October 30, 2017 | Author: Anonymous | Category: N/A
144 Fonterra Co-operative Group Ltd. 321. 108 Forsyth transferred from soil to plants ......
2013/14 Draft Annual Plan Full Submissions
Submitters 1-152
1
Alphabetical index of submitters SUBMITTER ID SUBMITTER LABEL
71 31 67 124 25 47 74 50 30 80 69 51 49 53 113 102 37 117 59 4 54 106 70 84 138 8 96 19 45 145 66 129 144 108 58 9
Allison, Debbie Anonymous Anonymous 2 Averill, Kerry Barlow, Jane Bax, Grant and Christine Baxter, Murray & Helen Beetham, Barrie Blake, Gary Boyd, Derek Brokenshire, Craig Browne, Gabrielle Buchanan, Connal Butler, Bethney Ann Bygrave, Ernie Carter Holt Harvey Ltd Cave, Patricia CCS Disability Action Clarke, Brian Clarke, Stuart Corban, Peter Cotman, James Cresswell, Bryan Dale, Christopher Dean, Matthew Dodds, Roger Edens, Sue Evans, Norman Featherstone, William Federated Farmers, Waikato Branch Flynn, Helen Fogarty, David Fonterra Co-operative Group Ltd Forsyth, Trish Fraei, Peter & Sandra Fraei, Rodney
PAGE NUMBER
116 64 110 236 53 86 120 89 62 129 113 90 88 94 201 164 74 209 101 31 95 177 114 133 271 36 151 47 83 329 109 248 321 182 100 37
2
SUBMITTER ID SUBMITTER LABEL
46 103 48 3 151 136 98 149 100 95 77 101 92 34 78 85 142 52 6 83 40 75 5 65 18 111 152 127 88 14 21 43 121 89 73 82 42 60
French, Elizabeth Frost, Brian & Bridget Gill, Kevin Goodrick, Ralph Gordon & Reid, Roger & Ellis Goudie, Sandra Greene, Frank Hamilton City Council Hamilton Youth Council Harbour, Matt Harris, Stephen Hauraki District Council, Paeroa Office Hayward, Mary Higgins, Allan Hillery, John Hines, Rex Hobbs, Bernard Holmes, Keith Gordon Arkle Hopper, Selwyn Howard, Suzanne Hudson, Nigel Hume, Malcolm Hutchison, Gillian Inframax Construction Limited Jones, Frank Julian, Ron Kaiaua Boating Club (Inc) Kaingaroa Timberlands Partnership Kane, Neville Keefe, Hinewai & John King, Carl Kopuera Land Company Ltd Lakes and Waterways Action Group Trust (LWAG) Lansdaal, Richard Latto Holdings Ltd Lay, Shirley Leather, Peter James LeLievre, Glenn
PAGE NUMBER
85 168 87 30 356 267 153 339 157 150 124 161 147 67 125 134 319 91 34 132 77 121 33 108 46 193 358 241 143 42 49 81 223 144 118 131 79 103
3
SUBMITTER ID SUBMITTER LABEL
57 24 126 7 115 105 44 140 109 26 68 41 90 146 114 72 20 15 56 110 107 91 62 116 134 143 55 61 79 32 150 64 35 1 12 93 23 123
Liddle, Wendy Lithgow, Peter Living Streets Hamilton Lloyd, David Local Authority Shared Services Ltd Lockwood Trusts Partnership Lord, Bob Lowe, John Lower Waikato Catchment Advisory Committee Lynch, David Macdonald, Rex Mallinson, David and Maureen Masters, Gary Matamata Piako District Council Maungatautari Ecological Island Trust Maverick Energy Ltd McDonald, Heather McGill, J & S McLean, Richard Mighty River Power Limited, Generation Services Moehau Environment Group Morrissey-Brown, Michele Nash, Ronald & Patricia New Zealand Historic Places Trust, Tauranga - Lower Northern Area Office New Zealand Transport Agency Newson, Paul Jonathon Nicholls, Robert Ogden, Alan Overwater, Barbara Patterson, Gillian Peart, David Perry, David Petley, Debra Physicians & Scientists for Global Responsibility Reid, Margaret Rennie, Gloria Rigby, R & C Silvester, Linda
PAGE NUMBER
98 52 239 35 207 175 82 317 184 54 111 78 145 335 203 117 48 43 97 190 179 146 105 208 262 320 96 104 127 65 352 107 70 20 40 148 51 231
4
SUBMITTER ID SUBMITTER LABEL
38 141 125 2 86 87 22 132 112 135 147 128 63 133 118 13 39 119 137 94 29 27 16 33 131 122 130 99 97 120 81 17 28 10 104 36 76 11
Sinclair, Alan Joseph Singh, Manvinder South Waikato District Council Stainer, Geoff Steffert, Maurice and Robyn Steffert, Warwick and Marion Stott, Barry Surf Life Saving Northern Region and Surf Life Saving New Zealand Swney, Kevin Russell & Patricia May Taupo District Council Taupo Lake Care Incorporated Te Awa River Ride Charitable Trust, S Perry S Ulmer M Ingle R Waddell J Williams N Richardson t/tees Te Huia, Alison Thames Coromandel District Council The Enviroschools Foundation Thomson, Richard Tidman, Adrian Toop, Martin Tui 2000 Inc Tully, Rosemary Underwood, SP Van Der Staak, Guus Vandy, Philip and Georgette Waerenga Land Co Ltd Waikato District Health Board, Population Health Service Waikato River Trails Trust (WRTT) Waipa District Council Waitomo District Council Walker, Stanley Russell Warm Homes Clean Air, Advisory Group Weaver, Trevor and Sue West, Allan West, Stephen Wetherill, Nicholas and Linda Whaingaroa Environmental Defence Incorporated Society White, Lesley Whyte, David Woods, Hayden
PAGE NUMBER
75 318 237 29 137 141 50 256 200 264 337 242 106 258 218 41 76 221 268 149 61 55 44 66 254 226 251 155 152 222 130 45 57 38 174 73 123 39
5
Index by submission topic HEADING, SUBM. ID SUBMITTER NAME CLAUSE, SUBCLAUSE
PAGE NO
0 General Comments 44 51 67
Lord, Bob Browne, Gabrielle Anonymous 2
82 90 110
1 Introduction, About Waikato Regional Council 136
Goudie, Sandra
267
1 Introduction, Local Government Reform 42 99 129 136 145
Leather, Peter James Waitomo District Council Fogarty, David Goudie, Sandra Federated Farmers, Waikato Branch
79 155 248 267 329
1 Introduction, Our strategic direction, Land and water flagship goal 121 144 149
Lakes and Waterways Action Group Trust (LWAG) Fonterra Co-operative Group Ltd Hamilton City Council
223 321 339
1 Introduction, Our strategic direction, Regional development flagship goal 64 145
Perry, David Federated Farmers, Waikato Branch
107 329
2 Groups of Activities, How to read this section 131
Waikato District Health Board, Population Health Service
254
2 Groups of Activities, Catchment management 99 110 144
Waitomo District Council Mighty River Power Limited, Generation Services Fonterra Co-operative Group Ltd
155 190 321
6
HEADING, SUBM. ID SUBMITTER NAME CLAUSE, SUBCLAUSE
PAGE NO
2 Groups of Activites, Catchment management, Catchment services 55 64 99 104 108 121 123 125 127 131 133 135 144 146 149
Nicholls, Robert Perry, David Waitomo District Council Whaingaroa Environmental Defence Incorporated Society Forsyth, Trish Lakes and Waterways Action Group Trust (LWAG) Silvester, Linda South Waikato District Council Kaingaroa Timberlands Partnership Waikato District Health Board, Population Health Service Thames Coromandel District Council Taupo District Council Fonterra Co-operative Group Ltd Matamata Piako District Council Hamilton City Council
96 107 155 174 182 223 231 237 241 254 258 264 321 336 339
2 Groups of Activites, Catchment management, Harbour catchment management 93 123 133 136
Rennie, Gloria Silvester, Linda Thames Coromandel District Council Goudie, Sandra
148 231 258 267
2 Groups of Activities, Community saftey 110 131 135
Mighty River Power Limited, Generation Services Waikato District Health Board, Population Health Service Taupo District Council
190 254 264
2 Groups of Activities, Community saftey, Waikato CDEM group 100 104 123 133
Hamilton Youth Council Whaingaroa Environmental Defence Incorporated Society Silvester, Linda Thames Coromandel District Council
157 174 231 258
7
HEADING, SUBM. ID SUBMITTER NAME CLAUSE, SUBCLAUSE
PAGE NO
2 Groups of Activities, Community saftey, Resilient development 100 108 110 135
Hamilton Youth Council Forsyth, Trish Mighty River Power Limited, Generation Services Taupo District Council
157 182 190 264
2 Groups of Activities, Environmental, community and economic information 131 133 137
