Submission by:
Guardians of Pāuatahanui Inlet and Pāuatahanui Inlet Community Trust

6 March 2013

The only aspect of this project that is of concern to PICT and GOPI is its potential to cause lasting ecological damage to the environment of the Pāuatahanui Inlet, either directly or via a reduction in the ecological health of the Pāuatahanui Stream. Our concern with this application has been to look carefully at the issues surrounding the requests for discharge permits of sediment to freshwater and of potentially deleterious material to the cleanfill site.

With respect to discharge of sediment to freshwater we note that the proposed erosion and sediment controls, and the criteria for assessing their effectiveness and taking action if they fail, comply with standard guidelines. We applaud the intention to revegetate retired land and steep slopes and to create wetlands where appropriate.

These proposals are what we now expect to see in all resource consent applications. But, as always, their effectiveness is dependent on the quality of the monitoring process. It is especially important that the regulatory authority develop and maintain a monitoring programme that is independent of that of the applicant's. It is equally important that the public are informed of the nature of the authority's monitoring programme, and its results.

However we are unable to evaluate the potential for environmental damage in the "discharge of material (cleanfill) which may not always fully comply with the Regional Soil Plan definition of cleanfill" as no details are given in the application. Instead it states that this issue will be covered in a Cleanfill Management Plan, which has yet to be developed. This is unfortunate as we know that some residents are taking it to mean that the company will be dumping toxic material at the site. We trust not, but it is clear that some further information to the public on this point would be advisable.   

While we regret the loss of the tributary stream bed, we accept that the proposed mitigation for this loss will probably result in no nett loss of ecological health in the Pāuatahanui Stream itself.

However, this application is for a long-term, 35 year consent. Consequently, we are very concerned that the application fails to consider the possible effects of climate change on the frequency and severity of heavy rain events. We acknowledge that the various guidelines to which Winstones are working also do not take this into account, but consider that a company which expresses a desire to be environmentally responsible has not done so as a forward looking addition to their responsibilities.

Submitted jointly by:

John McKoy
Chairman
Pāuatahanui Inlet Community Trust

and

John Wells
Chairman
Guardians of Pāuatahanui Inlet Inc.

6 March 2013