Our Ref: 626073 File: A53-0033 13 April 2016 To: Horizons Regional Council [email protected] Subject: RUAPEHU DISTRICT COUNCIL’S SUBMISSION TO HORIZONS REGIONAL COUNCIL’S ANNUAL PLAN 2016/17 Submission from: Ruapehu District Council Private Bag 1001 TAUMARUNUI 3964 Point of Contact: Anne-Marie Westcott ENVIRONMENTAL MANAGER Email: [email protected] Phone: 07 895 8188 COUNCIL WISHES TO SPEAK IN SUPPORT OF ITS SUBMISSION. 1 Thank you for the opportunity to submit on the draft Annual Plan 2016-17. We apologise that this submission is late. We received the draft Annual Plan material on March 29 2016, just two weeks before the deadline for submissions. This is a very tight turnaround and we were unable to write the submission in the time available. We would have liked more time to be able to engage with our own Elected Members on the issues raised for consultation in this Annual Plan. 1.1 Ruapehu District Council (RDC) generally supports the proposals in the Horizons Draft Annual Plan 2016-17, however we would like to comment on some aspects of it. 2 SECTION TWO – LAND AND WATER MANAGEMENT 2.1 RDC is grateful for the support given by Horizons during the contamination of Raetihi river system. The Raetihi community continues to watch the Makotuku River closely and is concerned about its general degradation from its headwaters throughout the catchment. Page 2 Our Ref: 626073 13 April 2016 2.2 Thank you also for your efforts in the Environment Court in attempting to limit NZ Energy’s water abstraction. RDC notes that the ‘Water Allocation Grandfather’ clause does create rights for the energy company but is concerned about the volume grandfathered under the One Plan water allocation system which has been shown to have an effect on the Makotuku River water quality and quantity. 2.3 Recently RDC, in conjunction with Horizons staff, developed an application for funding from Envirolink to provide a better understanding of the respective impacts of ammonia, nitrate and phosphorus on periphyton growth in rivers downstream of point source discharges. However, and disappointingly, Horizons has recently chosen not to submit this application for funding. This research would provide better certainty about effluent treatment standards that are needed to address environmental impacts caused by excessive periphyton growth. This research is relevant to many wastewater treatment systems which discharge to water across the Horizons Region and nationally. Within the Horizons Region, it has direct relevance to discharges managed by Rangitikei DC, Manawatu DC, Palmerston North City Council, Tararua DC and Ruapehu DC. Periphyton growth is a major question, and the lack of understanding around this leads to significant cost in the consenting process. The expected outcomes from this research would have helped significantly clarify the scientific debate in recent high profile consent cases such as the Palmerston North wastewater plant discharge to the Manawatu River and the Feilding wastewater plant discharge to the Oroua River. In the Ruapehu District, this research is directly relevant to the discharge from the Raetihi wastewater plant to the Makotuku River. 2.3.1 Given the research relates to a gap in scientific knowledge, with at least region-wide applications, rather than to a site-specific problem, it seems logical that the research effort (including funding) should not be borne by one individual district council, and that it falls within regional council’s role to lead or at least contribute to the effort. This was acknowledged at staff level, and accordingly an application for Envirolink medium advice grant was developed between Ruapehu District Council, Massey University and Horizons staff, with the research to be conducted by Massey University’s School of Engineering and Advanced Technology and Aquanet Consulting. In that process we must commend Horizons Scientist’s collaboration and efforts. Manawatu and Rangitikei Districts have agreed to provide in-kind contributing in the form of monitoring equipment. Both Massey and RDC invested significant staff and consultant time to develop the proposal, only for the proposal to not be submitted by Horizons. We note that Horizons were not asked to fund the proposal, only to submit the application. Horizons’ failure to lodge the application is now costing RDC additional staff and consultant time to pursue alternative sources of funding. 2.3.2 RDC believes the causes of the growth of periphyton downstream of point source discharges are not well understood and would like Horizons as the lead environmental agent to investigate the factors involved in periphyton growth in the whole catchment of the Makotuku River. RDC cannot afford to go down the track that Palmerston North City Council did in removing phosphorous from its effluent, only to find that it did not solve the effect created in the river by the discharge. 