Waikato District Health Board, Population Health Service Thames Coromandel District Council Tui 2000 Inc
254 258 268
2 Groups of Activities, Environmental, community and economic information, Monitoring 123 133 146
Silvester, Linda Thames Coromandel District Council Matamata Piako District Council
231 258 335
2 Groups of Activities, Environmental, community and economic information, Fees and charges (consultation topic) 96 102 105 121 123
Edens, Sue Carter Holt Harvey Ltd Lockwood Trusts Partnership Lakes and Waterways Action Group Trust (LWAG) Silvester, Linda
151 164 175 223 231
2 Groups of Activities, Environmental, community and economic information, Fees and charges air discharges oppose proposed model 104 123
Whaingaroa Environmental Defence Incorporated Society Silvester, Linda
174 231
2 Groups of Activities, Environmental, community and economic information, Fees and charges land use discharges - oppose proposed increase 65 127
Inframax Construction Limited Kaingaroa Timberlands Partnership
108 241
8
HEADING, SUBM. ID SUBMITTER NAME CLAUSE, SUBCLAUSE
PAGE NO
2 Groups of Activities, Environmental, community and economic information, Fees and charges other discharges 104 123
Whaingaroa Environmental Defence Incorporated Society Silvester, Linda
174 231
2 Groups of Activities, Environmental, community and economic information, Understanding natural resources 104 121 123 133 149
Whaingaroa Environmental Defence Incorporated Society Lakes and Waterways Action Group Trust (LWAG) Silvester, Linda Thames Coromandel District Council Hamilton City Council
174 223 231 258 339
2 Groups of Activities, Flood control and protection works 131
Waikato District Health Board, Population Health Service
254
9
HEADING, SUBM. ID SUBMITTER NAME CLAUSE, SUBCLAUSE
PAGE NO
2 Groups of Activities, Flood control and protection works, Flood protection 6 7 59 101 121 133 135
Hopper, Selwyn Lloyd, David Clarke, Brian Hauraki District Council, Paeroa Office Lakes and Waterways Action Group Trust (LWAG) Thames Coromandel District Council Taupo District Council
34 35 101 161 223 258 264
2 Groups of Activities, Flood control and protection works, Stopbank performance (consultation topic) 16 35 146
Vandy, Philip and Georgette Petley, Debra Matamata Piako District Council
44 70 335
2 Groups of Activities, Flood control and protection works, Stopbank performance - support scheduled programme of work 2 3 4 6 7 21 25 29 33 43 49 59 101 109
Stainer, Geoff Goodrick, Ralph Clarke, Stuart Hopper, Selwyn Lloyd, David King, Carl Barlow, Jane Underwood, SP Waerenga Land Co Ltd Kopuera Land Company Ltd Buchanan, Connal Clarke, Brian Hauraki District Council, Paeroa Office Lower Waikato Catchment Advisory Committee
29 30 31 34 35 49 53 61 66 81 88 101 161 184
10
HEADING, SUBM. ID SUBMITTER NAME CLAUSE, SUBCLAUSE
PAGE NO
2 Groups of Activities, Flood control and protection works, Stopbank performance - oppose scheduled programme of work 76 81 97 98 138
Whyte, David Weaver, Trevor and Sue Walker, Stanley Russell Greene, Frank Dean, Matthew
123 130 152 153 271
2 Groups of Activities, Flood control and protection works, Te Puru flood protection works (consultation topic) 38 70 74 83 133
Sinclair, Alan Joseph Cresswell, Bryan Baxter, Murray & Helen Howard, Suzanne Thames Coromandel District Council
75 114 120 132 258
2 Groups of Activities, Flood control and protection works, Te Puru flood protection - support option A 18 28 68 92
Jones, Frank West, Stephen Macdonald, Rex Hayward, Mary
46 57 111 147
2 Groups of Activities, Flood control and protection works, Te Puru flood protection - support option B 13 24 151
Thomson, Richard Lithgow, Peter Gordon & Reid, Roger & Ellis
41 52 356
11
HEADING, SUBM. ID SUBMITTER NAME CLAUSE, SUBCLAUSE
PAGE NO
2 Groups of Activities, Flood control and protection works, Te Puru flood protection - support option C 5 8 9 10 12 14 15 17 19 20 23 36 37 39 40 41 47 48 50 53 54 58 60 61 62 63 66 69 77 78 82 84
Hutchison, Gillian Dodds, Roger Fraei, Rodney Wetherill, Nicholas and Linda Reid, Margaret Keefe, Hinewai & John McGill, J & S West, Allan Evans, Norman McDonald, Heather Rigby, R & C White, Lesley Cave, Patricia Tidman, Adrian Hudson, Nigel Mallinson, David and Maureen Bax, Grant and Christine Gill, Kevin Beetham, Barrie Butler, Bethney Ann Corban, Peter Fraei, Peter & Sandra LeLievre, Glenn Ogden, Alan Nash, Ronald & Patricia Te Huia, Alison Flynn, Helen Brokenshire, Craig Harris, Stephen Hillery, John Lay, Shirley Dale, Christopher
33 36 37 38 40 42 43 45 47 48 51 73 74 76 77 78 86 87 89 94 95 100 103 104 105 106 109 113 124 125 131 133
12
HEADING, SUBM. ID SUBMITTER NAME CLAUSE, SUBCLAUSE
PAGE NO
2 Groups of Activities, Flood control and protection works, Te Puru flood protection - support option C 90 143
Masters, Gary Newson, Paul Jonathon
145 320
2 Groups of Activities, Flood control and protection works, Te Puru flood protection - oppose all options 31 57 111 140 142
Anonymous Liddle, Wendy Julian, Ron Lowe, John Hobbs, Bernard
64 98 193 317 319
2 Groups of Activities, Flood control and protection works, Grahams Creek flood protection works (consultation topic) 32 80 91 136
Patterson, Gillian Boyd, Derek Morrissey-Brown, Michele Goudie, Sandra
65 129 146 267
2 Groups of Activities, Flood control and protection works, Grahams Creek flood protection works - support works proposal 133
Thames Coromandel District Council
258
2 Groups of Activities, Flood control and protection works, Grahams Creek flood protection works - oppose works proposal 93
Rennie, Gloria
148
13
HEADING, SUBM. ID SUBMITTER NAME CLAUSE, SUBCLAUSE
PAGE NO
2 Groups of Activities, Flood control and protection works, Land drainage 52 59 73 103 112 124 152
Holmes, Keith Gordon Arkle Clarke, Brian Latto Holdings Ltd Frost, Brian & Bridget Swney, Kevin Russell & Patricia May Averill, Kerry Kaiaua Boating Club (Inc)
91 101 118 168 200 236 358
2 Groups of Activities, Flood control and protection works, River management 27 136
Van Der Staak, Guus Goudie, Sandra
55 267
2 Groups of Activities, Natural environment and heritage, Biosecurity 34 94 99 108 121 130 133 144 145
Higgins, Allan Tully, Rosemary Waitomo District Council Forsyth, Trish Lakes and Waterways Action Group Trust (LWAG) Waipa District Council Thames Coromandel District Council Fonterra Co-operative Group Ltd Federated Farmers, Waikato Branch
67 149 155 182 223 251 258 321 329
2 Groups of Activities, Natural environment and heritage, RPMS 146 149
Matamata Piako District Council Hamilton City Council
335 339
14
HEADING, SUBM. ID SUBMITTER NAME CLAUSE, SUBCLAUSE
PAGE NO
2 Groups of Activities, Natural environment and heritage, Biodiversity 1 71 79 85 86 87 88 89 107 119 130 131 133 136 137 141
Physicians & Scientists for Responsible Genetics (NZ) Allison, Debbie Overwater, Barbara Hines, Rex Steffert, Maurice and Robyn Steffert, Warwick and Marion Kane, Neville Lansdaal, Richard Moehau Environment Group Toop, Martin Waipa District Council Waikato District Health Board, Population Health Service Thames Coromandel District Council Goudie, Sandra Tui 2000 Inc Singh, Manvinder
20 116 127 134 137 141 143 144 179 221 251 254 258 267 268 318
2 Groups of Activities, Natural environment and heritage, Natural heritage 108 114 116 122 128 137
Forsyth, Trish Maungatautari Ecological Island Trust New Zealand Historic Places Trust, Tauranga - Lower Northern Area Office Waikato River Trails Trust (WRTT) Te Awa River Ride Charitable Trust, S Perry S Ulmer M Ingle R Waddell J Williams N Richardson t/tees Tui 2000 Inc
