Submission on the Draft Auckland Unitary Plan

Royal Forest and Bird Protection Society of New Zealand Inc. Northern Regional Office: 34A Charlotte Street PO Box 108 055, Symonds Street, Auckland 1150, New Zealand P: +64 9 302 0203 F: +64 9 303 4548 www.forestandbird.org.nz

TO: Auckland Unitary Plan Feedback Team, Auckland Council, Freepost 237170, Private Bag 92300, Auckland 1142

Royal Forest and Bird Protection FROM: Society of New Zealand Inc. Northern Regional Office: 34A Charlotte Street PO Box 108 055, Symonds Street, Auckland 1150, New Zealand Attn: Dr Mark Bellingham [email protected]

SUBMISSION ON THE DRAFT AUCKLAND UNITARY PLAN

Forest & Bird Charity Registration No. CC26943 Forest & Bird was established 90 years ago and has contributed to regional and local planning, and nature conservation in Auckland for much of that time. The Society represents 25,000 supporters in the region and owns a number of nature reserves that are open to the public.

The Society generally supports the provisions for nature conservation in the plan and the need to direct Auckland's growth so that it both provides for ecologically sustainable growth while minimising on-going significant and permanent damage to the natural environment.

We find parts of the plan do not meet these ecologically sustainable growth tests;  Particularly the poorly constructed policies and rules for the coastal environment.  The failure to address the predicted sea level rise across the whole region (that is required by the NZ Coastal Policy Statement). The latter will add significant costs to development in Auckland, on roads, sewers, stormwater and water supply infrastructure. But the wider spatial effects will be most profound in the 90% of Auckland that in non-urban, where land areas of land have been reclaimed around the Kaipara and Manukau Harbours.

As is the New Zealand planning tradition, the plan fails to address how the objectives and policies in the plan will be monitored and the processes for this.

We have commented a narrow range of matters relating to the Society's core interests. We support the EDS submissions on other related matters.

The following pages outline the changes sought to the draft Unitary Plan.

Forest & Bird Charity Registration No. CC26943 2.4.3.4 BIODIVERSITY

2.4.3.4 Biodiversity

2.4.3.4 Support Objective1 2.4.3.4 Support Objective2 2.4.3.4 Oppose This objective recognises the HGMPA The protection and restoration of Objective3 and WRHAA. However, the word natural heritage features of the ‘promoted’ is weak and fails to give Waitākere Ranges heritage area and effect to the above legislation This the Hauraki Gulf/Te Moana Nui o objective is not carried through into the Toi/Tīkapa Moana is promoted. policies. It is unclear therefore how it will The insertion of specific policies and be implemented. methods implementing these pieces of legislation. 2.4.3.4 Support in part The criteria for identifying significant Consider including the five categories P1 biodiversity are supported. set out in the pNPSIB. Forest & Bird suggests that regard should be had to the pNPSIB which sets out five categories which are regarded as significant. 2.4.3.4 Support in part Forest & Bird supports the intention to Address the incomplete utilisation of P2 identify other areas that contribute to policy 11 of the NZCPS. biodiversity or ecosystem services.

2.4.3.4 Support in part Forest & Bird supports the requirement Amend as set out in reasons. P6 to avoid adverse effects on these areas. However currently this policy – applying to significant indigenous biodiversity – is (in some respects) weaker than Policy 7 which applies to other biodiversity. This

Forest & Bird Charity Registration No. CC26943 is because policy 6(b) and (c) – allow adverse effects to be mitigated or offset – whereas policy 7 does not allow remediation, mitigation or offsetting of significant adverse effects. This policy is also inconsistent with the NZCPS: Paragraph (a)(ii) relates to policy 11(a)(vi) of the NZCPS which requires all adverse effects to be avoided. 2.4.3.4 Support in part Forest & Bird supports the requirement Apply the no net loss concept in this P7 for significant adverse effects to be policy. avoided and other adverse effects to be avoided, remedied, mitigated or offset. Forest & Bird suggests that the ‘no net loss’ concept must be applied to all indigenous biodiversity (not just significant indigenous biodiversity) to enable the Council to achieve its function of maintaining indigenous biodiversity. 2.4.3.4 Support in part This policy lists a number of adverse Amend to clarify what this policy P8 effects on indigenous biodiversity which intends. are “to be avoided”. 2.4.3.4 Support in part Forest & Bird considers that it needs to Amend as set out in reasons. P9 be clearer that this relates to maintaining existing activities. 2.4.3.4 Support in part Forest & Bird support this policy which Add a new paragraph to apply to any P10 recognises the impact of kauri die back pests that may arise during the 10 disease and gives effect to policy 12 year lifetime of the NZCPS. 2.4.3.4 Support in part Forest & Bird supports the general Amend to encourage the use of P11 intent of the policy directing avoidance transferable development rights of clearance or damage. Forest & Bird where “loss is unavoidable to create

