West Coast Regional Council

Regional Policy Statement Review Discussion Document

Summary of Feedback Received

March 2014

Contents

Background ........................................................................................................................................................ 1

Summary of Response – ‘Yes’ ............................................................................................................................ 3

Summary of Response – ‘Yes, and…’ ................................................................................................................. 6

Summary of Response – ‘Yes, but…’ ................................................................................................................ 18

Summary of Response – ‘No’ ........................................................................................................................... 22

Summary of Response – ‘Other’ ...................................................................................................................... 35

Complaints Regarding Council ......................................................................................................................... 46

Submitters ........................................................................................................................................................ 47

1

Background The Council released a Discussion Document as the first stage of the review of the Regional Policy Statement (RPS) on 18 November 2013. The feedback period was then extended, and closed on 17 January 2014. The Discussion Document identified two new Regionally Significant Issues: 1. Promoting Positive Effects – Using and developing our natural resources; and 2. Promoting Sustainable Communities. The purpose of the Discussion Document was to initiate discussion on what is important to the West Coast community, to gain feedback from these communities, and to promote general awareness of the RPS review. Staff and Councillors made themselves available at towns throughout the region to answer questions and talk to the public as well as attending a number of meetings. A total of 233 written responses were received on the Discussion Document. Feedback Received There were a wide range of responses received with a clear majority (75%) in support for the approach and direction proposed by Council in the Discussion Document. A breakdown of the responses received by category is provided below.

Type of Feedback Number Percentage

‘Yes’ Support for new provisions identified in the Discussion Document 68 30%

‘Yes and…’ Support for new provisions identified in the Discussion Document and provided further comment on questions posed or additional feedback

93 40%

‘Yes but…’ Support for provisions in the Discussion Document but noted reservation on some matters

12 5%

‘No’ Did not support the new provisions identified in the Discussion Document 37 16%

‘Other suggestions’ Did not indicate support for or against provisions identified in the Discussion Document but provided ‘Other’ issues that thought were regionally significant

16 7%

‘Complaint against Council’ Used this as an opportunity to make a complaint against the Regional Council 4 2%

Total 230 100%

No particular comment provided 3

While the ‘Yes’ and the ‘Yes, and…’ comments are self-explanatory, feedback provided from those in the ‘Yes, but…’ category supported the direction proposed in the Discussion Document, provided that development was not at the expense of the environment. Responses from all categories (‘Yes’, ‘Yes, and…’, ‘Yes, but…’ and ‘No’) provided additional suggestions for other regionally significant issues, potential wording for the current RPS as well as other considerations to take into account when reviewing the RPS. There was limited commonality in these though the three topics that were raised several times included a diversification of the economy, harvesting of wind thrown timber and climate change. A number of the suggestions do not relate directly to our regional council RMA functions, or would not qualify as regionally significant issues, but

2

these matters can be raised with our partner organisations (e.g. District Councils, Development West Coast and the Department of Conservation). There were also a number of comments made that will be useful to refer to when reviewing individual chapters of the RPS. These comments will be considered by staff during the review process. Note that not all feedback received has been recorded verbatim. However staff have endeavoured to capture the main points raised by submitters. Process from here Staff will use the comments made on the Discussion Document while reviewing the RPS. Council is anticipating the draft RPS to be notified for public consultation in mid-2014. Further updates on the progress of the review process can be found on the RPS page on the Council website www.wcrc.govt.nz.

3

Summary of Response – ‘Yes’ Summary of comments made – ‘Yes’ Submitter No. Should enable industries and commerce and welcome them to do business providing sustainable management RMA purposes are met. Encourage controlled growth – believe region could support population of 50,000. Most communities able to absorb proportionate growth. Transport and infrastructure may need development but undertake in line with growth not pre-emptive.

6

Strongly supports review of the RPS to ensure balance for the WC for the future by recognising the importance of resource use and development and ensuring that all development is undertaken in a way that benefits the local communities whilst promoting the sustainable management purpose of the RMA. Sustainability means regard for the environment but equally important is the consideration of social and economic values – ensuring a better quality of life for everyone, now and for generations to come.

11

Supportive of this and growing the Coast 13, 24 Believe that the Council are on the right track; Agree with changes to maintain community feel; region needs balance so that communities are sustainable; making it easier for new industries, retaining our proud identity of being West Coasters and maintain our good environmental standards; Support review proposed and good to see common sense policy – is frustrating in trying to get on with business when the holdups cause your business to become stagnant; RPS should actively promote growth and development; support utilisation of natural resources for the economy of the region; As a community need to have a balanced approach to development allowing the use of reserves and resources; use and development of resources vital for region and RPS should have leading role; About time someone woke up and stood up for the residents of the West Coast; support the council; need development to stimulate job creation to ensure we have the services to keep West Coasters employed and get new people into the district with different skills; be a good idea to review; completely support new direction considering adopting; like the direction Council is heading; support the Council; Support the Council to allow more consideration for what the people and their communities would like for the future; support the Council; pleased to see you are promoting the positive use of resources; support initiative to find a more balanced approach to resource management in our region and to encourage and attract industry and investment; I support the idea; I support the WCRC; Agree that there needs to be more consideration of the people of the West Coast for sustainable communities – I hope the Regional council puts this in the RPS; we support the ideas within the Discussion Document and the review of the RPS; very pleased to see that Council is reportedly putting a greater emphasis on jobs and industry including mining; support the Council promoting sustainable communities; support the ides and the review of the RPS; Support the Discussion Document and the Haast to Hollyford Road; agree you have identified the new significant issues for the WC – we support what you are doing; fully support the direction laid out; support the Council; Support the Council with this policy; proposals are up to date and valid; support approach; agree with proposal; support the council in their endeavours; support the changes; support the changes; support; Discussion Document makes sense and is about time that RCs started looking at this sort of thing – needs to be more of this attitude in NZ; fully support direction laid out; agree – need to create more jobs for all ages; this would be in the interest of the WC; agree with Discussion Document; agree with Discussion Document;

15, 16, 17, 18, 21, 22, 25, 26, 31, 40, 50/51, 54, 55, 56, 59, 60, 61, 62, 68, 69, 73, 75, 78, 83, 95, 102, 115, 126, 141, 143, 146, 156, 161, 167, 168, 174, 186, 187, 188, 210, 215, 216, 226, 228, 229

As a West Coast community we need to have the predominant say in our future development. Need the consent process to be achievable in a timely manner but also ensure either minimal impact on the environment or where that is not possible, sound remedial practices, once the operation is complete. 26

Support a more balanced approach. The promotion of sustainable management of our natural resources should look at communities and jobs in the first instance and then balance this with the environmental issues. WC needs to grow in wealth in order to protect the environment. 30

Support the inclusion of the two new RSI’s. RMA requires consideration of both positive and adverse effects. Including specific reference to these in the RPS will ensure that the Regional and District plans can achieve a balance between allowing positive effects and avoiding, remedying and mitigating adverse effects of activities on the environment. Will assist WC Councils when exercising their functions under the RMA to promote the sustainable management of our natural and physical resources and will allow our communities to provide for their social, economic and cultural wellbeing thereby achieving the purpose of the Act.

37

Congratulate the Council for adopting a more positive approach regarding resources available. Needs and welfare of local ratepayers should be taken into consideration when writing the RPS. I believe that this is a very important part of this document. I believe that these ideals can co-exist with our environmental responsibilities. 66

I support an RPS that promotes through better access provision of the Regions minerals to enable improvements in economic, social and cultural well-being. I support an RPS that places a strong emphasis on the opinion and consensus of the local population rather than those outside the area. I support an RPS that encourages and supports economic growth by allowing better access to land.

74

4

Summary of comments made – ‘Yes’ Submitter No. I support the recognition that people and their communities are also part of the environment that needs to be looked after now and into the future. The RMA should allow this so I agree that the RPS needs to be about promoting positive effects to develop sustainable communities on the Coast. I support what the regional Council is trying to achieve with amendments to the RPS to allow for more consideration of the human ecology so there is both a healthy environment and healthy economy.

77

Council needs to support responsible mining to benefit the WC economy. We need to grow our economy by using our resources wisely. 88 Congratulations on the focus and direction of the Regional Policy Statement Review. I fully support the intent of the statement which has a focus on people and the communities they live in and opportunities available. Your "Finding the Balance" document is timely and needed to create the platform for growth within the West Coast Region while managing resources in a sustainable way.

91

I support the review of the RPS. It is well overdue and needs to be streamlined and made relevant to today. The new RPS should also balance the environmental impacts of any land use with the social and economic benefits to the WC. It should also put greater weight on submissions from residents of the WC that are directly affected than those who live off the WC and are not affected.

96

Support proposed changes to the RPS. The promotion of the positive effects of natural resource use and development will benefit the WC. Anything that provides balance to the current environmental focus of the RMA will provide more certainty for investment in and development of natural resources on the WC. 132

I congratulate the Council on their courage in deciding to enforce the RMA properly by giving weight to social and economic issues, not just environmental, as has been the case in the past. I agree that we should promote growth for sustainable communities on the WC. 140

The Council has correctly identified the significant resource management issues for the WC. The Discussion Document identifies the major sectors contributions to GDP and hence employment on the WC. Minerals, Dairy and Tourism. Without these proposed changes to the RPS the first two industries are under threat. Sustainable communities are vital and their opinions and input should receive priority over outside parties and organisations views. The promotion of positive effects in the RPS is supported. I believe this would change the present dismal outlook for business and employment in the region. I support the policies outlined by the WCRC and applaud them for their vision.

142

Support the Council in considering promotion of social, cultural and economic aspects of the RMA in its upcoming review. If its long term policy can encourage and promote opportunities for job and economic growth as well as manage environmental issues and effects, I foresee a positive and dynamic environment ahead. 152

We have had a mining interest on the WC for over 3 years. We find this to be a region with tremendous potential for growth in many sectors especially mining. Like many WC people we have become frustrated by almost all significant developments within our region being held up due to objections and actions of well organised national organisations with extreme environmental views and crusades. Congratulate the Council for this insightful action to consider reviewing our RPS to develop it into an enabling document while maintaining our environmental values. Yes we think you have identified the significant issues with relation to resource consenting on the WC. You are absolutely correct in that the process needs to consider alongside the environmental effects the positive effects of projects in generating economic activity on the WC and the contribution a development would have in community development. In including the economic and community contributions of a particular project or development, this will also encourage second level processing on the WC and further stimulation of regional economy and communities. Support the RPS promoting the positive effects of development. Agree that the RPS must be an engaging document. Support the development of a vision for the WC to have sustainable communities with a strong local identity. The careful and considered utilisation of our abundant resources we can grow our WC economy and communities while protecting and preserving our natural environment for future generations.

153

Think this proposed RPS is better balanced to reflect the economic aspects of the WC. It also better represents the current economical environment and the communities need arising from this. Caring for our environment while providing opportunities for WC’ers to prosper on the Coast. 183

Believe the RPS should not just be about environmental effects but must also look at economic and community benefits. Agree with the suggestion that the RPS actively promotes opportunities for jobs, economic growth and population growth. The management of environmental effects needs to remain but to be considered in a balanced way with the above. The RMA talks of “promoting sustainable management of natural and physical resources”. It is all about a sensible balance.

194

Agree with the direction being taken by the Council. The consent process to utilise our natural resources must be simplified. There must be financial consequences for entities who appeal decisions. If they lose they must be liable for lost earnings, personal guarantees need to be taken to cover these potential liabilities. 196

5

Summary of comments made – ‘Yes’ Submitter No.

Generally supports the direction foreshadowed in the two discussion points posed by the discussion document. Consider that ‘promoting positive effects’ is an appropriate aim, and that recognition should be given within the RPS for the sustainable use and development of resources which help provide for the community’s social, cultural and economic well-being. Also support the aim of ‘promoting sustainable communities,’ and in particular, efficient growth that is well integrated with strategic infrastructure. However, consider it important that these new concepts are considered in the wider context of all regionally significant issues. In this way support the introduction of new objectives and policies in the RPS which are compatible with existing well-founded aims and particularly aims that recognise and provide for regionally significant infrastructure.

201

Support this initiative. Need to do everything we can to encourage growth on the West Coast while also maintaining the environment. 205 The RC gets a lot of pressure from DoC, Forest and Bird and other organisations but not much support. Conservation is not the only saviour for the WC. We need to promote our resource use and Council need to promote economic and social development. RC needs to support our mining industry on WC to eradicate unemployment issues. We need to grow our economy by utilising our resources.

225

6

Summary of Response – ‘Yes, and…’ Summary of comments made – ‘Yes, and…’ Submitter No.

RPS should encourage growth in transport infrastructure including: - International airport required at Hokitika - Expansion and upgrading of roading network - Haast to Hollyford road identified – will have greatest positive impact in 50 years

2, 3, 4, 19, 32, 39, 81, 92, 93, 99, 101, 111, 112, 117,127, 128, 148, 165, 171, 176, 177, 207, 219, 220, 222, 223, 224

RPS should assist: - The mining sector - Developers of electricity projects - The farming sector and ensure that high rainfall and quick discharge taken into account when considering impact of intensive dairying; and - Ensure needs of communities are noted as a matter of significance

2, 3, 4, 19, 32, 39, 81, 92, 93, 99, 101, 111, 112, 117, 127, 128, 148, 165, 171, 207, 219, 220, 222, 223, 224

Economies grow or die based on RPS, allow views of minority to dictate outcomes and RPS fails and our community suffers.

2, 3, 4, 19, 32, 39, 81, 92, 93, 99, 101, 111, 112, 117, 127, 128, 148, 165, 171, 207, 219, 220, 222, 223, 224

Develop more mining on the Coast. 5 ‘Modern-mining’ promoted, good restoration rewarded and the RPS promote best practice and the extractive industries as an integral mix of activities. 7 Environmental issues take up more than the social or economic issues. To assist with tourism need to provide through routes – Haast to Hollyford and Karamea north as have experience with tourists objecting to back tracking. Most of the region needs development in all areas. Has been some poor development in past but regeneration quick – earthquake slips example, but do need a future. Hydro development should be encouraged, highest rainfall little generation. Water quality improving but needs to get better

9

Review needs to embrace the identity of our communities built on farming, mining, milling, horticulture, agriculture and all associated industries – where we have come from and a priority for next 10-20 years. Should promote investment and job creation by engaging more in the positive effects of development and not prioritise all the adverse effects – balance must be met. RMA a robust process but the prolonged time for appeals must be stopped or better defined to a limited period. Imbalance of high compliance costs and poor regulation process must become more proactive to enable economic growth and future investment in the region.

10

Support the initiative as opposed to current focus which almost exclusively focusses on environmental wellbeing. Sustainable management principles still to be adhered to but not at the expense of all the other benefits to communities. Economic, social, cultural and environmental wellbeing effects need to have equal consideration in all decisions regarding resource management decisions. The conservation and mining industries can and must work together to find manageable compromises thus keeping door open to minerals projects which can and have so many benefits for local communities. Mineral extraction single largest contributor to GDP in the region with multiple

23

7

Summary of comments made – ‘Yes, and…’ Submitter No. benefits. Agree that new and existing extraction projects remain subject to planning and clearly defined standards regarding land use however the conservation movement has worked hard to restrict mining activity in the region and the negative publicity has portrayed a distorted view of all mining companies. The benefits of mining to promoting sustainable communities are many including: - Significant contribution to local communities in terms of community grants and sponsorship, and the money circulated in the community from wages and salaries; - Provides work for locals and those from overseas. Contributions from these individuals is significant through exposure to new cultures and ideas; Unlike industries such as tourism which fluctuate depending on domestic or international trends, mining is consistent in terms of being able to provide for and develop communities. Like many West Coaters have become frustrated by almost all significant developments within our region being held up due to objections and actions of well organised national organisations with extreme environment views and crusades. Congratulate Council on insightful action to develop RPS into an enabling document while maintaining our environmental values, support promoting positive effects of development and the development of a vision for the WC to have sustainable communities with a strong local identity. Yes have identified the significant issues with relation to resource consenting on the WC. Correct that the process needs to consider alongside the environmental effects the positive effects of projects in generating economic activity on the WC and the contribution a development would have in community development. In including the economic and community contributions of a particular project or development, this will also encourage second level processing and further stimulation for regional economy and communities. Support RPS promoting positive effects of development. Must be an engaging document. Support development of a vision for the WC to have sustainable communities with a strong local identity. Careful and considered utilisation of our abundant natural resources we can grow our WC economy and communities while protecting and preserving our natural environment for future generation.

27, 28, 29

Owners of freehold land should be able to develop bush clearing and Schedule 2 wetlands. There is still plenty left for the environment. Getting a mining permit is easy. Trying to get a land use consent is too costly with every obstacle put in your way. In the end you just walk away. Tourism has its place but they too are sick of the long bush corridor and want to see things. Why should we have to build walls to prevent people seeing a gold screen working.

46

Have identified the new RSI’s for the region. Where possible less need for consents (i.e. more activities that are permitted). This is assuming the rules or guidelines are sensible and realistic for the West Coast. Consider that promoting the positive effects of using and developing our resources would assist with balancing the RMA and that the inclusion of these policies would assist with stimulating economic growth. New RPS should assist with creating well paid long term goals. A realistic population growth target is 3%. Pushing activities such as tourism could potentially put unnecessary strain on our transport system and public services, resulting rate payers having to lump this bill.

47

We agree that a more balanced approach is critical to resource management for the West Coast. The Council is to be congratulated for taking such a proactive approach to identifying the new significant resource management issues for the West Coast. The approach that has been adopted is totally on the right track with the discussion points included in the Discussion Document. In the past environmental considerations have been given too much weight and social and economic well-being has been given too little focus. More focus on promoting positive effects and finding ways to fund and establish our sustainable communities should both be priorities. The inclusion of use and development provisions that promote industry development and stimulate economic growth would be fantastic. Because much of the Coast is locked up (or rather “protected”) I feel that we should be able to and encouraged to make excellent economic and social use of the land we have for economic benefit. The cumulative impacts of intensive residential/commercial/industrial developments that are well managed will not detract from the overall environment of the West Coast because of the low percentage of land area that is able to utilised. What we do need to be concerned about is our communities dying because we become the “green conscience” for the rest of the country where they can play by their own rules but lock up our productive land. A good example of this was the wetland schedule that was approved at the Environment Court level. To lock up further land on the West Coast was just absolutely ridiculous and we applaud the efforts of the WCRC to manage the effects of this decision. Perhaps there is some way that the influence of organisations and people who do not reside on the Coast could be given less weight during decision-making processes or, rather, more weight is given to local groups and residents. Non-local groups get all the advantages of our industries and are completely hypocritical in the way the lobby and protest about local initiatives. They do not have to live with the potential of a depressed local economy and low employment opportunities that are likely to result from

48

8

Summary of comments made – ‘Yes, and…’ Submitter No. their targeted and biased campaigns. Agree with changes being suggested. As people who live in area we should have more control over how we develop our resources and make the most of the opportunities we have. Should make sure proposed options are soundly based on resource available e.g. Pike River amounts of coal were vastly overinflated. Also need evidence that whoever is looking to exploit a resource actually has a sound business plan and experience at managing successful business so it is successful and does make a positive different to the population and economy. Only by maintaining or increasing our population that will be able to hold on to the health, government and education services we have available on the WC.

53

Would like to see more job support for the resource sector – mining, fishing, forestry farming (dairy) and possibly hydro. This would result in more jobs in the engineering, transport and support services – which in turn supports our smaller local business in the local towns on the Coast. All these jobs generate higher wages, which would in turn keep more people (younger) on the Coast for the future – benefit our local rugby teams. We all support tourism but it cannot financially support the Coast on its own – this generally means lower wages.

64

The RPS will help promote more local and outside investment in our communities. We still have huge resources that can be managed in a way that will not only help the WC but all of New Zealand with minimal environmental impact. By using our resources smarter and having better access to them will help future generations to stay on the WC. We need to give industries incentives to crank up which in turn will grow our communities.

67

Support Haast Hollyford Road; 100% for Haast Hollyford Road. A chance to get this done at no cost to NZ. Not having a road through this beautiful area is discriminating against 98% of NZers as there is no chance of going there any other way. With 86% of the WC locked up in National Parks or DOC what is the use if we cannot see it? 71, 72

Pleased to see that the within the Discussion Document the importance of minerals has been acknowledged. Firmly believe that specific reference to mineral resources and their management and protection should be made with the new RPS in the form of a chapter dedicated to mineral resources. Within this minerals chapter the importance of aggregate resources should be acknowledged. Without specific guidance on the management of aggregate and mineral resources there is likely to be sterilisation and loss of significant aggregate and mineral resources within the region.

79

Much of company’s core work (Fulton Hogan) revolves around the civil construction, contract work and land development, including the maintenance or refurbishment of infrastructure of national significance 9for example, roading and rail corridors, and in providing materials and services that are essential “building blocks” for the maintenance of sustainable communities 9sealing chip, concrete aggregates, asphalt, etc) for housing business and infrastructure.

80

Support the review to grow our region. The likes of the greenies trying to stop development of our resources should have to put up at least $1m bond and pay compensation for any delays for consents being granted. 87

We commend the Council in its proposed more balanced approach going forward. Our region has always relied on its land based resources from the beginning of human habitation, compared to the rest of the country we still have the greatest portion of visible pre-settlement land. It is a challenge to notice any previous work in many areas due to the recovery generated by our climate. Our communities need work to provide for themselves and to maintain and keep the communities going forward. If overly restrictive rules are put/kept in place maintaining existing jobs may be impossible and future growth non- obtainable. The West Coast has resources available that haven’t even been touched yet and it would be a shame not to be able to seize the opportunity due to overly restrictive plans. However we must still have the ability to set limits so as to make sure the land, air and water are safe now and following into the future. In summing up we do agree with the Councils approach of applying more weight in the Regional Plan to the economic, social and cultural well-being of our Province.

