SUBMISSION FROM THE GUARDIANS OF LAKE WANAKA
QLDC DISTRICT PLAN REVIEW
23 October 2015
1. SUBMITTER DETAILS
NAME:
Guardians of Lake Wanaka (Chair, Don Robertson)
PHONE NUMBER:
0274446640
EMAIL:
Don Robertson donandgaye@xtra.co.nz
Aimee Raynes araynes@doc.govt.nz
POSTAL ADDRESS: The Secretary, c/o Department of Conservation, PO Box 93 Wanaka
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2. DISTRICT PLAN REVIEW
The Guardians of Lake Wanaka have comments on the following sections: Chapter 3 Strategic
Direction, Chapter 4 Urban Development, Chapter 5 Tangata Whenua, Chapter 6 Landscapes,
Chapter 21 Rural and Chapter 33, Indigenous Vegetation and Biodiversity. Our comments and
concerns as expressed in this submission are focussed mainly on those aspects (often missing)
in the proposed District Plan that relate to intended management of water quality, aquatic
biodiversity and aquatic ecosystems.
3. SPECIFIC PROVISIONS
Chapter 3, “Strategic Direction” section 3.1 states “This chapter sets out the over-arching
strategic direction for the management of growth, land use and development in a manner that
ensures sustainable management of the Queenstown Lakes District’s special qualities”; which
includes reference to one attribute being “pristine water”. In this chapter, we also refer to the
Objectives 3.2.4.1 “Promote development and activities that sustain or enhance the lifesupporting capacity of air, water, soil and ecosystems,” 3.2.4.5 “Preserve or enhance the
natural character of the beds and margins of the District’s lakes, rivers and wetlands”, “3.2.4.6
Maintain or enhance the water quality and function of our lakes, rivers and wetlands” and
policies 3.2.4.5.1 “That subdivision and / or development which may have adverse effects on
the natural character and nature conservation values of the District’s lakes, rivers, wetlands and
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their beds and margins be carefully managed so that life-supporting capacity and natural
character is maintained or enhanced”, 3.2.4.6.1 “That subdivision and / or development be
designed so as to avoid adverse effects on the water quality of lakes, rivers and wetlands in the
District”.
Chapter 4 “Urban Development” – we refer to the entire chapter.
Chapter 5 “Tangata Whenua” – we refer to the entire chapter.
Chapter 6 “Landscapes” We refer here to Section 6.2, Objective 6.3.6, Policies 6.3.6.1 and
6.4.1.4. These state - Section 6.2 …”The lakes and rivers both on their own and, when viewed
as part of the distinctive landscape, are a significant element of the national and international
identity of the District and provide for a wide range of amenity and recreational opportunities.
They are nationally and internationally recognised as part of the reason for the District’s
importance as a visitor destination, as well as one of the reasons for residents to belong to the
area. Managing the landscape and recreational values on the surface of lakes and rivers is an
important District Plan function”. Objective 6.3.6 – “Protect, maintain or enhance the landscape
quality, character and visual amenity provided by the lakes and rivers and their margins from
the adverse effects of structures and activities”; Policies 6.3.6.1 “Control the location, intensity
and scale of buildings, jetties, moorings and utility structures on the surface and margins of
water bodies and ensure these structures maintain or enhance the landscape quality, character
and amenity values”; 6.4.1.4 “The landscape categories apply to lakes and rivers. Except where
otherwise stated or shown on the Planning Maps, lakes and rivers are categorised as
outstanding natural landscapes”.
Chapter 21 Rural: Section 21.1 includes: “The purpose of the Rural zone is to enable farming
activities while protecting, maintaining and enhancing landscape values, nature conservation
values, the soil and water resource and rural amenity. A wide range of productive activities
occur in the Rural Zone and because the majority of the District’s distinctive landscapes
comprising open spaces, lakes and rivers with high visual quality and cultural value are located
in the Rural Zone, there also exists the desire for rural living, recreation, commercial and
tourism activities”. And also states, inter alia:
Pursuant to Section 86(b)(3) of the RMA, the following rule(s) that protects or relates to
water have immediate legal effect:
• 21.5.7: Dairy farming grazing within the bed or margin of a water body. (We have left out
the other two RMA items as 21.5.7 is the item of interest here).
