Wet Weather Wastewater Overflows in the Ōtākaro/Avon River, Ōpāwaho/Heathcote River, and the Ihutai/Avon- Heathcote Estuary

CCC Wet weather wastewater overflows Christchurch City Council 20-Oct-2017

Wet weather wastewater overflows in the Ōtākaro/Avon River, Ōpāwaho/Heathcote River, and the Ihutai/Avon- Heathcote Estuary

Section 127 change to resource consent conditions of CRC092692

P:\605X\60507690\4. Tech work Area\4.5 Planning\change in conditions application\CCC wastewater s127 AEE v2.docx Revision 2 – 20-Oct-2017 Prepared for – Christchurch City Council – Co No.: N/A AECOM CCC Wet weather wastewater overflows Wet weather wastewater overflows in the Ōtākaro/Avon River, Ōpāwaho/Heathcote River, and the Ihutai/Avon-Heathcote Estuary – Section 127 change to resource consent conditions of CRC092692

Wet weather wastewater overflows in the Ōtākaro/Avon River, Ōpāwaho/Heathcote River, and the Ihutai/Avon-Heathcote Estuary Section 127 change to resource consent conditions of CRC092692

Client: Christchurch City Council

Co No.: N/A

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In association with Christchurch City Council

20-Oct-2017

Job No.: 60507690

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Quality Information Wet weather wastewater overflows in the Ōtākaro/Avon River, Document Ōpāwaho/Heathcote River, and the Ihutai/Avon-Heathcote Estuary

Ref 60507690

Date 20-Oct-2017

Prepared by Helen Lawrence

Reviewed by Duncan Whyte

Revision History

Authorised Rev Revision Date Details Name/Position Signature

1 13/10/2017 Draft for client review Justine Bennett – Associate Director -

Environment 2 20/10/2017 Final for lodgement Justine Bennett – Associate Director -

Environment

Table of Contents 1.0 Introduction 1 1.1 Purpose of this report 1 1.2 Structure of this report 1 2.0 Background 2 2.1 Christchurch wastewater network 2 2.2 Hydraulic model 2 2.3 Relevant resource consents and compliance strategy agreement 2 2.4 Current status 3 3.0 Description of Proposed Activities 4 3.1 Condition amendments 4 3.2 Reasons for proposed changes 4 3.3 Overflow sites 4 3.4 Future works programme 5 4.0 Description of the Environment 6 4.1 Ōtākaro/Avon River 6 4.1.1 Hydrology 6 4.1.2 Recreational and amenity values 6 4.2 Ōpāwaho/Heathcote River 6 4.2.1 Hydrology 6 4.2.2 Recreational and amenity values 7 4.3 Ihutai/Avon-Heathcote Estuary 7 4.3.1 Hydrology 7 4.3.2 Recreational and amenity values 7 4.4 Water quality and ecological values 7 4.4.1 Ōtākaro/Avon River 8 4.4.2 Ōpāwaho/Heathcote River 8 4.4.3 Estuary Water Quality 9 4.5 Cultural values 9 5.0 Resource consent requirements 10 5.1 RMA Section 127 10 5.2 Previous submitters 11 6.0 Consultation 12 6.1 Environment Canterbury 12 6.2 Tangata Whenua 12 6.3 Compliance and Monitoring Liaison Group 12 7.0 Assessment of Effects on the Environment 13 7.1 Introduction 13 7.2 Effects on human health 13 7.3 Effects on freshwater quality 13 7.3.1 Event based loading 14 7.3.2 Annual contaminant loading 18 7.3.3 Summary of effects on water quality 19 7.4 Effects on ecology 19 7.5 Effects on amenity and recreational values 19 7.6 Effects on cultural values 19 8.0 Statutory Assessment 21 8.1 National Policy Statements 21 8.2 Canterbury Regional Policy Statement 21 8.3 Canterbury Land and Water Regional Plan 21 8.4 Christchurch District Plan 22 8.5 Mahaanui Iwi Management Plan 22 8.6 Te Te Rūnanga o Ngāi Tahu Freshwater Policy Statement 23 8.7 Part 2 Assessment 23 8.8 Section 105 24 8.9 Section 107 24

9.0 Notification 25 10.0 References 26 Appendix A Existing resource consent CRC092692 and compliance strategy A Appendix B Overflow sites description B Appendix C Cultural Impact Assessment D

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1.0 Introduction

1.1 Purpose of this report This Assessment of Effects on the Environment (AEE) supports an application under section 127 of the Resource Management Act 1991 (RMA) by Christchurch City Council (CCC, the applicant) for the change in conditions of resource consent CRC092692. Resource consent CRC092692 allows the CCC to discharge water and contaminants to water from overflow points in the Christchurch wastewater network as a result of wet weather events. This report sets out the proposed changes to CRC092692 and an assessment of the environmental effects of the changes. As the changes are an alteration to provide clarification on the meaning of an overflow event and to reflect network changes resulting from the Canterbury Earthquakes 2010 and 2011, the changes are considered within the scope of the original consent and can be considered under Section 127 of the RMA. This report addresses the resource consent requirements and satisfies Section 88 of the RMA. Section 88 requires that an application for resource consent includes, in accordance with Schedule 4, an AEE in such detail as corresponds with the scale and significance of the effects that the activity may have on the environment. In accordance with Section 127 of the RMA, only the effects of the change are considered.

1.2 Structure of this report The remainder of this report is set out in the following sections:  Section 2: Background  Section 3: Description on the activities  Section 4: Description of the environment  Section 5: Resource consent requirements  Section 6: Consultation  Section 7: Assessment of effects on the environment  Section 8: Statutory assessment  Section 9: Notification assessment

The following information is appended to this report:  Appendix A – Existing consent and compliance strategy  Appendix B – Overflow sites description  Appendix C – Cultural Impact Assessment

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2.0 Background

2.1 Christchurch wastewater network Christchurch’s wastewater is managed through a network of over 2,600 km of public wastewater pipes, 30,817 manholes and over 140 pump stations which all convey wastewater from homes and businesses to the Christchurch Wastewater Treatment Plant in Bromley. Pumping is required due to the flat ground the city is built on. From the treatment plant wastewater is discharged to the Pacific Ocean via the ocean outfall 3 km off South New Brighton. Wastewater predominantly consists of water and the remaining small portion is a range of debris and inert materials, organic materials, nutrients, pathogens, oil, grease and compounds such as heavy metals and organic compounds. The concentration of contaminants in wastewater is variable and dependent of the source. Generally Christchurch’s wastewater by volume is approximately 30% infiltration from stormwater and groundwater, approximately 60% domestic wastewater and the remainder is from commercial/industrial sites. The system has over 120 constructed overflow points which are in place to ensure that when there is a major disaster, or pump stations fail or the system is overloaded, normally during wet weather events, wastewater is managed to avoid discharges to roads and private land where public health risks are much higher. Emergency overflows are a feature of all municipal wastewater networks both in New Zealand and overseas. Total avoidance of wastewater overflows caused by wet weather events is not practical due the over design required and the high cost involved in upgrading the larger older networks. Overflows during wet weather events are highly diluted due to the inflow and infiltration of stormwater and groundwater into the system and also the higher flows in surface water bodies.

2.2 Hydraulic model Over time the hydraulic model used to predict and assess wastewater overflows for Christchurch City has been improved. The early model was developed by the Australian Water Technologies (AWT). The current Christchurch wastewater model was developed by Opus in 2011, and then updated in 2014 with additional SCIRT survey data, and is much more extensive than the early model. It is the 2014 model that the 2016 post-rebuild model is based on, with predicted post-quake growth and the SCIRT rebuild programme actions included. Using 15 years of rainfall records modelling has been used to carry out long term simulations (LTS) of the wastewater system to determine overflow locations and also to prioritise future network upgrades. Many of the overflow sites were damaged in the earthquakes and have been modified, replaced or removed as a result of earthquake recovery works. Catchments have also changed with the earthquakes particularly in relation to the Residential Red Zones. The modelling completed provides a better understanding of the overflow locations and overflow frequencies but does not change that the expected effects of the discharges on the receiving environment will continue be less than minor.

2.3 Relevant resource consents and compliance strategy agreement In 2002 CCC was granted resource consent CRC991222; to discharge contaminants to the Ōtākaro/Avon River and Ōpāwaho/Heathcote River from wastewater overflows from the wastewater system in severe wet weather events. That resource consent required a two year overflow frequency standard (2 year Average Recurrence Interval (ARI)) to be met and included a table of system improvement works that CCC were required to undertake by set dates. Overflow discharge points in CRC991222 were limited to 12 sites. Following the granting and implementation of CRC991222, through further improvements to modelling used to determine the performance of the wastewater systems indicated additional sites were expected to overflow either at the time or into the future. The cost of carrying out the capital works to achieve the overflow frequency standards had also increased, to the extent that CCC considered it was not an effective use of ratepayer’s money to complete all required system improvements. Therefore a new consent application was lodged to cover the additional over flow sites and amend the 2 year ARI to a 6 month ARI.

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The replacement consent application (CRC092692) was lodged in 2009, covering 22 specified locations discharging overflows from the wastewater network to the receiving environments of the Ōtākaro/Avon River, Ōpāwaho/Heathcote River, and Ihutai/Avon-Heathcote Estuary. CRC092692 was publically notified in February 2009 and the hearing completed in June 2010. An appeal to CRC092692 was resolved in March 2014, resulting in the termination of CRC991222. The resource consent was granted for all the specified sites with specific overflow event frequency standards to be met for each catchment by 2015, 2020 and 2025. The full set of consent conditions for CRC092692 is included in Appendix A. CRC092692 commenced on 4 March 2014 and is due to expire on 4 March 2029. In 2010 and 2011 the Canterbury Earthquakes caused significant damage to the wastewater pipes and pump stations, causing a significant increase in groundwater infiltration to the wastewater network. As a result of the damage, Officers of both CCC and Environment Canterbury (ECan) considered that CCC was unable to comply with the conditions of CRC092692 and sought an agreement in relation to the enforcement and compliance of CCC’s wastewater overflow resource consents. This agreement is included in Appendix A; it sets out the conditions of CRC092692 that CCC are required to comply with and details of further obligations required of CCC. The agreement terminated on 17 September 2017 and an extension to the agreement was made until 20 October 2017 as documented in Appendix A. This application is for the purposes of changing the conditions of CRC092692 to reflect the changes to the wastewater network following the earthquakes and improved modelling, and to enable the wastewater network to be compliant during wet weather events.

2.4 Current status A compliance assessment comparing the Long Term Simulation (LTS) overflow data with the existing frequency of overflow event consent conditions of CRC092692 was completed using the hydraulic model. The results of this assessment are summarised below. In regards to Condition 3, which limits overflows to the 22 locations identified in Schedule 1 of the resource consent, the model identified 10 consented sites which did not overflow during the LTS but also identified 28 additional overflow sites. Therefore the current situation does not comply with Condition 3. The compliance assessment against Condition 5a is shown in Table 1 below. As agreed by ECan the event frequency is calculated across each receiving environment as one overflow event, rather than each individual site as a discharge event. Documentation of this confirmation is included in Appendix A.

Table 1 Compliance assessment against CRC092692 Condition 5a – consented overflow locations only (Schedule 1 sites) Annual Overflow Annual Overflow Event Receiving Environment Frequency Consent Compliance Frequency Limit (2015) Ōtākaro/Avon River 6.20 7 Yes Ōpāwaho/Heathcote River 8.00 8 Yes Ihutai/Avon-Heathcote Estuary 0.67 0.87 Yes

Compliance with Condition 5b is indicated in the overflow sites Table 1 of Appendix B with red highlighting the exceedances. The hydraulic model identified compliance with Condition 5b (annual overflow event frequency at each site of no more than 2) is met at all the existing consented overflow sites except Fisher Avenue which is modelled to overflow on average 2.4 times a year but actual data shows this site only overflows on average 1.8 times per year. As stated above additional overflow sites have been identified, of these 5 of the sites are modelled to overflow more than twice a year. These sites are 40 Guild Street (PS121/1), Tilford Street (PS13/1), Sandwich Road/Eastern Terrace (PS21/3), Opawa Road (PS44/1) and (PS77/1).

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3.0 Description of Proposed Activities

3.1 Condition amendments CRC092692 authorises the discharge of water and contaminants to water from overflow points in the Christchurch wastewater network as a result of wet weather events. The proposed changes to conditions are limited to the following amendments (text to be inserted is underlined and text to be deleted is struck out): Condition 7: For the purposes of determining compliance with Condition (5) and Condition (6), the overflow frequency shall be calculated using a field-calibrated computer model which predicts the annual average number of overflow events and total overflow volumes into the Avon and Heathcote Rivers and the Avon-Heathcote Estuary. For the purposes of calculating “overflow frequency” for a water body, an overflow will be counted as one event if there is more than one overflow location on that water body overflowing at the same time or within 24 hours of each other. The model shall use a long-term time series methodology to assess current system performance against actual rainfall records. The period of actual rainfall to be analysed shall be of 25 15 years duration and the period end shall be less than three years from the date of the analysis being undertaken. Condition 8: Within 3 months of the date of commencement of this variation to the consent, CCC will consult with the Community Liaison Group to determine the 17 most frequent or largest volume overflow locations that are to be continuously monitored automatically. Automatic monitoring and alarm systems shall be provided and thereafter maintained operational at each of these overflow locations. which the field calibrated computer model identifies as overflowing more than once in every 3 years. Schedule 1: Changes are also sought to Schedule 1 to include all the locations that overflow in the post-SCIRT rebuild wastewater network overflow model. Schedule 1 is referenced in conditions 3 and 5 of CRC092692 and the full Schedule 1, as currently proposed, is included in Appendix B.

3.2 Reasons for proposed changes It is proposed to change Condition 7 to clarify how compliance is to be measured. This change reflects the discussion held between CCC and the ECan compliance officer. The change from using 25 years of rainfall data to using 15 years is as previously agreed with ECan through confirmation of the compliance strategy included in Appendix A. The changes to Condition 8 are to identify the most important sites for monitoring overflows, as continuous monitoring of all overflow sites would be expensive and of little benefit. The changes to Schedule 1 are to reflect the changes to the wastewater network post-earthquake and the greater understanding of the wastewater network brought about by the improved hydraulic model.

3.3 Overflow sites Additional overflow sites to the existing resource consent are to be included in this new application, which results in a total of 40 overflow sites in the Christchurch urban area which discharge into the Ōtākaro/Avon River, Ōpāwaho/Heathcote River or the Ihutai/Avon-Heathcote Estuary. A description of the location of each of these sites, the modelled frequency of overflows and the average annual overflow volume is set out in Table 1 of Appendix B. The plan showing the location of the discharge sites currently consented to remain in Schedule 1 and the additional sites is also included in Appendix B.

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3.4 Future works programme As set out in the compliance strategy set out by CCC and agreed to by ECan included in Appendix A, CCC have plans in place for capital upgrades to resolve the overflows from all locations that are currently modelled to overflow more frequently than is provided for in Condition 5(b) of the existing consent. The funding for the required projects is included in the CCC Long Term Plan and therefore progress towards reducing overflow frequencies at key sites is scheduled to be completed. The dates for these upgrades to be met are included in the proposed update to Schedule 1 included in Appendix B.

3.5 Alarms and monitoring CCC has a response plan for overflow events as required by Condition 17 of the existing resource consent. The plan includes procedures for public notification, erection of pollution signs, and water quality sampling. All the Response Plan requirements are in place and there are no changes sought to this condition. Condition 8 of the existing resource consent requires that all overflow sites identified as overflowing more than once in three years have automatic monitoring and alarm systems installed. In the event of an overflow alarm activation and confirmation that an overflow is occurring, laboratory staff sample the river upstream of the discharge point, at the discharge point and downstream of the overflow point in order to gauge the effects of the overflow on river quality. If there are multiple discharge points on a river the monitoring occurs upstream of the most upstream overflow point and downstream of the most downstream overflow location. Further sampling is carried out after the rainfall event and cessation of the overflow to determine when the coliform levels have returned to normal. The public meeting held to review the model outputs on 30 November 2016 was addressed by CCC staff and by Joel Wilson WCS Engineering from Melbourne who has carried out the model optimisation assessments. The meeting was attended by 50 people and this meeting gave the view that “frequency” of overflow was the key issue to target and any mitigation works were to primarily aim to reduce the frequency of overflows in wet weather. Naturally, achieving continued reduction in overflow frequency will also reduce total overflow volumes. In almost every case the most frequent overflows also reflect the largest volume overflows on an annual basis. The programmed works for mitigation are therefore aimed to reduce overflow frequency, and the proposed monitoring regime is aimed to monitor all overflows with a frequency of 1 in 14 years (ARI 0.07) as predicted by the modelling. Due to the changes in location and additional discharge sites shown to overflow in the model, a change to Condition 8 is sought to enable the Community Liaison Group to determine the 17 most frequent or largest volume overflows. This will enable the alarm and monitoring to be targeted to those sites of highest priority to the community.

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4.0 Description of the Environment A summary of the each of the main catchments receiving wastewater overflows is provided below, followed by a summary of the water quality, ecological, and cultural values across the catchments.

4.1 Ōtākaro/Avon River 4.1.1 Hydrology The main stem of the Ōtākaro/Avon River is 26 km long, and it drains an effectively flat catchment area covering about 90 km2 that comprises most Christchurch suburbs north of the approximate east- west line formed by Ferry Road, Moorhouse Avenue, Blenheim Road and Yaldhurst Road. The highest point above sea level is about 30 m, and the land slopes eastwards at about one tenth of a degree. Over 80% of the Ōtākaro/Avon River catchment is urbanised, however large areas previously occupied by residential dwellings in the east along the river are now cleared due to the red zoning following the Canterbury earthquakes. The Ōtākaro/Avon River flow is comprised of a spring-fed baseflow and stormwater runoff from the northern Christchurch suburbs. The dry weather base-flow is fed by springs located mostly in the Avonhead area which in turn are fed by groundwater that is recharged from areas well outside the river’s surface catchment area. Other than the spring fed tributaries there are approximately 74 km of stormwater drains that flow into the Ōtākaro/Avon River, contributing to the water quantity and quality of the waterway. Although the spring-fed baseflow fluctuates with the groundwater levels the average baseflow is approximately 1.6 m3/s but with flows of up to 30 m3/s resulting from stormwater contributions during heavy rainfall events. 4.1.2 Recreational and amenity values Urbanisation has modified the diversity of natural features throughout the Ōtākaro/Avon River catchment, particularly through highly engineered drains and retaining walls in both tributaries and the main stem of the Ōtākaro/Avon River. However, there are pockets of natural landscape that have been retained or restored and now have significant value, for example through Riccarton Bush, Hagley Park, Travis Wetland and Horseshoe Lake. The Ōtākaro/Avon River has public access almost continuously along both banks from Fendalton Road to the estuary and there are number of public parks adjacent to the river, such as Hagley Park and also including public space through the Central City that is being developed as part of the Te Papa Ōtākaro/Avon River Precinct. A number of sports clubs also have facilities along the banks of the Ōtākaro/Avon River, including rowing, kayaking and waka ama. In addition to these water sports, the river has many tracks alongside it used for walking, cycling and jogging.

4.2 Ōpāwaho/Heathcote River 4.2.1 Hydrology The main stem of the Ōpāwaho/Heathcote River is 25 km long and its catchment is approximately 103 km2, draining the area generally south of the Ferry Road, Moorhouse Avenue, Blenheim Road and Yaldhurst Road line, and extending up onto the Port Hills. The catchment is predominantly residential, but with commercial and industrial areas, with the largest of these in Hornby, Sockburn and Woolston, and residential and rural areas in the Port Hills. The Ōpāwaho/Heathcote River is fed by a combination of springs and stormwater runoff from the southern Christchurch suburbs. Dry weather flow in the Ōpāwaho/Heathcote River is sustained by springs in the Hoon Hay area. The base-flow in the Ōpāwaho/Heathcote River fluctuates due to groundwater levels with an average flow of 0.8 m3/s but with flows of up to 33 m3/s resulting from stormwater contributions during heavy rainfall events.

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4.2.2 Recreational and amenity values The Heathcote and its tributaries contribute to the city’s natural and cultural heritage and there are sections of the river which have particularly high levels of amenity, such as the river sections through Beckenham and St Martins. Urbanisation has reduced amenity in areas where the diversity of natural features has been reduced. Recent new subdivisions with retention basins and areas of restored native riparian margins contribute to the overall amenity of the catchment. The Ōpāwaho/Heathcote River provides a natural link through the southern suburbs to the estuary and is widely used for walking, cycling and jogging. There are a range of recreational facilities along the river bank including tracks, lighting, seats, picnic tables, jetties, boat ramps, playgrounds and toilets. The river is also a used for kayaking and fishing.

4.3 Ihutai/Avon-Heathcote Estuary 4.3.1 Hydrology The Ihutai/Avon-Heathcote Estuary is a shallow, roughly triangular shaped estuary and receives incoming water from the Ōpāwaho/Heathcote River from the southwest; the Ōtākaro/Avon River from the north; and seawater from Pegasus Bay to the southeast. The estuary covers a total area of about 8 km2, and has an average depth of 1.4 metres at high tide (Mean High Water Springs). About 85% of the area is a tidal mud and sand flat exposed during periods of low tide. The estuary is surrounded on all sides by the built environment; residential properties at Sumner to the south; Christchurch Wastewater Treatment Plant and oxidation ponds to the west and residential properties on the South New Brighton Spit to the east. The South New Brighton Spit separates the estuary from Pegasus Bay. 4.3.2 Recreational and amenity values There are a wide variety of recreational activities undertaken at and around the estuary, including yachting, windsurfing, kiteboarding, fishing, picnicking, canoeing, kayaking, bird watching, walking and jogging. The proposed Christchurch Coastal Pathway is being completed in stages and will connect Ferrymead and Sumner along the shore of the estuary, providing additional access to the estuary area. The ECan recreational water quality of swimming sites database indicates the quality of water for swimming has improved although is still considered poor other than at the southern end of the estuary, i.e. monitoring sites at Beachville Road, spit tip and Moncks Bay.

