal ONFL defined by the One Plan Review includes coastal areas and features listed in Schedule G of the One Plan, being part of n) Coastline of the Region; namely Foxtangi Dunes, Hokio Beach South Dune Fields, and for their ecological values; the Ohau and Waikawa River estuaries.

33. The One Plan Review describes the area as:

The Horowhenua coast is a relatively short (35km) stretch of a much more extensive sand dune system extending from Paekakariki in the south to Whanganui in the north (130 km). The sand dune country with associated inter-dunal lakes and wetlands, lagoons and estuaries, is the most extensive dune system in New Zealand.2 However, much of the inland area of this dune system has been modified through farming, forestry, earthworks and settlement. The dominating influence of the coastal environment is the predominant west-north-westerly winds, which have a major influence on the physical shape of the dune landscape, and local climate.

34. Land to the west of The Pot is typical of this character, being dune fields overlaid with pasture and pine shelterbelts.

35. The Landscape Values of the Coastal ONFL, which includes the area of the Hokio Beach South Dune Field as defined by the One Plan, are defined by the One Plan Review as:

(a) Open, continuous and expansive landscape relatively free of visible structures;

(b) Plantation forests and residential settlements detract from natural values;

(c) Remnant dune areas of once extensive dune system;

(d) Intact dunefields and river estuaries have a high proportion of indigenous vegetation and habitats;

(e) Wild and natural coastal values valued by the community;

(f) Coastal processes evident and still occurring;

(g) Highly significant cultural and spiritual landscape for tangata whenua; and

(h) Historic values associated with coast providing an early transport corridor.

Page 8 36. The Waiwiri Stream flows from the shallow dune lake of Lake Papaitonga to the coast, a distance of around 4.8km. Wetland and coastal forest surround the lake and includes kahikatea/pukatea, tawa and pukatea-tawa-swamp maire. The stream exits the lake to the southwest, where it flows through duneland which has been heavily modified by agricultural activities. There is little indigenous vegetation cover in the upper reaches of the stream. There are patches of flax, cabbage tree and other native planting to the south-east of The Pot, though grazing stock gaining access to these areas is an issue. To the west of The Pot, the length of the stream to the coastline is also characterised by pasture covered duneland and in places by small areas of native vegetation. As mentioned in the evidence of Dr Ausseil, Horizons undertakes instream mechanical harvesting of pest macrophytes in the lower reaches of the stream. The Boffa Miskell Assessment of Marine Ecological Values1 identifies that the marine environment the stream flows to is a moderate-high energy exposed beach. This is addressed in the evidence of Dr De Luca.

37. Land within The Pot itself is predominately covered by recently felled pine forest, an area of kanuka forest along the northern shore of the open lake which forms The Pot infiltration pond (The Pot pond). The Pot pond is approximately 7 ha in area and has a storage capacity of 425,000 m3. The pond level varies by up to 1.4 m. The Pot pond was originally designed as an infiltration basin, so is not lined. There is a smaller pond to the north-east of this large pond which is enclosed by mixed vegetation, including areas of willow and poplar. The central part of The Pot site includes an area of sedgeland, and several smaller scattered areas of raupo and wetland. Along the southern boundary of the site within the Waiwiri Stream are groups of cabbage trees and areas of flax. Most of the stream is open, with little tree cover, and in places suffers from intrusion of stock from adjoining areas. The area of kanuka forest and carex sedge wetland in the north-west of the site are both recognised as regionally threatened habitats in the Horizons One Plan (these areas are discussed in more detail in the evidence of Dr Keesing).

38. The area of felled pine forest has had some replanting with native species including hebe, manuka, kanuka, ngaio, and coprosma species, however there is extensive coverage of inkweed and nightshade throughout the site, which has thrived following the exposure of open ground created by the pine removal and the treated wastewater irrigation of the area.

39. The Pot is typical of the characteristics of the Coastal Environment Domain categorisation in the District Plan in which it is situated. The Coastal Environment Domain covers 9,381 ha. and the District Plan notes in relation to the Coastal Environment Domain, “The uniqueness and dynamism of the coast and its processes result in a high level of sensitivity to modification.”

