Before Commissioners Appointed by the Canterbury Regional Council

BEFORE COMMISSIONERS APPOINTED BY THE CANTERBURY REGIONAL COUNCIL

IN THE MATTER of the Resource Management Act 1991

AND

IN THE MATTER of applications for resource consents by Lyttelton Port Company for capital and maintenance dredging

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EVIDENCE OF HENRY TAMATEA COUCH FOR TE HAPŪ O NGĀTI WHEKE, TE RŪNANGA O KOUKOURĀRATA, NGĀI TAHU SEAFOOD, AND TE RŪNANGA O NGĀI TAHU

27 April 2017

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INTRODUCTION

1. Ko Te Poho o Tamatea-pōkai-whenua te maunga. Ko Whakaraupō te moana. Ko Uruao, ko Takitimu, ko Te Makawhiua ngā waka. Ko Waitaha, ko Ngāti Mamoe, ko Ngāi Tahu ngā iwi. Ko Ngāti Wheke te hapū Ko Te Rāpaki o Te Raki-whakaputa te papa-kāinga, papa-tū-waewae. Ko Rāpaki te marae. Ko Te Wheke te whare.

2. My name is Henry Couch. I was born in Rāpaki 68 years ago, and I have lived here all my life. I have worked on and around the port for over 50 years, 36 of these years as a watersider (wharfee). See Figures 1 and 2. I have been a Tangata Tiaki/Kaitiaki for 19 years, I was a member of the Rāpaki Rūnanga Executive for over 50 years, a Trustee for Rāpaki for 33 years and I was the chairman of the Rāpaki sewerage committee that removed the septic tanks at Rāpaki, piping this wastewater to Lyttelton to one-day be piped across to Bromley. I was a member of the Southern Shellfish Fisheries Plan Working Group. I am still a member the Ngāi Tahu Mahinga Kai Hī Ika Kōmiti (Customary Fisheries Advisory Committee).

3. My whānau have a long-standing relationship with Whakaraupō / Lyttelton Harbour that spans at least 24 generations. I consider myself fortunate to have learnt and benefited from the knowledge that my ancestors have passed on to me, and I too want to pass on my knowledge to next generation so that they can uphold our tikanga and enjoy the various kai from our culture. I value our harbour deeply and equally, feel responsible for it. See Figure 3.

SCOPE OF EVIDENCE

4. My evidence focuses on the mahinga kai values of Whakaraupō, and my relationship with them over the years. Its purpose is twofold:

(a) To impress upon the Commissioners that the mahinga kai values in the Harbour are still real and present for many people, and they continue to occupy a core place in the culture of Ngāti Wheke; and

(b) To reinforce the need to develop and manage the harbour in respect of those values. Their recovery is our recovery. Mō tātou: All of us. Tātou is inclusive of everyone. (See Figure 4).

5. My evidence is part of the main body of evidence presented jointly by Te Hapū o Ngāti Wheke and Te Rūnanga o Ngāi Tahu on behalf of the whānau of Ngāti Wheke and Ngāi Tahu who maintain their rights and responsibilities in the harbour. My evidence is intended to complement the evidence presented by my colleagues and relations from Te Hapū o Ngāti Wheke and Te Rūnanga.

6. My evidence will look at some of the tikanga that relate to our mahinga kai. The tikanga helps frame and guide our relationship with the harbour.

7. I will highlight some of the key changes that I have observed over my lifetime, and list my key concerns. To conclude, I set out my aspirations for the future of our harbour and people.

8. Some of the old people of Canterbury used to say something like, “Ka pari te tai, ka neke ranei te kawau?” When the tide comes in, will the Kawau (cormorant/shag) leave its rock? 1

BACKGROUND

9. Whakaraupō is the principal mahinga kai within our takiwā (territory), and is a taonga of paramount importance for the survival of our people.

10. As a young person growing up in Rāpaki, we spent most of our time at the beach. See Figure 5 and Figure 6. It was there that we learnt how to gather shellfish and cook them. We never had a problem finding something to eat, whether on the land or in the harbour.

