The Waitakere Ranges Local Board's position on the Watercare Plant

In the interests of public transparency I thought I should set out what the Local Board submitted on the resource consent application for the Waima water treatment plant. Here it is.

The submission is subject to final approval which will be considered at our board meeting on September 26.

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The Waitākere  Ranges Local Board is responsible for identifying and communicating the interests and preferences of the people in its local board area.

Followingis our input to the consent application by Watercare.  This relates to the environmental, heritageand social impacts of the proposal.

We would like to be heard at the hearing

Summary

1. We oppose theapplication in its current form.
2. We note theproposed development is in the Waitākere  Ranges Heritage Area and is adjacent to regionalparkland and our view is that it is inconsistent with the objectives of the Waitākere Ranges Heritage Area Act 2008 as well asthe Muddy Creek Local Area Plan.
3. We inviteWatercare to renew consultation with the Waima community to locate a site and aplant design that will satisfy local expectations.
4. We inviteWatercare to investigate repositioning of the plant to the sludge site close tothe Nihotupu lake as identified in the Local Board’s letter to Watercare dated October9, 2018 a copy of which is attached.
5. Alternatively weinvite Watercare to consider repositioning the site in an urban industrial areasuch as Spam Farm in Glendene which is more suitable for the location of alarge industrial complex of this sort.
6. We are concerned
   1. the plant designrequires the destruction of 3.5 hectares of regenerating sub tropicalrainforest that is home to many indigenous species including a previouslyunidentified wasp.
   1. The project willrequire up to 118 heavy vehicle movements a day on Titirangi’s narrow andfragile roads.
7. We support therestoration and repurposing of the Nihotupu Filter Station which is a scheduledheritage building at the entrance to Exhibition Drive
8. We support asignificant restoration fund being established should the new plant beconstructed in the Waima area.

Comment

Waitākere Ranges Heritage Area Act considerations

Weacknowledge that Watercare holds a special designation on the site and theterms of this designation have been considered by the High Court in TPG vWatercare [CIV-2017-404-2762].  Wenote however that the significant ecological area overlay of the Unitary Plan posessome restrictions on what can occur specifically in relation to vegetationclearance and earthworks and stream diversion and therefore overrides thedesignation.

Thesubject site is within the Waitākere  Ranges Heritage Area (WRHA), established bythe WRHA Act 2008. Section 7 of the Act recognises that:

“(1) The heritage area is of national significanceand the heritage features described in subsection (2), individually orcollectively, contribute to its significance.

(2)   The heritage features of the heritage area are—

(a)   its terrestrial and aquatic ecosystems of prominent indigenouscharacter that—

(i)         include large continuous areas ofprimary and regenerating lowland and coastal rainforest, wetland, and dunesystems with intact ecological sequences:

(ii)        have intrinsic value:

(iii)       provide a diversity of habitatsfor indigenous flora and fauna:

(iv)       collect, store, and produce highquality water:

(v)        provide opportunities forecological restoration:

(vi)       are of cultural, scientific, oreducational interest:

(vii)      have landscape qualities ofregional and national significance:

(viii)     have natural scenic beauty:

(b)   the different classes of natural landforms and landscapes withinthe area that contrast and connect with each other, and which collectively givethe area its distinctive character: …

(e)   the quietness and darkness of the Waitākere  Ranges and the coastal parts of the area: …

(g)   the opportunities that the area provides for wildernessexperiences, recreation, and relaxation in close proximity to metropolitanAuckland:

(i)         the subservience of the builtenvironment to the area’s natural and rural landscape, which is reflected in—

(ii)        the distinctive harmony,pleasantness, and coherence of the low-density residential and urban areas thatare located in regenerating (and increasingly dominant) forest settings; …

(l)    its distinctive local communities:

(m) the Waitākere Ranges Regional Park and its importanceas an accessible public place with significant natural, historical, cultural,and recreational resources:

(n) the publicwater catchment and supply system, the operation, maintenance, and developmentof which serves the people of Auckland.”

