Our Ref: 626073 File: A53-0033

13 April 2016

To: Horizons Regional Council [email protected]

Subject: COUNCIL’S SUBMISSION TO HORIZONS REGIONAL COUNCIL’S ANNUAL PLAN 2016/17

Submission from: Ruapehu District Council Private Bag 1001 3964

Point of Contact: Anne-Marie Westcott ENVIRONMENTAL MANAGER Email: [email protected] Phone: 07 895 8188

COUNCIL WISHES TO SPEAK IN SUPPORT OF ITS SUBMISSION.

1 Thank you for the opportunity to submit on the draft Annual Plan 2016-17. We apologise that this submission is late. We received the draft Annual Plan material on March 29 2016, just two weeks before the deadline for submissions. This is a very tight turnaround and we were unable to write the submission in the time available. We would have liked more time to be able to engage with our own Elected Members on the issues raised for consultation in this Annual Plan.

1.1 Ruapehu District Council (RDC) generally supports the proposals in the Horizons Draft Annual Plan 2016-17, however we would like to comment on some aspects of it.

2 SECTION TWO – LAND AND WATER MANAGEMENT 2.1 RDC is grateful for the support given by Horizons during the contamination of Raetihi river system. The Raetihi community continues to watch the Makotuku River closely and is concerned about its general degradation from its headwaters throughout the catchment.

Page 2 Our Ref: 626073 13 April 2016

2.2 Thank you also for your efforts in the Environment Court in attempting to limit NZ Energy’s water abstraction. RDC notes that the ‘Water Allocation Grandfather’ clause does create rights for the energy company but is concerned about the volume grandfathered under the One Plan water allocation system which has been shown to have an effect on the Makotuku River water quality and quantity.

2.3 Recently RDC, in conjunction with Horizons staff, developed an application for funding from Envirolink to provide a better understanding of the respective impacts of ammonia, nitrate and phosphorus on periphyton growth in rivers downstream of point source discharges. However, and disappointingly, Horizons has recently chosen not to submit this application for funding. This research would provide better certainty about effluent treatment standards that are needed to address environmental impacts caused by excessive periphyton growth. This research is relevant to many wastewater treatment systems which discharge to water across the Horizons Region and nationally. Within the Horizons Region, it has direct relevance to discharges managed by Rangitikei DC, Manawatu DC, Palmerston North City Council, Tararua DC and Ruapehu DC. Periphyton growth is a major question, and the lack of understanding around this leads to significant cost in the consenting process. The expected outcomes from this research would have helped significantly clarify the scientific debate in recent high profile consent cases such as the Palmerston North wastewater plant discharge to the Manawatu River and the Feilding wastewater plant discharge to the Oroua River. In the Ruapehu District, this research is directly relevant to the discharge from the Raetihi wastewater plant to the Makotuku River.

2.3.1 Given the research relates to a gap in scientific knowledge, with at least region-wide applications, rather than to a site-specific problem, it seems logical that the research effort (including funding) should not be borne by one individual district council, and that it falls within regional council’s role to lead or at least contribute to the effort. This was acknowledged at staff level, and accordingly an application for Envirolink medium advice grant was developed between Ruapehu District Council, Massey University and Horizons staff, with the research to be conducted by Massey University’s School of Engineering and Advanced Technology and Aquanet Consulting. In that process we must commend Horizons Scientist’s collaboration and efforts. Manawatu and Rangitikei Districts have agreed to provide in-kind contributing in the form of monitoring equipment. Both Massey and RDC invested significant staff and consultant time to develop the proposal, only for the proposal to not be submitted by Horizons. We note that Horizons were not asked to fund the proposal, only to submit the application. Horizons’ failure to lodge the application is now costing RDC additional staff and consultant time to pursue alternative sources of funding.

2.3.2 RDC believes the causes of the growth of periphyton downstream of point source discharges are not well understood and would like Horizons as the lead environmental agent to investigate the factors involved in periphyton growth in the whole catchment of the Makotuku River. RDC cannot afford to go down the track that Palmerston North City Council did in removing phosphorous from its effluent, only to find that it did not solve the effect created in the river by the discharge.

