Submission on Publicly Notified District Plan Clause 6 of Schedule 1, Resource Management Act 1991 To: Hamilton City Council Date: 29/3/2013 Submission method: on-line Submission number: 305 Submitter Details: Company Email id: [email protected] Contact Name: The Waikato Tree Trust Name: The Waikato Tree Trust Address: c/- 26 Eton Drive, Hillcrest, Hamilton, 3216, New Zealand Phone daytime: 64 07 8566563 Mobile: I wish to be heard in support of my submission. If others make a similar submission, I will consider presenting a joint case with them at a hearing. I could not gain an advantage in trade competition through this submission. This is a submission on the Hamilton City Council Proposed District Plan (the Proposal): The specific Support, My submission is: I seek the following decision from the local authority: provision(s) of Oppose the proposal or that my Support submission in part relates to is: 20.1 Purpose Support Note; We would appreciate for "Purpose", that it would c) The sites are identified on the Planning Maps and are listed in Schedule 9C: in part be desirable to comment specifically identifying the Long Significant Natural Areas in Volume 2, Appendix 9. The significance of a site is tailed bat (Chalinolobus tuberculata) population within the based on the ecological significance of its indigenous vegetation. The sites were city as this is a unique fauna characteristic of the city. We assessed using the criteria for determining significant indigenous vegetation and also seek that where possilbe when there is inclusion in significant habitats of indigenous fauna contained in the Regional Policy Statement (2000). Also included is a map of the identified long tailed bat (Chalinolobus commnets in relation specifically to Natural Environments tuberculata) roost sites within the city and surrounding rural area. that proetction of this species is mentioned. A survey of the city for long tailed bats in 2012 identifed locations that e) Significant Natural Areas include: the bats frequently roost, an inclusion of this map would be useful to include it the Significant Natural Areas. i. Identified areas of the Waikato River corridor and gully systems. ii. Peat lakes and wetlands. iii. Remnant indigenous vegetation or trees, specifically in relation to areas identified that long tailed bats (Chalinolobus tuberculata)) roost. iv. Other areas that contribute to indigenous biodiversity. Significant Support 20.2.1 Significant Natural Areas are protected, Significant Natural Areas 20.2.1 Objective and Policies Natural Areas in part maintained, restored and enhanced. Agree, Yes like the 20.2.1 inclusion of 'enhanced' 20.2.1a The values and Objective Policies Objective and characteristics that define the City’s Significant Natural 20.2.1 20.2.1a Policies Areas shall be identified. Has this not already been Significant Natural Areas are The values and characteristics that define the completed? If so why not? How can a plan be written to protected, maintained, restored City’s Significant Natural Areas shall be identified. protect areas that haven't been identified or characteristics and enhanced. not yet defined!!!. This is essential for the District Paln, 20.2.1b without this what are we writing objectives and policies Areas of indigenous vegetation, biodiversity and for! 20.2.1c i. The character and degree of modification, habitats of indigenous fauna shall be scheduled as damage, loss or destruction that will result from the Significant Natural Areas. activity. ii. The duration and frequency of effect (e.g. long- 20.2.1c term or recurring effects). iii. The magnitude or scale of The particular values and characteristics that effect, including effects on ecological processes supporting make an area a Significant Natural Area shall be or provided by the Significant Natural Area. iv. The protected from adverse effects by having regard irreversibility of effect. v. The resilience of the area to to: assimilate change. Who determines the resilience of the i. The character and degree of modification, area to assimilate change? If the area is deemed a damage, loss or destruction that will result from 'Significant Natural Area' surely it should be enhanced not the activity. compromised by a determination of resilence to assimulate ii. The duration and frequency of effect (e.g. change. Only include if change is proactive i.e. enhancing long-term or recurring effects). an existing remnant that has extensive pest plant vegetation iii. The magnitude or scale of effect, including presnt that requires removal etc, may require methods to effects on ecological processes supporting or remove that could be deterimental to other flora in short provided by the Significant Natural Area. iv. The irreversibility of effect. term. vi. The opportunities to minimise pre-existing or v. The resilience of the area to assimilate potential adverse effects (e.g. restoration or enhancement), change. where avoidance