90

I simply want to encourage you to take a holistic view – a pristine environment is dead with no jobs. One need not sacrifice the other. Role is one of coordinating and communicating than standing back and letting it happen. Don’t hinder business. People go where there are jobs, good transport, communication, health and education. Build for the future but keep in mind that the spend for marketing must be targeted, clever with and significant. Do not think that our transport networks can cope with growth. While noted as one of the top drives in the world, the Buller Gorge is dangerous. It is irresponsible to promote it in its present state. The drive to Karamea likewise. The road needs to be put through to Collingwood. Adequate off road transport needs to be encouraged e.g. heavy loads do not mix well with passenger vehicles. It only takes a shift in costs to shift habits.

97

I fully endorse a positive approach to the RPS that acknowledges the social well-being of the WC along with the environment. It is very important that we have an RPS that allows sustainable communities and enhances the WC as a place you can do business and enjoy living. I endorse the promotion of promoting the positive effects of resource use and development. Our view should not only be for the benefit of the WC but NZ and the global effect e.g. the positive effect in mining high quality coal. One tonne of

98

9

Summary of comments made – ‘Yes, and…’ Submitter No. quality WC coal when burnt provides far greater heat and far less toxic emissions than burning a tonne of low grade international coal. Having a policy that promotes population growth on the WC allows for low impact living as opposed high density metropolitan living that has greater social, infrastructure and environmental issues associated with such intensity. Throughout the Buller District we can sustain twenty percent growth in population without having to increase infrastructure. If the WC could have steady growth through to a population of 35,000 in five years and 40,000 in ten years such growth would be manageable and allow for any social and community adjustments as possibly required. Many thanks to the WCRC for this positive initiative and I look forward to the outcome. I feel that farming, mining and tourism will remain the mainstays of the West Coast economy in the future. To ensure their future viability and the ability to attract new enterprises to the West Coast I think the issues identified in the discussion document are correct and measures should be taken in the RPS to balance the weighting of importance between industry/business and conservation. At the moment conservation appears to be the priority. Sustainability of existing use of resources is of importance. If Global warming climate change and rising sea levels are going to be an issue, the Regional council should take further steps to simplify consent processes to protect existing land uses e.g. ensuring landowners can quickly gain consents to do remedial river protection work, clean waterways and channels to maintain the existing land area and drainage. The state of the mining industry at present shows just how dependent our economy is on extraction and farming industries for economic sustainability. We have adequate airports coast wide. We have underutilised ports which unfortunately can’t meet the needs of exporters and we have many roads that are barely adequate for current population and usages. Unless industry remains viable, population is going to remain static, aging and economically depressed. If steps aren’t taken to promote the economic and social benefits of industry along with conservation values to the West Coast, we will never have a sustainable future. The ongoing viability of what services we have is dependent on some form of population growth or at least growth in utilisation and some way of retaining financial profit on the West Coast. If the RPS can assist in this form of growth through promoting all forms of industry it would be very beneficial

106

I am in favour of the review changes. For the Coast to prosper we need support from local government to start new projects and expand existing work. Tough stances should be taken on minority, limited person groups protesting therefore stopping new or expanding works that follow consent guidelines. Keep consent processes simple and easy to understand to encourage new and existing businesses to apply and move forward. Rivers, lakes and waterways need to remain open and unobstructed for recreational users to use responsibly, boating, fishing, swimming etc. Maintaining water quality as well as promoting the use of our valuable resource for economic benefit and wellbeing are equally important.

108

As dairy farmers we are pleased with the work the Council is doing towards maintaining the beautiful WC and keeping an eye on the clean green image. To make the new RPS more user-friendly use plain English an highlighting bullet points. Promoting positive WC is a must for ill-informed city people so visual comparisons are essential e.g. the amount of WC mined is equivalent to say Auckland airport or Jade Stadium.

109

There is too much outside influence in the WC. Resources belong to the people in the District first not to everybody outside. Unless there is a change in attitude to the Coast when it comes to resources we should benefit and have more say on it. Dairy industry has to look after waterways but councils in their sewage need to do the same. How do we have WDC not having a proper consent for what they are doing and get away with it. DoC has too much say over private land, what can be done. Tourist operations have to get real and pay real wages not below the minimum wage as in the case of 5 out of 7 premises.

114

Think have identified the right issues. Should focus on encouraging businesses that add value to local resources not just using them as a commodity. I think the issues raised should be managed with a longer term view. I think the policy should reflect long term goals for the region (20-30 years). User-friendly RPS – a clear design helps but think its ‘profile’ needs to be raised i.e. it should be more obvious what it affects, when and how i.e. it should be referred to more often. The question is not whether to mine or not, it isn’t even whether the mining should be done in an environmentally sensible way (although it should), I think the question should be around how the community can get the best value out of those resources. That comes down to how they are extracted, how they are sold (products v commodities) and how the economic benefits flow. Inclusion of use and development provisions may possible assist with stimulating economic growth although I think value-add is the most important consideration. Think the RPS has a very important role in encouraging sustainable growth at consistent pace over the long term i.e. smoothing out the current fluctuations we get. For population growth – 50% over one generation (45,000 in 25 years?). Businesses must operate in a way that deals with the issues of infrastructure and public services. Presently there is a huge amount of value created in the NZ economy by mineral and dairy industry on WC. Very little of that stays here for infrastructure, education and public services. It is essential that this trend is reversed if you want to get growth, increase population and create sustainable communities.

116

Thanks for the opportunity to respond to the RPS review. The Discussion Document presents a balanced picture of the issues confronting ‘Coasters’. Any RPS requires a balancing of competing short term and long term needs of sustainability and growth. This document clearly identifies the competing demands of sustainability vs growth. 119

10

Summary of comments made – ‘Yes, and…’ Submitter No. Sustainable population growth is an issue I would like to see more attention given to as I believe a population of around 32k is too small to enable key services such as health and education to be maintained at a level to assure Coasters of access to high quality services. Possibly a population of around 60k would enable health and education services to grow, thus keeping and growing these services. As well, we could grow and develop a highly skilled work force and balance an aging population. Between 1080 being dumped on our environment and DoC and the Twig and Tweet brigade locking up land and protesting any new opportunities for progress, the West Coast is being strangled. Our children are forced to leave to find work and businesses are closing fast. All that will be left will are aging people and possibly no hospital if DoC and the ‘greenies’ get their way. We don’t have a decent transport system so how are the expected influx of tourists expected to get around. Coasters take back your area of NZ and tell the anti progress brigade to crawl back to their caves and mind their business. Support the Council on their endeavour to ‘find the balance’.

130

Mine everything we can, open-cast Pike River. Sort out cow effluent in our waters. Get rid of 1080. 131 I think that the WCRC is completely on the right track with the discussion points included in the Discussion Document. In the past environmental considerations have been given overriding consideration and social and economic well-being has been given too little focus. So much of the Coast is locked up. I feel that this should allow us and encourage us to make excellent economic and social use of the land we do have as the cumulative impacts of intensive residential/commercial/industrial developments are not something we have to be concerned about. A good example of this is effluent management. We are never going to have the same level of problems that result from intensive dairy that other parts of the country do. I agree with the entire discussion document. More focus on promoting positive effects and finding ways to fund and establish our sustainable communities should both be priorities. Perhaps there is some way that the influence and opinions of local organisations and residents could be given greater consideration during the decision-making process. It often feels like we are not trusted to manage our own communities and resources and that the West Coast is held to an impossibly high standard that does not apply to the rest of the country and it is our local communities that suffer for it. The inclusion of use and development provisions that promote industry development and stimulate economic growth would be fantastic.

133/134

Finding uses for land/mining that minimise environmental impact – creating greater public awareness of what is being done to protect environment and how much DoC already control to balance ‘green’ scare tactics would be a great benefit. Promoting business ventures that do not rely exclusively on land use. Sustainable communities require employment and entertainment opportunities for youth. Many families leave the WC when children become teens due to a lack of perceived opportunities in education and employment. Marketing to counteract natural perception of WC as ‘behind the times/hillbilly’ culture will help sustain communities, build pride. Celebrate successes/achievements of WC initiatives such as positive effect of 1080 use to control possums and allow rata to flower etc or jobs /income created by farming mining.

135

Yes think issues have been identified. Should be managed by implementing real life tasks that can be done by people in the community. To create a more user friendly document use less wording (statements and bullet points) alongside a related image or video of what is being proposed. Promoting positively is always best although other industries should also be considered. Do not think that the inclusion of use and development provisions will assist with stimulating economic growth. Role of the RPS should be proactive. Population growth should be kept low. People need a reason to visit and fall in love with the Coast before they’ll even consider investing. Do not think our current transport networks can cope particularly for people who do not have vehicles.

136

The RPS need to reflect the importance of economic sustainability of our communities. Economic prosperity means we have the money required to care for our environment. Poverty/desperation breeds environmental degradation. The RPS needs to take economic prosperity into consideration destroys our economic base. Yes – we need to be exploiting our rich mineral resources.

138

I think the Regional Council should be applauded for the proactive efforts it has made to ensure a wide group of the local public are made aware of the Regional Policy Statement Review. Whilst I do not have answers to many of the questions raised in the feedback request document, I am heartened by the use of the word 'balance' with a clear emphasis on the importance of promoting economic needs of the Coast, in a sustainable fashion. The Council clearly understands the important leadership role it has. Without jobs, there are no people, and without people, there is no money to inject back into the Coast. I particularly like the efforts you have made to ensure the business community knows that the Coast is a place that welcomes new ideas, new investment, and new people.

139

The WC is gifted with significant deposits of Coal, Gold and many other minerals including ilmenite, rare earths and platinum. Currently the WC minerals industry contributes approx. $640m to local GDP off $960m of production value. In February this year 1,917 people were directly employed on the WC in the minerals industry. Using Berl multipliers the employment numbers increase to 4,533 with the inclusion of sub-trades and related services. Minerals industry supports not quite one third of the WC population. WC has potential from known projects to expand significantly. Known opportunities and projects incudes: Westland Titanium, Pike River Mine, Blackwater Mine,

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Summary of comments made – ‘Yes, and…’ Submitter No. The Globe Deeps, Platinum exploration, Copper exploration and opportunities identified in the Aero Magnetic survey data. Factors that hold back or discourage growth in the WC minerals industry include: difficulty in attracting investors, difficultly in recruiting and retaining key staff and difficulty in gaining access to land for exploration and mining. Investors when faced with a world of minerals investment opportunities will often be put off investing on the WC by what they perceive as a drawn out and uncertain consenting process. Support the proposal to include economic and community effects along with environmental effects when evaluating applications for consents. Our belief that this sends a very positive message to any organisation or individual considering investing into the development of WC mineral resources. This inclusion of economic and community effects will encourage mining companies to invest into the WC community. This investment into the community will aid in further development of services and facilities available within the community and in turn aid in encouraging people to both work and live on the WC with their families. Inclusion of community and economic effects in the consenting process will provide some certainty to minerals companies that their potential contributions to the local economy and community will be taken into account when authorities are considering the potential positive and negative effects of a proposed activity. The proposals and suggestions as outlined in the Document will go a long way in establishing the RPS as an enabling document and encourage investment and development within the region. I feel that the present resource consent process and costs put many small potential mining operators off opening up a mine or other small business. The time to get a consent is also crazy. If this were handled by a private company this process would take half the time. 147

Support Councils intent to review the RPS with a view to generating a document that strikes a better balance between environmental protection measures and facilitating appropriate resource use and development that fosters the economic well being of the community. RPS has to meet the sustainable management purpose of the RMA as per s5. In this regard the reasonable foreseeable needs of future generations and the social and cultural well being of WC communities is important and must be taken into account. Well established that other matters (s6 & s7) are subordinate to the overriding purpose of the Act in s5. Specifically: The environment includes people and communities and the RPS has previously been weighted towards avoiding, remedying or mitigating effects on the environment,

while giving less guidance on providing for the social, economic and cultural well-being of the region’s people. Support Councils intention to amend the RPS to include policy which will specifically focus on ‘promoting positive effects’ through which the positive contributions

mining makes to society both regionally and nationally are appropriately recognised. Agree that the RPS should have a greater emphasis on creating ‘sustainable communities’ and that the people who live in the WC environment should have a greater say

on how that environment is managed. Agree that the RPS must recognise that sustainability relates to both the ‘natural’ environment and the people who live within it. Our companies are significant regional

employers and part of their community. Mining companies contribute to environmental projects such as pest control and support the protection and recovery of at risk native species through initiatives that

would otherwise not occur. Mining activity directly benefits the regions economy and therefore its people, a strong local economy and support from successful businesses result in greater levels of

healthcare service, higher quality and a greater number of community facilities and services and improvements to regional infrastructure. Agree that mineral extraction is a key economic driver for the WC region which benefits not only WC residents but the entire national population. The role coal plays in

the economy is achieved through direct mining activity, but also other industries that rely on coal to produce or value add to their products, such as the dairy and food production industries.

Greater recognition should be made of the fact that if mining is not conducted here we must import coal and other minerals from international sources where industry may not be as well regulated and who’s environmental standards may be lower than ours.

Strongly agree that ‘poor quality regulation and high compliance costs can act as a brake on business growth, investment and job creation’. Support is given to any amendment to the RPS that will encourage good quality regulation which will be facilitated by straight forward and easy to interpret plans and rules, while ensuring that the RMA’s sustainable management purpose is met.

Greater consideration of WC community’s sustainability and the recognition of the positive effects of mining need not come at the expense of the environment, which is still given full consideration through te provisions in the RMA and the Regional Plans.

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Summary of comments made – ‘Yes, and…’ Submitter No. These amendments are important given the status if the RPS as a guiding document for the region and from which regional plan policies and rules draw upon. The Discussion Document is an important step in the process of ensuring the RPS reflects the social needs of the regions communities as well as the physical environment in which they live. The inclusion of policies that seek the ‘promotion of positive effects’ and the need to realise the vision of ‘sustainable communities’ will better achieve the outcomes promoted by the RMA. I agree that the Regional Council has identified 2 key new significant resource management issues. A RPS that only focuses on the mitigation and prevention of issues does not fully weigh that up against the prospective benefit of any activity. For the New Zealand Fire Service, the second discussion point is of vital importance. Sustainable communities are at the forefront of how the Fire Service is able to provide the service that it currently does on the West Coast. All the firefighters on the West Coast are volunteers, and respond to incidents for their communities as a primary driver. We continually need new volunteers, and this can only be achieved where people are available. One of the key methods to providing sustainable communities is to ensure there are employment opportunities in the Region. Promotion of the positive effects of the industries here, or possibly here on the West Coast, will ensure a RPS that does not only look only at what ‘negative’ effect there may be on the environment, but what ‘positive’ effect there could be too. This gives another ‘string to the bow’ for the Regional Council, and does not reduce its responsibility to care for the environment, which after all, is our biggest asset. For the Fire Service, stable employment assists in recruitment, and our volunteers are supported by employers who equally care for the West Coast and its communities.

150

Yes are on the right track in promoting the positive effects to be gained from the use of our resources is essential to balancing the RMA in our area. The inclusion of use and development provisions are essential for stimulating growth. The new RPS should have a major role in promoting growth in the region. . With continuing farm development, tourism and mining improvements I believe up to 100 plus permanent residents could be achieved per annum. Our transport and public services are not a problem as they automatically grow and expand with demand.

154

Use it or lose it. NZ needs to export to maintain a national standard level in employment, funding health, education and general security. Leaving trees to die and rot is a crime against nature the sustainable milling NZ had allowed mature trees to be harvested. New growth could then regenerate quicker. Some of NZ/WC coals are of the highest grade in the world. Exporting these to be blended with low grade coals in the likes of China and Japan give them better heat and ash factors that reduces harmful emissions (a global warming problem). NZ needs a common sense balance to all such enterprises. Extremism on both sides of any argument should not be tolerated. Continued court challenges are a cost to the nation and an insult to common-sense. NZ needs a back to basics approach.

158

I whole-heartedly support the changes to the RMA as proposed by WCRC. Balancing environmental issues must be a priority if this region is to survive and, I believe, without growth in both the economy and population that the ecology will eventually suffer.We need industry that employs our youth in well paid and stable jobs to halt the export of our most precious commodity: our future generations. Transport links are critical to our success and, while supporting the Holyford-Haast road in principle, I firmly believe we need a loop road through from Karamea to Tapawera to finally rid ourselves of the very real threat that relying on the alpine road and rail routes pose. More needs to be done to encourage exports from our ports and I also think any new manufacturing industry should be compelled to process any raw materials extracted from the coast, on the coast.

159

I would like to submit the following with respect to the RPS. The regional policy statement and its implementation should reflect the region's collective future vision whilst being mindful of its past. Current implementation I feel strongly favours the past, with the focus on protection due to past environmental harms through industry. For this region to advance in a balance and equitable manner, fair consideration needs to be given to the future of the citizen's within the province. The West Coast unfortunately features poorly in all socio-economic measures for well being. What province can sustain good health, education and employment for its citizens when 83% of its land and resource are under guardianship. Which allows concessions from these resources to produce only 15 % of its overall economic wealth (2006). This approach has socially and economically impoverished West Coasters. Parallels with the past and present challenges faced nationally by the Tangata whenua are worth considering. Maori being dispossessed of land and resources had no choice but to accept second class citizenship. Past environmentally harmful industry practices are now well policed and are considered socially unacceptable. West Coasters are intuitively conservationists, we have chosen to live here, because of our love for the outdoors. The Coast has moved on and needs a regional policy statement which directs implementation towards both protection and prosperity. This would allow the provinces citizens a chance to fair employment and there right to prosper both economically and socially.

160

Are interested in future growth and planning restrictions within the West Coast Region that may have the potential to adversely affect the general operation of mineral, coal and aggregate extraction. 162

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Summary of comments made – ‘Yes, and…’ Submitter No. More decisions need to be made locally. Environment is important but jobs and the economy is just as important. People are the most important thing. 164 New industry need to be developed on the WC to establish economic growth. Amendments need to be made to the RMA to prevent lobby groups from stymying applications for mining etc – e.g. Denniston/Bathurst. 170

Mining exploration and development must be allowed to grow and expand without intervention from Groups and Lobbyists desperate to show the world how PC we are. Certainly the environment and surrounds protection must be uppermost in the thought process but must not be the deciding factor. NZ has untapped mineral wealth which would help offset the relatively small tax paying population base with our domestic and overseas economic commitments allowing our nation to grow.

173

There is a definite need for a wider range of industries on the WC; along with expansion or (in the case of coal) redevelopment of existing industries. A change in emphasis in the RPS from an environmental bottom line to a more rounded and balanced approach is needed. However, any change must be sustainable and safe. Mining provides well paid employment and must be encouraged. Coal and gold have been the backbone of the industry on the WC but other minerals should be included.

175

Have correctly identified the new regionally significant issues. In the review and proposed changes to the RPS, Council should consider the weighting of submissions to consent applications. More weight should be given to submissions from within the WC than to those from outside this region. In the past the RPS has put unreasonable emphasis on environmental concerns to the near exclusion of social and economic and cultural concerns. The document should be rebalanced to put greater emphasis on social, economic and cultural concerns. Greater than its emphasis on environmental issues. The RPS should make a clear statement that the regional economy and society requires the use of, and access to, a variety of natural resources. This is both for sustaining the existing community and growing this community along with the regional economy.

179

Agree with the proposal to include the newly identified significant issues in the RPS. Believe that their inclusion will go some way in assisting WC’ers in determining their own futures. Defining and measuring positive effects may be a challenge in itself but worth an attempt. Personally think that a population target of 50,000 is a bit high – 40,000 may be more realistic given our population history. Health services will obviously be critical to success.

182

Support the inclusion of recognising the positive effects of sustainable resource use and enabling economic activities. Industry in using resources sustainably, can positively contribute to the social, economic and environmental wellbeing of the local and wider communities where they are located. Whilst assisting the creation of new opportunities is important, it is also important to support and enable existing activities so they can operate effectively and efficiently. Providing efficient, secure and reliable infrastructure and services such as transport links, water, wastewater / solid waste disposal and telecommunications contributes to efficiency and continuing / future business viability and certainty. The RPS should set the framework for managing growth in making provision to identify and direct growth in order that infrastructure and services can be developed in parallel to provide amenities efficiently without diminishing the value to existing activities. Providing for and directing growth can also help to protect values such as production land and avoid conflict between incompatible activities by managing what activities go where.

185

I find this to be a region with tremendous potential for growth. Like many West Coast people I have become frustrated by almost all significant developments within our region being held up due to objections and actions of well organised national organisations with extreme environment views and crusades. I congratulate the West Coast Regional Council for this insightful action to consider reviewing our Regional Policy Statement to develop it into an enabling document while maintaining our environmental values. You are correct in that the process needs the consideration alongside the environmental effects the positive effects of projects in generating economic activity on the West Coast and the contribution a development would have in community development. In including the economic and community contributions of a particular project or development, this will also encourage second level processing on the West Coast and further stimulation or regional economy and communities. I support the Regional Policy Statement promoting the positive effects of development. I support the development of a vision for the West Coast to have Sustainable Communities with a strong local identity. The careful and considered utilisation of our abundant natural resources we can grow our West Coast economy and communities while protecting and preserving our natural environment for future generations.