4.4 Water quality and ecological values CCC undertakes regular water quality and ecological monitoring in all its major waterways, with water quality monitored monthly at numerous sites and ecological sampling occurring on a 5-yearly frequency throughout the city. The most recent monitoring reports were used to describe ecological values (Boffa Miskell 2014, 2015). Compared to its natural state, the existing urban waterway environment is degraded: Increased impervious area results in more intense and flashy flood flows; lack of riparian vegetation, channel straightening, and piping severely reduces habitat quality; tide gates, weirs, and perched culverts create barriers for migratory fish; and water quality is degraded by industrial and residential stormwater contaminants, nitrate-rich groundwater, and potentially also wastewater overflows. The Ōtākaro/Avon River and Ōpāwaho/Heathcote River and their tributaries, along with numerous other Christchurch waterways, are recognised as Sites of Ecological Significance (SES) under the Christchurch District Plan. The reasons for their SES classification vary slightly from river to river, and include both aquatic and terrestrial ecology aspects. However, from an aquatic ecology perspective the key reason for the SES classification of these waterways is that they support At Risk fish species (inanga, longfin eel, and bluegill bullies) and their migratory routes, and some waterways also support At Risk freshwater crayfish (kēkēwai) and freshwater mussel (kākahi). The sensitivity of the receiving environment – in particular the Ōtākaro/Avon River and the Ōpāwaho/Heathcote River – varies depending on the environmental pressures under consideration.

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Recent ecological surveys are consistent with historical studies that show generally degraded instream and riparian conditions, with dominance of fine sediments (due to bank erosion and runoff), minimal shading and limited instream habitat availability and variation (Boffa Miskell 2014, 2015). Despite the lack of shading and elevated nutrient concentrations, which are both conducive to nuisance plant growths, bed coverage with aquatic plants (macrophytes), and algae (periphyton) is low to moderate (Boffa Miskell 2014, 2015). For example, macrophyte and periphyton cover complied with Land and Water Regional Plan freshwater outcome levels at 41 out of 44 sites recently sampled in the Ōtākaro/Avon River and Ōpāwaho/Heathcote River (Boffa Miskell 2014, 2015). Removal of macrophytes two or three times per year by CCC contractors is the reason for relatively low coverage of macrophytes and periphyton, despite favourable growing conditions. Aquatic macroinvertebrates include snails, worms, insects, and crustaceans, and they are regularly sampled by CCC to provide an indication of stream health. The most recent ecological assessment of the Ōtākaro/Avon River and Ōpāwaho/Heathcote River and their tributaries indicate that these waterways are generally in poor ecological health, and are typical of waterways in moderately urbanised catchments (Boffa Miskell 2014, 2015). Quantitative Macroinvertebrate Community Index (QMCI) scores – an index of macroinvertebrate community and overall stream health – are indicative of poor to fair quality at 42 out of 44 sites (Boffa Miskell 2014, 2015). Land and Water Regional Plan freshwater outcomes for QMCI scores were met at 21 out of the 44 sites sampled (Boffa Miskell 2014, 2015). The macroinvertebrate community is generally dominated by pollution-tolerant snails, fingernail clams (Mollusca), Diptera (two-winged flies), and crustaceans. Pollution-sensitive stoneflies (Plecoptera) and mayflies (Ephemeroptera) are absent from both catchments, and caddisflies (Trichoptera) are present, but not abundant (Boffa Miskell 2014, 2015). Cashmere Stream (an upstream tributary of the Ōpāwaho/Heathcote River) is one of few waterways in Christchurch that has freshwater crayfish (kēkēwai) and freshwater mussel (kākahi) populations (McMurtrie & James 2013; Boffa Miskell 2015). A single freshwater crayfish has also been recorded from the upper Ōpāwaho/Heathcote River (Taylor & Blair 2012). Kēkēwai and kākahi are particularly valued, due to their At Risk – Declining conservation status (Grainger et al. 2014), and because they are both mahinga kai. 4.4.1 Ōtākaro/Avon River Considering the poor ecological health of these waterways, the Ōtākaro/Avon River catchment has a reasonably diverse fish fauna. Three of the seven fish species recorded during the most recent survey have an At Risk–Declining conservation status, including bluegill bully, inanga and longfin eel (Boffa Miskell 2014; Goodman et al. 2014). In addition, inanga, the most important of the five whitebait species, has known spawning sites in the lower Ōtākaro/Avon River catchment (Taylor & Blair 2011). The largest of these spawning sites are immediately upstream of Avondale Bridge, and further downstream in the vicinity of Amelia Rodgers reserve (Taylor & Blair 2011). Seismic activity following the September 2010 and February 2011 earthquakes has led to considerable habitat damage at a number of these spawning sites, particularly at Lake Kate Sheppard (Taylor & Blair 2011). In other areas, poor vegetation maintenance and encroachment of suitable spawning vegetation by invasive plants, such as yellow-flag iris, has led to a decline in inanga spawning habitat quality (Taylor & Blair 2011). Trout spawning also occurs in some of the faster-flowing, gravel-dominated reaches of the Ōtākaro/Avon River and a number of its tributaries, primarily Waimairi and Wairarapa streams (Taylor et al. 2012). 4.4.2 Ōpāwaho/Heathcote River The Ōpāwaho/Heathcote River catchment has a comparatively diverse fish fauna (Boffa Miskell 2015). Three of the 12 fish species recorded during the most recent fish survey are considered At Risk- Declining, including bluegill bully, inanga and longfin eel (Boffa Miskell 2015; Goodman et al. 2014). Inanga spawning is known from the lower reaches of the Ōpāwaho/Heathcote River, mainly from immediately downstream of Opawa Road Bridge (Taylor & Blair 2011). Many of the historic inanga spawning habitats were adversely affected by seismic activity (Taylor & Blair 2011). However, recent surveys indicate that inanga are now spawning further downstream of historic records, with the total area of spawning similar to or greater than pre-earthquake records (Orchard & Hickford 2016). Trout spawning has also been recorded from the upper Ōpāwaho/Heathcote River. The most recent trout spawning survey revealed that most redds were found in the reach from Colombo Street Bridge upstream to Rose Street (Taylor & Blair 2012). Redd numbers have remained reasonably stable over time within this catchment (Taylor & Blair 2012).

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4.4.3 Estuary Water Quality Pollutants that contribute to poor water quality in the estuary are stormwater runoff, animal and bird wastes, contaminants from roads and car washing, and wastewater overflows (Ihutai Management Plan, 2013). Additional contaminants were discharged to the estuary following the Canterbury earthquakes but have decreased over time due to the repair and replacement of infrastructure. The estuary is classified as having Class Coastal Contact Recreation water and Class Coastal Aquatic Ecology under the Canterbury Regional Coastal Plan. The coastal marine area of the estuary is also classed as an Area of Significant Natural Values (S5.5.15) in the CRCP.

4.5 Cultural values The cultural values relating to the above catchments are set out in the cultural impact assessment (MKT, 2017) included as Appendix C. By way of summary, the following key values are highlighted:  Significance of freshwater to Ngāi Tūāhuriri/Ngāi Tahu for a range of reasons and in particular as a promotor of all life and a taonga to be cared for passed on to future generations.  There are a range of taonga species that rely on the Ōtākaro/Avon River and Ōpāwaho/Heathcote catchments, including: freshwater fish, waterfowl, riverine birds and taonga plant species.  Mahinga kai is of great significance to Ngāi Tahu as a link to the continuation and understanding of cultural heritage. A wide range of mahinga kai has historically been evident in the Avon/Heathcote catchments, including freshwater fish species (tuna/eel, whitebait, trout, lamprey, crayfish, mussel and flounder), birds and plants such as fernroot and root of the cabbage tree.  The Ōtākaro/Avon River was an important travel route and mahinga kai for ancestors, including two sites that are registered Wāhi Tapu – Puari and Tautahi.  The Ōpāwaho/Heathcote River was also an important travel route and source of mahinga kai, in particular through providing link to Te Waihora/Lake Ellesmere.  The Ihutai/Avon/Heathcote Estuary was part of a larger fishery used by Ngāi Tahu due to the abundance and variety of fish and shellfish, and there were several settlements located near the estuary. It is noted that due to the state of water quality in the catchments set out in Section 4.4 above, the cultural values are also currently degraded.

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5.0 Resource consent requirements

5.1 RMA Section 127 Section 127 of the RMA allows for the holder of a resource consent to apply for changes of conditions: (1) The holder of a resource consent may apply to a consent authority for a change or cancellation of a condition of the consent, subject to the following: (a) the holder of a subdivision consent must apply under this section for a change or cancellation of the consent before the deposit of the survey plan (and must apply under section 221 for a variation or cancellation of a consent notice after the deposit of the survey plan); and (b) no holder of any consent may apply for a change or cancellation of a condition on the duration of the consent. (2) [Repealed] (3) Sections 88 to 121 (sections relating to resource consent applications) apply, with all necessary modifications, as if— (a) the application were an application for a resource consent for a discretionary activity; and (b) the references to a resource consent and to the activity were references only to the change or cancellation of a condition and the effects of the change or cancellation respectively. (3A) If the resource consent is a coastal permit authorising aquaculture activities to be undertaken in the coastal marine area, no aquaculture decision is required in respect of the application if the application is for a change or cancellation of a condition of the consent and does not relate to a condition that has been specified under section 186H(3) of the Fisheries Act 1996 as a condition that may not be changed or cancelled until the chief executive of the Ministry of Fisheries makes a further aquaculture decision. (4) For the purposes of determining who is adversely affected by the change or cancellation, the consent authority must consider, in particular, every person who— (a) made a submission on the original application; and (b) may be affected by the change or cancellation. Section 127 requires the application to be considered as a discretionary activity. Case law has established that Section 127 may be used for the purpose of changing conditions provided that the application is not for a materially different activity (i.e. increase in scope). The question of whether an activity is materially different is one of fact and degree to be determined in the circumstances of the case. In this case a change in conditions is considered appropriate as:  Changes are to provide clarity to the compliance calculations set out in the conditions that have previously been agreed by ECan;  Additional sites that may overflow are proposed to be included but all have frequencies lower than the set conditions or have plans in place to ensure compliance can be met;  All additional discharge sites are within the Ōtākaro/Avon River , Ōpāwaho/Heathcote River catchments or the Ihutai/Avon-Heathcote Estuary;  The same level of monitoring of wastewater discharges sites will be provided; and  All remaining conditions of the existing consent have or will continue to be met.

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5.2 Previous submitters As set out above, Section 127(4) requires consideration of every person who made a submission on the original application. The original application was publically notified and received 60 submissions, of which 58 were opposed. Submissions were made by:  A range of interest groups (Avon Loop Planning Association, Avon-Heathcote Estuary Ihutai Trust, Christchurch Estuary Association, Royal Forest and Bird, and Mahaanui Kurataiao Limited)  Canterbury District Health Board;  Neighbourhood and residents associations (Inner City West, Redcliffs, Mount Pleasant, Central Riccarton, Beckenham, Christchurch Combined);  Sports clubs (Pleasant Point Yacht Club, NZ Salmon Anglers Association); and  Concerned members of the public. Key issues raised by the submitters were the unacceptability and offensiveness of discharging untreated wastewater into Christchurch’s rivers, the perceived health risk and concerns in relation to the consent duration. As the assessment of effects on the environment set out in Section 7.0, the effects of the proposed change in conditions is expected to be negligible and therefore there are not expected to be effects on parties that submitted on the original application.

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6.0 Consultation

6.1 Environment Canterbury CCC has been involved in ongoing discussions relating to compliance with the existing resource consent. A summary of these discussions is included in Appendix A.

6.2 Tangata Whenua CCC has engaged with Ngāi Tūahuriri Rūnanga regarding wastewater overflows. Te Ngāi Tūāhuriri Rūnanga have mana whenua over the Avon and Heathcote catchments. A Cultural Impact Assessment (CIA) of the discharges from the wastewater network has been prepared by Mahaanui Kurataio Limited and endorsed by Te Ngāi Tūāhuriri.

The CIA is in Appendix C of this report and relates to the CCC wastewater network, including sites outside the existing consent scope which are not relevant to this consent application. Further engagement with Ngāi Tūahuriri Rūnanga in relation to wastewater management as set out in the mitigation measures of the CIA will be continued through the Compliance and Monitoring Liaison Group meetings, Te Hononga and further hui with Ngāi Tūahuriri Rūnanga as appropriate.

6.3 Compliance and Monitoring Liaison Group Annual meetings of the Compliance and Monitoring Liaison Group are held in accordance with the following groups as set out in Condition 11 of the existing consent: CCC, ECan, Te Rūnanga o Ngāi Tahu, the Ihutai/Avon-Heathcote Estuary Ihutai Trust, Beckenham Neighbourhood Association, the Christchurch Estuary Association, the Combined Christchurch Residents Association and Community and Public Health. The Compliance and Monitoring Liaison Group has met regularly in the recent years post- earthquakes. These meetings have been poorly attended with usually less than 5 members of the nominated Community Liaison Group attending however those attending expressed their appreciation for the progress made in the rebuild efforts and in the effort to keep the group informed of progress on the consent for wet weather overflows. Additional presentations have been made to well attended wider public meetings on 3 August 2016 and on 30 November 2016 on the development of wastewater model post rebuild and the optimisation of measures that are required to continue to reduce wet weather overflows. At the first of these meetings the presentation also covered the results of the online survey that drew out people’s views on their key values for waterways in Christchurch.

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7.0 Assessment of Effects on the Environment

7.1 Introduction Section 104 of the RMA requires the consent authority, when making a decision on a resource consent application, to have regard to the actual and potential effects on the environment of allowing an activity. Under Section 127 of the RMA the consideration of the effects is limited to the effects of the change in condition. The environmental effects of the proposed changes are assessed in this section of the report.

7.2 Effects on human health The effects on human health of the wastewater overflow points have been described and discussed through the previous resource consent applications and hearing processes. As a summary, the public health risks associated with wet weather overflows in the Avon and Heathcote catchments relate to direct recreational contact public have with the surface water bodies. This contact is through direct immersion in water leading to the ingestion of water, accidental immersion in water, for example falling out of a kayak, and no direct immersion but exposure through walking in the area or potential pathogen transfer from dogs that have been immersed in water. Potential health risks associated with wet weather wastewater overflows must be considered within the context of the probability of people being exposed to wastewater contaminants and also the general water quality of the receiving environment. Water quality monitoring summarised in Section 4.4 above indicates that there is a relatively high level of faecal coliforms within the existing catchment which means that the baseline level of public health risk associated with waterway contact is relatively high. The impact of this is that the use of the waterways in the Avon and Heathcote catchments are already considered unsuitable for recreational water contact. Wet weather overflows are also expected to occur for short periods of time, generally for a maximum of a couple of days as a result of a large storm, and the probability that anyone would be swimming in the river or estuary at that time is very low. Even where the worst case scenario is considered through using the highest individual infection risk from the worst overflow point, the highest overflow frequency, and the probability that someone is swimming during the an overflow event, the potential infection risk for the community (of gastroenteritis) would be significantly lower than the background level of health risk to the community from everyday life. Given the remote probability of the current wastewater overflows causing illnesses such as gastrointestinal infections in the wider community it is considered unlikely that additional sites to be included in Schedule 1 will alter the potential risks on human health. However, it is noted that there are human health risks in relation to the use of the Avon and Heathcote waterways due to poor water quality from the full range of contributing factors. Assisting in the public awareness of the risks in relation to wet weather wastewater overflows is the provision of signage during overflow events to lower the likelihood of people or pets coming into contact with wastewater contaminants. Use of signage and public education of the risks will continue. Overall, due to the reasons above the potential effects on human health resulting from the change in consent conditions are expected to continue to be less than minor.

7.3 Effects on freshwater quality Wastewater overflows have the potential to affect water quality in the receiving environment. As CCC is seeking to alter their existing discharge permit, the change in effect is a primary consideration. However, the existing water quality in the Ōpāwaho/Heathcote River and Ōtākaro/Avon River currently receive discharges from the additional sites to be consented under this application, and consequently, it is difficult to assess the change in effect. Consequently, the overall effects of the proposed change have been assessed to support the application.

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The event based and annual loading of wastewater discharges and stormwater discharges were compared to assess the effects on the receiving environment. This approach provides an indication of the overall contribution that wastewater discharges make to the pollutant load in the Heathcote and Ōtākaro/Avon River. The assessment used a combination of water quality monitoring data, stormwater contaminant load estimates and wastewater loads were extracted from long term simulation modelling of the network. Event based loading was based on wet weather events, as this is when wastewater discharges occur. 7.3.1 Event based loading 7.3.1.1 Methodology This assessment was undertaken to estimate the contribution of wastewater overflows to water quality in the receiving environment during wet weather events. This approach was adopted, as wastewater overflows are most likely to occur during wet weather events. The assessment considered a single ‘typical’ wet weather event from March 2014. Contaminant loads in the receiving environment were estimated by combining flow rate and contaminant concentrations. River flow rates were obtained from two continuous flow monitoring stations at Gloucester Street (Ōtākaro/Avon River) and Buxton Terrace (Ōpāwaho/Heathcote River). Contaminant concentrations were derived from CCC long term monthly water quality monitoring sites near the flow gauges at “AVON04” at Manchester Street and “HEATH04” at Bowenvale Avenue. The water quality data was filtered to only include wet weather events, when more than 5 mm of rain fell within 24 hours or 10 mm within 48 hours prior to the measurement. The median wet weather contaminant concentration was used to estimate the contaminant loads. Contaminant loads from overflows were estimated using the wastewater hydraulic model and medium strength values for raw wastewater contaminant concentrations (Metcalf and Eddy|AECOM, 2014). For the comparison between stormwater and wastewater contaminant loads, the event that gave the highest modelled contaminant concentration for wastewater discharges into the receiving environment (i.e. worst case) was used. The assessment includes all nearby outfalls, but not discharge from upstream areas. This approach was adopted as the effects of dilution and time delay of upstream discharges would be overly complex to assess, and moreover, it is unlikely that the peak of upstream contribution would coincide with the peak contributions from the nearby discharges. 7.3.1.2 Contaminants Three contaminants were chosen for comparison: biochemical oxygen demand (BOD), faecal coliforms, and total suspended solids (TSS). BOD was chosen as an indicator as it occurs in comparatively high concentrations in wastewater, and would therefore be more likely to be elevated compared to stormwater. Median wet weather water quality data shows the maximum median concentration found at any site within the catchments was 4 mg/L, whereas the modelled input concentration for wastewater was 199 mg/L. Faecal coliforms were selected as they are an indicator for the contribution of wastewater microbial contamination. TSS was selected for assessment as it is a visible contaminant and community consultation suggested it is seen as important indicator of waterway health.

7.3.1.3 Results For both of the flow monitoring sites, the wastewater contaminant loads (in terms of kg/s) are consistently and considerably lower than the stormwater contribution (as shown in Figure 1 to Figure 6). As there is some uncertainty in modelling faecal coliforms, an “upper range” scenario was considered to ensure that the contribution of wastewater was not underestimated. The upper range scenario includes faecal coliform loads that are 100 times greater than the modelled load. This limit had a small effect on the contribution of wastewater in comparison to stormwater concentrations (Figure 3 and Figure 4).

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Figure 1 BOD event based loading comparisons for Ōtākaro/Avon River at Gloucester Street

Figure 2 BOD event based loading comparisons for Ōpāwaho/Heathcote River at Buxton Terrace

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Figure 3 Faecal coliforms event based loading comparisons for Ōtākaro/Avon River at Gloucester Street

Figure 4 Faecal coliforms event based loading comparisons for Ōpāwaho/Heathcote River at Buxton Terrace

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Figure 5 TSS event based loading comparisons for Ōtākaro/Avon River at Gloucester Street

Figure 6 TSS event based loading comparisons for Ōpāwaho/Heathcote River at Buxton Terrace

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7.3.2 Annual contaminant loading 7.3.2.1 Method The annual contaminant loads were estimated at 23 wastewater overflow locations on the Ōtākaro/Avon River and 24 wastewater overflow locations on the Ōpāwaho/Heathcote River. Annual stormwater contaminant loads were estimated for each catchment based on land use within the catchment. Runoff contaminant loads were estimated for residential, industrial, commercial, rural, and open space land uses based on information from literature reviews (Duncan, 1999). The areas of each land use were estimated using CCC land use GIS information. The annual stormwater loadings were then estimated by combining the areas and annual loads for each land use. The wastewater contribution was calculated using the average annual mass loads from the long term simulation. 7.3.2.2 Contaminants BOD was used for the comparison, as relatively high concentrations are found in wastewater, and would therefore be more likely to be elevated compared to stormwater. TSS was selected for assessment as it is a visible contaminant and community consultation suggested it is seen as important indicator of waterway health. 7.3.2.3 Results For most of the overflow locations within the two catchments, stormwater contribution, based on annual load, is considerably higher than wastewater. In all except one location, wastewater makes up less than 10% of the annual contaminant load for BOD and TSS, and at 75% of sites, the wastewater load is less than 2% of the annual load. At one location (Halswell Road on the Ōpāwaho/Heathcote River), the stormwater catchment is very small and the annual wastewater contribution is above average. This results in the only instance where wastewater makes a greater contribution to the BOD contaminant load than stormwater. Figure 7 shows the results of the assessment, indicating maximum, minimum and quartile ranges for wastewater contribution (note that a log scale is used for the percentage contribution of wastewater).

