The Waitakere Ranges Local Board’s position on the Watercare Plant
In the interests of public transparency I thought I should set out what the Local Board submitted on the resource consent application for the Waima water treatment plant. Here it is.
The submission is subject to final approval which will be considered at our board meeting on September 26.
The Waitākere Ranges Local Board is responsible for identifying and communicating the interests and preferences of the people in its local board area.
Following is our input to the consent application by Watercare. This relates to the environmental, heritage and social impacts of the proposal.
We would like to be heard at the hearing
- We oppose the application in its current form.
- We note the proposed development is in the Waitākere Ranges Heritage Area and is adjacent to regional parkland and our view is that it is inconsistent with the objectives of the Waitākere Ranges Heritage Area Act 2008 as well as the Muddy Creek Local Area Plan.
- We invite Watercare to renew consultation with the Waima community to locate a site and a plant design that will satisfy local expectations.
- We invite Watercare to investigate repositioning of the plant to the sludge site close to the Nihotupu lake as identified in the Local Board’s letter to Watercare dated October 9, 2018 a copy of which is attached.
- Alternatively we invite Watercare to consider repositioning the site in an urban industrial area such as Spam Farm in Glendene which is more suitable for the location of a large industrial complex of this sort.
- We are concerned
- the plant design requires the destruction of 3.5 hectares of regenerating sub tropical rainforest that is home to many indigenous species including a previously unidentified wasp.
- The project will require up to 118 heavy vehicle movements a day on Titirangi’s narrow and fragile roads.
- We support the restoration and repurposing of the Nihotupu Filter Station which is a scheduled heritage building at the entrance to Exhibition Drive
- We support a significant restoration fund being established should the new plant be constructed in the Waima area.
Waitākere Ranges Heritage Area Act considerations
We acknowledge that Watercare holds a special designation on the site and the terms of this designation have been considered by the High Court in TPG v Watercare [CIV-2017-404-2762]. We note however that the significant ecological area overlay of the Unitary Plan poses some restrictions on what can occur specifically in relation to vegetation clearance and earthworks and stream diversion and therefore overrides the designation.
The subject site is within the Waitākere Ranges Heritage Area (WRHA), established by the WRHA Act 2008. Section 7 of the Act recognises that:
“(1) The heritage area is of national significance and the heritage features described in subsection (2), individually or collectively, contribute to its significance.
(2) The heritage features of the heritage area are—
(a) its terrestrial and aquatic ecosystems of prominent indigenous character that—
(i) include large continuous areas of primary and regenerating lowland and coastal rainforest, wetland, and dune systems with intact ecological sequences:
(ii) have intrinsic value:
(iii) provide a diversity of habitats for indigenous flora and fauna:
(iv) collect, store, and produce high quality water:
(v) provide opportunities for ecological restoration:
(vi) are of cultural, scientific, or educational interest:
(vii) have landscape qualities of regional and national significance:
(viii) have natural scenic beauty:
(b) the different classes of natural landforms and landscapes within the area that contrast and connect with each other, and which collectively give the area its distinctive character: …
(e) the quietness and darkness of the Waitākere Ranges and the coastal parts of the area: …
(g) the opportunities that the area provides for wilderness experiences, recreation, and relaxation in close proximity to metropolitan Auckland:
(i) the subservience of the built environment to the area’s natural and rural landscape, which is reflected in—
(ii) the distinctive harmony, pleasantness, and coherence of the low-density residential and urban areas that are located in regenerating (and increasingly dominant) forest settings; …
(l) its distinctive local communities:
(m) the Waitākere Ranges Regional Park and its importance as an accessible public place with significant natural, historical, cultural, and recreational resources:
(n) the public water catchment and supply system, the operation, maintenance, and development of which serves the people of Auckland.”
