1,000 signatures reached
To: Auckland Council
Sign on to the submission in opposition to the Replacement Water Treatment Plant in Titirangi
Titirangi Protection Group encourages it’s supporters to sign on to our submission which will be presented to Auckland Council.
The Watercare application involves earthworks and vegetation removal, including in a Significant Ecological Area (SEA) overlay, and stream works including the reclamation and diversion of a length of intermittent stream. Resource consents are also being sought for the diversion and discharge of groundwater and stormwater, and the disturbance of potentially contaminated land.
Works will happen Monday to Saturday – 6 days per week.
The site forms part of a network of habitat through the Waima area and adjoins regional parkland habitat to the north and south and forms an important connection for wildlife in this network. The Yorke and Armstrong Gullies provide high quality freshwater habitats. Longfin eel and inanga are present in the catchment.
The area is well known for its rich biodiversity in flora and fauna, including rare species of ferns, epiphytes, butterflies, and snails. The site contains habitat for nationally threatened plant species, is also home to a range of native invertebrates that help keep nutrients cycling and are our key pollinators. Most recently a new species of native wasp was identified on the site.
The more of us who make a submission the more likely it is that this special site will be protected. The following is a condensed version of the Titirangi Protection Group submission.
Why is this important?
We submit that the site was selected based on altered scores, due almost entirely to inappropriate political pressure on the CCO as a result of sustained media coverage, resulting in the most optimal site from being selected.
We submit that the first principle of the RMA to AVOID irreversible adverse environmental effects has not been satisfactorily achieved with the project being proposed in this location. It is also inconsistent with the relevant objectives and policies of the Auckland Unitary Plan.
Noting that Auckland Council declared a climate emergency on 11th June 2019 we submit the removal of thousands of trees is irresponsible and out of step with best practice.
The ecology reports confirm this site forms linkages and corridors for wildlife with adjoining regional parkland including the North-West Link, furthermore edge effects will compromise the trees that remain outside of the construction site.
We submit that proposed buffer zones are totally inappropriate in size, additionally at the Reservoir 2 site all high integrity bush inside the “buffer zone” will be removed, and replaced by low value vegetation. Watercare already plan that that new vegetation may need to be removed in the future for pipe maintenance.
The shaft of the NH2 is inside the area of highest ecological value, and within riparian margins. This “creep” of add-ons is indicative of further encroachment over time. This is further demonstrated by the Watercare statement: “Revegetation of the decommissioned WTP site is not proposed, in order to preserve the long term resilience of the water supply system through allowing space for future refurbishment and/or expansion of the plant"
EFFECTS ON BIODIVERSITY:
We submit that due consideration has not been made to:
The impact of noise on surrounding wildlife. Furthermore in our view a satisfactory understanding of the underlying wildlife habitat that will be disturbed has not been established. Eg, a single bird survey period of December-January is inadequate. The bat survey was also inconclusive and further investigations are warranted.
After the applicant was notified on 10 June 2019 of the discovery of new insect species and the presence of other rare insect species, further investigations were warranted before the application was lodged.
KAURI AND KAURI DIEBACK:
Large parts of the Waitakere Ranges are closed to prevent the spread of kauri dieback yet 3.5ha of land are to be cleared within this protected area. We would like to point out that:
Only those kauri with a trunk diameter >20cm have been counted during site surveys, leaving smaller regenerating kauri unaccounted for. No investigations specific to the proposed development have been undertaken and the Ecological Report does not address the sensitive root systems of kauri and the impact of stress on vulnerability to kauri dieback.
The SOPs for kauri dieback were not designed for projects of this scale and all soil from the project site must be considered as contaminated for the purpose of the potential spread of kauri dieback disease to kauri beyond the project footprint treated in accordance with this assumption.
IMPACTS DOWNSTREAM OF THE SITE
We submit that sediment controls are inadequate and the risk of failure could be catastrophic. Titirangi-Laingholm Catchment Modelling, including flood profiling is still underway giving insufficient information regarding the risk. Failure Mode 1 does not adequately address the evacuation or warning systems with downstream residents or the school which tests water in Kopai Gully.
Given all soil is assumed to be contaminated such an event would risk healthy and genetically diverse kauri downstream. It would also risk the population of inanga at Little Muddy Creek.
This proposal has a 8year construction period. Consideration must be made of the impact not only for local traffic that use these roads every day, but for tourist traffic, school buses and cyclists. Pedestrian safety for school children and recreational and dog walkers will be compromised. Vibration damage of homes along the truck routes will be an additional cost to the project not budgeted for.
TOURISM AMENITY IMPACTS
The proposed construction site is at the gateway to the Waitakere Ranges and would be a very visual scar and tarnish our international image.
THE PROPOSED TRUST:
Titirangi Protection Group opposes mitigation regarding it as a blunt archaic tool and out of step with progressive thinking to development in our city.
We submit that this is only compensation (and should in no way be referred to as “mitigation”) and is focused on Biosecurity not Biodiversity. Mitigation is over and above what is currently planned or supported. We note there are multiple groups in the proposed zone who have support to increase biodiversity in the area via Auckland Biodiversity expertise and Auckland Council Grants. The NETR has increased this support.
Any Trust should be in existence for the whole operational life of the plant, not just the period whilst being built and commissioned.
The expected high level of engagement in the catchment is based on the aspirations of the community in relation to the Muddy Creeks Local Area Plan, however this does not take into account the resistance of many in the catchment who oppose the project and want no part in perceived blood/hush money.
WHY IS THIS IMPORTANT?
The site is almost completely covered in native vegetation and has been identified as a Significant Ecological Area (SEA) in the AUP. The site is only one of a small number of SEAs in Auckland that meet all 5 of the conditions required to be a SEA.
Studies show direct connections between spending time in a forest atmosphere and the lowering of the stress hormone cortisol. The loss of forest, together with the noise and disruption will be distressing for the community over a long period of time.
How it will be delivered
This will be delivered to Auckland Council with supporting evidence with the Titirangi Protection Group submission requesting that the application is declined in its entirety. A full copy is available by emailing email@example.com