Figure 7 Wastewater loadings as a percentage of stormwater loading contribution

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7.3.3 Summary of effects on water quality While it is difficult to assess the incremental change in effects from the overflow sites being added to the discharge consent, the overall effects of the discharges on the receiving environment have been assessed. The effect of the wastewater discharges on water quality was assessed by considering the relative contribution of wastewater discharges and stormwater runoff to the receiving environment. This assessment of event based and annual load contributions suggests that the current wastewater discharges (which includes those that are to be included in the discharge consent) make a less than minor contribution to water quality in the Ōtākaro/Avon River and Ōpāwaho/Heathcote River during wet weather events and make a minor contribution to annual contaminant loads in the rivers.

7.4 Effects on ecology In turn the impacts on ecology as a result of the additional sites are expected to be negligible due to:  The dominance of pollution-tolerant macroinvertebrate species present, and overall “moderately tolerant” sensitivity of the biological community.  The lack of any ecological effects detected in earlier targeted wastewater overflow surveys (McMurtrie & Burden 2006; Suren et al. 2008; Suren & Brown 2009).  The lack of any long-term ecological effects following post-earthquake wastewater discharges, despite the discharge of very large volumes of raw wastewater and lack of dilution by flood flows.  Rapid dilution of the wastewater by river water and stormwater runoff.  The infrequent nature of the discharges. Therefore the overall effects on freshwater quality and ecology of the proposed change in conditions will be less than minor, particularly when continued efforts will be made to improve the wastewater system.

7.5 Effects on amenity and recreational values The potential effects of wastewater discharges on amenity and recreation values are to lower the amenity value, and limit recreational uses of the river and riparian parks. As overflows occur predominantly during extreme weather events the impacts on recreational uses are generally avoided as people are less likely to be out doing water sports or making use of walking tracks along waterways during such inclement weather. Floatable or solid materials in wastewater discharges are generally trapped in manholes within the system and not released during wet weather overflows. Although there is potential for material to be discharged to waterways during overflow events, discharges sites are generally located below the water level during rainfall events ensuring that any solids in the overflows are released directly into the water flow. The waterways are also generally flowing much faster and carrying a higher volume of suspended material during overflow events, limiting the potential amenity impact of the wastewater discharges. Given the above the factors the potential adverse effects of the change in conditions on amenity and recreational values are expected to be less than minor.

7.6 Effects on cultural values The following provides a summary of the cultural impacts identified in the CIA in Appendix C that are relevant to the changes to the conditions proposed. The CIA was prepared to provide an assessment of an application as CCC prepared an application for a new resource consent if they were unable to comply with the existing resource consent. This section 127 application will allow the CCC to comply with the existing resource consent. However, the CIA still provides some useful discussion of the effects of the current wastewater overflows on cultural values of concern to Ngāi Tūāhuriri Rūnanga.

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The impacts of the wastewater discharges on cultural values as outlined in the CIA relate to:  The tikanga of not putting human waste into areas (waterways in this instance) that are used for the gathering of food or where it could come into contact with a Wāhi Tapu, which means the discharges are considered to constitute desecration in cultural terms.  The effects of degrading water which is a taonga central to all Māori life.  The resulting impacts on taonga species and mahinga kai through limiting the habitat available and not enabling the recovery of ecosystems to provide for native flora and fauna. It is acknowledged that the existing resource consent currently provides for wastewater discharges to surface waterways that are in any form unacceptable to tangata whenua. Ultimately the frequency of the overflow events and the volume discharged will continue to be reduced through engineered improvements to the wastewater system, providing for the continued improvement required by Ngāi Tūāhuriri. The effects of the change in resource consent conditions on the above impacts are of a small scale given the existing degradation of the values and the limited contribution of wet weather wastewater overflows to the current situation. Ensuring that tangata whenua have input to the location of the monitoring system through their membership in the Compliance and Monitoring Liaison Group, this ensures that any effects on particular sites that may be of specific cultural significance can be appropriately monitored and followed up if necessary. Potential effects on human health ae addressed in Section 7.2 above and detail that the risks to human health are low. In relation to the potential effects on mahinga kai, although historically used as mahinga kai the waterways and estuary are not currently used for mahinga kai due to the degradation of the environment. Impacts on human health through harvesting mahinga kai are therefore not expected and although the continued discharges will not improve the situation, the effects of the change in conditions on mahinga kai are limited. As the effects of the consent condition changes on freshwater quality, ecology and human health are considered to be minimal given the current situation and compliance with the majority of the consent conditions, the scale of the change in effects on cultural values are limited and expected to be no more than minor.

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8.0 Statutory Assessment

8.1 National Policy Statements The National Policy Statement for Freshwater Management 2014 (NPS: Freshwater) sets out the objectives and policies for freshwater management under the RMA. Objectives A1 and A2 are of relevance to that activity as it has the potential to effect freshwater quality. These objectives give Regional Councils the responsibility of ensuring that freshwater objectives and limits are met through the implementation of regional plans including the Land and Water Regional Plan (LWRP). On this basis the proposed activity will not impact on the consent authority’s ability to set and meet environmental limits and is therefore consistent with the NPS Freshwater.

8.2 Canterbury Regional Policy Statement The Canterbury Regional Policy Statement (CRPS) gives an overview of the significant resource management issues facing the region. The purpose of the CRPS is to set out objectives, policies and methods to resolve those resource management issues and to achieve the integrated management of the natural and physical resources of Canterbury. Chapter 7 - Freshwater  Objective 7.2.1 – Sustainable management of fresh water  Objective 7.2.3 – Protection of intrinsic value of waterbodies and their riparian margins  Policy 7.3.6 – Fresh water quality Water quality in the Avon and Heathcote catchments is currently degraded; however the effects of wet weather overflow wastewater discharges are limited to due to the dilution provided and the temporary nature of the discharges. Due to the limits included in the consent conditions the quality and amenity of the waterways will be maintained and then improved over the remaining duration of the consent. The change in conditions proposed is not expected to result in further degradation of water quality and as such is consistent with the objectives and policies in Chapter 7 of the CRPS.

8.3 Canterbury Land and Water Regional Plan The LWRP identifies the resource management outcomes and goals for managing land and water resources in Canterbury to achieve the purposes of the RMA. The following objectives and policies are considered relevant to this proposal. Objectives  3.6 Water is recognised as essential to life and is represented for its intrinsic values  3.8 The quality and quantity of water in fresh water bodies and their catchments is managed to safeguard the life-supporting capacity of ecosystems and ecosystem processes, including ensuring flow and quality of water to support the habitat and feeding, breeding, migratory and other behavioural requirements of indigenous species, nesting birds and, where appropriate, trout and salmon.  3.11 Water is recognised as an enabler of the economic and social wellbeing of the region.  3.19 Natural character values of freshwater bodies, including braided rivers and their margins, wetlands, hāpua and coastal lagoons, are protected.

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Policies  Policy 4.5 Water is managed through the setting of limits to safeguard the life-supporting capacity of ecosystems, support customary uses, and provide for community drinking-water supplies and stock water, as a first priority and to meet the needs of people and communities for water for irrigation, hydro-electricity generation and other economic activities and to maintain river flows and lake levels needed for recreational activities, as a second priority.  Policy 4.7 Resource consents for new or existing activities will not be granted if the granting would cause a water quality or quantity limit set in Sections 6 to 15 to be breached or further over allocation (water quality and/or water quantity) to occur or in the absence of any water quality standards in Sections 6 to 15, the limits set in Schedule 8 to be breached.  Policy 4.12 There are no direct discharges to surface water bodies or groundwater of: (a) untreated sewage, wastewater (except as a result of extreme weather related overflows or system failures) or bio-solids; …  Policy 4.14B Have regard to Ngāi Tahu values, and in particular those expressed within an iwi management plan, when considering applications for discharges which may adversely affect statutory acknowledgement areas, nohoanga sites, surface waterbodies, silent file areas, culturally significant sites, Heritage New Zealand sites, any listed archaeological sites, and cultural landscapes, identified in this Plan, any relevant district plan, or in any iwi management plan. As set out in Section 7.0 the potential adverse effects on water quality resulting from the change in conditions will be minimal and is not expected to cause further breaches in water quality limits. Any discharges will be the result of weather events as provided for under Policy 4.12(a) and regard has been given to Ngāi Tahu through the development of the CIA and their membership on the Compliance and Monitoring Liaison Group. CCC recognise that water is essential to life and have therefore committed to ongoing upgrades to the system to continue lowering the frequency and volume of wastewater discharges where the cost required is acceptable to Christchurch City ratepayers. Given the above, the change in consent conditions is considered consistent with the relevant objectives and policies of the LWRP.

8.4 Christchurch District Plan As noted previously in this application the discharges subject to this application are an existing activity. The CCC are continually upgrading and expanding the wastewater network and at times these works require resource consents under the Christchurch District Plan, as well as other resource consents from ECan. However, such applications will be dealt with on a project by project basis and do not form part of the present application.

8.5 Mahaanui Iwi Management Plan The Mahaanui Iwi Management Plan 2013 outlines the Ngai Tahu values and policies in regard to natural resource management within the Canterbury Region. The following policies are relevant to the wastewater overflow discharges:  Policy WM2.2 - To require that water is recognised as essential to all life and is respected for its taonga value ahead of all other values.  Policy WM6.1 - To require that the improvement of water quality in the takiwā is recognised as a matter of regional and immediate importance.  Policy WM6.8 - To continue to oppose the discharge of contaminants to water, and to land where contaminants may enter water.  Policy WM6.9 - To require that local authorities work to eliminate existing discharges of contaminants to waterways, wetlands and springs in the takiwā, including treated sewage, stormwater and industrial waste, as a matter of priority.

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 Policy P6.3 - Stormwater should not enter the wastewater reticulation system in existing urban environments.  Policy P7.4 - To continue to oppose the use of waterways and ocean as a receiving environment for waste. These policies all relate to avoiding and opposing the discharge of wastewater to waterways and recognising the value of water quality. The effects on cultural values of the change in conditions are set out in Section 7.6 and confirm that the change is not expected to cause further degradation that could further impact cultural values. However, the policies oppose the release of wastewater to freshwater bodies, and therefore the change is not consistent with the relevant provisions of the Mahaanui Iwi Management Plan.

8.6 Te Te Rūnanga o Ngāi Tahu Freshwater Policy Statement The Te Rūnanga o Ngāi Tahu Freshwater Policy Statement (NTFPS) was produced by Te Rūnanga o Ngāi Tahu to describe their association with freshwater resources, the ways they want to participate in freshwater management and the environmental outcomes sought through their participation. The policy statement sets out the unique role water plays in Maori life and provides principles upon which freshwater should be managed. The principles are similar to those set out the cultural values section above and the assessment of the Mahaanui Iwi Management Plan above. While the continued discharge of wastewater to the Avon and Heathcote catchment waterways are against the policies of the NTFPS, the amendments to the existing consent conditions are not expected to result in further degradation of the cultural values the policy document seeks to protect.

8.7 Part 2 Assessment The purpose of the RMA, as stated in Section 5 of the Act, is to promote the sustainable management of natural and physical resources. The purpose is support by the principles contained in Sections 6-8 of the Act. Section 5: Purpose Sustainable management is defined as in Section 5(2) a follows: …means managing the use, development, and protection of natural and physical resources in a way, or at a rate, which enables people and communities to provide for their social, economic, and cultural wellbeing and for their health and safety while— (a) sustaining the potential of natural and physical resources (excluding minerals) to meet the reasonably foreseeable needs of future generations; and (b) safeguarding the life-supporting capacity of air, water, soil, and ecosystems; and (c) avoiding, remedying, or mitigating any adverse effects of activities on the environment. The ongoing provision of a functioning and affordable wastewater network to services homes and businesses across Christchurch City enables the community continue to provide for their social, economic and cultural wellbeing. Changing the resource consent conditions and allowing low frequency and short term wastewater overflows from the system to the Avon and Heathcote catchments is considered an appropriate balance between the economic considerations of continued upgrades to the CCC network and the potential environmental effects. Particularly as the monitoring completed indicates the potential adverse effects of the discharges are less than minor. On this basis, the change in resource consent conditions is consistent with Section 5 of the RMA. Section 6: Matters of National Importance Section 6 contains the following matters of national importance of relevant to the proposal: a. the preservation of the natural character of the coastal environment (including the coastal marine area), wetlands, and lakes and rivers and their margins, and the protection of them from inappropriate subdivision, use, and development: b. the relationship of Maori and their culture and traditions with their ancestral lands, water, sites, waahi tapu, and other taonga:

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The above matters have been assessed throughout AEE. Section 7: Other Matters Section 7 of the RMA outlines other matters which are considered relevant to this application: (a) kaitiakitanga: (aa) the ethic of stewardship: (c) the maintenance and enhancement of amenity values: (d) intrinsic values of ecosystems: […] (f) maintenance and enhancement of the quality of the environment: (g) any finite characteristics of natural and physical resources: As discussed in Section 7 of this AEE, the impact of the proposed additional overflow locations is expected to be less than minor in the context of the existing environment. Therefore the above characteristics of the environment will not be compromised. Section 8: Treaty of Waitangi Section 8 requires the principles of the Treaty of Waitangi to be taken into account when managing the use, development, and protection of natural and physical resources. These principles have been taken into account by engaging with Ngāi Tūahuriri Rūnanga through representation on the Compliance Monitoring Liaison Group, and ongoing consultation.

8.8 Section 105 Section 105 of the RMA applies to certain applications. It requires consent authorities to have regard to the nature of the discharge, sensitivity of the receiving environment to adverse effects, the applicant’s reasons for the choice and any possible alternative methods of discharge. The discharge qualities have been addressed through the previous consent processes and the sensitivity of the environment has been described throughout this report. Alternative methods of discharge have not specifically been addressed; however different combinations of wastewater network upgrades have been considered through the city-wide wastewater optimisation project.

8.9 Section 107 Section 107 states that a consent authority shall not grant a discharge permit to discharge a contaminant or water into water if, after reasonable mixing, the contaminant or water discharged (either by itself or in combination with the same, similar, or other contaminants or water), is likely to give rise to particular effects in the receiving waters. The effects are the following: (c) the production of any conspicuous oil or grease films, scums or foams, or floatable or suspended materials: (d) any conspicuous change in the colour or visual clarity: (e) any emission of objectionable odour: (f) the rendering of fresh water unsuitable for consumption by farm animals: (g) any significant adverse effects on aquatic life. Due to the timing of wet weather wastewater overflows during high rainfall events, any discharges are into waterways with high levels and flow rates. Therefore any wastewater discharged is generally quickly mixed and diluted to avoid all of the above effects.

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9.0 Notification The AEE contained in Section 7.0 of this report has concluded that the that the effects on the environment of the proposed changes to CRC092692 are no more than minor and as such, the nature of this application does not warrant public or limited notification.

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10.0 References Boffa Miskell Limited (2014). Ecological Values of the Avon River Catchment: An ecological survey of the Avon SMP catchment. Report prepared by Boffa Miskell Limited for Christchurch City Council, May 2014. Boffa Miskell Limited (2015). Aquatic ecology of sites within the Heathcote, Estuary and Coastal, and Avon SMP catchments: informing the comprehensive discharge consent. Report prepared by Boffa Miskell Limited for Christchurch City Council, August 2015. Duncan, H.P., 1999. Urban Stormwater Quality: A statistical overview. Cooperative Research Centre for Catchment Hydrology. Goodman, J. M., Dunn, N. R., Ravenscroft, P. J., Allibone, R. M., Boubee, J. A. T., David, B. O., Griffiths, M., Ling, N., Hitchmough, R. A., and Rolfe, J. R. (2014). Conservation status of New Zealand freshwater fish, 2013. New Zealand Threat Classification Series 7, Department of Conservation. Grainger, N., Collier, K., Hitchmough, R., Harding, J., Smith, B., and Sutherland, D. (2014). Conservation status of New Zealand freshwater invertebrates, 2013. New Zealand Threat Classification Series 8, Department of Conservation, Wellington. McMurtrie, S., and Burdon, F. (2006). Ecological effects of sewage overflow events on the Ōpāwaho/Heathcote River. Report prepared by EOS Ecology for Christchurch City Council, September 2006. McMurtrie, S., and James, A. (2013). Cashmere Stream: reducing the pressures to improve the state. Report prepared by EOS Ecology for Environment Canterbury, March 2013. Mahaanui Kurataiao Ltd (2017). Cultural Impact Assessment: Wet weather waste-water overflow consent application – Ōtakaro me Ōpawaho ki Ihutai rātau ko Puharakekenui ki Te Riu o te Aika Kawa). Report prepared for Christchurch City Council, February 2017. Metcalf and Eddy|AECOM. (2014). Wastewater Engineering: Treatment and Reuse (5th ed.). Boston: McGraw-Hill. Orchard, S., and Hickford, M. (2016). Spatial effects of the Canterbury earthquakes on inanga spawning habitat and implications for waterways management. Waterways Centre for Freshwater Management and University of Canterbury Marine Ecology Research Group Report 2016-002, prepared for the IPENZ Rivers Group and Ngāi Tahu Research Centre, February 2016. Suren, A., Bonnett, M., Wech, J., and Sykes, J. (2008). The ecological effects of wastewater overflow discharges in waterways of the Avon River/Otakaro catchment. NIWA Client Report CHC2008-168, Prepared for URS New Zealand Ltd and the Christchurch City Council, December2008. Suren, A., and Brown, S. (2009). Responses to S92 request for further information – CRC092692. NIWA Client Report CHC2009-129, prepared for URS New Zealand Ltd, September 2009. Suren, A., and Brown, S. (2009). Responses to S92 request for further information – CRC092692. NIWA Client Report CHC2009-129, prepared for URS New Zealand Ltd, September 2009. Taylor, M., and Blair, W. (2011). Effects of seismic activity on inaka spawning grounds on city rivers. Environment Canterbury Report U11/12, June 2011. Taylor, M., and Blair, W. (2012). Halswell and Heathcote aquatic values; selected aspects; monitoring round # 4. Report prepared by Aquatic Ecology Ltd for Christchurch City Council, September 2012. Taylor, M., Burdon, F., and Blair, W. (2012). An update on trout spawning in the Avon River, and notes on the effects of seismic activity on physical habitat. Environment Canterbury Report U12/3, February 2012.

Appendix A

Existing resource consent CRC092692 and compliance strategy

The Canterbury Regional Council (known as Environment Canterbury)

GRANTS TO: Christchurch City Council

A DISCHARGE PERMIT: To discharge water and contaminants to water form overflow points in the Christchurch wastewater network as a result of wet weather events

COMMENCEMENT DATE: 04 Mar 2014

EXPIRY DATE: 04 Mar 2029

LOCATION: Various, AVON & HEATHCOTE CATCHMENTS, CHRISTCHURCH

SUBJECT TO THE FOLLOWING CONDITIONS:

GENERAL

1 The contaminants discharged shall only be stormwater, groundwater and wastewater from the Christchurch City Council wastewater network.

2 The discharges shall only occur as a result of wet weather events overloading the wastewater network.

3 The discharges shall only occur at the overflow locations identified in Schedule 1 of this consent.

4 For the purposes of this consent, an “overflow event” at each location may consist of one or more discharges and shall only be deemed to have commenced when there has been no prior discharge at that location for a period of 24 hours.

Frequency of Overflow Events

5 a. The annual overflow event frequency, as calculated in accordance with Condition (7), shall be as follows:

i. The total annual overflow event frequency calculated across the 10 overflow sites in the Avon River catchment, as identified in Schedule 1, shall be no more than 8.4 at the commencement of this consent, improving to: no more than 7 by 2015, no more than 4.9 by 2020, and no more than 4.77 by 2025;

ii. The total annual overflow event frequency calculated across the 10 overflow sites in the Heathcote River catchment, as identified in Schedule 1, shall be no more than 14.2 at the commencement of this consent, improving to: no more than 8 by 2015, no more than 4.7 by 2020, and no more than 4.63 by 2025; Page 2 CRC092692

iii. The total annual overflow event frequency calculated across the 2 overflow sites in the Avon-Heathcote Estuary, as identified in Schedule 1, shall be no more than 0.86 at the commencement of this consent, no more than 0.87 by 2015, no more than 0.88 by 2020, and no more than 0.92 by 2025.

b. Each individual site in Schedule 1 shall achieve an annual overflow event frequency of no more than two by the date specified in Schedule 1.

Volume of Overflows

6 The total volume of wastewater overflowing into each of the Avon and Heathcote rivers and Avon-Heathcote Estuary, as calculated in accordance with Condition (7), shall reduce by the same proportion as the reduction in frequency of discharge under Condition 5, between the commencement of the consent and 2025.

Use of Computer Model to Determine Average Recurrence Interval Compliance

7 For the purposes of determining compliance with Condition (5) and Condition (6), the overflow frequency shall be calculated using a field-calibrated computer model which predicts the annual average number of overflow events and total overflow volumes into the Avon and Heathcote Rivers and the Avon-Heathcote Estuary. The model shall use a long- term time series methodology to assess current system performance against actual rainfall records. The period of actual rainfall to be analysed shall be of 25 years duration and the period end shall be less than three years from the date of the analysis being undertaken.

Monitoring

8 Within 3 months of the date of commencement of this consent, automatic monitoring and alarm systems shall be provided and thereafter maintained operational at each overflow location which the field calibrated computer model identifies as overflowing more than once in every three years.

9 At each monitored overflow location the following shall be monitored:

a. Start date and time of overflow event

b. End date and time of overflow event

c. Peak flow rate during overflow event

d. Total volume discharged during overflow event.

