Proposed Land and Water Regional Plan
Further Submissions by Orion New Zealand Ltd.
Submitter
Plan Provision Further Submission
Support/Oppose
99 – Oil New Rules for The submitter seeks to address legacy discharges from sites which are known
Companies
Contaminated
to be contaminated. The Oil Companies are concerned that the general rule
Land
5.6 would mean that all passive discharges from contaminated sites would
require a resource consent as they are not otherwise permitted. It seeks to
remedy this by introducing a permitted framework for discharges from
contaminated sites.
There is a possibility that Ecan could technically use Rule 5.6 to tidy up legacy
discharges, however this is considered to be unlikely as it would require a
significant amount of resources. However, there is merit in this submission.
Orion suggests that Ecan carefully consider the content of the proposed rules
and whether the standards suggested are appropriate for the nature of the
discharge.
167
– Rule 5.7
Canterbury
Onsite
Regional
wastewater
Council
disposal
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– This submitter seeks to include additional requirements for septic tanks,
including that the discharge shall not include any hazardous waste. Hazardous
waste is defined in the PLWRP as waste which includes bacteria and
pathogens.
The purpose of a septic tank is to treat human effluent, however the
discharge from these systems may have residual bacteria, and as such it may
Support in Part
Relief Sought – Accept
submission point “A-C” in
Schedule Five to the extent
that it seeks the introduction
of a permitted activity
framework
for
legacy
discharges on contaminated
sites, but request Ecan to
consider
whether
the
proposed conditions are the
most appropriate way to
determine
whether
a
discharge is permitted, or
whether there may be other
suitable conditions for this
proposed new rule.
Oppose in part
Relief Sought – Reject part of
the submission on Rule 5.7
which seeks to include
reference to hazardous
Submitter
Plan Provision Further Submission
Support/Oppose
not be possible to comply with this requirement, meaning that there is waste.
potential for all septic tank discharges to require a consent.
167
– Rule 5.9
Canterbury
Onsite
Regional
wastewater
Council
disposal
– This submitter seeks to include additional requirements for septic tanks, Oppose in part
including that the discharge shall not include any hazardous waste. Hazardous
waste is defined in the PLWRP as waste which includes bacteria and Relief Sought – Reject part of
pathogens.
the submission on Rule 5.9
which seeks to include
The purpose of a septic tank is to treat human effluent, however the reference to hazardous
discharge from these systems may have residual bacteria, and as such it may waste.
not be possible to comply with this requirement, meaning that there is
potential for all septic tank discharges to require a consent.
263
– Policy 4.23
Transpower
NZ Ltd
This submission seeks to amend Policy 4.23 so that there are no adverse Support
effects “beyond the site boundary” rather than no adverse effects
whatsoever.
Relief Sought – Accept
An amendment to this submission was also sought by Orion, to change the submission point B1.
wording from “no adverse effects” to adverse effects “are avoided”. This
submission complements our original submission.
263
– Rule 5.7 –
Transpower
existing on-site
NZ Ltd
wastewater
treatment
systems
This submission seeks an exemption from complying with the “potentially Support
contaminated land” requirement, which requires substation septic tanks to Relief Sought - Accept
have a discharge permit. Orion supports this submission, as a method to submission point B2.
achieve the outcome sought in its original submission.
263
– Rules 5.155-157 This submission seeks to remove the “non-complying activity” status, for Support
Transpower
Earthworks
earthworks where the permitted activity conditions cannot be complied with.
NZ Ltd
over aquifers
Rules 5.155-157 remain largely unchanged from the NRRP, however if the Relief Sought – Accept
permitted activity standards cannot be complied with, the activity status is submission point B3.
non-complying. Transpower have correctly identified that this activity status
is onerous, given the amount of underground infrastructure which already
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Submitter
Plan Provision Further Submission
Support/Oppose
exists, and the fact that intrusion into groundwater cannot necessarily be
avoided during the installation of electricity distribution networks.
358 – Nga Rule 5.7 – OnRunanga of site wastewater
Canterbury
disposal
and
Te
Runanga o
Ngai Tahu
This submission seeks to require all existing septic tank discharges to obtain a Oppose
discharge consent as a controlled activity.
Relief Sought – Reject
This requirement is considered to be unduly onerous. The environmental submission point relating to
effects of septic tanks can be managed through permitted activity standards, the activity status of Rule
including the relevant New Zealand Standard, without the need for a resource 5.7.
consent.
364 – Forest Rules 5.5 and This submission seeks that the provisions relating to “recovery activities” are Oppose
and Bird
5.6
only able to be applied during a State of Emergency.
Relief Sought – Reject
Recovery activities – especially those associated with the Canterbury submission point on the
Earthquakes – continue long after the initial State of Emergency is declared. general rules 5.5 and 5.6
The Civil Defence and Emergency Management Act 2002 provides Civil
Defence groups the power to carry out works in a State of Emergency. The
purpose of this rule is to provide a relaxed activity status for recovery
activities after an emergency, and so this submission would defeat the
purpose of the rule.
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