189

Agree with the RC updating its RPS to include economic and social aspects in resource consents and plans. Look forward to a plan where opponents to resource consents have to provide real facts as to why they have concerns about a consent application rather than the old “I don’t like it”. 190

Both proposals are supported. Minerals exploration and mining make a significant contribution to the WC economy and community and the region holds good minerals potential. Mining earns directly and indirectly close to one third of the regions household income. That wealth is earned from a footprint of 14km2 compared to a total regional area of 23,000km2. Miners earn on average double the national average wage. Activity carried out in tandem with other major industries on WC including dairying, tourism and conservation. Evidence from GNS is that the region has further potential in a variety of minerals and metals. While there has been a downturn in coal and gold

192

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Summary of comments made – ‘Yes, and…’ Submitter No. mining on the WC there are new developments also afoot e.g. Bathurst Resources, Pacific Minerals. Often forgotten is the contribution to communities made by exploration and mining companies. That includes support to health care services such as rescue helicopters, hospitals and ambulances; and to community facilities such as swimming pools, and community halls. Businesses are also ratepayers enabling public works funded by local government. Businesses can also make direct contributions to funding of infrastructure such as roads. These can be significant at the regional level. From an economic growth and wellbeing perspective, therefore, mining is a strategic sector for the WC and should receive high priority treatment in the RPS. Some might argue the RMA already recognises the benefits of economic activity, and the need to safeguard the environment. The RPS cannot derogate from the primary legislation. That said, plans and rules could be developed in a way that inadvertently or otherwise weigh unfairly against minerals exploration and mining. RPS could provide direction to avoid that. Mining proposals are best suited to being considered on a case-by-case basis. That proceeds by assessing all of the values at the site, the effects of the project on competing values, and informed proposals for managing those effects. Such decisions are informed by stakeholders and iwi input, where relevant, and decision-makers must form an overall broad judgement across the four well beings. Knowing that mining creates high wealth from a small footprint, and that the number of and distribution of mines and prospects change over time, information on minerals prospectivity should form an input into all land-use decision-making e.g. resource consent application to convert privately-owned farmland into a subdivision. Possible in such a case that the opportunity cost of foregoing potential mining could outweigh the economic benefits of the subdivision. The material on sustainable communities draws attention to the current economic downturn in prices for gold and coal and consequent staff redundancies at mines. Agree that business cycles are an inevitable part of the economics of mining; however also believe there will be long-term demand for these and other minerals. As the Escarpment mine is developed, and other projects come on stream, people will move back to the WC. That will also occur with renewed strengthening of commodity process. Mining is typically strongly cyclical, but mining investment is underpinned by strong demand for the products of mining, particularly from developing countries. Question is how to build resilience into the industry on the WC. One solution is to provide for ‘critical mass’ i.e. to encourage investment in minerals. The Governments aerial geophysical survey and platinum tender are examples of ways of encouraging more exploration activity on the WC, as are the GNS Science Survey, the Berl report, and the recent government report on regional economic development. There is also an opportunity to reduce unnecessary and burdensome bureaucratic red tape. While industry should continue to face high standards, consent processes should not take years and cost millions of dollars. The seemingly endless appeal processes are a strong disincentive for investment. Accept that this is a matter for the RMA system as a whole rather than the West Coast RPS. In terms of the Councils role there may be an opportunity to improve coordination and engagement between regulatory agencies e.g. DOC, LINZ, HPT, NZP&M to speed up regulatory approval processes. Have sought central government action to align consent, concession and access arrangement processes, at least for significant projects, so far to no avail. Are aware of moves to better align consent and concession processes, and separately, concession and access arrangement processes, where applicants would find that useful. Council could be proactive about facilitating such alignments on receipt of consent applications. RPS must enable social, cultural and economic wellbeing. Objectives and policies should be designed to actively promote social, cultural and economic wellbeing. Focus should not be primarily on the adverse effects – there are positive social, cultural and economic throughout the region via regional documentation, plans and statements (i.e. media statements). Resource management and the community needs to involve both sides of discussion both positive and negative. Discussions at community and regional can produce an integrated, planned and well managed result by inclusion rather than exclusion (eg “affected party status” decisions which are pursued to seek a certain pre-perceived outcome); perceived problems should be fully and positively discussed rather than seeking a preventative outcomes based on perceptions and personalities which may have no basis. The use of the words “issue”, “effect”, “outcome”, “expectation”, “economic wellbeing” to name but a few, have been used negatively and certainly in opposition to cultural and social expectations during submissions and interactions between the community and council. Sustainable management is vitally important in enabling the community who have expectations during submissions and interactions between the community and Council. Sustainable management is vitally important in enabling the community who have expectations for their social and cultural requirements (be they personal or legislatively based) i.e. recognition of personal Treaty of Waitangi based rights, or expectations by residents of long standing occupation of property to have their domestic investments preserved and protected against short term gains. Wider community benefits which are lost by the imposition of development with short term goals leading to social, health and cultural losses to the wider community. To identify the positive social, cultural and economic effects which are a vital part of the sustainable growth of communities which supports the regional characteristic, cultural and social fabric whilst engaging in economic growth (but not at any cost). The rural community supports industry but should not be unfairly

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Summary of comments made – ‘Yes, and…’ Submitter No. compromised by the industries that it supports or can accept as part of an integrated forward plan which is implemented to achieve positive outcomes e.g. it may be better in the long term to forego short-term financial gain in order to achieve permanent positives in a community that will continue to exist in an area in many forms after short-term uses may have destroyed that community. Regional plans and policies must address matters pertaining to water in order to actively manage the natural processes and ensure we do not continue to see a perpetuation of the “water wars”. Think you have accurately identified the key new significant resource mgmt. issues. Believe promotion of the positive effects of using & developing our resources would assist with balancing the RMA in this region. Anything to further understanding of how current mining methods differ from those before & to promote the modern mining methodology and considerations , esp relating to minimisation of effects on the natural environment & also offset/improvement of more accessible natural environments. Increase understanding of actual ‘uses’ of minerals mined in our region – Seems to be a lack of understanding especially of the coal industry – most people appear to think West Coast coal is primarily used a s a power plant heating source, reality is quite different & many hi tech industries rely on coal from this region.

198

As a previous West Coast resident, with family and friends still living in both Greymouth and Westport, I think the Regional Council has the right idea with the RPS to provide a balanced approach to resource management and especially with the focus on resource use and development to ensure the economy is boosted. The West Coast is ‘home’ for so many people and it is/would be a shame to see so many people move away from their preferred place to live solely because they cannot secure work or provide for their families. Its important to make the most of the Coast’s resources to ensure the residents can make a life for themselves on the Coast, and I think the RPS will assist in achieving this. I support the Regional Council in what they are trying to achieve with the RPS.

200

Fully support these two new issues identified by the Council, and considers those issues are important factors in reaching an overall broad and balanced judgment between competing interests pursuant to Part 2 of the RMA. As significant resource management issues for the region, agree that the new issues identified should appropriately be included in the proposed RPS. The RPS should establish objectives, policies and methods of implementation in respect of those issues, as required pursuant to section 62 of the RMA.

The Council states in the Discussion Document that it wants the RPS to “recognise the importance of resource use and development in the West Coast region, and how it can contribute to enabling people to provide for their economic, social and cultural well-being.” Endorses this direction and considers that appropriately planned and managed use and development is integral to sustainable management pursuant to the RMA. The positive effects associated with renewable electricity generation are well documented. The New Zealand Energy Strategy 2011-2021, the New Zealand Energy Efficiency and Conservation Strategy 2011-2016, the National Policy Statement for Renewable Electricity Generation 2011, and sections 7(i) and (j) of the RMA all recognise and document the benefits to be derived from the use and development of renewable energy. The RPS currently does not appear to have any express recognition of the positive effects associated with renewable electricity generation. Consider it appropriate that the RPS reflect the positive effects of renewable generation, as documented in the national policy documents listed above. The Council also states in the Discussion Document that it “wants to see our economy grow by enabling access to the resources of the region”. Endorses this objective. Consider that there are a range of sectors in which development will lead to economic growth in the West Coast region – both by direct and indirect (downstream) spending, additional employment, and expanding the numbers of workers skilled in particular areas. The Council lists in the Discussion Document a number of sectors where it sees growth as important to the region. Agree with the examples provided, and considers that renewable energy generation is another sector, reliant on the region’s natural and physical resources, which if enabled in the RPS, would lead to growth in the region.

Council states that it “wants the RPS to be more enabling for our communities to generate employment opportunities and create wealth for our communities”. Fully support the sustainable growth of West Coast communities. It wishes to encourage economic growth in the region, by operating and expanding its existing generation portfolio. Trustpower’s schemes within the West Coast provide direct and indirect employment, as well as other contributions such as rates and recreational activities. In providing embedded reliable generation in the region, Trustpower also provides for the social and economic wellbeing of the West Coast communities. Finally, in operating in an environmentally responsible manner, Trustpower provides for environmental, social and cultural wellbeing of the region. Methods suggested by Council to promote growth in the region, by making it easier for businesses to operate include: Ensuring plans are straight forward and easy to interpret, Standardising plan definitions and rules across the region, thereby decreasing compliance costs, and

203

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Summary of comments made – ‘Yes, and…’ Submitter No. Clear regulation to define boundaries around what is allowed. Welcome this recognition by Council of the type of changes to regulation to attract business. Trustpower is committed to responsible and effective electricity generation and to applying best industry practice to its activities. It acknowledges the importance of the environment to its continued operations and has adopted a set of environmental policies which encourage the minimisation of adverse impacts associated with its activities. However, Trustpower is mindful that consenting and compliance obligations are very demanding, and can impact on consideration of project viability. By way of example, Trustpower has some 578 resource consents and 4027 consent conditions across all of its schemes nationally. The number of consents and conditions increased by 259 and 2621 respectively in the eight years ending 28 February 2013. This is a direct consequence of the new generation projects that Trustpower has consented, and of the reconsenting of existing schemes under the RMA. Trustpower welcomes recognition by Council of the need to standardise plans to decrease compliance costs, and looks forward to working with Council to ensure that the draft RPS appropriately maintains the balance between future growth and maintaining environmental standards. In summary support the direction set out in the Discussion Document and consider that inclusion of the two new issues proposed by Council are appropriate and will provide certainty for resource management outcomes in the region. Acknowledge that if these new matters are included in the RPS, there will be some further discussion required around the detail of provisions to establish objectives, policies and methods of implementation in respect of those issues. That level of detailed analysis is appropriate at the time of formal notification of the draft RPS, and has restricted its comments on the Discussion Document accordingly. Agree need more jobs in Reefton. Need young people and middle aged people in work. Proper development to fit in with environment. 204 Support the initiatives discussed for the RPS. It is very important to have that balance between the environmental factors vs community/social factors. Times are changing and its great to see the WCRC doing is utmost to keep the WC going. I think that wide, constant publication of the RPS is important so all West Coasters know what it is about. We live in a beautiful part of the Country and we need to make the most of this to encourage visitors. Whilst I fully believe in the sustainability of our environment for our future generations – I also think it is short-sighted to restrict access to certain parts of our natural resources i.e. bush as then no-one gets to appreciate it.

206

I fully support the mineral industry and the future expansion on the WC as long as the nest practices policy is in place and safety is paramount. We need to use our mineral resources to create employment which will support population growth and in turn increase demand for retailers and the need for new businesses which will create even more jobs thus allowing a larger population, with a higher population comes more funds for infrastructure and so on. Regarding numbers of people in the future I think that depends on how well the WC is marketed nationally and internationally as an industry friendly region to where the minority doesn’t rule over the overwhelming majority and environmental issues are contained within the best practice policy in a straight forward document with the least amount of red tape as possible. I would like to see the RPS include a marketing side to it, from what I have read so far it seems the Council is already on track especially regarding getting public feedback and seeking growth for the region. The dairy industry needs to be supported and the best practices enforced. Tourism is important especially with what the WC has to offer regarding the beautiful scenery throughout the Coast including the waterways, beaches and National parks etc. I feel the mining industry and the tourism industry can work with each other, for example the tours up at Stockton, there is plenty of land, sand and sea for all. Environment – concerning the emotion and propaganda used by small but vocal groups who resist progress and growth, I think it would be good for the RPS to be shown publicly as a supporting policy to help counter these groups.

209

The Haast Hollyford Road project will provide huge tourism benefits for the West Coast region, as well as providing a valuable backup rout in the event of a disaster (witness the recent weather related difficulties when there were major slips on the Haast Pass). Underpinning that will be the need to build new tourist and accommodation facilities to match. Airports - It is clear that Hokitika Airport is the most logical location for an airport covering the majority of the region, with Westport remaining a strategic but secondary option unless there is a significant increase in passenger volume. In the event that the Haast Hollyford project proceeds, Hokitika has the potential to become “international”, again dependent upon demand and passenger volumes. Sea Ports – Existing port arrangements need to be reviewed, to ensure that available facilities match current and projected needs. If the Haast Hollyford Road progresses, there is significant potential for the expansion of the current Jackson Bay Wharf to provide for Cruise Shop visits. This could either occur via an extended wharf or by making provision for disembarkation and re-embarkation by tourists using “ships” tender facilities, as occurs in a number of pacific island tourist location. This will in turn provide potential for smaller fixed wing or helicopter aircraft, as well as busses and potentially event a tourist train, to deliver passengers to Glaciers or to other tourist attraction and shopping in the likes of Hokitika or Greymouth. In some jurisdictions the concept of cruise/fly is just starting to take off, and it would be foolish of the West Coast region not to recognise and provide for that possibility (subject to appropriate due diligence of course). The plan needs to recognise and provide for a range of activities which include, but are not limited, to - Electricity generation and transmission (lowering cost and

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Summary of comments made – ‘Yes, and…’ Submitter No. improving security of supply); farming (ensuring farming developments are, subject to due diligence and process, encouraged where appropriate; Mining (under the same premise as Farming above); Land Transport (the provision of appropriate road and rail infrastructure that will encourage sustainable growth, the introduction of new industries, and employment); Electronic Transmission and Reception facilities, i.e. data, that will match the needs of businesses and residents in the 21st century). Councils intent to provide a better balance between managing negative effects and promoting positive effects through the proposed changes to the RPS is commendable. Shows a real commitment to act as an enabler for the community rather than limit itself to a role as a watch-dog in respect of its regulatory functions. Little doubt that if the Council and other WC bodies can be successful in enabling future development, the regulatory role that is required under the Act will only become more important for the region. Additional development can only be allowed to proceed in the region if any negative effects are able to be appropriately managed. Have actively promoted the enhanced security and capacity of electricity transmitted into the region, which supplements electricity generated locally. Has resulted in a greatly enhanced transmission system which will cater for a significant increase in demand coming from any commercial development, and also the consequential spinoff load growth which would follow that development. Within the region have demonstrated a willingness to work with developers to ensure successful commercial outcomes which enable development. Local sub-transmission and distribution networks are also well maintained and will respond to increased demand. The electricity network capacity in general should therefore not be a constant to any future development. With regard to other infrastructure, roading for example, experience tells us that there should be no reason to believe that enhancements to those networks would not be able to be planned and delivered alongside new developments, where required. Managing pressure on infrastructure that is caused by extensive new developments is exactly the type of challenge that local providers should be looking forward to. Will the inclusion of use and development provisions assist with stimulating local growth – simple answer is you don’t know unless you try. Council should definitely be including provisions which are designed to assist while also creating performance measures to enable review of the effectiveness of those provisions. No single agency can take responsibility on its own for stimulating growth, however all agencies working in co-operation will have a positive impact. Councils lead in this regard is very important regionally. The key to the WC’s future prosperity is in developing sustainable businesses, and where those businesses utilise natural resources, managing those resources in a sustainable manner. Access to renewable resources will continue to play an important role in delivering that sustainability. The Council is right to include sustainability in its vision, while recognising that there is a close link between positive effects and sustainable resource utilisation.

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Think that the Council has correctly identified the significant resource management issues for the WC. Spot on. Congratulations. Your graph on sector contribution to GDP tells a good story. Clearly shows how important the minerals and dairy sector is to us on the WC. Need to be able to continue to access these resources for the benefit of our region. The flow on effect from these industries for employment is massive – engineering, contractors, transport companies – survive on the WC as a result, NOT from tourism as some people would believe especially from people from Auckland and Wellington. Keep up the good work in promoting the access to the resources of the region. Need this now and into the future.

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I totally support the objectives set out in the document as the WC needs its people to stay, work and play in their own backyard to ensure a sustainable future going forward, The notion that both the farming and extraction industries can co-exist is and can be fully achievable with the appropriate level of management and consultation. It is of the utmost importance that the promotion of our resources in a positive way to assist the balancing of the impact of the RMA in this region. Therefore the inclusion of use and development provisions would, in my view, greatly assist in stimulating economic growth in this region. The WC needs to attract more people into its various sectors and to do this for the longer term, we need to build the population. A fast track method for this would be the building and provision of secure well managed work across all industries both existing and proposed. This will build wealth and ensure our overall sustainability.

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Summary of Response – ‘Yes, but…’ Summary of comments made – ‘Yes, but…’ Submitter No. Should Council become more ‘enabling’ through its review of the RPS and interpretation of the RMA with regard to consenting applications to develop land or extract minerals I would like to see a more stringent approach to applying and particularly enforcing consent conditions, with penalties that encourage consent holders to ensure they comply. E.g. gold mining in central Westland – cannot think of one operator who has not breached their consent conditions on numerous occasions. Applies to small and large operators. Present level of fines or consequences are obviously not sufficient or effective as a deterrent. Main thing to remember is that the RMA requires council to protect the life supporting capacity of air, water, soil and ecosystems; and avoid, remedy or mitigate adverse effects on our environment. Acknowledge that this includes people and communities but without healthy and functioning natural ecosystems and without access to clean water people and communities will be disadvantaged. Give consideration as to how much development and population growth the Coast needs beyond being simply “sustainable” – there is a risk the “West Coast” lifestyle could be lost.

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Encouraged to see the WCRC propose to give more explicit recognition to enabling economic, social and cultural wellbeing through inclusion in the Regional Policy Statement, an overarching tool that shapes decisions across both the Regional and District Councils here on the West Coast. However, we are mindful of the tensions that will exist when developing policy and assessing resource consent applications with respect to the above wellbeings and the environment. We make the following observations: With the background documents/reports informing the WCRC RPS Review being generally supportive of minerals exploration, mining and dairy farming, how can the

WCRC implement a fair and balanced approach to the weighting of both potential positive and negative effects of resource use and development by these, and other industries?

What mechanisms are in place or can be used to ensure that positive effects of resource use and development, especially positive economic effects, are not overstated? CPHWC considers that a careful and transparent approach will be required when assessing the positive (and negative) effects of resource use and development against its effects on cultural, social, economic and environmental wellbeing. We propose the use of health and social impact assessments as one mechanism for helping to address the irreconcilable tension identified by Matheson. CPHWC recommends: The use of health impact and social impact assessments as a mechanism for ensuring balanced consideration of the effects of resource use and development, and CPHWC offers assistance in facilitating such assessments. CPHWC acknowledges that the environment is of major importance for the West Coast’s economic development. However, while economic wellbeing is necessary for good health, a sustainable and thriving ecosystem is also vital to supporting and sustaining health of present and future generations of people and communities on the WC. If the WCRC, through the RPS, is to benefit the people of the West Coast it will need to broaden its focus to support diversity of development and not limit itself to further development of current industries. In promoting the positive effects of development, it is also important not to lose sight of the need to set appropriate conditions in resource consents to avoid, remedy or mitigate negative effects. There must also be robust and effective monitoring and enforcement of these conditions. If this is not done, then a balance of effects will not be achieved and development and use of resources for economic or social benefits will be at the expense of damage to the environment, communities and their health. CPHWC recommends that A cautious approach is taken to forecasting potential economic benefits of resource use and development and that a transparent process is required to ensure decisions

are made based on the best possible analysis of available evidence. Sufficient emphasis is still given to the need to set, and monitor compliance with, resource consent conditions that will avoid, remedy or mitigate negative effects of

development and use of resources.

It is important that economic growth is not promoted by relaxing regulatory requirements, including monitoring and enforcement, which exist to prevent environmental degradation and promote health. Effects on water quality as a result of land intensification (dairying) have contributed to public drinking water contamination. Increases in number of abatement notices issued in 2012/13 and WCRC noting that it has been the first year that staff have visited all dairy farms. This highlights at least two issues:

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Summary of comments made – ‘Yes, but…’ Submitter No. First, that decisions have already been made under the RMA and the existing RPS which have taken economic development into account. Secondly that councils, including the WCRC, have set conditions associated with resource consents that were either inadequate to prevent the degradation of

waterways, or that the conditions were adequate but were not able to be monitored and enforced effectively. CPHWC recommends that if resource use and development is to increase on the West Coast There will need to be a commensurate increase in the resources available for assessing resource consent applications adequately and for monitoring and enforcement of

consent conditions to ensure that negative effects are adequately avoided, remedied or mitigated. While the RPS is an important document and greater clarity about what is and is not allowed will be welcomed by business and communities alike, to be truly sustainable communities must have the opportunity to be engaged in decision-making about use and development of resources. This input provides open standing for all person’s to participate in the plan-making and consenting processes and that this was conceived as one of the checks and balances of the RMA regime where elected representatives (often laypersons) are responsible for decisions made under a complex legal framework. Carruthers and Pilkinton (page 18) cite case law which describes the purpose of public participation as two-fold -“first, to recognise and protect as appropriate the particular rights and interests of those affected and more general public interests and, second, to enhance the quality of the decision making”. Since the last census in 2006, the population of the West Coast has increased by only 2.6% overall to 32,148 people. This growth in population has not been evenly distributed with Buller’s population increasing by 7.9%, the Grey District’s increasing by only 1.1%, and Westland’s population declining by 1.2%. As the discussion document notes, many West Coast communities are in decline. We note, however, that rapid population growth in any area of the Coast, particularly its smaller settlements, would place immediate pressures on several determinants of health, such as the availability and affordability of housing, education and health services, amongst others. Population growth is also likely to come predominantly from in-migration, rather than natural increase. This also means the population, as well as increasing, may become more culturally and ethnically diverse. While this brings benefits, it also brings challenges as local communities and services may not initially be able to respond well to the needs of these new Coasters. The BERL report states that the West Coast region does not have the transport infrastructure to support significant increases in mineral production, especially with respect to rail and ports. This is in contrast to the Development West Coast/Minerals West Coast/GNS report which speaks of the West Coast being well connected via excellent road networks and rail links. While the present transport infrastructure may be broadly adequate for current needs, it still has some significant problems. The large number of freight vehicles, which includes milk tankers, has been identified as an issue for the road network within the Regional Land Transport Strategy. Additionally, weather and other natural events make our roading network fragile, unstable and expensive to maintain. Without significant investment in the maintenance and upgrading of transport networks, increased freight traffic has potential negative impacts on both social and environmental wellbeing. The BERL report refers to the need for the region to invest in more rail and port infrastructure to support development initiatives. The challenge is how the West Coast can afford to invest in this infrastructure, as investment will be required before the positive effects of development contribute to economic growth. CPHWC suggests that consideration should be given to how those who will benefit most directly from development and use of resources could contribute to funding infrastructure investment. Agree with discussion points raised – however the environment must be protected – but not to the exclusion of reasonable development. 63 Support aspirations of Council in developing and RPS that facilitates development and sustains the isolated WC community. Notwithstanding support, it is critical that the policies and methods of the RPS not only achieve a suitable balance between environmental and other needs, but are also robust and defensible. 70

I agree with the RC wanting to be more active in promoting social, cultural and economic well-being by promoting opportunities for jobs and economic growth, but disagree with the focus on extractive industries. Care for our environment should remain our main bottomline as a healthy environment underpins everything. I support stronger consideration of economic, social and cultural wellbeing but not at any cost to the environment. Know that the extractive industries are currently important for the WC and will remain so in the medium term but would like the RC to take a more long-term view and also that extractive industries are using irreplaceable and finite resources. Communities and their well-being cannot be sustainable in the long-term if they are based on unsustainable industries and business. Support a review of regulations and procedures to simplify consent processes but these should not be at any cost to the environment or democratic process.