11. As I got older, my brother and uncles started to teach me where and how to find other kai-moana. See Figure 7. We would walk or swim to get to where we wanted to go, and I would say that we must have found our way around the entire coastline in the harbour, including Quail Island (Ōtamahua) and Rīpapa Island.

1 The kawau does not leave its perch readily, despite the incoming tide, and is likened to a person who does not stray far from home, or who is a staunch advocate for the people and place they belong to. 4

12. My brother and uncles told me that the harbour was my pātaka (storehouse) and playground, and to look after it. See Figures 8 and 9. They talked about respecting the harbour and taking only what we needed for ourselves and our whānau. They taught me to leave enough for other whānau and for tomorrow.

13. I still gather and fish throughout our rohe (district, territory) and continue to share what I catch with the kaumātua of Rāpaki. Just seeing the looks on their faces is enough reason for me to gift what I have gained from our harbour. See Figure 10). The joy, it seems, is like the smile on a child’s face when you give them an ice cream.

14. Even though I am getting on in years myself, I still manage to dive in most bays of the Harbour every 2-3 years. I have always owned boats, and currently use a 10ft dingy for setting nets, a kayak to get into hard-to-access places, and a 5 metre Cabin boat to cruise around our rohe to keep an eye on it.

15. In October 1998, my relation, Wiremu Gillies, and I were the first two Tangata Tiaki (customary fisheries managers) to be appointed in New Zealand under the Fisheries (South Island Customary Fishing) Regulations 1998. Nineteen years later, there are five of us who are now responsible for managing our customary fisheries in the harbour, and I present my evidence today with their mandate and the support of Te Hapū o Ngāti Wheke and Te Rūnanga o Ngai Tahu.

16. My evidence is focused on the mahinga kai values of the Harbour as I have come to understand from living in Rāpaki and fishing it most of my life. Over that time, I have been involved in several projects initiated to help improve the mauri (state of well-being, energy, vitality) of the harbour and its key mahinga kai. I note a few of them in my evidence to illustrate the range of efforts that Ngāti Wheke and the people of Lyttelton Harbour have taken to protect and enhance the ecological and cultural values of our harbour.

17. Our primary objective as Tangata Tiaki is to help ensure that the pātaka is always full and to restore it back to the vital mahinga kai that it was.

MAHINGA KAI

18. Mahinga kai is defined as the customary use and management of natural resources, the places where those resources are gathered and the resources themselves. Inherent in mahinga kai management is the aspiration of abundant, customary food that is safe to eat.”

19. Mahinga kai is a primary marker of our identity as Ngāi Tahu. It is a source of great pride and sustenance for our whānau and communities, something that may not be so obvious to those who do not fish, hunt, fossick and feather.

20. Whakaraupō is the largest harbour on Banks Peninsula, Te Pātaka o Rākaihautu, the primary storehouse of Rākaihautu, the famed Waitaha explorer who led the first migration of people into Te Waipounamu.

21. In my life time, I have seen my people use all parts of the harbour for sustenance.

(a) The bays and coastline from Te Awaparahi (Battery Point/Gollans Bay) to Awaroa at the Heads of the Harbour have always been recognised as breeding areas for pāua, kina and other species of shellfish and not typically used for taking kai. See Figure 11 and 12. The only time we could harvest from that area was when we were absolutely in need (e.g. big gatherings like a tangi) and the other parts of the harbour were too rough to access safely.

(b) The bays and coastline of the southern outer harbour were extensively utilised for the gathering of pāua, kina, kūtai (mussels), kōura (crayfish), as well as hoka (red cod), moki, mārari (butterfish) and pioke (rig).

(c) The bays and coastline of the middle harbour were extensively utilised for the gathering of pāua, kina, kūtai (mussels), kōura (crayfish), tio (oysters), tipa (scallops) and tuaki (cockles/clams), as well as moki, mārari (butterfish) and pioke (rig).

