BEFORE THE ENVIRONMENT COURT AT CHRISTCHURCH (ENV-2012-CHC-138, 139)

IN THE MATTER OF Appeals under sections 120 and 121 of the Act

BETWEEN D R MCINTYRE AND WAITAKI TRUSTEES (GOLDEN ACRES LIMITED) Appellant (ENV-2011-CHC-138)

AND

BETWEEN C E F KIDD AND G W KIDD

Appellant (ENV-2011-CHC-139

AND CANTERBURY REGIONAL COUNCIL Respondent

EVIDENCE IN CHIEF OF STEPHEN KENNETH BROWN ON BEHALF OF THE ROYAL FOREST AND BIRD PROTECTION SOCIETY OF NEW ZEALAND INCORPORATED AND THE MACKENZIE GUARDIANS INCORPORATED 22 December 2017

Royal Forest and Bird Protection Society of New Zealand Inc. PO Box 2516 Christchurch 8140 Solicitor acting: Peter Anderson 021 2866992 [email protected]

Duncan Currie/Ruby Haazen Richard Allen Counsel for Mackenzie Guardians Solicitor 8 Mt Eden Road Unit 1, 26 Putiki Street Eden Terrace PO Box 78326 AUCKLAND Grey Lynn Ph: (021) 144 3457 AUCKLAND E: [email protected]

1. My name is Stephen Kenneth Brown. I hold a Bachelor of Town Planning degree and a post- graduate Diploma of Landscape Architecture. I am a Fellow and past President of the New Zealand Institute of Landscape Architects, an Affiliate Member of the New Zealand Planning Institute.

2. This statement of evidence has been prepared in response to the appeals over the granting of consent for irrigation of land owned by C.E.F. and G.W. Kidd (referred to in my evidence as the Kidd Block) and D.R. McIntyre and Waitaki Trustees Golden Acres Limited (referred to as the McIntyre Block). It has been prepared on behalf of the Royal Forest And Bird Protection Society Of New Zealand Incorporated and the Mackenzie Guardians Incorporated.

PROFESSIONAL EXPERIENCE

3. I have practised as a landscape architect for 36 years. During that period, the great majority of my professional practice has focussed on landscape assessment and planning. This has included evaluating the landscape, natural character and amenity effects associated with large scale proposals, such as Auckland’s Waterview Connection (SH16 / SH20) project, the recently consented East West Link project, and the two tranches of King Salmon marine farm proposals for the Marlborough Sounds.

4. I have also undertaken a large number of assessments of landscape and natural character characteristics and values in different parts of New Zealand, including, for example, the West Coast Region and related districts, the Auckland Region (twice) and the Far North District. Relevant projects and studies are set out in my Appendix A. In 2006 I was also part of a team managed by Urbis Ltd that was awarded the (UK) Landscape Institute’s Strategic Planning Award for the “Landscape Value Mapping Study of Hong Kong”. I developed the assessment method and assessment criteria employed in that study.

5. Of most relevance to the current proceedings, I undertook an evaluation of the northern two- thirds of the Mackenzie Basin in 2016 as part of my analysis of the Basin for the Plan Change 13 Appeals. I prepared evidence for those appeals and attended the Environment Court

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hearing, which addressed them. I will further explain the relevance of that work to the current appeals in my statement.

CODE OF CONDUCT

6. I confirm that I have read the Code of Conduct for Expert Witnesses contained in the Environment Court Practice Note 2014 and that I agree to comply with it. I further confirm that I have considered all the material facts that I am aware of that might alter or detract from the opinions that I express, and that this evidence is within my area of expertise, except where I state that I am relying on the evidence of another person.

7. This statement has been prepared in response to the appeals arising from the Canterbury Regional Council’s decision to decline water take consents for the Kidd and McIntyre blocks, north to northwest of Lake Benmore within the Mackenzie Basin. As a result, I have visited the Mackenzie Basin and undertaken an evaluation designed to assist the Court in its deliberations over PC13.

PRELIMINARY COMMENTS: THE WITHDRAWAL OF THE KIDD APPEAL & CHANGES TO THE McINTYRE PROPOSAL

8. This statement has been prepared in response to both the Kidd and McIntyre appeals. Since nearly of it was prepared, C E F and D G W Kidd have withdrawn their appeal and Mr McIntyre has reduced the scale of his irrigation proposals by approximately 50%. These are significant changes.

9. Unfortunately, I have not had the time to recast my statement in line with those changes, while my Annexures still address both the Kidd and McIntyre blocks, as well as the wider setting afforded by the Mackenzie Basin. I was also unaware of them when I undertook my recent site visit, which compounds the difficulty of responding to the changes to the appeals. Even so, in response to the withdrawal of the Kidd appeal and amendments to the McIntyre application, I have added a brief section at the end of my Conclusions which attempts to summarise how that withdrawal affects my findings. In all other respects, my evidence remains as drafted up to the 20th December 2017.

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SCOPE OF EVIDENCE

10. I was asked to review the evidence of Christopher Glasson on behalf of the applicants, Peter Rough on behalf of the Canterbury Regional Council, and to visit both the Kidd and McIntyre sites in order to evaluate the landscape effects of both irrigation proposals. I have also been asked to explore those effects in the context of the wider-ranging proposals for irrigation across the Mackenzie Basin that I addressed in my 2016 evidence on PC13, so as to reach findings about the cumulative effects and changes that irrigation proposals – of the sort proposed by Messrs Kidd and McIntryre – are having on the wider landscape character and values of the Basin.

11. I have undertaken that evaluation. At the outset, I need to make it clear that I don’t disagree with the description of both irrigation sites, as outlined in the evidence of Mr Glasson, nor with his analysis of much of the wider landscape setting afforded them. In this regard, my views are also aligned with those of Mr Rough, who makes the point in his statement that he feels little is to be gained from reiterating much of the material in Mr Glasson’s evidence, which provides and introduction to the sites and their landscape surrounds.

12. Consequently, my evidence focuses on the following matters:

a) The changes to the wider Mackenzie Basin landscape and its Subzone that led to PC13;

b) The Basin’s wider characteristics and values;

c) Recent and on-going changes to the Basin’s wider characteristics and values;

d) The ‘place’ of the Kidd and McIntryre blocks within this landscape matrix;

e) Visual exposure and other effects;

f) My findings about the effects of irrigating the Kidd and McIntyre blocks.

13. In reaching my findings about the effects of the both consents, I have also taken into account the evidence of ecologist, Dr Susan Walker. As you will see, there is close alignment between the views that she expresses in relation to some aspects of the current proposals and my own, although I am not an ecologist and have avoided stepping beyond my area of expertise. Nevertheless, as with PC13, I have found Dr Walker’s evidence provides important ‘reference

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points’ in relation to some key matters addressed by Messrs Glasson and Rough – such as the significance and prevalence of hieraceum within the Mackenzie Basin and the viability of pastoral planting within the proposed buffer areas around each irrigation circle.

INTRODUCTION

14. As with my PC13 evidence, I need to start by indicating that, even though I live and work (for the most part) within Auckland, I have visited and stayed within the Mackenzie Basin over many years – in fact, decades – and consider that I know it reasonably well, albeit not with the same familiarity and intimacy as those who live and work within the Basin. Even so, I have visited it in both a professional capacity, and also as a ‘visitor’: passing through on the way to Wanaka, Queenstown and Mt Cook / The Hermitage far more times than I can recall, as a guest at Tekapo village (once being foolish enough to swim in the lake) and Omarama, while skiing at Roundhill, Mt Dobson and Ohau ski fields, and as a student undertaking field trips to the Pukaki Basin, Mt Cook and the Tasman Glacier.

15. In 2009 I was briefed to assess the effects of proposed irrigation schemes on behalf of a number of Upper Waitaki landholdings owned by Southdown Holdings Ltd, Five Rivers Ltd, Williamson Holdings Ltd, and Killermont Station Ltd. After initially presenting evidence on this matter to Environment Canterbury, I was subsequently asked to prepare evidence for additional intensive dairying proposals. After much consideration, I decided that I could not endorse or support proposals for further dairy intensification within the Upper Waitaki catchment. I was involved in preliminary discussions between Richard Peacock in 2010 (then owner of Glen Eyrie Downs and one of the water right applicants) and EDS, but these occurred without achieving any merger of views over the future of the Upper Waitaki area.

16. In 2013, I was invited to visit Simons Hill Station, abutting SH8, southeast of Lake Pukaki. Again, I was asked if I could support irrigation proposals to support dairy intensification. After much deliberation, I decided that I was unable to support the landowner’s proposals for irrigation of large parts of that property.

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WIDER CONTEXT – UNDERLYING THREATS

17. In my PC13 evidence, I raised the following concerns about where the landscape of the Mackenzie Basin and, to a certain extent, our national landscape, is heading (paragraphs 12 to 17): 12. I raise these matters because I need to make it clear that I have not come into the current appeals without much forethought about the situation unfolding within the Mackenzie Basin. The issues of tussock decline and loss, rabbits, forestry, and wilding trees, even the effects of past hydro-electricity development and more recent rural-residential ‘sprawl’ near Twizel, are hardly new. However, I believe that the recent acceleration of change within the Basin has left us now perilously close to a landscape ‘tipping point’, beyond which it would be all too easy to see one of this nation’s truly iconic landscapes irrevocably changed to the point where its sense of place and identity are largely lost. I believe this would be a tragic outcome for the Mackenzie Basin, Canterbury Region and nation as a whole. Indeed, I see the Mackenzie Basin as symbolic of a range of landscape issues that are confront New Zealand presently – where in light of cumulative and accumulative effects, the very sense of place associated with key landscapes is being eroded and, in some instances, lost. I regard the Mackenzie Basin as one of these places.

13. The extent of change and the importance of protecting the spectrum of landscape types was made very clear to me during a project in 2012. While undertaking an initial assessment of landscape and natural character values within the West Coast Region, I met a small group of Swiss tourists at Cape Foulwind, near Westport. I had just completed an initial reconnoitre of the coastal landscape from Oparara near the start or end of the Heaphy Track in the Buller District, to Big Bay at the bottom of the Westland District. The tour group explained to me that they had spent 3½ weeks touring both the North and South Islands and were thoroughly fed up with seeing endless ‘bare’ pasture and production forestry’ – not the pristine environments and landscapes of promotional legend. I countered that more than a third of the country’s landscape heritage is protected in national parks, but their quick, rather perceptive, repost to this, was that much of our national park system focuses on the snow, ice and scree of the Southern Alps and the three volcanoes of the Volcanic Plateau. Rural New Zealand, including parts of Central Otago and the Mackenzie Basin, had rather underwhelmed them.

