SUBMISSION
TO:
Queenstown Lakes District Council
DATE:
23 October 2015
PLAN CHANGE:
Queenstown Lakes District Council Proposed District Plan
KĀI TAHU KI OTAGO
Te Rūnanga o Moeraki, Kāti Huirapa Rūnaka ki Puketeraki, Te Rūnanga o Ōtākou
PAPATIPU RŪNAKA
and Hokonui Rūnanga (collectively Manawhenua)
Manawhenua support the Proposed District Plan for the Queenstown Lakes District (PDP).
Manawhenua do wish to be heard in support of this submission at a hearing, and requests an opportunity to
expand on this submission. If others make a similar submission, we will consider presenting a joint case with
them.
1.
Introduction
1.1
Te Rūnanga o Moeraki, Kāti Huirapa Rūnaka ki Puketeraki, Te Rūnanga o Ōtākou and
Hokonui Rūnanga are Manawhenua within the Otago Region.
1.2
The takiwā of Te Rūnanga o Moeraki is based at Moeraki and extends from the Waitaki River
to the Waihemo (Shag) River. The takiwā of Kāti Huirapa Rūnaka ki Puketeraki centres on
Karitāne and extends from the Waihemo River (Shag River) to Purehurehu Point (north of
Heyward Point). The takiwā of Te Rūnanga o Ōtākou centres on Ōtākou and extends from
Purehurehu Point to Te Matau (the Clutha River). The takiwā of Hokonui Rūnanga centres
on the Hokonui region and includes a shared interest in the lakes and mountains between
Whakatipu-Waitai and Tawhititarere with other Murihiku Rūnanga and those located from
Waihemo southwards.
1.3
Manawhenua have assessed the PDP and recommends amendments to provide for their
cultural values, rights and interests within the region. Manawhenua support the PDP
provisions except where we ask for specific amendments or additions as listed.
2.0
Consultation with Manawhenua
2.1
Recently, staff from KTKO Ltd and Te Ao Marama, on behalf of Manawhenua, worked with
Council to revise the proposed ‘Tangata Whenua’ chapter prior to notification. Manawhenua
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were encouraged by the constructive approach taken by Council Staff to recognising and
providing for their values, rights and interests in the PDP.
3.0
Introduction
3.1
Manawhenua acknowledge the provisions that have been included in the PDP that seek to
recognise and protect their ancestral relationship and their culture and traditions with their
lands, water, culturally significant sites, wāhi tapu and other taonga and the willingness of
the QLDC to incorporate those matters in the PDP.
3.2
Further amendments and additions to this plan are sought to better incorporate the broader
interests and aspirations of Kāi Tahu in the management of natural and physical resources
within the QLDC area. These changes are considered necessary to:
(a) Better achieve the purpose of the Resource Management Act 1991 (RMA), including the
matters of national importance under section 6, the requirement to have particular regard
to kaitiakitaka under section 7, and the requirement to take into account the principles of Te
Tiriti o Waitangi (Treaty of Waitangi) under section 8 of the Act; and
(b) Take into account the relevant iwi management plan, the Kāi Tahu ki Otago Natural
Resource Management Plan 2005, as required under s61(2A) of the RMA; and
(c) Give effect to the National Policy Statement for Freshwater Management; and
(d) Restore the social, economic, cultural, and environmental well-being of Kāi Tahu within the
Queenstown-Lakes district.
3.3
The submission intentionally refers to both Ngāi Tahu and to Manawhenua. The submission
draws a subtle distinction between issues that relevant to Ngai Tahu the Iwi, as opposed to
matters that are determined by those who are Manawhenua in the District.
3.4
The specific decisions sought are listed in Appendix 1. Text to be deleted is shown as
strikethrough. Replacement text is shown underlined. We also seek any consequential
amendments necessary to give effect to the decisions sought.
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4.0
General Submissions
District Plan Wide Issues
4.1
There is no description of the issues or needs at a resource specific level, or of the threats
and challenges facing the district at a resource specific level.
4.2
It is often unclear where responsibility lies or where there is overlap of responsibilities
(Territorial authority or Regional Council).
Integration of Manawhenua Values
4.3
The objectives and policies in the Manawhenua1 chapter need to be better reflected and
interwoven throughout the remainder of the document. Manawhenua values in the
document lack visibility and detail. The references to Manawhenua values in the policies lack
detail and the linkages to the tangata whenua chapter are not clearly articulated.
4.4
Throughout the District Plan there is reference to ecological, heritage, and landscape values.
It is submitted that ‘Manawhenua values should also be a matter for consideration and
should be specifically referenced. This would raise the visibility of Manawhenua values and
ensure that they are specifically addressed.
Wāhi Tūpuna
4.5
There is a desire from Manawhenua for landscapes and sites of significance to be
acknowledged in the PDP. It is important to note that while the term ‘cultural landscapes’
has been used in the past, these areas are considered distinct from natural landscapes.
While natural landscapes may be enriched by historical and cultural values, ‘cultural
landscapes’ also encompass highly modified sites that are significant in terms of section
6(e).2
4.6
For this reason these cultural landscapes are referred to as ‘wahi tūpuna’, ancestral places
that are of contemporary importance for Manawhenua. Having said that, a number of wahi
tūpuna’ overlap with natural landscapes, as the landforms around which they are based are
significant to both Manawhenua and to the wider community.
1
It is submitted that ‘Manawhenua’ is the appropriate heading for this chapter as it references those who
uphold the mana of the whenua (land) within the Queenstown Lakes District.
2
Resource Management Act 1991, Section 6(e): the relationship of Maori and their culture and traditions with
their ancestral lands, water, sites, waahi tapu, and other taonga.
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4.7
Wahi tūpuna incude sites that are wāhi tapu and wāhi taoka, kāika, trails, mauka, roto and
significant views. The activities that may threaten the relationship of Manawhenua with
wahi tūpuna include:

