Submission on the proposed New Zealand Coastal Policy Statement 2008 Sections 49 and 57 of the Resource Management Act 1991

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1 Submission on the proposed New Zealand Coastal Policy Statement 2008 Sections 49 and 57 of the Resource Management Act 1991 To: Board of Inquiry Proposed NZCPS C/- Department of Conservation PO Box Wellington 6143 Submitter: Lost Waves Aotearoa 2008(Lost Waves) 21 Gretel Place, Hillcrest, North Shore City 0627 Phil Hoare - mariko@xtra.co.nz Lost Waves wishes to be heard by the Board of Inquiry on this submission. This is a submission on the Proposed New Zealand Coastal Policy Statement Policy Lost Waves strongly support the notified proposals, especially policy 20 - Surf breaks of national significance. Identification of these surf breaks is of national importance, as they are finite and at risk and cannot be replaced. Artificial reefs as a mitigation method are not satisfactory; to date there has been no successful outcomes despite limited recent attempts. 3. While we support the general intent of the provision in policy 20 and the naming of significant surf breaks, we would prefer naming the location and seek minor rewording to encompass the location of the nationally significant surf breaks such as Ahipara, Piha, Raglan, Taranaki Surfhighway 45, Gisborne, Whangamata, White Rock, Kaikoura, Dunedin and Papatowai. It is our submission that it would better guide decision making. 4. Lost Waves also seek a rewording in policy 20 para(b) to replace the words coastal marine area with the words coastal environment. The words coastal marine area does not allow for activities outside that boundary that could potentially create adverse affects. Activities such development of subdivisions, farming and forestry, industry and hard wall engineering construction nearby or on surf breaks. 5. Policy 30 Integrity and functioning

2 6. Lost Waves seek that under Policy 30(c) the wording is amended to include hydrodynamic processes and features) It is our submission that would allow for more certainty for active protection of surf breaks. 7. New Policy 8. Lost Waves seeks insertion of new policy, one that directs regional Councils to identify and protect surf breaks of regional significance. It is our submission that while higher level policy such NZCPS has notified provisions for significant nationally surf breaks, there are regions that have regionally important significant surf breaks in need of active protection. The mechanism suggested will allow for regions to identify those surf breaks through community consultation. 9. Policy Policy 14 (c) (e) encourages a mixture of uses along the coast and discourage continuous urban development of the coast where it has not already occurred. It is our submission that this could permit a mixture of inappropriate uses such as mining, industrial plants, large sprawling commercial centres, high rises and canal developments. The policy would allow for such development, therefore we would recommend amending that section or deletion. Lost Waves also recommend replacing the word discourage with the word avoid. We have concerns that the above clauses could be circumvented by adding small reserves. 11. Policy The provisions within Policy 15 does not address the coastal issues, particularly rural coastal development and policy 15 (e) ---- that maintains the character of the existing built environment should be encouraged, and where development resulting in a change in character would be acceptable.-- is too permissive. It allows for places that have inappropriate building activity to add more, rather than less. The policy does not aid guidance and could potentially be difficult to implement. In addition the policy does not address any issues in the built environmental of green building, climate change or sustainable buildings. It is our submission that the policy be amended. 13. Strong Support. 14. Lost Waves support the objectives and policies, that pertain to Tangata Whenua or Maori such as objective 4, 5, 9, policy 2, 3, 4, 32(f)43(c)48(b)56, 14(g) and strongly support Policy 5. The precautionary approach is welcomed and fitting for today s planning approaches. 15. Further considerations

3 16. Lost Waves agrees that the provisions in the notified proposals offer more guidance to quality planning and decision making; but are still concerned that there is no direction for councils and decision makers in many areas particularly areas that are rural in nature and have sparce communities in significant natural zones. More guidance needs to be advanced. The rampant development on rural and coastal communities remains unchecked from inappropriate development, along with adverse affects to surf breaks, coastal users and surfer s health; and while it may be seen irrational the alternative is a full coastal moratorium until some certainty takes place, therefore we seek further consideration of the following points. 17. That Mapping of areas of the New Zealand coast where preservation is of national importance take place (no subdivision, construction of major infrastructure or urban development). 18. Mapping of areas of the coast considered suitable for low density development (subdivision where the average minimum lot size is above 20 hectares). 19. Mapping of areas of the coast already compromised by development and considered suitable for more development (subdivision to urban residential standards). 20. Policies that encourage restoration of the coast by planting native vegetation and creating natural habitats such as wetlands. 21. Policies that will ensure the preservation of areas considered to be of national importance for preservation. 22. Policies that encourage long term certainty over future land use through mechanisms such as covenants. 23. Policies that will ensure high standards in terms of landscape and biodiversity conservation for areas considered suitable for low density development (up to say 20 hectares) 24. Policies that will establish firm urban limits and ensure high standards of urban design in areas considered suitable for further urban development 25. Policies that will ensure that members of the public will have effective access to and along the coast

4 26. Clear subdivision policies which will discourage the creation of new lots in excess of foreseeable demand 27. Lost Waves seeks the following decisions: 28. That Policy 20 is amended to identify the places where surf breaks of national significance are located as follows: The surf breaks at Ahipara, Piha, Raglan, Taranaki Surfhighway 45, Gisborne, Whangamata, White Rock, Kaikoura, Dunedin and Papatowai, which are of national significance for surfing, shall be protected from inappropriate use and development, including by: 29. That Policy 20(a) is amended to replace the words coastal marine area with the words coastal environment as follows: ensuring that activities in the coastal environment do not adversely affect the surf breaks; and 30. That the following new policy is added: Regional councils shall identify in regional coastal plans regionally significant surfing breaks that reflect the diversity of types of breaks and range of surfing skill levels and surfing enjoyment and these shall be protected from inappropriate use and development, including by: (a) ensuring that activities in the coastal environment do not adversely affect the surf breaks; and 31. (b) avoiding, remedying or mitigating adverse effects of other activities on access to, and use and enjoyment of the surf breaks 32. That Policy 30(c) is amended as follows: the dynamic and hydrodynamic processes and features that arise from the natural movement of sediments, water and air 33. Amend the wording in policy 14(c) to stay away from the potential to have inappropriate subdivision and development and replace the word discourage with the word avoid. 34. Amend policy 15(e) to encompass climate change, green building or sustainable building, plus amend the wording to NOT be permissive of adding to inappropriate development. 35. Retain objective 4, 5, 9, policy 2, 3, 4, 32(f)43(c)48(b)56, 14(g) and Policy 5.

5 36. Take into consideration our submission from and amend the objectives and policies. 37. If others make a similar submission, Lost Waves would consider appearing on the same day and time frame to assist the Board of Inquiry 38. Lost Waves seek to have hearings in Auckland, Hamilton, Wellington and Christchurch to allow those submitters in those districts to be heard at minimal cost.

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