10 Water quality sampling shall be undertaken as follows: a. Location – Multiple Discharges. Where multiple overflow discharges occur simultaneously within any 2.5km stretch of river or estuary, samples shall be obtained:

i. Within 200 metres downstream of the point of the most downstream discharge, as far as practicable at a commonly used access point to the river or estuary; and

ii. Within 100 metres upstream of the point of the most upstream discharge. Page 3 CRC092692

b. Location – single Discharges. Where (9)(a) does not apply, samples shall be obtained, with respect to each overflow location:

i. Within 200 metres downstream of the point of discharge, as far as practicable at a commonly used access point to the river or estuary; and

ii. Within 100 metres upstream of the point of discharge, and

iii. Where the sampling is in accordance with Condition (10) (c) (i), directly in the discharge plume within 10 metres downstream of the point of discharge.

c. Parameters

i. Three overflow events subject to this consent shall be sampled for the following parameters: suspended solids, BOD, zinc, copper, lead, dissolved reactive phosphorous, ammonia, faecal coliforms, and E. coli. The events sampled shall be the first overflow event from PS15 (Alport), the first overflow event into the Avon River and the first overflow event into Dudley Creek, following the commencement of consent.

ii. Samples from all overflow events except those discharging into Dudley Creek shall thereafter be tested for E. coli.

iii. Samples from overflow events discharging into Dudley Creek shall thereafter be tested for E. coli and ammonia.

d. Timing and Frequency

i. Sampling shall occur within 10 hours of receiving notification from the automated alarm system that an overflow is occurring or as soon thereafter as daylight permits.

ii. Sampling is to be repeated once daily until the E. coli. concentration of the downstream samples is less than two times the E. coli. concentration of the upstream sample, then for one more day.

e. Sampling shall be undertaken by a person(s) trained to IANZ accredited or equivalent standards.

f. Missed Samples. Where for health and safety reasons any water samples cannot be obtained, or the timeframe does not meet Condition (10) (d) (i), these reasons shall be recorded.

g. Testing shall be carried out by an IANZ accredited laboratory.

Compliance and Monitoring Liaison Group

11 a. A Compliance and Monitoring Liaison Group shall be formed by the consent holder and meetings convened at least once annually. Page 4 CRC092692

b. The following organisations shall be invited to have up to two representatives on the Compliance and Monitoring Liaison Group: Christchurch City Council, Environment Canterbury, Te Runanga o Ngai Tahu, the Avon-Heathcote Estuary Ihutai Trust, Beckenham Neighbourhood Association, the Christchurch Estuary Association, the Combined Christchurch Residents Association and Community and Public Heath.

12 The Compliance and Monitoring Liaison Group shall at each meeting be updated by the consent holder on matters relating to the exercise of this consent, including but not limited to: a. Relevant capital and maintenance works completed in the past year and currently programmed by the consent holder;

b. Development and refinement of the computer model;

c. Any new technologies in wastewater overflow reduction or prevention measures; and

d. Compliance and monitoring results in accordance with Condition 16.

Compliance and Monitoring Reporting

13 Commencing in 2011, a report shall be submitted to Canterbury Regional Council, Attention: RMA Compliance and Enforcement Manager, by 31 August each year addressing the following matters:

a. A full record of overflow events for the year ending 30 June. At minimum this shall include the parameters required by Condition (9).

b. Any capital and maintenance works undertaken in the previous financial year to maintain compliance with Conditions (5) and (6).

c. The capital and maintenance works identified in the Annual Plan, Long Term Council Community Plan, and any other relevant statutory document, to ensure ongoing compliance with Conditions (5) and (6).

d. Water quality sampling results in accordance with Condition (10) including the locations from which samples were taken.

e. Minutes of the meeting(s) held by the Compliance and Monitoring Liaison Group under Condition (11).

14 By 31 August of the third full year from the date of commencement of this consent, and thereafter by 31 August every third year, a report shall be submitted to Canterbury Regional Council, Attention: RMA Compliance and Enforcement Manager, addressing the following matters:

a. The current modelled annual overflow event frequency at each overflow location. Page 5 CRC092692

b. An independent peer review report of the current modelled results, carried out at the consent holder’s cost, commenting on the confidence that may be had in the results, and recommendations for improving confidence if appropriate. Peer review to include consideration of the following:

i. Infrastructure data (pipes, manholes, weirs, and pump stations)

ii. Catchment delineation and connections

iii. Dry and wet weather flow parameters

iv. Rainfall records

v. Verification and error checking procedures and outcomes

vi. Known errors, omissions or inaccuracies

c. A comparison between the modelled annual overflow event frequencies and volumes and the recorded overflow event frequencies and volumes in the previous reporting period, including an explanation of any discrepancies.

d. The current modelled total volume of wastewater overflowing into each of the Avon and Heathcote rivers and the Avon-Heathcote Estuary.

15 By 31 August of the third full year from the date of commencement of this consent, and thereafter by 31 August every sixth year, a report shall be submitted to Canterbury Regional Council, Attention: RMA Compliance and Enforcement Manager, containing:

a. An assessment by a suitably qualified person(s) of the human health and ecological effects arising from any overflow events in the previous reporting period.

b. A Cultural Health Assessment, by a person(s) recommended by Te Runanga o Ngai Tahu, and commissioned by the consent holder, which assesses the effects of the overflows on tangata whenua values, including the state of the mahinga kai species and their habitat, and mauri.

16 Copies of the reports prepared under Conditions 13-15 shall be provided, at the same time as submission to Canterbury Regional Council, Attention: RMA Compliance and Enforcement Manager, to the members of the Compliance and Monitoring Liaison Group.

Response Plan

17 The Consent Holder shall maintain and comply with a current Sewer Overflow Response Plan setting out the procedures relating to an overflow event. The Response Plan shall include, but not be limited to, the following matters:

a. Notification of the Canterbury Medical Officer of Health within 1 hour of the receipt of information relating to an overflow event.

b. Identification of parties potentially affected by overflow events.

c. Methodology for sampling of overflow events in accordance with Condition (10). Page 6 CRC092692

d. Notification of any discharge to the potentially affected parties identified in condition (17)(b). The consent holder shall undertake all reasonable endeavours to notify potentially affected parties by fax or phone within 6 hours of the receipt of information relating to an overflow event, unless any party requests an alternative arrangement and this is agreed to by the consent holder.

e. Public health warning signs shall be erected at the following locations:

a. the overflow site

b. at a maximum of 200 metre intervals on both banks for at least 600 metres downstream of those locations for any sites that are or are known to have been discharging, ensuring that wherever practicable, signs are located at commonly used access points to the waterway.

These signs shall only be removed when water quality sampling has ceased in accordance with Condition (10)(d)(ii).

a. At least twice a day during an overflow discharge and on the day following an overflow, waterway banks shall be inspected for a minimum distance of 600 metres downstream of the overflow, and any objectionable material relating to the exercise of this consent shall be removed.

b. A copy of the most recent Sewer Overflow Response Plan shall be provided to Canterbury Regional Council, Attention: RMA Compliance and Enforcement Manager and the Canterbury Medical Officer of Health annually on 31 August.

Investigation into Screening

18 a. Within 18 months of the commencement of this consent, the consent holder shall undertake an investigation into the feasibility of screening each overflow site to reduce or prevent the discharge of floatable and suspended solids.

b. The results of the investigation shall be provided to Canterbury Regional Council, Attention: RMA Compliance and Enforcement Manager on completion and to the Compliance and Monitoring Liaison Group at their next meeting following completion.

Investigation of contamination of riparian areas

19 a. Within 18 months of the commencement of this consent, the consent holder shall complete an investigation into potential contamination of riparian areas as a result of overflow events and the health risk they may pose to riverbank users and residents.

Review of Consent Conditions

20 The Canterbury Regional Council may, once per year, on any of the last five working days of June or November, serve notice of its intention to review the conditions of this consent for the purposes of:

a. Dealing with any adverse effect on the environment which may arise from the exercise of the consent and which it is appropriate to deal with at a later stage; or

b. Requiring the adoption of the best practicable option to remove or reduce any adverse effect on the environment; or

c. Requiring screening at any overflow site; or

d. Addressing any discrepancy between modeled overflow frequency or volume and actual overflow frequency or volume.

Issued at Christchurch on 5 December 2014

Canterbury Regional Council

9 December 2016

Paul Hulse Environment Canterbury [email protected]

Dear Paul

Re: Wastewater Overflow Consent – Request to Vary Compliance Strategy Agreement

Due to earthquake damage to Christchurch’s wastewater network, Christchurch City Council (CCC) and Environment Canterbury (ECan) entered into a compliance strategy agreement for CCC’s wastewater overflow consent on 31 July 2012. One of the conditions of that non-enforcement agreement is that CCC must either comply with the conditions of the overflow consent by 17 March 2017 or submit a new consent by that date. 17 March 2017 was six months before the previous overflow consent CRC991222 expired, but this has now been replaced by CRC092692.

The preliminary results of wastewater modelling of the current wastewater network indicate that CCC is unlikely to be able to comply with the current overflow consent, therefore a new overflow consent will need to be sought.

A key input to the consent application are the cultural impact assessments for Christchurch, Lyttelton Harbour and Akaroa Harbour. However, Mahaanui Kurataiao Ltd has advised that these will not be prepared until 28 February 2017.

We wish to submit a robust overflow consent application that fully takes account of the cultural impact assessments and considers all environmental effects, including cultural effects. We also wish to have meaningful engagement with the runanga about wastewater overflows once the cultural impact assessments have been prepared about how the effects of wastewater overflows can be avoided, remedied or mitigated. This will not be possible if the original application date of 17 March 2017 is retained. We therefore respectfully request that the non-enforcement is varied by mutual agreement, so that the submission date is delayed by six months to 17 September 2017.

Yours sincerely

Bridget O’Brien Team Leader Asset Planning – Water & Wastewater Christchurch City Council

Encl: Compliance Strategy Agreement for Wet Weather Wastewater Overflows to Rivers

Civic Offices, 53 Hereford Street, Christchurch, 8011 PO Box 73010, Christchurch, 8154 Phone: 03 941 6438 TRIM Reference: 16/1419332 Email: [email protected] www.ccc.govt.nz From: Lawrence, Helen Sent: Tuesday, 10 January 2017 9:39 a.m. To: Lawrence, Helen Subject: FW: Request to vary compliance strategy agreement for overflow consent

Importance: High

. Fr om: Paul Hulse [mailto:[email protected]] Sent: Monday, 12 December 2016 12:15 p.m. To: [email protected] Cc: Bourke, Mike; Bennett, Justine; [email protected]; Catherine Challies; Joe Harrison; Bill Bayfield Subject: FW: Request to vary compliance strategy agreement for overflow consent

Good afternoon Bridget,

Thanks for your e-mail.

Environment Canterbury agree to vary the compliance strategy agreement for the Wastewater Overflow Consent, specifically to allow for a later application date (from 17 March 2017) of 17 September 2017.

We note that the reason for the delay is due to the CCC conducting cultural impact assessments for Christchurch, Lyttelton Harbour and Akaroa Harbour and subsequent engagement with Rūnanga.

Any questions please let me know.

Regards, Paul Hulse Zone Manager

From: O'Brien, Bridget [mailto:[email protected]] Sent: Friday, 9 December 2016 11:00 a.m. To: Paul Hulse Cc: Catherine Challies ; Joe Harrison ; Bourke, Mike ; Bennett, Justine ; Moore, John Subject: Request to vary compliance strategy agreement for overflow consent

Hi Paul

Please find attached our request to vary the compliance strategy agreement for the wastewater overflow consent, so that we can submit our consent application by 17 September 2017 rather than 17 March 2017 to take into account the cultural impact assessments.

Thanks Bridget

Bridget O'Brien Team Leader - Asset Planning - Water & Wastewater DDI: 03 941 6438 Mobile: 027 613 1574 Web: www.ccc.govt.nz Christchurch City Council Civic Offices, 53 Hereford Street, Christchurch PO Box 73014, Christchurch, 8154 Please consider the environment before printing this email

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Christchurch City Council http://www.ccc.govt.nz ********************************************************************** 21 June 2017

Stuart Edwards Environment Canterbury [email protected]

Dear Stuart

Re: Wastewater Overflow Consent CRC092692 – Compliance Strategy

As discussed in our meetings with you on 31 January and 6 March 2017, we have completed the wastewater network modelling required to assess compliance with Condition 5 of CRC092692.

Compliance with Condition 5a

(5) (a) The annual overflow event frequency, as calculated in accordance with Condition (7), shall be as follows:

(i) The total annual overflow event frequency calculated across the 10 overflow sites in the Avon River catchment, as identified in Schedule 1, shall be no more than 8.4 at the commencement of this consent, improving to: no more than 7 by 2015, no more than 4.9 by 2020 and no more than 4.77 by 2025;

(ii) The total annual overflow event frequency calculated across the 10 overflow sites in the Heathcote River catchment, as identified in Schedule 1, shall be no more than 14.2 at the commencement of this consent, improving to: no more than 8 by 2015, no more than 4.7 by 2020, and no more than 4.63 by 2035;

(iii) The total annual overflow event frequency calculated across the 2 overflow sites in the Avon-Heathcote Estuary, as identified in Schedule 1, shall be no more than 0.86 at the commencement of this consent, no more than 0.87 by 2015, no more than 0.88 by 2020, and no more than 0.92 by 2025.

15 years of rainfall data between 1 January 2000 and 1 January 2015 were run through the 2016 post-SCIRT rebuild wastewater network overflow model. The average number of overflow events per year to each waterway was then calculated. As agreed, if multiple sites were overflowing to one waterway during the same storm, this was counted as one overflow for the purposes of calculating the average.

Post-earthquake changes to the wastewater network and improved modelling have resulted in some overflow locations identified in Schedule 1 no longer existing, and some additional locations not in Schedule 1 have been identified. All overflow locations were included in the calculation of the average number of overflows per waterway per year, not just those in Schedule 1. The results are summarised in Table 1. No values exceed the consented frequency, so Council is compliant with this consent condition.

Table 1 – Assessment of compliance with Condition 5a

Waterway 2015 Consent Limit Average Modelled Average Annual Annual Overflow Frequency Overflow Frequency Avon River 7 6.20 Heathcote River 8 8.00 Avon-Heathcote Estuary 0.87 0.67

Civic Offices, 53 Hereford Street, Christchurch, 8011 PO Box 73010, Christchurch, 8154 Phone: 03 941 6438 TRIM Reference: 17/400486 Email: [email protected] Page 1 www.ccc.govt.nz Compliance with Condition 5b

5 (b) Each individual site in Schedule 1 shall achieve an annual overflow event frequency of no more than two by the date specified in Schedule 1.

The date has passed by which all overflow locations in Schedule 1 need to meet an annual overflow event frequency of no more than two. The wastewater network modelling found that all but one location in Schedule 1 complied with this consent condition. The exception was Fisher Avenue (overflow ID PS20/4), which modelling showed overflowed on average 2.4 times per year. Comparison with overflow monitoring data for Fisher Avenue on a storm by storm basis for the past few years since monitoring equipment was installed found that the model is conservative and is predicting a higher frequency of overflows than actually occur. The actual overflow frequency for this site was 1.8 per year on average.

The modelling also identified five further locations not in Schedule 1 which exceeded the annual overflow consent frequency, as shown in Table 2.

Table 2 – Modelled overflow frequency for locations which overflow more than twice a year on average

Overflow ID Location Receiving Overflow Frequency Environment (Average Number of Spills per Year) PS20/4 Fisher Avenue Heathcote River 2.40 PS13/1 Tilford Street Heathcote River 6.07 PS21/3 Sandwich Road/Eastern Terrace Heathcote River 5.40 PS44/1 Opawa Road Heathcote River 4.80 PS121/1 40 Guild Street Avon River 5.80 PS77/1 Beacon Street Styx River 6.60

Strategy to comply with Condition 5b

We have plans in place to resolve all six overflow locations so that they comply with Condition 5b. A city-wide optimisation project has been undertaken to identify the most cost-effective suite of capital projects to reduce wastewater overflows and the projects required to achieve compliance with Condition 5b are set out in Table 3. There is budget available for these projects in the Council’s Long Term Plan.

These projects are sized to contain a 3 year annual recurrence interval storm. By addressing the most frequent overflows as proposed above, we will also comply with the 2020 and 2025 overflow frequency targets in Condition 5a.

Civic Offices, 53 Hereford Street, Christchurch, 8011 PO Box 73010, Christchurch, 8154 Phone: 03 941 6438 TRIM Reference: 17/400486 Email: [email protected] Page 2 www.ccc.govt.nz Table 3 – Capital projects required to achieve compliance with Condition 5b

Overflow Project to Resolve Overflow Cost Estimate Completion Date Fisher Avenue Increase capacity of the gravity $990,000 June 2020 and Sandwich main along Eastern Terrace Road/Eastern between Tennyson Street and Terrace Sandwich Road.

Divert part of the catchment to $7,300,000 June 2022 the Southern Relief Sewer on St Asaph Street which has spare capacity, by constructing a new pump station in the vicinity of the Milton Street/Selwyn Street intersection and a new pressure main to the Southern Relief. PS13/1 Tilford Increase capacity of pump $1,000,000 June 2020 Street station and pressure main Opawa Road Increase capacity of pump $130,000 June 2021 station

40 Guild Street Overflow PS121/1

This is a new pump station put in as part of the earthquake rebuild and while the modelling suggests that the site overflows there have been no known issues with this pump station. The new wet weather overflow monitoring contract will include an overflow monitor at this site to confirm that there are no issues during wet weather. The pump station level data during wet weather shows a high level but not to the point of overflow. This is such a small catchment (< 20 hectares) that it is unlikely to have any issues in wet weather. However, further investigation of the modelled flows are in progress.

Beacon Street PS 77/1

The catchment for this station is largely made up of the Brooklands Red Zone area. There is a current project to install pressure sewer units on the properties that are now going to remain in this red zone and when this is completed in October this year the whole gravity system currently serving some of the remaining properties can be disconnected and abandoned. This gravity system is in a very poor state and abandoning on it will resolve this overflow completely.

Risks

The funding for these projects is being drawn down from available budgets in the Long Term Plan. However, there is a risk that the Council could reduce those budgets through the Long Term Plan process, but given that complying with our resource consents is a legal requirement, this is unlikely.

Apart from funding, the other risk is that the recommended projects may change once the wastewater network model is fully calibrated after the flow monitoring we plan to carry out over the next year.

Should either of these risks eventuate, we would engage with you further on the best way forward.

Civic Offices, 53 Hereford Street, Christchurch, 8011 PO Box 73010, Christchurch, 8154 Phone: 03 941 6438 TRIM Reference: 17/400486 Email: [email protected] Page 3 www.ccc.govt.nz Conclusion

We believe that the approach of undertaking capital works so that we comply with our current wet weather overflow consent is preferable to seeking a new consent. Please advise whether you agree with this approach.

If you are agreeable, we will submit an application to vary the current consent, so that all overflow locations are included in Schedule 1, and also to clarify other consent conditions.

Yours sincerely

Bridget O’Brien Team Leader Asset Planning – Water & Wastewater Christchurch City Council

Civic Offices, 53 Hereford Street, Christchurch, 8011 PO Box 73010, Christchurch, 8154 Phone: 03 941 6438 TRIM Reference: 17/400486 Email: [email protected] Page 4 www.ccc.govt.nz From: Stuart Edwards Sent: Friday, 7 July 2017 12:11 p.m. To: O'Brien, Bridget Cc: Duncan Harvest; Steve Firth Subject: RE: HPRM: CRC092692 wastewater overflow consent - compliance strategy

Hi Bridget. Sorry for the delay in responding to your e-mail. A agree that a s127 consent variation is the most cost effective path to clarifying the consent conditions. It would be helpful to provide some clarity around the river reach approach to defining an overflow event. I’ve discussed this with Michelle Stevenson at Ecan, Surface Water Ecologist, and she is in agreement with the approach. It would be useful to include her comments in any s127 application. In my view the most pragmatic approach to defining a river reach for a stormwater overflow event registration is to have Mike Burke, or an output of the modelling, define river discharges that have a common stormwater catchment. As you are proceeding along a s127 consent variation path the effects will be examined through the audit process so no higher authority approval is needed. Regards Stuart

From: O'Brien, Bridget [mailto:[email protected]] Sent: Wednesday, 21 June 2017 11:20 AM To: Stuart Edwards Cc: Bourke, Mike ; Moore, John Subject: HPRM: CRC092692 wastewater overflow consent - compliance strategy

Hi Stuart

Please find attached a letter setting out how we plan to comply with our wastewater overflow consent. I look forward to your response.

Thanks Bridget

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Christchurch City Council http://www.ccc.govt.nz ********************************************************************** From: Lawrence, Helen Sent: Monday, 9 October 2017 9:40 a.m. To: Lawrence, Helen Subject: FW: CRC092692 Wet weather sewer overflows

From: "O'Brien, Bridget" Date: 3 February 2017 at 5:20:11 PM NZDT To: "Bennett, Justine" , Joel Wilson Cc: "Bourke, Mike" Subject: FW: CRC092692 Wet weather sewer overflows

Hi Justine, Joel

Please see below for ECan's confirmation of our interpretation of the overflow consent condition. This is great news and means that we pretty much comply with our current overflow consent and will likely seek to vary it (e.g. to include additional overflow locations in Schedule 1) rather than apply for a new consent for the city. However, we will still need to apply for a consent for Lyttelton and Akaroa Harbours as they aren't in the scope of the current consent. We may also need to apply for consents to the Styx and Halswell Rivers, if the overflows shown by the modelling are real. Mike and Dale are going to look closer at the existing consent conditions to see if there are any other conditions that we would like to vary.

While we work out a way forward, can you please stop work on the overflow consent project, other than for Lyttelton and Akaroa Harbours?

