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SAR 04-83-03-83 DOCDM-2845010 29 July 2016 Southland Water And

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SAR 04-83-03-83 DOCDM-2845010 29 July 2016 Southland Water And SAR 04-83-03-83 DOCDM-2845010 29 July 2016 Southland Water and Land Plan Southland Regional Council Private Bag 90116 INVERCARGILL 9840 Attention: Anita Dawe Dear Anita, PROPOSED SOUTHLAND WATER AND LAND PLAN 3 June 2016 Please find enclosed the submission by the Director-General of Conservation in respect of the proposed Southland Land and Water Plan 2016. The submission identifies the Director- General’s concerns. Please contact Ken Murray in the first instance if you wish to discuss any of the matters raised in this submission (03 3713759 [email protected]). Yours sincerely Tony Preston Operations Manager Murihiku Department of Conservation Te Papa Atawhai DOC-2845010 Christchurch Shared Services Private Bag 4715, Christchurch Mail Centre, Christchurch 8140, New Zealand www.doc.govt.nz RESOURCE MANAGEMENT ACT 1991 SUBMISSION ON PROPOSED SOUTHLAND WATER AND LAND PLAN 2016 TO: Southland Regional Council SUBMISSION ON: Proposed Southland water and Land Plan 2016 NAME: Director-General of Conservation ADDRESS: RMA Shared Services Department of Conservation Private Bag 4715 Christchurch Mail Centre 8140 Attn: Ken Murray STATEMENT OF SUBMISSION BY THE DIRECTOR-GENERAL OF THE DEPARTMENT OF CONSERVATION Pursuant to clause 6 of the First Schedule of the Resource Management Act 1991 (RMA), I, Tony Preston, Operations Manager Murihiku, Department of Conservation acting upon delegation from the Director-General of the Department of Conservation, make the following submission in respect of the Proposed Southland Water and Land Plan to the Southland Regional Council. 1. This is a submission on the Proposed Southland Water and Land Plan. 2. The specific provisions of the Proposed Plan that my submission relates to are set out in Attachments 1 to this submission. The decisions sought in this submission are required to ensure that the Proposed Southland Water and Land Plan: a. Gives effect to the New Zealand Coastal Policy Statement 2010 and the National Policy Statement for Freshwater Management 2014. b. Promotes the sustainable management of natural and physical resources in particular the protection of the significant natural resources of Southland. c. Recognises and provides for the matters of national importance listed in section 6 of the Act and to have particular regard to the other matters in section 7 of the Act. d. Gives effect to the decisions of the Environment Court on the Proposed Southland Regional Policy Statement. e. The changes sought are necessary, appropriate and sound resource management practice. 3. I seek the following decision from the Council: 3.1 That the particular provisions of Proposed Southland Water and Land Plan that I support, as identified in Attachment 1, are retained. 3.2 That the amendments, additions and deletions to Proposed Southland Water and Land Plan sought in Attachments 1 are made. 1 3.3 Further, consequential or alternative relief to like effect to that sought in 3.1 – 3.2 above. 4. I wish to be heard in support of my submission and if others make a similar submission, I will not consider presenting a joint case with them at the hearing. Tony Preston Operations Manager Murihiku Pursuant to delegated authority From Lou Sanson Director-General of Conservation Date: 29 July 2016 Note: A copy of the Instrument of Delegation may be inspected at the Director-General’s office at Conservation House, Whare Kaupapa Atawhai, 18/32 Manners Street, Wellington 6011. 2 ATTACHMENT 1: PROPOSED SOUTHLAND WATER AND LAND PLAN SUBMISSION BY THE DIRECTOR-GENERAL OF CONSERVATION The specific provisions that my submission relates to are set out in Attachment 1. My submissions are set out immediately following these headings, together with the reason and the decision I seek from the Council. The decision that has been requested may suggest new or revised wording for identified sections of the proposed plan. This wording is intended to be helpful but alternative wording of like effect may be equally acceptable. Text quoted from Proposed Southland Water and Land Plan is shown in Italics. The wording of decisions sought shows new text as underlined and original text to be deleted as strikethrough. Unless specified in each submission point my reasons for supporting are that the policies are consistent with the purposes and principles of the Resource Management Act 1991 (RMA). PC REF PLAN PROVISION POSITION AND REASON RELIEF SOUGHT GENERAL Whole of Plan All At present, the proposed RPS is still subject to Amend the proposed Southland Water and Land Plan appeals in the Environment Court. (pSWLP) to give effect to the Southland Regional Policy Statement once each chapter has been determined by the Environment Court. Section 