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14. What their comments highlighted is, in my view, the increasing ‘internationalisation’ of New Zealand’s rural landscapes. More over, the landscapes of a country once renowned for its diversity are – outside the national parks network – developing an increasing ‘sameness’, a homogeneity of elements and patterns, that is irrevocably eroding the specialness of New Zealand as a whole.

15. Ben Espie, at his paragraph 3.16 comments that: “…. the fragmentation or visual division of the empty, open landscape of the Mackenzie is a significant threat to its character and the visual amenity that it provides….”. This implies that the Basin’s landscape is becoming increasingly compartmentalised, losing its vast, expansive qualities. For example, when I recently drove past Simons Hill Station next to SH8, its now verdant plane of green pasture directly abutting the highway, together with production forestry straddling the hill slopes south of Simons Hill, reminded me that this iconic part of the South Island is progressively losing its distinctiveness and the very qualities that until recently set it apart from most of the rest of New Zealand. The repetition of international models of rural production places the Mackenzie Basin at risk of losing its uniqueness and much of its sense of place.

16. Similarly, when I first visited Glen Eyrie Station with Richard Peacock in 2009, I explained to Mr Peacock that I was concerned about the loss of identity within both the upper Waitaki Basin and wider Mackenzie country, faced with the potential outward spread of dairy pasture and irrigation from between Lake Ruataniwha and Omarama, particularly (at that stage) towards Lake Ohau and the Lindis Pass. He countered by telling me that he had spent millions of dollars removing wilding pines from his own property near Omarama and then drove me north of Twizel, pointing out the expanse of pine forestry and wilding conifers evident near Lake Pukaki, west of Twizel, and climbing into the foothills north of Lake Ohau. He very succinctly commented that soon all of the Basin landscape ‘would be Canada’.

17. The situation has hardly improved since that 2009 site visit. Attachment A to the Council’s Section 293 Report (addressing the Environment Court’s First, Sixth, Seventh, Eight and Ninth Decisions, and its comments on matters raised in relation to PC13) includes the Court’s commentary on the risks of taking no action to better manage the Mackenzie Basin landscape:1

1 Mackenzie District Council Plan Change 13 s293 Report (27 May 2016), p.22 addressing the First Environment Court Decision

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[250] As for the risks of acting or not acting, we agree with the Council’s Section 32 report that “There is a very real risk that if action is not taken soon that some very important landscape […] could be degraded by some very inappropriate development and subdivision”. Further, the operative district plan and PC13(N) raise the probability of degradation to the landscape (and also potentially ecosystems) from further areas of intensified farming activities.“”

18. Consequently, the Mackenzie Basin is clearly faced with multiple ‘threats’, which I would summarise as follows:  Ecological degradation and the loss of its distinctive grasslands habitat and landscape;  The greening of the Basin;  Production forestry and shelterbelts;  Wilding pines;  Sporadic development;  Land and landscape fragmentation; and  The ‘internationalisation’ of the Basin landscape and loss of both its character and identity.

19. Clearly I am far from alone in perceiving these threats, and the pressure being exerted on it comes from both from the expectations of generations of New Zealander’s who regard it as an inspirational, even iconic, landscape – although the latter is questionable: a matter that the PC13 decision explores at paragraph 47 – but also the pastoral landowners / lessees who, as tenure review progresses, see the opportunity to transform the agricultural production model across the Basin. Hence, I felt that my reference at paragraph 12 (above) to the Mackenzie Basin being at a ‘tipping point’ was entirely appropriate, and the PC13 decision appears to agree with me on that point:

[365] Mr Caldwell submitted:

112 The reality is that the Basin has undergone significant change as a result of irrigation consents, and other factors. Various expert evidence addressed the degree of change, with reference to the concept of a "tipping point". Mr Densem and Ms Lucas consider the Basin is at or at least approaching its tipping point in terms of landscape effects. Mr

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Brown opined the Basin was almost beyond it. Using the operative date will only increase the area in the Basin that is subject to less stringent control, and will further threaten the Basin breaching its tipping point. It is therefore submitted restricting the exemption for water permits to those granted prior to 14 November 2015, and reserving control over matters that relate to landscape protection, is most appropriate.

We accept that submission and consider a policy along general lines of 3B13(3) would be the most effective way of addressing the issues.

20. Furthermore, Ben Espie, who appeared for Pukaki Downs Station at the PC13 hearing, commented at paragraph 3.16 of his evidence that: “…. the fragmentation or visual division of the empty, open landscape of the Mackenzie is a significant threat to its character and the visual amenity that it provides….”. This implies that the Basin’s landscape is becoming increasingly compartmentalised, losing its open expansive palette of finely textured grasslands that inexorably carry the eye to the surrounding hills and alps.

21. Graeme Densem also pointed out in paragraphs 14, 52 and 53 of his PC13 evidence that the traditional consolidation of pastoral irrigation and oversowing within ‘sheltered homestead blocks’ has fundamentally changed as a result of the leasehold tenure review process. This has, in his opinion, resulted in accelerated ‘conversion’ of the former dry stocking grasslands since 2009.

22. In a related vein, when I first visited Glen Eyrie Station with Richard Peacock in 2009, I explained to him that I was concerned about the loss of identity within both the upper Waitaki Basin and wider Mackenzie country, faced with the potential outward spread of dairy pasture and irrigation from between Lake Ruataniwha and Omarama, particularly (at that stage) towards Lake Ohau and the Lindis Pass. He countered by telling me that he had spent millions of dollars removing wilding pines from his own property near Omarama and then drove me north of Twizel, pointing out the expanse of pine forestry and wilding conifers evident near Lake Pukaki, west of Twizel, and climbing into the foothills north of Lake Ohau. He very succinctly commented that all of the Basin landscape ‘would soon be Canada’.

23. Consequently, in looking at the Basin landscape as whole, I concluded with a statement – at paragraph 20 of my PC13 evidence – that is at least as relevant now as it was in 2016:

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More generally, the Basin’s iconic, tussock landscape continues to succumb to rabbits and over-grazing, and its glacial valleys and basins are dotted or lined with a mixture of hydro canals, roading, sporadic farm development and transmission lines. It is truly a checkerboard of disparate activities and forms of land cover. As a result, it is barely ‘hanging in there’ as one of the true touchstones of the New Zealand landscape and national identity and it is my opinion that the entire Basin is at, or close to, a key ‘tipping point’ in relation to its landscape future. I agree with Mr Densem that some areas of the Basin Subzone have already descended below the threshold for ONL status. When considered as a whole, the Subzone still qualifies as being sufficiently natural and outstanding to deserve as an ONL, but at a more fine-grained level, not all of its constituent parts reach the outstanding threshold. This is especially evident around the margins of Twizel and Lake Ruataniwha.

24. However, as I also pointed out in my PC13 statement (paragraph 21), this situation is hardly new. The concluding remarks to the following article from the New Zealand Journal of Ecology 2001 (pages 12 and 13; New Zealand Journal Of Ecology, Vol. 25, NO. 1, 2001; The Origin Of The Indigenous Grasslands Of Southeastern South Island In Relation To Pre-Human Woody Ecosystems, M.S. McGlone Landcare Research, P.O. Box 69, Lincoln) make that all too clear:

“ …….. The history of the impact of human settlement on grasslands is an important factor when considering conservation management and goals. The present indigenous lowland and montane grasslands are unparalleled in the historical record. Pre-fire grasslands tended to have abundant Chionochloa only above tree line in the wetter western ranges. On the flat topped mountains of the dry interior, a diverse mixture of grass species and low shrubs seems to have been more the rule than pure tussock grassland. Below tree line, the grasses formed intricate mixtures with trees and shrubs. The extensive Chionochloa rubra, C. rigida and C. macra tussock grasslands present in 1840 AD represented a new anthropogenic community that was created by periodic fire that eliminated and repressed the previous woody ecosystems. …………..

Despite this clearly anthropogenic origin, the tussock grasslands of the montane and lowland South Island have been regarded as the de facto natural vegetation cover. ………………

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As lowland and montane tussock grasslands are increasingly being brought into the national conservation estate, the question of how to manage them has become important. Being seral communities, formed and maintained by fire and modified by grazing, they are unstable. Those adjacent to shrubland and forest, exotic or indigenous, will always be vulnerable to invasion by woody plants. Most are open to fast-spreading weeds and mammalian pests. Ultimately, management designed to maintain them in their current condition, be that continuation of grazing, fire, or other means of woody plant and weed control (for instance, Calder et al., 1992), will have to be undertaken on a large scale.

More importantly, as has been known for a long time, behind nearly every lowland or montane tussock grassland stands the ghost of a destroyed woody ecosystem and, on a national scale, a unique dryland ecological zone has been nearly eliminated. If preservation of the entire span of fully functional New Zealand ecosystems is an aim, it follows that some attempt will have to be made to ensure the existence of self-sustaining examples of the pre-human woody cover of the southeastern South Island. However, there must be some doubt as to how feasible this goal is. ……………. In the current pyrophilic situation, it is difficult to envisage how sustainable indigenous semi-arid woodlands could be recreated. Perhaps the most that can be done is to attempt to preserve small examples as ecosystems-in- waiting while maintaining the ecological health of the magnificent, although thoroughly anthropogenic, successor grasslands.”

KEY ISSUES

25. In 2016, I identified a range of landscape issues that are associated with management of the Mackenzie Basin Subzone. Again, I regard these as being entirely relevant to the current ‘landscape condition’ of the Basin. Accordingly, the following paragraphs (24-31) are largely drawn directly from my PC13 statement, albeit with some editing to remove the focus on PC13, together with the corresponding Attachments (also appended to this brief of evidence).

26. “The issues associated with this ‘transitional landscape’ and its grassland ecosystems have been identified repeatedly over the duration of the current proceedings by Mr Densem and others.

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27. First, there is a fundamental need to protect those key aspects of the Subzone landscape that are recognised, shared, and endorsed by the wider community:

a. the penetrating, crystal clear, views across large, even vast, open spaces;

b. the strong visual signature of landforms – of the glacial valley / moraine / shield framed by an ice and snow clad, alpine fastness – that is fundamental to the Basin’s character;

c. the lakes that are the jewels and points of focus in the Mackenzie ‘crown’;

d. the grassland landscapes that are both harsh and also softly flowing and gently rolling, with that revealssubtle gradations and topographic transitions; and

e. the unique ecology of the lower montane grassland environment.

