From: Royal Forest and Bird Protection Society NZ Inc
Address for Service:
Al Fleming
PO Box 70 171
Tauranga 3155
8 February 2011
Page # Section Submission
To: Environment Bay of Plenty
PO Box 364 Whakatane
Decision sought:
Whole document
PRPS should adopt a “strong sustainability model” as identified in “Strong sustainability for New Zealand – Principles and scenarios” see http://sites.google.com/site/strongsustainability
Whole document
Whole document
Whole document
The directive nature of the Proposed RPS is supported.
The use of the word ‘enable’ is problematic when it is not used in other parts of s5 of the Act.
The BOPRC produce many maps (GIS format) that would be of great value to iwi / community groups that have GIS capability.
A project to collate the available maps and make them accessible would be valuable.
Retain the directive nature of the Proposed RPS
Review the use of the word
‘enable’ in all objectives and policies.
Include information / map access and availability in appropriate method(s)
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Page # Section
Whole document
Whole document
24 - 26 Objectives 2 and
4
27 2.3.1 Energy
Submission
Environmental Education initiatives should be co-ordinated with other agency, territorial authority, community and business education initiatives.
Where appropriate BOPRC should contract external environmental education providers, e.g. Experiencing Marine Reserves
The RPS was released prior to the gazettal of the NZCPS
Once the NZCPS is gazetted BOPRC should undertake a review of the RPS to ensure that the NZCPS is fully implemented. This may necessitate a variation to the RPS.
Policy 20 of the NZCPS gives clear direction on vehicle access to beaches but the PRPS does not.
The RPS needs to ensure that an integrated approach is taken throughout the region. At present district council approaches are inconsistent and encourage vehicles to some parts of the coast. Adverse effects include public safety, amenity, erosion, and biodiversity maintenance.
The supposition that hydro-electric energy is renewable is incorrect. The water utilised may be renewable (although finite), but the natural character of the river is not.
This should be acknowledged and explained in the introduction.
Subsequent policies should also reflect this.
Decision sought:
Include environmental education project in appropriate method(s)
Include wording to provide for review of RPS so as to ensure NZCPS is implemented
Provide more specific direction on controlling vehicles on beaches to ensure an integrated approach i.e. policies and methods.
Amend discussion of hydro-electric energy to clarify that is only a partially renewable source.
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Page # Section
34
54
73
75
76
Geothermal sustainability
Objective 18
2.10 Water quality and Land
Use
2.10 Water quality and land use
2.10.3
Objective 29
Submission
Geothermal energy should not be managed within a 100 year timeframe. If used “sustainably” geothermal resources may self replenish.
Significant resources need to be identified in policies and methods so these resources are not lost or adversely affected through permitted activities.
Community groups are also involved in the Kaimai Catchments Project including
Forest and Bird’s Kaimai Mamaku Campaign. See www.kaimaimamaku.org.nz
for more information
This issue should explicitly mention both stormwater and ‘point source’ pollution associated with:

Inappropriate agricultural practises, e.g. cows in unfenced streams
 dairy factories and forestry plants, e.g. Tasman pulp and paper
Should include reference to life supporting capacity of freshwater ecosystems.
Decision sought:
Remove the presumption that geothermal resources can be depleted.
Add text identifying significant resources
Add “iwi, community groups, and landowners
See submission
3
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Page #
79
80
Section Submission
Water Quantity The national ‘Report of the Land and Water forum: A fresh start for freshwater’ identifies a number of recommendations associated with water quantity and quality. One example is rural water supply for agricultural, forestry and horticultural purposes should be metered and a water rate charged. Part of the revenue generated should be used for river / stream restoration.
The RPS should provide for a review of the RPS to ensure that the approved Land and Water recommendations are provided for / implemented asap.
This may necessitate a variation to the RPS.
Objective 31 Demand for water currently exceeds supply in many catchments of the BOP. Demand is likely to increase.
On this basis the objective “meet the range of uses and values for which water is required” is untenable.
Decision sought:
Include wording to provide for review of RPS so as to ensure that recommendations from the Report of the
Land and Water forum NZCPS area provided for / implemented asap
Rewrite this objective to ensure that water allocation
(a) Safeguards the life supporting capacity of freshwater ecosystems; and (b) meets the reasonably foreseeable needs of future generations; (c) recognises and provides for s 6 matters and (d) is allocated according to agreed criteria, rather than being on a first-come, first-served basis.
4
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Page # Section
92 Policy CE 6B p92
Mangroves
Submission
NIWA and Forest and Bird have identified significant concerns associated with the current methodology of mangrove removal in Tauranga harbour.
Forest and Bird has recently submitted a paper to the BOPRC which identifies alternative methods of removal and a trial and monitoring regime associated with those methods.
The following criteria should also be taken into account when considering applications to remove mangrove:
 any existing protection status on the proposed removal site
 is the area proposed to have greater protection
 is the mangrove part of a good quality vegetation sequence
 connectivity of habitat along estuary margins
 avifauna habitat values
 high tide bird roost
 fish habitat
Decision sought:
Remove the term enable
Add the aforementioned criteria to the policy
5
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Page # Section
95 Policy CE 12B
Enabling sustainable aquaculture
Submission
An “ecosystem integrity” approach should be adopted within a Regional Coastal
Plan.
Identify “marine habitat types” through the DOC / MinFish Marine Protected
Areas mapping process, i.e. marine habitat stocktake, prior to potential aquaculture areas being identified / established.
No mention is made of the potential effects of aquaculture on marine mammals.
Research funding should be provided by industry for appropriate research on ecosystem effects of aquaculture, e.g. mapping benthic habitats.
An industry code of practise should be developed at a national level and enforced by BOPRC
Decision sought:
Remove the term enable
Amend to include