(d) The centre of the middle harbour was extensively utilised for the gathering of hoka (red cod) and pioke (rig). Sharks were fished using nets set around the harbour. 6

(e) The bays and coastlines of the inner harbour were extensively utilised for the gathering of pāua, kina, kutāi (mussels), tuaki (cockles/clams), pipi and tio (oysters), as well as pātiki (flounder) and they were special for the fishing method for harvesting pioke (rig) in shallow waters (local whānau used a machete to harvest pioke that are present in the ankle-deep channels when the pioke enter this bay to feed on crab).

(f) The open waters of the inner harbour were extensively utilised for the gathering of pioke and pātiki, which were traditionally taken using nets to set in the harbour.

(g) Other mahinga kai resources of Whakaraupō included marine mammals, waterfowl, seabird eggs, forest birds, plants and trees, eels and other freshwater fish from the streams flowing into the harbour.

22. While we are fortunate that we can still get a good feed of several of these species, I am also aware and concerned that some of these species have already disappeared completely from areas where they used to be (e.g. tuaki, pipi, tipa/scallops and seaweeds – refer to the red dots shown on Map 1 and Attachment 1), while others are in the process of moving away. The red rectangle in Map 1 represents the portion of kaimoana breeding ground that has been lost in the inner harbour. Our tuaki (cockle) beds in Rāpaki, for example, are clearly shifting out of the Rāpaki Mātaitai and into the neighbouring bays. This is not what we want to see. We have harvested from these beds for centuries and we do not want to lose them from our back doorstep.

EFFORTS TO PROTECT AND ENHANCE MAHINGA KAI

23. I have been involved in several initiatives and projects over the years. I have listed the key ones below to demonstrate our community’s commitment to looking after our harbour.

Mātaitai

24. There are very few Customary Protection Areas (CPA) in place over traditional fishing grounds to assist Ngāi Tahu to sustain customary fishing 7

practices and knowledge. Ngāi Tahu are therefore applying significant resources (both financial and human) towards the protection of traditional fishing grounds in order to provide whānau with the opportunity to exercise kaitiakitanga (guardianship/stewardship) and to thus perpetuate customary fishing practices and knowledge. Cultural and physical nourishment relies on these mahinga kai practices taking place.

25. Ngāi Tahu are well aware of the challenges that exist in seeking to protect traditional fishing grounds of significance using CPA. The need to ensure the wise use of time and resources has meant efforts are focussed on the protection of traditional fishing grounds that have the greatest contemporary significance.

26. The Rāpaki Mātaitai was promoted by Wiremu Gillies, Melville Rehu and myself in 1997. See Figure 13. It was approved the following year and was the first mātaitai in the country. The Rāpaki Mātaitai encompasses all the waters of Rāpaki Bay from the Cass Bay church reserve boundary to the Taukahara boundary (refer to Map 2).

27. In December 2011, we applied for the Whakaraupō Mātaitai, which encompasses the inner two-thirds of the harbour, excluding the inner port area, the Rāpaki Mātaitai, the reclamation area and the landing area immediately adjacent to the Diamond Harbour wharf (refer to Map 1).

28. Mātaitai are customary protection areas which are used to manage fisheries using customary knowledge and practice. The principal purpose of these Mātaitai is to manage, protect and enhance fisheries resources in order to recognise and provide for the customary non-commercial use and management practices of Ngāi Tahu whānui. The other main purpose is to give further recognition to the special relationship Te Hapū o Ngāti Wheke have with the harbour (legislative recognition of the manawhenua manamoana that Te Hapū o Ngāti Wheke hold in the harbour).

29. Tangata Tiaki are nominated by mana whenua, appointed by the Minister for Primary Industries, and are responsible for setting limits and managing the fisheries resource. The Whakaraupō Mātaitai will also include an advisory committee of fishing experts from the local community in order to 8

enlist the help of non-hapū members in the management of this harbour area.