Kind regards Bridget

From: Stuart Edwards [mailto:[email protected]] Sent: Tuesday, 31 January 2017 3:50 p.m. To: O'Brien, Bridget Cc: Bourke, Mike; McEntee, Dale; Paul Hulse; Joe Harrison Subject: RE: CRC092692 Wet weather sewer overflows

Hi Bridget. I’ve discussed the interpretation of condition 5 of CRC092692 internally and agree with the position that the event frequency is calculated across all 10 schedule 1 overflow sites/catchment and not counting each individual site as a discharge event. I.e. in a storm event where there are sewer overflows then the discharge to the river is counted as a single discharge event. In reality I would expect that discharge points in the same sub- catchments are likely to be equally stressed in a storm event. As we discussed today a possible way forward is to apply for a change of conditions to the existing consent that clarifies the intent of condition 5 and defines the discharge points of consequence (points that have a volume/ frequency that has a measurable short term environmental effect). As the consent was publically notified, potential effects on submitters to the consent application and others that may be affect by the proposed changes should be considered and evaluated (s127 RMA). Regards Stu

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Christchurch City Council http://www.ccc.govt.nz ********************************************************************** AECOM CCC Wet weather wastewater overflows Wet weather wastewater overflows in the Ōtākaro/Avon River, Ōpāwaho/Heathcote River, and the Ihutai/Avon-Heathcote Estuary – Section 127 change to resource consent conditions of CRC092692

Appendix B

Overflow sites description

P:\605X\60507690\4. Tech work Area\4.5 Planning\change in conditions application\CCC wastewater s127 AEE v2.docx Revision 2 – 20-Oct-2017 Prepared for – Christchurch City Council – Co No.: N/A AECOM CCC Wet weather Overflows B-1 Christchurch City Council west weather wastewater overflows - change in consent conditions of CRC092692 – Appenidx B

Table 1: Wastewater Overflow site summary Overflow Overflow Site Receiving Included in Average Annual Overflow Frequency Location ID Environment original consent Volume (m3) (Average No. of Spills per Year) PS13/1 Tilford St Heathcote No 4,485 6.07 PS121/1 40 Guild St Avon No 3,542 5.8 PS21/1 Sandwich Rd/Eastern Tce Heathcote No 2,521 5.4 PS44/1 Opawa Rd Heathcote No 5,549 4.8 PS20/4 Fisher Ave Heathcote Yes 14,103 2.4 PS111/1 Cambridge Tce Avon No 845 2 PS1/15 St Andrews Sq Avon Yes 1,095 1.6 PS120/1 30 Emmett St Avon No 283 1.53 PS120/2 7 Orontes St Avon No 757 1.4 PS2/2 137 Cambridge Tce Avon No 1,429 1.4 PS18/2 Mackenzie Ave Heathcote No 1,226 1.4 PS111/2 Fitzgerald Ave/Heywood Tce Avon No 1,006 1.33 PS20/3 Tennyson St Heathcote No 1,760 1.33 PS14/1 Bromley Rd Heathcote No 220 1.27 PS22/1 25A Eastern Tce Heathcote Yes 1,585 1.2 PS12/1 Smith St Heathcote No 763 1.13 PS43/2 107 Ashgrove Tce Heathcote No 7,446 1.07 PS18/2 Clarendon Tce Heathcote No 1,119 0.93 PS68/1 Penruddock Rise Heathcote No 4,239 0.93

P:\605X\60507690\4. Tech work Area\4.5 Planning\change in conditions application\Appendices\Appendix B Tables.docx Revision 1 – 19-Oct-2017 Prepared for – Christchurch City Council – ABN: 00 AECOM CCC Wet weather Overflows B-2 Christchurch City Council west weather wastewater overflows - change in consent conditions of CRC092692 – Appenidx B

Overflow Overflow Site Receiving Included in Average Annual Overflow Frequency Location ID Environment original consent Volume (m3) (Average No. of Spills per Year) PS1/6 Kilmore St (BB) Avon No 9,877 0.73 PS1/21 Grassmere St (NR) Avon Yes 20,302 0.67 PS20/2 Waltham Rd Heathcote Yes 268 0.47 PS60/1 Halswell Rd Heathcote Yes 8,237 0.47 PS6/3 70 Thames St Avon No 1,064 0.4 PS119/1 32 Jameson Ave Avon No 211 0.33 PS31/1 Main Rd Estuary No 4,341 0.27 PS2/1 Hereford St Avon No 55 0.2 PS57/1 14 McCormacks Rd Estuary No 1,453 0.2 PS15/1 28 Gould Cr Heathcote Yes 582 0.13 PS127/1 297 Centaurus Rd Heathcote No 27 0.13 PS 1/16 Fendalton Br (North) Avon Yes 33 0.07 PS139/1 10 Bassett Street Avon No 195 0.07 PS1/17 Deans Ave Avon No 1 0.07

PS19/1 Beckford Rd Heathcote Yes 0 0 PS9/1 52 Chelsea St Heathcote Yes 0 0 PS1/20 174 Clarence Avon No 277 0.73 PS136/2 70 Bexley Road Avon No 0 0 PS10/1 401 Linwood Ave Heathcote Yes 21 0.40 PS42/2 175 Sparks Rd Heathcote Yes 95 0.27 PS1/11 11 Retreat Rd Avon No - -

P:\605X\60507690\4. Tech work Area\4.5 Planning\change in conditions application\Appendices\Appendix B Tables.docx Revision 1 – 19-Oct-2017 Prepared for – Christchurch City Council – ABN: 00 AECOM CCC Wet weather Overflows B-3 Christchurch City Council west weather wastewater overflows - change in consent conditions of CRC092692 – Appenidx B

Proposed Schedule 1 Location Date by which number of Overflow Receiving Grid Reference overflows to be Point ID Street environment (NZMS 260) no more than 2 annually PS13/1 Tilford St M35: 839-403 Heathcote 30 June 2020 PS121/1 40 Guild St M35: 821-438 Avon Expected compliant 2017 PS21/1 Sandwich Rd/Eastern Tce M36: 815-382 Heathcote 30 June 2020 PS44/1 Opawa Rd M36: 838-383 Heathcote 30 June 2021 PS20/4 Fisher Ave M35: 8155-3836 Heathcote 30 June 2022 PS111/1 Cambridge Tce M35: 816-427 Avon Compliant 2017 PS1/15 St Andrews Sq M35: 7870-4407 Avon Compliant 2017 PS120/1 30 Emmett St M35: 821-445 Avon Compliant 2017 PS120/2 7 Orontes St M35: 822-447 Avon Compliant 2017 PS2/2 137 Cambridge Tce M35: 803-418 Avon Compliant 2017 PS18/2 Mackenzie Ave M36: 835-395 Heathcote Compliant 2017 PS111/2 Fitzgerald Ave/Heywood M35: 818-426 Avon Compliant 2017 Tce PS20/3 Tennyson St M36: 815-388 Heathcote Compliant 2017 PS14/1 Bromley Rd M35: 848-409 Heathcote Compliant 2017 PS22/1 25A Eastern Tce M35: 8120-3739 Heathcote Compliant 2017 PS12/1 Smith St M35: 835-404 Heathcote Compliant 2017 PS43/2 107 Ashgrove Tce M36: 794-375 Heathcote Compliant 2017 PS18/2 Clarendon Tce M36: 832-393 Heathcote Compliant 2017 PS68/1 Penruddock Rise M36: 780-367 Heathcote Compliant 2017 PS1/6 Kilmore St (BB) M35: 818-423 Avon Compliant 2017 PS1/21 Grassmere St (NR) M35: 7942-4534 Avon Compliant 2017 PS20/2 Waltham Rd M35: 8151-3878 Heathcote Compliant 2017 PS60/1 Halswell Rd M35: 7524-3687 Heathcote Compliant 2017 PS6/3 70 Thames St M35: 807-450 Avon Compliant 2017 PS119/1 32 Jameson Ave M35: 803-453 Avon Compliant 2017 PS31/1 Main Rd M36: 894-379 Estuary Compliant 2017 PS2/1 Hereford St M35: 804-417 Avon Compliant 2017 PS57/1 14 McCormacks Rd M36: 875-390 Estuary Compliant 2017 PS15/1 28 Gould Cr M35: 8521-3915 Heathcote Compliant 2017 PS127/1 297 Centaurus Rd M36: 827-383 Heathcote Compliant 2017 PS 1/16 Fendalton Br (N) M35: 7874-4254 Avon Compliant 2017 PS139/1 10 Bassett Street M35: 848-453 Avon Compliant 2017

P:\605X\60507690\4. Tech work Area\4.5 Planning\change in conditions application\Appendices\Appendix B Tables.docx Revision 1 – 19-Oct-2017 Prepared for – Christchurch City Council – ABN: 00 AECOM CCC Wet weather Overflows B-4 Christchurch City Council west weather wastewater overflows - change in consent conditions of CRC092692 – Appenidx B

Location Date by which number of Overflow Receiving Grid Reference overflows to be Point ID Street environment (NZMS 260) no more than 2 annually PS1/17 Deans Ave M35: 787- 416 Avon Compliant 2017

PS19/1 Beckford Rd M36: 8240-3881 Heathcote Compliant 2017 PS9/1 52 Chelsea St M35: 8450-4065 Heathcote Compliant 2017 PS1/20 174 Clarence St M35: 778-417 Avon Compliant 2017 PS136/2 70 Bexley Rd M35: 868-445 Avon Compliant 2017 PS10/1 401 Linwood Ave M35: 8450-4065 Heathcote Compliant 2017 PS42/2 175 Sparks Rd M36: 7736-3762 Heathcote Compliant 2017 Avon Expected PS1/11 11 Retreat Rd M35: 826-429 compliant 2017

P:\605X\60507690\4. Tech work Area\4.5 Planning\change in conditions application\Appendices\Appendix B Tables.docx Revision 1 – 19-Oct-2017 Prepared for – Christchurch City Council – ABN: 00 Legend Outfall locations Not previously consented Previously consented

Environment Canterbury Regional Council; Hurunui District Council; Waimakariri District Council; Timaru District Council; Waimate District Council; Mackenzie District Council; Waitaki District Council AECOM CCC Wet weather wastewater overflows Wet weather wastewater overflows in the Ōtākaro/Avon River, Ōpāwaho/Heathcote River, and the Ihutai/Avon-Heathcote Estuary – Section 127 change to resource consent conditions of CRC092692

Appendix C

Cultural Impact Assessment

P:\605X\60507690\4. Tech work Area\4.5 Planning\change in conditions application\CCC wastewater s127 AEE v2.docx Revision 2 – 20-Oct-2017 Prepared for – Christchurch City Council – Co No.: N/A Te Ngāi Tū Āhuriri Rūnanga Inc. 219 Tuahiwi Road RD1 Kaiapoi Phone 03 313 5543 Fax 03 313 5542 Email: [email protected]

23 May 2017

Tēnā Koe,

Re: Cultural Impact Assessment Report Rūnanga Approval

At the Kaitiaki Portfolio Committee hui for Ngāi Tūāhuriri held on the 18th May 2017, the committee on behalf of Te Ngāi Tūāhuriri Rūnanga moved to endorse the recommendations contained in the Cultural Impact Assessment report, titled: “Wet weather waste-water overflow consent application- Ōtākaro me Ōpawaho ki Ihutai rātau ko Puharakekenui ki Te Riu o te Aika Kawa”.

This letter is to confirm that Te Ngāi Tūāhuriri Rūnanga endorse the recommendations contained within this report prepared by Kyle Davis from Mahaanui Kurataiao Limited .

If you have any queries or would like further clarification please don’t hesitate to contact Mahaanui Kurataiao directly on 03 377 4374.

Ngā Mihi

Clare Williams Hoana Burgman Chairperson Kaitiaki Portfolio Holder

Cultural Impact Assessment: Wet weather waste-water overflow consent application – Ōtakaro me Ōpawaho ki Ihutai rātau ko Puharakekenui ki Te Riu o te Aika Kawa)

24 February 2017

Nā, Mahaanui Kurataiao Ltd.

Contact person Kyle Davis Email: [email protected]

TABLE OF CONTENTS

1. Executive Summary……………….……………..……….…………………….4 2. Introduction………………………………………..……….…………………….4 3. Report Scope……………………………………..……….……………………..5 4. Methodology……………………………….………………….………….……...5 5. Manawhenua………………………...…………………………………..………5 6. Legal and Policy Context…………………….……...…………………….……6 7. Activity-specific Policies of relevance…………………………………………9 8. Proposed Consent summary………………………………………………….11 9. Prior Consent Application 2010………………………………………….…..12 10. Additional Background – Ecological Studies 11. State of the Takiwā Research and Cultural Health Indexes…..……….….15 12. Important concepts in Te Ao Māori………………...……………………...... 16 13. Cultural Values associated with Puharakekenui ki Te Riu o Te Aika Kawa and Ōpāwaho me Ōtakaro ki Ihutai:…………………………………….…..18 14. Cultural Values Impacts……………………………………………………...20 15. Recommendations and Conclusions……………………..….……………..31 16. Bibliography/references………..…..………………………………..……….32

Appendix 1: Ngāi Tahu Claims Settlement Act 1998 – Taonga Species Schedule 97 and 98

2 Mahaanui Kurataiao Ltd Cultural Impact Assessment

Disclaimer The cultural information in the CIA report is the intellectual property of Te Ngāi Tūāhuriri Rūnanga. Christchurch City Council is able to use the CIA report for the purposes of their current Resource Consent application for Wet weather Waste-water overflows only. Use of the report in other circumstances will be subject to written approval from both parties.

3 Mahaanui Kurataiao Ltd Cultural Impact Assessment

1. EXECUTIVE SUMMARY

This Cultural Impact Assessment (CIA) was requested and mandated by Claire Williams and Joan Burgman, Kaitiaki representatives for Ngāi Tūahuriri Rūnanga. The information within this assessment is based on conversations with Ngāi Tūāhuriri representatives, Mahaanui Kurataiao Ltd staff and Christchurch City Council (CCC) staff. Various legislation and policies are involved in the protection and recognition of Mana whenua cultural values that could potentially be affected by this proposal. Such cultural values are outlined in this assessment. Some recommended options and considerations are given in this assessment to help inform the design and planning of the development of this site, along with remedial and/or mitigation mechanisms.

2. INTRODUCTION

CCC has an existing 15 year consent for the occasional overflow of wastewater to the environment during large storms. A condition of this consent includes the requirement for reductions over time for the total amount of overflows within the Avon and Heathcote catchments. This means that the average overflow rate could be less than the two per year originally envisaged. However, earthquake damage to the wastewater network means that more storm-water and groundwater gets into the pipes than previously. As a result of the damage caused by the earthquakes, a non-enforcement agreement between CCC and ECan is in place. Under this agreement, CCC needs to either comply with the existing consent by March 2017, or apply for a new consent (if CCC cannot comply). Due to the earthquakes, it is unlikely that CCC will be able to comply, and therefore are starting the process of applying for a new consent. The proposed consent activity affects a number of identified cultural values outlined in this assessment within the ancestral lands of Ngāi Tahu takiwā of Te Ngāi Tūāhuriri Rūnanga as Mana whenua, and the ancestral lands of Ngāi Tahu.

4 Mahaanui Kurataiao Ltd Cultural Impact Assessment 3. REPORT SCOPE

As previously stated this assessment documents cultural values associated with the areas/environs where the global consent for waste-water overflows is sort . CIAs are a mechanism to assess potential impacts of proposed activities on cultural values and can make recommendations within the context of such potential impacts.

This assessment provides some additional context and information to assist Ngāi Tūāhuriri, Christchurch City Council, and other partners with their further discussion and planning around the proposed development.

4. METHODOLOGY

The information contained within this assessment is based on available literature and conversations held with Ngāi Tūāhuriri, Mahaanui Kurataiao staff and CCC staff. The reviewed literature included, Ecological reports and texts, ECan consent decisions, Iwi management plans, relevant policy documents, Ngāi Tahu cultural and environmental mapping, ethnographic texts, historic texts, etc. A site visit was undertaken on November 15 2016 with Mike Bourke (CCC) and Amy Beran of Mahaanui Kurataiao Ltd.

5. MANAWHENUA

Te Rūnanga o Ngāi Tahu Act 1996 The Te Rūnanga o Ngāi Tahu Act 1996 establishes Te Rūnanga o Ngāi Tahu as representing the tribal collective of Ngāi Tahu Whānui. This act directs membership of Te Rūnanga o Ngāi Tahu to be composed of the Papatipu Rūnanga of Ngāi Tahu whānui. This act effectively gives Ngāi Tahu legal identity.

Te Runanga o Ngai Tahu (Declaration of Membership) Order 2001 This order is supplementary to the above act and superseded schedule one of said act. The Papatipu Rūnanga and their respective takiwā are set out in this order. Te Ngāi Tūāhuriri Rūnanga is thus established as a Papatipu Rūnanga of Ngāi Tahu Whānui. Te Ngāi Tūāhuriri Rūnanga is the modern day assemblage and representative of the hapū, Ngāi Tūāhuriri, one of the five primary hapū of Ngāi Tahu. The takiwā of Te Ngāi Tūāhuriri Rūnanga is described as centring on “…Tuahiwi and extends from the Hurunui to Hakatere, sharing an interest with Arowhenua Rūnanga northwards to Rakaia, and thence inland to the Main Divide”.

5 Mahaanui Kurataiao Ltd Cultural Impact Assessment 6. LEGAL AND POLICY CONTEXT

Te Tiriti o Waitangi / The Treaty of Waitangi The first formal intervention by Britain in New Zealand was an immediate and direct outcome of the brig Elizabeth incident which occurred in 1830, where Captain of the brig Elizabeth John Stewart transported Te Rauparaha and his men to undertake incursions in Akaroa Harbour, and particularly at the Ngāi Tahu kāinga at Takapūneke (Te Rauparaha and his forces also made incursions at Kaiapoi Pā and Ōnawe Pā). This intervention led in turn, through a series of events between 1833 and 1840, to the dispatching of Lieutenant- Governor Hobson to New Zealand, the signing of the Treaty of Waitangi and the assumption by Britain of sovereignty over New Zealand. The treaty signing formalized an agreement between Her Majesty the Queen of England and the Māori Chiefs of Aotearoa allowing British subjects to settle in areas such as Te Waipounamu, under formal British colonial rule. The fact that at Ōnuku, in Akaroa Harbour, the treaty was signed by Iwikau and Hone Tikao (John Love) on 30th May 1840, puts Canterbury and the various hapū of Canterbury Ngāi Tahu, generally, in a unique position within the Nationally significant history related with Treaty of Waitangi, and Māori – Pākehā relations. The modern variant of the Ngāi Tahu claim, Te Kerēme, which sought remediation for historic treaty breaches, was filed with the Waitangi Tribunal in 1986, by then Upoko Rūnanga of Ngāi Tūāhūriri - Rakihia Tau. Negotiations between the Crown and Ngāi Tahu on the claims began in 1991, after the release of the tribunal‟s Ngāi Tahu Land Claims report, and claims were settled in 1998. The Treaty also guaranteed to Māori the protection of their taonga (possessions), including waters, lands, fisheries and mahinga kai. These rights are affirmed in Article 2, as follows: Māori text: “Ko te Kuini o Ingarani ka whakarite ka whakaae ki ngā Rangatira, ki ngā hapū, ki ngā tangata katoa o Niu Tirani, te tino rangatiratanga o rātou whenua o rātou kāinga me o rātou taonga katoa. Otiia ko ngā Rangatira o te Whakaminenga me ngā Rangatira katoa atu, ka tuku ki te Kuini te hokonga o ērā wāhi whenua e pai ai te tangata nōna te whenua, ki te ritenga o te utu e whakarite ai e rātou ko te kai hoko e meatia nei i te Kuini hei kai hoko mona” English text: “Her Majesty the Queen of England confirm and guarantees to the Chiefs and Tribes of New Zealand to the respective families and individuals thereof the full exclusive and undisturbed possession of their Lands and Estates, Forests, Fisheries and other properties which they may collectively or individually possess so long as it is their wish and desire to retain the same in their possession…”. Ultimately Te Tiriti o Waitangi recognises and guarantees the protection of tino rangatiratanga (sovereignty) and so empowers kaitiakitanga as customary trusteeship to be exercised by mana whenua/tangata whenua over their taonga, such as sacred and traditional places, built heritage, traditional practices, and cultural heritage resources. Council/Crown responsibilities in relation to the Treaty are defined in statute, particularly the Local Government 6 Mahaanui Kurataiao Ltd Cultural Impact Assessment Act 2002, the Resource Management Act 1991, Conservation Act 1987 as well as iwi settlement legislation (Te Runanga o Ngai Tahu Act 1996, and Ngai Tahu Claims Settlement Act 1998). With the exception of the Conservation Act requiring the Department on Conservation to give effect to the principles of the Treaty, the other legislation require administering bodies to take into account/have regard for Treaty Principles, being: (1) The acquisition of sovereignty in exchange for the protection of rangatiratanga (2) The Treaty established a partnership, and imposes on the partners the duty to act reasonably and in good faith (3) The freedom of the Crown to govern (4) The Crown‟s duty of active protection (5) Crown duty to remedy past breaches (6) Māori to retain rangatiratanga over their resources and taonga and to have all the rights and privileges of citizenship (7) Duty to consult

Resource Management Act 1991 The purpose of the Resource Management Act 1991 (RMA) is set out in Section 5(1) as „to promote the sustainable management of natural and physical resources.” „Sustainable management‟ is defined in Section 5(2) as managing the use, development and protection of natural and physical resources, and any adverse effects of activities on the environment are avoided, remedied or mitigated. It is inclusive of the “cultural wellbeing” of people and communities. The RMA also recognizes the relationship between Māori and their culture and traditions with their ancestral lands, water, sites, wāhi tapu and other taonga as a matter of national importance (Part II s. 6(e)), including the protection of sites of significance to Māori, including wāhi tapu (s. 6(f) historic heritage). Section 7 of the Act identifies kaitiakitanga as a matter that particular regard must be given in relation to managing the use, development and protection of natural and physical resources, and section 8 establishes that all persons exercising functions and powers under the Act shall take into account the principles of the Treaty of Waitangi. The Canterbury Regional Policy Statement 2013 sets out policy recognising the appropriate tangata whenua entities that may seek to exercise the aforementioned provisions. It is the task of those who have duties in relation to the RMA ensure active protections towards improved outcomes for all parties.