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Summary of comments made – ‘Yes, but…’ Submitter No. Understanding of document is that WCRC is attempting to short circuit the RMA to allow Council to influence what requires a consent and what does not. The reason for this being to offset the conservationists. In todays world, two thirds of the population of NZ would class themselves as conservationists, the other third would be mainly involved with extractive industries e.g. mining and dairy farming. Ironically enough, mining and dairy farming are very compatible at the present time owing to the fact that Westland’s untapped minerals include huge areas of high quality serpentine. At the moment serpentine related fertilisers are the in thing as it is said to alleviate the present problem of nitrogen loads in our waterways caused by more cows on less hectares. I am all for the exploitation of the very valuable minerals from these locations. However, it is glaringly obvious that two things are necessary before mineral extraction takes place. We require deep water loading facilities at Jacksons Bay and facilities in place to fully process the minerals before loading. Not only will this create employment for West Coasters, but will keep heavy haulage traffic off our already overloaded highways.

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In general terms support direction being taken. The Councils recognition and promotion of the regions natural resources is pragmatic and appropriate and reasonable to expect that the positive effects of the use of those resources are provided for in the RPS. Commend the Council for adopting an approach of promoting sustainable communities. The outcomes we anticipate that this approach will generate are a sound approach to resource use and development for future generations. Of concern is Councils comments regarding outside organisations/people dominating local decision-making. While we hold some sympathy for this perceived injustice, note that the statement fails to recognise the partnership aspects of some investment in the region. While do not have a local office in the region invest in roading and transport infrastructure in partnership with Council and the TAs. Consider that it is important that this cooperative and collaborative approach is retained, both to support the Council’s objectives in the review of these matters of the RPS, and from the perspective in WC infrastructure. Accordingly, suggest that Council should exercise some level of caution in adopting this approach to resource management.

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Innovation in the use of our resource assets is required. How can rip, s#^t and bust extractive industries lead to a sustainable long term future without regional taxation on those industries allowing for replacement employment opportunities to develop. Did the owners of all the sawmills contribute to population growth – they did. Was it sustainable, which is what Council wants to achieve in the RPS – no. Apart from helping to clear land for farming and bush roads for tourism, the sawmill owners took their money and ran. Taxation may be out of the jurisdiction but if you are talking about inclusion and use of development provisions to stimulate economic growth make sure there are some real sustainable long term benefits. Don’t pander to the short term, short sighted businesses that contribute nothing to the stated aims want to achieve. Identify industries that have outcomes that will provide long term benefits and reduce their rate and compliance costs. Put money into working alongside those industries so they don’t stuff the environment for the next generation.

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We must focus on intelligent use of our natural resources as not only NZ as a whole but the WC especially so. The WC is home to finest coal in the entire world and with responsible effort along with new cutting edge technology i.e. newest stack scrubber, low emission coal burning etc; it’s nothing short of criminal to be giving it away to China where there is no environmental effort. This document ignores the basic problem of the working tax-payer. Promoting business growth alone only exacerbates the primary challenge facing us – land and housing – affordable. Our housing is third world quality lacking dry, warm insulated, double glazed windows, solar. Where does population growth find this housing? Open up some real estate, allow us to live here affordably.

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Sustainability and growth are key words here. Minerals are lucrative but finite. Long term vision with short term goals and ways to achieve them. RPS should be flexible enough to deal with changes in government i.e. national policy focus. Simple to read and understand. Supported by elected members and council staff who are familiar with and can explain it. Population growth cannot happen without expansion of a range of industries, not just focusing on or two. Requires partnership with all Councils to provide incentives for businesses to come to or start up on the Coast. Tourism has huge potential but currently not facilities or infrastructure to support growth.

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Support any changes to the objectives and policies of the RPS which would increase efficiency in processing resource consents and reduce compliance costs as long as the changes did not permit or lead to a reduction of protection to the unique WC environment. This unique environment is a legacy for future generations never to be diminished to meet short term financial objectives. To date the sustainable use of this resource has provided more economic benefits to the Coast than any other sources like mining and farming. The current RPS acknowledges this and any suggested amendments should be viewed through this lens. Caution against knee-jerk reaction by the council to promote short-term business interests at the expense of the environment. There could be a strong case for policies and objectives which retain for the council some control over the rate of access to a resource. This would ensure that an applicant recognises a responsibility to self-regulate the boom and bust cycle which plays havoc with sustaining communities. The document implies that land under DoC management cannot contribute to the economic, social and cultural development of the region. This is nonsense. DoC and its

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Summary of comments made – ‘Yes, but…’ Submitter No. land contributes massively to the tourist industry and the employment of hundreds of people providing related services. AS well as that it has to be acknowledged that mining, farming and recreational activities occur on DoC land. Also suggests that people and organisations not resident on the WC have too much influence on the decision-making. The RMA was drawn up as enabling legislation and allows everyone to contribute in the submission process; West Coasters and non-residents. The sub-text of the suggestion is that it would be appropriate to change the RPS in a manner that would result in notifying fewer applications for public submission. Sustainability is important. Whilst minerals extraction is clearly a big earner it is a finite resource and therefore ultimately unsustainable. Also interested in figures for relative contribution to GDP. How much of the mineral GDP goes to locals and how much to international companies. How many jobs are provided by each of the three industries. The dairying income does go to local farmers (as long as farms are not sold to international interests) but we must be sure to enforce standards to protect waterways etc to ensure it too is sustainable. Encouraging further light engineering industry would be worthwhile with a surfeit of skilled workers ex-mines. There is no reason why their products need to be directly related to mineral extraction or dairy. Though it is a relatively low-wage industry, tourism can provide many jobs including vital low skill work and is sustainable as long as we do not degrade the environment.

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Summary of Response – ‘No’ Summary of comments made – ‘No’ Submitter No. Existing RPS already allows for mineral extraction recognising benefits to community. Criticisms of Discussion Document: Concentrates on mining as only way to improve economy Use of references, statements, graphs No statement in an RPS can influence commodity prices No consider the numbers of people employed in the different industries i.e. more in tourism and dairying than tourism Mining can harm environment that provides for tourism and dairying if uncontrolled DOC land is available for use, except for Schedule 4. Statement in document regarding access incorrect WCRC implies sustainability only to do with economics – ill thought out statements can contribute to environmental degradation Generalisations about positive effects of resource development can be misused and should be avoided.

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Oppose inclusion of new policies because: They do not constitute resource management issues under the RMA – outside functions set out in s30, not RC role to promote economic development or investment,

population growth or industries that can provide jobs. RMA already provides for positive effects to be considered by Councils and if Council has not given due consideration to these in the past then is an issue of process. Doing so would compromise the Councils ability to fulfil its functions under the RMA – attracting investment, jobs and growing the economy would create conflicts of

interest that would compromise objectivity of consenting staff Doing so would perpetuate the misconception that adverse effects can be offset by positive effects – RMA provides for positive effects to be considered while any

adverse effects must be avoided, remedied or mitigated. The Council has no legal mandate to manage the regions social, cultural and economic wellbeing – s5 states that sustainable management enables “people and

communities” to provide for these things. Doing so would create opportunities for legal challenge, creating legal and financial risk for Council and ratepayers The RMA does not provide for people and communities to provide for social, economic and cultural wellbeing at the expense of natural and physical resources, the quality of the environment and/or future generations.

12

Own and operate a tourism business – consider that there is huge potential to tourism on WC but low numbers are due to lack of investment in promotion domestically and internationally. Tourism can and does provide a sustainable economic future for the area. Believe mining is unsustainable. 20

Existing RPS provides adequate protection. The Act does not need ‘balancing’. The using and developing of our resources needs managing. Inclusion of growth and development provisions unnecessary as if this were the case, why after 150 years of extraction is the WC not richer? No role for the RPS to play in promoting and managing growth. Transport networks have plenty of capacity. Public services cannot adequately service the existing environment so needs further investigation.

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Does not consider the Discussion Document to be correct in its comments re economic climate – commodity markets go through boom and bust scenarios regularly. Consider there are few, if any, business proposals that get rejected because they conflict with regional plans, objectives or policies. Mineral extraction has the potential for serious environmental degradation. Loosening environmental laws could eventually lead to extremely expensive clean-up operations – sensible option is to avoid such scenarios with strong environmental protection. Effects on industry such as mining can be direct and adverse on lives of neighbouring people. Proposed changes concentrate on active promotion of exploitation whilst people adversely affected put under greater duress. Extraction of them can be difficult and even proof of existence even in abundance does not necessarily imply that they are a source of wealth as extraction can be prohibitively expensive. Minerals may be a key driver but this has to change as they are so finite. WC one of the best places for growing berry and feijoa fruits and other agricultural products. Huge wealth in peat soils that Regional Council fails to recognise value of when they are lost through humping and hollowing and flipping for dairy expansion. Regional Council needs to predict future trends in order to ensure that the appropriate infrastructure is in place but should not ‘fish’ for people to support population growth and economic output. Alterations to the RPS need to take into account Matheson and McVeagh’s comment “central government concern that some councils have gone too far in their endeavours to address social and economic wellbeing under the LGA 2002.” Council need to investigate what population increase the environment can sustain without environmental degradation. Is there enough of the right infrastructure in place to prevent degradation.

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Summary of comments made – ‘No’ Submitter No. Should improve educational wealth as currently lowest in NZ (census) in order to have better understanding about the environment we live in and our natural ecosystem services e.g. wipeout of whitebait spawning areas due to injudicious land practices. Environmental standards should be high before encouraging further business. Pers com with Karamea resident indicates poor estuary water quality and now too polluted to swim, Mohikinui, Ngakawau, Waimangaroa, Orowaiti all unhealthy and if cannot be kept clean through enforced compliance on resource consents then there needs to be a cap on conversion of land to industries that require such consents. Water quality monitoring questioned for Buller if nothing north of Buller Rv are monitored. More time need to be put into ensuring proper compliance, talking to different sectors of the community and educating as to healthy ways in which to interact with wider environment e.g. burning of prohibited materials such as household rubbish when includes plastics, volatile organic compounds and other chemicals. Newsletter article does not reach those needs to. Bottom lines for water quality need to be included at the Councils earliest convenience in line with mandate from the NPS on Freshwater Management. No mention of climate change. Inevitable that there will be laws in the future that govern potential carbon dioxide emissions at source which should be taken into account by this region. One of the RPS policies is to stabilise greenhouse gas emissions in the region yet there has been no education as to adverse effects of it. RPS in current form has necessary power required to invoke high quality regulation but Council does not heed nor ensure compliance of its own rules and regulations on the environment. Sees avoiding, remedying and mitigating adverse effects as being the positive effects of the RMA because without a healthy natural environment we can only have a short-lived prosperous urban community. Since first RPS has been decline in natural character of wetlands, lakes and rivers and their margins, and on ONFLs et the RPS said they were to be protected. Wetlands all but disappeared, waterways through production land run turbid and filthy, groundwater polluted with nitrates and pesticides, weeds proliferated, little done to protect coastline with subdivision occurring within 20m, creek outlets classed as ditches running through farmland allowing for non-consented opening of mouths at will and others have too much diversion so that their estuaries dry up. Do not support intent of Discussion Document. Current RPS is a balanced approach to allowing prosperity whilst protecting environmental values. Need to incorporate bottom-lines for ecological health as the priority. Most glaring problem with current RPS is the lack of interest of the Council to comply with it. Focus of the review should be on adopting the Freshwater NPS provisions and secondly on ensuring enforcement and compliance. No reason to adopt new policy directions and do not have my support 38 Resources are finite. Making minerals accessible to multinationals, opening the country up to big business ventures that are not in the interests of communities and infrastructure creates short-term gain and environmental degradation e.g. Proposed illmenite mining on the Barrytown Flats – noise pollution, pressure on roads with trucking sand to Greymouth, disruption to native fauna – black petrel breeding colony already under threat. Making consents easier to obtain and fast forwarding mineral exploitation is dangerous and shortsighted. Communities must be involved in submission process. West Coast is largest natural area and has the most diverse mineral resources, also most vulnerable. Must be stringent controls set in place for any exploratory mining and must be supported by people who will affect. RMA affected parties must be party to any decision-making process – short-term caretakers of the land.

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Ramping up mineral extraction an outdated and misguided approach. Unlike waterways affected by dairying, ground that has been mined can never be restored to its former state especially if existing species are unique and become endangered or extinct due to activity. Discussion Document’s graph shows that dairy and tourism sector contributions equals that of minerals. They are also more compatible which suggests that these are better areas to ramp up than minerals. There is no new vision or positive way forward for the WC, nor importantly any way to transition to a sustainable new future. New thinking needed that is based on sustainable and renewable resources (water, wind, sea, waves things that can be grown on the land or in the sea, positive uses of waste). Agree that good quality regulation can stimulate growth but can be taken too far. Along with this there is a crucial need for effective monitoring and enforcement and not caving into pressures exerted by big business. Fear that Council intends to notify fewer development projects similar to the quarry on the Coast Road which was halted due to public pressure. Locals need to have a voice on what happens here as well as people from outside the area who care for this important environment and its vulnerable eco-systems. Suggest panel of thinkers from around world (including the Coast and NZ be funded to look at the current situation and come up with viable alternatives and possible transition pathways to a dynamic new future based on economically sustainable resource and value-adding processes.

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Once lose pristine environment cannot get it back. When you give into ‘dirty’ industries and urban sprawl can’t go back. Mae industries respect the environment - have a ‘zero tolerance’ for pollution. Promote clean ‘green’ industries. Promote education both by building good schools and colleges and educating everyone. Use mass transport 43

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Summary of comments made – ‘No’ Submitter No. early on and then let it grow as too hard to start once everything is built up. Oppose proposals and do not think should modify the RPS in the ways proposed. Reasons are: Argument for including the positive effects of natural resource development, and [unspecified] ‘use and development provisions’, alongside the current environmental

protection priorities in the RPS is based on a spurious and misleading notion of ‘balance’ that fails to recognise that environmental protection and sound management are the ‘bottom line’ on which social, cultural and economic wellbeing depend. ‘Does ‘balance’ between competing interests mean that environmental considerations can be traded off against economic development aspirations as though jobs in mining was somehow equivalent to soil and water quality or ecological diversity. These are not commensurable in any way. Protection of the environment is a bottom line: the basis on which economic development depends, not something to trade away for short term financial prosperity. Access to the regions resources has to be decided on a case by case basis, what the RMA is for and what the Council does. Some mining provides economic opportunities while causing little damage to the environment (beyond loss of resource for the future), given enough good attention to management (avoiding, remedying or mitigating adverse effects). And some significantly degrades the environment in ways that cant be avoided, remedied or mitigated – and so should not be allowed to proceed regardless of the jobs it might provide. These are issues of adequate knowledge and good judgement not matters that can be resolved by generalisations in the RPS espousing ‘the positive effects’ of natural resource development. Balance points keep shifting. Without any bottom line or set limit can keep trading off bits of one thing for another until the original thing is gone e.g. Bathurst – what is now to be protected either already been extensively modified or has always been of lesser ecological value.

Have misleadingly overstated the case for future prosperity from mining. The assessment referred to in the “Mineral Resources of the West Coast Region” gives only desk top probabilities of particular mineral occurrences and estimates of potential ‘in ground’ resources which do not imply that the resources are recoverable or that they can be mined at a profit. Several of the known prospects have been extensively investigated and shown to be uneconomic with the exception of illmenite on the Barrytown Flats though its true economic potential is still in question.

The current RPS already acknowledges that mineral exploration and extraction may in some cases be highly prioritised because of social and economic values – the changes are unnecessary.

If an organisation or party has a valid point to make in any debate about consenting processes it would be absurd to reject their claims solely on the basis that they don’t live here. Contrary to statutory and professional obligations to give due consideration to all points on their own merit.

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Business of a new ‘balance’ seems to imply that to date there has been too much emphasis on protecting our environment and too little on using it for economic development whereas consider opposite to be the case. ‘Promoting the sustainable management of natural and physical resources’ should be embraced by Council, not just reluctantly complied with because it is law. Councils priorities should be for the concerns West coasters and all New Zealanders, not for overseas backed companies who may be keen on prospecting here as a tax break. Disagree with current doom and gloom forecast – census data paints a different picture. West Coast official boundaries contain a lot of steep high country (mountains). Does not mean we have met our environmental ‘obligations’ and do not need to take care of the lower or gentler areas where we live and work. Ecosystems so not work like that. The majority of these areas have already been greatly modified in the past but we need to be working to prevent further degradation (water quality). Rare untouched remnants must be preserved. West Coast needs to be seen as an integral part of ‘Team New Zealand’. Already it has a reputation as a place where ‘cowboys’ can get away with things that they might not somewhere else. It is not the place of the Regional council to be encouraging this perception. Two new policies and unhelpful and unnecessary. Put the word ‘sustainable’ back with ‘environment’.

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Should not promote growth and development for the following reasons: Responsibility of RC to protect the right of everyone (including species besides humans) not just the interests of those with money and influence. Promotion of growth

and development take time, energy and money away from governance. Should come from the community instead. Protect our environment not just talk about it. RC not identified significant resource management issues – is going backward to more boom and bust mentality; decades of mineral extraction does not create a

sustainable community. Document misuses the word sustainable and little in it that is sustainable, development not sustainable. Promoting positive effects usually comes with a long term big price. Denial of extent of negative effects usually has long term bad synergistic effects. RMA an attempt at a real balance to get us to not ignore the negative effects. Council wants to diminish that balance by focussing on short false term notions of

sustainability and the powerful illusions of grandeur that denial brings. To avoid, remedy or mitigate the adverse effects should always come first - the positive results come naturally and promote social, cultural and economic well-being in a

truly sustainable way. Should be a win-win for humans and flora/fauna. Population growth never been shown to give a positive result for the environment or humans. How many homes use solar technologies – why isnt the WC an example and leader in alternative energy. Lots of unhealthy pollution from coal.

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Summary of comments made – ‘No’ Submitter No. If Council really promoting sustainable communities would promote things like organic farming and cooperative business. About long term sustainability of people and

their environment not based on the narrow-mindedness of the short term gain, a quick buck and leaving the mess for someone else to deal with later. Should promote a sustainable living wage for everyone Work on public transport for tourists and the local population, including a trail head transport system for the cycle trail and commuter transport for workers and

students (possibly using rail). Current RPS complies with RMA. Changing it will result in plan changes, oppose having to do this. If pre-empting RMA changes then need to make this clear to the public. Discussion Document written by people with vested interest in mining. Consider it to be misleading and questions posed to obtain supportive answers. No mention of projects declined or problems with obtaining consents. Primary resource management issue is a healthy environment. Without clean air, water productive soils and a vibrant biodiversity there cannot be long term prosperity. A national issue and those on the WC cannot expect that their views will be the only ones that count. Oppose a parochial attitude to planning on the WC. Want to see an increase on public notification for consent applications concerning extractive industries, roads and subdivisions as these are likely to have the greatest environmental impacts. RPS must explicitly recognise environmental bottomline which must be reflected in all district and regional plans. Needs to provide for the issue that there will be instances when ‘balance’ cannot be achieved between economic development and environmental degradation. Must acknowledge and embody the principle that nature cannot and should not be valued in purely economic terms. Is not a tradable commodity. Current RPS is adequate in respect to water (Chapt 8) and Habitats and Landscapes (Chapt 9). Plans devolved from this are still new and require time to bed in. Unless the resources and political will are present to action it, it remains a pointless document. If you develop a new RPS believe needs central pillar of the Rights of Nature and the recognition that the Natural World is not there purely for the benefit of the human race – rights set out in the United Nations Universal Declaration of the Rights of Mother Earth. Because of intensification of dairying RPS need to address the protection of water quality, and of lakes rivers and wetlands from run-off and stock access. Positive effects must include protecting and enhancing biodiversity and ecological well-being and needs to promote such positive effects especially on non-conservation land. Discussion Document fails to make clear that much conservation land on WC is unsuitable for development and that much of that land is not Schedule 4. An omission commonly made by Coasters and cynically exploited in this Document. Use and development provisions already exist in the RMA and any RPS is required to adhere to this. May occur once provisions of s5(2)(a-c) have been addressed. Goal for RPS should be for a stable economy and population. Focus on growth a worn out model and unsuitable for finite planet. Future will continue with agriculture, fishing tourism and mining but only where these do not destroy the natural environment. Like to see open-cast mining phased out especially where destroys unmodified landforms and ecosystems. Provisions around mining in current RPS are unbalanced and must not be included in any new RPS. Environmental protection and state of environment are not chips to be gambled with.

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Are concerned about a real, or perceived, conflict of interest with a statutory agency in charge of habitat protection moving in a direction of promotion of development involving the same habitat. Certain developments will invariably be at odds with s6 and 7 matters. The discussion document is lacking in mechanisms to fulfil the RC statutory function to protect and provide for s6 and 7 matters of national importance including 7(h) the protection of the habitat of trout and salmon. How should council manage issues for the next 10 years? Sustainably so as to provide adequate resources for current and future generations. Most industries are now aware that when given preferential access to public resources, such as freshwater, a level of environmental responsibility is expected. The RMA spells this out very clearly in section 5 where development should be managed in a way that (a) sustains the potential of natural and physical resources to meet the reasonably foreseeable needs of future generations and (b) safeguarding the life-supporting capacity of air, water, soil ad ecosystems and (c) avoiding, remedying or mitigating any adverse effects of activities on the environment. Interestingly in section 5(a) of the RMA an exclusion for minerals is made presumably due to their finite nature and consumptive use. Herein lies an issue that needs to be recognised. Extractive industries such as mineral extraction and industries which consume or leave public resources in a state which are unfit for alternative or future industry use are not sustainable. Therefore special provisions and contingencies (such as bonds) are required for ‘clean-ups’ in the event of industry failure. Numerous ‘historic workings’ that have been abandoned have left acid mine drainage issues for future generations. Council needs to be aware that it is unacceptable to expect future generations to bear the environmental consequences from poorly managed development in an effort to provide short term financial gain.

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Summary of comments made – ‘No’ Submitter No. Is promotion of natural resource use a statutory function of Regional Councils? The only reference to ‘promotion’ in regards to the RMA is in s5 of the Act regarding the purpose of the act being to ‘promote the sustainable management of natural and physical resources’. This is a purpose of the act not a specified function of Councils, it would be a stretch of the imagination to interpret this as meaning the WCRC has a role to promote the West Coast’s ‘natural resources’ for development purposes. Under s61 a regional council shall prepare and change its RPS in accordance with its functions under s30. Nowhere in s30 is there any reference to regional councils as promotional entities. All references to functions of Regional Councils refer to the control functions of effects management as would be expected of a regulatory agency. Stimulating economic growth – is the RMA the problem? The overwhelming majority of consents processed in NZ are processed on a non-notified basis, with less than 4% being subject to public hearing or appeal. This indicates that the system is working well. Yes some developers and submitters abuse the process but there are legal mechanisms and robust appeals processes in place to address these problems. The latest proposed RMA reforms are also proactive in this area. Role in promoting and managing growth – All types of submitters including competing businesses have a right to have their say when a new resource user has the potential to affect the existing users. The WCRC needs to be aware of ‘knee-jerk’ reactions to an isolated number of cases. The RMA has received steady criticism from some quarters for the complexity of its procedures and the compliance costs they are perceived to impose on businesses. However, such criticisms are not unique. Similar complaints are routinely directed at other regulatory regimes designed to achieve public policy outcomes – including tax, employment and ACC. In the most recent Compliance Cost Survey conducted by business NZ, the RMA was in fact identified as a compliance cost priority by less than 10% of business respondents. That relatively low level of concern is consistent with international assessments of the RMA’s efficiency. Concerns do not align with international assessments of the Acts efficiency. The World Bank, for instance, assesses NZ as the 3rd easiest country for ease of doing business – an assessment that include consideration of the resource consent process. Realistic population growth – proactive planning for the next 50 years is for communities and government agencies to be aware of impending limits, and make wise decisions ahead of time about how to manage within these limits, in order to share the cost of the limit equitably. The planning process, if properly resourced, can handle this. “Future focussed” and “proactive” planning processes are fine, provided that these terms are defined in terms of physical and ecological limits. If not, unrestricted growth is simply a recipe for uncontrolled use with damaging consequences that future generations will have to pay for. It would be wise to implement ecological bottom lines so as not to impinge on current and future generation’s lifestyles which are an important consideration in growing and maintaining local communities. Protect our water supplies and wild food from aerial toxins like 1080. Not appropriate for the regulator to promote poisons. Stop rubber-stamping gold mines, roads and dams as ‘non-notifiable’ and passing the buck confusing submitters “oh that’s the other council not us”. Sustainable – bring back the RMA. No Hollyford Road. 82

Strongly disagree with the biased and blatant focus the Discussion Document has on encouraging the development of mining and dairy farming. This is not a balanced outlook. A better economic policy for the West Coast should have an emphasis on encouraging diversity in my opinion. Diversity will create more economic stability as opposed to the boom and bust cycle of the mining sector. I am very disappointed at the lack of emphasis on looking after the natural environment. The Lonely Planet Travel Guide just listed the West Coast in the top ten places in the world to visit. I think we need to be very careful to look after this reputation by looking after the natural environment. This should be the biggest focus of the RPS.

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I do not find anything I agree with. Paper written by a mining enthusiast with rose tinted glasses, and basically proposes upsetting the present checks and balances between environmental use and access to resources, in favour of mining for short term gain and leaving subsequent generations of Coasters to pay the price. And what that basically means is that future Coasters will be paying foreign multi-nationals to wreck our country for a few temporary jobs. Tourism employs more people than mining, or even agriculture on the Coast. It doesn’t even get a mention in the paper despite the potential for mining to harm the environment and damage the tourist industry. We already give too much weight to positive effects of mining, and coal mining is a dinosaur which need to be phased out. We know the result of coal burning is climate change and rising sea levels and future coasters will have to contend with that too. Many mines like Pike River are intrinsically hazardous and prohibitively expensive to run properly, so they should never happen. Similarly, some mines will cause unacceptable environmental damage. The Councils job is to call these proposals to account and ensure damage is avoided or mitigated. It has a perfectly adequate system to do that now and has to take each proposal individually. Giving mining carte blanche because miners need jobs is not an option. In facet mining is the opposite of sustainable, and does not sustain communities for long. Reefton has had a boom, and is about to get to the bust soon.

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Overall a very disappointing document. Lacked objectives and outcomes and failed to qualify many of the statements made. Used old data and did not provide adequate reviews of inter-related issues. No indication of the economic benefit of tourism to the WC. On pg 13 only the extraction industries are given and there is no indication of the 118

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Summary of comments made – ‘No’ Submitter No. value provided by approx. 600,000 tourists visiting each year. In additional although there was criticism relating to ‘locked up’ land by DoC there is no analysis of the benefits of the conservation estate and the national parks of the region. Furthermore mush of the conservation estate is inaccessible due to geographic constraints. Should this be considered a major economic issue then the WCRC should enter into a discussion with the government on suitable regional compensation. There was also a very strong emphasis on the extraction industries which have proven to be unsustainable throughout the world and do not provide for long-term development or employment. I found the document did not explain what an RPS is and under what legislation a council is required to produce one. I am not sure how the objective of the discussion doc (Imagine the West Coast in 10, 20 or even 50 years into the future….) directly relates to the purpose of the RPS under the RMA (“to achieve the purpose of the Act by providing an overview of the resource management issues of the region and the policies and methods to achieve integrated management of the natural and physical resources of the whole region”). I consider that the RMA deals particularly with resource management issues and the RPSs fit within that framework. The Discussion Document suggests that the RPS should be more people oriented and have a strategic or visionary status. The RPS does not seem to me to be the place to do this. I am happy with the emphasis given in the current version of the RPS. I do not see the need to change this. The two new policy directions are fine concepts but do not fit within the ambit of the RPS. I have no issue with organisations and individuals from elsewhere in NZ contributing feedback on this issue. Many WC’s now live in other areas and many other NZers have intense and specific interests in a wide range of WC issues – including employment, recreation, hunting, fishing, history, the environment etc. Their contributions should be welcome too.

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I find your new ideas on mining hard to stomach. Having had Birchfield's mining down here in Ross breaking the terms of their license captured on film. Despite this having no action taken by either the WCRC or the WDC over the years. Having the nature of Ross changed to the state where there will be many dollars spent removing exotic weeds etc by the population of Ross at no expense for either Ray Thomas or Birchfield's mining. Having a historic road disappear into "Lake Roddy", Grimmond Avenue. I might mention that other mining concerns have had to toe the line. At a recent submission hearing in Hokitika the mining rep "Green and Gold stated that people who build in a pre-worked gold area should not be there and they should move aside or words to that effect. At the present site of Birchfield's mining the Ross community were given no right to comment as we were told it had nothing to do with us. Birchfield's mining has removed one of the toes of Mount Greenland allowing substantial SW winds into the town. No effect eh. Your new ideas have been put into your plan purely driven by a boom and bust industry. Very little long term thought is apparent only what I perceive to be a desperate quick fix solution to the recession which can only result in long term damage.

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Balancing to get a positive, of the effects and use of development, means that the environment has to be a number one consideration, so as to ensure that all other 'industries' are not compromised for the sake of short-term operations. Tourism being a huge long-term employer on the Coast, means that long-term consideration has to be given as to the effects that opencast extraction has on the visuals; not just for the tourism industry but also the residents and ratepayers of communities within the vicinities of these operations. Visual amenities are a huge part of our reason for residing/owning property. Also the monitoring of waterways which are of importance as food source and recreation - long-term. How can the WCRC support the rest of the industries/ratepayers/residents on the Coast, when they are already low in resources to follow up on incidents that are a negative on the environment that we live in? Sustainable communities, would be the long-term employment opportunities. China is now a huge contributor to the West Coast Tourism sector, and we have been advised of the increase of Chinese visitors in tourism over the coming years...they wish to see our clean and green environment. Communities and townships need to be seen as a positive visual for residents and visitors alike. Retaining each communities identity is common-sense, as these are what tourists come to see, especially those with significant historical sites etc. The Cycle Trail is winding its way through small communities that are building their scope to create more opportunities through tourism, the long-term future of these areas is the history. Operations encroaching within the communities is a long-term negative: visuals, climate, environment. With the West Coast Minerals Booklet that was advertised in Toronto a couple of years ago; the rest of the world was invited to come and dig away at our region. Unfortunately, West Coasters were not privy to the booklet...only those with mining interests. If this was supposed to be such a positive for the West Coast Region, why were Coasters left out on this. I believe there is good reason why so many people distrust many of the 'authorities', i.e. WCRC decision making, especially when miners and farmers have been predominant within the council recently. Good decision making comes from considering all aspects for all, not just those with a vested interest. I hope that the WCRC protects all the communities for the right long-term reasons and that all industries comply 100% to promote the clean green image so that our long-term tourism industry can continue, plus consideration on our rights of where and how we all chose to 'live'.. We need to be able to trust the decision making to be of balance.

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I am wary of Discussion point one for it seems that it is already covered in the existing RPS: OBJECTIVE 16.1 Options for the evaluation, use and development of mineral resources are not unnecessarily hindered while other natural and physical resources are sustainably managed. OBJECTIVE 16.2 The ability to evaluate mineral resources is 123

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Summary of comments made – ‘No’ Submitter No. protected. So, if the intent already exists, and has existed for some time, what is actually intended? My suspicion is that some resource-use activities will become non-notifiable. I also suspect that this move is being encouraged by the present government, who economically have difficulty comprehending anything other than exploitation and low wages. Discussion point two seems to be pretty dumb. Of course we want sustainable communities. And of course we could do with more people living here. But to see the solution lying in the development of resource extraction is to ignore West Coast history, from the gold rush onwards. Resource extraction is unsustainable because the resource is extracted. So a new resource has to be extracted. Boom and bust until there is nothing left. There are still issues to be explored, such as the rate of extraction, the end use of the mineral (while coking coal is still necessary, thermal coal is unforgiveable in terms of climate change), other possibilities (e.g. coal to carbon fibre), ownership and profit flow (does it stay here or go offshore?), what other possibilities are there for the associated industries, especially engineering? As well, it is unwise to ignore consensus gathering around issues like climate change, to put oneself out of sorts with young people who are rightfully worried about an inhabitable planet for their children. There is no easy solution to the problem of developing sustainable communities in this area of the country or one would have been found by now. Factors like exchange rates, import controls, consumer education come into it. Is the fact that the dairy industry is a co-operative in terms of processing and marketing important? What motivates people to live here – if it is lifestyle then a rush of mining activity defeats the purpose. In terms of local control of decision making, I would agree that it would be better if local processes are not dictated by urban-based pressure groups, but it is a complex matter. We could start with 1080 drops, where it seems communities could very easily discuss the issue and decide for themselves what happens in their area. Would the Government allow that? Very unlikely. When it comes to the resource consent processes, obviously community groups are disempowered by the need for lawyers and expert opinions and the costs involved. As with Bathurst, it can become a struggle to see who runs out of money first. And then who is judging? Is it someone from outside the area who will be assumed to be neutral? Or a local councillor who might well represent his or her own class interests – the lack of diversity and the brush with at least a feeling of corruption which tarred the last regional council was not good. Or has it been taken over by the Government’s fast track authority? In summary, this movement you are proposing feels ideologically driven, and the purpose has to be either dishonest, or at least disingenuous. Council seems to want to address the ‘tough times’ by making it easier for companies to explore and extract coal and minerals by reducing resource management requirements and probably further limiting the number of consents that are publicly notified. Disagree for a number of reasons – Council currently struggles to ensure adequate compliance of mining operations, therefore there are operations that are not carried out in accordance with consent conditions and environmental degradation occurring. Council therefore struggling to uphold some of the basic tenets of the RMA. Lowering standards as proposed would worsen this problem. The comment that “Too often, planning and consenting processes here are dominated by organisations or parties who live outside of the region” is unfounded and sadly narrow minded. It could be that this is a veiled reference to the legal and statutory challenges that Bathurst has faced in gaining consent and other permissions for the Escarpment mine (however, these challenges came equally from West Coasters). The idea implicit in the aforementioned quote, that it is ‘none of your business because it’s our back yard’ is unintelligent on two counts: it fails to acknowledge the national significance of some of the mining projects being facilitated by the WCRC. To expect and prefer that other New Zealanders will not be interested in resource use in the WC region, especially when environmentally sensitive areas are involved, is presumptuous at best and negligent at worse. Forest and Bird have many members who are West Coasters. So, if Council is serious about incorporating Coasters views on the RPS, then they will also embrace views of people who are concerned about environmental sustainability. There is no need to further emphasise the positive effects of resource use and development in the RPS. The economic importance of enabling opportunities for the utilisation of coal and minerals is already sufficiently covered in the RPS. While I acknowledge that mining is currently a key driver of our regional economy, I would like to see Council intelligently facilitate and prepare for a truly sustainable future economy.

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Although I am an advocate for sustainable healthy communities (which includes the attainment of environmental, economic, social and cultural wellbeing) I am doubtful that the RMA needs ‘balancing’ and that ‘promoting the positive effects of using and developing our resources’ will necessarily be beneficial to the West Coast in the long term. I hold this opinion for the following reasons: Apparent from further reading material and recently held economic summit that Council views further investment in extracting minerals and dairying as the future

economic base for the WC.

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Summary of comments made – ‘No’ Submitter No. Decline of our communities being experienced by many small communities. Process of deciding the effects of using and developing natural resources is fraught with difficulty. Giving every effect equal weight, even if possible may not serve the

WC well. Becomes an exercise in caution requiring investment in appropriate resources. A deep commitment to protecting the environment (without which there is no sustainability of communities either socially, culturally or economically) is required. Past experience shows that the positive effects of potential economic development can be overstated and potential environmental effects understated. Document does not explain how it will ensure that appropriate resource and processes will be established to ensure decisions are made with a long-term view.

Question then becomes how to measure the effect, who will make the decisions based on those measurements and indeed should there be equal weighting to both the positive and negative effects.

Clear some form of assessment is required when weighing up the effects of development on the environment, the economy and communities. It is also clear that that assessment currently takes place within the existing RMA process. However, current use of the RMA process has not necessarily prevented or mitigated negative environmental effects. If the WCRC, or indeed any other regional council in New Zealand, has focussed on the environment at the expense of economic and other well-beings, how is it that our waterways are degraded, communities experience poor air quality and we still have an economy that is based to a large extent on the extraction of fossil fuels? Is it realistic to think that a balance can be struck that will ensure a sustainable environment in the pursuit of economic growth; more so if we continue to develop a coal-based industry, have limited monitoring and poorly enforced consent conditions.

Globally the state of the environment has played second fiddle to economic development and human wellbeing, resulting in emerging scientific knowledge regarding the negative effects of human behaviour being ignored at best or actively denied at worst. Examples of where this has occurred span the issues of tobacco use, acid rain, holes in the ozone layer, and climate change/ global warming. In each of these man-made situations there have been attempts (by countries, people or businesses that stand to lose if change occurs) to deny the evidence surrounding these issues and prevent or prolong attempts to address the issues through regulatory policy. The periods of ‘doubt’ that followed each of the issues has negatively impacted on many lives, communities and environments across the globe.

While I also agree that people who live in the West Coast communities should have a voice in the development of the RMA it is disingenuous to state that too often planning and consenting processes are dominated by organisations or parties who live outside the region; Central legislation and policy dominates decisions, international protocols also impact and, as it is impossible to ensure any negative effects on an environmental area are not confined to that area, I believe it is important that voices from other areas are able to be participate in decision making. The fact that around 90% of consents are approved through the non-notifiable process means the public are already prevented from participating within the RMA process

The demands of society are not presently in balance with its needs for a healthy environment. Environmental well-being underpins social, community, cultural and economic well-being in that without a healthy environment there can be no social well-being. Therefore, a healthy balance between those facets that society depends on for the necessities of life would be one that excludes activities, such as coal extraction, that threatens the well-being of society via the effects of carbon emission induced climate change. Extractive industry also has negative effects on biodiversity, regardless of whatever effect it has on the wider environment. Future social and economic well-being depends on maintaining biodiversity over and above economic considerations. The balance must lie then in giving priority to environmental well-being. To date the WCRC has not been supportive of biodiversity when a commercial use has been found for resources that would destroy that biodiversity. The expansion of Solid Energy’s Stockton open cast coal mine at Happy Valley and the headwaters of the Waimangaroa river is a good example. Clearly the WCRC supported the extraction of coal at the expense of an area that had rare and unique flora, fauna and geology associations that were found nowhere else and had even been recommended for protection. It is apparent then that regardless of the discussion document’s stated intention of finding a balance between the different facets of society, unless there is a culture change within the council itself, it will continue to support activities that are not in balance with the long term sustainability of West Coast society. The fact that water quality in many lowland streams and lakes throughout New Zealand are now so polluted they are not safe for drinking or swimming in is an indictment of local governments’ failure to find a balance for even one of the basic needs for a healthy community, clean water. It is of limited use for the WCRC to canvass public opinion about where it thinks the balance should lie between society’s competing interests for resource use. Often members of the community are pressured by their immediate needs supporting the destruction of unique environmental values even though they know that to do so is contrary to the long term well-being of their families and their descendants. If the WCRC is going to place itself in the position of promoting economic growth it follows that it cannot also promote a healthy environment because it is economic growth that has led to an imbalance in carbon emissions resulting in the impacts of climate change. The WCRC needs to consider that its support for economic growth per se is support for the effects of the present fossil fuel based economic system, which is likely to result in the flooding of Greymouth, Hokitika, Westport and most coastal communities on the West Coast via global warming, increased rainfall and sea level rise. The WCRC should be actively promoting environmentally sustainable land use practices, not business as

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Summary of comments made – ‘No’ Submitter No. usual. The Council’s vision for the West Coast to “...have sustainable communities with a strong regional identity” is great. But that identity, as every visitor knows, is based on a romantic past of unsustainable forestry, coal and gold mining, and the present natural environment that is the basis of a sustainable tourism industry. Few West Coast communities would want to identify themselves with the pollution created by the Stockton coal mine that has resulted in one of the most polluted rivers in New Zealand, the Ngakawau. Conversely, Greymouth, Hokitika and Westport communities like to identify themselves as clean exciting places to visit with wild green forests and stunning landscapes, not with the raw sewage they dump into their rivers or the global warming they have helped create. The discussion document comment that “Too often, planning and consenting processes here are dominated by organisations or parties who live outside of the region” is a parochial view that is at odds with the fact that most large businesses in the region, which contribute the larger portion of damage to the environment, are dominated by shareholders who do not live on the West Coast and are often not even resident in NZ. Multi-national corporations and international investors have had a lot influence on the direction of development on the West Coast and continue to do so. For the Council to suggest that non-residents should be treated as aliens and their contributions of lesser value, is to promote an insular myopic society unable to take advantage of new ideas and the benefits they bring. The timber industry is a good example of how the West Coast lost a sustainable resource and potential source of employment and wealth by destroying large areas of native forest and exporting largely unprocessed logs, which could have been the basis of a thriving manufacturing industry. If the Council is to become involved in promoting a healthy local economy, it needs to promote truly sustainable practices, not the boom and bust policies such as those that have dominated mining to date. On the other hand the tourism industry has diversified enormously, largely to take advantage of every aspect of the West Coast’s natural environment, and is now the largest single contributor to the local economy. The discussion document seems to be a veiled attempt to sideline key functions of environmentally responsible management and monitoring, in favour of promoting development. The language plays on West Coasters’ long held sense of injustice and righteousness (“people who live outside the region” etc). Discussion point 1 seems to pit the “positive effects” of development against the “negative effects” on the environment. What about promoting the positive effects of good environmental management outcomes? The statement that “the Council believes that people and communities are at the heart of any future growth” is indicative of a concerning attitude from the council. If the Council was really looking for a balanced approach, “environment” would also be considered to be at the heart of that growth. DP1 plays down the importance and potential of tourism and plays up the advantages of mineral extraction with seemingly little recognition of the boom and bust nature of this industry and the potential for damage that has on our communities. The RPS should not shift its focus away from sustainably managing our resources to “promoting development”. It seems the council already struggles to monitor, meet and ensure our environmental bottom lines are being met. These changes seem to be an attempt to further loosen the rules and enable the council to pay less heed to their responsibility as environmental managers. Do the job you are mandated to do, not the job that suits your own personal economic drivers. We must ensure these resources that make the Coast such are special and unique place to live are upheld for generations to come, not squandered for short term, current generation, economic gain.

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RC’s role is to look after the management of natural resources. Environment = the bottomline. Development is a private enterprise that will be possible provided it is sustainable. No need for WCRC to promote. Why don’t we have ‘good regulation’? By all means be fair, consistent. How much money from mining sticks on the WC? How many Mum and Dad mines are there? What if it runs out in 1 or 2 generations? What will we have to show for the scars on the landscape? Coal mining is a sunset industry not way forward. Population growth is happening globally we can be the haven. RC job on fresh/marine/ground water management is substandard - not a good precedent.

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The issues of the discussion document don’t just concern people living on the West Coast. There are many people who have interests in the WC. Of greatest importance is the fact that the WCRC must consider issues of national significance and not just local needs when it comes to its responsibilities under the RMA. The vast majority of land here is owned by all the people of NZ and the WCRC has a duty to stick to the law regarding the sustainable management of it. Have an interest in West Coast’s management of natural resources because of the large areas of land that is of national significance, with unique flora and fauna and incredibly high natural landscape values. The two new regional significant issues in the discussion document are not necessary in the new RPS. As suggested in the discussion document they add no further weight or balance to decisions regarding development or mining because these issues are already covered by the current RPS and District Plans and environmental issues have not prevented developments in the past. If the concern is for the time taken for developers to obtain consents then it is clear to see that those who have good applications that don’t upset our environments or our people can proceed quickly and those that are questionable in their operational cleanliness (water pollution etc) or impact on people and environment are likely to be held up and questioned using due legal process. The purpose of the Resource Management Act (RMA) is “to promote the sustainable management of natural and physical resources.” Mining is not a “sustainable” industry. Once you take the resources out of the ground it does not grow back. Nor can it be sustainably managed, because in the long term it simply runs out. Misleading to imply that future generations will be better off by easy mining now. The discussion document states that “mineral extraction is the key economic driver on the WC”. However it doesn’t provide up to date or reliable references to support the claim that mining a wide range of minerals could bring in potential wealth to communities. Our investigation suggests that these statements are unrealistic.

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Summary of comments made – ‘No’ Submitter No. We support the rewriting of the RPS (second generation RPS) so that it adequately reflects the future for the West Coast. There is a definitive need for bottom line outcomes, standards or measure to make it clear what is to be achieved. Identifying the issues is a good thing. If Council concerned about what to do about the loss of work for the local businesses that support the mining industry then there is no better time than now for them to move to Christchurch and get involved in the rebuild. The suggested approach intends to address the issues of balancing economic and social development against the values of the environment. There is fundamental economic and logical error with this. You can’t balance two things that have completely different sets of values. The discussion document is very generic in its approach and there is a danger there will be no methods of valuing the environments that should be protected or carrying out “balancing” endeavours. It is therefore misleading. Legal action could follow if the WCRC intends to take little or no consideration for the environmental effects on development or mining consents. Historically the WC has depended on large businesses for employment but these tend to have boom and bust cycles, and when they bust the impact on communities is major. New initiatives need to go into attracting alternatives and supporting small and medium size businesses that bringing new young people into the region with families who will stay. Most Coasters have left the region for education and employment elsewhere in the world/NZ outside of the extractive industries. Many of them are now professionals and it is time to attract these Coasters back to bring new global businesses here. Looking ahead there is an opportunity. Trying to keep a dying mining industry afloat for certain people with invested interests is not of benefit to the entire communities on the West Coast. Tackle the hard issues and set bottom lines in the next RPS so we can see what will be protected and what will be developed rather than use general ideas. Indicate how mining coal will be fazed out. How our water ways will be measured for the specific dairying pollutants. Putting development on mining as has been suggested as a long term approach to population and wealth generation is seriously misguided and unsupported by evidence. The golden egg is the protected natural environment and magnificent landscapes that no other region has in such abundance and it has all the evidence of millions of years of evolution. It amazes people the world over and can attract people to live here. It is easy to market as well. The declining demand for coal is evidence that coal mining should not be relied on for economic wealth for our communities. Mining communities across the world are often poorer communities. The new RPS should recognise sustainable communities as promoting economic, environmental and social resilience, not simply population growth and wealth. A diversity of industries is always healthier than relying on one or two large industry. The RPS needs to show more diversity in its approach and a transition away from a carbon based economy. Proposed changes do not address the cause of the economic lull and therefore do not provide the answer to the ‘tough times’ currently facing the WC. Unrealistic to think that changes in the RPS will increase economic activity when the causes of the economic lull are much wider than anything the RPS can address. Current approach to resource management on the WC is already balanced with s5 and the relevant planning documents providing for the positive effects to be balanced against adverse effects when decisions are made on whether activities should proceed. Changes are contrary to s59. Councils focus on mining is misguided. Believe that providing more weight to positive effects is contrary to s59 and unnecessary. Matters raised in Discussion Document do not comply with s59. Current planning documents identify issues in the manner anticipated by s59 and provide strong recognition of the benefits of the use and development of resources – Chapt 16 relates to minerals and contains objectives and policies that recognise the benefits of mineral extraction. Chapter 3 of the Land and Water Plan has a whole chapter dealing with the use and development of the regional land and water resources. Current approach to resource management is already balanced. When making assessments consent authorities and the Court on appeal apply s5 and make an overall broad judgement which involves balancing the positive effects on economic well being with the adverse effects on the environment e.g. West Coast Environment Network Inc v West Coast Regional Council [2013] NZEnvC 45. Given contentious nature of proposals and likelihood of litigation Councils time and resources would be better spent coming up with and promoting new ideas to fuel and economy which are truly sustainable, rather than perpetuating the existing unsustainable boom/bust nature of the current economy. Support the notion of sustainable communities but consider the definition proposed, which focuses solely on population and wealth, is inaccurate and inappropriate. A more appropriate definition for a sustainable community is one that is economically, environmentally and socially healthy and resilient. Resilience is important to a sustainable community. Term sustainable suggests a long term approach to an issue. Mining not a long term approach. Coal mining unsustainable for two key reasons; the

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Summary of comments made – ‘No’ Submitter No. boom/bust nature of the industry, a significant factor in the current economic position of the region; and the burning of coal is one of the biggest contributors to climate change internationally. Nature of the WC biggest treasure have. Understand see growth perspectives for the region in the mineral sector but extracting new minerals on a larger scale will have negative impact on the WC. This circumstance could be the chance to concentrate on ‘managing’ the untouched nature and get welfare for WC people this way. Mineral resources will be exploited in several decades anyway but untouched nature will have an increasing price, a real market value in a world with more and more people who don’t leave any space for plants and animals. Charge tourists access to national parks and restrict access. With new investments from international mining companies in the region lose the biggest treasure have – the nature. Be smart and stay independent, cooperate with partners where you can set the rules. Need to take the initiative in own hands and not those investors from outside. Invest in the education of nature specialists coming from the community. Think social, community, economic and cultural well being for the WC could be achieved by a brave and smart specialisation of the unique environment have.

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We fear that the obvious "pro-mining" stance summarised in this discussion point ignores or does not touch on the negative effects of mining on the social and cultural well being of communities. Recently, we had a gold mine operating over the road and now are an affected party in another resource consent for gold mining. We also made submissions against another gold mining consent that was for 20 years and would have dug over the entire valley we live in. With the proposed change to move all mining consents to the Regional Council and this RPS it is obvious that we will soon be surrounded by goldmines. Having these noisy operations move in next door is a true strain on our well being. The noise is invasive to say the least. It is also stressful to have to continually educate ourselves on all the rules and conditions involved around mining and then also have to act as the policing body for the Councils with its complaint based system. And when complaints are made, such as in the case of noise, monitors do not arrive until days later and then have taken readings mostly in the wrong place, not at our notional boundary as the consent conditions require. There have been subdivisions developed here over recent years. This RPS seems to ignore the well being of anyone not involved in the mining industry. More mining on the West Coast will directly detract from our social and cultural well being and those others who live at Stafford and other affected areas. There is no mention of the negative economic effects of mining. These have to be included in this Policy Statement to come up with the "net benefit" of mining or it is not a true reflection of the economies of mining or its employment effects. It is too focussed on mining as the economic saviour of the West Coast. Tourists do not want to see mining operations as they drive down the road. For example, the area south of Ross is a visual disaster. By the tone of the RPS in terms of tourism, it does not matter too much as "tourism related employment opportunities are not as lucrative as those of the extractive industries." Were all tourism related businesses included in that statement? For example, I know the local Hokitika supermarket attributes up to 10-20% of its turnover to tourists. If they stop coming, how many people lose their jobs? Has the decrease in land value of surrounding land because of nearby mining operations been considered? It has historically been disregarding as an argument in terms of resource consents. If wealth generation and economies are allowed as part of the argument in support of mining applications, land values have to be allowed as part of the arguments against it to make it a true wealth measure. All surrounding properties will lose significant value if more gold mines are developed in the valley. In addition, the economic affect of people moving away from the Coast because of increased mining needs to be taken into consideration too. Besides our neighbour mentioned above, we know of three other parties who would consider moving away, including ourselves. My husband and I both have degrees and the others are highly educated people (2 doctors, a nurse). These are they type of people that the West Coast lacks given the latest reporting. Do we want to drive them away? How is this economic cost included in this RPS? With a large portion of the West Coast GDP already attributed to mining, the West Coast is highly exposed to changes in the gold and coal markets. What happens if the price of gold or coal plummets and we are even more heavily invested in it? When is concentration instead of diversification of assets a good idea? Only when the party can be exposed to very high risk. This is obviously not the case in terms of the West Coast as so many people will be affected, the very thing you are trying to avoid. Negative economic effects of mining needs to be considered here too in order to be a true reflection of wealth generation and employment opportunities.

191

You forget climate change – surely the biggest threat to sustainability and obviously demanding that there is a move away from fossil fuels especially the most polluting of all – coal. Why does a community have to ‘grow’ in order to be sustainable? Surely a community can only be sustainable if it is based on sustainable industry – i.e. not mineral extraction. Dairy farming is potentially a sustainable industry but only as long as it doesn’t destroy our environment – through polluted waterways, nitrate run off or methane. Tourism is also potentially sustainable – as long as it doesn’t destroy what people come to experience – scenery, nature, quiet, biodiversity. Fishing is also potentially sustainable and if caught by local fishermen and processed locally (not by Talleys in Motueka) could support the local economy. That would of course mean not overfishing. Horticulture is another much investigated but not encouraged or recognised industry. Isnt it time the Council recognised that the Coast has benefitted hugely from green initiatives – Okarito, Punakaiki National Park, the end of logging and $120M compensation. So get off the mineral bandwagon. As for ‘balance’ once its gone it is

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Summary of comments made – ‘No’ Submitter No. gone forever. Once a resource is left it is still there until the next ‘balancing act’. Try surveying people why they live on the Coast. You might be surprised and perhaps not want to hear the answer. Promotion of economic development is the job of Development West Coast. The West Coast Regional Council (WCRC) should not be using ratepayers money to pick economic winners. The risk is too high for such a small rating base as the West Coast. Plus if this eats into the capital and investments of the WCRC, future generations will have their opportunities severely diminished. When economic benefits are weighed up against environmental benefits, the environment will always lose out in any analysis that uses a monetary measurement system. This is because economic costs and benefits are easily measured in dollars but environmental costs and benefits are not. The WCRC should stick to their knitting ie avoiding, remedying or mitigating adverse environmental effects. I suggest the WCRC gets the basics of this right before embarking on any “Think Big” schemes. We, in Westland District, have experienced and are paying for the side effects of such local body overconfidence.

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No do not think these should be new significant resource management issues. A sustainable economy is one that is linked to a sustainable environment. Yes there are other issues the Council has not identified. The WCRC has a reputation of having a cavalier attitude to freshwater ecosystems. Both mining and dairy industries continue to degrade the West Coast aquatic environment. To manage these other issues develop more aspirational standards than those suggested in the MfE’s FW NPS backed up by meaningful monitoring and enforcement. For example set ecological flows as non-negotiable baselines when determining water allocations for industry or farming. Recognise the importance of water temperature limits for our cold water ecosystems. Better manage WDC and West Coast meat plants waste water. Actively manage and mitigate the siltation of waterways due to mining and flood protection works. For a more user-friendly RPS enable public participation at consent hearings. Restore the right to appeal to the Environment Court or equivalent body for matters of national importance. Participation in a process without power is not democracy. Environmental concerns are not negative effects. Stimulating growth etc is one consideration of the RMA. Promote sustainable communities by promoting (environmentally) sustainable activities. Population growth will fluctuate, first grow and decline as extractive industries strip the resource (Coal, gold, minerals, forests etc). Corporate/industrial farms have a minimised and transient labour force. There is limited land left that is suitable for development for intensive farming. Static or modest growth seem likely unless a new paradigm is found. State highways and rail provide an adequate base for the regions roads which are adequate for the size and distribution of the population. Upgrading roads to suit heavy trucks – milk tankers, logging trucks, mining equipment etc should have a “user pays” component. It is unrealistic for remote and smaller communities to expect the services of a metropolitan centre. Services should reflect the rating base.

202

Do not support the Regional Council's proposed direction for the West Coast Regional Policy Statement. The changes appear to be largely aimed at reducing resource management requirements for mining activities. In our view, this would result in a larger environmental footprint for existing mining operations while contributing less to the local economy. At the same time, it seems unlikely that the changes would bring new mining operations. Supports vibrant, thriving West Coast communities. Population estimates from Statistics New Zealand suggest that the West Coast is likely to be home to fewer people, and fewer families, in decades to come. This is a concern that faces much of New Zealand. The West Coast needs to both plan for this population shift/decline, and look for ways to counteract it. However, short term gains in population – such as from a three-five year mining operation – are unhelpful, with organizations such as schools and healthcare services having difficulty in responding to rapid change. The Regional Council needs to consider other factors besides mining that may influence future West Coast population projections. An example of this would be improved internet access – what this has done, or could do, for economic and social wellbeing. Many West Coasters chose to live in the region because of their enjoyment of the stunning natural environment – whether this be through fishing or hunting, beach walks, biking or tramping. Lowering environmental standards around mining is likely to endanger this enjoyment locals have of their area. The bar for environmental regulation of mining is already set at a very low level on the West Coast. It is worth noting that there are also considerable issues with compliance of even the rules/consent conditions that are set, with miners regularly letting settling ponds go into creeks/rivers at night, breaching resource consent conditions and even operating without consent. These issues are partly the result of a lack of will to enforce resource consent conditions, although that situation does appear to be improving. However, there is an ongoing lack of monitoring by mining companies or the Regional Council which means that many consent breaches are never reported. Basic automated measurement of water quality and other parameters would make compliance monitoring more objective and more complete. However, the proposed Regional Policy Statement moves in the opposite direction, and sends a signal from the Regional Council that environmental standards will be further lowered. This will significantly worsen these issues. A situation of deteriorating environmental management would be likely to lead to more complaints and even litigation against the Regional Council. On the other hand, better environmental management by mining companies can lead to significantly improved outcomes for both the environment and the local community. Monitoring, water management, revegetation and replanting are not expensive in the scheme of a mine, but are labour intensive and provide high levels of local employment. A shift in attitude by the Regional Council could go a long way to promoting better environmental management and compliance with resource consents by miners. The proposed shift in the policy statement seems to be based on the assumption that lower environmental standards on the West Coast are needed to counteract lower commodity prices. There does not seem to be any evidence to back this up, for example an analysis of the relative contributions

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Summary of comments made – ‘No’ Submitter No. of environmental management costs and commodity price shifts to the financial viability of a project. It seems likely that any changes to environmental management costs would be very small compared with shifts in commodity prices. Other factors such as fuel prices also seem to have an impact on the viability of some mining operations. The proposed changes make no mention of climate change, or the acknowledgement by coal companies themselves that the world is likely to shift away from coal. When considering how to achieve sustainable communities in the long term, the West Coast needs to bear this in mind. Lowering barriers to coal mining will result in future costs for West Coast communities through sea level rise, as the need for flood protection and erosion prevention works increase. Believe that the proposed changes significantly increase environmental damage from existing mining operations, lower local employment through reducing environmental management requirements, and fail to sustain future communities by bringing in new, and often short-term, industrial operations. I think you are going to sell the WC to overseas mining interests. Im against this happening. Most of us live here because we love our wild places – untouched. Youre selling our wild places and dangling promises of sustainable development and up-graded infrastructure in return. We pay rates and taxes for these developments already. 221

Using and developing resources had already been the main, if not only, criterion for the RC, so that there is no balancing by enhancing/pushing this further. There should not be further population growth – this cannot make sustainable communities as our population will ultimately crash. RC has not maintained but reduced environmental standards and further business growth won’t do it either. Big mines don’t do it. Small mines repairing the damage at the same time as they advance is necessary for long term “sustainability”. The Lake Ianthe mines are a disaster. It is unacceptable that every greedy farmer has his own rubbish dump. This is what the RMA was meant to stop. This is not a ‘minor’ effect – change it. 1080 practice is criminally endangering the public.

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Summary of Response – ‘Other’ Summary of comments made – ‘Other’ Submitter No. Does not consider that the West Coast can afford the monetary cost of change. 1 Need to develop a wider range of job opportunities than the main income earners of mineral extraction and dairying. To be resilient. Mineral extraction not sustainable and dairying becoming a monoculture and if/when the bubble deflates there needs to be something else already in place – work in collaboration with DWC, DOC, Councils and other agencies to find solutions beyond total reliance on extracting/using natural resources – apart from tourism (33);

6, 8, 9, 33

Earthquake preparedness 7 Centralised medical services ineffective such as in severe weather or major earthquake. 9 Pest control needs to improve and not rely on 1080. Other pests needing to be put on control list – magpies. 9 Risk of land/soil contamination by genetically engineered organisms and products containing nanoparticles 12 Electromagnetic pollution 12 Prohibition of harvesting of windthrown timber a disgrace. WCRC be proactive and initiate dialogue with DOC to amend legislation; One small way to establish a sustainable commercial business (ideally with a value-added product leaving the WC) – there may be other natural/cultural resources (other than minerals on Private conservation land that could be managed sustainably; wind-blown native trees left to rot is a complete waste. Communities could harvest and create jobs; There is a small but significant wood timber industry in Southland. This raises the prospect for something similar being rekindled on the WC. The focus should be on the industry’s sustainability as opposed to imported timber which is milled unsustainably leaving wildlife with a rapidly-shrinking habitat and a damaged environment. However, forestry work must be safe and with 10 deaths this year around the country, much needs to be done.

14, 33, 46, 175

Initiate discussion with DOC re transfer of land with low conservation value from DOC to another body (to be formed for the purpose of administering developing this land). As long as land is administered by DOC the public’s perception that it is ‘conservation land’ and therefore to be ‘protected at all cost’ is wrong; Have had successive governments crying out for more production, increased GDP while on the other they are rendering access to land with which to achieve this virtually unattainable especially that which is controlled by DOC. The current Government has done nothing to rectify the Labour created situation where Stewardship land is under DOCs control and virtually inaccessible to the average miner due to draconian criteria and unrealistically high access fees and years of costly delays.

14, 56

Proposed transfer of RMA functions (mining) from Westland to WCRC is a great step forward. WDC planning dept has been a major obstruction to the development of Westland industry for too long. 14

Sandflies – great to find a proper deterrent or a vaccine. A must to increase opportunities for foreigners Lack of proper infrastructure for top end tourists (good restaurants, fishing charters, hunting outfitters etc) 31

Rates payable on Conservation ground (over 80% of the West Coast is closed to conservation) Royalties payable on the exports of Coast minerals In cases where conservationist objects to the use of our extractive industry, and win their case, rates thereafter are paid on said ground in lieu of.

35

Used plastic and glass bottles are becoming a costly issue for al Councils to recycle. Debate on asking government to charge a recycling fee of say 3 cents per item on all glass and plastic vessels sold in NZ. This money to be divided up between all Councils operating recycling depots. (this in turn would take the burden of a rubbish rate to a user pays principal.

35

Councils to support a plan to educate all WC tourism ventures on building websites and social networking to convince more people to visit region and stay another day; further promotion of tourism which has most amount of people employed on WC. 35, 41

Current tourism industry geared for summer. Has rich historic heritage aim sights on promoting off season deals. 35 Developing industries utilising resources to ensure that local people are employed for local business e.g. sphagnum moss shipped out as a raw product. Should be manufactured on WC. Natural product can then be exported as a finished product rather a precious resource at no real capital gain. Manufacturing small kitset homes built on WC utilising local labour to be shipped off to places where there are housing shortages.

41

Currently abusing wildlife by poisoning it with hazardous toxins. Industry employs a lot of people, costs an excessive amount and is not beneficial to the environment. 41

36

Summary of comments made – ‘Other’ Submitter No. Advocate for ground control of pests using same labour force. Forest management can employ a lot of people and be structured to be environmentally safe. Ask the ‘rural’ Westland ratepayers to contribute to the Seawall – we’d be happy to pay to protect the business infrastructure – or to the plantings landscapes – ‘Donate a tree’. Hokitika Lions is continuing with the ‘Plant a tree’ international Lions project – would we be able to help with landscaping? 63

Should include precautionary principle concerning GE crops, silviculture and stock in the absence of indemnification for conventional growers whose livelihood may be destroyed if their product becomes destroyed by GE material. 64

Introduce a West Coast certification system for its products – add value. IT industry to develop here because of agreeable lifestyle, affordable land and housing and a reasonable infrastructure. The communications infrastructure does need upgrading but RPS should encourage non-extractive industries. Tertiary and vocational education and training – become a centre for environmental and ecological studies for domestic and international students. Native timber plantation forestry as rimu and totara grow faster on the WC and a highly valued in building and furniture.

64

Recognition of the need for people and communities to be able to provide for their social, economic, and cultural well-being and for their health and safety - seek that the RPS outlines in detail how farming, mining, built infrastructure and other resource use and development enables people and communities to provide for their social, economic, and cultural well-being and for their health and safety thereby supporting councils in appropriately managing the use, development, and protection of natural and physical resources. The advantage of including this information in the RPS is that not only will it be conveniently at hand, but it will also have statutory weight in that associated objectives and policies must be given effect to within regional and district plans. Pastoral farming and in particular dairy farming makes a substantial contribution to the West Coast economy with 147,660 cows milked across 68,399 hectares. This activity makes a substantial contribution to the local economy. For example the model Southland dairy model farm, a 609 cow farm, showed farm working expenses for the 2011/2012 year of $885,634, or $1454 per cow. Sheep and beef farming also makes an important contribution to the economy with the national sheep and beef model showing budgeted farm working expenses of $349 per annum in the 2012/13 year. Most of these expenses are sourced locally and relate to labour, contractor and professional fees, bought in feed, and other local services. Emphasise that unlike other industries which have a degree of flexibility in operations, dairy farming expenses are relatively stable from year to year; the cows still need to be milked, grazing fees paid, cow health expenses paid, regardless of market or climatic conditions. Dairy farming thus imparts a degree of economic stability to the region that other regions can-not. Added to the benefits generated on-farm, almost all milk produced on West Coast Farms is processed locally at Westland Milk products, a major employer in the region. In other words, reducing opportunities for farm production has a directly proportional effect on jobs and opportunities for enterprising West Coasters.

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The ethic of stewardship of land occupiers and industry and community groups Section 7(aa) of the Resource Management Act (1991) requires the Council, in the making of decisions and undertaking of its duties to have particular regard to the ethic of stewardship. Federated Farmers seeks the inclusion of appropriate policies and methods (in particular in the indigenous biodiversity and water quality chapters) that outline how the requirements of section 7aa are to be applied in the West Coast region. The view of Federated Farmers is that the ethic of stewardship is fundamental to the shift in environmental consciousness that has been occurring in the rural sector for the past generation. It is reflected in increasing acceptance of both changing regulations and of efforts made to take care of the environment because it makes sense or is the right thing to do. The importance of stewardship has already been illustrated in the Lake Brunner catchment where voluntary methods and facilitating behavioral change have proven very valuable in managing nutrient inputs to the lake. Federated Farmers seeks the inclusion of policies and methods that: Recognise the ethic of stewardship and its applicability in achieving the purpose of legislation, and better environmental outcomes at appropriate places in the RPS. Support the development of regional and district plans that recognise the ethic of stewardship and not disadvantage those who have undertaken stewardship efforts

(relative to those who have chosen not to) unless there is no other practicable option.

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Water quality Federated Farmers sees the water quality chapter as a key priority because it provides essential strategic direction for the implementation of the National Policy Statement for Freshwater Management (the NPSFWM) on the West Coast. Seek that the RPS promotes a principled approach to water management, with substantial guidance in Policy as to how the NPSFWM is to be implemented. Does not see it as appropriate that current water quality provisions are rolled over effectively leading to an unguided implementation of the NPSFWM. The manner in which the NPSFWM is implemented will have huge implications for farm business risk. If it is done well business and the environment will both remain healthy and be enhanced over time. If it is not, businesses will be subject to a high level of uncertainty and additional cost, most likely (at least on the West Coast) for little actual environmental gain. Of particular relevance are NPSFWM policies A1 (which requires the setting of water quality limits) and A2 (which

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Summary of comments made – ‘Other’ Submitter No. requires that the council specify targets and implement methods. In some places a focused approach may be required to meet water quality limits at the local level. Seek that the RPS supports implementation of the NPSFWM through policy and methods by: Adopting the core principle of working back from where we want to be at a specific time in the future (rather than attempting to freeze development or apply

prescriptive interventions to farm systems); Promoting the use of formal community-led processes, ideally with a sub-committee of local community members providing recommendations to the Council; Articulating a preference for non-regulatory methods to meet Policy A2 targets, with regulatory methods only adopted where there is evidence that they are the most

efficient and effective method to do so. Promoting the section 7(aa) ethic of stewardship and clarifying that this means individuals or organisations going beyond what they are specifically required to do to

protect the environment. It will be appropriate to include explanatory comment to describe the role of the ethic of stewardship in the rural environment and why it is important that it be recognised and provided for.

Promotion of good practice is important across the region, even in catchments where water quality limits are met and/or unlikely to be exceeded in future. Accordingly Federated Farmers seeks that the RPS guide the promotion of good practice, ideally in partnership with community or industry groups and NGOs active in the region. Practices that should be specifically promoted on farm include: Retention and restoration of riparian buffer zones; Careful application of the correct types and quantity of fertiliser and agrichemicals; Application of farm dairy effluent to land at appropriate rates and depth in light of weather and soil conditions; Careful stock management to reduce soil damage and accelerated erosion, and effects of stock entry to water. New Zealand Coastal Policy Statement The New Zealand Coastal Policy Statement – 2010 (NZCPS) includes policies to guide the management of the coastal environment, including stringent requirements for the management of the coastal environment (which has now been interpreted as extending some distance inland). Very concerned about the policies of NZCPS particularly when read together. Policies 11, 13, and 15 of the NZCPS require absolute levels of protection for natural resources identified as ‘significant’ or ‘outstanding’, and very high levels of protection for other natural resources in the coastal environment. These policies combine with Policy 1 (which provides the basis of the definition of the extent of the coastal environment) and Policy 3 (which requires a precautionary approach) to create an outcome that does not in our view provide for management of natural resources in a way or at a rate that enables people and communities to provide for their social, economic, and cultural well-being and for their health and safety. Interpretation of Policy 15 (outstanding natural features or outstanding natural landscapes) in the Courts has done little to allay concerns and it is expected that the similarly stringent Policies 11 and 13, which relate to indigenous biodiversity and natural character will face the same difficulties. Given the potential problems, it is essential that the RPS provides suitable guidance for implementation of the NZCPS in a manner that reflects the particular challenges, pressures, drivers and preferences of the West Coast. At a minimum the RPS should include policies and methods for coastal areas that: Recognise the functional need for human activities to take place in the coastal environment. Recognise the role of farming in sustaining the indigenous biodiversity, natural character and landscape values in the coastal environment and the ethic of stewardship

that is so important in sustaining these values. Enable activities that do not have significant adverse effects on areas of outstanding natural landscape, outstanding natural character and notable indigenous

biodiversity in the coastal environment, including fences, changes to cropping regimes, stock water systems, minor vegetation clearance, shelter belts, and simple farm structures.

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Indigenous biodiversity The indigenous biodiversity chapter of the RPS is a priority because there is as yet no national guidance on the topic and there is a significant amount of indigenous on private land on the West Coast. It is appropriate that the current RPS is updated to reflect changing understandings of effective and efficient methods to protect and if appropriate, enhance biodiversity on private land. Policies that might assist enhanced outcomes for biodiversity include: Promote the maintenance and enhancement of biodiversity throughout the region;

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Summary of comments made – ‘Other’ Submitter No. Have particular regard to the ethic of stewardship of land occupiers in maintaining and enhancing biodiversity, including the appropriate management of grazing and

pest management activities. To achieve good outcomes for biodiversity, the RPS should include methods to: Promote the use of QEII covenants or other voluntary methods as the preferred approach to identify and protect areas of high biodiversity. Require that compulsory identification is only to occur when absolutely necessary and having particular regard to the ethic of stewardship as is applies to current and

future actions by occupiers or private land. Require that wherever possible, the identification of ecologically significant areas is undertaken in partnership with the people who have cared for and sustained them. Prepare a Biodiversity Strategy to guide the biodiversity actions of the Council and identify programmes and actions for indigenous biodiversity on land, freshwater

biodiversity and coastal and marine biodiversity. Require that WCRC work with district councils, land occupiers, and community groups, to achieve integrated and cost-effective maintenance and enhancement of

indigenous biodiversity including pest management activities. Prepare and implement pest management strategies or undertake other actions under the Biosecurity Act 1993 to minimise impacts on indigenous biodiversity values. Prepare practice notes and other educational material to assist land occupiers in their efforts to care for indigenous biodiversity. Federated Farmers also seeks that the revised RPS includes policies to foster the ethic of stewardship to achieve enhanced outcomes for biodiversity on private land. Stewardship is important because attention and care, beyond what can be reasonably or legally expected of all land occupiers and councils is often required to achieve long-term positive outcomes for biodiversity and overall enhancement of biodiversity at the regional level. It is therefore incredibly important that the RPS and district plans subservient to it avoid to the greatest extent possible a management framework that punishes those who exercise stewardship while rewarding those who do not. Outstanding natural features and outstanding natural landscapes Seek a balanced approach to the management of outstanding natural features and outstanding natural landscapes (ONFLs). It is appropriate for ONFLs and other natural features important to the community to be identified and protected. We also support guidance as to what might be appropriate, including the benefits derived from the use and development at the local, regional and national level, and seek recognition of the value of specific types of use or development in key locations. Seek to avoid a situation where the RPS intervenes in the practice of landscape assessment by imposing assessment criteria, or requires the identification of visual amenity landscapes. Assessment criteria are likely to be subject to change as professional practice evolves or in response to recommendations from the community. The concept of visual amenity landscapes (VALs) has been found to be generally unhelpful because amenity, or those things that make the environment pleasant, is important in all places, including some of the most highly modified areas in the region. Accordingly Federated Farmers seeks that there is no reference to VALs in the RPS.

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Federated Farmers seeks a balanced approach to natural hazards that recognises the role of councils in ensuring financial (and other) risks to the community are minimised, without unduly interfering in the day to day activities of people. To achieve this Federated Farmers seeks policies and methods that: Recognise the specific need for flood protection works or works in beds of lakes and rivers to prevent damage to land and infrastructure and in particular loss of ability

to make reasonable use of land. Recognise the resilience of farming activities to natural hazards with simple farm structures (hay sheds, storage bins) exempt from natural hazards rules in district plans

that exclude structures. Require all councils to work together to maintain a civil defence and emergency management response capability.

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It is important that access does not impinge on production, create safety problems for people, facilitate crime, or create an adverse effect on the environment. In particular access should be able to be blocked where necessary to safeguard rare and endangered species, or prevent crime or harm to people or stock. 70

In relation to waste and hazardous substances, Federated Farmers seeks policies and methods that: Promote awareness of waste minimisation and responsible disposal of waste. Enable continued on-farm disposal of solid waste, including fallen stock. Enable a practical but effective approach to safe storage, use, and disposal of hazardous substances.

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Federated Farmers seeks an approach to electricity generation that specifically encourages non-consumptive use of water resources and a reasonable balance between meeting electricity needs and provision for white water activities. 70

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Summary of comments made – ‘Other’ Submitter No. The key areas consider need referencing within the RPS and mineral chapter are as follows: Mineral resources, including aggregate, should be recognised as a regionally significant resource with the WC Region. Their importance should be reflected in there being a separate chapter within the proposed RPS specifically on mineral resources. We note that under discussion point 3

minerals have a specific reference. Land development and new regional and district planning provisions should not restrict future access to mineral resources within the WC Region. Land development must not result in reverse sensitivity effects which could constrain existing or future aggregate and mineral extraction sites. The RPS should provide for the protection of mineral resources with the West Coast including the extraction, processing and handling of these resources.

79

Recognising and providing for aggregate production The references to Network Utilities and Network Utility Operators in Chapt 15 are acknowledged as is the recognition of the importance of network utilities and transport systems. In addition support retention of Policy 9.4 (“Enable the continued development, use and maintenance of network utilities in or near habitats and landscapes”). Consider that the RPS overlooks the broader significance of aggregate production for the creation and maintenance of sustainable communities. Seek that it is amended to explicitly recognise the importance of aggregate extraction and production for regionally significant infrastructure construction, operation, maintenance ad upgrading and for broader economic activity across the region. Moreover, the activities associated with aggregate production should be provided for as an integral part of the activity of winning and processing aggregates; such activities typically include crushing, washing and stockpiling aggregates. Suggested wording could include the following: Objective 16.X Extraction of aggregates, and associated processing, is recognised and provided for as an important activity for the development and maintenance of sustainable communities. Policy 16.X Recognise the value of gravel extraction and aggregate production for regionally significant infrastructure, and for economic activity, and enable the production of aggregates where adverse environmental effects are adequately managed. Policy 16.Y Permit aggregate extraction while ensuring that the activity in undertaken in a way or at a rate that avoids, remedies or mitigates adverse effects on induced erosion, water quality, significant indigenous biodiversity, significant wildlife habitat, sites of cultural significance to Ngai Tahu, or access to areas with high recreational values. A similar suite of provisions, or cross referencing, could occur within Chapt 15 and Chapt 9 to ensure that these matters are integrated through the RPS. Further, it is requested that recognition is afforded to both land-based and river or coast-based gravel extraction activities (and the complementary role that river-based extraction can afford to flood mitigation); to this end, an equivalent amendment may be appropriate in Chapters 7 (Soils and Rivers), 10 (The Coastal Environment) and 11 9Natural Hazards). It is noted that currently no specific recognition is afforded to the activity of gravel extraction in these Chapters.

80

Cleanfill Activities The RPS includes provisions dealing with Solid and Hazardous Waste in Chapt 12. Whilst the existing Objs and Pols are considered relevant, identify that the matter of cleanfill management is omitted from the more specific suite of provisions dealing with such matters as hazardous wastes, municipal solid wastes, human and stock effluent. This omission means that cleanfill operations fail to be considered under the broader and generic policies dealing with waste disposal. Cleanfill is an activity distinctly different from solid waste disposal and the management of effluents or hazardous substances. Can be used to rehabilitate degraded sites and can increase the productive potential of other areas. Specific recognition to be given to the management, and provision made for the disposal, of inert cleanfill materials. Such an approach should align with the MfE Cleanfill Guidelines. Suggested wording follows: Objective 12.Y The disposal of cleanfill materials is provided for to enable the efficient management of this waste stream. Policy 12.Y Enable the establishment and use of appropriate cleanfill facilities throughout the region.

80

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Summary of comments made – ‘Other’ Submitter No. A definition for cleanfill should be incorporate into the RPS. Be the same as the MfE Guidelines. Integration of planning documents Chapt 4 of the RPS addresses Cross Boundary issues and integrated management. Strongly endorse this approach. District and regional function for managing natural resources under the RMA often overlap, particularly in relation to the effects of land uses, natural hazards and similar activities. Where regulatory overlaps occur, the compliance burden and uncertainty created by the need to obtain multiple resource consents from more than one agency substantially increases costs without, necessarily, increasing value or providing a more sustainable outcome from an effects perspective. Where process streamlining can be achieved, and duplication avoided, this will significantly improve the cost-effectiveness and certainty of resource management. It is noted that Method 4.4 seeks to “Combine with the appropriate restrict and regional councils in jointly processing resource consent applications that cross administrative boundaries”. This Method is supported as both efficient and appropriate. Seek an additional Method in Chapt 4 to provide for an advocacy function for the RC that seeks to achieve the efficient integration of functions in statutory planning documents to avoid duplication of controls and to ensure complementary approaches of regulatory agencies. Would provide scope for Council to more closely align planning initiatives with TA to minimise duplication, and allows that matters such as transfer of powers (s33 RMA) or delegation of functions (s34 RMA) may be considered to streamline regulatory controls and processes.

80

It is hard to believe that we have failed to progress our indigenous forest industry in this age of environmental consciousness. Could not invent a more environmentally sound system than one whose consumer products are non-toxic, biodegradable, recyclable, energy efficient and come from a natural renewable resource that cools and cleans the air from carbon dioxide, produces oxygen, stores clean water and provides both wildlife habitat and recreational enjoyment. To rural people in Westland, it is ironic that those from urbanised areas, living the least sustainable lifestyles, demand that we who live in a largely forested land should not have access to any public indigenous forest for sustainable timber production. How many kiwis know that in 1990 UNESCO advised us that in World Heritage Parks, allowable activities include making roads, sustainable logging and tourism. With DOCs current funding difficulties, is the public attitude any different? As a licensed rimu sawmiller, my access is limited to perhaps 1% of the 10% approx. of land that is private land. DoC pay no rates. DoCs pest control funding could come from the forest itself. We export our children. We have the equipment and helicopters so there is no need for foreign investment and we need the jobs. 1ton/hectare/year of rimu both grows and falls over on the millions of hectares of the DoC estate on an acidic soil that would not grow one sheep. A mature rimu tree can realise $10k in wet sawn timber - double if processed.

84

RPS should promote truly sustainable industries and businesses that will take the WC forward not just for the next 20-30 years but into the next century and beyond. Approach requires courage and a long-term vision for a truly sustainable community that can live without negatively impacting on and exploiting our fragile environment 86

Currently Bathurst has offered a small respite but need to invest in other ways to sustain the current population. Live in such a beautiful part of NZ which could become more accessible to the tourist trade. A walkway up the Brittanica track to Mt Rochfort with its wonderful coastal views then down the Denniston track. Maybe a mini tramway using the Denniston incline. There are numerous tracts of land here suitable for agriculture. It has been found that avocado and persimmons grown well here as do potatoes and many other crops which are always expensive on the WC. How about encouraging people with land to run alpacas for the valuable wool. Tourism brings people who bring trade to our businesses.

89

The review process should include the objective of restructuring and simplifying the current RPS to make it a more accessible and readable document. Range and complexity of subjects that need to be covered in the document are acknowledged but other Councils have been able to produce documents which are much briefer e.g. Otago 22 pages (double column) compared to 122 pgs of current WC RPS. Do not need to include the introductory chapter with commentary on legal requirements. Discussion Document does not list all 13 issues of current RPS as still being regionally significant. Need to clarify status of all issues and the intention to have these included or otherwise in the revised RPS. Discussion document lists two new issues – phrases are generic and do not describe in sufficient detail what the issue is. Maintain that no lesser status should be applied to tourism and the hospitality sector than to the mining or farming sectors. In terms of sustainability tourism is likely to outlast both mining with less negative impact on the environment. Reword the new issues identified in the discussion document to clarify their meaning (with sufficient text to enable performance monitoring) and ensure that equal status on specific industry commentary is given to the tourism and hospitality sector.

94

Promotion and encouragement of West Coast arts and crafts – natural resources – stone inclusive of semi-precious such as pounamu, serpentine, limestone, clay etc. Support an artist workshop so artists not working in isolation also means a hub for sales and tourism potential e.g. old yards/buildings at the Grey Wharf. Wonderful talent that needs expanding.

100

In regards to cattle being moved on public roads, particularly large herds being shifted to and from pasture, I feel farmers should be compelled to install an underpass or 110

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Summary of comments made – ‘Other’ Submitter No. alternatively have to hose the road. Thick cattle excrement is most annoying and hard to avoid and does little to improve our image to visitors. I think it would be beneficial if there was a way that the Regional Policy Review Statement allowed for the opportunity to work on some areas of the the Grey District Plan to see if there are any areas which leniency can be exercised for the sake of economic growth within our community. For example opening up some rural areas to be residential would be extremely beneficial for attracting developers as well as opening up a more idealistic attractive place to live to bring more people into the area. To avoid losing much of our rural look which is also very important, perhaps a rule could be in place so that only rural areas which are located within very close proximity to already established residential areas can be developed at first. Perhaps the new rule could apply to blocks of land that are within a 2 km radius of residential areas at present. Without control to township growth this would allow for anybody to subdivide land as of right which would constitute a potential waste of production of farming/commercial development land. Further to this Council resources would be stretched. For example: Residential extension could be done in such a manner that Council could reserve residential status to the fringes of existing townships.

113

Chapter 3 – There is no indication relating to the frequency of the use of economic instruments. Without this information the ‘tool’ is valueless. Chapter 4 – There are no details of cross-boundary integration of policy or development. Chapter 8 – This Chapter fails to identify the significant impacts of dairy, hydro-generation, removal of rocks from rivers and the significance of riparian strips to water management. Chapter 10 – There is no indication of the development of Marine Reserves and their significance to the coastal environment. Similarly there is no mention relating to the impacts of poor management on the marine mammals and sea birds, especially from industrial discharges. There are no policy statements relating to coastal wetland management. Chapter 11 – There should be specific policy regarding building and other activities close to the Alpine Fault. For natural hazards management “Encourage” should be replaced with “Require”. Chapter 12 – There are no indications of an audit of solid and hazardous waste management being undertaken despite the number of industries with high waste potential. Chapter 13 – The WC has good potential for solar energy generation, which would make a significant contribution to providing sustainable air quality management. Chapter 14 – Although coal can meet some energy requirements it is not the solution to solving energy issues, and the WC and the WCRC should consider alternative energy sources which are both sustainable and less destructive to the environment generally. Internationally there is a downward trend in the use of coal. Chapter 15 – Although mining has been a historic mainstay of the WC it is now time to investigate sustainable alternatives to provide long term employment. There is no mention in this chapter of environmental protection relating to mining or the use on non-notifiable consents often given to mining industries.

118

When RC allocated whitebait stands throughout the region, Council did not take into account Kai Tahu customary right in the allocation of stands on Crown rivers. Council needs to address this issue created by an iniquitous act done by a past Council. As the native reserves that evolved out of the 1860 Arahura Deed of Purchase were excluded from the purchase , then the minerals, above and below the surface of the reserves are Kai Tahu owned. Some of the reserves are managed by Mawhera Incorporation and some by Trusts. Statement of Native Reserve Mineral ownership should be a statement in the RPS.

124

Important that Council acknowledges that planning around transitioning away from the boom-bust cycle of mining is a necessary and intelligent step. This transition should be something intelligently and astutely prepared for, not something that our region suddenly finds itself in a panic over. I am not envisaging this move away from coal mining happening tomorrow, or even in 5 years’ time, but anyone with any knowledge about sustaining environmental systems (thus long term regional economic health), would agree that now is the time to discuss and incorporate this into our region’s long-term vision. To ignore the need would be unreasonable and foolish. In the discussion document, Council does not touch upon the real threat to our ‘sustainable communities’ the effects of climate change pose. Although Council may argue it is not a matter relevant to the RMA, it is a fact that the burning of coal is one of the biggest contributors to global climate change. Global encompasses regional, and with our many coastal settlements we are likely to face threats such as increased frequency and amplitude of flooding events and coastal erosion. This is clearly not conducive to sustainable communities. It is quite evident that coal mining cannot sustain communities in the long term, and the dramatic fluctuation in population on the West Coast over the last 150 years demonstrates this. The forecasted decline in population on the West Coast cannot be remedied by narrowly continuing with this boom-bust economic model.

125

My recommendation is that the WCRC Regional Policy Statement continues to give priority to protecting the environment as the state of the environment is integrally linked to people’s wellbeing, both economic and socio-cultural. Without a flourishing and sustainable environment there is no use debating our economic, social and cultural well-being. Additionally the WCRC, through its Regional Policy Statement, could lead the West Coast in investigating and promoting a more diverse economic base here on the

129

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Summary of comments made – ‘Other’ Submitter No. Coast, one that doesn’t rely on depleting and/or destroying our natural ecosystems. Start locally, don’t just promote ideas make them happen and help the locals ideas happen too. Plenty of locals have ideas to start up own business and guidance for these people would be beneficial. Local creativity should be encouraged and supported to showcase the WCs distinct culture. Provide business support to stop closures. Minerals biggest asset but other industries need to be fostered. Give young people a reason to stay on the WC to boost the population.

136

Note that the CDEM Act and the RMA have similar purpose statements. Both aim to improve and promote sustainable management of [either hazards or natural and physical resources] … to enable people and communities [generally] to provide for their social, economic, and cultural well-being and for their health and safety. We extend this now to talk of community resilience - i.e. the ability to absorb and recover from emergency events. Clearly part of being able to do so involves the risks being managed to 'acceptable' levels, and this links to risk reduction through management of natural hazards under the RMA. It also links to the goal of communities having robust (strong and diversified) economies, social cohesion etc. As such, that the revised RPS aims to enable people to provide for their social and economic needs would be fine in our terms. This also fits with the RMA reforms that the Government has signalled. They are mainly aimed at reducing uncertainty for users, and processing times and costs, so individuals and communities can 'get on with living'. The thing that the Regional Council will need to be clear about, in engaging its communities on this, is expectations as to the line between the RPS staying within the RMA's purpose (of regional polices that promote sustainable management that enable economic growth), and not that these policies actively promote development per se. In other words, the RMA is to manage natural and physical resource to sustain the potential of natural and physical resources (excluding minerals) to: meet the reasonably foreseeable needs of future generations; and safeguarding the life-supporting capacity of air, water, soil, and ecosystems; and avoiding, remedying, or mitigating any adverse effects of activities on the environment. This above alone is what is to be 'improved and promoted' and not achieving specific economic aims that, instead, are only enabled to occur if they do not undermine this management (as also are conservation aims for the protection of resources where appropriate). This is a subtle and yet important distinction in that policies should be neutral in terms of not 'picking winners' or having an inherent bias towards either the use or protection beyond achieving this purpose. We have stressed here the 'engaging of communities' and managing their expectations and I'm sure that council officers understand this distinction. Also the ultimate test will be the Courts if any new policies are challenged during the formal process. Having said all the above, when a draft RPS is being developed, perhaps ahead of formal consultation, I suggest you engage on specific natural hazard policy provisions if you can. The current ones could be improved I feel. For example, look at Waikato Regional Council's proposed RPS.

145

There is huge potential for aqua culture and this needs to be driven by Council. Rewards are huge with very little land and water use. 147 Happy to see the focus of this: “Using and developing our resources positively” is essential. For too long our resources “forests, flora, fauna, walkways, coastline, mountains rivers, gorges & lakes” have been over regulated. Nearly every sign has a “NO” on it. No Access, dogs, bikes, vehicles, swimming, shooting, fishing, camping. It about time we focused on becoming user friendly community and start by identifying what our resources are, who wants to use them & how can we make them accessible and more attractive to them. Then look at how to invest in our resources to enhance them. EG Tree top walkway, Denniston Mine, Wilderness Trail, Glacier tours, Oceana Gold mine tours are examples of enhancing natural resources and adding value to the West Coast experience. We could be a fishing Mecca, if people were encouraged to fish or told where they could fish for whitebait, trout, kawhai, snapper, eels, surf casting, big game fishing we got it all here. Sustainable communities. Lets start with a sustainable unified council for the whole West Coast. Tourists don’t care whether they’re in Grey, Westland, Buller. They’re on the West Coast and until we as locals accept that fact, then the WC will never be working to full sustainability. We need more people living on the West Coast too spread the infrastructure costs imposed by our 4 councils. There is an abundance of land on the West Coast, why not develop it and offer free land for first home buyers to build on, which would encourage young locals and new Zealanders to consider us as an option. Southland did it with free Polytech fees many years ago and turned their young population decline around by thinking outside the square. Disestablish Development West Coast, set up a Unified Council as a board vested to run the West Coast. Give them, access to the DWC funds and resident West Coasters become the shareholders, who the Board are accountable to. A charter would exist to ensure a community well being component sat alongside financial accountability and long term planning. WC Regional Council is surplus to requirements in its current form.

157

Consider that it is important that any new resource use and development policy framework ensures that future access to mineral, aggregate and coal resources in the Region is safeguarded in that: 162

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Summary of comments made – ‘Other’ Submitter No. The mineral, aggregate and coal resources are recognized as Regionally significant resources The management of natural resources and new Regional and District Planning provisions do not restrict future access to mineral, aggregate and coal resources The management of natural resources and promotion of community sustainability do not result in reverse sensitivity effects which could constrain the development of

existing and future mineral, aggregate and coal extraction sites. Policies in relation to pest control in the current RPS are primarily focused on the adverse ecological and environmental effects of pests. Adverse economic effects of pests are noted but only in the form of passing references to the provisions of the Biosecurity Act 1993 and Councils ability to prepare pest management strategies (now named pest management plans) under that Act. Given the economic importance of cattle and deer farming in the region, the significant threat posed to these industries by possum-vectored bovine TB, the consequent need for continued large scale possum control under the NPMP, and Councils role in supporting the National Pest Management Plan, then we submit that the RPS should recognise the economic importance of animal pest problems and the need for effective pest control for economic reasons. Specifically, the existing policy 9.6 could be amended as follows: Policy 9.6 Promote the containment and reduction of noxious and potentially noxious pests and weeds in situations where they cause, or are likely to cause, adverse effects, including: a) Destruction or degradation of indigenous flora or fauna; b) Reduction in biodiversity; c) Adverse economic effects, particularly in relation to primary production; d) Land instability; e) Spread within waterways. Such an amendment would provide WCRC with a specific regional policy basis for its continued engagement with, and support for, NPMP possum control programmes in the WC region which contribute significantly to the value of the region’s dairy, beef and farming industries.

163

Public transport needs to be addressed throughout the WC. 170 Somebody make the township of Reefton observe only one regional anniversary day. Either Buller or Reefton but not both. 172 A major disappointment has been the abandonment of hydro-electric generation. An effort should be made to re-energise those projects. Relatively cheap power would be an incentive to industries to relocate to the WC. Cheaper power would also assist the provinces residents. Tourism seems focussed only on the natural, but there are other possibilities. Mining is one, for example, the possibility of reopening or constructing a gold mine to show what working underground was like could go with the Blacks Point stamp battery. A tour of a coal mine is another possibility, as is a gold dredge. These opportunities would need to be advertised widely, but are significant in England and Wales. An example of historic mining tourism is at Denniston.

175

Issues to consider - climate change. Sea level and erosion have always been issues for the WC and now it is time to consider this for the future. An example within our region is the Glaciers melting at an alarming rate, indicating impacts of global warming from greenhouse gas emissions mainly caused from burning coal. We must take responsibility for cause and effect otherwise unsustainable coal mining will cause unsustainable tourism. We need to realise a new future and open ideas for new industries and initiatives that will take us forward and at the same time protect the natural environment. A possibility not mentioned is the growth industry of internet business. The West Coast could be hugely attractive to people who want a lifestyle change. To bring their businesses here so the WC is marketed for what it is, an amazing outdoor environment. This could attract the type of people needed, young people who want a healthy, outdoors lifestyles.

180

Suggest the following issues, objectives and policies for sustainable communities: Issues WC communities have not proved resilient to economic fluctuations which have resulted in adverse effects on social wellbeing from a loss of employment opportunities

and population decline. The WC economy is over reliant on a small number of industries which are prone to boom/bust cycles. The WC has failed to maximise the economic benefits and employment opportunities associated with its natural beauty.

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Summary of comments made – ‘Other’ Submitter No. Objectives To create communities that are economically, environmentally and socially healthy and resilient for future generations. To create a sustainable economy on the WC that is both diverse and innovative. To maximise the economic benefits and employment opportunities associated with the natural beauty of the WC. Policies To recognise the important contribution that the natural beauty of the WC makes towards its economic and social well being. To enable new and innovative employment opportunities which provide economic diversity and resilience To promote the WC as a desirable place to establish innovative and sustainable businesses. Proposed changes should promote communities that are economically, environmentally and socially healthy and resilient. Recommend that: a) Agree to high-priority treatment of minerals prospecting, exploration and mining in the RPS, as a strategic sector for the WC. b) Note support of the proposals to highlight the positive effects of development, and of the need to encourage developers into the WC. c) Agree to provide direction for a vales, benefits and effects-based, and case-by-case approach to considering all minerals exploration and mining proposals in the RPS, in

recognition of the nature of minerals activities. d) Agree to factor into all landuse decisions an assessment of minerals prospectivity at those places. e) Note that the dynamism observed in the mining industry is inherent to that industry, and agree that the way to manage the risks in this area is to encourage more

minerals investment on the WC; f) Agree on the need to reduce unnecessary and burdensome bureaucratic red tape on applicants for regulatory approvals; and g) In relation to Rec (f), agree to provide direction to the Council in the RPS to actively improve coordination with other regulatory agencies, and to facilitate alignment of

regulatory processes, where this would be useful.

192

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Summary of comments made – ‘Other’ Submitter No. The Review affords an opportunity to revisit existing objectives and policies in the operative RPS. Since the RPS became operative in March 2000, several changes to the national planning framework have been made. For example, the National Policy Statement on Electricity Transmission (NPSET) was gazetted 13 March 2008, and the RPS is yet to give effect to that document. While the RPS recognises regionally significant infrastructure, there is an opportunity through the review to better align the RPS (and specifically the provisions relating to the regional significance of the National Grid) with the NPSET. The NPSET establishes national policy direction to recognise the benefits of transmission. It recognises the importance of security of supply for the wellbeing of New Zealand and New Zealanders, and makes it explicit that electricity transmission is a matter of national significance under the RMA in order to meet the electricity needs of present and future generations of New Zealanders. The NPSET provides guidance to local government about the management and future planning of the National Grid, in terms of: recognising the national benefits of transmission; managing the environmental effects of transmission; managing the adverse effects of third parties on the transmission network; and long term strategic planning for transmission assets. Reliable and constant energy supply is critical to sustaining the regional economy, population growth and way of life for West Coasters, all of which are issues addressed in the discussion document. These key drivers increase demand on electricity transmission, and in meeting this demand, Transpower also faces an increasing number of constraints. The National Grid is not, on the whole, protected by designations or easements. The Electricity Act 1992 provides Transpower with statutory rights to the continued ownership and operation of existing assets built prior to 1 January 1988, including access rights to inspect, operate and maintain the lines. However, the Grid is regularly vulnerable to the adverse effects of land use change and encroaching activities by other entities. As the owner and operator of the National Grid, Transpower faces a number of issues that are relevant to the review of the RPS including: managing the National Grid transmission lines, particularly within natural areas and the beds/margins of lakes and rivers; managing adverse effects of the National Grid; recognising and protecting National Grid transmission line corridors; enabling the maintenance of the existing National Grid transmission lines; managing adverse effects of others’ activities on the National Grid; ensuring security of supply and recognition of the benefits of the National Grid; enabling the establishment of new lines as required to meet increased demand and security requirements; management of hazardous substances and potentially contaminated land; and achieving consistency in all these matters, across local government boundaries.

201

At this stage, and given the scope of the Discussion Document, it is appropriate to record that there are several other key issues to Trustpower in the current RPS, in particular water quantity, biodiversity and protection of habitats and landscapes, that Trustpower would like to comment on. Should Council wish further explanation from Trustpower around any of these issues in advance of notification of the draft RPS, we would be most happy to provide this.

203

Do some rat control in all the overgrown areas in Cobden. We never see anything done here and have been paying rates for years. 227

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Complaints Regarding Council Summary of comments made Submitter No. Presently taking WCRC to Environment Court for its reckless, ill-informed and improper actions in respect of a traditional whitebait stand or jetty in the Buller River historically permitted by WHL and BDC. WCRC appears out of touch with community interests and well-being at the district level. Need to recognise the historic, cultural, social and environmental significance of Westport’s rivers and coastal and marine areas by encouraging and facilitating traditional fishing, whitebaiting and recreational activities, and acting to preserve rather than destroy the heritage. Should consider the full transfer of its powers to the appropriate authority (BDC) to ensure that local government is properly in touch with the local community,

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Consider current inspection fees are a rip off. Does not think that Council has ever helped mining. Council staff incompetent as since 2013 the New River at the Gantry has been running dirty. Drop allocated charges, get reasonable. 103

The need to seek feedback tells that systems are breaking down. Both RMA and RPS have fundamental problems. Comes down to too much bureaucracy linked with the undermining of common sense and a lack of funding. Too many resources spent on maintaining the bureaucracy some of which is beyond Council control. Main issue is where going to get funding in future from in an ever decreasing economy. No jobs, no rates, smaller towns. What good is it to have natural resources if no one can get at them to use. Make it easy for small business and hard for big corporations. Local business is a must. Find alternative funding other than increased rates to encourage people to stay in the region. Get rid of RPS altogether.

104

Have been issued three abatement notices over 1 year. Believe concerns could have been addressed without these. No consideration of circumstances outside our control. Make us look bad and that are intentionally damaging our environment – is not the case. Believe abatement notice process has changed and are now issued without working with organisation first. Would rather work with the council and not against them. Smaller companies now having great difficulty dealing w overload of legislation and overzealous enforcement. Have canned two potential projects because on this and experience with WCRC. RPS suggests WCRC will promote business opportunities. Own experience contrary to this and makes the RPS hypocritical. Why would you want to invest in the region if knew what had to go through – too tough for business to deal with. To promote business WCRC needs to turn this around.

178

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Submitters

Number Name Surname Organisation 1 Karen Byrne Alpine Rentals 2 Bianca Aranguren 3 Andrew Havill Aratuna Freighters Limited 4 Durham Havill Aratuna Freighters Limited 5 BF Archer 6 Yvonne Archer 7 Chris & Elspeth Auchinvole 8 Dr Clare Backes 9 Raymond Bade

10 Kathryn Bainbridge 11 Bathurst Resources Limited 12 Merryn Bayliss 13 Bryan Williamson Bella Vista Motels 14 Peter Bennett 15 Alan Berry 16 Mark Berry 17 Paul Berry 18 Peter Berry 19 Hayley Bill 20 Alison & Andre Gygax Birds Ferry Lodge 21 Evan Birchfield 22 Paulette Birchfield 23 Karen Birchfield Birchfield Coal Mines 24 Allan Birchfield Birchfield Minerals 25 Jane Birchfield Birchfield's Ross Mining Ltd 26 Brian Blackman 27 Brian Blacktopp 28 Hayden Blacktopp 29 Joan Blacktopp 30 Mark Bolland 31 Miguel Sobrino Blue Grey Farm 32 Liana Bradley 33 Ted Brennan 34 Jane Brownie 35 Charles Bruning 36 Buller Conservation Group 37 Garry Howard Buller District Council 38 Bill Burton 39 Chelsea Byrne 40 Cameron Milne C&K Milne Timber Products 41 Nicola Calcott 42 Kathryn Cannan 43 Cynthia Cappello 44 John Caygill 45 Ross Macrae Character Holdings Ltd 46 Bryan Chinn 47 48 Chris & Jan Coll 49 Dr Cheryl Brunton Community and Public Health West Coast 50 Linda Connors 51 Mark Connors 52 Margaret Costello 53 Kay Costley 54 Sue Costley 55 Tanya Cumming 56 Ian Cummings 57 Rob Danford

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Number Name Surname Organisation 58 Dave Newey Department of Conservation 59 Dave McMillan Dispatch and Garlick Limited 60 FM Douglas 61 Christine Dunn 62 Len Dunn 63 Anna Dyzel 64 Collin & Sam Elliott 65 Paul Elwell-Sutton 66 Barney Fahey 67 Patrick Fahey 68 Shirley Fahey 69 Paul Fahey 70 Michael Bennett Federated Farmers of New Zealand 71 Janis Fensom 72 John Fensom 73 Lloyd Ferguson 74 Criag Findlay 75 Jim Findlay 76 Dean Kelly Fish & Game New Zealand 77 C Frogley 78 Lesley Frogley 79 Jonathon Green Fulton Hogan Ltd 80 Garry Wells Fulton Hogan Ltd - Greymouth 81 Colin Furness 82 B Gaia Gaia Trees 83 Gus Gordon 84 Andy Grigg 85 Jack Grinstead 86 Ingrid Gruner 87 Leslie Guenole 88 Gloria Hammond 89 Fran Harris 90 Michael & Christine Hart 91 Mike Havill Westland Mayor 92 Monique Havill 93 Kirk Haworth 94 Clive Hellyar 95 Neville Higgs 96 Pete Hines 97 Gail Howard 98 Garry Howard 99 Daniel Hume

100 Tessa Hunter 101 John Hutchison 102 Steffan Jamieson 103 Steven Jasper 104 Alan Jemison 105 Bill Johnson 106 Brian Jones 107 Dr Brendan Kaye 108 Justin Kendrick 109 Carol Keoghan 110 AK Keown 111 Sheeraz Khan 112 Barry King 113 Sharel Kokshoorn 114 Anje Kremer 115 Kent Baigent Kumara Gold 116 Dave Kwant

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Number Name Surname Organisation 117 Keith Laverny 118 Dr Mike Legge 119 Selwyn Leitch 120 Hamish Macbeth 121 Steve Maitland 122 Biddy Manera 123 Paul Maunder 124 James Russell Mawhera Incorporation 125 Karen Mayhew 126 Brian McEnaney 127 Jamie McGeady 128 Bryan McGrath 129 Rosie McGrath 130 June-Anne McIntosh 131 Mark McIntosh 132 Phil McKinnel 133 Laura McLaughlin 134 Willie McLaughlin 135 Megan McLellan 136 Kelly McLeod 137 Bruce Menteath 138 Robert Miedema 139 Andrew Miller 140 Dianne Milne 141 Kristine Milne 142 Robert Milne 143 Katie Milne 144 Peter O'Sullivan Minerals West Coast 145 Jonathon Jull Ministry of Civil Defence and Emergency Management 146 Vicki Molloy 147 Dion Monopoli 148 Peter Moor 149 Andy Eccleshall New Zealand Coal & Carbon Ltd 150 Mark Boere New Zealand Fire Service 151 Ian McCabe NZ Transport Agency 152 Paul Noble 153 David Wong-Tung NZG Limited 154 A.D. O'Callaghan 155 Johno O'Connor 156 Tracy O'Connor 157 Jack O'Connor 158 Patrick O'Dea 159 Brent Oldham 160 John Olsen 161 Tracy O'Malley 162 Elza Lotter OceanaGold Corporation 163 Nick Hancox OSPRI New Zealand 164 Geoff Parker 165 Ray Parkinson 166 Jo Parsons 167 Nicola Davy PB Davy Auto Electrical 168 Peter Davy PB Davy Auto Electrical 169 Nicole Piper 170 Mary Prendergast 171 Bruce Smith Rayce Management Services 172 S. Robinson Reefton Auto Lodge 173 M.W. Rennie 174 Zelda Richardson 175 Gavin Riley

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Number Name Surname Organisation 176 James Robinson 177 Noleen Robinson 178 Mike Rogers Rockies Mining Limited 179 Robert Rose 180 Royal Forest & Bird Protection Society - West Coast Branch 181 Royal Forest & Bird Protection Society - Christchurch 182 Philip Rutherford 183 Lisa Shannahan 184 Martin Siegwald 185 Alison Johnstone Silver Fern Farms Limited 186 Hayden Smith 187 Jenny Smith 188 Kylie Smith 189 Eddie Davis Southern Gold Buyers Limited 190 Murray Stewart 191 Celine & Anthony Stowkowski & Thrupp 192 Geena Kumar Straterra Inc 193 Sublett 194 Tony Sullivan 195 Terry Sumner 196 Drew Talboys 197 Hemi Te Rakau 198 Nathan Thompson 199 Susi Thompson 200 Angela Townrow 201 Rhedyn Law Transpower New Zealand Ltd 202 Peter Trolove 203 Laura Marra Trustpower Limited 204 Raewyn Turvey 205 Colin van der Geest 206 Rachel van der Geest 207 Ben Wakeford 208 Helen Wallis 209 Dale Wearing 210 Damian Webster 211 Lynley Hargreaves West Coast Environment Network 212 Stewart Robertson West Coast Tai Poutini Conservation Board 213 Graeme Purches Westland District Property 214 Robert Caldwall Westpower 215 Ian Whitmore 216 Sally Widdowson 217 Jenna Williams 218 John Willis 219 Linda Winchester 220 Philip Winchester 221 Kerry Wood 222 Alan Worthington 223 Juliana Zwies 224 Owen Zwies 225 Helen 226 Tanya 227 228 229 230 231 232 Fritz Fehling