182 203 208 226 242 268
2 Groups of Activities, Regional democracy, Governance support 75
Hume, Malcolm
121
2 Groups of Activities, Regional democracy, Constituency review inc Maori seats 56 108 129
McLean, Richard Forsyth, Trish Fogarty, David
97 182 248
15
HEADING, SUBM. ID SUBMITTER NAME CLAUSE, SUBCLAUSE
PAGE NO
2 Groups of Activities, Regional democracy, Iwi engagement 75 127
Hume, Malcolm Kaingaroa Timberlands Partnership
121 241
2 Groups of Activities, Regional democracy, Communications 100 104 123 147
Hamilton Youth Council Whaingaroa Environmental Defence Incorporated Society Silvester, Linda Taupo Lake Care Incorporated
157 174 231 337
2 Groups of Activites, Resource management implementation 131
Waikato District Health Board, Population Health Service
254
2 Groups of Activites, Resource management implementation, Community, education and participation 118 120 121 125 130 133
The Enviroschools Foundation Warm Homes Clean Air, Advisory Group Lakes and Waterways Action Group Trust (LWAG) South Waikato District Council Waipa District Council Thames Coromandel District Council
218 222 223 237 251 258
2 Groups of Activites, Resource management implementation, Compliance 46 121 132
French, Elizabeth Lakes and Waterways Action Group Trust (LWAG) Surf Life Saving Northern Region and Surf Life Saving New Zealand
85 223 256
2 Groups of Activites, Resource management implementation, Consent processing 106 121 123 144
Cotman, James Lakes and Waterways Action Group Trust (LWAG) Silvester, Linda Fonterra Co-operative Group Ltd
177 223 231 321
16
HEADING, SUBM. ID SUBMITTER NAME CLAUSE, SUBCLAUSE
PAGE NO
2 Groups of Activities, Strategic and integrated planning, Strategic development 99 115 121 130 134
Waitomo District Council Local Authority Shared Services Ltd Lakes and Waterways Action Group Trust (LWAG) Waipa District Council New Zealand Transport Agency
155 207 223 251 262
2 Groups of Activities, Strategic and integrated planning, Regional planning and integration 1 26 30 104 108 117 119 123 130 133 134 135 149 150
Physicians & Scientists for Responsible Genetics (NZ) Lynch, David Blake, Gary Whaingaroa Environmental Defence Incorporated Society Forsyth, Trish CCS Disability Action Toop, Martin Silvester, Linda Waipa District Council Thames Coromandel District Council New Zealand Transport Agency Taupo District Council Hamilton City Council Peart, David
20 54 62 174 182 209 221 231 251 258 262 264 339 352
2 Groups of Activities, Strategic and integrated planning, Rural public transport 64
Perry, David
107
17
HEADING, SUBM. ID SUBMITTER NAME CLAUSE, SUBCLAUSE
PAGE NO
2 Groups of Activities, Transport connections, Transport operations 45 51 95 100 104 117 123 126 130 131 134 135 149
Featherstone, William Browne, Gabrielle Harbour, Matt Hamilton Youth Council Whaingaroa Environmental Defence Incorporated Society CCS Disability Action Silvester, Linda Living Streets Hamilton Waipa District Council Waikato District Health Board, Population Health Service New Zealand Transport Agency Taupo District Council Hamilton City Council
83 90 150 157 174 209 231 239 251 254 262 264 339
2 Groups of Activities, Transport connections, Total mobility 134 135
New Zealand Transport Agency Taupo District Council
262 264
2 Groups of Activities, Transport connections, Electronic ticketing 134 135
New Zealand Transport Agency Taupo District Council
262 264
3 Finances, Financial overview - general rates comments 11 22 93 104 108 113 123 129 136 145
Woods, Hayden Stott, Barry Rennie, Gloria Whaingaroa Environmental Defence Incorporated Society Forsyth, Trish Bygrave, Ernie Silvester, Linda Fogarty, David Goudie, Sandra Federated Farmers, Waikato Branch
39 50 148 174 182 201 231 248 267 329
18
HEADING, SUBM. ID SUBMITTER NAME CLAUSE, SUBCLAUSE
PAGE NO
3 Finances, Prospective financial statements 11 108 129
Woods, Hayden Forsyth, Trish Fogarty, David
39 182 248
3 Finances, Funding impact statements, including schedule of fees and charges 64 72 75 104 123
Perry, David Maverick Energy Ltd Hume, Malcolm Whaingaroa Environmental Defence Incorporated Society Silvester, Linda
107 117 121 174 231
19
PSGR Physicians and Scientists for Global Responsibility Charitable Trust Formerly Physicians and Scientists for Responsible Genetics New Zealand
PO Box 8188 TAURANGA 3145
+64 7 576 5721
[email protected] www.psgr.org.nz
10 February 2013
CEOs, Mayors and Councillors of all Regional, District and City Councils in New Zealand, cc Community and Local Boards, and CEOs and Board Members of all District Health Boards
Long Term Council Community Plans The Trustees of PSGR thank Council for their response to previous correspondence. We again ask that you take into consideration the following concerns for a sustainable district and a healthy community when establishing your Long Term Plan 2013-2023, and in doing this draw support from the members of District Health Boards and Community and Local Boards. Physicians and Scientists for Global Responsibility is a Charitable Trust established to provide independent scientific assessment and advice on matters relating to genetic engineering and other scientific matters including nanotechnology and synthetic biology. We offer the following: 1 Genetic Engineering (terms also used include genetic modification and transgenics) We draw Councils' attention to the RMA Section 32 analysis for Auckland and northern councils and the work of Dr Kerry Grundy, Team Leader (Futures Planning) at Whangarei District Council and convener of the Inter-Council Working Party (ICWP) on GMO (genetically modified organisms) Risk Evaluation and Management Options. The ICWP has investigated the nature and extent of risks local authorities could expect to face from transgenic organisms in the environment and the options available to address those risks. It has sought legal opinion on whether local government has jurisdiction under the Local Government Act (LGA) and Resource Management Act (RMA) to regulate genetically engineered organisms. The latest documents released on 5 February 2012 can be found at www.wdc.govt.nz. We quote: “... there are significant risks to local government and their communities from outdoor use of GMOs, including environmental, economic and socio-cultural risks” and “the potential adverse effects of releasing GMOs into the environment could be significant – including possible major and long term harm. Moreover, these effects could be irreversible.”i The plan provisions commissioned by the ICWP “provide for a precautionary approach to the way the use of natural resources is managed for the outdoor use of GMOs in order to achieve the purpose of the RMA” and “a rationale for prohibiting the general release of a GMO in district and unitary plans pending the availability of sufficient information about the risk of any potential effects of the activities on the environment. The evaluation also reflects community values in respect of the environmental risks the community is prepared to accept at the moment.”i 20
NZ Councils, Community and Local Boards, and District Health Boards Physicians and Scientists for Global Responsibility
10 February 2013 page 2 of 9