Section8 sets out the objectives of the Legislation. It says:

“Theobjectives of establishing and maintaining the heritage area are—

(a)  toprotect, restore, and enhance the area and its heritage features:

(b) to ensurethat impacts on the area as a whole are considered when decisions are madeaffecting any part of it:

(c)  to adoptthe following approach when considering decisions that threaten serious orirreversible damage to a heritage feature:

(i)   carefullyconsider the risks and uncertainties associated with any particular course ofaction; and

(ii)  take intoaccount the best information available; and

(iii) endeavourto protect the heritage feature:

(d) torecognise and avoid adverse potential, or adverse cumulative, effects ofactivities on the area’s environment (including its amenity) or its heritagefeatures:

(e)  torecognise that, in protecting the heritage features, the area has littlecapacity to absorb further subdivision:

(f)  to ensurethat any subdivision or development in the area, of itself or in respect of itscumulative effect,—

(i)   is of anappropriate character, scale, and intensity; and

(ii)  does notadversely affect the heritage features; and

(iii) does notcontribute to urban sprawl:

(g)  tomaintain the quality and diversity of landscapes in the area by—

(i)   protectinglandscapes of local, regional, or national significance; and

(ii)  restoringand enhancing degraded landscapes; and

(iii) managingchange within a landscape in an integrated way, including managing change in arural landscape to retain a rural character:

(h) to manageaquatic and terrestrial ecosystems in the area to protect and enhanceindigenous habitat values, landscape values, and amenity values:

(i)   torecognise that people live and work in the area in distinct communities, and toenable those people to provide for their social, economic, environmental, andcultural well-being:

(j)   toprovide for future uses of rural land in order to retain a rural character inthe area:

(k)  to protectthose features of the area that relate to its water catchment and supplyfunctions …

Ascan be seen most of these objectives are protective.  Only objective (k) is supportive of theconstruction of the treatment plant and it talks about protecting featuresrather than changing features.

Section13 of the Act requires a decision making body when considering a resourceconsent for a discretionary or non complying application to give particularregard to the purpose and objectives of the Act.  If the application involves a controlled orrestricted discretionary activity then consent authority must consider thepurpose of this Act and the relevant objectives as if they were mattersspecified in the plan or proposed plan.

Clearlyspecial care needs to be taken in the assessment of this application.

Thecurrently bush covered part of the Watercare site is on a highly prominentlocation at the intersection of Scenic Drive and Woodlands Park Road.

ExhibitionDrive is an entry point to Waitākere  Ranges Regional Park so we believe theprotecting  the values of the park shouldbe a major consideration, along with the impacts on the character of Waima andTitirangi. 

Theproposed changes to the site will have significant impact on the heritage andecological values with the removal of vegetation, the earthworks, theconstruction impacts and the eventual built form.

Weacknowledge the importance of the area’s water supply function and the need fora growing Auckland.  A good outcome wouldbe to balance this with the other heritage features, particularly subservienceof the built environment to the natural landscape, protection, enhancement andrestoration of ecosystems, and the area’s distinctive local communities.

Muddy Creeks Local Area Plan

TheWaitākere  Ranges Heritage Area Act 2008allows for the creation of local area plans. The purpose of these plans is set out in section 25(2) of the Act asfollows:

“Thepurpose of a LAP is to—

(a)        promotethe purpose of this Act and the objectives; and

(b)       provideobjectives (particularly long-term objectives) in relation to—

(i)         thefuture amenity, character, and environment of the local area to which the LAPapplies; and

(ii)        thewell-being of the local community within that area (including its economic andsocial wellbeing); and

(c)        informdecision-making processes that relate to the heritage area.”

Theeffects of a LAP are set out in sections 27 and 28 of the Act.  The provisions are somewhat complex but theboard believes that the terms of any existing plan are a relevant considerationin assessing what heritage features to give effect to and how much weightshould be given.

TheMuddy Creeks Plan, a local area plan for Waima, Woodlands Park, Laingholm andParau, was adopted in 2014. It contains the following passage:

Statement of existing character and amenity

Woodlands Park and Waima arevisually contained on their northern and western sides within the steepforested slopes of the Regional Park and Watercare land that includesExhibition Drive. Houses are nestled within the regenerating forest. Largetrees, many of them kauri, are a prominent feature. Dissected valleys andgullies give each road a sense of intimacy and isolation while offeringelevated glimpses of the Manukau Harbour. At the top of Woodlands Park Road,the Huia filter station is a prominent feature which reminds us of the historyand current water supply function of the area.

Statement of future character and amenity

In Laingholm, Woodlands Park andWaima the delicate balance between houses and vegetation along the slopes willbe maintained. Footpaths designed in sympathy with the area will line the mainroads, and a network of walkways will join pockets of settlements, schools,halls and shops, Laingholm Beach and South Titirangi. Ecological corridorswithin the area will provide safe, healthy and connected ecosystems andterrestrial habitats.

Site selection process and requirement to lookat alternatives

The replacementof the Huia Water Treatment Plant has been a contentious subject in the area.There was strong opposition to locating the plant in Oratia, and there isstrong local opposition to the current proposal.