30. Mātaitai are an active form of kaitiakitanga within a contemporary context. Rāpaki Tangata Tiaki/Kaitiaki have already conducted significant work within the mātaitai. The current work programme includes:

Mātaitai bylaws

31. New fishing rules were established under mātaitai bylaws to help restore and protect the resources in the Rāpaki Mātaitai. The new rules include prohibitions on taking pāua and native seaweeds and restrictions on taking tuaki and pipi.

Reseeding pāua

32. Over the years, Melville Rehu and I have brought pāua back up the harbour from Little Port Copper and planted them back into the sea in various locations around Rāpaki. This is an old practice of our people and I did it to help create greater growth and abundance closer to our whānau and community.

Reseeding tuaki (cockle)

33. In 2009 and 2010, I enlisted the help of Associate Professor Islay Marsden (School of Biological Sciences, University of Canterbury) to re-seed the tuaki beds within the Rāpaki Mātaitai. Islay continues to provide science support to Tangata Tiaki/Kaitiaki.

34. With the support of our Southern relations, we collected about 25 sacks of tuaki from the Ōtākou harbour and translocated them up along the Canterbury coastline at Timaru, Whakaraupō, the Rakahuri (Ashley / Saltwater Creek Estuary) and Kaikōura. See Figure 13.

Compliance

35. There has also been compliance work through the appointed Honorary Fisheries Officers, including signage, marker buoys, and information pamphlets. See Figure 14.

Harbour wastewater management 9

36. In 2005, I participated on the Lyttelton Wastewater Working Party that was set up to review the waste water treatment and disposal systems of Whakaraupō and evaluate a range of future treatment and disposal options for wastewater that currently discharges into our harbour from the Diamond Harbour, Governors Bay and Lyttelton wastewater treatment plants.

Future work programme:

37. Future work includes:

• Establishment of mātaitai bylaws to support the rebuilding of fisheries within the Whakaraupō Mātaitai as part of the Whakaraupō Integrated Management Plan.

• Conducting Marine Cultural Health Index (MCHI) assessments. The MCHI, developed in collaboration with the University of Otago, is part of the Ngāi Tahu ‘State of the Takiwā’ Cultural Monitoring Framework. The MCHI is a rapid inventory of cultural health that can be conducted over any fisheries area. The key indicators of cultural health focus on abundance and food safety.

• Translocating further tuaki from Otago, scallops from Stewart Island, oysters from Bluff and pāua from other areas of Banks Peninsula with associated fishing prohibitions using mātaitai bylaws.

Tribal solidarity

38. I am a member of the Ngāi Tahu Mahinga Kai Hī Ika Committee, facilitated by Te Rūnanga o Ngāi Tahu to co-ordinate and support customary fisheries management across the Ngāi Tahu takiwā. We meet between 2 and 4 times a year to help guide Ngai Tahu’s response to key regional and national issues affecting our fisheries resources (eg the recent review of Te Ohu Kaimoana / Maori Fisheries Commission). Members are also able to share experiences from their respective takiwā, helping build solidarity throughout the takiwā.

Baseline mahinga kai survey

39. With the support of the University of Otago and Te Rūnanga o Ngāi Tahu, we began a baseline survey of mahinga kai values in the harbour in 2015, focussing particularly at this stage on pāua, kina, tuaki and pipi.

40. The results of this work have begun to fill an information gap in terms of understanding the effects of the Port’s activities on our mahinga kai values. Studies conducted by the Port in preparation for the recovery plan had not included sub-tidal zones of the harbour where a lot of our kai is found, so it could not inform us with any degree of certainty about the effects of the proposed port developments on our mahinga kai values.

41. That process has allowed us to provide additional information to the Minister for Primary Industries about mahinga kai in support of the Whakaraupō Mātaitai.

Tikanga (values, customs, practices)

42. Finally, I note that our tikanga also plays an ongoing key role in protecting and enhancing mahinga kai. See Figure 15. These social norms have been handed down from generation to generation, and include:

(a) Take what you and your whānau need, not what you want;

(b) Waste not, want not;

(d) Leave the breeders, as they will ensure the resource remains over the long term;

(e) Rest a resource that is under stress so that it can recover and provide for another day;

(f) Harvest kai when it is at its prime.