Councils have a duty of care to protect their community from uninsurable long-term costs and damage that may arise given the scientific uncertainty around transgenic organisms in situations of commercial open release. We outline some of the concerns. The terms genetic modification and biotechnology are often used interchangeably with the deliberate process of genetic engineering, which we take as the most accurate description of the technology. While biotechnology encompasses many other processes and offers many important non-transgenic applications that have contributed largely to support and improve agriculture, genetic engineering technology raises the main focus of our concern because of the manner in which it impinges on organisms and their ecological relationships. The application of genetic engineering technology alters the DNA of a living organism in ways which are much more radical than what occurs due to the generally incremental, slow processes of natural evolution. It does this in a way that is inevitably disruptive to some degree as a result of the essentially random insertion of transgenic (or cisgenic) DNA into the functional DNA of a host organism. It may cause noticeable changes in the appearance of the organism and/or differences in the biochemistry and physiology of the organism. These changes are unpredictable and may result in the production of new proteins, with potential toxic effects, within the transgenic organism. Many scientists are concerned about releasing genetically engineered organisms into the environment. That genetic engineering is of community significance for councils to address was amply determined in a 2009 Colmar Brunton Poll, to be found at http://www.wdc.govt.nz/PlansPoliciesandBylaws/Plans/Genetic-Engineering/Pages/default.aspx. New Zealand companies are concerned. Fonterra has said there is insufficient support in this country or from overseas customers to warrant local production of food from genetically engineered sources, and food producers Heinz Watties, Goodman Fielder and others have GE free policies.ii When genetically engineered organisms are released into the environment, their transgenes can replicate, be transferred to other organisms, and contaminate so that the engineered characteristics spread through the eco-system. Farmers in the US face having to eradicate weed species that have developed herbicide-resistant traits, including resistance to multiple herbicides. These so-named ‘superweeds’ can grow aggressively and out-compete transgenic crops. Over-application of herbicides and pesticides to transgenic crops has increased substantially the volume of agricultural chemicals used and this has aided in the development of weeds resistant to those chemicals. In December 2012, the Foundation for Arable Research confirmed New Zealand’s first case of glyphosate-resistant ryegrass in a Marlborough vineyard and blamed frequent applications of that herbicide as the cause.iii Introducing transgenic ryegrass, which is in development, into this country’s pastures would potentially contaminate conventional ryegrasses and would jeopardise our substantial ryegrass seed export industry.iv Trevor James of AgResearch is reported as saying: “There are 61 weeds all around the world resistant to glyphosate; there are six in Australia and it's a major problem with their cropping...”v Ryegrass (Lolium rigidum) is an acknowledged problematic weed in Australia and the first glyphosate-resistant weed was annual ryegrass which emerged in 1996.vi Glyphosate is the active ingredient in the widely applied herbicide marketed as RoundUp. Commercial RoundUp Ready (glyphosate-resistant) cotton was first grown in Australia in 1996 and may have contributed. Other resistant crops grown elsewhere are seen as culpable in the emergence of herbicide-resistant weed species.
21
NZ Councils, Community and Local Boards, and District Health Boards Physicians and Scientists for Global Responsibility
10 February 2013 page 3 of 9
Each year weeds cost Australia over AUD$4 billion in control and lost production.vii Recently, the Australian government committed AUD$15.3 million over four years to establish a comprehensive National Weeds and Productivity Research Programme to reduce the impact of invasive plants. Wild radish (Raphanus raphanistrum) costs the Australian grain industry AUD$140 million/p.a. for weed control and in lost production.viii In relation to widely grown transgenic oilseed rape/canola, Britain’s advisory committee on releases to the environment (ACRE) identified wild radish, wild turnip, hoary mustard, brown mustard and wild cabbage as species from which hybrids could be formed with the transgenic varieties. A Swedish study found transgenic canola seed could remain viable in the wild even 10 years after release.ix In one field trial plot, researchers found 46% of seeds in a wild turnip plant contaminated with transgenic DNA.x Wild radish, wild turnip and wild cabbage grow in New Zealand. Councils will be aware of the heavy costs incurred to remove wilding pines. With experiments on RoundUp Ready pinus radiata some communities potentially face the risk of transgenic pines resistant to glyphosate becoming a superweed. (See ‘2 Wilding Pines’ on page 4.) Dr Charles Benbrook, a research professor at the Centre for Sustaining Agriculture and Natural Resources at Washington State University, US, states: “the spread of glyphosate-resistant weeds in herbicide-resistant weed management systems has brought about substantial increases in the number and volume of herbicides applied. If new genetically engineered forms of corn and soybeans tolerant of 2,4-D are approved, the volume of 2,4-D sprayed could drive herbicide usage upward by another approximate 50%.”xi N.B. There is an application for approval currently before Food Standards ANZ for transgenic soy resistant to three chemicals: 2,4-D (2,4-dichlorophenoxyacetic acid), glufosinate ammonium and glyphosate. Other transgenic crops are being developed to resist 2,4-D (an ingredient in Agent Orange), dicamba (a herbicide in the 2,4-D family), HPPD-inhibiting herbicides, and glyphosate and AL (GAT).xii Transgenic crops also potentially endanger the human environment. In 2009, the American Academy of Environmental Medicine issued a statement ‘Genetically Modified Foods’ that included: “GM foods pose a serious health risk in the areas of toxicology, allergy and immune function, reproductive health and metabolic, physiologic and genetic health and are without benefit.”: http://www.aaemonline.org./gmopost.html. It is claimed transgenic crops benefit farmers. Hear from US farmers who planted transgenic crops on http://www.youtube.com/watch?v=jEX654gN3c4&feature=plcp (24 minutes) and an interview with Nnimmo Bassey, head of Friends of the Earth International speaking of farmers in India, south-east Asia, Africa and Latin America (8.18 minutes), http://www.guardian.co.uk/environment/2011/oct/19/gm-crops-insecurity-superweeds-pesticides. The Supreme Court of India is currently considering the advice of a scientific expert panel for a tenyear moratorium on field trials of genetically engineered organisms. The International Assessment of Agricultural Knowledge, Science and Technology for Development (IAASTD), a large, comprehensive United Nations study, does not support the thesis that genetic engineering is a solution to feeding future generations, and transgenic crops could threaten food security: www.agassessment.org/docs/SCReport,English.pdf.