The followingaspects of the proposal are, in no particular order, the matters of mostconcern:

1. Environmentdestruction including the clearing of over 3 hectares of forest close tosignificant stands of Kauri.
2. Amenitydestruction, particularly for Manuka Road residents who would especially be affectedby the proposal.
3. Disruption to thelocal community caused by construction and truck movements.

The local boardhas always taken a keen interest in issues relating to tree protection.  In a world where forests in Alaska, Siberia,Brazil and Africa are burning and where the planting of sufficient trees may bethe world’s best chance to prevent runaway global warming the thought of 3.5 hectaresof Waitākere  forest and bush beingcleared fills us with dread.

The plant is alarge industrial style plant and is totally out of place in Waima, in asensitive ecological area. 

The board hadpreviously proposed to Watercare that it should construct the plant on anothersite.  A copy of our letter isattached.  Watercare has rejected thisproposal.

We note theproposal would have these benefits:

• Low quality vegetation would becleared
• Watercare would have to remediate asite which is currently a dumping area for treated carbon which is a by productof the treatment process
• The affect on amenity would be limitedas the site is on the far site of a ridge away from houses.

Weaccept however that the proposal would increase the disruption caused by trucktrips to a greater area.

Thissort of activity should take place in an industrial area, not in an area ofenvironmental sensitivity.  We would urgeWatercare to go back to the drawing board on this application and reconsiderplacing the treatment plant in a suitably designated industrial area.

Design

Thesize of the plant is of concern.  Thetechnology being used, settlement tanks, requires this size plant.  We would urge Watercare to consideralternatives such as filtration so that if a treatment plant is located inWaima then much smaller bush clearance is required.

In relation to the current proposal we arepleased to see that the final revised proposal decreased the amount ofvegetation to be cleared by having two separate reservoirs.  Also the intensity of the construction wasreduced by having the second reservoir constructed after the first one wasfinished.

With regards to design, we consider thatthe proposed design is sprawling and that there has been no opportunity taken toreduce footprints of actual infrastructure. Is there not a more effective process that could require smaller moredispersed responses?  Were other sitesexplored for partial filtration?  With adistributed filtration system (including smaller plants at different parts ofthe network) raw water could be piped to different parts of the network andthen filtered and cleaned.

Construction

The effects on the local communitywill be considerable.  Amongst otherthings there will be a number of daily truck movements and it has beenestimated there could be up to 118 per day.

Roads in the area are steep andnarrow and windy.  There arerealistically only two roads that trucks could take into the area.  One is through Titirangi village usingTitirangi Road and the other is on Atkinson Road.  The first will cause considerable disruptionto the village.  The second will taketrucks past two primary and one intermediate school in a one kilometre stretchof road.

Mitigation proposals

We support the proposed mitigation packagehowever have concerns that the construction will put pressure on the catchment whichis wider than the Waima catchment and the mitigation package should addressthis.

We recommend the catchment be extended toinclude Parau to the west, and parts of South Titirangi to the east.

Heritage

We note that Sandra Coneyand Bob Harvey have submitted on the future of the Nihotupu FilterStation.  Wesupport the restoration and repurposing of the Station that is proposed.

We do question if works affecting the Nihotupuand Huia Filter Stations, which have heritage status, can be achieved by use ofthe Outline Plan of Works process.  Webelieve that consideration of the treatment of these buildings should be partof the public hearing process.

Restoration

We consider that the effects are thatsignificant that an increase in the proposed funding to support sustainableon-going ecological change is appropriate.

We also consider there should also beinvestment in social mitigation similar to that provided to the Waterview communityfollowing the NZTA tunnel project that occurred there.

We recommend that the Waima Biodiversity Trustinclude a representative of the Waitākere  Ranges Local Board along with an AucklandCouncil staff representative in its make up. We ask that the Trust Deed bechanged accordingly.  While the trustwill be operating independently there is a need for it to be aware of whatcouncil is doing and for council to be aware of what the trust is doing. Havinga technical representative from Auckland Council along with an electedrepresentative would help with this. The local board oversees council’s localenvironmental activities, including the support of volunteer groups doingecological restoration.

We also consider there should be an emphasison supporting the efforts of locally based environmental groups.

WaimaBiodiversity Management Plan

We recommend thatthe Management Plan include support of the full range of community ledactions in the Muddy Creeks Local Area Plan to deliver on the objectives for“Ecology and Ecosytems” as outlined in Appendix 1 of the plan. The biodiversityplan should support environmental education programmes to foster environmentalstewardship in the area beyond the proposed 10 year life of the trust and itsfunding.