Submission on Te Anau Manapouri Wastewater Treatment Area Notice of Requirement for Designation Southland District Council, PO Box 903 INVERCARGILL 9840

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To: Submission on Te Anau Manapouri Wastewater Treatment Area Notice of Requirement for Designation Southland District Council, PO Box 903 INVERCARGILL 9840

Contact Details of Submitter:

Name: Manapouri Doubtful Sound User Group (MDSU) Attention: Fiona Black

Address C/o Real Journeys P O Box 1 Te Anau 9640

Phone: (03) 249-9033 Fax: (03) 249-8902 E-mail: [email protected]

1. Background: The Manapouri Doubtful Sound User Group (MDSU) is a group of mainly tourism operators with interests in Lake Manapouri and Doubtful Sound. The current members of the group are: John Twidle (Meridian Energy & DCOET), Clint Tauri (Fiordland Cruises), Richard Abernethy (Fiordland Expeditions), Fiordland Explorer Cruises, Chris and Diane Lemin (Deep Cove Charters), Reg Calder and Jo Wilson (Adventure Kayak and Cruise), Peter McCallum (RD Petroleum), Mark Hosie, TA & G Fishburn and Real Journeys.

2. Submission on Te Anau Manapouri Wastewater Treatment Area Notice of Requirement for Designation

Section 168A of the Resource Management Act details the matters the council must consider as follows: When considering a requirement and any submissions received, a territorial authority must, subject to Part 2, consider the effects on the environment of allowing the requirement, having particular regard to— a) any relevant provisions of— i. a national policy statement: ii. a New Zealand coastal policy statement: iii. a regional policy statement or proposed regional policy statement: iv. a plan or proposed plan; and b) whether adequate consideration has been given to alter-native sites, routes, or methods of undertaking the work if— i. the requiring authority does not have an interest in the land sufficient for undertaking the work; or

ii. it is likely that the work will have a significant adverse effect on the environment; and c) whether the work and designation are reasonably necessary for achieving the objectives of the requiring authority for which the designation is sought; and d) any other matter the territorial authority considers reasonably necessary in order to make a decision on the requirement.

Hence the Southland District Council (SDC) must have regard to consideration of alternative sites and methods when considering this proposal to site the Te Anau Manapouri waste water treatment facilities at Lot 2 DP 410687 Manapouri. MDSU contends that the SDC has not given adequate consideration to alternative sites and methods for the relocation of Te Anau waste water treatment facilities. MDSU believe it is more appropriate to upgrade the current Te Anau treatment facility because we understand there is sufficient land at the current site for such redevelopment. The proposal to relocate of Te Anau – Manapouri waste water treatment facilities to Manapouri Highway, Manapouri, Lot 2 DP 410687 will require waste from Te Anau to be pumped uphill to Manapouri. No information has been provided regarding the provisions to be made for power cuts. Moreover the maintenance of such a long pipeline and pumping stations will have greater inherent on going costs for the community which has not been addressed in the Notice of Requirement for Designation.

Also the above section of the RMA requires SDC to have regard to significant adverse effects on the environment. MDSU contends that this proposal to change the land designation does not adequately address effects on the environment. The effects of discharges are not tackled at all in the Notice of Requirement for Designation. This should be addressed as part of this process to allow the community to make an informed decision regarding the proposed land designation change. Further the effects of the proposed treatment plant on neighbours has not been elucidated adequately either in the Notice of Requirement for Designation. The current Te Anau waste treatment facility attracts a good deal of birdlife, having such bird life concentrated on the land around the Te Anau Manapouri Airport will have an adverse effect on the operation of the Airport. Most of the members of MDSU are tourism operators and as such we believe it is very short sighted to put forward a proposal which will adversely impact on this airport operation especially because the airport is struggling to attract business.

Accordingly because of the deficit of information in the Te Anau Manapouri Wastewater Treatment Area Notice of Requirement for Designation and because MDSU believes the current Te Anau Wastewater Treatment Plant should be upgraded instead of being relocated the MDSU is opposed to the proposed change in designation of the area 1701 Te Anau – Manapouri Highway, Manapouri, Lot DP 410687.

Date: 22 February 2013

Ted Loose Chair Manapouri Doubtful Sound User Group