2.4 RDC is currently charged $26,463 as an Additional Research Site under Water Quality Charges for Discharge Consents (Schedule of Charges, Horizons Annual Plan, pg

Page 3 Our Ref: 626073 13 April 2016

191). This is on top of the Discharge to Water annual fee and any compliance inspection cost of the resource consent discharge. The Additional Research Site fee is the highest fee of all charges for Water Quality Discharge consents in the region with the next being Rangitikei District Council followed by Manawatu District Council. It is assumed that this fee goes towards research into effects on the river systems from wastewater treatment discharges, however the resource consent applications are now lodged and RDC sees limited value (with the exception of Raetihi) in continuing to collect such a high level of detailed information.

3 SECTION THREE - FLOOD PROTECTION AND CONTROL WORKS 3.1 The Makotuku River at Raetihi Township is significantly congested with willows, both above and below the township. The willows have the effect of forming a dam and holding water up in this area. This creates a high risk within the township at peak flows when the township drainage systems are no longer able to discharge in to the Makotuku River as was the case in June 2015. This resulted in a number of habitable floors being affected with flooding and some self-evacuation occurring. Council seeks to partner with Regional Council in managing this river system.

3.2 RDC wishes to thank Horizons for their investigation into the upper Mangawhero and tributaries for flood and erosion risks in Ohakune (Draft, July 2015). RDC provisionally supports the development of the Upper Mangawhero and Tributaries Scheme. We ask that it extends to cover construction that safeguards RDC’s wastewater treatment asset and links with the downstream private scheme. As Horizons are the specialist in stock bank flooding development we ask that they lead this proposal. Also that they investigate the river gravel management within the proposed scheme area to control flooding.

3.2.1 RDC would also like to understand the rating impacts of this scheme on the Ohakune community before making a final commitment to the scheme.

3.3 River scheme RDC would like to thank Horizons for undertaking the improvements to the Taringamotu River Scheme and its ongoing support. While the establishment of the scheme appeared to be quite fraught, it has improved the river system for the community.

3.4 Upper Scheme The maintenance and clearing of poplars in the lower and previous clearing of the township has been much appreciated by locals. This project has noticeably enhanced the visibility and beauty of the Whanganui River system for the Taumarunui community.

4 SECTION FOUR - BIOSECURITY AND BIOACTIVITY MANAGEMENT 4.1 Please refer to RDC’s submission to Horizons Animal and Plant Pest Management Strategy (Attachment 1).

4.2 Ngati Rangi have aspirations to restore the bush and wetlands area adjacent to the Ohakune Wastewater Treatment Plant. We support their endeavors in this project.

5 SECTION FIVE – REGIONAL LEADERSHIP AND GOVERNANCE 5.1 Horizons provides rural advice to dairy farmers as a service. RDC believes that this is a

Page 4 Our Ref: 626073 13 April 2016

service that Horizons could extend to councils regarding wastewater treatment systems. A more collaborative approach to technical concerns may help to avoid adversarial discussions at consent hearings and the resulting costs of adversarial positions. Collaboration would be a good move towards co-governance and partnership of service delivery for our communities as best practice moving forward. RDC has experienced the benefits of such a collaborative approach before lodgment in establishing the science and agreeing up front who would be collecting that science for our resource consents. We believe that other councils would benefit from such a collaborative approach. Currently costs for the Resource Consent can be more than the actual cost of the upgrade.

5.2 As discussed in the presentation given by RDC in October 2015 regarding resource consents, we found that Iwi had aspirations to be more involved in the governance space and discussions up front. This position still remains available within the Wai Group for Horizons to participate in our journey with Ngati Rangi and Ngati Uenuku.

5.3 Ngati Rangi and Ngati Uenuku would like to form a Memorandum of Understanding (MOU) with both RDC and Horizons. This desire for an MOU was referred to in the presentation in October 2014 regarding resource consents (proposed content of MOU attached. Attachment **)

6 REGIONAL ECONOMIC GROWTH RDC supports Horizons role in facilitating regional economic development.

ATTACHMENT 1 Our Ref: 621864 File: C60-1254

09 February 2016

To: Horizons Regional Council Private Bag 11025 Manawatu Mail Centre PALMERSTON NORTH 4442

Subject: HORIZONS REGIONAL COUNCIL COMBINED REGIONAL PEST MANAGEMENT PLAN AND STRATEGY 2015-2025

Submission from: Ruapehu District Council Private Bag 1001 TAUMARUNUI 3964

Point of Contact: Anne- Marie Westcott ENVIRONMENTAL MANAGER Email: [email protected] Phone: 07 895 8188

Council wishes to speak in support of its submission.