KEY CONCERNS

43. Sedimentation and loss of water depth in the Upper Harbour – As a long-term resident and active fisher of the harbour, I have noticed that there 11

has been an incremental buildup of sediment in the upper harbour over time. I think that sedimentation is the biggest killer in the harbour. While I know that the silt comes off the land, my instincts tell me that the build-up in the upper harbour is compounded by the effects of the breakwaters on the natural ebbs and flows of the harbour. See Figure 16 and Figure 17. The sedimentation seemed to increase dramatically after the development of the Cashin Quay breakwater in the late 1950s and early 1960s, and it is not difficult to see that these structures create changes elsewhere in the Harbour. I have seen these changes, especially in Corsair Bay, Cass Bay and Rāpaki, Governors Bay/Ōhinetahi, Allendale, Mansons Peninsula, Moapuku Point, King Billy Island, Teddington, Charteris Bay, Church Bay and Pāua-o-Hinekotau Head. Mahinga kai species such as conger eel, karengo, tuaki, pipi and pāua were gathered in many of these locations but this is no longer possible due to sediment induced habitat change – especially the decline of seaweed cover (refer to Map 1 and Attachment 1).

44. The building up of silt, and associated loss of water depth in the upper harbor, changes the nature of the seabed along our shoreline. We are finding that the seabed surface has become much ‘harder’ in recent times and we fear that it may be getting too hard for the tuaki and pipi to be able to feed and break through and breathe. We need to make decisions about the harbour with these dynamics and perspectives in mind, and must act now to avoid this situation getting worse.

45. I acknowledge that the Port Company has responded proactively to our concerns and has initiated research through the University of Canterbury to investigate a broader range of core sampling from throughout the harbour. I have no doubt that this will increase our understanding of sedimentation in the harbour, and I look forward to results of that work informing how we can best manage the harbour.

46. Seaweed – The loss of seaweed is becoming an ever-increasing concern. We used to have seaweed that was thick and plentiful, and I remember my father making us bull kelp shoes as we walked around the rocks. My mum would also use the seaweed for medicinal purposes, as well as a conditioner for our garden. Today, there is relatively very little seaweed left, which is very concerning as the seaweed provides essential habitat for pāua, kina and pupu (periwinkles), and shelter for finfish. Once the 12

seaweed disappears it won’t come back and those other species will go too. This tells me our mahinga kai habitat in Whakaraupō is vulnerable, and we need to make sure that we fully understand the effects of the proposed port activities on mahinga kai.

47. Effects of dredging on mahinga kai habitat – I am concerned that an increase in dredging will inevitably lead to greater transportation of sediment around the harbour – whether mechanically or ‘on the tide’. I have already described the sediment build up in the harbour over my lifetime, and I am concerned that our mahinga kai will not tolerate further sedimentation arising from further dredging. I think that test dredging, which is done safely and done right, could be beneficial. This was raised previously but didn’t happen as the dredger broke down (see Appendix 2).

48. Dumping Dredge Spoils on Breeding Grounds – I understand that the Port Company’s current maintenance dredging regime dumps spoil along the north-eastern coastline of the outer harbour. I have seen the build-up of sediment on the reefs and rocky shoreline in that area, and I fear that the spoil dumping will kill this environment if it is allowed to continue.

49. I have noted already in my evidence that this stretch of coastline is a breeding ground for pāua, kina and other shellfish. I am concerned for the sustainability of these species within the harbour if the mahinga kai habitat in this area is further degraded. If pāua and kina cannot breed here, then what is the future of these species elsewhere in our harbour? To that end, we never accepted the disposal at Awaroa as appropriate. What does that mean for the future of my people? Our culture is to collect kaimoana, and many of our whānau still rely on these resources to put food on the table. This harbour is their pātaka (storehouse) and it is their right handed down from our ancestors and recognised by Te Tiriti o Waitangi. We want to protect that right and hand it down again to the generations that follow us.