Activities that affect the peaks, ridgelines and upper slopes of hills and mauka, where either
the mauka itself, or views of it, are significant to Manawhenua. These activities tend to be
those that affect the skyline, or create a strong visual impact on the upper slopes, and
include forestry, buildings, structures, network utilities, mining, tracks and roading.

Earthworks that may disturb archaeological sites.

Subdivision
4.8
Council and Manawhenua have agreed to defer the development of wāhi tūpuna (cultural
landscapes) mapping and the related provisions until Stage 2 of the PDP. Identification of
wāhi tūpuna and the threats to them will enable plan users and Council staff to easily
identify the areas of interest to Manawhenua.
4.9
However, due to this staged approach adequate provision has not been made to ensure
appropriate consideration of mapped wāhi tūpuna’ within the rules created by stage one of
the PDP. Stage one of the PDP contains a number of important chapters providing for
development in the district and it is submitted that these rules should include protections
for wāhi tūpuna’.
4.10
It is intended, as noted in Chapter 5, that the sites and areas of wāhi tūpuna’ will be mapped
and provision will be made in the District Plan triggering consultation with Manawhenua. It
is submitted that references to effects on wāhi tūpuna’ are required in the Stage 1
provisions to give full notice that this is a relevant consideration in relation to certain
activities and in order to adequately recognise and provide for the relationship of
Manawhenua with wāhi tūpuna. For example, where there are matters of discretion
reserved for a restricted discretionary activity ‘Effects on wāhi tūpuna’ should be an added
as a matter of discretion. This is particularly important where a plan provision provides that
the relevant activity is to be treated as non-notifiable.
Customary uses and practices
4.11
It is intended that areas where customary uses are occurring these will be mapped and
provision will be made in the District Plan triggering consultation with Manawhenua. Again,
there is no reference to mapped areas of customary use in the rules of part one of the PDP.
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It is submitted that references to effects on customary uses are required in the Stage one
provisions to give full notice that this is a relevant consideration in relation to certain
activities. This is particularly important where a plan provision provides that the relevant
activity is to be treated as non-notifiable.
Protection of taonga species
4.12
It is intended that areas of habitat of taonga species will be mapped and provision will be
made in the District Plan triggering consultation with Manawhenua. Again, there is no
reference to mapped areas of habitat of taonga species in the rules of part one of the PDP.
It is submitted that references to effects on the habitat of taonga species are required in the
Stage one provisions to give full notice that this is a relevant consideration in relation to
certain activities. This is particularly important where a plan provision provides that the
relevant activity is to be treated as non-notifiable.
Cemeteries, crematoriums and landfills
4.13
These activities, which may result in contaminants entering the air, land or water, and
ultimately the food chain, are considered potentially significant by Manawhenua wherever
they are located. It is submitted that effects on Manawhenua should be a matter for
consideration as part of any consent application proposing these activities.
4.14
It is submitted the District Plan must include rules that ensure Manawhenua is consulted,
particularly where the proposed activity is close to wahi tupuna, customary use areas,
nohoanga and the habitat of taonga species.
5.0
Specific Submissions
5.1
Manawhenua request the specific amendments to the PDP detailed in Appendix 1.
Manawhenua request that all the plan provisions proposed as part of stage one of the PDP
are reviewed to ensure that sufficient direction is given to the decision maker to ensure
adequate consideration of the effects of proposed activities on mapped wahi tupuna.
Nahaku noa, Nā
Chris Rosenbrock
Manager
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Address for Service:
Tim Vial
Principal Planner
KTKO Ltd,
PO Box 446
Dunedin 9054
Phone Number: (DD) (03) 471 5480
E-mail: tim@ktkoltd.co.nz
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