It is, in places, a sublimely beautiful and, in many places, a notably empty landscape (Annexures 1-4), even if the Subzone landscape increasingly oscillates between retention and degradation of these elements.

The second key issue that needs to be confronted is that raised by Matt McGlone in his 2001 paper2: just what sort of ecological and landscape future is realistically achievable for the Mackenzie Basin, given the transitional nature of its current grassland regime? The Basin, as we know it, is not one of climax ecological sequences of beech forest framing alpine lake margins (except near Ben Ohau), woody shrubland, wetlands and glades of tussock – of the sort that first confronted Maori explorers and can still be found within parts of the Te Wahipounamu World Heritage Area and nearby Snowdon Forest. Nor is it the landscape experienced by Julius Von Hochstetter on his trails to the Godley River, Mt Cook and Lake Ohau in 18623, when he described seeing groves of ‘Wild Irishmen’, cabbage trees, flax, coprosma, griselinia, matagouri, Spaniards, and ‘fagus’ of various kinds, as well as large swathes of tussock. Instead, the Mackenzie vernacular now idealised has come to mean a more simple palette of tussock, matagouri and Spaniards, with a clear emphasis on the low level matrix of grasslands that helps to express landforms and enhance the Basin’s much celebrated ‘long views’.

2 New Zealand Journal Of Ecology, Vol. 25, NO. 1, 2001; The Origin Of The Indigenous Grasslands Of Southeastern South Island In Relation To Pre-Human Woody Ecosystems, M.S. McGlone Landcare Research, P.O. Box 69, Lincolcol 3 Geology Of The Provinces Of Canterbury And Westland, New Zealand : A Report Comprising The Results Of Official Explorations - Exploration Of The Head Waters Of The Waitaki, Julius Von Hochstetter, 1862 12 Brown NZ Ltd December 2017

28. Yet, much of this land is too arid, too peppered with rabbits, too affected by over grazing and too chemically impoverished to re-establish the ‘swaying sea of tussock’ that no doubt most New Zealanders still associate with the Mackenzie Basin. Consequently, despite reading much about the Basin’s ecology and discussing it at length with other experts, I remain unclear just what the ‘end game’ for the Mackenzie Basin really is. What can realistically be achieved across it, given the pressures that the Basin is subject to, the very specific botanical niche of its tussock communities and the importance now attached to those communities by New Zealand at large?

29. In my view, it is doubtful that tussock grassland regeneration on any scale can be achieved without some form of human intervention, even if this means no more than reduced stocking rates and continuation of the war on rabbits. However, current trends also raise the prospect of increasing rationalisation of those areas already used for rural production versus protection and enhancement of those that have more of a conservation focus (eg. north of Mount John - Annexure 5, Photo F). What is required are unique and innovative methods to provide the financial support necessary for the resurrection and sustenance of tussock communities, and therefore the grassland landscapes, across the Subzone. These need to be coupled with protective mechanisms and environmental bottom lines to preserve key values and attributes.

30. Moreover, just as not all perceptions of the Mackenzie landscape are aligned with its ecological reality, the Subzone is also far from ‘pristine’ or wholly natural. Its landscape contains a plethora of cultural ‘relics’, aside from the High Country runs. These include its linear matrix of hydro canals, associated accessways and earth channels that dissect the central shield / moraine landscape between Tekapo and Pukaki, before extending through to Lake Benmore and re-emerging around Lake Ruataniwha (Annexure 5, Photo G). This strategic network is augmented by the transmission towers that march across the Basin south of Tekapo and from Twizel to the Dalgety Range. Moreover, SH8 and a matrix of local roads impose their own geometric pattern on its soft terrain near the western and eastern edges of the main glacial corridor below Tekapo.

31. Taking all of these factors into account, it is my view that PC13 cannot hope to provide any permanent resolution for the future of the Subzone. At best, it provides breathing space within which future, more permanent, outcomes for the Basin ONL can be explored. This will

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likely require the on-going involvement of the District Council, the Mackenzie Trust, DoC, iwi, landowners and other stakeholders. In my opinion, it is critical that such collaboration focuses on options that have a sound ecological foundation and that it promotes landowner engagement in the rehabilitation process.

32. Some of the more immediate issues, and related pressures, that face the Basin ONL – purely from a landscape standpoint – include:

a. The expansion of cultivated, irrigated pasture into areas that have remained part of the dry land stocking regime until recently. This is occurring notably near SH8 from Irishmans Creek through to Simons Hill Station, and within Burkes Pass; near Mt Gerald Station, Godley Peaks Station and Lake Alexandrina – both sides of Lake Tekapo; near the Tekapo Canal above Lake Pukaki; west of Haldon Rd near the Grays River then Grampian Mountains; both sides of Twizel; and within pockets north to west of Lake Benmore (examples – Annexure 6: Photos H & I);

b. The associated development and use of pivot irrigation systems within a landscape that has limited ability to absorb or integrate structures of this size (examples – Annexure 7: Photo J);

c. The ad-hoc spread and interruption of views by shelterbelts, often disrupting key ‘long views’, notably in the vicinity of SH8 and Haldon Rd (examples – Annexure 8: Photos K & L);

d. The spread of production forestry blocks and other woodlots across the Basin landscape. This is a largely an historical occurrence, but now has a very marked impact on areas west and south of Lake Pukaki extending in pockets through to Lake Ohau, and including the key scenic corridor past Glentanner Station towards Mt Cook / Aoraki. More recent woodlots are also located south of Tekapo in the central basin (examples – Annexure 9: Photos M & N);

e. The related spread of wilding trees across the Basin, most notably across the striated, glacial landscape framing Lake Pukaki, but also south of the Tekapo and into the margins of the Rollesby Range, Dalgerty Range and Grampian Mountains west of Hawdon Rd (examples – Annexure 11: Photo Q);

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f. The depletion of grasslands, together with other natural ecological associations across the Basin, notably within areas that are more arid and that have been, or are still, subject to over-stocking (examples – Annexure 10: Photo O); and

g. Pockets of isolated and / or sporadic / ad-hoc development, although traditional farm homesteads are also part of the Mackenzie Country landscape vernacular (examples – Annexure 11: Photos P & Q);

33. In looking at this list of issues and, in particular, at point (f), it is my understanding that even though the issue of grassland retreat is commonly farmed in terms of tussock being ‘out- competed’ by hieracium, it is actually an issue of natural species competition tilted in favour of one species by over-stocking and rabbits. Hieracium is, in fact, part of the natural matrix and ecological sequence of plant species found across the Mackenzie Basin; more so within its arid eastern extremities near Haldon Road and Hakataramea Pass Road. These areas would struggle to support tussock grassland even without Hawkweed. Twenty years of experience with the Tekapo Scientific Reserve has demonstrated that the removal of stock and rabbits alone can result in significant rejuvenation of grasslands. In other words, the issue is not Hawkweed; it is human induced over use of a fragile soil resource and habitat. This is discussed by Dr Walker, in particular at paragraphs 34-37 and 39 of her statement.

34. Consequently, solutions to the ‘loss of grasslands’ and the elimination of Hawkweed do not need to solely focus on pastoral intensification. Other alternatives are available; for example, retirement and lower stocking rates across many areas traditionally used for dryland grazing offer another, potentially more sustainable, alternative.”

THE MACKENZIE BASIN TODAY

35. Looking at the Mackenzie Basin again, some 16 months since my last site visit, the situation has hardly improved; indeed quite the reverse. The margins of SH8 continue to be littered with sporadic development, notably a new heliport immediately south of the Tekapo Army Camp and Fork Stream and an expanding array of buildings and accessways within the Twizel Airport grounds, while pivot irrigation is becoming an ever more prominent feature of the highway margins.

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36. The outwash plain stretching between SH8 (south of Tekapo) and Haldon Road lies at the core of the Mackenzie Basin – with its expansive landform, open grasslands and long views to the Alps, Old Man Range and Rollesby Range. Yet existing pivot irrigators located between the highway and the confluence of the Fork Stream with the Tekapo River, combined with shelterbelts, geometric blocks of pine forest and the inevitable ‘greening’ of the grassland under and around each irrigator, are combining to create a distinctly ‘cultural’, human- modified, landscape quite unlike that which existed prior to tenure review (Annexure 12).

37. Further south again, pivot irrigation across Maryburn Station lines the edge of the plain between SH8 and Haldon Road (Annexures 13 and 14), while new irrigation is currently being installed adjacent to the highway on the Simons Hill and Simons Pass Stations (Annexures 15 and 16). Although the ‘necklace’ of moraine at the southern edge of these two stations – south of the Mary Range and directly west to south of Simons Pass – is to be protected from irrigation and effectively set aside as a vestige of the pre-dairying Basin (as a result of negotiations between the Simons Pass Station landowner and the Mackenzie Guardians) – this still effectively means that most of the highway corridor from Tekapo most of the way through to Lake Pukaki will soon be lined by pivot irrigation and green pasture. A sizeable and aesthetically significant, ‘gap’ remains in this sequence of irrigated land south of the Old Man Range on the western side of SH8, south of the army camp, heliport and Fork Creek. However, I understand that tenure review is almost been complete for that land as well, making it a likely target for future applications for irrigation – albeit subject to the provisions of PC13. Regardless, the transition from a hard tussock / browntop dominated landscape into one more akin to areas like Montalto, Staveley, Mount Somers and Mount Hutt – on the edge of the Canterbury Plain’s farming checkerboard – is unmistakable.

38. Closer to Twizel and Lake Ruataniwha, then progressing down the outwash valley below Twizel to Lake Benmore, the influence of Twizel itself, together with the Lake Ruataniwha / Benmore hydro project becomes much more marked. A scattering of buildings around the previously mentioned airport and DoC’s bird recovery centre reinforce the transition into a peri-urban environment, while the sequence of three major dams and substations down the Ohau River valley (Annexure 17) is mirrored by transmission lines that cut across the landscape around Lake Ruataniwha and either side of the Ohau and Twizel Rivers. Pivot irrigators come close to

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SH8, while a broad scattering of wilding pines southwest to north of the aptly titled “Town of Trees” emphasises landscape transition of a different kind.

