Taranaki Regional Council Resource Management Act 1991 Further Submissions for the Proposed Coastal Plan for Taranaki Further submissions on the Proposed Coastal Plan for Taranaki was publicly notified for submissions on 21 July 2018 with a deadline for further submissions on 8 August 2018. A total of 25 further submissions were received by the Council. The index on the following page gives the submitter name (with original submitter number in brackets) and the page number where their further submission can be found. The original submitter number is given to assist users with cross referencing against other documents. Page Submitter Name Number Federated Farmers (2) 1 Radio New Zealand Ltd (35) 7 (Project Reef Life) Bruce Boyd (11) 11 Transpower New Zealand Ltd (26) 13 Trans-Tasman Resources Ltd (6) 23 Meridian Energy Ltd (20) 73 Z Energy Ltd, BP Oil Ltd, Mobil Oil NZ Ltd (46) 79 Powerco (45) 101 South Taranaki Underwater Club (10) 126 Department of Conservation (29) 127 Kiwis Against Seabed Mining (55) 135 Fonterra (47) 136 Climate Justice Taranaki Inc (21) 142 Ministry for Primary Industries (16) 149 Te Korowai o Ngāruahine Trust (41) 152 New Zealand Defence Force (33) 172 Royal Forest and Bird Protection Society (43) 179 Te Kotahitanga o Te Atiawa Trust (58) 188 Karen Pratt (9) 205 Port Taranaki Ltd (32) 212 Te Rūnanga o Ngāti Mutunga (40) 241 Taranaki Energy Watch (51) 259 Petroleum Exploration and Production Association of New Zealand (37) 270 Nga Motu Marine Reserve Society Inc (44) 291 Te Runanga O Ngāti Ruanui Trust (61) 294 Federated Farmers of New Zealand Further submission to the Taranaki Regional Council on the Proposed Coastal Plan for Taranaki 31 July 2018 1 Federated Farmers’ further submission to the Proposed Coastal Plan for Taranaki To: Taranaki Regional Council Name of submitter: Federated Farmers of New Zealand Contact person: Lisa Harper Regional Policy Advisor Address for service: Federated Farmers Taranaki 15 Young St PO Box 422, New Plymouth Phone: 06 7573425 Email: [email protected] 1. Federated Farmers could not gain an advantage in trade competition through this submission. If others make a similar submission, we would be prepared to consider presenting a joint case with them at any hearing. 2. Taranaki Federated Farmers welcomes this chance to make further submissions on the proposed Coastal Plan. We made submissions on these plan changes in March 2018. We would like to take this opportunity to make further submissions on some points raised within the submissions of other parties involved in the plan review process. This further submission provides Federated Farmers’ views on points raised that are not already covered in our original submission. Federated Farmers wishes to be heard in support of this submission. Thank you. 2 2 Federated Farmers’ further submission to the Proposed Coastal Plan for Taranaki Submitter Submission Provision and/or Support/oppose/neutral Reason Relief sought no. topic Trans-Tasman 6 Policies 11 & 13; Support in part Policies currently require the Accept submission Resources Limited Coastal water & air maintenance and quality enhancement of water and air quality. We agree with TTR, who prefer reference to maintenance or enhancement, ‘as enhancement is not required under the RMA or higher order policy documents in all cases’. Policy 16; Support in part For reasons given by Accept submission Relationship of submitter tangata whenua 3 Silver Fern Farms 8 Policy 22, rules 6 & Support For reasons given by Accept submission 13; Discharge of submitter; at present no contaminants to other practical options are coastal waters available than to discharge to coastal waters. Meat processing plants operated by SSF are essential infrastructure to the farming sector in Taranaki. Department of 29 Policy 14; Support in part We agree that mapping That Council Conservation Biodiversity, areas of significant consider mapping mapping indigenous biodiversity is as an alternative to helpful to plan users, using a schedule of although we are aware that significant species there may be resource or and ecosystems. practical constraints. For example, some biodiversity may be small in extent and/or mobile and can 3 Federated Farmers’ further submission to the Proposed Coastal Plan for Taranaki therefore be difficult to map. Significant Natural Areas on land have also been mapped by District Councils. We disagree that the approach of protecting ‘areas’ is inadequate. Policy 18; Amenity Oppose The relief sought is very Reject submission broad. Amenity on the coast is also adequately managed in District Plans. Forest and Bird 43 Natural character Oppose Identification of areas of Reject submission natural character is already a feature of the relevant District Plans. It is unclear what value could be gained 4 by repeating the process, or by the additional provisions sought. Relief sought for Objective 6, that natural character is ‘restored where degraded appropriate’ is aspirational, but ‘appropriate’ is a necessary qualifier. Relief sought for Policy 9 (‘avoiding adverse effects…’, with no qualification) does not reflect that some adverse effects on natural character may be allowable in some circumstances. 