SUBMISSION ON RODNEY DISTRICT OPERATIVE DISTRICT PLAN: PROPOSED PLAN CHANGE 105 / PROPOSED RODNEY DISTRICT PLAN 2000: PROPOSED VARIATION 62
Te Arai Special Zone
TO:
Chief Executive Officer
Rodney District Council
Private Bag 500
OREWA
ATTN: Environmental Policy and Planning
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Name: Te Arai Beach Preservation Society |
OFFICE USE |
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Address: Ph: 09 431 4852 Fax: 09 431 4867 Email: info@tearai.org |
Submission No: 2037/1 |
1. The specific provision of the proposed change/variation that our submission relates to:
Proposed Plan Change 105 is opposed in its entirety. Proposed Variation 62 is opposed in its entirety.
2. Our submission is that :
a. Without derogating from the above generality, the Society particularly opposes those parts of the Proposed Plan Change and Proposed Variation which enable the development of a resort/hotel and village centre complex including 200 village homes and to the Forest Living provisions allowing for housing capped at 650 residences.
b. The Society submits that this intensity of development will adversely affect the natural, landscape and conservation values of Te Arai and the community’s experience of it for this generation and future generations to come.
c. This area is recognized through regional and district policy documents for its remote and scenic values and the Proposed Plan Change and Proposed Variation are contrary to policies promoting protection of these values. The Te Arai coastline is identified as an Outstanding Natural landscape in Change 8 to the Auckland Regional Policy Statement (ARPS) and an Outstanding Landscape under the Operative ARPS. Further it is identified as a Coastal Protection Area in the Auckland Regional Plan: Coastal and by the Department of Conservation as an Area of Significant Conservation Value.
d. Under s6 of the RMA (Matters of national importance) Council is required to protect and provide for preservation of the natural character of the coastal environment [s6(a)], the protection of outstanding natural features and landscapes [s6(b)]. The Proposed Plan Change and Proposed Variation are contrary to these sections of the Act. Mitigation measures are proposed, but the Society submits that these will not compensate for, or overcome the fundamental change of introducing intensive built resources, in effect a new town, into the coastal environment of Te Arai.
e. Unique features of Te Arai are a low level of built development, quality coastal landscape and a remote wilderness experience and the Society submits that adverse effects on these values must be avoided. The Society submits that the intensity of development facilitated by the Proposed Plan Change and Proposed Variation will result in these values being lost forever. In an increasingly developed and busy world, one of the “reasonably foreseeable needs of future generations” [s5(2)(a) RMA] is the ability to enjoy unspoilt, remote coastal areas such as Te Arai.
f. Under Section s6 (c) of the RMA Council is required to recognise and provide for protection of significant habitats of indigenous fauna. For example, Te Arai Beach has been identified as important habitat for 8 indigenous shorebirds, 5 of which are threatened. For 2 of these birds (the Northern NZ Dotterel and the Fairy Tern) this is a critical breeding site. The Society submits that shorebirds in particular the Fairy Tern are sufficiently vulnerable that adverse effects must be avoided, the risk that proposed mitigation measures may not work is too great and therefore the proposed development should not be allowed to go ahead.
g. Under Section s6 (c) of the RMA, Council is also required to recognise and provide for protection of areas of significant indigenous vegetation, and under s7(d) to have regard to the intrinsic values of ecosystems.
h. Under Section 6(f) of the RMA, Council is required to recognise and provide for the protection of historic heritage.
i. The Society submits that the Proposed Plan Change and Proposed Variation are contrary to the provisions of the Hauraki Gulf Marine Park Act 2000 and to the provisions of the New Zealand Coastal Policy Statement.
j. The Society strongly supports policies in the Auckland Regional Policy Statement to contain urban development and to contain the expansion of rural and coastal settlements. The Proposed Plan Change and Proposed Variation are contrary to these policies and to provisions of the RMA requiring that a district plan must give effect to any national policy statement, NZCPS and any regional policy statement.
k. The Society submits that in addition, the Proposed Private Plan Change and Variation are contrary to the policies and direction for Rodney District set out in Council’s Vision Rodney document.
l. Under s7 (c) and s7 (f) of the RMA Council is required to have regard to the maintenance and enhancement of amenity values and of the quality of the environment. The Society submits that the intensity of development proposed will adversely affect people’s enjoyment of the area and the quality of the environment by a significant increase in built structures, traffic, noise, pollution and people pressure. It is not only the amenity value and quality of the environment at Te Arai Beach that will be affected, but also the quality of life for those people who live in the surrounding rural area, particularly along road routes.
m. Te Arai complements the existing township of Mangawhai through its natural character and by providing wilderness and recreational values for visitors and residents to enjoy. The Society submits that the township will be adversely affected if the Proposed Plan Change and Proposed Variation are allowed, as will be the case for tourism and recreation operators and groups based on these values.
n. The Society submits that the intensity of development proposed will adversely impact on the infrastructure of the Te Arai/Mangawhai area. This includes but is not limited to roading, power supply as well as police, emergency and health services.
o. Section 7(b) of the RMA provides for the efficient use and development of natural and physical resources.The Society submits that the Proposed Plan Change and Proposed Variation are contrary to this section of the Act. Need for a new coastal township in this location is not proven and limited employment opportunities will result in residents of the Forest Living Zones making long road commutes to other centers. This is not sustainable in terms of adverse effects on the region’s infrastructure but also in view of climate change concerns and the need to reduce carbon emissions.
p. The Society further submits that the proposed new coastal town is not sustainable in view of growing evidence of climate change and the impacts that this could have particularly in relation to coastal settlements. For example, the proposed development will be vulnerable to the projected increase in severe storm events.
q. The Proposed Plan Change and Proposed Variation are also opposed on the grounds that Te Arai beach forms half of the only large undeveloped areas of ocean beach coastline on the east coast of Auckland region.
r. In conclusion the Society strongly supports provisions of the Operative Plan, Plan Change 55 and Proposed Plan 2000 that recognise and provide for the unique values of this section of coastline and submits that these should be retained. We believe these existing provisions have strong community support. This is further evidenced by the nearly 3000 signatures the Society collected to a petition opposing urbanization of Te Arai.
3. We seek the following decision from the Council.
That Proposed Plan Change 102 and Proposed Variation 62 be not approved.
4. If others make a similar submission I would/would not cooperate with them in presenting a joint case at any hearing
We would consider this at time of request and depending on circumstances.
5. Do you want to attend the Council hearing of this submission YES
6. Do you want to speak in support of this submission at the Council hearing YES
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Signature (Chairman) Date
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Signature (Secretary) Date