Forest & Bird Charity Registration No. CC26943 recognises the need to provide for a single building platform per site”. reasonable use of land where a site has been created that has SEA. 2.4.3.4 Support P12 2.4.3.4 Support in part Enhancement is necessary to achieve Provide for promotion of habitat P13 the identified objectives. However, creation. Forest & Bird considers that habitat creation for all indigenous species should be promoted where appropriate. 2.4.3.4 Support in part This policy is generally supported, Amend to clarify that adverse effects P14 however there are some which are more than minor should be inconsistencies. Forest & Bird contends avoided. that all adverse effects which are more than minor should be avoided. 2.4.3.4 Support Forest & Bird supports the specific P15 recognition of the need to avoid cumulative effects. 2.4.3.4 Support Forest & Bird supports this policy which P16 recognises the very high values of SEA- Marine 1. 2.4.3.4 Oppose in part Forest & Bird considers that “no “the existing structure has no P17 significant adverse effect” is too high a significant adverse effect on the bar. Forest & Bird also considers that values and ecological and physical both the existing structure and the processes operating in the SEA- extension or alteration must have Marine that is more than minor” minimal adverse effects. 2.4.3.4 Biodiversity Policies 18 Oppose in part Livestock have no place in the CMA and Avoid the following activities: this activity is contrary to Policies a. disturbance of the foreshore and 2.4.3.4.1, 2, 6, 7,.8,. seabed and damage to vegetation and habitat from livestock in the CMA

Forest & Bird Charity Registration No. CC26943 2.4.3.4 Biodiversity Policies 19 Oppose in part The descriptions in Appendix 6.1 are Avoid mangrove removal within any vague in many cases and do not asign SEA-Marine 1 or 2 where it will what values are significant. threaten the viability or significance of the ecological values identified in Appendix 6.1 for the SEA-Marine. 2.4.3.4 Biodiversity Policies 21 Oppose The descriptions in Appendix 6.1 are Provide for mangrove seedling vague in many cases and do not asign removal in SEA-Marine 1 areas that what values are significant. do not have significant values associated with mangroves recorded in Appendix 6.1

2.7 COASTAL ENVIRONMENT

Sustainably managing our natural resources Freshwater 5.21 Forest & Bird considers that this section is poorly structured and does not follow the NPSFM framework.

(a) There are aspects of the NPSFM which are not clearly covered by the RPS: (b) protecting the quality of outstanding freshwater bodies (Objective A2), (c) protecting the significant values of wetlands (Objective A2 and B4), (d) improving the quality of freshwater in water bodies that have been degraded by human activities to the point of being over-allocated (Objective A2). 5.22 There is a strong focus on methods to avoid over-allocation, however, there is little mention of the need to first establish freshwater objectives and set freshwater quality limits and environmental flows for all freshwater bodies. Forest & Bird requests amendments to address this.

Sustainably managing our coastal environment 5.23 This section protects the life supporting capacity of coastal ecosystems and the social, economic and cultural values of the coastal environment. 5.24 The section contains good principles relating to the management and protection of the Hauraki Gulf, in accordance with the Hauraki Gulf Marine Park Act. However, whilst it is recognised that the Hauraki Gulf supports unique and important values to which the council must pay special attention, the Auckland region also includes the west coast, which is also an iconic and valuable environment which should be protected. The draft does not currently include adequate provision for management of the west coast. Many of the provisions in the draft which relate only to the protection of the Hauraki Gulf should apply to the west coast as well.

Forest & Bird Charity Registration No. CC26943 5.25 Forest & Bird is also concerned that objectives and policies in relation to the management of coastal water quality are too weak. It is recognised that in many cases water quality issues are complex and expensive issues to resolve (for example in relation to the upgrading of the stormwater network). However, Policy 21 of the NZCPS provides clear direction that councils should identify areas with poor water quality and prioritise improving those areas. Forest & Bird considers that the RPS should provide clear direction that areas with poor water quality are to be identified and improved as a matter of priority.