Te Rūnanga o Ngāi Tahu Freshwater Policy The purpose of the Te Rūnanga o Ngāi Tahu Freshwater Policy Statement is the management of freshwater resources within the rōhe of Ngāi Tahu. The Freshwater policy statement provides a foundation for resource management agencies and Papatipu Rūnanga planning for freshwater. Fresh water is taonga to Ngāi tahu stated as “water is central to all Māori life”, the importance of water protection is required to ensure the taonga is available for future generations. Chapter 5 of the plan identifies the need to protect the Wāhi

7 Mahaanui Kurataiao Ltd Cultural Impact Assessment Tapu, Mauri, Mahinga Kai and kaitiakitanga values. The Wāhi Tapu objectives are “To afford total protection to waters that are of particular spiritual significance to Ngāi Tahu”. Mauri values state “Restore, maintain and protect the mauri of freshwater resources” and “protect the opportunities for Ngāi Tahu‟s uses of freshwater resources in the future.” Mahinga Kai states “Protect critical mahinga kai habitats and identified representative areas.” The Ngāi tahu Freshwater Policy provides the guidelines which support and protect water as a resource.

Mahaanui Iwi Management Plan 2013 The purpose of the Mahaanui IMP is to be a tool for Ngā Rūnanga to ensure the recognition and protection of Ngāi Tahu values. It is a manawhenua planning document that reflects the key values of the six Papatipu Rūnanga who hold manawhenua rights over lands, skies and waters. The IMP covers the range of environmental issues that impacts on the Ngāi tahu values and looks into the different policies within the 6 rūnanga area and catchments. The plan provides a values-based, policy framework for the protection and enhancement of Ngāi Tahu values.

United Nations Declaration on the Rights of Indigenous Peoples At its 61st session and 107th plenary meeting of 13 September 2007, the United Nations General Assembly adopted the United Nations Declaration on the Rights of Indigenous Peoples. This was done to enshrine (according to Article 43) the rights that “constitute the minimum standards for the survival, dignity and well-being of the indigenous peoples of the world.” The declaration recognizes Indigenous peoples‟ rights to self-determination, freedom to pursue development and rights to traditionally owned land and resources. The Declaration is the product of almost 25 years of deliberation by U.N. member states and Indigenous groups. It was adopted by 144 countries initially with Aotearoa/New Zealand (and Canada, U.S.A and Australia) now sup[porting the declaration since 2009/2010. The Declaration does not override the rights of Indigenous peoples contained in their treaties and agreements with individual states, and it commands these states to observe and enforce the agreements.

Te Whakatau Kaupapa Summary: Ngāi Tahu Resource Management Strategy for the Canterbury region. Te Whakatau Kaupapa is a document that still has relevance today in recognizing Ngāi Tahu‟s beliefs and values. This document provides pro- active assistance to the planning authorities by identifying the beliefs and policies that the Māori have regard to natural resources and following the Treaty of Waitangi principles. Section 2 of the Plan outlines the relationship between the Treaty of Waitangi and Ngāi Tahu and how to implement the treaty with the planning authorities. Te Whakatau kaupapa advocates for the protection of taonga resources that provide for Ngāi Tahu and to make the planning authorities aware of the need for this protection. Te Whakatau Kaupapa also recognizes the importance of maintaining the history and protection of Ngāi Tahu‟s values. Section 3 the Ngāi Tahu and the

8 Mahaanui Kurataiao Ltd Cultural Impact Assessment Environment and is the Ngāi Tahu concepts of land, water, and the allocation of the resources for their uses where the relationship between Ngāi Tahu and the land is discussed.

Canterbury Regional Policy Statement 2013 The Canterbury Regional Policy Statement (RPS) sets out objectives, policies and methods applicable to the region‟s natural and physical resource management processes and issues. Chapter 2 Recognises Tangata Whenua, Mana Whenua, Te Rūnanga o Ngāi Tahu and Ngā Papatipu Rūnanga in the Canterbury Region. Additionally specific sections give direction concerning specific issues relating to protection and consideration of Taonga and Wāhi tapu. Section 2.2.6 states “…In the management of natural resources, it is important that the habitats and wider needs of taonga are protected and sustainably managed and enhanced…”, and provides a clear direction to territorial authorities to give effect, in planning documents, for sustainable management and enhancement in relation to Taonga/habitats/environs. Section 2.2.8 states “…It is important that wāhi tapu sites are protected from inappropriate activity and that there is continued access to such sites for Ngāi Tahu…”, and provides for the need for exclusion of certain sites from destruction or modification, maintenance and/or enhancement of sites/areas, and where this destruction/modification has occurred historically – appropriate measures for restoration and/or enhancement. Chapter 4 of the RPS recognises the relationship between Ngāi Tahu and the natural environment and by extension the Canterbury Regional Council. Chapter 2 also describes processes and provides tools to assist in sustaining such relationships. This includes acknowledging the section 6 provisions in the RMA, recognising the need to work with Ngā Papatipu Rūnanga, and acknowledging the need to consult Iwi Management Plans. Accumulatively these policies and objectives give further recognition for the need for Regional Council to work with those Papatipu Rūnanga with interests in the Canterbury Region, especially on issues relating to the consenting process as it relates to interaction with the natural environment, and cultural values, rights and interests.

7. ACTIVITY SPECIFIC POLICIES OF RELEVANCE

Te Rūnanga o Ngāi Tahu Freshwater Policy Mauri values within the Te Rūnanga o Ngāi Tahu Freshwater Policy state “Restore, maintain and protect the mauri of freshwater resources” and “protect the opportunities for Ngāi Tahu‟s uses of freshwater resources in the future.”

Te Whakatau Kaupapa 1990 Section 4 includes the Ngāi Tahu objectives and policy statements as “That no discharge into any water body should be permitted if it will result in contamination of the receiving water (4-20(1))” and “ Further deterioration, of either water quality or quantity is unacceptable”. This section mentions the

9 Mahaanui Kurataiao Ltd Cultural Impact Assessment importance water had on Māori lives and reasons for its protection. “The maintenance of water quality and quantity are perhaps the paramount resource management issues to Ngāi tahu”.

Mahaanui Iwi Management Plan 2013 Section 5.3 has relevant policies that promote the protection of water quality. WM2.2 “To require that water is recognized as essential to all life and is respected for its taonga value ahead of all other values”, WM6.1 “To require that the improvement of water quality in the takiwā is recognised as a matter of regional and immediate importance”. Under Section 5.4 Papatūānuku of the plan identifies the importance of land use and has relevant policies stating (P6.3) “Stormwater should not enter the waste water reticulation system in existing urban environments.” (P7.4) “To continue to oppose the use of waterways and the ocean as a receiving environment for waste”.

United Nations Declaration on the Rights of Indigenous Peoples Articles 25 and 32 no.2 are of particular relevance when considering Māori concerns regarding actions/impacts associated with freshwater: Article 25 Indigenous peoples have the right to maintain and strengthen their distinctive spiritual relationship with their traditionally owned or otherwise occupied and used lands, territories, waters and coastal seas and other resources and to uphold their responsibilities to future generations in this regard. Article 32 no.2 States shall consult and cooperate in good faith with the indigenous peoples concerned through their own representative institutions in order to obtain their free and informed consent prior to the approval of any project affecting their lands or territories and other resources, particularly in connection with the development, utilization or exploitation of mineral, water or other resources.

Canterbury Land and Water Regional Plan 2015 Section 4 includes the policy (4.5) “Water is managed through the setting of limits to safeguard the life supporting capacity of ecosystems, support customary uses, and provide for the group or community drinking- water supplies and stock water as a first priority and to meet the needs of people and communities for water for irrigation..”. Section 5 identifies the region wide rules to back up the policies. This states that “The discharge of wastewater from a new, modified or upgraded on-site domestic wastewater treatment system onto or into land in circumstances where a contaminant may enter water is a permitted activity, provided the following conditions are met:…The discharge does not result in waste water being visible on the ground surface.” Section 5.86 states the that “The discharge of treated sewage effluent into surface water or a wetland is a non-complying activity” and 5.87 “The discharge of untreated sewage onto or into land in circumstances where a contaminant may enter water or into surface water, a wetland or groundwater, as a result of a spill, overflow, or equipment failure, is a non-complying activity”. The LWRP provides a guideline of the protection of the land and

10 Mahaanui Kurataiao Ltd Cultural Impact Assessment water as valuable resources and the policies and rules required to protect them.

8. PROPOSED CONSENT SUMMARY

As mentioned in the introduction, the new consent is proposed to cover existing overflow points within Christchurch including the Avon River, Heathcote River and the Avon/Heathcote estuary. The (2012) BECA report states that major damage to collector sewerage as a result of the 2010/11 earthquake series and states that the wet weather events are causing more overflows into the Ōtakaro /Avon and Ōpāwaho/Heathcote Rivers. The conveyance of wastewater in Christchurch is via gravity assisted sewers draining to “..pump stations with rising mains which connect either to other pump stations or directly to the wastewater treatment plant…”. The treated wastewater from the treatment plant is then discharged to a series of ponds which remove pathogens and provide disinfection (BECA:2012). The wastewater network has 114 overflow points. Computer modelling indicated that 22 of these sites are known or expected to overflow (see Map 1) below for overflow site details). CCC have stated that the previous consent focused on reducing the frequency of overflows to waterways, but that this approach did not provide a linkage between the frequency of overflows and the subsequent effects on the waterways. CCC has further suggested that while we all want to improve the quality of our waterways, we need to work out the best way to do that, which may for example mean getting better outcomes by reducing contaminants in storm-water instead of spending a lot of money to reduce the amount of wastewater overflows. By way of example, CCC stated that to eliminate wastewater overflows altogether would require converting most of the city to a pressure sewer system and would cost over $2 billion. However, it wouldn‟t necessarily result in an improvement in water quality. According to CCC extensive monitoring of the water quality in waterways (including over 7,000 water quality samples collected and analysed by the Council in the past year) has indicated that the key contaminants are:

 Sedimentation is the main contributor for poor water quality. Sediment smoothers habitat and can contaminate food sources Generally, sediment originates from construction sites, un-stabilised excavated / disturbed surfaces, vehicles and earthquakes.  Metals (zinc and cooper) which is toxic to fish and other creatures and comes from vehicle brake pads, tyres and building products (roofs, spouting and downpipes).  Bacteria which creates a public health risk and comes mostly from ducks and dogs, and occasionally from wastewater overflows.  Nutrients (nitrogen and phosphorus) can be toxic (e.g. ammonia) and can encourage the growth of weeds and algae. Nutrients come from fertilizer, soils, and the faeces of livestock, dogs and ducks.

11 Mahaanui Kurataiao Ltd Cultural Impact Assessment CCC is planning to take a different approach to the wastewater overflow consent this time and is instead taking an effects based approach with a focus on the values of the waterways, effect on those values and methods reduce such effects. The six values identified by CCC for waterways are:  Ecology  Drainage  Culture  Heritage  Landscape  Recreation

9. SITE VISIT

The writer and Amy Beran (Environmental Advisor, Mahaanui Kurataio Ltd.) joined Mike Bourke (CCC) and undertook site visits to the constructed outfalls, overflow points and Grassmere (Dudley Creek), Fisher Avenue, corner of Fitzgerald and Kilmore Streets, Halswell Road, Tennyson Street and Next to the Christchurch Yacht Club in Moncks Bay (See Photos below).

Fig.1 Grassmere – constructed outfall

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Map 1 – Modelled overflow points in the Ihutai / Avon Heathcote Estuary and Te Riu o Te Aika Kawa / Brooklands Lagoon

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Fig.2 Corner of Fitzgerald Avenue and Kilmore Street – constructed outfall (earthquake damaged)

Fig.3 Fisher Avenue – constructed outfall

Fig.4 Halswell Road – constructed outfall

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Fig.5 Tennyson Street – constructed outfall

Fig.6 Constructed outfall adjacent to Christchurch Yacht Club

10. ADDITIONAL BACKGROUND

Bridget O‟Brien (Team Leader - Asset Planning - Water & Wastewater, Christchurch City Council) attended the Ngāi Tuāhuriri hui on Freshwater in August 2016, and in addition attended a Ngāi Tūāhuriri Kaitiaki Portfolio hui on 1st September 2016, a „Water wānanga‟ summary document/brochure was supplied and then reviewed by the kaitiaki. It was at this hui that the CIA was requested. Throughout the drafting process Bridget has been of great assistance in supplying additional information when requested.

11. PRIOR CONSENT APPLICATION 2010

The activity proposed in 2010, due also to prior non-compliance, was to increase maximum frequency of overflow discharge occurrences to once every six months, discharging groundwater, wastewater and stormwater into the Ōtākaro and Ōpāwaho, their tributaries and drains entering Ihutai. The consent seeks to discharge from up to 23 overflow points, with discharges including micro-organisms, organic material, suspended sediment, nutrients, heavy metals and hydro carbons. The duration of consent sought was 25 years. The ensuing hearing concluded with a decision which included statements around the degradation of the mauri of Ōtākaro and Ōpāwaho as a result of

15 Mahaanui Kurataiao Ltd Cultural Impact Assessment wastewater overflows. And that it would not be possible to mitigate discharge of sewage into freshwater.  The decision considered a duration of 25 years to be too long.  The decision considered that there should also be some sampling of riparian areas that have been flooded with wastewater overflow water. The application was granted to discharge groundwater, wastewater and stormwater into the Ōtākaro and Ōpāwaho, their tributaries and drains entering Ihutai for a duration of 15 years. The conditions as part of the granted consent were as follows:  The contaminants discharged shall only be storm-water, groundwater and wastewater from the Christchurch City Council wastewater network.  The discharges shall only occur as a result of wet weather events overloading the wastewater network.  The discharges shall only occur at the overflow locations identified in Schedule 1 of this consent.  For the purposes of this consent, an “overflow event” at each location may consist of one or more discharges and shall only be deemed to have commenced when there has been no prior discharge at that location for a period of 24 hours.  The total volume of wastewater overflowing into the rivers and estuary, in accordance with computer modeling, shall reduce by the same proportion as the reduction of frequency of discharge between the commencement of the consent and 2025.  Within 3 months of the commencement of the consents, automatic monitoring and alarms shall be provided and monitor the following; a. Start date and time of overflow event b. End date and time of overflow event c. Peak flow rate during overflow event d. Total volume discharged during overflow event.  In addition to the automatic monitoring, there will also be water quality sampling undertaken at overflow locations.  A Compliance and Monitoring Liaison Group shall be formed by the consent holder and meetings held at least once annually, and may include up to two representatives from Te Rūnanga o Ngāi Tahu.  The consent holder will maintain and comply with a current Sewer Overflow Response Plan.  Compliance and monitoring report must include a Cultural Health Assessment by a person(s) recommended by Te Rūnanga o Ngāi Tahu that assesses effects of the overflows on tangata whenua values.

12. ADDITIONAL BACKGROUND – ECOLOGICAL STUDIES

An ecological survey (2014) conducted by Boffa Miskell ecologists surveyed fish communities within at least a 20m reach at the 29 research sites. A total

16 Mahaanui Kurataiao Ltd Cultural Impact Assessment of 705 fish, consisting of 7 species were captured in the 29 sites. They were (in descending order of abundance); 1. Common bully (Gobiomorphus cotidianus) (Not threatened species) a. Found at 69% of sites 2. Brown Trout (Salmo trutta) (Introduced species) a. Found at 55% of sites 3. Shortfin eel (Anguilla australis) (Not threatened species) a. Most common species found (present at 76% of sites) 4. Longfin eel (A. dieffenbachii) (Declining species) a. Found at 65% of sites (19 of 29 sites). 5. Upland bully (G. breviceps) (Not threatened species) a. Found at 48% of sites 6. Bluegill bully (G. hubbsi) (Declining species) a. Found at at 17% of sites (5 of 29 sites, mainly in the mainstem of the Avon) 7. Inanga (Galaxias maculatus) (Declining species) a. Found at 10% of sites (3 of 29 sites.

No fish were observed at Ilam Stream at Waimairi Road, Addington Brook upstream of Avon confluence and Shirley Stream Stapletons Road. Wai-iti Stream at Clyde Road, Dudley Creek downstream Jameson Ave and Taylors Drain at Heaton Street had the greatest fish densities. The (2008) URS report on the effects of discharges wastewater overflows noted that the rivers are effected by high concentrations of Escherichia coli (E.coli, ammonia, and total suspended solids. Ammonia occurs in highest concentrations for both rivers in the lower tidal reaches, and believed to be derived from treated wastewater discharges to the Avon/Heathcote Estuary from the CWTP. In these rivers there is increasing trends downstream but the ammonia levels where generally below trigger values for toxicity to fish.  The cause of a large amount of ammonia in the Avon River appears to enter from Addington Drain(near the Public Hospital) and downstream.  The Heathcote River has higher ammonia concentrations, with these increasing at about the Curletts Road at the location where Hayton‟s Drain enters. Due to the water quality of the Avon-Heathcote Estuary, Shellfish are not considered to be safe to eat because of faecal coliform concentrations in the estuary are higher than the shellfish standards (14/100 ml). The mudflats of the estuary provide habitat for hairy-handed crabs, mud snails (titoko), wedge shells (hanikura), whelks and microscopic creatures, which provide food for young fish and wading birds. Flounder (patiki) and other flatfish enter the estuary to breed, while eels (tuna), adult whitebait (inanga), yellow eyed mullet and many small fish are daily or seasonal visitors, feeding on plankton and marine species.

17 Mahaanui Kurataiao Ltd Cultural Impact Assessment The effects of the toxicity levels of ammonia and/or nitrite to fish and other freshwater fauna has been well documented, but other potential effects of wastewater discharge include oxygen depletion or BOD, changes to water acidity, and changes to water temperature. Some of the effects may be interactive, for instance it is known that the toxicity of ammonia increases with pH. The fish communities at the survey sites located six native species (longfin eel, shortfin eel, upland bully, common bully, bluegill bully, inanga). Niwa found the same species as Boffa Miskell Study. A total of 360 fish identified, with 90% being shortfin eel, upland bully or common bully. Interestingly, and in some cases - conversely the Burrell (2016) report surmises that the effects of faecal pathogens are not considered to have significant effect in relation to stream ecology. Key effects from faecal pathogens have effect on recreational users and people gathering food.  The comparison of ecological sampling conducted pre (in 2008) and post-earthquake (2013). In 2014 Boffa Miskell concluded that the macro invertebrates community of the Ōtākaro/Avon River had not change markedly.  The wastewater overflows have effects on the dominance of pollution- tolerant macro invertebrates species present, and overall “moderately tolerant” sensitivity of the biological community.  Wastewater flows do potentially contribute to the cumulative effects of urbanisation on water quality and ecology.  The key contaminants of concern are in relation to the waste water overflow, are the elevated biochemical oxygen demand (BOD), which can result in depleted oxygen concentrations, and ammonia toxicity. The invertebrate and fish fauna present is to be at least moderately tolerant of these potential effects, due to their persistence in waterways that are exposed to a range of other urban contaminants (e.g., metals and sediment from stormwater run-off, and upwelling nitrate-rich groundwater), in addition to degraded aquatic habitat and altered hydrology. The assumption rhetoric in the underlined portion of the preceding paragraph and its successive points, hopefully only considers a basic presence/absence of species, and thei relative „persistence‟ rather than making an assumption around ideal ecological abundance.

13. STATE OF THE TAKIWĀ RESEARCH AND CULTURAL HEALTH INDEXES

The State of the Takiwā monitoring system was developed by Ngāi Tahu to facilitate manawhenua/tangata whenua to glean information relevant to the cultural health of water-ways within the their Takiwā, and in accordance with the Ki Uta Ki Tai Natural Resource Management framework and tribal vision. Influences in cultural health scores are varied, with an example outline here: Positive Influences – factors associated with good cultural health scores  Native restoration and/or remnant vegetation

18 Mahaanui Kurataiao Ltd Cultural Impact Assessment  The presence and abundance of indigenous species and mahinga kai species in particular  High water quality including clarity  Natural water flow patterns  Natural stream bed morphology and stream bed composition e.g. absence of silt  Presence of natural springs or other taonga in good condition

Negative influences – factors associated with poor cultural health scores  The absence of flowing water (e.g. Avonhead, Burnside, Wilmers Road)  Degraded and/or heavily urbanised areas  Limited vegetation and/or the presence of exotic vegetation  Poor water clarity and/or high sedimentation  Highly modified river channels  Lack of indigenous species  Lack of mahinga kai species

Ihutai/Avon-Heathcote Estuary The 2007 (Pauling et al.) State of the Takiwā research found that the Ihutai catchment has become a state of poor to very poor health due to impacts from historical and ongoing drainage and untreated stormwater. The impacts also involve loss of native vegetation of such as wetlands, grasslands, and lowland forests. The catchment area has a concern of E.coli and antibiotic resistance levels that are severely impacted and contributed by human and agricultural sources in the catchment. The recommendations for the future requires thought towards the protecting, enhancing, and extending areas of native vegetation/native riparian buffer zones and native plant restorations efforts. The identification and development of storm-water treatment systems and the effect it has on the ecology of the area. Along with the interpretation of cultural and historical significance of the areas of importance in this catchment. The recommendations include the regular monitoring, including cultural assessments that allow understanding of the success or future management and development of the catchment. A further State of the Takiwā study was undertaken in 2012 (Land et al.), which stated that the health of the Avon-Heathcote Estuary remains in poor cultural health and the assessment shows the cultural health is similar to that in 2007. E.coli and antibiotic resistance indicate that there is faecal contamination from a range of sources in the catchment. Following from the 2011 Earthquake the levels were expected to be high but identifies the need for attention. Repairs have been completed to wastewater infrastructure, identifying that faecal contamination remains throughout the catchment.

19 Mahaanui Kurataiao Ltd Cultural Impact Assessment The E.coli levels are bringing implications to mahinga kai values and activities across the region because of the safety concerns from degraded water quality, riparian areas, the presence of erosion, and pest species. The condition of habitats for indigenous species was variable but overall considered as degraded. The recommendations include the elimination of contaminant inputs in the catchment, restoring water quality at which mahinga kai can be safely gathered, protection and enhancement of known springs, and the to restore riparian areas within 20m from waterways and prevent developments from encroaching on waterways.