22
NZ Councils, Community and Local Boards, and District Health Boards Physicians and Scientists for Global Responsibility
10 February 2013 page 4 of 9
PSGR urges Council to apply a precautionary policy on genetically engineered organisms to meet its duty of care to its ratepayers and to protect the environment. For a guide to Council for plan development, we recommend the comprehensive analysis of the myths and truths relating to genetically engineered organisms and peer-reviewed studies found at http://earthopensource.org/files/pdfs/GMO_Myths_and_Truths/GMO_Myths_and_Truths_1.3b.pdf, the executive summary of which follows this letter. This document supports PSGR's recommendations. 2 Wilding Pines Wilding pines are invasive, cost New Zealand millions of dollars to control and are a threat to biodiversity, farm productivity and landscape values. Different conifers dominate in different areas of New Zealand. There are ten main ‘wilding’ species: Radiata Pine (Pinus radiata); Douglas-fir (Pseudotsuga species); Bishop Pine (Pinus muricata); Corsican Pine (Pinus nigra); Dwarf Mountain Pine (Pinus mugo); Lodgepole Pine (Pinus contorta); Maritime Pine (Pinus pinaster); Ponderosa Pine (Pinus ponderosa); Scots Pine (Pinus sylvestris); European Larch (Larix decidua).xiii Forestry in New Zealand is a major export earner and a significant employer. Ninety percent of our plantation forests are in pinus radiataxiv which generate wilding pines to flourish from coastal areas to high altitudes. Pines seed efficiently from pinecones. Wind-blown seeds are widely distributed and readily take root. Wilding pines compete with native trees and plants and pine needles discourage regeneration of native forest floor species. Wilding pines are aggressive colonisers and create economic and environmental consequences for Regional Councils, the Department of Conservation, National Park Boards, private landowners and others. Funding can come from such as the Ministry of Agriculture and Forestry Sustainable Farming Fundxv, government’s Biodiversity Fundsxvi, and the Environmental Enhancement Fund from Environment Bay of Plenty.xvii The monitory sources used deplete the public purse. It is our understanding that Regional Councils are taking action against wilding pines as part of The New Zealand Biodiversity Strategy (2000) which fulfils in part commitments made under the Convention of Biological Diversity to halt the decline of our indigenous biodiversity: http://www.biodiversity.govt.nz/pdfs/picture/nzbs-whole.pdf. In its 2005 Pest Management Strategy, Canterbury Regional Council advocated changes to the district plans of territorial authorities to prevent or control the planting of inappropriate conifers.xviii Of concern to PSGR was the approval by the Environmental Research Management Authority (now the Environmental Protection Agency; EPA) for the New Zealand Forest Research Institute Limited, trading as Scion, to plant pinus radiata with a number of engineered traits, including herbicideresistance: Applications GMF000032; GMF000033; GMF000034; GMF000035; GMF000036; GMF000037; GMF000038; GMF000039; all approved with controls. The experimental trees would be trialled over two decades in the open environment in the Rotorua area. The premise is that the trees will largely be engineered using what is commonly termed ‘terminator’ technology, making the trees sterile, i.e. not able to flower or replicate. Transgenic traits are likely to be unstable and the variants of terminator technology offer no absolute guarantee of sterility. The traits can break down and the trees revert to flowering. Even if totally sterile, terminator trees can spread by asexual means. Genes can spread horizontally in soil bacteria, fungi and other organisms in the extensive root system of forest trees. There could be long-term 23
NZ Councils, Community and Local Boards, and District Health Boards Physicians and Scientists for Global Responsibility
10 February 2013 page 5 of 9
impacts on soil biota and fertility. Sterile monocultures yield more readily to disease. Trees that do not flower and fruit cannot provide food for the organisms that feed on pollen, nectar, seed and fruit; thus, essential pollinating insects may not be available, especially for beekeepers, horticulturalists and crop growers. One of the proposed engineered traits is herbicide-resistance. As we have shown, in the US herbicidetolerant transgenic crops have increased the use of herbicides, rather than cause a reduction in usage. This has led to substantial numbers of weed species becoming herbicide- resistant and in turn causing major difficulties for farmers and other growers. Herbicide-resistant pines could lead to wilding pine superweeds. Worrying is the fact that conventional pinus radiata seeds have been found viable “at least up to twenty-four years.”xix You may feel your council could consider its area of jurisdiction is too far away to worry about contamination or cross-pollination from genetically engineered trees grown elsewhere. In this regard, we refer you to the work of Sing el al (1993) who found that pollen from pine trees had travelled over 600 kms. Pollen is in the order of 100 to 10 microns or smaller in size. Once in the atmosphere, it can travel vast distances. It would need a failure rate of only a part of a percent for transgenes in pollen to contaminate other trees, potentially at great distances, in ways that could not easily be monitored. The risks are environmental and economic. Terminator technology has attracted a voluntary moratorium from many countries because of the risks involved. The effect on New Zealand’s reputation overseas and exports could be damaging. These experiments are not in New Zealand’s best interests. We refer you to our full submission to the Environmental Risk Management Authority (ERMA) on this Application (now the jurisidiction of the EPA): www.psgr.org.nz/index.php?option=co m_content&view=article&id=80: submission-on-application-erma200479-to-field-test-incontainment-pinus-radiata&catid=24:environmental-risk-management&Itemid=39. With the tools contained in the latest release from the ICWP, Councils have the means to endorse their plans with a precautionary statement, or something more stringent, to avoid the undesirable effects of transgenic wilding pines. 3 Nanotechnology Nanotechnology refers to techniques used to engineer structures, materials and systems that operate at a scale of 100 nanometres (nm) or less, the scale of atoms and molecules. One nanometre measures one-billionth of a metre. Recent evidence from hydroponic plant studies showed manufactured nano-materials (MNM) can be taken up and processed by plants. Priester et al (2012)xx found MNM can impact on microbes and microbial processes related to nutrient cycling, to plant growth and composition if MNMs are transferred from soil to plants, and to plant-microbe interactions that affect soil fertility. The researchers propose MNM could alter the quality and yield of soil-based food crops. A further conclusion was that dispersing wastewater biosolids which may contain MNM on paddocks growing food crops could lead to agriculturally associated human and environmental risks from MNM. It raised concern that there could be toxic effects higher up the food chain that could potentially be a threat to any form of life. 24
NZ Councils, Community and Local Boards, and District Health Boards Physicians and Scientists for Global Responsibility
10 February 2013 page 6 of 9
Biosolids that may contain MNM are routinely dispersed on New Zealand paddocks and into water systems. Treated sewage that may contain MNM is discharged into the sea.xxi Council should be aware that MNM can potentially pose serious problems. We do not know what happens when MNM are ground up, incinerated or disposed of in a landfill, or when they are released into the atmosphere, water or soil. Studies have shown nanoparticles can move in unexpected ways through soil and can potentially carry other substances with them. Airborne MNM could travel vast distances. We do not have filters fine enough to trap MNM and we currently have no way of tracking them in soil, air or water. Caution must also arise when we consider studies such as that detailed in the European Respiratory Journalxxii: “Seven young female workers (aged 18–47 yrs), exposed to nanoparticles for 5–13 months, all with shortness of breath and pleural effusions were admitted to hospital. Immunological tests, examinations of bacteriology, virology and tumour markers, bronchoscopy, internal thoracoscopy and video-assisted thoracic surgery were performed. Surveys of the workplace, clinical observations and examinations of the patients were conducted. Polyacrylate, consisting of nanoparticles, was confirmed in the workplace. Pathological examinations of patients' lung tissue displayed nonspecific pulmonary inflammation, pulmonary fibrosis and foreign-body granulomas of pleura. Using transmission electron microscopy, nanoparticles were observed to lodge in the cytoplasm and caryoplasm of pulmonary epithelial and mesothelial cells, but are also located in the chest fluid. These cases arouse concern that long-term exposure to some nanoparticles without protective measures may be related to serious damage to human lungs.” Two of the workers died. It is known that varieties of nanoparticles can pass through skin into the bloodstream, enter an individual cell, and pass through the blood-brain barrier and into the placenta. Relatively few toxicological studies on nanoparticles have been carried out and where they have been performed on animals and fish adverse reactions have been observed, including fatalities. Councils and District Health Boards need to work closely on developing safety measures in regard to MNM. Potential gains from nanotechnology need to be weighed against the fact that science is increasingly being privatised and patents on nano-products and -technologies are growing rapidly. Vested interest can too easily override issues of safety, regulation, and public consultation and interest. This is not a subject for the ‘too hard’ basket. Items marketed today containing MNM include electronic, cosmetic, automotive and medical products, and packaging.xxiii MNM known to be in use in New Zealand are dental fillings, cleaning materials, protective and non-stick applications on glass, personal care products, veterinarian and pharmaceutical products. MNM are inadequately regulated in New Zealand. Manufacturers are not required to state on a product that it contains nanomaterials, or to notify the EPA they intend to import or manufacture products containing nanoparticles, other than cosmetics. Despite PSGR’s repeated requests, the Ministry of Research, Science and Technology, now the Ministry of Business, Innovation and Employment (MBIE), has not updated us on their 2010 position on developments for handling nanoparticle waste material. We refer you again to the actions of the City of Berkeley in California, the first authority to address nano waste: www.ci.berkley.ca.us/ (enter nano waste in ‘search’); title 15, pages 9 and 10 on www.ci.berkeley.ca.us/uploadedFiles/Clerk/Level_3_-_General/BMC-Part1-T1-22--091807.pdf; and www.ci.berkeley.ca.us/uploadedFiles/Planning_(new_site_map_walk-through)/Level_3__General/Manuffactured%20Nanoscale%20Materials.pdf. 25
NZ Councils, Community and Local Boards, and District Health Boards Physicians and Scientists for Global Responsibility
10 February 2013 page 7 of 9
We also refer you to the PSGR submission to Tauranga City Council on nano waste on www.psgr.org.nz/index.php?option=com_content&view=article&id=81:submission-to-tauranga-citycouncil--western-bay-of-plenty-district-council-nano-waste&catid=21:general&Itemid=39, and TCC’s response on www.psgr.org.nz/index.php?option=com_content&view=article&id=83: responseto-submission-o-nanotechnology-waste-tcc&catid=21:general&Itemid=39. Council’s Long-term Plans PSGR urges New Zealand Councils to apply strong precautionary policies on genetically engineered organisms and on nanoparticles for Unitary, Local and Regional plans to meet their duty of care to ratepayers and to protect the environment; and on District Health Boards to be cognisant of the risks of genetically engineered organisms and nanoparticles in terms of human health. We look forward to your response
Yours sincerely
Jean Anderson for the Trustees of PSGR
Paul G Butler, BSc, MB, ChB, Dip.Obst. (Auckland), FRNZCGP, General Practitioner, AUCKLAND Jon Carapiet, BA(Hons), MPhil. Senior Market Researcher, AUCKLAND Bernard J Conlon, MB, BCh, BAO, DCH, DRCOG, DGM, MRCGP (UK), FRNZCGP General Practitioner, ROTORUA Elvira Dommisse BSc (Hons), PhD, Mus.B, LTCL, AIRMTNZ, Scientist, Crop & Food Research Institute (1985-1993), working on GE onion programme, CHRISTCHURCH Michael E Godfrey, MBBS, FACAM, FACNEM Director, Bay of Plenty Environmental Health Clinic, TAURANGA Elizabeth Harris, MBChB, Dip Obs, CNZSM., CPCH, CNZFP; DMM, FRNZCGP General Practitioner, KUROW Frank Rowson BVetMed, Veterinarian, MATAMATA Peter R Wills, BSc, PhD, Associate Professor, University of Auckland, AUCKLAND Damian Wojcik, BSc, MBChB, Dip.Theology, Dip.Obst., DCH, FRNZCGP, FIBCMT (USA), FACNEM, Director and founder of the Northland Environmental Health Clinic, WHANGAREI Jean Anderson, Businesswoman retired, TAURANGA.