1 INTRODUCTION AND SUMMARY OF MAIN POINTS

1.1 Ruapehu District Council (RDC) appreciates the opportunity to submit on the Horizons Regional Council (HRC) Combined Regional Pest Management Plan and Strategy 2015- 2035 (RPMP). As a predominately rural district that comprises a large portion of the Horizons Region, this strategy will significantly affect our communities and Council operations. RDC support the general direction of the proposed plan and strategy and has proposed that some additional information be added.

Page 6 Our Ref: 621864 09 February 2016

2. PEST ANIMALS

2.1 Regarding 2.1.2 (table 2.1) of the RPMP, RDC would like to advocate that the likes of feral mustelids, koi carp and feral cats remain in this part of the RPMP section. Removing these pests from this section releases HRC from their responsibility to protect the region from serious, adverse effects associated with these organisms and animals.

2.2 An increase in the Koi Carp and feral cat populations will have devastating effects on native species and ecosystems. Koi Carp, a noxious species, degrade water quality through stirring up sediment making the habitat unsuitable for other animals and plants. Both feral cats and koi carp threaten native wildlife.

3. PEST PLANTS

3.1 Regarding 2.1.3 (table 2.2), RDC maintains that the responsibility of the progressive containment of pests plants such as broom, tutsan and wilding conifers should also include HRC.

3.2 HRC’s involvement in the containment of tutsan is vital at a regional and local level.

3.2 RDC would like to advocate that heather is included in table 2.2. Heather is an invasive plant pest and needs to be controlled immediately. Heather has now become an issue in National Park and is starting to appear on Crown and Iwi lands such as Erua.

4 ERADICATION PROGRAMME

4.1 Rook nests have now been observed as far south as Ohakune. This implies that the pest is spreading. RDC requests HRC’s commitment to eradicating this pest because it can have devastating effects on newly sewn crops and damage mature pasture by tearing it up.

4.2 RDC supports and wholly appreciates HRC’s commitment to eradicate Alligator Weed.

5. PROGRESSIVE CONTAINMENT PROGRAMME

5.1 RDC would like to advocate that tutsan be moved from the progressive containment programme to the eradication programme. Tutsan can, and will, spread to invade almost all types of terrain. It is a serious environmental pest producing a large amount of seed.

6 MANAGING FRESHWATER PEST PATHWAYS

6.1 RDC supports the good practices proposed in the RPMP. It is vital that information is produced to educate the region on these practices.

7 TRANSPORT CORRIDORS; PEST DISPERSAL, CONTAINMENT AND ERADICATION

7.1 RDC agrees to the reasonable expectations of roadside pest control and containment that the RPMP puts forward. However, RDC is concerned that there is potential for costs to exceed our ability to pay.

Page 7 Our Ref: 621864 09 February 2016

7.2 RDC has a well-established annual plant pest management meeting with Horizons to collaborate on the containment of plant pests.

7.3 Total eradication of any plant pest is financially out of the question for RDC.

7.4 Regarding 3.4.5, RDC is concerned about the tradeoff between the proposed reduction of mowing frequency in the summer months to minimize seed dispersal with motorist safety and general district-wide tidiness.

8 SPECIE SPECIFIC PROGRAMMES

8.1 RDC acknowledge and support the work of HRC and TBfreeNZ in managing the Possum population.

8.2 RDC would like to advocate that Heather be added to the Specie Specific Programme for reasons stated above.

ATTACHMENT 2

Memorandum of Understanding (MOU)

Key Aspects to a Memorandum of Understanding (MOU) between parties to consolidate a process to continue to move forward including the following:

Who a. Formalise a relationship between Ngāti Rangi, Uenuku and RDC, including confirming:

• Frequency of meetings

• Representation b. Horizons must be involved - could be either as a member of this MOU or a separate MOU; c. Ngāti Tamahaki also to be involved – could either could be either as a member of this MOU or a separate MOU, d. DOC also to be involved - could be either as a member of this MOU or a separate MOU.

Why

To establish an enduring relationship to address issues of common interest in the rohé.

What a. Address the additional recommendations of the Wai Group formed for the WWTP consent renewal process; b. Catchment management including water quality improvement and water allocation; c. Develop process for recognising and incorporating Cultural Health Indicators into water quality monitoring; d. Develop a code of practice for protection of taonga and waahi tapu; e. Develop consultation process for resource consents; f. Develop consultation process for other council decision making processes; g. Investigate external sources of funding for infrastructure upgrades and improvements; h. Define process and timeframe for future relationship (e.g. MOA), and i. Define a disputes resolution process