THE PROPOSAL AND EFFECTS ON NATURAL CHARACTER VALUES

40. Natural character is about condition. It is a term used to describe the naturalness (i.e. lack of modification) of coastal, river/stream and wetland environments and their margins. A lack of, or lower level of, modification would equate to a higher level of natural character.

41. The preservation of the natural character of the coastal environment, wetlands, rivers lakes and their margins is a matter of national importance. The approach of the Horizons One Plan is to maintain the current degree of natural character of the coastal environment, wetlands, rivers, lakes

1 Levin Wastewater: Assessment of Effects on Marine Ecological Values, prepared for Horowhenua District Council, 12 July 2019, Boffa Miskell Limited.

Page 9 and their margins and to restore and rehabilitate natural character where appropriate. Assessment of natural character involves inputs from several disciplines – freshwater and terrestrial ecologists, water quality specialists, geomorphologists and landscape architects.

42. In assessing the effects of the proposed continuation of discharge of wastewater on the natural character values of the Waiwiri Stream and the Hokio Beach Dune Fields, the following points need to be considered:

(i) The existing baseline of natural character values of the stream and dune fields;

(ii) The scale of change from the continued discharge of wastewater onto the adjacent land to the natural character values of the Waiwiri Stream and dune fields; and

(iii) The degree and nature of any potential effect from the continued discharge.

43. The Review found that the existing landscape values of Lake Papaitonga and the Waiwiri Stream which contribute to its very high natural science, sensory and shared and recognised values are:

(a) Regionally rare remnant of interdunal lake, wetlands, stream and coastal forest.

(b) Good biodiversity and rare intact sequences of lake/wetland/forest ecosystems.

(c) The lake, its surrounds, and Waiwiri Stream are highly valued as an ancestral landscape by tangata whenua.

(d) Several well-known and documented stories relating to Maori and European history in the vicinity of the lake.

44. As outlined in Section 5 of the Review, the landscape factors considered in the evaluation of natural character are consistent with the One Plan’s requirements for evaluating ONFLs, (Policy 7- 7A: Assessing outstanding natural features and landscapes, including Table 7.22 Natural Features and Landscape Assessment Factors), as well as with Policy 15(c) of the NZCPS. The One Plan also provides policies in relation to regionally outstanding natural features and landscapes, including identifying and managing natural character.

45. The Review assessed these values in 2011. At this time, the irrigation of wastewater from The Pot had been carried out for over 20 years and formed part of the baseline assessment of natural character values of the Waiwiri Stream. The Pot is adjacent to but not part of this ONFL.

46. An outstanding natural feature or landscape is defined in the Review as having “attributes that are exceptional or pre-eminent. These attributes make it stand out amongst other natural features or landscapes. While evidence of human presence and activity may be apparent, natural attributes dominate.”

47. This is important to note, as while there may be evidence of human modification in the form of discharge to land in the vicinity of the Waiwiri Stream, it was not considered at that time that this modification was sufficient to diminish the stream’s high natural character values outlined above. Indeed, there is considerable human modification along the Waiwiri stream and within is wider catchment. In this way the modification around The Pot area is not dissimilar to the rest of the area.

Page 10 Likewise, the effect of any discharge to The Pot on the adjacent Coastal ONFL was not considered to diminish the high natural character of the area. Given the expert evidence on behalf of the applicant this is unsurprising. Again, the Pot area is not dissimilar to the areas adjacent to (and within) this ONFL.

Scale of change

48. The irrigation concept for the future discharge regime is substantially the same as the current activity. There would also be minimal effects from small scale earthworks (trenching, tracking) and trimming and clearance of vegetation to install the additional irrigation infrastructure, as well as fixing and improve the existing infrastructure.

49. The key changes proposed to the irrigation scheme are:

• Increase the irrigated area to reduce the aerial load of water and nutrients per hectare; • Upgrade the irrigation infrastructure to minimise unplanned discharges due to pipe and fitting degradation; • Reduce the per-event application rate to optimise the time wastewater is retained in the surface soil and increase the likelihood that water and nutrients are taken up by plants and therefore, not lost to groundwater; • Increase the return time for application events to reduce the incidence of soil hydrophobicity, thereby reducing the risk of preferential flow paths or overland flow occurring; • By putting on less, more often, there is an overall reduction in discharge to groundwater from the irrigation area; and • A change in the distribution of discharge through the year to take advantage of high use by plants and lower water table in upgradient position.