Section No Support/ Reasons Decision Sought (or words to like Oppose effect) 2.7.1Objective1 Support in part This objective recognises the Amend to include these matters importance of protecting and enhancing the life supporting capacity of ecosystems but it does not include other key matters set out in Objective 1 of the New Zealand Coastal Policy Statement to which the council is required to give effect. Notably, these include maintaining or enhancing natural biological and physical processes, protecting representative or significant natural ecosystems and sites of biological importance and maintaining the diversity of New Zealand’s indigenous coastal flora and fauna 2.7.1Objective2 Support in part This policy proves that the social, Amend to include reference to economic and cultural values of the protecting ecosystem and habitat coastal environment are protected by values, delete ‘where possible’ and maintaining, and where possible, add ‘where it is degraded’ at the end enhancing water quality. of the sentence. 2.7.1P1 Support This policy provides that the intensification of use and development should be avoided where it will have a significant adverse effect on areas identified as having

Forest & Bird Charity Registration No. CC26943 high biodiversity and ecological value. 2.7.1P2 Support This policy provides that subdivision, use and development in the coastal environment should be provided for in an integrated manner. Where these activities are appropriate, Forest & Bird supports this policy. 2.7.1P3 Support in part This policy provides for the Remove the phrase ‘where management of the discharge of practicable’ from the contaminants into the coastal environment but the reference to ‘where practicable’ is not consistent with the requirements of the NZCPS which requires that adverse effects of activities on the areas identified be avoided. 2.7.3Objective5 Support in part The term ‘supported’ is far too vague Replace term ‘supported’ with term and should be replaced with provisions ‘created’ and add additional sentence which refer to the creation and good “Marine protected areas are management of marine protected areas. managed to protect and enhance the ecosystem values of those areas.” 2.7.3P3 Support in part It is appropriate that this provision Insert ‘applications for’ after ‘require’ requires recognition of the interconnectedness of the gulf and the consequent need to assess applications for use and development in this context. 2.7.3P6 Support in part It is important that an effective network Replace ‘support’ with ‘provide’ of conservation and protected areas covering land and sea is created, but the term ‘support’ is weak and unclear.

Forest & Bird Charity Registration No. CC26943 PART 3 REGIONAL AND DISTRICT OBJECTIVES AND POLICIES

3.2.5 COASTAL ZONES

3.2.5.1 Coastal zones  We support the inclusion of objectives and policies giving effect to the Hauraki Gulf Marine Park Act and recognising the need to protect the Hauraki Gulf’s unique values. However, we are concerned that this special attention should not be at the expense of the west coast, which also retains important natural values. As currently drafted there are a number of objectives and policies in relation to the Hauraki Gulf (set out below) which should be extended to cover Auckland’s entire marine area.  The objectives and policies in relation to certain activities in the coastal environment are unduly weighted in favour of economic development and arbitrary clearance of mangroves, without reflecting on the failure of sediment management in catchments causing coastal deposition and shallowing of intertidal areas (where mangroves can grow). The policy setting out the need for a precautionary approach to the coastal environment appropriately recognises the absence of complete information about the effects of mangrove clearance and other activities like offshore mining, but appears to equate precaution with adaptive management.  The poor protection of the CMA is a major step backwards, as stock grazing and stock access to the CMA is allowed and the plan provides for clearance of significant wildlife habitat as a permitted activity, even within SEA Marine 2 areas. This is the provision for mangrove clearance across large parts of the region, without any rationale, except that the marine SEAs fail to comprehensively address significant areas in the CMA and identify these areas.  Most of the Marine SEAs come from the 1985 Auckland Regional Planning Scheme, with minimal changes. Potential SEAs, such as the Kaipara seagrass beds (identified by NIWA for ARC in 2004 fail to make the cut) yet these are the nursury areas for 98% of the west coast North Id snapper stock!  The Marine SEAs also fail to recognise that with 100year sea level rise predictions (NZCPS policies 24 & 25) that most of the regions saltmarshes and much of the mangroves will be under water, along with the habitat and refuge they provide for wildlife forced into this zone by habitat loss on the land e.g bittern, banded rail, fernbird

The information relating section 3.2.5.1 Background is factually incorrect, Forest & Bird seek the following changes:

Mangroves are a valuable part of coastal ecosystems and perform an important role in trapping sediment and contaminants and in mitigating coastal erosion. However, in some areas mangroves have been spreading and are having an adverse effect on other use and values of the coast. A key factor contributing to their spread is the level of sediment entering the CMA from catchments, both from past and current land use, and cumulatively over time. Another factor is mangroves spreading to recover their natural range after being reduced in extent by stock grazing. Mangroves have increased significantly in some areas with

Forest & Bird Charity Registration No. CC26943 poor catchment management. With increasing urbanisation and use of coastal areas this has resulted in demands for mangroves to be able to be removed back to an extent that existed at a earlier point in time when the CMA was grazed and there was less shallow mangrove habitat in the CMA.