26
NZ Councils, Community and Local Boards, and District Health Boards Physicians and Scientists for Global Responsibility
10 February 2013 page 8 of 9
GMO Myths and Truths An evidence-based examination of the claims made for the safety and efficacy of genetically modified crops, Michael Antoniou, Claire Robinson, John Fagan; June 2012, Earth Open Source http://earthopensource.org/index.php/reports/58 Executive Summary: Genetically modified (GM) crops are promoted on the basis of a range of far-reaching claims from the GM crop industry and its supporters. They say that GM crops: • Are an extension of natural breeding and do not pose different risks from naturally bred crops • Are safe to eat and can be more nutritious than naturally bred crops • Are strictly regulated for safety • Increase crop yields • Reduce pesticide use • Benefit farmers and make their lives easier • Bring economic benefits • Benefit the environment • Can help solve problems caused by climate change • Reduce energy use • Will help feed the world. However, a large and growing body of scientific and other authoritative evidence shows that these claims are not true. On the contrary, evidence presented in this report indicates that GM crops: • Are laboratory-made, using technology that is totally different from natural breeding methods, and pose different risks from non-GM crops • Can be toxic, allergenic or less nutritious than their natural counterparts • Are not adequately regulated to ensure safety • Do not increase yield potential • Do not reduce pesticide use but increase it • Create serious problems for farmers, including herbicide-tolerant “superweeds”, compromised soil quality, and increased disease susceptibility in crops • Have mixed economic effects • Harm soil quality, disrupt ecosystems, and reduce biodiversity • Do not offer effective solutions to climate change • Are as energy-hungry as any other chemically-farmed crops • Cannot solve the problem of world hunger but distract from its real causes – poverty, lack of access to food and, increasingly, lack of access to land to grow it on. Based on the evidence presented in this report, there is no need to take risks with GM crops when effective, readily available, and sustainable solutions to the problems that GM technology is claimed to address already exist. Conventional plant breeding, in some cases helped by safe modern technologies like gene mapping and marker assisted selection, continues to outperform GM in producing high-yield, drought-tolerant, and pest- and disease-resistant crops that can meet our present and future food needs. http://earthopensource.org/files/pdfs/GMO_Myths_and_Truths/GMO_Myths_and_Truths_1.3b.pdf. See also 1. The Sustainability Council of NZ www.sustainabilitynz.org/council.asp. 2. GM Watch www.gmwatch.org/. 3. Herbicide-resistant weeds www.weedscience.org/summary/MOASummary.asp and www.weedscience.org/In.asp; 4. PSGR Frequently Asked Questions on Genetic Engineering www.psgr.org.nz/index.php?option=com_content&view=article&id=54&Itemid=25. 5. A Review of the Adequacy of New Zealand’s Regulatory Systems to Manage the Possible Impacts of Manufactured Nanomaterials ( January 2011) www.msi.govt.nz/assets/Nanotechnology-review.pdf. 6. ‘Nanotechnology: safe or not?’ Organic New Zealand September/October 2010 and ‘Nano waste, how do we deal with it?’ Organic New Zealand November/December 2010. 7. The ETC Group on Nanotechnology http://www.etcgroup.org/issues/nanotechnology.
27
NZ Councils, Community and Local Boards, and District Health Boards Physicians and Scientists for Global Responsibility
10 February 2013 page 9 of 9
i
‘Managing Risks Associated with the Outdoor Use of Genetically Modified Organisms Proposed Plan Change, Section 32 Report, and Legal Opinion’ cover note by Dr Kerry Grundy, Convener of the Inter-council Working Party on GMO Risk Evaluation and Management Options. Documents on www.wdc.govt.nz. ii
The Greenpeace GE Free Food Guide is to be updated in 2013 http://www.gefreefood.org.nz/.
iii
www.far.org.nz/index.php/media/entry/glyphosate-resistance-confirmed-in-new-zealand www.nature.com/hdy/journal/v88/n5/full/6800071a.html. v http://www.3news.co.nz/Weeds-herbicide-resistance-a-big-concern/tabid/1160/articleID/280328/Default.aspx. vi Sydney Morning Herald, 8 May 2012. vii http://www.csiro.au/en/Outcomes/Safeguarding-Australia/Aust-Weed-Management.aspx viii http://www.daff.gov.au/natural-resources/invasive/national_weeds_productivity_research_program ix ‘Long-term persistence of GM oilseed rape in the seedbank’, D’Hertefeldt T et al, Biol Lett. 23 June 2008; 4(3): 314– 317. www.ncbi.nlm.nih.gov/pmc/articles/PMC2610060/. x www.guardian.co.uk/science/2003/jul/10/gm.sciencenews xi http://www.nlpwessex.org/docs/benbrook.htm. xii www.soils.wisc.edu/extension/wcmc/2012/ppt/Davis_2.pdf xiii ‘Wilding conifers - New Zealand history and research background’, a presentation by Nick Ledgard at the "Managing wilding conifers in New Zealand - present and future" workshop (2003). xiv ‘Situation and outlook for New Zealand agriculture and forestry’, NZ Ministry of Agriculture and Forestry, 2007. xv ‘The Project’. South Island Wilding Conifer Management Group; retrieved 17 January 2009. xvi ‘Mid Dome project receives biodiversity funding’, New Zealand Government, 19 October 2008. xvii http://www.boprc.govt.nz/news-centre/media-releases/july-2011/environmental-projects-secure-regional-councilfunding/. xviii Canterbury Regional Council (June 2005), Canterbury Regional Pest Management Strategy (2005), Christchurch, New Zealand: Canterbury Regional Council. ISBN 1-86937-563-7. xix ‘The Fire Pines’, Richard Warren and Alfred J Fordham, http://arnoldia.arboretum.harvard.edu/pdf/articles/1040.pdf xx ‘Soybean susceptibility to manufactured nanomaterials with evidence for food quality and soil fertility interruption’, 2012, www.pnas.org/content/early/2012/08/14/1205431109?utm_source=HEADS-UP+2430+AUGUST++2012&utm_campaign=SMC+Heads-Up&utm_medium=email (A) ‘UCSB Scientists Demonstrate Biomagnification of Nanomaterials in Food Chain’ http://ucsb.imodules.com/s/1016/indexNL.aspx?sid=1016&gid=1&pgid=252&cid=1417&ecid=1417&ciid=1790&crid=0 xxi Mangere www.bvsde.paho.org/bvsaar/cdlodos/pdf/beneficialuse941.pdf; Guidelines for the Safe Application of Biosolids to Land in NZ, August 2003 www.waternz.org.nz/documents/publications/books_guides/biosolids_guidelines.pdf; The Cost-Benefits of Applying Biosolid Composts for Begetalbe, Fruit and Maize/Sweetcorn Production Systems in NZ 2004 www.mwpress.co.nz/store/downloads/LRSciSeries27_Cameron2004_4web.pdf Christchurch http://researcharchive.lincoln.ac.nz/dspace/bitstream/10182/1747/1/ssd_sewage_sludge.pdf xxii ‘Exposure to nanoparticles is related to pleural effusion, pulmonary fibrosis and granuloma’, Song Y et al. http://erj.ersjournals.com/content/34/3/559.short 2009 xxiii www.nanotechproject.org/inventories/consumer/ iv
Ends
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H
Stopbanks: a community investment We think the stopbank maintenance works programme we're proposing balances management of risk
and the delivery of cost effective work. Please tell us what you think. The feedback you give us will be considered during deliberations on the
FEEDBACK FORM
Plan.