1 INTRODUCTION Page 13 New Provision Approximately 57% of Southland is managed by the Include a new section of the Plan after Water Statutory Context of Department of Conservation. The values of these Conservation Orders including the following: Plan areas include the pristine water quality of Te Wähipounamu South West New Zealand World Other Management Plans and Strategies Heritage Area. Approximately 57% of Southland is managed by the Under s66(2)(c) RMA Council shall have regard to Department of Conservation. Activities on these lands management plans and strategies prepared under and waters are also managed under plans and strategies other Acts. These include the Fiordland National Park made pursuant to the National Parks Act 1980, the Management Plan, Rakiura National Park Conservation Act 1987 and the Reserves Act 1977: Management Plan and Stewart Island Rakiura Fiordland National Park Management Plan, Rakiura Conservation Management Strategy, Mainland National Park Management Plan and Stewart Island Southland West Otago Conservation Management Rakiura Conservation Management Strategy, and a Strategy. A Southland Murihiku Conservation Southland Murihiku Conservation Management Strategy. Management Strategy has been approved but will be A significant part of South West New Zealand is operative on 1 September 2016. recognised as being internationally significant as part of 3 PC REF PLAN PROVISION POSITION AND REASON RELIEF SOUGHT Te Wähipounamu South West New Zealand World Heritage Area. This area is recognised among other matters for its pristine water quality. Page 14 Issues Support in part. Retain Issues Water Quality with the following Issues Water Quality The sensitive water bodies include lagoons such as amendments to the second paragraph: Waituna and Te Waewae and coastal lakes such as Southland’s main catchments end with estuaries while George. smaller catchments can have lagoons and lakes which In Te Anau Basin there are lakes (such as Thomas) or are all particularly sensitive to nutrient and sediment parts of lakes (Lower Waiau Arm of Lake Manapouri) loads. which are sensitive to nutrients and sediment enrichment. Page 14-15 Issues Support. Retain Water Quantity Surface Water and Groundwater Issues Water Quantity The issues as outlined accurately reflect the Issues as notified. Southland situation. Page 15 Issues Support in part. Retain Issues Soil Resources as notified with the Soil Resources Two issues are missing, loss of soil and soil following new sentence added: compaction, through inappropriate land use. Inappropriate use of land can result in soil erosion or soil compaction. Page 16 River and Lake Beds Support in part. Retain Issues River and Lake Beds as notified with the Issues Southland’s river beds have nationally significant following new sentence added after the first sentence in braided river bird values in particular the major the first paragraph: habitat of the nationally critical black billed gull and ...and food gathering. Southland’s braided river beds are nationally endangered black fronted tern and a nationally significant habitat for braided river birds, nationally vulnerable banded dotterel. These species being a national stronghold for the threatened black require bare gravel bars for successful roosting and billed gull and important for the threatened black nesting. fronted tern and banded dotterel. Page 16-17 Indigenous biodiversity Support in part. Retain Issues Indigenous biodiversity as notified with the Issues The term “ecological services” is used. To be following amendments: consistent with the proposed Regional Policy In the first paragraph amend the third sentence to read: Statement (pRPS) the term ecosystem services ...and provision of ecological ecosystem services should be used and its definition from the RPS including protection of soil, reduction of flood peaks and included in this plan. Furthermore, the importance of the maintenance of stream flow during droughts. the ecosystem services should be highlighted including protection of soil, reduction of flood flow peaks and the maintenance low flows. 4 PC REF PLAN PROVISION POSITION AND REASON RELIEF SOUGHT Physiographic Zones Page 18-21 All of the Support in part. Amend the physiographic units to reflect the Council’s science as outlined in Physiographic The concept of physiographic zones is strongly Physiographics of Southland Part 3 and other relevant Council science. In particular Zone supported. However it is essential the descriptions it is essential to take into account the existing water quality data and trends and Descriptions of the physiographic pathways reflect the Council’s whether the water quality breaches or will breach in future this plans water quality and Policies science. Secondly within these physiographic zones objectives and standards. It is also essential to take into account
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