50. Recovery of Whakaraupō – My biggest concern is that the state of the harbour environment at present suggests to me that our Mahinga Kai are becoming more and more limited and vulnerable. I fear that it may not be too long before our people will not be able to feed themselves from their own pātaka / storehouse. I am conscious that many of my people do not have the luxury of being educated or having the money to afford to buy 13

what they need, when they need it. They do, however, have a right to their traditional mahinga kai, and that must be available to them for their sustenance and survival.

51. I have already described the efforts over the years by Ngāti Wheke and the Whakaraupō community to improve mahinga kai and the cultural health of Whakaraupō. I look forward to seeing these activities and relationships actioned as part of the catchment management plan which was started after the Recovery Plan process. While we expect this plan to build on existing initiatives and relationships and help us work together not only to enhance mahinga kai values but the overall health of Whakaraupō, I also look forward to achieving additional gains for Whakaraupō as a result of this process.

CONCLUSION

52. I have prepared this evidence in the hope that the Lyttelton Port and our harbour can be developed and managed in respect of its mahinga kai values.

53. I understand the need to enhance the economic viability of our region through the port’s activities. It employs our people and is the gateway for business.

54. I am equally aware of the current state of the harbour, particularly with respect to our mahinga kai, and the associated needs of my people. It is my job as a local tangata tiaki / kaitiaki to act in their best interests.

55. Te Tiriti o Waitangi recognised and guaranteed our rights to our waterways, kai and culture. My biggest fear is that the proposed dredging will further erode the mahinga kai values of the harbour and potentially undermine the ongoing ability of our whānau to sustain themselves from their traditional mahinga kai.

56. We know that when dredging occurs, the dynamics of the harbour will change, and the mahinga kai values will be affected. I therefore urge the Panel to adopt a cautious approach by supporting our proposed conditions and outcomes. 14

57. We want to explore sustainable options for managing our mahinga kai in the harbour, including the reduction of sediment build up in areas of sensitivity and/or significance. We want to work with our harbour community to see Whakaraupō flourish again and become the rich resource that it has the potential to be. See Figures 18 and 19.

Henry Couch

Figures

Figure 1. Church at Rāpaki.

Figure 2. Te Wheke.

Figure 3. Rāpaki.

Figure 4. Inner Whakaraupō/Lyttelton Harbour.

Figure 5. Rāpaki children collecting mahinga kai.

Figure 6. Gathering mahinga kai in recent years. 18

Figure 7. Uncle Arthur Trawling

Figure 8. Sediment deposits on seaweed at Ōtamahua/Quail Island (April 2015)

Figure 9. Sediment deposits on seaweed at Ōtamahua/Quail Island (April 2015)

Figure 10. The harbour is to be enjoyed by our young and our old.

Figure 11. The inner harbour at Lyttelton viewed from the hills and the extent of the harbour that has been lost.

Figure 12. Bill Gillies.

Figure 13. The collecting, sorting and reseeding of tuaki in the Whakaraupō.

Figure 14. Hori Briggs Honorary Fisheries Officer (Born in Lyttelton, 1933-2014).

Figure 15. How fishing in Whakaraupō used to be.

Figure 16. Effects of breakwaters in the harbour. 23

Figure 17. Whakaraupō/Lyttelton Harbour viewed from Living Springs.

Figure 18. Our young people being able to fish.

Figure 19. Killer whales in Whakaraupō

Maps

Map 1. Whakaraupō Mātaitai July 2016. Red outline shows the portion of kaimoana breeding ground lost.

Map 2. Rāpaki Mātaitai 2

Attachment 1 – CDP Evidence: Henry Couch

Wāhi/Area Area type # on Map 1 Sedimentation impacts on mahinga kai Kai-o-ruru Mahinga Kai 1 Karengo was gathered here traditionally but it is no longer present due to sedimentation.

Te Wharau Kainga/ Mahinga Kai 2 Tuaki, pipi and tipa (scallops) were gathered here traditionally but they are no longer present due to sedimentation.