39. Two salmon farms also line the banks of the Ohau Canal: one almost directly below Lake Ruataniwha (Annexure 18), the other near the Ohau Canal’s spillway into the Ohau River (Annexure 19). Although providing a degree of interest and culinary appeal for tourists, both farms – especially the one near the spillway into the Ohau River – are hallmarked by their aluminium cages and have all the aesthetic charm of an industrial estate. Exposed service areas, portacom type buildings and a motley assortment of storage areas and vehicle circulation only embellish such impressions.

40. As a result, the landscape around Twizel and the Ohau River could hardly be described as being a pristine, or near-pristine state; far from it. In the Environment Court’s 2011 Rosehip Orchards decision ([2011] NZEnvC 387) the comment was made, at paragraph 51, that, “There are questions about the future of the landscape which the Council has recognised but not fully tackled.” Yet, if anything, the landscape situation across the Mackenzie Basin has deteriorated very appreciably since that time; perhaps especially so since the concept of having reached a ‘tipping point’ was first put by myself and others at the PC13 hearing. The Court also commented, at paragraph 64 of the 2011 decision that “the rate of change [referencing dairy farm development] at least on pastoral leasehold land has been relatively sedate compared with other parts of New Zealand”. Unfortunately, it appears that the rate of change has picked up very considerably since that observation was made. As a result, the strands of landscape coherence and integrity associated with the Basin’s open, grassland landscape are being rapidly picked apart.

41. In this regard, I note that the description of the Mackenzie Basin in Appendix 4 of the Canterbury Regional Policy Statement states as follows in relation to Aesthetic (values):

Aesthetic: The vast basin, large river valleys and enclosing mountain ranges form a dramatic and spectacular landscape. While some parts of the basin have been substantially modified by residential, hydro and agricultural development, the basin as a whole retains its openness and largely coherent character. Despite the landcover modifications induced by historic farming practices, the area maintains a high level of visual coherence………..

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42. I am no longer certain that this description is appropriate for large parts of the Basin. At the PC13 hearing in 2011, Dr Michael Steven, who was described at paragraph 63 as being, “an experienced and thoughtful landscape architect called by Pukaki Downs”, suggested that the landscape framing the landscape around Pukaki Downs was no longer sufficiently natural to qualify as an ONL. I suspect from reading the 2011 decision that the Court had some sympathy for Dr Steven’s assessment, but ultimately determined that all of the Mackenzie Basin should be identified as an ONL – apart from the settlements of Twizel and Tekapo. I also note that in the more recent PC13 decision (2017), the Court – at paragraph 381 – emphasised the importance of ‘connectivity in the Mackenzie Basin ONL’, both visually and biophysically.

43. Thus, while the much discussed, Modified Pigeon Bay or WESI factors remain clearly central to the identification of ONLs, evaluation of any landscape’s overall value must also inevitably address its integrity – which is closely aligned with coherence of expression and connectivity – and its intactness, which is directly linked to the concept of ‘sufficient naturalness’. Landscapes without sufficient integrity / coherence and intactness will inevitably struggle, in my opinion, struggle to cross the threshold of being an ONL. It was for this reason that I raised concerns about parts of the Mackenzie Basin ONL at paragraph 20 of my ONL statement:

“I agree with Mr Densem that some areas of the Basin Subzone have already descended below the threshold for ONL status. When considered as a whole, the Subzone still qualifies as being sufficiently natural and outstanding to deserve as an ONL, but at a more fine-grained level, not all of its constituent parts reach the outstanding threshold. This is especially evident around the margins of Twizel and Lake Ruataniwha.”

44. Looking at the same area again has only confirmed my views in this regard. Although most of the Basin Subzone remains appropriately an ONL at present, its values have been appreciably compromised around Twizel, Lake Ruataniwha and the upper Ohau River. They are also being rapidly eroded either side of the SH8 corridor from Tekapo to Omarama. Although the Canterbury RPS seems to consider that this landscape has sufficient resilience to withstand the encroachment of changing agricultural regimes, I do not agree with this assessment. The open, fine-grained, nature of most of the grasslands landscape still found between Tekapo and Lake Pukaki makes it particularly vulnerable to disturbance and change, while the apparent

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proliferation of other forms of development near SH8, as well as around the Basin’s major rivers and canals, is further eroding its intrinsic naturalness, coherence and intactness. 45. As such, it is not difficult to see the day when much of the Basin will largely emulate the foothill margins of the Canterbury Plains, and at that stage, most of the Mackenzie Basin will cease to be an ONL. Indeed, the attached Google Earth Image of the Basin (Annexure 20) shows the linear progression of irrigation next to SH8, most markedly south of Twizel, and onto the margins of the main alluvial outwash fans; yet this image was flown in December 2016, just before the most recent upsurge in irrigation projects, such as those described across Maryburn Station and on the Simons Hill and Simons Pass Stations. The one irrigator currently on the McIntyre block is also clearly apparent.

46. Turning, therefore, to the landscape in closer proximity to the Kidd and McIntyre blocks, a very evident dichotomy emerges between the landscapes experienced either side of the Ohau River. On its south side, the linear path of the Ohau Canal carves its way through the Twizel / Benmore landscape, steeply elevated in places above the surrounding river and side terraces. The two main sections of the canal culminate in the immense penstocks, powerhouses and substations of and C, while much of the lower-lying terrace landscape ‘trapped’ between the lower canal and the Benmore Range is irrigated – either by K-Line or flood irrigation: I’m not sure which. Transmission lines weave their way to and from the substations, while the small camping ground and boat ramp below the station leave their mark on the immediate landscape, but lack the visual presence of the other elements I have just described. Significantly, however, pivot irrigators are largely noticeable for their absence: the one existing pivot irrigator on the McIntyre block is too remote to easily register and have a noticeable effect on the landscape near the Ohau River and Canal. Even so, the combination of green pasture, the canal and its embankments and the main hydro-electric generation infrastructure clearly creates a decidedly modified, ‘cultural’ landscape.

47. It provides stark counterpoint to the rapidly rising, mass of the Benmore Range which climbs skyward immediately south of the Ohau Canal. Covered in a fine-grained matrix of grasses, tussock, hawkweed, mosses and ‘pincushion’ species – of the kind described by Dr Susan Walker – the Range’s uplifted form and shorn, angular profile contrasts very markedly with the surrounding plains and basin, both in terms of its form and ‘naturalness’. In particular, its

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complex matrix of frequently ‘browned off’ grasslands afford a reminder of the vegetative matrix that, until quite recently, dominated most of the Mackenzie Basin and upper Waitaki.

48. The landscape around the Ohau Canal also contrasts with the sequence of planar outwash and downcut river landscapes to the north – stretching towards the centre of the Mackenzie Basin. While the gravel braids and banks of the Ohau River are most prominent in the immediate foreground, the finely-gravelled, gently falling, outwash plains that contain the Kidd and McIntyre sites, are prominent beyond. Indeed, their terraces merge with one another when looking from McAughtries Road and the canal side-roads northwards, to create visual ‘stepping stones’ that meld with the more distant outwash landscape around Simons Hill and Simons Pass Stations, north of Lake Benmore.

49. Their terraces are flanked by the deeply etched, courses of the Ohau and Pukaki Rivers, while the Twizel River runs between them. Both application properties reach a physical nexus close to the ‘top’ of Lake Benmore – north to east of the Ohau C Power Station – with willows marking the passage of all three rivers. This vegetative sequence culminates in a greater massing of both willows and shrubland vegetation near the East and West Springs, as well as around the camping ground and small marina / boat launching area below the nearby power station.

50. Even without this vegetation, the contrast between the planar landscape of both outwash plains and the down-cut river fairways that flank would be clearly apparent. While the flat- topped, gently undulating, profile of both terraces is accentuated by their finely tilled, surfaces and homogenous, exotic grassland, cover, the three rivers flanking the Kidd and McIntyre sites are deeply etched into the Benmore landscape. Although the willows that I have already mentioned and other sporadic vegetation soften its margins, this remains a harsh environment that is only marginally less so amid the sharply etched nooks and crannies of all three river corridors. It is often dry, even desiccated; a landscape largely of bold landforms that have, historically, been strongly articulated by their natural land cover. Even between the uplifted terraces, an expanse of river braids dominates all three fairways, so the actual water courses – and side pools – are often closely confined, even hidden, by the gravel banks and vegetation either side of them.

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51. This landscape, it is clearly the product of eons of fluvial erosion and deposition, as views across it eloquently reveal. However, it is also an inter-montaine basin landscape defined, more loosely by a complex layering of surrounding ranges. Looking across both the Kidd and McIntyre properties, the Benmore Range is clearly the most proximate of these; but the Gray Hills and Grampians Mountains are also prominent to the east, while the Ben Ohau Range dominates the western skyline. Slightly to the north of that range, Mt Cook / Aoraki stands like a lone sentinel at the head of Lake Pukaki, although a persistent haze on the day of my site visit limited my ability to capture its significant presence and grandeur in my annexures.

52. Looking at this complex landscape as a whole, it is my opinion that other parts of the Mackenzie Basin are certainly more ‘compromised’ in terms of their ONL values than most of the area that I have just described – especially so near Tekapo, Twizel, Lake Ruataniwha and SH8 in general. Even so, I retain concerns about some of this landscape, and the advent of both salmon farms within the Ohau Canal has simply added to both the erosion of landscape value in its immediate vicinity and the feeling that sporadic, ad-hoc development is becoming the ‘norm’ within parts of the wider Basin.

53. On the other hand, it is my opinion that this renders what remains of the natural and ‘semi- natural’ parts of the Basin all the more important, if the current ONL is to retain any semblance of cohesion, intactness and integrity into the future. I include the outwash plains that the Kidd and McIntyre blocks sit in this grouping of significant ‘remnants’ – which increasingly focuses on the Mackenzie Basin’s lakes margins (including those of Lake Benmore) and the remnant swathe of grassland between Simons Pass / Hill Stations, Maryburn Station and Haldon Road.

THE EFFECTS OF IRRIGATION ON THE KIDD AND McINTYRE BLOCKS

Receiving Environments & Audiences

54. I have viewed the Kidd and McIntyre blocks from a variety of vantage points, including:

1) McAughtries Road – next to the Ohau Canal between the and Ohau B power stations (the Kidd property) – Annexure 21;

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2) McAughtries Road near the Ohau B penstocks intake (Kidd property) – Annexure 22;

3) McAughtries Road between the Ohau B and Ohau C power stations (the Kidd property) – Annexure 23;

4) McAughtries Road near the Ohau C penstocks intake (mainly the McIntyre property) – Annexure 24;

5) Falston Road south of the Ohau C power stations (the McIntyre property) – Annexure 25;

6) SH8 near Twizel – much the same location as that employed by Mr Glasson (Kidd property) – Annexure 26;

7) Old Iron Bridge Road above DoC’s Bird Recover Centre near Lake Ruataniwha (Kidd property) – Annexure 27;

8) The Ohau River track extension of Old Iron Bridge Road (Kidd property) – Annexure 28; and

9) The Pukaki River anglers track (Mcintryre property) – Annexure 29.