Also in Chapter 21 we comment on Objective 21.2.3 – “Safeguard the life supporting capacity of
water through the integrated management of the effects of activities”. This is served by Policy
21.2.3.1 “In conjunction with the Otago Regional Council, regional plans and strategies:
• Encourage activities that use water efficiently, thereby conserving water quality and quantity;
• Discourage activities that adversely affect the potable quality and life supporting capacity of
water and associated ecosystems”.
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Objective 21.2.12, “Protect, maintain or enhance the surface of lakes and rivers and their
margins” and the ten Policies under it.
Chapter 33: Indigenous Vegetation and Biodiversity. We comment here on section 33.1,
Objective 33.2.1 and in a general way on its many policies.
4. OUR SUBMISSIONS ARE:
Chapter 3 - we strongly support the intent of 3.1. and the intent of related Objectives 3.2.4.1,
3.2.4.5, 3.2.4.6 and Policies 3.2.4.5.1 and 3.2.4.6.1.
Chapter 4 – we note that the entire chapter is devoid of mention of water quality, of
stormwater, of urban run-off impacts on ecosystems.
Chapter 5 – we note there is only passing reference to the management of lakes, rivers,
streams, wetlands.
Chapter 6 – we strongly support the intent of these sections, objectives and policies. (Section
6.2, Objective 6.3.6, Policies 6.3.6.1 and 6.4.1.4.). However the wording is too weak to ensure
confidence that the intent will be achieved. Waterways, lakes & wetlands are not adequately
covered in policy 6.3.2.5.
Chapter 21 – we support the intent in Section 21.1, Objective 21.2.3 and policy 21.2.3.1. but we
are concerned the wording is too weak to ensure confidence that the intent will be achieved.
All over the district but especially on the shores of the 3 deepwater lakes we can see stock
grazing and polluting water bodies directly and indirectly through rain run-off bringing faecal
bacterial and microbial pathogen pollution added to through inflow of nutrients from
topdressing and toxins from use of pesticides. Toxins and pathogens in urban stormwater
runoff is also an issue inadequately addressed. There is a real potential, if these parts of
Chapter 21 are applied as worded, to rapidly contribute to the declining quality of water in
iconic Lakes Wakatipu, Wanaka and Hawea. In Section 21.1 it is quite unclear what the rules
are, and from our perspective we are especially interested in more clarity around the item
21.5.7: Dairy farming grazing within the bed or margin of a water body. This is unclear. Why is
it only referring to dairy farming? What are the “rules” referred to? We are concerned that
actions to manage these very serious issues could fall into the gaps between ORC and QLDC
responsibilities. Objective 21.2.12 and the ten Policies under it (with the exception of Policy
21.2.12.5) limit their focus to “Protect, maintain or enhance the surface of lakes and rivers and
their margins”. This seems odd. Why? Does this have something to do with the split
responsibilities between the District and Regional Councils?
Chapter 33 – “Indigenous Vegetation and Biodiversity” has no specific acknowledgment of
aquatic biodiversity or its protection. This chapter heading is misleading and should be
revisited. Vegetation is “biodiversity”. The last para in 33.1 “Purpose” states “Much of the
indigenous vegetation habitat has been removed” - in fact removal will also be a consequence
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for all of the very many other organisms dependent on vegetation. Also what about aquatic
environments? Lakes, rivers streams, wetlands and aquifers are all rich habitats for biodiversity
–but are not mentioned in the Purpose.
Objective 33.2.1 – states “Protect, maintain and enhance indigenous biodiversity”. We support
the intent of the objective and all of the many policies in this chapter but suggest that some
deficiencies include the absence of clear definitions of the animal size cut-off for any
quantitative assessments of biodiversity, the absence of mention of any metrics of biodiversity
which might help determine whether objectives are being achieved, or capable of being
achieved, the absence of specific mention in objectives or policies of biodiversity in aquatic
ecosystems, and in some cases referring to vegetation as if it is all of the biodiversity in the
habitats mentioned. There are also scenarios implicit in some policies which should be explicit –
where the removal of indigenous vegetation will have an impact on the aquatic biodiversity in
that catchment.