50. The scale of change from the future discharge regime to the Waiwiri Stream will not have a noticeable change to the stream's natural character nor affect its ranking as an ONFL. The proposed riparian planting will improve natural character (and enhance the linkage of the ONFL to the native vegetation around Lake Papaitonga). Earthworks will only have a minimal scale of change and to be consistent with that currently occurring. The discharge to groundwater effecting the neighbouring Coastal ONFL (Hokio Beach Dune Fields) is also considered to be negligible (if any).

Degree and nature of effects

51. An ecological assessment by Boffa Miskell (2016)2 found that The Pot does not contain many areas of valued indigenous ecology. There are two areas (indigenous vegetation communities) of higher value which are significant vegetation and significant habitat for indigenous fauna and are considered to be regionally threated habitat types according to Horizons One Plan Schedule F). These areas are the kanuka forest to the north of The Pot and a Carex sedge wetland in the north- western portion of the site (this is addressed in more detail in the evidence of Vaughan Keesing).

52. The Boffa Miskell report finds that:

2 Pot and Tucker Land Blocks, Levin: Assessment of Ecological Values, prepared for Lowe Environmental Impact by Dr Vaughan Keesing, Boffa Miskell Limited, 9 June 2016

Page 11 “The current discharges, while increasing nutrient input (often to levels above Regional thresholds) in to the Waiwiri Stream, do not appear to be having detrimental effects on benthic invertebrate, fish or macrophyte. Those communities are comprised of robust species which have been affected, it seems, by a long history of land use and catchment discharge. Additional nutrient, while not promoted, is unlikely to diminish the current aquatic biotic condition; that is, it is unlikely to further adversely affect the aquatic biota. It may however, exacerbate seasonal periphyton blooms and thus oxygen levels and toxins.”

53. In his Evidence Dr Keesing states that expanding the irrigation there would be no direct effects to the significant ecological features he has identified and that buffers around Waiwiri Stream and all drains will ensure that wastewater irrigation does not cause adverse effects of the valued ecological features.

54. Further on, he states that:

“One last difference from the current irrigation is that along the southern boundary the irrigation proposed will be closer to the Waiwiri Stream than previously. This then runs the risk of subsurface discharge of nutrients and potentially contaminants to the stream. To mitigate this, I understand that the Council are proposing a revegetated buffer (some 20m in width) and I consider this buffer and planting sufficient to reduce the risk of subsurface (or surface) discharge of irrigated water to the Waiwiri Stream to an acceptable (i.e. a virtually no risk) level.”

55. I note that the 20m buffer matches the 20m width of the ONFL. As mentioned above, planting this buffer area with locally sourced indigenous species is likely over the long-term improve natural character of the Waiwiri Stream and will link it to the indigenous vegetation around Lake Papaitonga. Water quality effects from The Pot is assessed by Dr Ausseil in relation to the Waiwiri Stream to be similar to the existing discharges (with a reduction in nitrogen from The Pot proposed in the consent conditions). Dr Ausseil's opinion is that the proposal will not have more than minor adverse effects on water quality in the Waiwiri Stream. He also states that the current monitoring, which has limitations, shows no evidence of adverse effects from The Pot site on aquatic life or life- supporting capacity values of the Waiwiri Stream. The Assessment of Effects on Water Quality and ecology by Aquanet3, June 2018, concludes that “the effects of the proposed activities at the Pot can be expected to remain similar in nature, intensity and spatial extent”.

56. In terms of proposed mitigation, the Water Quality report suggests that the northern bank of the stream (true right) should be given priority for riparian planting, and this along with other mitigation measures suggested are expected to “have a positive impact on in-stream water quality and ecology compared with the current situation. The extent of the positive impact is difficult to quantify at this stage but can be assessed by monitoring over time.”