Mangroves can affect access, navigation, views, amenity values and the ongoing safe use and function of structures, infrastructure and drainage systems. In some areas mangrove spread has resulted in mangroves dominating over other habitat types as they recover their natural range and reducing biodiversity. Removal may be appropriate to address some limited issues. As the coast is predominantly public commons, mangrove removal should be for the purpose of maintaining biodiversity or to provide for public use and benefit, rather than for private property gain or enhancement. In some areas plans have been developed for the management of the land-sea interface. These include existing coastal compartment plans, comprehensive coastal management plans, area plans, reserve management plans and integrated catchment management plans. Mangrove removal proposals, and initiatives to reduce sediment inputs, should take into account the strategic direction provided by any plan adopted for the area. With increasing sea level rise mangrove extent over the region is likely to decrease.

Removal activities disturb and damage the foreshore and seabed and can have adverse effects on water quality from the release of sediment and contaminants. Removal can also affect ecological values, including on native and migratory bird species, particularly during breeding and feeding times. At the same time mangrove spread can have localised effects on wading bird feeding and roosting areas and removal may be appropriate where there are no alternative roost sites. As areas have different use and values, and are subject to varying natural processes of wind, wave and tide, the effects of mangrove removal will differ between locations. The most appropriate method of removal and disposal of removed mangroves will also differ between sites. Mangrove removal should must be accompanied by initiatives to address the long-term issue of mangrove spread by reducing the amount of sediment entering the CMA, as sediment that settles in upper estuaries and harbours creates an environment where mangrove habitat s can successfully establish and spread. The long-term maintenance of cleared areas needs to be provided for if they are to remain free of mangroves in the long-term. Mangrove seedlings can quickly re-colonise areas if they are not removed on an on-going basis. Sediment may also move from cleared areas over time and result in mangrove stumps needing to be cut back to the new seabed level to maintain the safe use of cleared areas.

Section No Support/ Reasons Decision Sought (or words to like Oppose effect) 3.2.5.1.1 Objective 4 Oppose Contrary to case law. Arbitrary Delete Obj 4 baselines for mangrove clearance have been rejected by the Environment Court (Mangawhai Harbour Restoration Soc. vs NRC 2012) 3.2.5.1.1 Policy 2 Oppose in part An AEE should be required when Encourage Require an assessment of disturbance and clearance activities are sediment inputs in the area and

Forest & Bird Charity Registration No. CC26943 proposed, as this covers SEA areas also. promote catchment initiatives to reduce sediment and nutrient inputs when mangrove removal activities are proposed. 3.2.5.1.1 Policy 3 Oppose in part This policy needs to apply to seedlings Provide for mangrove and seedling only removal where mangroves have spread and the proposed removal is necessary to enable, maintain, restore or enhance: 3.2.5.1.1 Policy 4 Oppose Contrary to case law. Arbitrary Delete Policy 4 baselines for mangrove clearance have been rejected by the Environment Court (Mangawhai Harbour Restoration Soc. vs NRC 2012) 3.2.5.1.1 Policy 6 Oppose in part Provides no clear guidance as to Delete subclause (e) outcomes and will result in more significant CMA clearance as non- 6. Require mangrove removal to: notified activities. e. take an adaptive management approach for mangrove removal and disposal where a significant area of removal is proposed and there is uncertainty over the extent of adverse effects

Forest & Bird Charity Registration No. CC26943 PART 4 RULES

4.3 6 Coastal Zone Rules

1.4 Activity Table Disturbance and extraction

 The plan is excessively permissive in terms of allowing unnecessary damage and disturbance to the CMA.  Livestock need to be prohibited from the CMA, this is general standard practice for most regional councils as it recognises the long-term and cumulative damage to coastal ecosystems from on-going livestock access to this public land.  There is no particular rationale for allowing disturbance of SEAs to clear mangroves (except for some irrational hatred of indigenous vegetation and natural processes occurring in SEAs).  The areas for mangrove control are excessive as current practice has not required any ecological assessment of the need to remove mangroves, as these are processeda s non-notified applications even when the effects are significant and contrary to the plan policies.