Moepuku Mahinga Kai 3 Pāua and kūtai were gathered here traditionally but they are no longer present due to sedimentation (traditionally, farming livestock were taken on to Quail Island by swimming them across from Moepuku only during spring tides. Today livestock could be walked across every low tide).

Te kawakawa Kainga/ Mahinga Kai 4 Tuaki and pipi were gathered on the southwest corner of the island traditionally but they are no longer present due to sedimentation.

Ōtamahua Kainga/ Pā/ Mahinga 5 One of the few areas in the harbour where tipa (scallops) and tio (oysters) were/are gathered by Kai whānau. However stock abundance has decreased dramatically due to sedimentation.

Whakaraupō Mahinga Kai 6 Tuaki and pipi were gathered traditionally but they are no longer present in significant numbers due to sedimentation. Ohinetahi Kainga/ Pā/ Mahinga 7 Tuaki and pipi were gathered traditionally but they are no longer present in significant numbers Ka due to sedimentation. Te Rāpaki a Te Kainga/ Mahinga Kai 8 The area is named after the prominent Ngāi Tahu chief Te Rakiwhakaputa. Rakiwhakaputa (Rāpaki) The location of New Zealand’s first ever Mātaitai Reserve.

A Māori Reserve (Rāpaki MR 875) was established in this bay noting its specialness to the local hapū.

Tuaki, pipi and pāua abundance has decreased dramatically due to sedimentation.

Conger eel were seen here traditionally but they are no longer present due to sedimentation.

Appendix 2.

7 October 2016

Te Hapū o Ngāti Wheke PO Box 107 Lyttelton [email protected]

Dear Kopa Lee

RE: Trial dredge spoil disposal at offshore grounds

An opportunity has arisen to conduct some limited trial dredge spoil disposal at the proposed off-shore disposal sites to complement our understanding of the coastal environment. We have discussed the option of using the New Era (the maintenance dredge currently working in port) with the dredge operators and they are receptive to undertaking this work if the suitable weather conditions occur during the period. The existing campaign runs until early December and if we agree this is a valuable trial, and apply for resource consent, we have time to utilize this opportunity.

We think this has some value and are interested in undertaking the work, however it would need to be supported by manawhenua if we want to obtain resource consent while the New Era is in port. We understand Environment Canterbury could process the consent application in the timeframe required if written approval from ‘affected parties’ is obtained.

LPC would like to undertake up to 10 trial disposal events at the proposed offshore grounds. The purpose of this monitoring is to ‘ground truth’ the modeling by comparing physical measurements with model predictions. It will also provide valuable data on the benthic- surface turbidity relationship.

The disposal events would be monitored with both the existing real time monitoring network and manual measurements of suspended sediment, turbidity, light and other water quality parameters. A brief resource consent application is being prepared covering the parameters outlined below. There may be opportunities for a small number of people to observe the trial disposal which we are happy to discuss if this proceeds.

The proposed trial and associated works are as follows:  Use the New Era to dispose three consecutive dredge loads at 3 different locations, two within the channel deepening disposal ground and one within the proposed offshore maintenance ground. Two maps are attached showing the proposed disposal locations. Dredge loads are approximately 830 m3.  Monitor the concentration and extents of the plumes using manual water quality measurements, visual methods and the installed real time monitoring network.  Compare the data to the modelled predictions  Prepare a report detailing the findings We would make the report available to you, and we expect this would be completed early in the new year. Preliminary results will be available prior to the full report being produced.

LPC P036

In order to undertake this activity, consent is needed (for the deposition and disturbance of the seabed and discharge of dredge spoil). To enable LPC to gain this consent within the timeframe that the New Era is here, we are seeking your written approval, as an affected party.

We are preparing this resource consent application now and are seeking your early advice if you are interested in supporting this application.

Please advise who is the appropriate contact for us to follow up this request and naturally feel free to contact myself on 0272981347,or Jared Pettersson 021679838 if you would like to meet and discuss, ideally next week.

Yours sincerely,

KIM KELLEHER Environmental Manager

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