Section 8 sets out the objectives of the Legislation. It says:
“The objectives of establishing and maintaining the heritage area are—
(a) to protect, restore, and enhance the area and its heritage features:
(b) to ensure that impacts on the area as a whole are considered when decisions are made affecting any part of it:
(c) to adopt the following approach when considering decisions that threaten serious or irreversible damage to a heritage feature:
(i) carefully consider the risks and uncertainties associated with any particular course of action; and
(ii) take into account the best information available; and
(iii) endeavour to protect the heritage feature:
(d) to recognise and avoid adverse potential, or adverse cumulative, effects of activities on the area’s environment (including its amenity) or its heritage features:
(e) to recognise that, in protecting the heritage features, the area has little capacity to absorb further subdivision:
(f) to ensure that any subdivision or development in the area, of itself or in respect of its cumulative effect,—
(i) is of an appropriate character, scale, and intensity; and
(ii) does not adversely affect the heritage features; and
(iii) does not contribute to urban sprawl:
(g) to maintain the quality and diversity of landscapes in the area by—
(i) protecting landscapes of local, regional, or national significance; and
(ii) restoring and enhancing degraded landscapes; and
(iii) managing change within a landscape in an integrated way, including managing change in a rural landscape to retain a rural character:
(h) to manage aquatic and terrestrial ecosystems in the area to protect and enhance indigenous habitat values, landscape values, and amenity values:
(i) to recognise that people live and work in the area in distinct communities, and to enable those people to provide for their social, economic, environmental, and cultural well-being:
(j) to provide for future uses of rural land in order to retain a rural character in the area:
(k) to protect those features of the area that relate to its water catchment and supply functions …
As can be seen most of these objectives are protective. Only objective (k) is supportive of the construction of the treatment plant and it talks about protecting features rather than changing features.
Section 13 of the Act requires a decision making body when considering a resource consent for a discretionary or non complying application to give particular regard to the purpose and objectives of the Act. If the application involves a controlled or restricted discretionary activity then consent authority must consider the purpose of this Act and the relevant objectives as if they were matters specified in the plan or proposed plan.
Clearly special care needs to be taken in the assessment of this application.
The currently bush covered part of the Watercare site is on a highly prominent location at the intersection of Scenic Drive and Woodlands Park Road.
Exhibition Drive is an entry point to Waitākere Ranges Regional Park so we believe the protecting the values of the park should be a major consideration, along with the impacts on the character of Waima and Titirangi.
The proposed changes to the site will have significant impact on the heritage and ecological values with the removal of vegetation, the earthworks, the construction impacts and the eventual built form.
We acknowledge the importance of the area’s water supply function and the need for a growing Auckland. A good outcome would be to balance this with the other heritage features, particularly subservience of the built environment to the natural landscape, protection, enhancement and restoration of ecosystems, and the area’s distinctive local communities.
Muddy Creeks Local Area Plan
The Waitākere Ranges Heritage Area Act 2008 allows for the creation of local area plans. The purpose of these plans is set out in section 25(2) of the Act as follows:
“The purpose of a LAP is to—
(a) promote the purpose of this Act and the objectives; and
(b) provide objectives (particularly long-term objectives) in relation to—
(i) the future amenity, character, and environment of the local area to which the LAP applies; and
(ii) the well-being of the local community within that area (including its economic and social wellbeing); and
(c) inform decision-making processes that relate to the heritage area.”
The effects of a LAP are set out in sections 27 and 28 of the Act. The provisions are somewhat complex but the board believes that the terms of any existing plan are a relevant consideration in assessing what heritage features to give effect to and how much weight should be given.
The Muddy Creeks Plan, a local area plan for Waima, Woodlands Park, Laingholm and Parau, was adopted in 2014. It contains the following passage:
Statement of existing character and amenity
Woodlands Park and Waima are visually contained on their northern and western sides within the steep forested slopes of the Regional Park and Watercare land that includes Exhibition Drive. Houses are nestled within the regenerating forest. Large trees, many of them kauri, are a prominent feature. Dissected valleys and gullies give each road a sense of intimacy and isolation while offering elevated glimpses of the Manukau Harbour. At the top of Woodlands Park Road, the Huia filter station is a prominent feature which reminds us of the history and current water supply function of the area.
Statement of future character and amenity
In Laingholm, Woodlands Park and Waima the delicate balance between houses and vegetation along the slopes will be maintained. Footpaths designed in sympathy with the area will line the main roads, and a network of walkways will join pockets of settlements, schools, halls and shops, Laingholm Beach and South Titirangi. Ecological corridors within the area will provide safe, healthy and connected ecosystems and terrestrial habitats.
Site selection process and requirement to look at alternatives
The replacement of the Huia Water Treatment Plant has been a contentious subject in the area. There was strong opposition to locating the plant in Oratia, and there is strong local opposition to the current proposal.
The following aspects of the proposal are, in no particular order, the matters of most concern:
- Environment destruction including the clearing of over 3 hectares of forest close to significant stands of Kauri.
- Amenity destruction, particularly for Manuka Road residents who would especially be affected by the proposal.
- Disruption to the local community caused by construction and truck movements.
The local board has always taken a keen interest in issues relating to tree protection. In a world where forests in Alaska, Siberia, Brazil and Africa are burning and where the planting of sufficient trees may be the world’s best chance to prevent runaway global warming the thought of 3.5 hectares of Waitākere forest and bush being cleared fills us with dread.
The plant is a large industrial style plant and is totally out of place in Waima, in a sensitive ecological area.
The board had previously proposed to Watercare that it should construct the plant on another site. A copy of our letter is attached. Watercare has rejected this proposal.
We note the proposal would have these benefits:
- Low quality vegetation would be cleared
- Watercare would have to remediate a site which is currently a dumping area for treated carbon which is a by product of the treatment process
- The affect on amenity would be limited as the site is on the far site of a ridge away from houses.
We accept however that the proposal would increase the disruption caused by truck trips to a greater area.
This sort of activity should take place in an industrial area, not in an area of environmental sensitivity. We would urge Watercare to go back to the drawing board on this application and reconsider placing the treatment plant in a suitably designated industrial area.
The size of the plant is of concern. The technology being used, settlement tanks, requires this size plant. We would urge Watercare to consider alternatives such as filtration so that if a treatment plant is located in Waima then much smaller bush clearance is required.
In relation to the current proposal we are pleased to see that the final revised proposal decreased the amount of vegetation to be cleared by having two separate reservoirs. Also the intensity of the construction was reduced by having the second reservoir constructed after the first one was finished.
With regards to design, we consider that the proposed design is sprawling and that there has been no opportunity taken to reduce footprints of actual infrastructure. Is there not a more effective process that could require smaller more dispersed responses? Were other sites explored for partial filtration? With a distributed filtration system (including smaller plants at different parts of the network) raw water could be piped to different parts of the network and then filtered and cleaned.
The effects on the local community will be considerable. Amongst other things there will be a number of daily truck movements and it has been estimated there could be up to 118 per day.
Roads in the area are steep and narrow and windy. There are realistically only two roads that trucks could take into the area. One is through Titirangi village using Titirangi Road and the other is on Atkinson Road. The first will cause considerable disruption to the village. The second will take trucks past two primary and one intermediate school in a one kilometre stretch of road.
We support the proposed mitigation package however have concerns that the construction will put pressure on the catchment which is wider than the Waima catchment and the mitigation package should address this.
We recommend the catchment be extended to include Parau to the west, and parts of South Titirangi to the east.
We note that Sandra Coney and Bob Harvey have submitted on the future of the Nihotupu Filter Station. We support the restoration and repurposing of the Station that is proposed.
We do question if works affecting the Nihotupu and Huia Filter Stations, which have heritage status, can be achieved by use of the Outline Plan of Works process. We believe that consideration of the treatment of these buildings should be part of the public hearing process.
We consider that the effects are that significant that an increase in the proposed funding to support sustainable on-going ecological change is appropriate.
We also consider there should also be investment in social mitigation similar to that provided to the Waterview community following the NZTA tunnel project that occurred there.
We recommend that the Waima Biodiversity Trust include a representative of the Waitākere Ranges Local Board along with an Auckland Council staff representative in its make up. We ask that the Trust Deed be changed accordingly. While the trust will be operating independently there is a need for it to be aware of what council is doing and for council to be aware of what the trust is doing. Having a technical representative from Auckland Council along with an elected representative would help with this. The local board oversees council’s local environmental activities, including the support of volunteer groups doing ecological restoration.
We also consider there should be an emphasis on supporting the efforts of locally based environmental groups.
Waima Biodiversity Management Plan
We recommend that the Management Plan include support of the full range of community led actions in the Muddy Creeks Local Area Plan to deliver on the objectives for “Ecology and Ecosytems” as outlined in Appendix 1 of the plan. The biodiversity plan should support environmental education programmes to foster environmental stewardship in the area beyond the proposed 10 year life of the trust and its funding.