57. The evidence of Dr De Luca is that the activities at the Pot site are not having, and are unlikely to have in the future, any measurable effect on estuarine or open coastal marine ecological values. The Assessment of Effects on Marine Ecological Values by Boffa Miskell (July 2019) notes the proposed mitigation measures to be implemented as a part of the project will “reduce the mass of contaminants discharging to the receiving environment. Other mitigation measures will result in ecosystem enhancement in the Waiwiri catchment and Waiwiri Stream.”

3 Technical Memo: Levin WWTP Land Application at The Pot: Assessment of Effects on Water Quality and Ecology, prepared by Olivier Ausseil, Principal Scientist, Aquanet Consulting Ltd, 12 June 2018

Page 12 58. Natural character attributes and characteristics are discussed in Objective 6-2 and Policy 6-8 of the Horizons One Plan. They include:

(i) Natural elements, processes and patterns,

(ii) Biophysical, ecological, geological, geomorphological and morphological aspects,

(iii) Natural landforms such as headlands, peninsulas, cliffs, dunes, wetlands, reefs, freshwater springs and surf breaks,

(iv) The natural movement of water and sediment including hydrological and fluvial processes,

(v) The natural darkness of the night sky,

(vi) Places or areas that are wild and scenic,

(vii) A range of natural character from pristine to modified, and

(viii) Experiential attributes, including the sounds and smell of the sea; and their content or setting.

59. As outlined above, areas of natural character can be pristine to modified. The current discharge of wastewater to land at The Pot forms a part of the existing modified characteristics (pest plants, browsing by cattle in places, etc) of the Waiwiri Stream (and the adjacent Coastal ONFL which includes the Hokio Beach Dune Fields). The proposal will not diminish the stream’s natural character values. The proposed discharge will not affect the Waiwiri Stream’s existing natural elements, processes and patterns. Likewise, the natural character values of the adjacent Coastal ONFL will not be diminished.

60. Effects on biophysical and ecological values, as discussed in the assessments of ecology, water quality and marine ecological values are all considered to be no more than minor with most low to very low. The current rates of discharge do not, from the monitoring undertaken, appear to be having detrimental effects on benthic invertebrate, fish or macrophyte communities. Effects on water quality will remain similar to current effects. There will be no change to the effects on the coastal marine environment. The identified natural character values of other biophysical aspects (e.g. landform, geology) of the Waiwiri Stream and Hokio Beach Dune Fields are not considered to change due to the proposal.

61. The proposed discharges will not create a change to the existing experiential attributes of the Waiwiri stream.

62. Overall, it is considered that effects on natural character values remain low.

KEY FINDINGS AND OBSERVATIONS

63. Irrigation of wastewater from The Pot formed part of the baseline level of the Waiwiri Stream and the adjacent Coastal ONFL, which includes the Hokio Beach Dune Fields, when their natural character values were assessed in 2011.

64. The Waiwiri stream is modified by human activity, in particular farming, a loss of riparian vegetation and invasive weed macrophytes (which are mechanically harvested). This human modification,

Page 13 and the discharges to land at The Pot, was not considered sufficient to diminish the stream’s very high natural character values

65. Water quality effects of the proposal on the Waiwiri Stream is assessed by Dr Ausseil to be similar to the existing discharges (with a reduction in nitrogen from The Pot proposed in the consent conditions). Dr Ausseil's opinion is that the proposal will not have more than minor adverse effects on water quality in the Waiwiri Stream. He also states that the current monitoring, which has limitations, shows no evidence of adverse effects from The Pot site on aquatic life or life-supporting capacity values of the Waiwiri Stream.

66. Effects on biophysical values of the proposal remain the same as the existing activities – that is low. Effects on other aspects of natural character will not change. The proposed discharges will not create a change to the existing experiential attributes of the stream.

67. Overall, it is considered that effects on natural character values remain low.

68. Proposed mitigation within the application will, over time, have positive effects on the Waiwiri Stream and its catchment. In the long term, proposed mitigation may enhance some of the existing natural character attributes of the stream.