5. WE SEEK THE FOLLOWING PLAN CHANGE FROM THE QLDC:
Concerning Chapter 3 - we expect that with respect to section 3.1., Objectives 3.2.4.1, 3.2.4.5,
3.2.4.6 and Policies 3.2.4.5.1 and 3.2.4.6.1 there will be effective operationally meaningful
definitions, procedures and appropriate expertise supporting their intent. Reference to
maintain “pristine water” is excellent but how do we know that there are steps that will be
taken to ensure this happens? How do we know what QLDC recognises as “pristine”? Will its
definition actually permit large scale degradation of chemical and biological water quality? A
clear definition should be evident in the District Plan. The objectives and policies here need to
be stronger and possibly more specific. Note for example the current risks to Bullock Creek and
its wetlands in Wanaka from a wide range of urban toxins and bacteria in stormwater runoff.
Will these objectives and policies protect such waterways?
Concerning Chapter 4 – if the omission of mention of water quality, of stormwater, and of
impacts on ecosystems, is deliberate, then this should be stated and explained. If not then it
should be addressed. It is not clear why these aspects are omitted.
Concerning Chapter 5 – with reference to the slim mention of management of water and
aquatic life, ecosystems etc we suggest that there should be cross reference to other chapters
which strengthen the intent of this chapter of the District Plan to provide for good management
of waterways and aquatic ecosystems. Without this Chapter 5 is weak.
Concerning Chapter 6 - we expect that with respect to Section 6.2, Objective 6.3.6, Policies
6.3.6.1 and 6.4.1.4 there will be effective operationally meaningful definitions, procedures and
appropriate expertise supporting their intent. We note with concern that both rural and urban
developments continue without good evidence of these intentions being met. (A current
example is the potential effect of stormwater runoff from subdivision development in Wanaka
and which could have a detrimental effect on the water quality, biodiversity and ecosystem
function of Bullock Creek, an iconic waterway in the heart of Wanaka township). These aspects
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should all be evident and addressed in the District Plan. Emphasis on urban waterways and
wetland ecosystems should also be explicitly included. We suggest an additional new policy
6.3.2.6 which should address cumulative effects of contaminants in all water bodies.
Concerning Chapter 21 – we note that the wording of the items in Section 21.1, Objective
21.2.3 and Policy 21.2.3.1 is too weak to ensure the success of their intent. We urge QLDC to do
everything possible to strengthen the objectives and policies and underpin them with effective
operational procedures. The use of terms “encourage” and “discourage” in Policy 21.2.3.1
should be revisited and replaced with wording more conducive to achieving the intent of this
policy. We seek more clarity in Section 21.1 about item 21.5.7: Dairy farming grazing within the
bed or margin of a water body, and associated rules referred to in this section. We suggest
QLDC takes greater responsibility for rural environmental well-being, both biodiversity and
water quantity and quality as ORC isn’t taking a strong enough approach. QLDC and ORC should
clarify mutual responsibilities and ensure that environmental quality of all waterbodies is not
continually compromised. Clear cooperation between ORC & QLDC on all aspects of water
management would be an excellent development. This same issue appears to be behind the
apparently odd wording of Objective 21.2.12 and the ten Policies under it which pertain only to
water body surfaces and margins only (with the exception of Policy 21.2.12.5). If this
apparently unusual approach to ignore the waterbodies themselves relates to statutory
divisions of responsibility between ORC and QLDC this should be explicit – perhaps in Section
21.1.
Concerning Chapter 33 – The heading for this chapter would make much more sense if it was
changed to “Indigenous Biodiversity”. For Objective 33.2.1 – we suggest addressing deficiencies
and include clear definitions of the animal size cut-off for any assessments of biodiversity, the
metrics of biodiversity which might help determine whether objectives are being achieved,
address the absence of specific mention in objectives and policies of biodiversity in aquatic
ecosystems, and revisit wording in objectives and policies referring to vegetation as if it is all of
the biodiversity in the habitats mentioned; i.e. acknowledge non-plant diversity. Where there
are scenarios in some policies – where the removal of indigenous vegetation will have an
impact on the aquatic biodiversity and water quality in that catchment and receiving lake
waters – this should be addressed in objective and policy wording.
We wish to be heard in support of our submission.
6. SIGNATURE:
Chair, Guardians of Lake Wanaka
23 October 2015
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