Puharakekenui/Styx River (Te Riu o Te Aika Kawa/Brooklands Lagoon as the receiving environment) The 2012 (Orchard et al.) State of the Takiwā research noted the historical presence of raupō(bulrush), harakeke (flax), wiwi (rushes) and forest species such as kiekie. Kai-manu/birds included putangitangi (paradise shelduck), parera (grey duck), weka, kiwi and koreke (quail). Kai-ika/Fish included tuna (eels), kanakana (lamprey), inanga (whitebait) and pātiki (flounder). This research also found that native birds were positively identified at 9 of the 19 sites, with a maximum of 2 birds at each site. Pukeko was most commonly sighted. Other species recorded were Piwakawaka (fantail), Akiaki (redbilled gull), and Pūtakitaki (paradise shellduck). No forest species recorded, reflecting the lack of forest habitat.

A total of 8 indigenous fish species were identified at the sites. Short finned eel was present at 9 of the 15 sites. Long finned eel was found at 6 sites. Other indigenous fish species recorded were; common bully, giant bully, yellow-eyed mullet, herring, inanga (whitebait) and pātiki (flounder). Brown trout, freshwater crayfish (waikoura), shrimp and crab were recorded at one site each. The presence of long finned eel is notable as it is now listed as a threatened species. The cultural health of the inanga spawning site was in relatively good condition in comparison with other sites. The vegetation mid- catchment of Puharakekenui is dominated by pasture grass. Suitability assessment for harvesting mahinga kai (access and willingness to harvest) determined that four sites (21%) were evaluated as not being suitable for harvesting mahinga kai. These were:  Kaputone mid-catchment  Belfast Factory  Head of Kāinga Creek  Kāinga Creek mid-catchment

12 sites (63%) scored „moderate‟ on the mahinga kai index, showing that present day mahinga kaui values are present, and opportunities to improve mahinga kai values exist at all sites. These studies all noted concerns related with contaminants, and in many ways corroborate the assessed impacts listed in the relevant section.

20 Mahaanui Kurataiao Ltd Cultural Impact Assessment 14. IMPORTANT CONCEPTS / VALUES IN TE AO MĀORI

The Te Ao Māori concepts/values and Cultural Values associated with sites/areas outlined below all conceivably relate to the six values identified above by CCC. Whakapapa Whakapapa explains the origins, inter-connections and relationships in the Māori world. Whakapapa accounts for the way in which the universe, earth, sky, oceans, rivers, elements, plants, animals and humans have been created. Ultimately it is whakapapa that connects people to each other, to their ancestors, to the and natural resources. For Ngāi Tahu it is whakapapa that links their descent from the gods of creation.

Mauri Mauri or the life force present in all things (animate and inanimate) air, forests, waters and the life supported by them, is a central concept within the Māori environmental worldview. It is important to note this as this concept is something that is seen to be disturbed by past development and land-usage and may be further disturbed by future developments.

Tikanga Tikanga Māori are the customs and traditions that have been handed down over the generations. The first aspect of Tikanga Māori is a set of principles, ideas and beliefs based on traditional knowledge about a particular tikanga that has been passed down generation to generation from tupuna. The second aspect is the practice or operational usage of tikanga by a group or individual. It is important to note that ideas and practices relating to Tikanga Māori can differ between hapū and iwi. The concept of the base word „tika‟ means to be correct or right.

Kaitiakitanga Kaitiakitanga is the exercise of guardianship/stewardship by manawhenua over their area and resources in accordance with tikanga Māori (protocols and customs). Kaitiakitanga governs the way people interact with the environment, with the concept of maintaining best possible dynamic equilibrium within cultural uses and practices. Kaitiaki are seen to be the interface between the natural and spiritual realm of resource management. Being able to facilitate, wherever possible during the process, the voices and views of manawhenua may contribute to manawhenua being able to fulfil their kaitiaki responsibilities.

Manaakitanga Manaakitanga the act, or actions by a group or individual, relating with a display of respect, humility and hospitality. The value or principle applies to all

21 Mahaanui Kurataiao Ltd Cultural Impact Assessment social occasions when mana whenua/tangata whenua or officials are put into the role of looking after guests.

Wairua Wairua denotes the soul or spirituality of a person, ancestor or entity. Wairua can be sensed as part of a person, place, etc.

Ki uta ki tai Ngāi Tahu whānui use „ki uta ki tai‟ (mountains to the sea) as an overall approach to resource management. Ki uta ki tai encompasses the wider creation traditions, whakapapa and acknowledges the interconnectivity of environs, species, humans and other elements constituting and interacting from the mountains to the sea.

Pono and Tuturū The concept of pono refers to the quality of an entity or situation that is true, genuine or authentic. Tuturū denotes something that is fixed, permanent or enduring.

15. CULTURAL VALUES ASSOCIATED WITH PUHARAKEKENUI KI TE RIU O TE AIKA KAWA AND ŌPAWAHO ME ŌTAKARO KI IHUTAI

This section aims to describe the additional cultural values and interests associated with geographic features, for example sites, areas, and landscapes (e.g. mahinga kai associations, important landscape features, wahi tapu, place names, archaeological sites, etc).

Wāhi Ingoa Māori place names on the landscape exemplify the Māori relationship with landscape. Names can occur as species indicators, tupuna commemorations, transposition of ancient Hawaiki names, commemoration of the deeds of atua, etc. Many place names occur within the Ngāi Tahu Takiwā. There are in excess of a dozen place-names associated to the area where the works are to take place. These place-names refer to features like wāhi taonga / wāhi tapu, mahinga kai areas, natural features, ancestor commemorations, Pā and kāinga, etc.Use of Wāhi Ingoa occurs throughout this report where appropriate.

Wāhi taonga/tapu Wāhi tapu denotes those sites/areas that are Wāhi Tapu – places that are linked with death, ceremonies, atua and any other places with special constructions on them or within them, Wāhi Taonga – places that are treasured or valued by Manawhenua/Tangata Whenua.

22 Mahaanui Kurataiao Ltd Cultural Impact Assessment Wāhi taonga can include Archaeological sites of māori origin in the Ngāi Tahu takiwā, as these are generally culturally regarded as „Ngā tapuae o ngā tupuna/footsteps of our ancestors‟ and are culturally significant.

Ara Tawhito A network of Ngāi Tahu trails are known throughout Te Waipounamu. These functioned, among other things, as corridors for whānau and hapū travelling on seasonally migrating mahinga kai initiatives, envoys by high-ranking hapū members, etc, enabling the maintenance of links between settled and frequently visited areas. A number of trails existed in association with the Puharakeknenui, Opawaho and Ōtakaro catchments. These trails linked settlements, camping spots, urupā and resource gathering areas. The presence of these trails also corroborates the history of Māori settlement in the area.

Waimāori-Freshwater The Ministry for the Environment (2016) notes that “…iwi, hapū and whānau interests and values are not adequately considered in planning and resource management decision-making..” and in addition states government perspectives including ensuring “…iwi and hapū are able to participate in decision-making about fresh water in their rohe…” and “….the relationship of iwi and hapū with, and values for, particular freshwater bodies is recognised..” (Ministry for the Environment/ Manatū Mō Te Taiao:2016) A viewpoint of the Iwi chairs forum states that “…our wai (water) is an inseparable part of our whakapapa and our identity, and is a fundamental part of what drives our very existence. The future health and wellbeing of our waters are a matter of utmost importance to all iwi, as well as all New Zealanders…” (Iwi Charis forum:2017) Waimāori/freshwater is of significance to Ngāi Tūāhuriri/Ngāi Tahu, in particular, for a number of reasons. Water appears in Ngāi Tahu creation traditions, for example Maku (moisture/water) mated with Mahoranuiatea and begat Ranginui – his tears, resulting from continued separation from Papatūānuku, are the rains. Water is a promoter of all life and is as the circulatory blood system of Papatuanuku, and thus represents the life blood of the environment. Its condition and treatment are a reflection on the health and regard for Papatūānuku. Water is seen as central to all Māori life and is a taonga cared for and passed on by ancestors to provide and sustain life. It is for the present generation to ensure this taonga is in the same or an improved state for future generations. As previously mentioned there will be entry of waste-water over-flows to the freshwater system of the Ōtakaro/Avon River, Ōpawaho/Heathcote River, Ihutai/Avon-Heatchcote Estuary (as a receiving environment), Puharakekenui/Styx River and Te Riu o Te Aika Kawa/Brooklands Lagoon (as a receiving environment) during wet-weather events via constructed outfalls linked to known and probable over-flow points in the network, impacts are discussed below.

23 Mahaanui Kurataiao Ltd Cultural Impact Assessment Taonga Species Taonga species are native birds, plants and animals of special cultural significance and importance to Ngäi Tahu. Taonga species are largely treasured and prized in a contemporary sense as they link to traditions and whakapapa, and are customary food sources with varying degrees, as directed by statue and relative abundance, of „harvestabiliity‟. The Crown‟s settlement with Ngäi Tahu (Ngäi Tahu Claims Settlement Act 1998) included recognition of the special traditional relationship Ngäi Tahu have with taonga species (listed in schedules 97 and 98, see appendix 1 of this document). In addition paragraph three in the South Island Freshwater Eel Fisheries Plan recognises tuna/eels as a taonga species for Tangata Whenua. Ngäi Tahu, seeks to or, directly participates in the management of those species in many ways, including representation on species recovery groups and environmental advocacy.

Mahinga kai Mahinga kai is defined in the Ngai Tahu Claims Settlement Act (NTCSA) 1998 as “the customary gathering of food and natural materials, and the places where those resources are gathered” (s. 167). Mahinga kai may be birds or fish taken for food. It may also be plants such as pingao or harakeke, used for weaving, or paru (mud) used for dying fibres. Throughout history authorities have quite often relegated the definition of Mahinga kai to apply to cultivations only. Addressing this, a more appropriate definition, in preceding that defined in the NTCSA, was given by Natanahira Waruwarutū in the 1879 Royal Commission: “Mahinga Kai is not confined to land cultivated, but it refers to the places from which we obtain the natural products of the soil without cultivating. You know the plants that grow without being cultivated by man. The whole of this country was covered with Ti or cabbage trees in former times. There was also fernroot which is not usually cultivated; there is no cultivation necessary; it only requires to be dug up. Fernroot grew all the way between Kaiapoi and Purehurehu, and the people used to get fernroot between those two places. There were also wood hens all the way between Kaiappoi and Purehurehu and people used to catch them between these places. There were also all different berries the natives use to get from the forest trees. Those were the “Mahinga Kai” the natives meant” (Tau and Tau:nd) The continuation of mahinga kai is of great significance to Ngāi Tahu, as it is intrinsically linked to the continuation and understanding of the culture. Mahinga kai was, and is, central to the Ngāi Tahu way of life, being an important social and economic activity. Many sites and environs are associated with mahinga kai.

Ngā awa me ngā hāpua, ko ngā The specific water-bodies, of cultural significance, affected are as follows: o Pūharakekenui (Styx River) o Te Riu o Te Aika Kawa (Brooklands Lagoon)

24 Mahaanui Kurataiao Ltd Cultural Impact Assessment o Ōpawaho (Heathcote River) o Ōtākaro (Avon River) o Te Ihutai (Avon-Heathcote Estuary)

16. CULTURAL VALUES IMPACTS

The main purpose of this report is to identify those cultural interests and rights that are of utmost value and importance to Mana whenua and to assess the impact upon them in relation to the proposed activity. Methodology Detailed below is information to show the reader the relationship between identified cultural interests, rights and values, relevant policies, cultural impacts, etc. These are then coupled with potential mitigation measures and notable discussion points for further and ongoing engagement with Mana whenua.

Ōtakaro / Avon River The Ōtākaro was an important part of the interconnected network of trails, particularly as an access route through the swampy marshlands of Christchurch to specific mahinga kai nohoanga located throughout the wider Canterbury region. The Ōtākaro supported numerous mahinga kai nohoanga located on or near the river. More specifically Ōtākaro is the name of a mahinga kai nohoanga located near the mouth of the river. Foods gathered from Ōtākaro included tuna (eel), īnaka (whitebait), kōkōpū (native trout), kanakana (lamprey), waikōura (freshwater crayfish), waikākahi (freshwater mussel), tuere (blind eel) and pātiki (flounders). Eeling weirs made from manuka stakes were situated half a mile from the river‟s mouth until they were removed in the 1920s. A variety of birds were also gathered including pūtangitangi (paradise ducks), pārera (grey duck), raipo (sp. of duck), tataa (brown duck) and pāteke (teal). On the banks of the rivers plants such as āruhe (fernroot) and kāuru (root of the tī kouka/cabbage tree) were also gathered. The CCC/WCS mapped analysis, related with the consent application, of the 'Existing network performance under 2016 population data and 15-year historical rainfall analysis', indicates the multiple constructed outfalls along, or feeding into, the Ōtakaro/Avon River and several overflow points that connect to these outfalls. The modeling data is as follows: 1. Discharge frequency greater than 2 years = 4 points/sites 2. Discharge frequency less than 2 years = 3 points/sites 3. Discharge frequency less than 1 years = 6 points/sites 4. Discharge frequency less than 6 months = 1 point/site

25 Mahaanui Kurataiao Ltd Cultural Impact Assessment

Map 2 – Ōtakaro/Avon River, with overflow sites shown by flags

26 Mahaanui Kurataiao Ltd Cultural Impact Assessment Impact 1 Tikanga - The entry of wastewater to a water-body of known prior or current mahinga kai goes against tikanga Māori, as waste-water renders the kai species non-harvestable/non-consumable, not to mention the chemico-physical effect from faecal pathogens (Burrell:2016) on the species, its habitat and those that gather those species for kai. This tikanga is relative to the tikanga of not sitting on tables/eating areas/food preparation tables and not stepping over people, etc (Mead:2003, Keane:nd). This tikanga of not putting human waste into areas, such as water-borne areas, is eloquently expressed in the following quote by the late Auntie Rima Bell, a prominent kaumātua of Ngāi Tūāhuriri: “We do not believe that what we excrete from our bodies should be put back in our mouths again” (Tau and Tau:nd) The Ōtakaro/Avon River was, as previously mentioned in earlier sections an important travel route and mahinga kai for ancestors. An number of Kainga Nohoanga existed along the Ōtakaro/Avon River, among the significant of these was Puari and Tautahi, both of these are registered Wāhi Tapu with Heritage New Zealand. In addition the entry of wastewater to a water-body where it is likely to come in contact with a Wāhi Tapu could be tantamount to a form of desecration in cultural terms.

Mitigation measures 1 Advised mitigation could be in the form of: 1. Where possible, incorporating policies in relation to Waste-water discharge that protect for the requirements of tikanga māori. 2. The application of series of consents, related with each over-flow point or at least catchment specific, as opposed to a global consent which is vehemently objected to, by Manawhenua. 3. The drafting of Waste-water management plans for each network. 4. Investment by CCC in engineering solutions that will prevent entry of waste-water over-flows into fresh-water bodies/ecosystems that are upstream of, and adjacent to, known Wāhi Tapu (such as those at Pūari and Tautahi). 5. Further involvement by Manawhenua in planning around waste-water overflows management.

Impact 2 Waimāori-Freshwater - Waimāori is of significance to Ngāi Tahu for a number of reasons. Water appears in Ngāi Tahu creation traditions, for example Maku (moisture/water) mated with Mahoranuiatea and begat Ranginui – his tears, resulting from continued separation from Papatūānuku, are the rains. Water is a promoter of all life and is as the circulatory blood system of papatuanuku, and thus represents the life blood of the environment. Its condition and treatment are a reflection on the health and regard for Papatūānuku. Water is seen as central to all Māori life and is a taonga cared for and passed on by ancestors to provide and sustain life. It is for the present generation to ensure this taonga is in the same or an improved state for future generations. As previously

27 Mahaanui Kurataiao Ltd Cultural Impact Assessment mentioned there will be entry of waste-water over-flows to the freshwater system of the Ōtakaro/Avon River, during wet-weather event via constructed outfalls linked to known and probable over-flow points in the network.

Mitigation measures 2 (In addition to the above mitigation measures) Advised mitigation could be in the form of: 1. Investment by CCC in engineering solutions that will prevent entry of waste-water over-flows into fresh-water bodies/ecosystems generally and over all catchments within its district. This would include, in the very least, the redevelopment of the gravity network in vulnerable areas (as outlined in BECA:2012), such as those with more frequent overflows. 2. Along with the regional council, maintain regular monitoring of water quality over an array of sites within the respective catchments. 3. Compliance and monitoring report must include a Cultural Health Assessment by a person(s) recommended by Te Ngāi Tūāhuriri Rūnanga, that assesses effects of the overflows on tangata whenua values. 4. A shorter consent period, of at least less than 10 years coupled with an investigation and investment in new technologies, alternative bio-solids management, and water reuse. Opportunities to develop more sustainable waste-water schemes over the long term, with suggestions for staged implementation (as stated in BECA:2012), should be aggressively pursued by CCC.

Impact 3 Taonga Species - Taonga species are native birds, plants and animals of special cultural significance and importance to Ngäi Tahu. Taonga species are largely treasured and prized in a contemporary sense as they link to traditions and whakapapa, and are customary food sources with varying degrees, as directed by statue and relative abundance, of „harvestabiliity‟. A number of taonga species occur within or adjacent to the Ōtakaro/Avon River environ, including freshwater fish, waterfowl and other riverine birds and taonga plant species.

Mitigation measures 3 (In addition to the above mitigation measures) Advised mitigation could be in the form of: 1. Commission and resource studies and monitoring of the effects of wastewater and other discharges on aquatic, riparian and riverine species.

Impact 4 Mahinga Kai - Mahinga kai was and is central to the Ngāi Tahu way of life and is an important social and economic activity. Manawhenua are concerned that mahinga kai in its numerous forms should continue, or be re-invigorated, to be an integral part of their culture. As mentioned in previous sections of this document, a number of species were known to be harvested traditionally from this environ. The taonga species described above, are indicators of former presence and abundance. The continued discharge of waste-water into this environ further denies any future possibility of ecological health relative to any mahinga kai potential. 28 Mahaanui Kurataiao Ltd Cultural Impact Assessment

Mitigation measures 4 (In addition to the above mitigation measures) Advised mitigation could be in the form of: 1. Commission and resource further 'state of the takiwā' studies and mahinga kai assessment.

Ōpāwaho / Heathcote River The Ōpawaho meanders its way through what used to be raupō swamps and out to sea through Te Ihutai (The Avon-Heathcote Estuary). The Ōpawaho was highly valued as an important source of mahinga kai. The foods gathered from the Ōpawaho included tuna (eels), kanakana (lamprey), inaka (whitebait). On the banks of the river plants such as aruhe (fernroot), Tutu berries, and kauru (root of the ti kouka/cabbage tree) were also gathered. Wiremu Te Uki, a kaumatua of Ngāi Tūāhuriri claimed a number of mahinga kai sites including Ōpawaho in 1880 when he gave evidence before the Royal Commission established to investigate the Te Kerēme/Ngai Tahu Claim. By this time, Wiremu Te Uki was one of the few remaining elders who had signed Kemp‟s Deed (the Canterbury Purchase). His claim to mahinga kai on the Ōpawaho was made on behalf of the Kaiapoi Ngai Tahu.

“Ko taku hakoro te kaitiaki o Pohoareare – kei kona a matou tupapaku.” “My father was the guardian of Pohoareare, our dead are buried there.” - Wiremu Te Uki, April 3, 1880.12

The Ōpawaho was an important travel route (Ara tawhito) that was part of the interconnected network of trails that wove through the swampy marshlands/wetlands of Christchurch providing access to specific mahinga kai areas and kāinga nohoanga. In particular, Ōpawaho was the main access route from the coastline and mahinga kai nohoanga located around Te Ihutai (The Avon-Heathcote Estuary) to other connecting trails leading over the Port Hills, to other mahinga kai sites along the Ōpawaho and on to the trail that links up with Te Waihora. Other trails followed the drylands located throughout the interconnected waterways and swamps. The CCC/WCS mapped analysis, related with the consent application, of the 'Existing network performance under 2016 population data and 15-year historical rainfall analysis', indicates the multiple constructed outfalls along, or feeding into, the Ōpāwaho / Heathcote River and several overflow points that connect to these outfalls. The modeling data is as follows: 1. Discharge frequency greater than 2 years = 6 points/sites 2. Discharge frequency less than 2 years = 2 points/sites 3. Discharge frequency less than 1 years = 7 points/sites 4. Discharge frequency less than 6 months = 4 points/sites

29 Mahaanui Kurataiao Ltd Cultural Impact Assessment

Map 3 – Ōpāwaho/Heathcote River, with overflow sites shown by flags

30 Mahaanui Kurataiao Ltd Cultural Impact Assessment

Impact 1 Tikanga - (see Ōtakaro / Avon Impact 1). The Ōpāwaho/Heathcote River was, as previously mentioned in earlier sections an important travel route and mahinga kai for ancestors. An number of Kainga Nohoanga existed along the Ōpāwaho/Heathcote, among the significant of these was Puari and Tautahi, both of these are registered Wāhi Tapu with Heritage New Zealand. In addtion the entry of wastewater to a water-body where it is likely to come in contact with a Wāhi Tapu could be tantamount to a form of dessicration in cultural interms. The CCC/WCS map of the 'Existing network performance under 2016 population data and 15-year historical rainfall analysis', indicates the mutliple constrcuted outfalls along the Ōpāwaho/Heathcote River and several overflow points that connect to these outfalls.

Mitigation measures 1 Advised mitigation could be in the form of: 1. Where possible, incorporating policies in relation to Waste-water discharge that protect for the requirmeents of tikanga māori. 2. The application of „series of consents‟, related with each over-flow point or at least catchment specific, as opposed to a global consent which is vehemently objected to, by Manawhenua. 3. The drafting of Waste-water management plans for each network catchment. 4. Investment by CCC in engineering solutions that will prevent entry of waste-water over-flows into fresh-water bodies/ecosystems that are upstream of, and adjacent to, known Wāhi Tapu (such as those at Pūari and Tautahi). 5. Further involvement by Manawhenua in planning around waste-water overflows management.

Impact 2 Waimāori-Freshwater – (See Ōtakaro / Avon Impact 2)

Mitigation measures 2 (See Ōtakaro / Avon Impact 2 – Mitigation Measures 2)

Impact 3 Taonga Species - (See Ōtakaro / Avon Impact 3)

Mitigation measures 3 (See Ōtakaro / Avon Impact 3 – Mitigation Measures 3)

Impact 4

31 Mahaanui Kurataiao Ltd Cultural Impact Assessment Mahinga Kai - (See Ōtakaro / Avon Impact 4)

Mitigation measures 4 (See Ōtakaro / Avon Impact 4 – Mitigation Measures

Receiving environment - Ihutai / Avon-Heathcote Estuary Te Ihutai is an area of immense cultural and historical importance to Ngāi Tahu. Te Ihutai was part of a larger fishery used by Ngāi Tahu and was famous for its abundance and variety of fish and shellfish, including tuna (eel), kanakana (lamprey), inaka (whitebait), pātiki (flounder) and pīpī. Several settlements were located near Te Ihutai, including Raekura (Redcliffs), Te Kai a Te Karoro (Pā in South Brighton), Ōtākaro (Pā located near the mouth of the Avon River), Tauhinu-korokio (Mt Pleasant) and Te Ana o Hineraki (Moa Bone Point Cave). Whānau used to travel from the Ngāi Tahu stronghold of Kaiapoi Pā to gather kai from Te Ihutai. In 1868 the Native Land Court granted a 10 hectare Māori Reserve at Te Ihutai as a Fisheries Easement. However, in 1956 the Reserve was compulsorily acquired under the Public Works Act 1928, along with surrounding land, for a sewage treatment works for the Christchurch Drainage Board. The taking of Te Ihutai MR 900 has long been a sore point with the owners. The CCC/WCS mapped analysis, related with the consent application, of the 'Existing network performance under 2016 population data and 15-year historical rainfall analysis', indicates one point/site with a constructed outfall (with a discharge frequency greater than 2 years) that would direct discharge into Ihutai / Avon- Heathcote Estuary during a wet-weather event.

“For us it’s about concerns round the effects on mahinga kai and our future generations, any activity that would seek to continue the diminishing quality of Ihutai environs is unacceptable for us…” – Nigel Harris, Trustee, Ihutai

Impact 1 Tikanga - (see Ōtakaro / Avon Impact 1) As previously mentioned Ihutai/Avon- Heathcote Estuary was an immense mahinga kai area for Ngāi Tahu right up until the late 19th/early 20th century. A former Māori Reserve existed with the Wastewater Treatment ponds are today. With the forementioned multiple entry points to both the Ōtakaro/Avon and Ōpāwaho/Heatchote Rivers, Ihutai/Avon- Heathcote Estuary consitutes the resultant receiving environ for any waters that have come into contact with waste-water over-flows.

32 Mahaanui Kurataiao Ltd Cultural Impact Assessment 3. The drafting of Waste-water management plans for each network. 4. Investment by CCC in engineering solutions that will prevent entry of waste-water over-flows into fresh-water bodies/ecosystems that are upstream of, and adjacent to, known Wāhi Tapu (such as those at Pūari and Tautahi). 5. Further involvement by Manawhenua in planning around waste-water overflows management Impact 2 Waitai – coastal waters - Waitai is also of significance to Ngāi Tahu for a number of reasons. Waitai appears in Ngāi Tahu creation traditions, and is personified by Tangaroa, the atua of the sea and progenitor of all marine species. Kaimoana forms a large portion of the only remnant of customarily managed species, and is therefore of high importance and cultural significance.

Mitigation measures 2 (See Ōtakaro / Avon Impact 2 – Mitigation Measures 2)

Impact 3 Taonga Species - (See Ōtakaro / Avon Impact 3). Ihutai, of course has its own unique configuration of contemporarily occurring extant native (and/or endemic) (Taonga-) species. According to Owen (1992), the following taonga species have been observed:

Birds Australasian Gannet / Takapu (Morus serrator), Black Cormorant / Kawau (Phalacrocorax carbo), Little Cormorant / Kawaupaka (Phalacrocorax melanoleucos), Pied Cormorant / Karuhiruhi (Phalacrocorax varius), Spotted Shag / Koautai (Stictocarbo punctatus), White Heron / Kotuku (Egretta alba), Blue Reef Heron / Matuku - moana (Egretta sacra), Australasian Brown Bittern / Matuku (Botaurus poiciloptilus), Royal Spoonbill / Kotuku-ngutupapa (Platalea regia), Paradise shelduck / Putangitangi (Tadorna variegata), Grey Duck / Parera (Anas superciliosa), Grey Teal / Tete (Anas gibberifrons), New Zealand Shoveler / Hono, Kuruwhengi (Anas rhynchotis), New Zealand Scaup / Papanga (Aythya novaeseelandiae), Harrier / Kahu (Circus approximans), Marsh Crake / Koitareke (Porzana pusilla), South Island Pied Oystercatcher (SIPO) / Torea-pango (Haematopus finschi), Variable Oystercatcher / Torea-pango (Haematopus unicolor), Pied Stilt / Poaka (Himantopus leucocephalus), Branded Dotterel / Tuturiwhatu (Charadrius bicinctus), Wrybill / Ngutu parore (Anarhynchus frontalis), Lesser Knot / Huahou (Calidris canutus), Eastern Bar - tailed Godwit / Kuaka (Limosa lapponica), Southern Black-backed Gull / Karoro (Larus dominicanus), Black- fronted Tern / Tarapiroe (Sterna albostriatus), Red-billed Gull / Tarapunga (Larus novaehollandiae), Caspian Tern / Taranui (Sterna caspia), White-fronted Tern / Tara (Sterna striata), New Zealand Kingfisher / Kotare (Halcyon sancta), New Zealand Pipit / Pihoihoi (Anthus novaeseelandiae), Grey Warbler / Riroriro (Gerygone igata), Fantail /Piwakawaka (Rhipidura fuliginosa), Silvereye / Tauhou, Pihipihi (Zosterops lateralis).

33 Mahaanui Kurataiao Ltd Cultural Impact Assessment

Map 4 – Ihutai/Avon-Heathcote Estuary, with overflow sites shown by flags

34 Mahaanui Kurataiao Ltd Cultural Impact Assessment

Fish yellow-eyed mullet, herring /awa (Aldrichetta forsteri), Kahawai (Arripis trutta), sand flounder / patiki (Rhombosolea plebeia), short finned eel / tuna heke (Anguilla australis ), long finned eel / tuna (Anguilla dieffenbachi), sand stargazer (Crapatalus novaezelandiae), whitebait / inanga, mata (Galaxias maculatus attenuatus), brown trout (Salmo trutta),

Shellfish Anemone / kotoretore (Actinia tenebrosa), Mudflat Snail / Whetiko (Amphibola crenata), Ornate limpet / ngakihi (Cellana ornata), Radiate limpet / ngakihi (C. Radians), Spotted whelk / kawari (C. Maculosa), Paua (Haliotis iris), dark rock shell / kaaeo (Haustrum haustorium), estuarine limpet / ngakihi (Notoacmea helmsi), encrusted limpet / ngakihi (Patelloida corticata), Cat's eye / pupu atamarama (Turbo smaragdus), ribbed mussel / pukanikani (Aulacomya ater maoriana), cockle / tuangi, tuaki (Austrovenus stutchburyi), Blue mussel / toritori (Mytilus edulis aoteanus), pipi (Paphies australis), green-shelled mussel / kuutai (Perna canaliculus), Kaikaikaroro (Protothaca crassicosta), wedge shell / hanikura (Tellina liliana).

Mitigation measures (In addtion to the above mitigation measures) Advised mitigation could be in the form of: 1. Commission and resource studies and monitoring of the effects of wastewater and other discharges on aquatic, riparian and riverine species.

Impact 4 Mahinga Kai - (See Ōtakaro / Avon Impact 4)

Mitigation measures 4 (See Ōtakaro / Avon Impact 4 – Mitigation Measures

Pūharakekenui / Styx River Pūharakekenui (Styx River) was an important mahinga kai for local Ngāi Tahu. Foods gathered from Pūharakekenui included tuna (eel), kanakana (lampreys), waikōura (crayfish), and a variety of other native fish. The CCC/WCS mapped analysis, related with the consent application, of the 'Existing network performance under 2016 population data and 15-year historical rainfall analysis', indicates the multiple constructed outfalls along, or feeding into, the Pūharakekenui / Styx River and several overflow points that connect to these outfalls. The modeling data is as follows: 1. Discharge frequency less than 2 years = 2 points/sites 2. Discharge frequency less than 6 months = 2 point/sites Impact 1 Tikanga - (see Ōtakaro / Avon Impact 1). The Pūharakekenui/Styx River was, as previously mentioned in earlier sections an important travel route and mahinga kai

35 Mahaanui Kurataiao Ltd Cultural Impact Assessment for ancestors. An number of Kainga Nohoanga existed along the Pūharakekenui/Styx, among the significant of these was Puari and Tautahi, both of these are registered Wāhi Tapu with Heritage New Zealand. In addtion the entry of wastewater to a water-body where it is likely to come in contact with a Wāhi Tapu could be tantamount to a form of dessicration in cultural interms. The CCC/WCS map of the 'Existing network performance under 2016 population data and 15-year historical rainfall analysis', indicates the mutliple constrcuted outfalls along the Pūharakekenui/Styx River and several overflow points that connect to these outfalls.

Mitigation measures Advised mitigation could be in the form of: 1. Where possible, incorporating policies in relation to Waste-water discharge that protect for the requirements of tikanga māori. 2. The application of series of consents, related with each over-flow point or at least catchment specific, as opposed to a global consent which is vehemently objected to, by Manawhenua. 3. The drafting of Waste-water management plans for each network. 4. Investment by CCC in engineering solutions that will prevent entry of waste-water over-flows into fresh-water bodies/ecosystems that are upstream of, and adjacent to, known Wāhi Tapu (such as those at Pūari and Tautahi). 5. Further involvement by Manawhenua in planning around waste-water overflows management. Impact 2 Waimāori-Freshwater – (See Ōtakaro / Avon Impact 2)

Mitigation measures 2 (See Ōtakaro / Avon Impact 2 – Mitigation Measures 2) Taonga Species - (See Ōtakaro / Avon Impact 3)

Impact 3 Mitigation measures 3 (See Ōtakaro / Avon Impact 3 – Mitigation Measures 3)

Impact 4 Mahinga Kai - (See Ōtakaro / Avon Impact 4)

Mitigation measures 4 (See Ōtakaro / Avon Impact 4 – Mitigation Measures 4)

36 Mahaanui Kurataiao Ltd Cultural Impact Assessment

Map 5 – Pūharakekenui/Styx River, with overflow sites shown by flags

37 Mahaanui Kurataiao Ltd Cultural Impact Assessment Receiving environment - Te Riu o Te Aika Kawa / Brooklands Lagoon

Te Riu o Te Aika Kawa (Brooklands Lagoon) was an important mahinga kai for local Ngāi Tahu where a variety of shellfish, fish and plants were gathered. In 1868 the Crown granted the Pūharakekenui Māori Reserve between Pūharakekenui (Styx River) and Te Riu o Te Aika Kawa (Brooklands Lagoon).

“We as owners of Māori land in what is essentially a receiving environment would not support the granting of this consent, as we have been dealing with discharge issues for years, in particular the industries in Belfast discharging into the Puharakeknui/Styx River...” – Ben Te Aika, Trustee, Puharakekenui

Impact 1 Tikanga - (see Ōtakaro / Avon Impact 1). As previously mentioned Te Riu o Te Aika Kawa/Brooklands Lagoon was a mahinga kai area for Ngāi Tahu. A Māori Reserve exists adjacent to the lagoon today. With the forementioned multiple entry points to the Pūharakekenui River, Te Aika Kawa/Brooklands Lagoon consitutes the resultant receiving environ for any waters that have come into contact with wastewater over-flows.

Mitigation measures Advised mitigation could be in the form of: 1. Where possible, incorporating policies in relation to Waste-water discharge that protect for the requirmeents of tikanga māori. 2. The application of series of consents, related with each over-flow point or at least catchment specific, as opposed to a global consent which is vehemently objected to, by Manawhenua. 3. The drafting of Waste-water management plans for each network. 4. Investment by CCC in engineering solutions that will prevent entry of waste-water over-flows into fresh-water bodies/ecosystems that are upstream of, and adjacent to, known Wāhi Tapu (such as those at Pūari and Tautahi). 5. Further involvement by Manawhenua in planning around waste-water overflows management.

Impact 2 Waitai – coastal waters - (See Ōtakaro / Avon Impact 2) Waitai is also of significance to Ngāi Tahu for a number of reasons. Waitai appears in Ngāi Tahu creation traditions, and is personified by Tangaroa, the atua of the sea and progenitor of all marine species. Kaimoana forms a large portion of the only remnant of customarily managed species, and is therefore of high importance and cultural significance.

Mitigation measures 2 (See Ōtakaro / Avon Impact 2 – Mitigation Measures 2)

Impact 3

38 Mahaanui Kurataiao Ltd Cultural Impact Assessment Taonga Species - (See Ōtakaro / Avon Impact 3) Te Riu o Te Aika/Brooklyn‟s lagoon, also, has its own unique configuration of contemporarily occurring extant native (and/or endemic) (Taonga-) species. According to Owen (1992), the following taonga species have been observed:

Map 6 – Te Riu o Te Aika Kawa / Brooklands Lagoon, with overflow sites shown by flags

39 Mahaanui Kurataiao Ltd Cultural Impact Assessment

Birds Crested Grebe / Puteketeke (Podiceps australis), Australasian Gannet / Takapu (Morus serrator), Black Cormorant / Kawau (Phalacrocorax carbo), Pied Cormorant / Karuhiruhi (Phalacrocorax varius), Little Cormorant / Kawaupaka (Phalacrocorax melanoleucos), Spotted Shag / Koautai (Stictocarbo punctatus), White Heron / Kotuku (Egretta alba), Blue Reef Heron / Matuku - moana (Egretta sacra), Australasian Brown Bittern / Matuku (Botaurus poiciloptilus), Royal Spoonbill / Kotuku-ngutupapa (Platalea regia), Paradise shelduck / Putangitangi (Tadorna variegata), Grey Duck / Parera (Anas superciliosa), Grey Teal / Tete (Anas gibberifrons), New Zealand Shoveler / Hono, Kuruwhengi (Anas rhynchotis), New Zealand Scaup / Papanga (Aythya novaeseelandiae), Harrier / Kahu (Circus approximans)Marsh Crake / Koitareke (Porzana pusilla), South Island Pied Oystercatcher (SIPO) / Torea-pango (Haematopus finschi), Variable Oystercatcher / Torea-pango (Haematopus unicolor), Pied Stilt / Poaka (Himantopus leucocephalus), Branded Dotterel / Tuturiwhatu (Charadrius bicinctus), Wrybill / Ngutu parore (Anarhynchus frontalis), Lesser Knot / Huahou (Calidris canutus)Eastern Bar - tailed Godwit / Kuaka (Limosa lapponica), Southern Black-backed Gull / Karoro (Larus dominicanus), Red-billed Gull / Tarapunga (L.novaehollandiae), Black- fronted Tern / Tarapiroe (Sterna albostriatus), Caspian Tern / Taranui (Sterna caspia), White- fronted Tern / Tara (Sterna striata), New Zealand Kingfisher / Kotare (Halcyon sancta), New Zealand Pipit / Pihoihoi (Anthus novaeseelandiae), Grey Warbler / Riroriro (Gerygone igata), Fantail /Piwakawaka (Rhipidura fuliginosa), Silvereye / Tauhou, Pihipihi (Zosterops lateralis ).

Fish Yellow-eyed mullet, herring /awa (Aldrichetta forsteri), Kahawai (Arripis trutta), lemon sole (Pelotretis flaviliatus), sand flounder / patiki (Rhombosolea plebeia), short finned eel / tuna heke (Anguilla australis), long finned eel / tuna (Anguilla dieffenbachi), whitebait / inanga, mata (Galaxias maculatus attenuatus), sand stargazer (Crapatalus novaezelandiae), quinnat salmon (Oncorhynchus tshawytscha), brown trout (Salmo trutta).

Shellfish Mudflat Snail / Whetiko (Amphibola crenata), estuarine limpet / ngakihi (Notoacmea helmsi), cockle / tuangi, tuaki (Austrovenus stutchburyi), pipi (Paphies australis), wedge shell / hanikura (Tellina liliana).

Impact 4 Mahinga Kai - (See Ōtakaro / Avon Impact 4)

Mitigation measures 4

40 Mahaanui Kurataiao Ltd Cultural Impact Assessment (See Ōtakaro / Avon Impact 4 – Mitigation Measures 4)

17. RECOMMENDATIONS AND CONCLUSION

Manawhenua are very concerned with this proposed consent, as are the wider public as they share concerns for continued discharge, water quality, concern for shellfish standards and enhanced monitoring and access to data (BECA:2012). Manawhenua are passionately opposed to continued discharges of wastewater under any circumstances, and feel a global consent with a long duration is unacceptable. Manawhenua advise CCC to follow the mitigation measures proposed in the section above. Mana whenua have a general aversion to a global consent for this activity, and expects ongoing input and involvement as per an acknowledgement of their Rangatiratanga over their taonga environs and species. Manawhenua seek meaningful participation in the articulation of manawhenua values, implementation of outcomes sought. This participation can be achieved through, for example, working with entities such as Mahaanui Kurataiao Ltd - who can be commissioned to facilitate Te Ngāi Tūāhuriri Rūnanga input. Mahaanui Kurataiao Ltd (MKT) has a general mandate to represent the interests of the primary Papatipu Rūnanga of Canterbury who hold manawhenua rights and interests over the lands and waters within their respective takiwā and provides commercial planning and environmental services to private clients and the general public. Mahaanui Kurataiao Ltd may, in certain instances be best placed to facilitate input from Te Ngāi Tūāhuriri Rūnanga into the ongoing engagement sort by Ngāi Tūāhuriri. In general Mana whenua expect that proposal will recognise and provide for Mana whenua/tangata whenua values, including kaitiakitanga, rangatiratanga and mahinga kai, and would address the protection and restoration of freshwater systems and habitats, and sites of cultural significance to manawhenua/tangata whenua.

18. BIBLIOGRAPHY

Christchurch City Council – City Water and Waste Unit (2007) Sewer Overflow Response Plan.

Christchurch City Council (2012) Compliance Strategy Agreement for wet weather wastewater overflows to rivers.

Environment Canterbury (2010) Decision of Environment Canterbury on a Resource Consent Application – CRC092692

Keane, B.(nd) 'Marae protocol – te kawa o te marae - Basic marae etiquette', Te Ara - the Encyclopedia of New Zealand, http://www.TeAra.govt.nz/en/marae-protocol-te-kawa-o-te-marae/page-4 (accessed 11 January 2017) 41 Mahaanui Kurataiao Ltd Cultural Impact Assessment

Basil Keane, 'Marae protocol – te kawa o te marae - Basic marae etiquette', Te Ara - the Encyclopedia of New Zealand, http://www.TeAra.govt.nz/en/marae-protocol-te-kawa-o-te-marae/page-4 (accessed 23 February 2017)

Iwi Chairs Forum, „Fresh Water‟, http://iwichairs.maori.nz/our-kaupapa/freshwater/ (accessed 23 February 2017)

Lang, M., Orchard, S., Falwasser, T., Rupene, M., Williams, C., Tirikatene- Nash, N. & couch, R. (2012) State of the Takiwā: Te Āhuatanga o Te Ihutai. Te Rūnanga o Ngāi Tahu. Christchurch.

Mead, H.M. (2003) Tikanga: Living by Māori Values, Huia Publishers, Wellington, N.Z (Pgs, 48,98).

Ministry for the Environment/ Manatū Mō Te Taiao (2016) Next steps for fresh water: Consultation document. Wellington: Ministry for the Environment/Manatū Mō Te Taiao.

NIWA (2008) The ecological effects of wastewater overflow discharges in waterways of the Avon River/Ōtakaro catchment. NIWA Client Report.

Orchard, S., Sarson, R., Lang, M., Falwasser, T., Rupene, M., Williams, C. & Tirikatene-Nash, N. (2012) Cultural Health Assessment of the Puharakekenui / Styx River, Te Riu o Te Aika Kawa / Brooklands Lagoon and catchment. Te Rūnanga o Ngāi Tahu. Christchurch.

Owen, S-j (ed.) (1992) The Estuary Where Our Rivers Meet the Sea : Christchurch's Avon-Heathcote Estuary and Brooklands Lagoon. Parks Unit, Christchurch City Council. Christchurch, N.Z.

Pauling, C., Lenihan, T.M., Rupene, M., Tirikatene-Nash, N. & Couch, R. (2007) State of the Takiwā: Te Āhuatanga o Te Ihutai. Te Rūnanga o Ngāi Tahu. Christchurch.

Tau, H.R. & Tau, R.T.M. (nd) Mahinga Kai, evidence from the Tūāhuriri area, including the submissions of Rawiri Te Maire Tau and Henare Rakiihia Tau. Wai-27 Document #H6.

Taylor, W.A. (1952) Lore and History of the South Island Māoris. Bascands. Christchurch, N.Z.

Unknown author (2016) Wastewater Overflow Consent – Summary for Water Wānanga. 23 June 2016

URS (2008) Assessment of the Effects on the Environment – Discharge of Overflows from the Christchurch Wastewater Network to the Avon and Heathcote Catchments. Report prepared for Christchurch City Council (Network Planning and Asset Management Unit). 19 December 2008.

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