55. I have also visited the Ohau camping ground and ‘marina’ below the Ohau C power station, although neither offers views of the application sites (Annexure 30). McAughtries Road, which becomes Falston Road at the Ohau C Power Station, is the major conduit for public traffic past both sites. It links the chain of power stations down the side of the Ohau River and Canal, it provides access to Lake Benmore, to the camping ground and boat ramp / ‘marina’ directly below Ohau C and it provides access for trampers to a network of trails that criss-cross the Benmore Range. I note that Mr Glasson has also taken photos form elevated vantage points on the Range, which I did not have time to access.

56. Starting at SH8, McAughtries Road initially provides a broad overview of the valley flanking the Ohau River, as well as the Kidd block on the outwash plain on the far side of it, before gradually sinking lower as the adjoining canal angles gently downwards, cutting into the surrounding terrain. Even so, the end of this section of canal suddenly becomes much more elevated, and is perched well above the surrounding landscape, near the Ohau B penstocks. It offers a natural vantage point from which to look out over nearby river and the alluvial

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terraces that contain both the Kidd block and more distant, McIntyre block. In the course of my site visit, both local ‘tourists’ and anglers were making the most of this elevated lookout.

57. As McAughtries Road continues eastwards and rapidly falls towards the next section of canal through to the Ohau C Power station, a panoramic overview of the Kidd block is afforded those using the road, before it then descends to much the same level as that particular site. Thus, by the time the road reaches the outflow weir to the Ohau River and the ‘lower salmon farm’ abutting it, relatively little of the Kidd property remains visible. At this point, the McIntyre block also remains screened from viewing.

58. Yet, as the canal and accompanying road approach the next set of penstocks above Ohau C, they again become increasingly elevated above the adjoining river, offering expansive views over both application sites. The McIntyre block, in particular, becomes much more prominent in views from near the penstock intake, as well as from part of Falston Road, further to the south, which climbs onto a terrace above the Ohau C tailrace. Although the camping ground below the dam, together with its boat ramp / ‘marina’, are also located close to Falston Road, they sit much lower down – at the very edge of the Ohau River fairway. Consequently, much as I have already indicated, they are completely screened from the edge of the nearby McIntyre block by intervening willows. Views from Falston Road towards both sites also tail off as riverside vegetation, outwash ridges and the banks of the Ohau River screen both application sites. For all intents and purposes, therefore, little of either property is exposed to public viewing south of the camping ground – apart from vantage points perched high on the Benmore Range.

59. Returning to the general vicinity of SH8, the northern edge of the Kidd block is also distantly visible from the highway margins just south of Twizel (as is also agreed by Messrs Glasson and Rough), while Old Iron Bridge Road, approaching the DoC Bird Recovery Centre next to the bed of the Ohau River also offers fleeting views towards that same boundary. However, I would be the first to concede that such views are glimpses at best, in which the application site is distant. As a result, it has little real visual prominence, or even presence.

60. Other points of public contact and interaction with both blocks are not quite as remote and transitory, however. Four-wheel drive tracks, used by anglers to access the Ohau and Pukaki

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River banks, as well as both the East and West Springs near the confluence of all three rivers, trace the edges of the Kidd and McIntyre blocks. And even though the track linked to Old Iron Bridge Road, initially dropping down onto the river fairway below the outwash terraces that are the focus for the current applications, it still climbs up the river bank to directly abut the proposed irrigation area at a number of points. Further to the north and east, the angler’s track which leaves SH8 to follow the margins of the Pukaki River also drops below the main outwash terrace at first. But it then follows the elevated edge of the McIntyre block for some 1.35km before dropping down to the adjoining Pukaki River bed almost directly opposite the mouth of the Tekapo River.

61. Between these river systems and tracks, the Twizel Cycle Trail also follows a path past the Kidd and McIntyre blocks. Branching off the Te Araroa and Alps 2 Ocean Trails at Twizel, it traverses SH8, then follows the path of the Twizel River in a south-easterly direction. Passing over a wetland and boardwalk, then ‘Hobos Camp’, the trail climbs up onto the Kidd block terrace at several points, as is shown in Mr Glasson’s photos for his Viewpoints 8 and 9. In addition, the last 2kms of its route through to the converging Pukaki and Ohau River tracks (which I have already described, above) remain primarily on the main terrace above both the Twizel and Ohau Rivers. Unfortunately, I have not visited this trail, but Mr Glasson’s photos indicate that the area proposed for irrigation would be approximately as close to those using the trail as would be the case those using the Pukaki and Ohau River tracks.

Changes to Landscape Character

62. Reflecting upon these different types of public vantage point, it is clear that they offer quite different perspectives of both the application sites and their surrounds. The views from different parts of McAughtries Road and Falston Road cast both the Kidd and McIntyre blocks as part of the middle distance to background of most views – as part of a landscape continuum, or sequence, from rivers to mountains – that is largely defined by the interplay of natural landforms, articulated and accentuated by natural land cover. This continuum contrasts with the frequently linear, human-induced, landforms and structures in the more immediate foreground – canals, power stations, roads, other infrastructure and curtelage – close to key vantage points. Even when viewed from remote locations, such as the Benmore

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Range vantage points associated with Mr Glasson’s Viewpoints 10 and 11, this dichotomy seems very apparent.

63. Meanwhile, the ‘outwash and riverine’ landscapes experienced ‘first hand’ from the Pukaki and Ohau River tracks, Twizel Cycle Trail and other close-up locations – in actuality, from ‘within’ – are more cohesive and intact as a whole. Certainly, they are interrupted by the presence of wilding pines and fences; yet, this remains a landscape that is dominated by fluvial and montaine landforms in most directions, that still revels in a certain vastness of scale, ‘long views’ and big skies – all still set within a wider context that retains an innate sense of naturalness, despite human interference and encroachment.

64. Although these experiences are different, they both emphasise the importance of the Mackenzie Basin’s grassland / riverine core; a landscape of browns and greys, of smooth textured gravel plains that contrast with the surrounding belts of tectonic uplift. This is, after all, the very essence of the Basin and its fuller array of landscape characteristics, as described in CRPS Appendix 4 and expanded on in PC13 (albeit in a very simplified fashion).

65. Mr Rough, quite rightly, points out that the character of the Basin that PC13 is the product of both (his paragraph 61), “natural and human induced changes in the Basin, especially with regard to vegetation”. He then goes on to make the following summary statement about the natural state of the Mackenzie Basin (paragraph 65):

At paragraph 204 Mr Glasson states: “What we have generally had in the Mackenzie Basin has been a dry grassland character representing an Outstanding Natural Landscape value.” I accept that this is a widely held perception of the Basin but I understand that tussock grasslands did not become an all-pervasive cover on the floor of the Basin as a result of the human-induced changes I outlined at paragraph 60 above but, rather, a continuum developed, from tussock grasslands in the northwest of Basin, where climatic conditions are wetter, to cushion fields and herbfields in the eastern, drier, parts of the Basin.

66. This may well be true; indeed, the evidence of Dr Susan Walker reinforces much of what Mr Rough states when she criticises the evidence of Mr Glasson at her paragraph 76:

In particular, Mr Glasson appears to assume that the original vegetation cover across the basin floor was tussock grassland, rather than a continuum from 25 Brown NZ Ltd December 2017

tussock grasslands in the wetter northwest to the sparse, low-growing cushion, mat and non-vascular (lichen and moss) vegetation characteristic of drier parts of the Basin, as described in paragraph 18, footnote 9, and Appendix 3 of my evidence.

67. These matters were, of course, aired at the PC13 hearing, while my quote from M.S. McGlone at paragraph 22 and his concluding remark about “magnificent, although thoroughly anthropogenic, successor grasslands” warns us about our assumptions in relation to the natural state of the Basin. Indeed, it seems that past human action may well have created an ecological sequence that is so finely balanced – as it were, on a knife edge – that the “golden tussock-laden slopes” referred to in CRPS Appendix 4 can never be more than an interregnum in the Basin’s plant succession over time.

68. Yet, this makes the more varied vegetative continuum described by Dr Walker at her paragraph 18 no less real or significant; it is just different to common perceptions. It also fails to lessen the importance of the ecological and perceptual characteristics associated with a predominance of ground hugging plants, including the open spatial qualities and long views that I have just referred to, the clear articulation and interplay of landforms, and an overall sense of distinctiveness. The very barrenness of the dry basin, its raw elemental exposure to north-westers and the sense of remoteness born of expansiveness and a lack of enclosure – qualities that are rare away from continental land masses – set the Mackenzie Basin apart from the rest of New Zealand. Consequently, much as Mr Rough’s assessment of both the current Basin landscape, and proposed changes to it, seem trapped in a debate about true naturalness, my own focus is upon ‘sufficient naturalness’ (in line with the ONL prerequisites in that regard) and the values that are associated with the Basin, regardless of whether its natural vegetative continuum is focused on tussock and browntop or not.

69. Indeed, for its part, the Environment Court still felt that the area around the Kidd and McIntyre properties was sufficiently natural to be part of the Basin / Subzone ONL and I agree with that judgment.

70. Returning, therefore, to the issue of the type of change that would accompany the irrigation and ‘conversion’ of both application sites, the most overt signs of change would relate to the installation of the actual irrigators – each up to 782m in length – and the greening of the

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pasture under and immediately around the irrigated circles and semi-circles. More important, however, is what this would mean in terms of changes to the character of the landscape near the Ohau River and Lake Benmore.

71. In my assessment, the key landscape changes associated with the proposed farmland conversion therefore relate to the imposition of more human induced geometry, order and formality on the Basin landscape: in effect, the proposed irrigation would alter the landscape’s structure – across both sites, but also within the wider frame of the catchments exposed to them. This would, in turn, increase the quantum of human elements and structures – of anthropogenic modification – on that same landscape.