You are welcome to use this feedback form or send in your feedback on a separate sheet. The council looks forward to receiving your feedback. Submissions close at 4pm on Friday, rz April zor3.
Submitter Title (please circle): Dr @ Firstname: S*uo-l-# Organisation/group
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REGIONAL COUNCIL
Waikato Regional Council Private Bag 3o38 Waikato Mail Centre Hamilton 3z4o
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156
Hamilton Youth Council Our Submission on the Waikato Regional Council Draft Annual Plan Organization: Hamilton Youth Council Contact: Naomi Kumar, Deputy Chairperson on official behalf of the Hamilton Youth Council Email address:
[email protected] Postal address: Level 4, Council Offices, Garden Place, Hamilton City Council, Private Bag 3010, Hamilton 3240 Note: We would like to speak to our submission.
Purpose: This is the Hamilton Youth Council’s submission on Waikato Regional Council’s Draft Annual Plan which aims for a safer, more economically vibrant and ecologically healthy region. Who we are: The Hamilton Youth Council is a representative and advisory body of young people in Hamilton who aim to act as a way for young people to be engaged with the Hamilton City Council and with the local government of our city. We aim to represent as many young people as possible, looking after their interests and making Hamilton a better place for young people to live in. We are currently comprised of 19 young leaders in our city ranging from ages between 15-25 years old. Key points of our submission: Hamilton Youth Council has chosen to submit on the Waikato Regional Council’s draft annual plan as we recognize there are a number of strategies and policies determined by the regional council that directly impact young people. We have selected a number of key areas that we believe are relevant to comment on. We believe it is important that a youth perspective is taken into consideration when designing proposals for the wider Hamilton community as young people make up a
157
significant part of our population, particularly in the Waikato region.
Environmental, community and economic information Regional Perception Survey (in collaboration with Hamilton City Council and district councils)
We agree that monitoring and evaluating the perception of the general public as to what issues are of priority and what issues are of concern is important to the running of effective local government. The Hamilton Youth Council supports the execution of this project in the 2013/14 year and would like to strongly urge the council to take this evaluation one step further by specifically targeting youth in the region. Youth in the Waikato region have a highly vested interest in our environment and local quality of life – young people enjoy our rivers, lakes, land and natural resources, not least our public transportation network. Seeking out youth opinions specifically would ensure that the views of youth which can be different to the views of the community in general are heard. After all youth are the future ratepayers (many already are) and residents of the Waikato region.
Regional democracy Youth engagement with regional council
The Hamilton Youth Council acknowledges that the Waikato Regional Council is a preeminent local government body in our region – and as such the value of the engagement of young people within regional council cannot be forgotten. We would like to thank and express our great appreciation for the outreach previously conducted by council in welcoming us when we have submitted in past committee hearings or by inviting us to be a stakeholder in the strategic transport network review currently being undertaken We would like to take the opportunity however to encourage the council to consider further ways of doing so – not just with the Hamilton Youth Council, but with all other youth councils in the Waikato region and the youth community in general. Other than involvement in transport matters – youth should also be consulted on enviromental issues, land and resource management, environmental monitoring and education amongst them. These are all issues that do create excitement and passion amongst many youth.
Youth representation with regional democracy
158
As the Hamilton Youth Council is the official advisory and representative youth body for the Hamilton City Council – we would like to express our support for a consideration of how a similar concept could be implemented for the Waikato Regional Council. If the regional council were interested in gaining consistent and proactive youth feedback, advice and consultation, we believe that options around this issue should be explored Council might not need its own youth council – however a way of perhaps utlizing the current existing youth councils throughout the region might be the best way of moving forwards. This range of options might include a collaborative group of representatives from all youth councils in the region meeting up through an online forum or physically every quarter. It might include a collaboration between all chairpersons from local youth councils to work towards providing consistent feedback to the regional council or maybe the best approach is by formulating a panel of youth representatives from across the region.
Transport Connections
Hamilton Youth Council understands that nationwide policy relating to bus fare subsidies are not within local government’s control and that the council will be unable to meet the demands of young people in the Waikato community to provide a more affordable public transport system. However we would like to highlight the importance of lowering bus fares for young people in the city despite the unlikelihood of any changes in policy in coming times. We suggest bringing in a discounted student bus pass that would allow tertiary and high school students to purchase a great number of rides at a cheaper cost, enabling value for money. For instance, 100 rides for the general price of 75. Or alternatively a monthly or even yearly bus pass that could allow for unlimited rides on buses within the region. Although many young people are eligible to drive and own their own vehicles, public transport continues to be vital to young people in their commute from their residences to places of employment and education on a daily basis. The draft Annual Plan proposes one of the following options as a means to reduce costs: (a) either reduce the number of routes per trip or (b) reduce the frequency of buses while retaining the existing routes. The Hamilton City Youth Council does not support either proposal as they both have the potential to adversely affect young people. Instead, we propose a balance of the two proposals; for instance during peak times, more buses could be put on each route but during non-peak hours the buses could be made less frequent. Night time routes could
159
frequent more stops as it is potentially unsafe and unadvisable for youth to be walking longer distances at certain hours of the day in particular areas.
Community Safety
Hamilton Youth Council supports initiatives to improve community safety through the given emergency management strategies. Hamilton Youth Council believes that the development of a regional hazard plan should go forward in consultation with young people at the community level as stakeholders if reforms of the Resource Management Act 1991 become law. Young people are members of the community who will be directly impacted by the risks of potential civil defence emergencies. As such when contingency measures are created it is important to keep young people up to date with the plans put in place. Hamilton Youth Council suggests a range of educational programs or promotional strategies designed at informing youth at the community level.
To conclude, we support initiatives in place that plan for the sustainable growth and efficient management of resources in the vision of making the Waikato a flourishing, economically thriving region in New Zealand. Overall, we believe it is important that youth play a key role in informing decision making processes within local government and their opinions are heard during the consultations relating to policy in the community.
Regards, The Hamilton Youth Council.
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2013/14 Annual Consent Holder Charges Submission on behalf of Carter Holt Harvey Limited To:
Waikato Regional Council Private Bag 3038 Hamilton Submission lodged by email
Submitter:
Carter Holt Harvey Limited
Submitted by:
Philip Millichamp National Environment Manager Carter Holt Harvey Pulp Paper & Packaging
Address:
Private Bag 6 Tokoroa 3420
[email protected]
Date:
12 April 2013
1.
CARTER HOLT HARVEY PULP PAPER AND PACKAGING – KINLEITH
1.1
Carter Holt Harvey Pulp Paper and Packaging (“CHH”) is a division of Carter Holt Harvey Limited which is a New Zealand pulp, paper and packaging products processing business with substantial direct investment in the New Zealand economy.
1.2
The Kinleith Mill is one of CHH’s operations, located in the South Waikato District. Being a substantial industrial development, the mill holds a large range of discharge consents and takes, of these 21 major consents bring annual charges.