69. The current discharge of wastewater to The Pot will not create a change to the existing sensory values of the adjacent Hokio Beach Dune Fields. The dune/ sand plain landforms also remain unmodified by the proposal.

RESPONSE TO COUNCIL OFFICERS REPORT

70. The Horizons s42A report highlights that the Waiwiri Stream and the coastal area between The Pot and the Coast are identified as ONFL under the Horowhenua District Plan and the Hokio Beach South Dune Fields are included in the One Plan Schedule G as one of the Regional ONFLs. The report states that the application requires an assessment of effects of the proposal on natural character and the ONLF with regard to One Plan provisions and Policies 13 and 15 of the NZCPS. The report notes that the Beca Report considers the Waiwiri Stream as an ONFL, but not the adjacent regional ONFL of the Hokio Beach Dunes.

71. Within the One Plan, policies 6-6 to 6-10 relate to the identification and protection of natural character. The section 42A report notes in paragraph 184 that: “Objective 6-2(a) of the One Plan require that the characteristics and values of the Regions ONFL and the natural character of the coastal environment, wetlands, rivers and lakes are protected from inappropriate use and development. The Pot already exists in this environment and did so before (and when) the Waiwiri Stream and the adjacent Hokio Beach Dunes were classed as an ONFL. The proposal will have low to very low (if any) effects on these values not likely to alter the landform.

72. Policy 6-9 of the One Plan recognises that in relation to the natural character of the coastal environment, which is not the coastal marine area, that: “subdivision, use or development must generally (but without limitation) be considered appropriate if it: is compatible with the existing level of modification to the environment.” This applies to the Pot site and the ongoing discharge of treated wastewater.

Page 14 73. As discussed above, and as recognised by Policy 6-9 of the One Plan, areas of natural character can be pristine to modified. The ongoing discharge of wastewater to The Pot will not create a change to the existing sensory values of the adjacent Hokio Beach Dune Fields. The dune / sand plain landforms also remain unmodified by the proposal. Natural character values as identified in the 2011 Review are considered to remain High to Very High.

RESPONSE TO SUBMISSIONS

74. Eleven submitters raise issues relating to landscape and natural character within their submissions. All eleven submitters oppose the application. Submissions can be grouped into three main groups, as follows:

75. Submitters who oppose due to effects on natural character and the Waiwiri Stream:

(i) Submitter 17 Charles Rudd objects to the proposal “because of negative impacts and effects to: …Natural character and Amenity values.”

(ii) Submitter 9 Rachel Selby (Ngāti Pareraukawa Ngātokowaru) opposes the application due to the deterioration of the Waiwiri Catchment.

(iii) Submitter 13 Te Runanga o Raukawa (Jessica Kereama) opposes the application due to “specific concerns regarding impacts on cultural and environmental values associated with the site (the Pot), groundwater, the Waiwiri Stream and the coast.”

(iv) Submitter 14 Hokio Environmental & Kaitaki Alliance Inc (HEKA) opposes the application due to the “considerable deterioration in Waiwiri Stream catchment over the last 30 years”.

(v) Submitter 10 Ngātokowaru Marae Committee opposes the application due to the “Presence of wastewater in Waiwiri Stream” and the “effect on coastal environment.”

76. For the reasons set out above, in my opinion the proposal will have low effects on natural character of the coastal environment and the Waiwiri Stream.

77. Submitters who oppose due to effects on landscape character and the environment generally:

(i) Submitter 10 Ngātokowaru Marae opposes the application due to “effects on the dunescape.”

(ii) Submitter 3 David Wilson Gifford Moore (Ngāti Pareraukawa of Ngātokowaru Marae) opposes the application due to effects on the marine environment.

(iii) Submitter 5 Mid Central Public Health Service states that the proposed development requires “proper assessment and mitigation of potential effects on the coastal environment”.

(iv) Submitter 18 Ngāti Kikopuri Māori Marae Committee Society opposes the application due to “effects on the stream, coast and dunescape.”

Page 15 78. In my opinion, for the reasons set out above, the proposal will have low, if any, effect on the dunescape and will not affect the adjacent Hokio Beach Dunes ONFL.

Boyden Evans

14 October 2019

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