2.4 RDC is currently charged $26,463 as an Additional Research Site under Water Quality Charges for Discharge Consents (Schedule of Charges, Horizons Annual Plan, pg Page 3 Our Ref: 626073 13 April 2016 191). This is on top of the Discharge to Water annual fee and any compliance inspection cost of the resource consent discharge. The Additional Research Site fee is the highest fee of all charges for Water Quality Discharge consents in the region with the next being Rangitikei District Council followed by Manawatu District Council. It is assumed that this fee goes towards research into effects on the river systems from wastewater treatment discharges, however the resource consent applications are now lodged and RDC sees limited value (with the exception of Raetihi) in continuing to collect such a high level of detailed information. 3 SECTION THREE - FLOOD PROTECTION AND CONTROL WORKS 3.1 The Makotuku River at Raetihi Township is significantly congested with willows, both above and below the township. The willows have the effect of forming a dam and holding water up in this area. This creates a high risk within the township at peak flows when the township drainage systems are no longer able to discharge in to the Makotuku River as was the case in June 2015. This resulted in a number of habitable floors being affected with flooding and some self-evacuation occurring. Council seeks to partner with Regional Council in managing this river system. 3.2 RDC wishes to thank Horizons for their investigation into the upper Mangawhero and tributaries for flood and erosion risks in Ohakune (Draft, July 2015). RDC provisionally supports the development of the Upper Mangawhero and Tributaries Scheme. We ask that it extends to cover construction that safeguards RDC’s wastewater treatment asset and links with the downstream private scheme. As Horizons are the specialist in stock bank flooding development we ask that they lead this proposal. Also that they investigate the river gravel management within the proposed scheme area to control flooding. 3.2.1 RDC would also like to understand the rating impacts of this scheme on the Ohakune community before making a final commitment to the scheme. 3.3 Taringamotu River scheme RDC would like to thank Horizons for undertaking the improvements to the Taringamotu River Scheme and its ongoing support. While the establishment of the scheme appeared to be quite fraught, it has improved the river system for the community. 3.4 Upper Whanganui River Scheme The maintenance and clearing of poplars in the lower Ongarue River and previous clearing of the township has been much appreciated by locals. This project has noticeably enhanced the visibility and beauty of the Whanganui River system for the Taumarunui community. 4 SECTION FOUR - BIOSECURITY AND BIOACTIVITY MANAGEMENT 4.1 Please refer to RDC’s submission to Horizons Animal and Plant Pest Management Strategy (Attachment 1). 4.2 Ngati Rangi have aspirations to restore the bush and wetlands area adjacent to the Ohakune Wastewater Treatment Plant. We support their endeavors in this project. 5 SECTION FIVE – REGIONAL LEADERSHIP AND GOVERNANCE 5.1 Horizons provides rural advice to dairy farmers as a service. RDC believes that this is a Page 4 Our Ref: 626073 13 April 2016 service that Horizons could extend to councils regarding wastewater treatment systems. A more collaborative approach to technical concerns may help to avoid adversarial discussions at consent hearings and the resulting costs of adversarial positions. Collaboration would be a good move towards co-governance and partnership of service delivery for our communities as best practice moving forward. RDC has experienced the benefits of such a collaborative approach before lodgment in establishing the science and agreeing up front who would be collecting that science for our resource consents. We believe that other councils would benefit from such a collaborative approach. Currently costs for the Resource Consent can be more than the actual cost of the upgrade. 5.2 As discussed in the presentation given by RDC in October 2015 regarding resource consents, we found that Iwi had aspirations to be more involved in the governance space and discussions up front. This position still remains available within the Wai Group for Horizons to participate in our journey with Ngati Rangi and Ngati Uenuku. 5.3 Ngati Rangi and Ngati Uenuku would like to form a Memorandum of Understanding (MOU) with both RDC and Horizons. This desire for an MOU was referred to in the presentation in October 2014 regarding resource consents (proposed content of MOU attached. Attachment **) 6 REGIONAL ECONOMIC GROWTH RDC supports Horizons role in facilitating regional economic development. ATTACHMENT 1 Our Ref: 621864 File: C60-1254 09 February 2016 To: Horizons Regional Council Private Bag 11025 Manawatu Mail Centre PALMERSTON NORTH 4442 Subject: HORIZONS REGIONAL COUNCIL COMBINED REGIONAL PEST MANAGEMENT PLAN AND STRATEGY 2015-2025 Submission from: Ruapehu District Council Private Bag 1001 TAUMARUNUI 3964 Point of Contact: Anne- Marie Westcott ENVIRONMENTAL MANAGER Email: [email protected] Phone: 07 895 8188 Council wishes to speak in support of its submission.