Ecosystem integrity

Adverse effects on marine mammals
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Page # Section
96 Energy and
Infrastructure
Policy EI 1B
104 and
105
Integrated management
Policy IR 8C p
Policy IR 9D
Submission
Support the intent of this policy however:
Hydro-electricity is considered to be “renewable” within the PRPS.
However once a river is dammed it is non-renewable.
The current wording of “enabling … the use of small scale …renewable energy generation” encourages proposals such as the BOP Electricity
Kaituna River Dam. A significant stretch of the Kaituna rivers natural character, i.e. fast flowing rapids, would be changed to a slow moving lake.
The damming of undammed rivers within the BOP should not be enabled.
Enabling is again inconsistent with the Act.
This policy does not reflect the range of BOPRC activities regarding biodiversity protection. Examples include the Kaimai Catchments Project
(catchment management), biodiversity management plans, freshwater biodiversity and funding for landowners to fence riparian strips based on biodiversity values.
Decision sought:
Amend policy so that renewable energy is prompted and provided for where:

It is appropriately located

It is at an appropriate scale
 adverse effects are mitigated
Renewable energy should also recognise and provide for matters of national importance.
Add section which identifies aforementioned methods and include the term freshwater biodiversity.
7
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Page #
105
114
Section
New Policy
Policy IW 1B
Policy NH 6B
Submission
The New Zealand Emission Trading Scheme provides the opportunities for Regional Councils to invest in carbon sequestration projects.
The BOPRC could produce a scoping report identifying carbon sequestration opportunities including afforestation and pest control activities. This should be integrated with the proposed
Regional Pest Management Strategy.
Terrestrial and freshwater biodiversity gains should be provided for when identifying potential investment projects.
Why only (c) In the Western Bay of Plenty sub-region only?
Decision sought:
Include a new policy to identify carbon sequestration opportunities with afforestation, pest control and restoration of terrestrial and freshwater biodiversity values.
The sea level changes identified in the PRPS are less than those identified in the Intergovernmental Panel on Climate Change
(IPCC) 2007 report entitled: Climate Change 2007: Synthesis report.
A conservative sea-level rise projection by the IPCC (A1T) was a rise of between 1.4 and 3.8 meters. Forest and Bird note that
1.4 meters is significantly greater than the 0.8 m identified in (c) of Policy NH 6B.
Delete the words ‘In the western Bay of plenty sub-region only”.
Amend in line with best information, i.e. IPCC projections.
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Page # Section
124 Policy WL 6B
Submission
The proposed RPS does not comment on whether performance targets established in the Dairy and Clean
Streams Accord or associated Regional Action Plan have been met.
If there are non-compliant farms within the BOP then these farms should be identified and direction given to for them to comply.
This submission notes that a fundamental flaw with the
Dairying and Clean Streams Accord is the definition of an
“accord stream”, i.e. deeper than a red band (ankle depth) and wider than a stride and permanently flowing.
The BOPRC definition of streams should include all freshwater ways including those shallower and narrower than “accord streams”.
Decision sought:
Add “Undertaken an audit of dairy farms within the
BOP so as to assess whether they comply with performance targets as identified in the Dairy and
Clean Streams Accord”
Add appropriate methods and implementation
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Page #
124
126
Section Submission
Policy WL 6B Nutrient management plans which reuse dairy shed waste, retire / afforest uneconomical land parcels and create natural wetland systems; as opposed to only modifying fertiliser regimes, should be implemented over time.
Regional Council to facilitate and monitor development and implementation of ‘best practise’ farm nutrient management plans.
These should be a requirement of dairy farmer supplier contracts.
Policy WQ 1A Enable word is inappropriate (see earlier comments).
126
126
Policy WQ 2A Minimum flow requirements should maintain freshwater ecosystems.
Decision sought:
Add “Best practise nutrient management plans should be mandatory on all dairy farms by insert achievable date
Change the word “enable” to
“encourage”.
Amend (a) to read “surface water bodies that maintain freshwater ecosystems …”
139
Policy WQ 3B
Allocating water p126
Method 54:
Provide and support environmental education programmes
Forest and Bird support the move away from first-in, first-served.
See earlier comments re Land and Water Forum recommendations.
Environmental education programmes should be inclusive of all indigenous ecosystems and include experiential learning.
Experiential learning is best practise, school curriculum orientated and most effective in changing behaviours
Amend “… support experiential education
…Amend (b) to read “all Indigenous ecosystems including forests, wetlands, estuary, dune and marine ecosystems”
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The Society wishes to be heard in support of this submission.
If others make a similar submission, the society will consider making a joint case with them at the hearing.
Royal Forest and Bird Protection Society NZ Inc
Al Fleming
Central North Island Field Officer
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