1.3
We wish to present our submission to the Council in person.
2.
The fees are not justified
2.1
CHH strongly objects to the annual resource consent charges. There is no sound basis for the fees.
They do not reflect the costs of monitoring or
1
164
administration. We note the target of 77.5% cost share for consent holders proposed in the Annual Plan. CHH submits the fee system over-charges Kinleith many times more than the actual costs of administering its consents. 2.2
In 2012/13 the Kinleith Mill paid over $120,000 in fees and rates.
This
included: (a)
$63,000 in rates to the Regional Council.
The majority of these rates
cover services designated “Regional Council general” (which we presume encompasses activities such as state of the environment monitoring). (b)
$14,500 for Regional Council officers’ time and disbursements on an “actual and reasonable” basis from timesheets: These charges appear to cover all activities related to administering and enforcing the consents.
(c) 2.3
The
$43,935.54 (for our 21 consents for “Annual Resource Consent Charges”. annual
consent
holder
charges
cover
matters
such
as
consent
administration, monitoring and supervision and information gathering and research (which includes state of the environment monitoring). Yet for specific sites many of these costs are also charged on an actual cost basis. As set out above CHH was charged over $14,000 last year in actual costs relating to monitoring and administration. 2.4
On top of this there was a charge of approximately $44,000 which we can only assume in light of the actual charges related to matters such as state of the environment monitoring. We believe that this is not a reasonable reflection of
the costs incurred by the local authority in relation to the Kinleith Mill. 2.5
We observe that consent charges for large water related consents are significantly higher than large land use consents (and even large dams on the Waikato). Although it is acknowledged that there is a great deal of complexity and work associated with managing the water resources of the region, in our view there is an disproportionate contribution to state of the environment monitoring by water permit holders like Kinleith: all ratepayers use and access water, and indeed many rural activities rely on the permitted activity rules suggesting a cross subsidy by large users.
This is exacerbated in the case of
resource consents that exist for emergency purposes. 2.6
By way of example we paid $8,455.94 (increasing to $9,460 +GST under the proposed Annual Plan) for our emergency firewater take (consent 961346) under the guise of “Annual Resource Consent Charges” in the year to date. Although categorised as a “large user” consent this would only be used in an emergency, if
2
165
at all.
We query whether there should be a separate category for such
emergency or fire fighting consents. 2.7
A related issue is that an activity such as the Kinleith mill holds a number of consents for similar purposes: there are three water take consents.
Each of
these consents individually incurs a large consent holder charge even though they relate to the same activity – i.e. mill processing (and fire fighting backup). Cumulatively these three consents represent a total annual consent holder charge of approximately $27,000. It seems extreme to suggest that the mere existence of three separate consents should dictate three times the amount of state of the environment monitoring in addition to other actual charges for site monitoring. 2.8
The ability to charge for the administration of resource consents and state of the environment monitoring is prescribed by s36 of the RMA. Section 36(4) provides that when fixing a charge a local authority shall have regard to certain criteria. These include that the local authority should only require a person to pay a charge where (in the case where the monitoring relates to the state of the whole or part of the environment) that monitoring relates to the likely effects on the environment of that person’s activities.
2.9
In the event the local authority may fix different charges for different costs it incurs in the performance of its various functions, powers, and duties in relation to different areas or different classes of applicant or consent holder.
2.10
It is our view that the payment of three significant annual consent charges for water takes cannot relate to the collective effects of the Mill’s activities and the corresponding
need
for such a significant
contribution to
state
of the
environment monitoring. This is not a reasonable cost for the Mill. 2.11
We seek that the Council provide a “multiple large consent holder” category for activities such as the Kinleith Mill which have multiple consents for the same or similar purposes.
3.
Perverse outcomes
3.1
As discussed, CHH suspects the annual charges for the Kinleith Mill are being used to subsidise small consent holders or to cover other Council services. The effect of this approach is to contradict the Regional Council’s responsibility to set policies aimed at promoting sustainable management of natural resources and to recover its reasonable costs in respect of the activity to which the charge relates. By charging exorbitantly more than it costs to administer the consents, the Council
is
discouraging
high-value
users
like
Kinleith
because
we
pay
3
166
considerably more for the resource compared to other users (who may not be efficient), and/or end up subsidising Council activities on unrelated matters. 4.
Poor economic policy
4.1
On page 57 of the 2013/14 Draft Annual Plan it states “In preparing the proposed budget, the council has remained aware of the difficult economic climate that is still affecting our communities”. The policy seems to be ignoring the tough economic
market conditions faced by the Kinleith mill, which are exasperated by a high exchange rate. Whatever the case we do not see evidence of a genuine concern for economic considerations in the fees we are forced to pay. 4.2
A policy of excessive taxation or unjustified charges leads to economic risks. Ultimately this puts pressure on jobs. CHH accepts its responsibility to contribute to the community through paying appropriate rates and covering its costs over and above the general council services. However, we submit that paying more than four times our costs in extra fees is a poorly considered policy with destructive economic outcomes.
5.
Recommendations
5.1
We recommend that: (a)
Large users with multiple consents for the same or similar activities are charged one fee.
(b)
Non-utilised consents for emergency purposes are not required to pay the annual consent charge as a large consent holder.
(c)
Whatever system is used to determine admin fees there needs to be a clear and transparent policy for determining what activities can be charged to consent administration. The invoices need to be understood by consent holders, and above all be auditable. Based on the invoices we have received to date, CHH believes there is room for improvement in this regard.
(d)
CHH also submits that it would be desirable for the fee charging policy to incentivise council officers to work efficiently and to reduce costs.
A
suggestion is to reduce annual consent charges where there is a further charge for actual and reasonable fees (from timesheets).
For example
each hour spent could result in a reduction of half of that time cost from the annual consent charge.
4
167
Karen Wills From: Sent: To:
Subject: Attachments:
Bridget Frost [brfrost@orcon. net. nz]
Wednesday, 10 April2013 3:57 p.m. Have Your Say Submission Submission from Frost Farms.pdf; Submission to WRC.docx; flooded farm 004.jpeg; flooded farm 005.jpeg; flooded farm 007.jpeg; flooded farm 008.jpeg; flooded farm 009.jpeg; flooded farm 0'1O.jpeg; flooded farm 013.jpeg; flood 08 001.jpeg; flood 08 005.jpeg; flood 0B 008.jpeg; IMG_1995.jpe9; IMG_1999.jpeg; IMG 2000.jpeg; IMG_ 2001.jpeg; IMG 200a.jpeg; IMG 2007.jpeg
Hi, Please find attached oun submission due L2th thanks Bridget Fnost
April 2OL3. I
have also attached photos
168
Frost Farms 223 Seifeft Road Tauhei For many years our now the flooding in our area has been getting progressively worse. We has been on our farm since June 1999 and were told when we bought it that generally we could expect some flooding on the bottom couple of paddocks SOME years but that this flooding came in and went out quickly. We found this to be the case until 2007.
From 2007 the flooding on our farm had been a signiflcant percentage of the farm and has progressively been getting worse. Not only has the area of farm flooded been getting bigger but the frequency of the farm being flooded has also increased. - 2008 & 2012 - flooded signiflcantly 3 times, most other years we have gone under at least twice.
The costs incurred to our farm because of the flooding are varied and many and are difficult to put a monetary value on. Pasture damage, regrassing pastures Fencing repairs - costs and time Supplements feed costs while the paddocks are unable to be used Employing extra staff to help cope with the stress Unable to make decisions because of stress Added pressure on family and friends
. . . o . .
Because of the timing of when these floods occur it is primarily when we are most under pressure and in the busiest time of our business. It is also when the pastures are at their optimum and the grazing plan needs to be followed to get the best out of the pastures and be the best for our animals. As this is a natural occurrence we (as with you) have no idea when these things will happen but also we are unable to plan/prepare/protect ourselves in anyway from this happening as the water that is flooding our farm is coming from further up the stream and the stream fufther down is unable to handle the volume of water so it spills onto our land.
I
have attached photos of some of the floods over the years Thanking you for your time Brian and Bridget Frost
169
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