is not practicable. As above, include if proactive enhancement. However could be seen as a vi. The opportunities to minimise pre- indication that it is OK to transition areas vii. The existing or potential adverse effects (e.g. probability of effect. How is this measured? include only restoration or enhancement), where avoidance is due to exclusion may warrent no consideration to not practicable. probability of effects and therefore no refence can be vii. The probability of effect. made. viii. Cumulative effects. Surely cumulative effects MUST be proven. In the area of new develoments the viii. Cumulative effects. cumulative efffects may not be known for some time or evidence may take years to gather i.e. therefore research. ix. Need for, or purpose of, the works. This poses the question who makes the assessment and 20.2.1d how is the information provided? e.g. a major inland port Adverse effects of development on the City’s development may have a signifcant effect on "Signifcant Significant Natural Areas shall be avoided. Natural Areas" due to the increased risk of a biosecurity 20.2.1e breach (opening many containers that could contain The reduction, fragmentation and isolation of biological threats to native flora a & fauna). Is it therefore indigenous ecosystems and habitats shall be a compromise to offset economic gains for the avoided. environmental degradation? ix. Need for, or purpose of, 20.2.1f the works. The greater good of the environment?, society? The loss or disruption of corridors or connections or the bank? Need to consider however could be seen to linking indigenous ecosystems and habitat be used in an argument to justify removal of significant fragments shall be avoided. vegetation or habitat distruction. 20.2.1d Adverse effects 20.2.1g of development on the City’s Significant Natural Areas The loss or disruption to migratory pathways in shall be avoided. 20.2.1e The reduction, fragmentation water, land or air shall be avoided. and isolation of indigenous ecosystems and habitats shall 20.2.1h be avoided. 20.2.1f The loss or disruption of corridors or Adverse effects on ecosystems resulting from connections linking indigenous ecosystems and habitat changes to hydrological flows, water levels and fragments shall be avoided. Agree, specific to long tailed water quality shall be avoided. bats and their movements around the city. 20.2.1g The 20.2.1i loss or disruption to migratory pathways in water, land or The loss or disruption of protective buffering of air shall be avoided. Agree 20.2.1h Adverse effects on indigenous ecosystems shall be avoided. ecosystems resulting from changes to hydrological flows, 20.2.1j water levels and water quality shall be avoided. Agree, The loss of ecosystem services shall be avoided. water quality in the city streams and aquatic ecosystems needs to improve significantly, require filters in stormwater 20.2.1k pipes. (Kevin Collier paper) 20.2.1i The loss or disruption The loss, damage or disruption to ecological of protective buffering of indigenous ecosystems shall be processes, functions and ecological integrity shall avoided. 20.2.1j The loss of ecosystem services shall be be avoided. avoided. 20.2.1k The loss, damage or disruption to 20.2.1l ecological processes, functions and ecological integrity The loss or reduction of the cultural and spiritual shall be avoided. 20.2.1l The loss or reduction of the association with indigenous biodiversity which are cultural and spiritual association with indigenous held by tangata whenua shall be avoided. biodiversity which are held by tangata whenua shall be 20.2.1m avoided. 20.2.1m Non-native pest species within Non-native pest species within Significant Natural Significant Natural Areas shall be eradicated. 20.2.1n The Areas shall be eradicated. loss of habitat that supports indigenous species under 20.2.1n threat of extinction shall be avoided. 20.2.1o Significant The loss of habitat that supports indigenous Natural Areas shall be restored and enhanced to meet at species under threat of extinction shall be least the 10% threshold for habitat sustainability. Definitely avoided. agree! This is a minimum requirement! 20.2.1o Significant Natural Areas shall be restored and enhanced to meet a minimum of10% of the cities total land area for habitat sustainability. Significant Support 20.2.1 Significant Natural Areas are protected, Significant Natural Areas 20.2.1 Objective and Policies Natural Areas in part maintained, restored and enhanced. Agree, Yes like the 20.2.1 inclusion of 'enhanced' 20.2.1a The values and Objective Policies Objective and characteristics that define the City’s Significant Natural 20.2.1 20.2.1a Policies Areas shall be identified. Has this not already been Significant Natural Areas are The values and characteristics that define the completed? If so why not? How can a plan be written to protected, maintained, restored City’s Significant Natural Areas shall be identified.