4 Federated Farmers’ further submission to the Proposed Coastal Plan for Taranaki Biodiversity Support in part We support identification of Consider the values and identification of the characteristics that characteristics and contribute to the significance values that of areas of significant contribute to the biodiversity. significance of areas of significant biodiversity. Biodiversity, Oppose in part Manuka, kanuka and rata Enable the significance criteria have recently been re- clearance of classified as ‘threatened’, as regenerating a precautionary measure, pasture in the following the arrival in New coastal Zealand of the disease environment. myrtle rust. Otherwise these plants are common and In significance often behave as agricultural criteria or their 5 weeds in farmland. application, make note that manuka We recognise that protection and kanuka are not of coastal vegetation is included in important. However, we provisions, where would be concerned if the their threatened change in classification status is due to the status of these plants, introduction of coupled with significance myrtle rust. criterion b(ii) in F&B’s appendix 3 (relating to vegetation and habitat supporting a threatened or at risk species), make clearance of regenerating pasture on the coast more difficult for farmers. Powerco 45 Definition of Support in part We support the principle Accept submission reverse sensitivity behind proposed changes, in part. 5 Federated Farmers’ further submission to the Proposed Coastal Plan for Taranaki for reasons given by submitter. However, the phrase ‘in their vicinity’ is useful and we submit it should be retained. We would also omit the proposed ‘or intensification’, as this would be hard to judge and may catch relatively minor changes in activities. Policy 10; Support For reasons given by Accept submission Restoration of submitter natural character Oil Companies 46 Objective 8; Support FFNZ has similar concerns Accept submission indigenous to the submitter, in relation biodiversity to farming activities. 6 Fonterra 47 Policy 2; Integrated Support For reasons given by Accept submission management submitter Policy 6; Activities Support For reasons given by Accept submission important to the submitter well-being of people and communities END 6 Form 6 FURTHER SUBMISSION IN OPPOSITION OF SUBMISSIONS ON THE PROPOSED COASTAL PLAN FOR TARANAKI Clause 8 of Schedule 1, Resource Management Act 1991 To Taranaki Regional Council Name of person making further submission: Radio New Zealand Limited (RNZ) 1 This is a further submission in support and opposition to the submissions on the Proposed Coastal Plan for Taranaki (the Proposed Plan). 2 RNZ is a submitter on the Proposed Plan. 3 RNZ supports and opposes the submission by Royal Forest and Bird Protection Society of New Zealand Incorporated (Forest and Bird) on the Proposed Plan, as set out in Appendix 1. 4 RNZ does not wish to be heard in support of this further submission. Signed for and on behalf of Radio New Zealand Limited by its solicitors and authorised agents Chapman Tripp ______________________________ Ben Williams Partner 1 August 2018 Address for service of submitter: Radio New Zealand Limited c/- Gary Fowles PO Box 123 Wellington Email address: [email protected] 7 APPENDIX 1 Submitter Plan Provision Submission RNZ support/oppose Relief sought by RNZ name submission, and reasons 43 – Royal Objective 3 – Delete Objective 3: Oppose – RNZ considers that Retain Objective 3 as notified. Forest and Reverse there must be objectives in the Bird sensitivity The use and ongoing operation of Proposed Plan which protect Protection nationally and regionally important nationally and regionally Society infrastructure and other existing lawfully important infrastructure from established activities is protected from new reverse sensitivity. As a lifeline or inappropriate use and development in utility, it is essential that the coastal environment. continues operation, maintenance and improvement of RNZ’s national transmission network can occur unimpeded. 8 43 – Royal Policy 2 – Support Policy 2 with amendment: Oppose – RNZ submits that the Retain Policy 2 as notified. Forest and Integrated wording of (a) as notified is Bird management Provide for the integrated management of already consistent with the the coastal environment by: