BEFORE THE HEARING PANEL INVERCARGILL / WAIHŌPAI UNDER the Resource Management Act 1991 IN THE MATTER of the proposed Southland Water and Land Plan MEMORANDUM OF COUNSEL FOR THE SOUTHLAND REGIONAL COUNCIL 26 September 2017 WYNN WILLIAMS Southland Regional Council's LAWYERS Solicitor CHRISTCHURCH Level 5, Wynn Williams House, 47 Hereford Street, Solicitor: P A C Maw P O Box 4341, DX WX11179, (
[email protected]) CHRISTCHURCH 8140 Tel 0064 3 3797622 Fax 0064 3 3792467 1 MAY IT PLEASE THE PANEL 1 The purpose of this Memorandum is to update the Hearing Panel on the status of the proposed Southland Regional Policy Statement 2012 (pRPS). 2 At the time of preparing the Section 42A Report, both the pRPS and the operative Southland Regional Policy Statement 1997 (RPS 1997) were relevant to the decisions on submissions on the proposed Southland Water and Land Plan (pSWLP). 3 In the Section 42A Report, the Council Officers advised the Panel that:1 (a) the pSWLP must give effect to the RPS 1997; (b) the Panel is required to have regard to the pRPS, although it was submitted that the pSWLP should give effect to the parts of the pRPS that are 'beyond challenge'; and 4 The Council Officers considered that the pSWLP gives effect to the RPS and pRPS.2 5 At the time of preparing the Section 42A Report, the provisions of the pRPS that were under challenge were in Chapter 4 (Water) and Chapter 7 (Coast), as follows:3 (a) Objective WQUAL.2 - Lowland water bodies; (b) Policy WQUAL.3 - Wetlands and outstanding freshwater bodies; (c) Notified Policy WQUAL.4 - Waituna Lagoon; (d) Notified Method WQUAL.13 - Waituna Catchment.