Forest & Bird seeks the following changes to the activity status of the following below:

Activity table – General Coastal Marine zone, SEA-M and ONF overlays General SEA-M1 SEA-M2 ONF -Type ONF - Type Coastal A1 and A V1, V2, B, C, Marine Zone D, E, F Disturbance and extraction (s. 12(1) and 12(2(b)) RMA) Livestock access to the CMA not otherwise provided for Pr Pr Pr Pr Pr

Livestock access to the CMA (other than for droving and horse riding) Pr Pr Pr Pr Pr adjacent to intensively grazed production land after (date five years post-notification) Mangrove and seedling removal C D D D D  not in a marine reserve  in SEA-M1 only in areas listed in Appendix 6.5 or Appendix 6.6

Forest & Bird Charity Registration No. CC26943 Activity table – General Coastal Marine zone, SEA-M and ONF overlays General SEA-M1 SEA-M2 ONF -Type ONF - Type Coastal A1 and A V1, V2, B, C, Marine Zone D, E, F Disturbance and extraction (s. 12(1) and 12(2(b)) RMA) Mangrove removal (other than seedlings) from an area that was free Pr Pr Pr Pr Pr of mangroves in 1996  not in a marine reserve  in SEA-M only in areas listed in Appendix 6.5 Mangrove removal in significant wading bird areas listed in Appendix Pr Pr Pr Pr Pr 6.6 Mangrove removal to enable the operation, maintenance, use and P D C C C functioning of existing lawful structures, infrastructure and drainage systems, or to ensure public health and safety in the use or operation of infrastructure

 Maximum of 30m2 in GCM zone, SEA-M2', SEA-M1 and ONFs

4.3.6. 1.2 Assessment criteria

Forest & Bird seeks the following changes below:

4.3.6.1.2

2.8 Livestock access to the CMA

1. Droving or grazing livestock (apart from horses) in the CMA is Prohibited.

2. Livestock access to the CMA is limited to droving of stock or horse riding and must ensure: a. it does not occur in estuarine areas or areas of salt marsh or mangroves and no grazing of intertidal vegetation shall be allowed to occur

Forest & Bird Charity Registration No. CC26943 b. the stock must be moved along at all times and not left unattended c. horses must be kept under control at all times d. horses must not graze on intertidal vegetation e. horses must not be ridden or taken into bird breeding areas.

3. Adjacent to intensively grazed production land, livestock exclusion can be provided by way of permanent fencing, dense vegetation or natural barriers.

4. Any livestock exclusion measures must be permanent and effective.

Controls for livestock access are also provided in clause 4.3.7.3.1.1 and Part 4.2.3.8 - Lakes, rivers and wetland management.

2.9 Mangrove removal 1. Mangrove removal, including seedlings, mangrove removal from an area that was free of mangroves in 1996, and mangrove removal in significant wading bird areas. a. Removed vegetation is disposed of outside the CMA. b. The removal does not involve any discharge of chemical herbicides in the CMA other than as provided for in an approved pest management strategy c. Any visible disturbance to the substrate of the CMA must be remedied or recontoured within seven days of completion of the works. d. Removal is done by hand or by hand-held tools. e. Removal is not in areas where mangroves are serving to mitigate coastal erosion from wave action. f. Removal will not damage or disturb areas of salt marsh or seagrass. g. Written advice is given to the council at least 10 working days prior to removal, other than for the removal of 30m 2 or less of seedlings. The advice will include the location and extent of the mangroves to be removed, the timing and methods of removal, and sufficient evidence to demonstrate that the area was free of mangroves in 1996. h. In a significant wading bird area, removal is timed to avoid bird roosting and nesting seasons.

