Submission to:
The Proposed Canterbury Land and Water Regional Plan
Environment Canterbury
P. O. Box 345
Christchurch 8140
Submitter:
A. E. Kennedy
70 Perry Street,
Christchurch
My name is Ann Elizabeth Kennedy, I hold the qualification of Post Graduate Diploma in
Environmental Science – Aquatic Ecology (Canterbury) and Master of Environmental Management
(Lincoln).
The following statements are taken from the Proposed Canterbury Land and Water Regional Plan.
“Fresh water bodies in urban areas are particularly vulnerable to contamination from land
uses that discharge contaminants into storm water systems as these often discharge into local
streams or rivers. Older residential areas, commercial activities and roads discharge storm
water via kerb and channel directly into fresh water systems. Land use, soil type, slope,
drainage patterns and groundwater levels also influence how contaminants run-off or leach
into fresh water”.
“Vegetation helps to sustain the land and is a useful tool for managing the effects of land use.
For example, riparian margins, if wide enough and comprising appropriate vegetation, can
perform an important role in stabilising riverbanks, filtering out sediment running off the
land, and reducing levels of nitrogen and other contaminants entering water bodies. Wetland
can also filter sediment and contaminants, although introducing significant quantities for
treatment into a natural wetland will most likely change the wetland’s functioning and
values”.
“Appropriately managed artificial wetlands and swales can be very successful at removing
sediment and certain contaminants, and are increasingly being incorporated into urban design
for storm water treatment from roads and into the design of effluent treatment facilities
because direct discharges to water are inappropriate”.
In accordance with the above, I wish to submit on the following points:
Regional Wide Rules - The Discharge of storm water
5.72 The discharge of storm water into a river, lake, wetland or artificial watercourse or onto
or into land in circumstances where a contaminant may enter water is a permitted
activity provided the following conditions are met:
1. The discharge is into a community or network utility operator storm water system; or
2. The discharge is not from or onto potentially contaminated land;
3. The discharge is not into:
(a) a water race, as defined in Section 5 of the Local Government Act 2002;
(b) a wetland, unless the wetland is part of a lawfully established stormwater or wastewater
treatment system; or
(c) a water body that is Natural State, unless the discharge was lawfully established before 1
November 2013;
4. The discharge does not result in an increase in the flow in the receiving water body at the
point of discharge of more than 1% of a flood event with an AEP of 20% (one in five year event);
I request that “(d) the Red Zone of the Avon River where the discharge has not passed through a
wetland which is a lawfully established storm water treatment system” be added to 5.72, Point 3.
5.73
I request that the words in Rule 5.73 “non complying activity” read “a prohibited activity” –
to work in conjunction with my request in 5.72, 3 (d).
I look forward to Environment Canterbury taking this opportunity to improve the water quality of the
Avon River, its riparian margins, biodiversity, habitats and community wellbeing.
I wish to be heard.
A. E. Kennedy
Christchurch
5 October 2012