72. Directly related to this, the proposed blocks of irrigation It would contribute to the fragmentation of the natural sequence of dryland vegetative cover – both physically (as per Dr Walker’s evidence) and perceptually. The remaining natural components of the outwash plains, areas of moraine (such as that near the Simons Hill and Simons Pass Stations) and river courses would become increasingly isolated. Inevitably, this would contribute to further erosion of the Basin’s sense of naturalness and visual distinctiveness – both of which are fundamental to its identity and sense of place.

73. Viewed at closer range (eg. from adjoining tracks), the irrigators would sit ‘on top of’ the landscape, diminishing the articulation, and counterpoint, of its landforms and the continuity its vegetation cover. The irrigators and their spraying water would intrude into views across each application property, diminishing the scale and significance of the surrounding terrain, and even though the new exotic grasses subject to irrigation would cover the outwash gravels in an even, low level, ‘carpet’ of forage, they would do so without the natural sequence of vegetative species reflecting the natural gradients of soil dryness, nutrition and micro-climates (including katabatic breezes) that Dr Walker discusses.

74. I also note that in the evidence of Messrs Glasson and Rough, some weight appears to be given to the mitigatory effect of planting areas outside the proposed irrigation circles. This would apparently comprise much the same species as would be irrigated, but that they would somehow survive devoid of such assistance and, as a result, would help to mask the proposed areas of ‘greening’, or at least soften their outline. Having viewed some of the land that has

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already been ploughed, tilled and that is now covered in a sward of exotic grassland on both the Kidd and McIntyre blocks, it is clear to me that such species will struggle to survive through Summer and Autumn: in early December the grass on the McIntyre block, especially, already appeared to be struggling and under stress. In this regard, I note Dr Walker’s concluding comment – at her paragraph 78:

78. Based on my ecological understanding, I cannot see how ‘infilling with crops, and completely planting the block out with unirrigated crops or grassland’ would diminish ‘the circular patterns’ of the pivot circles as suggested by Mr Glasson. For this to be achieved, it is my opinion that either:

78.1. the irrigation in the pivots would need to be turned off as soon as seasonal drying commenced, causing the circles to dry at the same rate as the remainder, but defeating the fundamental purpose of the irrigation; or

78.2. the (‘infilling’) remainder would also need to be irrigated, perhaps

with k-line sprinklers.

75. In effect, such mitigation is unlikely to work unless artificially shored up by additional K-line irrigation. Moreover, many of the vantage points from which I have viewed both blocks, particularly near McAughtries Road and the Ohau Canal, are sufficiently elevated that the green circles within each property would still be distinguishable from the dried out, typically yellow, grasses between and around the irrigation circles, while close-up views – from the fishing tracks and Twizel Cycle Trail would more clearly expose the pivot irrigators above this vegetative regime. Consequently, I don’t believe that the mitigation described by Messrs Glasson and Rough would be meaningful or effective. The artificiality of the landscape encompassing both irrigation areas would still be evident.

76. Although I have framed these effects in terms of the direct impact associated with the Kidd and McIntyre blocks, there is no question in my mind that all of these effects would add to the already significant sequence of modification and landscape degradation across the Mackenzie Basin. In particular, irrigation of the Kidd and McIntyre blocks would exacerbate the already pervasive, encroachment of a regimented, structured, pattern of rural production on the Basin’s ‘grassland’ landscape. More subtly, the continued spread of human structures and patterns on the landscape would also reduce its sense of remoteness and (relative) isolation.

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In other words, both irrigation proposals would contribute to the cumulative loss of character, identity and key qualities across the Basin. The only remaining question is by how much?

The Quantum of Effect

77. Although the irrigators have a relatively light-weight, even ephemeral, appearance in more distant views, they are explicitly ‘man-made’ when viewed at closer proximity, while the greening of parts of the Mackenzie Basin is frequently more significant in terms of catching attention and signalling the advent of yet more change over any distance. Furthermore, appreciation of the spreading ‘patchwork quilt’ of irrigation across the Mackenzie Basin is not a matter that can be addressed via individual viewpoints alone. In fact, most people living within, and visiting, the Basin are likely to experience it in from both static vantage points and a quite dynamic fashion – motoring across its (relatively) vast spaces and looking across them. As a result, the basin landscape is actually experienced via a multitude of views and from many different vantage points.

78. Thus, the experience of someone trying to get to a camping site below the Ohau C Power Station or visiting the salmon farms above it will be quite different from an angler in their four- wheel drive experiencing the ‘splendid isolation’ of the track down the right bank of the Pukaki River. There is no way of comparing or weighing up these quite disparate perspectives – beyond acknowledging that they all contribute to the composite appreciation of the subject properties as part of a much wider landscape whole.

79. In reading the evidence of Messrs Glasson and Rough, I am, however, struck by the notion that both blocks, especially the McIntyre property, are relatively isolated and have little import in terms of public perceptions of the Mackenzie Basin. For example, even though Mr Rough shows, via his table after paragraph 53 that the Kidd block would result in ‘visual effect’ ratings that range from Slight to Substantial, the ratings for the McIntyre block are confined to more narrow range from Negligible to Moderate. However, the Pukaki River track through to the East Ponds is not addressed in these ratings (whereas the Ohau River track connected with Old Iron Bridge Road is), while the Negligible rating for the Twizel Cycle Trail in relation to the McIntyre block seems to ignore that they are directly across the Twizel River from one another – less than 450m from one another.

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80. I have already addressed the visual catchments and audiences exposed to both proposed irrigation blocks and the nature of the effects that they would generate. Tables 1 and 2 (overleaf) therefore pull these two analyses together – much as Mr Rough has done after his paragraphs 42 and 53 – while the following scale helps to explain the level of effect associated with each rating:

Very Low: The proposed irrigation area(s) would be largely screened from view or ‘lost’ within its wider Basin landscape setting, and would have little or no impact on that landscape’s character and values.

Low: A small part of the irrigation scheme(s) would be discernible, but it would remain a minor, to very minor, component of the wider Basin landscape, and would have a very limited impact on the character and related values of that wider setting.

Low / Moderate: The proposed irrigation area(s) would become a discernible component of the wider landscape, but such awareness does not have a marked effect on the overall character and values of the Mackenzie Basin.

Moderate: The proposed irrigation area(s) would be clearly recognisable within its / their wider landscape setting, altering the composition and character of those surrounds, but having a limited impact on the values currently associated with that existing landscape.

Moderate / High: The proposed irrigation area(s) would be a significant and readily apparent part of the Basin landscape, altering both its composition / character and values to an appreciable degree.

High: The proposed irrigation area(s) would become a dominant feature within the Basin landscape, adversely affecting both its character and values to a significant degree.

Very High: The proposed irrigation area(s) would be so dominant that it / they would fundamentally change the nature of the landscape visible from the viewpoint and would seriously degrade or compromise the values identified in relation to the Mackenzie Basin.

Table 1. KIDD BLOCK VIEWPOINTS: EFFECT RATINGS: McAughtries Road near SH8 Moderate

The canal road above the Ohau B Penstocks Moderate / High McAughtries Road between the Ohau B & C Power Stations Low / Moderate

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The canal road above the Ohau C Penstocks Moderate / High SH8 / Old Iron Bridge Rd (Near the DoC Bird Recovery Centre) Very Low

Ohau River Track Very High Twizel Cycle Trail* Very High Benmore Range* High

Table 2. MCINTYRE BLOCK VIEWPOINTS: EFFECT RATINGS: The canal above the Ohau B Penstocks Low / Moderate McAughtries Road between the Ohau B & C Power Stations Low The canal road above the Ohau C Penstocks High Falston Road Moderate

Pukaki River Track High Twizel Cycle Trail# No Rating Benmore Range* High

* Reliant on images produced by Mr Glasson for Viewpoints 8, 9, 10 and 11 # Not assessed on the ground: no effects rating attributed this viewpoint / catchment

81. In relation to the ratings for the “Benmore Range”, I should add that I was initially torn between accepting the partial integration of the new irrigation circles with those already visible north of the McIntyre block, together with the already green pasture at the foot of the Range (Mr Glasson’s Viewpoints 10 and 11). However, I eventually decided that the incongruity of multiple new green circles across the Kidd and McIntyre blocks would be simply too great – both individually and cumulatively – to support such a rating. The transformation of these blocks would signal a quite fundamental change to the basin landscape of the kind that I have already discussed. As such, the proposals would very appreciably increase the anthropogenic characteristics of the Basin at the expense of its residual naturalness. This tension is also apparent in respect of other elevated vantage points near McAughtries Road and the canal roads, particularly in relation to views from a number of elevated vantage points near both the Ohau B and Ohau C Power Stations.

82. Looking across both blocks of farmland from lower down and at closer range, especially from the Ohau and Pukaki River tracks, the situation changes dramatically. Although the nature of the vegetation cover changes very markedly at the edge of both blocks, the close proximity of

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multiple pivot irrigators would weigh much more heavily on such vantage points. Thus, for example the journey down the Pukaki River, south of its confluence with the Tekapo River, would involve passing two full-circle irrigators and one half-circle irrigator, while the remaining five irrigators would step back towards the Twizel River. Although the proposed irrigators on the lower ‘tip’ of the Kidd property have been removed from the current applications, the four remaining pivot irrigators would still be visible in the background, below the Benmore Range. Although the Ohau River track frequently drops down below the outwash terrace proposed for irrigation those points at which it climbs up onto the edge of that terrace would expose anyone using the trail to much the same experience in the course of travelling towards the Pukaki River and Lake Benmore.

KEY FINDINGS

83. On the basis of this analysis, I find myself unable to agree with my fellow landscape architects about the effects of irrigation across the Kidd and McIntyre blocks. In particular, it is my opinion that:

. Both the Kidd and McIntyre blocks would be exposed to public vantage points to a significant degree;

. Although such exposure may not always involve large audiences, it pertains to audiences that are frequently visiting the Basin because of its scenic / landscape and recreational values;

. The smallest audiences identified – anglers using the Pukaki and Ohau River tracks and cyclists on the Twizel Trail – would experience the pivot irrigation systems proposed at close range and would therefore be subject to a high level of effect;

. The pivot irrigators would, like many such existing structures, be intrusive in their own right, especially when viewed at closer range, but would create distinctive, green, ‘crop circles’ that highlight their presence in more elevated views, such as those from closer to the Ohau Canal;

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. Such effects would arise in relation to views experienced from static vantage points, but also dynamically – as part of the experience of travelling down McAughtries Road, through the wider Basin or from the trails on the Benmore Range; and

. They would add cumulatively to the effects generated by other irrigation systems that have been consented over recent years and that are already appreciably degrading the value of the Mackenzie Basin as a landscape and identified ONL.

84. In my opinion, while it might be possible to argue that the effects in relation to some individual viewpoints and specific views are quite limited, this is not the situation that becomes apparent when looking at the irrigation proposals as whole, in relation to multiple vantage points. In my opinion, the proposed schemes would exacerbate the landscape degradation already so apparent near SH8 – carrying it closer to the centre of the Mackenzie Basin north of Lake Benmore. Until recently, this blighting of landscape values was largely concentrated around that part of the SH8 corridor (and its margins) between Twizel and Omarama. Now, however, this degradation has clearly spread northwards, almost to Tekapo. The Kidd and McIntyre proposals would unequivocally reinforce this unfortunate transition.

STATUTORY ANALYSIS

85. Chapter 12 of the Canterbury Regional Policy Statement identifies the process by which ONLs are to be identified and protected generically. In addition Appendix 4 identifies the Mackenzie Basin as an ONL, as I have already indicated. Relevant RPS

provisions include the following:

Objective 12.2.1

Methods

The Canterbury Regional Council:

Will:

1. Set out objectives, policies or methods in relevant regional plans and protect outstanding natural features and landscapes from inappropriate subdivision, use and development, and to manage use and development, and its potential effects on the values of outstanding natural features and landscapes.

Territorial authorities:

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Will:

2. Set out objectives, policies or methods in district plans to avoid, remedy or mitigate adverse effects of subdivision, use and development of land on the values of outstanding natural features and landscapes and protect them from inappropriate subdivision, use and development, and in particular;

(a) will continue to enable activities that maintain the integrity of landforms and their associated landscape values; and

(b) may achieve protection through methods such as zoning, overlays or land purchase; and

(c) may include provisions that provide for covenanting, pest management, revegetation, or other mechanisms as appropriate to the values concerned.

86. The Mackenzie District Plan contains the following, related provisions:

Section 7 - Rural Zone Rural Objective 3 - Landscape Values

191. Protection of outstanding landscape values, the natural character of the margins of lakes, rivers and wetlands and of those natural processes and elements which contribute to the District's overall character and amenity.

Rural Policy 3C - Scenic Viewing Areas

192.To limit structures and tall vegetation within scenic viewing areas to enable views of the landscape to be obtained within and from these areas.

Rural Objective 4 - High Country Land

2. To encourage land use activities which sustain or enhance the soil, water and ecosystem functions and natural values of the high country and which protect the outstanding landscape values of the high country, its indigenous plant cover and those natural processes which contribute to its overall character and amenity.

Rural Policy 4B - Ecosystem Functioning, Natural Character and Open Space Values

3. Activities should ensure that overall ecosystem functioning, natural character and open space values of the high country are maintained by:

- Retaining, as far as possible, indigenous vegetation and habitat

- Maintaining natural landforms

- Avoiding, remedying, or mitigating adverse effects on landscape and visual amenity.

Rural Objective 6 - Rural Amenity and Environmental Quality

4. A level of rural amenity which is consistent with the range of activities anticipated in rural areas, but which does not create unacceptably unpleasant living or working conditions for 34 Brown NZ Ltd December 2017

the District's residents or visitors, nor a significant deterioration of the quality of the general rural and physical environment.

Rural Policy 6A - Livestock Farming

5. Avoid, remedy or mitigate adverse effects of livestock farming to protect the amenity of rural areas and the quality of the physical environment.

Rural Policy 6D - General Amenity Controls

194.To encourage and/or control activities to be undertaken in a way which avoids, remedies or mitigates adverse effects on the amenities and physical environment of rural areas.

Rural Policy 8B - Structures

195. To ensure that the location, design and use of structures and facilities, within or near waterways are such that any adverse effects on visual qualities, safety and conflicts with recreational and other activities on the waterways are avoided or mitigated.

Rural Zone Rule 3.1.1.e - Sites of Natural Significance, Scenic Viewing and High Altitude Areas

196. No building shall be erected on:

- Any area identified on the Planning Maps as a Site of Natural Significance.

- Scenic viewing areas as identified on the Planning Maps

87. Appendix J does not identify the area around the Ohau Canal or McAughtries Road as a Scenic Viewing Area, although locations on the edge of the Kidd blocks have been identified as Sites of Natural Significance – which Dr Walker addresses in her evidence on the local “SONS”, but which I do not.

88. Even so, the District Plan provisions clearly anticipate protection of the Mackenzie Basin’s ONL values, in accordance with both Objective 12.2 1 of the RPS and Section 6(b) of the RMA, together with its amenity values. I note in this regard, that Mr Glasson considers implementation of the proposed pivot irrigation schemes will have a very low adverse effect on the landscape values of the Basin. Consequently, he regards both as being consistent with the objectives and policies listed above.

89. I disagree with Mr Glasson in relation to his findings and further disagree with Mr Rough, who appears to circumvent the issue of effects on the ONL characteristics by arguing that the tussock

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grasslands are the product of human induced change. Again, I can only reiterate that both Appendix 4 of the RPS and PC13 have explored this issue and reached different conclusions from Mr Rough about the qualities that underpin the Mackenzie Basin’s landscape and which must, therefore, be protected. In my assessment, both irrigation proposals are quite contrary to the direction required by the District Plan’s Rural Objective 3 and, therefore, to the imperatives of Section 6(b) of the RMA.

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CONCLUSIONS

90. I have read the CRC decision and it is my opinion that it is full of weighing up, balancing and counter-balancing of exactly the sort that ‘King Salmon’ appeared to dismiss as being in appropriate. Indeed, whereas that particular Supreme Court case addressed the effects of development some 1.5km offshore of Pig Bay and its ONL, the Kidd and McIntyre blocks are firmly anchored in the heart of the Mackenzie Basin ONL. As a result, the CRC commissioners appear to have missed a fundamental point in relation to both applications: that even if they are considered to be less than significant in their own right, in relation to some specific viewpoints, they are significant as part of the tide of change that is transforming the essential landscape character of the Mackenzie Basin and undermining the very values that both Appendix 4 of the CRPS and PC13 are very clear about.

91. In my opinion, this is not an issue of subtle changes: it is one of incrementalism and an inability, or unwillingness, to address cumulative effects being allowed to progressively destroy the characteristics and values of a landscape that has been a touchstone of New Zealand’s identity and self belief. In an article recently written by Patrick Barkham in The Guardian (4th December 2017), the following assertion was made:

There can’t be a more successful tourism marketing campaign than “100% Pure New Zealand”. And New Zealand is seen as a world leader in another respect: how its farmers sell their food globally without government subsidies. But the tension between these two successes has been exposed by Sir Tim Smit, the co-founder of the Eden Project in Cornwall.

Smit has sparked a minor international incident by declaring that New Zealand is “so pure the people of Christchurch won’t even swim in the river Avon. Most of the lakes are full of algae. It is like a beautiful person with cancer.” He was speaking to British landowners pondering the New Zealand model for post-Brexit agriculture. British farmers currently receive £3bn in subsidies each year; environment secretary Michael Gove must design a much smaller subsidy system – or scrap it altogether.

Smit argues that New Zealand is no inspiration despite its farmers surviving the removal of subsidies in 1984. Their response has been to intensify, and export milk to China.

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Landscapes that George Monbiot might describe as sheep-wrecked are now cattle-wrecked; the cost, argues Smit, is water quality, as nitrates from fertilisers flood into rivers. Smit’s critique has been endorsed not only by Greenpeace New Zealand but also by the chief executive of New Zealand’s fish and game council, Martin Taylor, who calls the country’s clean, green image “a facade”. …………” “Courtesy of Guardian News & Media Ltd”

92. I think Patrick Barkham is absolutely correct to raise these issues, while all too many local and regional decision-makers live in an ‘Emperors new clothes’ world in which cumulative effects are buried by a ‘less than minor effects’ mantra that defies common sense. The Cambridge Dictionary Online describes “minor” – as an adjective – as meaning:

“having little importance, influence, or effect, especially when compared with other things of the same type:

a minor operation It's only a minor problem. There's been an increase in minor offences ……….. She suffered only minor injuries. It requires a few minor adjustments. a minor poet of the 16th century”

93. By extension, “less than minor” does not therefore mean ‘less than Very High, High or Significant’. And we should not live in a Cinderella land where ONL values are continually compromised because landscape is somehow viewed as being the poor cousin of imperatives for growth and the harder sciences – even though so much of this country’s identity is ultimately inextricably wrapped up in its landscape imagery and heritage.

94. In my PC13 evidence, I stated that (paragraph 80), “the Mackenzie Basin can be regarded as the landscape ‘bellwether’ of this country. The management process set in place by the Plan Change will have important implications for other important and sensitive landscapes across New Zealand.” Even though both water take applications for the Kidd and McIntryre blocks were declined by the Regional Council, the relevant comments from the commissioners in relation to their landscape effects fail to reflect this significance. In my opinion, the Court is now faced with a stark decision, either to draw a line in the sand that reflects the ONL status and values of the Mackenzie Basin or accommodate a form of agricultural production that can only further erode such values and

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eventually transform the landscape of the Basin into a more elevated, facsimile of much of the Canterbury Plains.

Additional Comments in Relation To The Withdrawal Of The Kidd Appeal & Revised McIntyre Proposal

95. I have considered what both changes to the appeal ‘mean’ in relation to the Mackenzie Basin landscape. Clearly, the removal of irrigators and irrigated areas from the Kidd blocks would reduce the visibility and perceived ‘creep’ of such systems down the left bank of the Ohau River. The remaining irrigators on the McIntyre land would be more isolated physically and there would not be the same sense of irrigation stretching towards Lake Benmore from near SH8 and Lake Ruataniwha, in a cumulative sense. The ‘tether’ between the existing areas of irrigation around the SH8 corridor and the remaining areas proposed for irrigation on the McIntyre block would be effectively cut.

96. Having said this, the remaining areas of irrigation would still remain visible: Mr Glasson’s images from the Benmore Range make this clear in relation to just one irrigator and there is no reason to assume that multiple irrigators and their ‘green circles’ would be any less visible – quite the reverse, in fact. Unfortunately, I do not know the exact disposition of the irrigators still proposed for the McIntyre blocks, but this therefore implies that the irrigators would still remain visible from near McAughtries Road, Falston Road, the Ohau C Power Station and the Pukaki River track – as per my Table 2.

97. In addition, while the extent of visible irrigation would clearly diminish (although I’m not quite sure where), the nature of the transformation to the landscape visible from the various vantage points that I have identified would still occur. Moreover, the physical isolation of the transformation has the potential to make it appear even more sporadic and ad-hoc than was previously the case. Consequently, while the proposed areas of irrigation would be more physically discrete and some distance from the chain of irrigation now following much of SH8, it would still be another pocket of irrigation that changes both the biophysical and perceived character of the Mackenzie Basin.

98. Ultimately, however, it is all too easy to focus on the relative visibility of the revised application and lose sight of the more important reality that the McIntyre scheme still represents one more piece in a tide of change to both rural production and landscape character across the Mackenzie Basin. In my opinion, the reduction in scale of the McIntyre proposals and withdrawal of the Kidd appeal clearly reduces the extent of such change – for the present – but does not alter its nature or 39 Brown NZ Ltd December 2017

import in relation the Basin’s ONL values. Accordingly, I consider that the revised McIntyre scheme would still have an appreciable and adverse effect on the landscape of the Mackenzie Basin and is not consistent with the protection of it as an ONL.

Stephen Brown BTP, Dip LA, Fellow NZILA

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APPENDIX A S BROWN LANDSCAPE, NATURAL CHARACTER & AMENITY ASSESSMENT PROJECTS

AWARDS:

Landscape Value Mapping of Hong Kong (2001 – 5): development of the methodology and assessment criteria for the ‘landscape values and sensitivity mapping’ of Hong Kong undertaken by Urbis Ltd for the Hong Kong Government – awarded the Strategic Planning Award by the (UK) Landscape Institute in 2006.

Auckland Geomorphic / Geological Features Assessment (2011): analysis of past case law, the RMA and current policy, together with field evaluation of 207 features to determine if they qualify as ONFs – for Auckland Council: NZILA Distinction (Landscape Planning & Environmental Studies Category) 2014

STRATEGIC ASSESSMENTS: Volcanic Cone Sightlines & Blanket Height Control Review (2015/16): re-appraisal of 87 sightlines within Auckland City to Mt Victoria, Mt Albert, Mt Roskill, Mt Eden, Mt Hobson, Mt Wellington, One Tree Hill, Mangere Mountain, Browns Island and Rangitoto, together with a complete review of the Blanket Height Control Areas that flank all of the major cones across and near the Auckland Isthmus: analysis of the sensitivity of each cone and the key threats to their visual integrity followed by the mapping of areas that should be subject to a new regime of building height controls under the Proposed Auckland Unitary Plan - for Auckland Council.

West Coast Region & Buller / Grey / Westland Districts Landscape Study & Natural Character Assessment (20011-14): assessment of the Buller, Grey and Westland Districts to identify the combined Districts’ / Region’s Outstanding Natural Landscapes and those part of the Region’s coasts and lake / river / wetland margins that display High and Outstanding levels of Natural Character – for the West Coast Regional Council & District Councils

Thames Coromandel Landscape Review & Assessment (2007 - 14): peer review of the Thames Coromandel landscape assessment leading to a complete re-assessment of the Peninsula, identification of its Outstanding and Amenity Landscapes, as well as coastal environments displaying high to outstanding natural character values – for Thames Coromandel District Council.

West Coast Rural Policy Area (2011): evaluation of the coastal environment, areas of coastal influence and assessment of amenity values to determine the extent of the proposed West Coast Rural Policy Area overlay – for Auckland Council

Buller District Landscape & Natural Character Assessment (2011): assessment of the Buller Districts Outstanding Natural Features and Landscapes, together with identification of its coastal environment, lake / river / wetland margins and identification of those areas displaying high Natural Character – for Ltd & the Environment Court (in relation to the Mokihinui hydro-electric project appeals)

Waikato Regional Policy Statement Chapter 12 – Landscape Review (2011/12): review of proposed ONLs and areas of high natural character across the Waikato Region, taking into account public submissions and the 2010 NZ Coastal Policy Statement – for the Waikato regional Council

Auckland Geomorphic / Geological Features Assessment (2011): analysis of past case law, the RMA and current policy, together with field evaluation of 207 features to determine if they qualify as ONFs – for Auckland Council

Auckland Region: Outstanding Natural Features Study (2011): assessment of over 220 geomorphic and ecological features (mainly volcanic remnants such as the Wiri Lava Cave, Orakei Basin / crater) to determine which of those should be classified as an Outstanding Natural Feature under section 6(b) of the RMA – for Auckland Council

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Auckland Region: Amenity Areas Study (2011): description and mapping of those areas within the Region that qualify as Amenity Landscapes within the Auckland – in terms of their aesthetic and natural characteristics, recreational appeal, etc – with reference to section 7(c) of the RMA – for Auckland Council

Auckland Region: Natural Character Assessment (2012/13): delineation of the coastal environment for the Auckland Region and identification of areas of high natural character employing key environmental indicators / parameters – for the Auckland Regional Council.

Manawatu / Tararua / Lower Rangitikei District Landscape Assessment (2009): identification of the Outstanding Natural Landscapes and Amenity Landscapes distributed within all three districts within 150km of the Turitea Wind Farm site in the northern Tararua Range – for Mighty River Power.

Otorohanga District Landscape Assessment (2009 - 11): identification of Outstanding Natural Features and Landscapes, Amenity Landscapes and parts of the District’s coastline – together with lake and river / stream margins – that display high Natural Character values – for Otorohanga District Council.

Kawhia Aotea West Coast Assessment (2006): assessment of the landscape and natural character values of the catchments around Kawhia and Aotea Harbours, including the identification of the area’s outstanding landscapes, visual amenity landscapes and parts of the coastline displaying high natural character – for Environment Waikato and the Waikato, Waipa and Otorohonga District Councils.

Whangarei District Landscape review / Assessment (2005): assessment of landscape values across Whangarei District to identify its Outstanding Landscape and Visual Amenity Landscapes, involving use of past public preference research, public consultation, identification of natural character values, landscape heritage values - in conjunction with Beca Carter Hollings & Ferner Ltd for Whangarei District Council.

Assessment of the Auckland Region's Landscape (2001-4): responsible for a review of landscape assessment methodologies appropriate for re-assessment of the Auckland Region's landscape, including literature search and organisation of workshops to review theoretical options - designed to address identification of Auckland's outstanding / iconic landscapes; followed by Q-Sort testing of public attitudes to landscape, and mapping of the Auckland Region’s Outstanding Landscapes - for the Auckland Regional Council.

Hauraki Gulf Islands District Plan - Plan Change Reviews (2003): detailed reviews of Plan Changes 23 (Subdivision), 24 (Earthworks), 25 (Indigenous Vegetation Clearance) & 26 (Lot Coverage) involving detailed assessment of the Waiheke and Great Barrier Island landscapes in respect of their capacity to accommodate changes to the relevant thresholds for permitted and discretionary activities and assessment criteria leading to recommendations in relation to each Plan Change - for Auckland City.

Auckland Urban Coastline Assessment: Waiheke Island Coastal Landscape Assessment: Great Barrier Island Coastal Landscape Assessment: (1993-5): Assessment of the VALUE, VULNERABILITY and overall SENSITIVITY of each of these coastal areas - involving their breakdown into landscape units, description and discussion of landscape character types and preparation of preliminary policies for landscape management - for the Auckland Regional Council. East Manukau Assessment: (1994-6): responsible for managing / overseeing assessment of the landscape values in each of these strategic landscape studies - involving their breakdown into landscape units, description and discussion of landscape character types and preparation of preliminary policies for landscape management - for the Hawkes Bay Regional Council & Manukau City Council.

Mahia Peninsula / Wairoa Coastal Strategy (2003): assessment of the landscape and natural character values of the Mahia Peninsula and nearby coastal areas, including Mahanga and Opoutama, to provide input on both conservation and strategic development strategies for the Wairoa District Coastal Strategy Study - for Beca Carter Hollings & Ferner and Wairoa District Council.

North Shore City Significant Landscape Features Assessment (1998-2001): identification, analysis and description of all significant landscape features within the Albany, Greenhithe, Paremoremo and Long Bay / Okura parts of North Shore City - for North Shore City Council.

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East Tamaki Catchment Management Study (2001): analysis of landscape and open space values in the East Tamaki catchment leading to recommendations in relation to future open space provision and park acquisition - for Beca Carter & Manukau City Council.Whangarei District Coastal Management Study (2003): assessment of the landscape values and ‘carrying capacity’ of settlement areas down the eastern Whangarei coastline leading to recommendations about future development and conservation strategies - in relation to: Oakura, Moureeses Bay, Woolleys Bay, Matapouri, Pataua South & North, Ocean Beach, Urquharts Bay, Taurikura, Reotahi and McLeods Bay - for Beca Carter & Whangarei District Council.

Waitakere City Northern Strategic Growth Area Study (2000 - 2001 & 2003): Analysis of existing landscape features, character areas and resources within the Whenuapai / Hobsonville / Brighams Creek catchment as the basis for evaluation of future growth options. This work includes the identification of key landscape sensitivities within the catchment, the identification of development constraints and opportunities in relation to the local landscape and the preliminary assessment of effects associated with shifting Auckland's MUL in the subject area - for URS New Zealand Ltd and Waitakere City Council (Eco Water). In 2003 this work was extended to cover Herald Island and the Red Hills area - for Landcare Research.

Franklin District Rural Plan Change Study (2002/3): responsible for re-evaluation of most of Franklin District - in relation to landscape values, sensitivities and residential development potential / appeal - to determine areas that present opportunities for residential growth, rural areas that should be specifically excluded from rural-residential development and generic features that should be conserved throughout the District - for Franklin District Council.

Assessment of the Auckland Region's Landscape (1983-4): region-wide appraisal of both the aesthetic quality and the visual absorption capability of different parts of Auckland's extra-urban landscape (covering 425,000 has). This study involved breaking the Region down into 633 landscape units and incorporated a public preference study with over 1100 public participants. It has enabled planners to come to terms with both public perceptions of landscape value and the relative vulnerability of different parts of the Region to development - for the ARC.

Whangarei District North-eastern Coastal Settlements Assessment (1996): assessment of key landscape features and elements that should be conserved to help define the margins of urban growth around Whangarei District's north-eastern coastline - from Ocean Beach in the south to Oakura and Whangaruru - for Whangarei District Council.

Volcanic Cone Sightlines Review (1997 - 2003): appraisal of current sightlines to Auckland’s volcanic cones leading to suggestions about the addition, deletion and location of sightlines, and the specification of controls in relation to each - for the ARC and Auckland City Council.

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