FILE REFERENCE RC26155 (TCC) RM17-0579 (BOPRC)

1. APPLICANT: Transpower Ltd

2. SUBMITTER DETAILS: Paora Stanley, Chief Executive Officer Te Runanga o Ngai Te Rangi Iwi Trust (Ngāi Te Rangi) Te Awa o Tukorao Lane PO Box 4369 South 3149

3. PROPOSED DETAILS

3.1 Ngāi Te Rangi understand the proposal is the realignment of the HAI-MTM-A Transmission Line, Maungatapu to Matapihi including Rangataua Bay, (the Application).

4. SUBMISSION DETAILS

4.1 Ngāi Te Rangi supports the removal of the HAI-MTM-A Transmission Line (A-Line) Maungatapu, but Ngāi Te Rangi opposes the realignment insofar as it relates to the termination structures (33C and 33B) that are required to be constructed to cross the Rangataua Bay.

5. REASONS FOR THE SUBMISSION

5.1 The Maungatapu Marae (Opōpoti) is located by the shores of Rangataua Bay. Maungatapu Marae has suffered significantly from the encroachment of residential development over the past 70 odd years.

5.2 The current view from Maungatapu Marae across Rangataua Bay to the Matapihi Peninsular towards Te Ngaio Pa will be affected even further by the application than the current alignment of the A-line high tension powerlines. Key viewpoints from the Marae atea looking eastward across Rangataua Bay to the Matapihi peninsular will suffer adverse visual effects that will degrade the amenity experienced from Maungatapu Marae.

5.3 The natural character of Rangataua Bay has already been compromised to some extent by the Maungatapu Bridge and tower 118 located in the Coastal Marine Area. It is acknowledged that the Application proposes to remove tower 118 from Rangataua Bay as well. That is supported.

5.4 However constructing Termination Structure 33C is opposed. Termination structure 33C in particular will be an eyesore from Maungatapu Marae, due to the significant height of the structure in comparison to any other structure in the immediate vicinity.

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Manuhiri who enter Maungatapu Marae will notice the imposing structure which will diminish the natural character of Rangataua Bay even further.

5.5 Transpower has the opportunity to improve the natural character of the area by reducing the visual pollution from these imposing industrial structures. The only limitation upon doing so is cost.

5.6 Once the realignment is complete it is unlikely that we will see any change for decades judging by how long it has taken Transpower to apply to shift Line-A from its current location. Therefore the best decision for the community that is left with these imposing structures needs to be made.

5.7 The Application as it relates to the section which crosses Rangataua Bay:

(a) is not consistent with s 6(e) of the Resource Management Act 1991 as it does not sufficiently recognise and provide for the relationship of Ngāti He and their culture and traditions with their ancestral lands, water, sites, waahi tapu, and other taonga;

(i) Termination structure 33C will block views from Maungatapu Marae southeastwards to its ancestral maunga at Tamapahore, impacting the relationship that Ngāti He has with its ancestral lands.

(b) is not consistent with s 7(a) of the RMA as it does not have regard to Ngāi Te Rangi kaitiakitanga over Rangataua Bay.

(c) is not consistent with section 7(c) of the RMA as the application does not have regard to the maintenance and enhancement of amenity values of Rangataua Bay;

(i) The amenity of the beach at Maungatapu (Opopti) will be affected by an imposing 34.5m termination structure that will be adjacent to the beach and out of place;

(ii) The amenity of the marae will be adversely affected due to the viewshaft towards Tamapahore being partially obstructed.

(d) is not consistent with s 7(f) of the RMA as the Application does not have regard to the maintenance and enhancement of the quality of the environment.

(i) Although the natural environment has been compromised to an extent by existing development, such as the causeway, bridge and subdivision, Transpower should not be adding to the degradation of the natural environment by constructing domineering structures of this size so close to the Marae environment, and residential environment such as the kaumatua flats and kohanga reo.

(e) is not consistent with s 8 of the RMA as it fails to take into account the principles of the Te Tiriti.

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The National Policy Statement on Electricity Transmission (Electricity NPS)

5.8 Policy 6 to the Electricity NPS states:

Substantial upgrades of transmission infrastructure should be used as an opportunity to reduce existing adverse effects of transmission including such effects on sensitive activities where appropriate.

5.9 Policy 6 is highly relevant to the Application before the consenting authority.

5.10 It is considered that the definition of “sensitive activities” within the Electricity NPS would not preclude bringing marae, kohanga reo, and kaumatua flats within that definition.

5.11 There has been a long history for tangata whenua who were aggrieved by the initial way in which Line-A was established and the time has come to rectify past deeds by realigning Line-A on a consistent path with the Maungatapu expressway. However the method utilised to cross Rangataua Bay is the most significant issue for Ngāi Te Rangi. Once any structure is constructed it will remain in place indefinitely. Therefore the option which has the least effects should be chosen.

5.12 Policy 7 of the Electricity NPS states:

Planning and development of the transmission system should minimise adverse effects on urban amenity and avoid adverse effects on town centres and areas of high recreational value or amenity and existing sensitive activities.

5.13 The Electricity NPS is clear in its direction that development of the transmission system should avoid adverse effects on areas of high recreational value or amenity and existing sensitive activities. Termination structure 33C has adverse effects for the community of Ngāti He. There are other options to cross Rangataua Bay which are not as visually dominating, which can avoid or at least mitigate the visual intrusion.

Tauranga Moana Iwi Management Plan

5.14 The Application states that the application is consistent with the Tauranga Moana Iwi Management Plan. From a Ngāi Te Rangi perspective this statement is not reliable. The Management Plan includes the following relevant policy and specific action:

Policy 15: Manage the effects of coastal structures (including moorings and jetties) and infrastructure in Tauranga Moana.

Action 15.2: Pylons are to be removed from Te Ariki Park and Opoopoti (Maungatapu) and rerouted along the main Maungatapu road and bridge. [Lead Agency: Transpower]

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5.15 The matter of how the lines are rerouted along the Maungatapu bridge is not agreed. Ngāi Te Rangi prefer that a design which is less visually intrusive be selected.

6. DECISION

6.1 Ngāi Te Rangi seeks that the Council approves the realignment, but opposes option 3(a) in the Application as the method to cross the Rangataua Harbour.

7. HEARING

7.1 I wish to be heard in support of my submission.

7.2 If others make a similar submission I will consider a joint presentation with them at the hearing.

Paora Stanley Chief Executive, Te Runanga o Ngai Te Rangi Iwi Trust

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