2. Mangrove removal to enable the operation, maintenance, use and functioning of existing lawful structures, infrastructure and drainage system, or to ensure public health and safety in the use or operation of infrastructure to a maximum of 200m2. a. Removed vegetation is disposed of outside the CMA. b. The removal does not involve any discharge of chemical herbicides in the CMA, other than as provided for in an approved pest management strategy. c. Any visible disturbance to the substrate of the CMA must be remedied or recontoured within seven days of the completion of the works. d. The removal must be immediately adjacent to the structure or infrastructure, or any drainage system

3. Effects on coastal processes, ecological values, water quality and natural character

Forest & Bird Charity Registration No. CC26943 Disturbance - mangrove removal g. Removal of mangroves, including seedlings, should be avoided from areas: i. identified as having significant ecological or natural character values, or where mangroves provide important ecological values ii. of active coastal erosion where mangroves provide a buffer against coastal processes causing erosion iii. where the sediments contain high levels of contaminants at risk of being re-suspended. h. Proposals to remove mangroves should include will require an assessment ecological values, sediment inputs in the area, and identification of catchment initiatives to reduce sediment and nutrient inputs that need to be implemented prior to any clearance being approved. i. Mangrove removal should:needs to: i. minimise the disturbance of the foreshore and seabed, and sediment and contaminant discharges ii. where practical, dispose of removed mangroves outside the CMA using an appropriate method iii. provide evidence that the disposal method will not result in significant adverse effects on the CMA where landward disposal is not proposed iv. take an adaptive management approach where a significant area of removal is proposed and there is uncertainty over the extent of adverse effects vi. provide for the long-term maintenance of cleared areas v. avoid burning removed mangroves as the method of disposal in the CMA.

6. Effects on existing uses and activities

Disturbance - mangrove removal g. Mangrove removal should be enabled may be considered where mangroves have spread and the proposed removal is necessary to enable, maintain or restore or enhance: i. essential public access to, or along, the CMA and ii. essential connections with reserves or publicly owned land and the sea iii. public use and amenity values iv. essential water access and navigation, including waka portage routes v. Necessary public health and safety, including sightlines and traffic safety vi. Necessary access to the coast from marae, or to areas of traditional use vii. ecological values, including significant wading bird feeding or roosting areas viii. cultural or historic heritage or natural features. h. Mangrove removal should be enabled may be considered where there is no practicable alternative, and removal is necessary to allow for: i. the operation, maintenance and use of existing lawful structures, or infrastructure including drainage ii. the provision of infrastructure, including drainage systems that cannot practically be located in an alternative area, that would avoid the need for mangrove removal iii. removal of areas identified for clearance in a reserve management, comprehensive coastal management or similar statutory plan that has been subject to a statutory

Forest & Bird Charity Registration No. CC26943 consultation process where the potential adverse effects have been considered.

4.4.8.3.1 Controlled activities

Section No Support/ Reasons Decision Sought (or words to like Oppose effect) 4.4.8.3.1 Controlled activities Oppose There are no appendices Ax or Bx and Delete (b) and insert remainder as a 3.1.1 Matters of control no particular reason that conforms discretionary matter in 3.3.1 3. Mangrove removal with the NZCPS or the policies in the plan to justify why 30 ha of habitat clearance is is appropriate

Forest & Bird Charity Registration No. CC26943 4.4 OVERLAY RULES

Forest & Bird seeks the following changes below:

SEA Development controls 2.1 Dwelling 1. One dwelling per site where there is no practicable alternative location on the site outside the SEA overlay: a. the total cleared area is 300m2, including any area cleared for additional buildings or access.

Forest & Bird seeks the following changes below where we have identified errors in the maps.

SEA MARINE OVERLAY MAPS Forest & Bird seeks the following changes noted above. The maps are grossly deficient and need to include existing information AND have clauses in appropriate places identifying the significant ecological values in coastal and marine areas may not have been surveyed and identified. This will require a precautionary approach to all applications and most activities in the CMA.

SEA TERRESTRIAL MAPS Natural Environment 1360 Alfriston Road, Ardmore: PT LOT2 DP 156737 – SUBJ TO LAND COVENANTS BLKS XII XV OTAHUHU SD: covenants should be identified as ‘Natural Environment: Significant Ecological Areas’.

Waitakere Ranges - 40-42 Paturoa Rd The road reserve adjacent to these properties has the most significant area of kauri forest in the locality. It is identified in the operative Waitakere Plan maps, but has been deleted in the Unitary Plan maps.

HERITAGE MAPS 188 Ranfurly Road, Alfriston: Historic Heritage Place – 1454, the Chapman-Taylor house is located in the wrong place. The historic house on our Olive Davies Reserve is about 100m to the south.

Forest & Bird Charity Registration No. CC26943