MHPS Submission to Environment Canterbury opposing the Central Plains Water scheme.
Reasons for The Malvern Hills Protection Society Incorporated (MHPS) objecting to the granting of consents to CPW .
Index
1.1.1.
Landscape values
1.1.2.
Community
impact
1.2.
Waianiwaniwa
valley
1.2.1. Biodiversity values
1.2.2. Historical values
1.2.3. Social impact on valley residents,
1.2.4. Equity issues
1.2.5. Permanent loss
of naturally drought proof productive land
1.2.6. Selwyn
Plantation Board land.
1.3.
Coalgate
1.3.1.
Loss of scenic
backdrop and natural character of area –
1.3.2.
Loss of quiet
rural character
1.3.3.
Dam safety,
evacuation, compensation and liability issues.
1.3.4.
Psychological
impact
1.3.5.
Disruption to
village during construction
1.3.6.
Impact of
Climate change
1.3.7.
Impact of
recreational activities
1.3.8.
Water quality
in reservoir, fluctuating water levels
1.3.9.
Pumps – noise
issues
1.3.10.
Drop in
property values during construction.
1.3.11.
Impact of level
headrace on Selwyn River
1.4
Impact on
Surrounding areas including Sheffield and Homebush
1.4.1
Safety issues
1.4.2
Visual impact
of canals/tunnel
1.4.3
Impacts during
construction of canals and tunnel
1.4.4
Loss of
productive farmland taken for canals /tunnel
1.4.5
Loss of
production on farms during construction
1.4.6
Social impacts
1.4.7
Impacts on the
Hawkins River
1.4.8
Impacts on
cemeteries and public reserves
2.
Wider Impacts
2.1.
Waimakariri
River
2.2.
Intake
structures
2.3.
Economic
2.4.
Downstream
effects.
2.5.
Potential to
spread Didymo across Canterbury.
2.6.
Contribution of
intensification to climate change.
2.7.
How will future water needs of other areas be
met?
2.8.
Electricity demand for intensive land use - is this
sustainable?
2.9.
Loss of shelter, animal welfare issues.
3.
Lack of proper investigation into alternatives
The MHPS considers that the proposals are contrary to the objectives and policies of a number plans including the Proposed Canterbury NRRP, the Transitional Canterbury Regional Plan, the Waimakariri River Regional Plan and the Proposed and Transitional Selwyn District Plans.
The MHPS requests that all applications
be DECLINED.
General character of Malvern Hills Area.
For the purposes of this submission, the Malvern Hills Area refers to the cluster of rolling hills – including the Harper Hills and the Malvern Hills – that are situated between the flat Canterbury plains to the East and the steeper mountains of the Torlesse ranges to the West. This area is bounded by the Waimakariri River to the North and the Rakaia River to the South. Through the centre of the district winds the Selwyn River.
Two major farming valleys are situated within the Malvern Hills – the Wairiri valley and the Waianiwaniwa Valley.
Currently the Malvern Hills Area is a rural farming district. The
predominant land use on the hills is sheep farming with beef, deer, goats,
pigs, ostriches and other animals also being farmed. The favourable climate,
with higher summer rainfall than the surrounding regions has encouraged the
establishment of a stable population and long established family farms.
The area has pockets of biodiversity with native remnants scattered throughout the hills and valleys, including raised spring fed peat bogs and native beech forest, at the head of the Wairiri Valley which have a QEII covenants on them. These remnants provide an important link in the chain of native remnants that stretch along the lower Canterbury foothills linking the larger patches such as Oxford forest and Mount Sommers, assisting native birds to move between these areas.
The majority of the population lives in three small villages (Whitecliffs, Glentunnel and
Coalgate) which are situated along the Selwyn River as it winds its way around
the Malvern Hills. Many of the local residents have lived in the area for a
major portion of their lives and have extended family in the region. These
long-term residents provide stability for the community and assist newer
arrivals in settling in.
New buildings are in keeping with the general character of the region
and no large ‘subdivisions’ have been created as has occurred elsewhere on the
plains.
In recent times two major walkways have been created. One at Glentunnel, which takes people past a number of historical
sites to the entrance of some disused coalmine shafts.
The other walkway at Coalgate takes people on a loop track up along the
ridgeline of the Harper hills and back down along the Selwyn River. From this
walkway stunning 360-degree views are to be had over the Canterbury plains on
one side and across the Malvern Hills to the Torlesse
ranges on the other.
Both Walkways are very popular both with local residents and with
visitors to the area.
The MHPS has serious concerns that the proposed dam and canals will
fundamentally alter the general character and feel of the Malvern Hills Area in
a number of ways. Some of these impacts are listed below.
1.1.1.
Landscape values
The existing landscape is highly valued by local residents.
The proposed dam wall will have a major impact on the local landscape,
which will not be able to be mitigated.
Currently the district is classified
as a region of “high scenic value” and the scenic highway 72/77 runs directly
pass the proposed dam wall.
1.1.2.
Community impact
The Waianiwaniwa valley is valued for existing contribution to community. The valley residents contribute to the stability and wellbeing of our community.
Through the Waianiwaniwa valley runs a number of quiet country roads. As they have very little traffic, visitors and locals use these roads for both cycling and running. Cyclists have the option of a ‘round trip’ from Coalgate to Whitecliffs going via the valley and returning via Glentunnel. Loss of the Valley roads greatly limits the range of round trips available to cyclists in the area.
The Deer Stalkers association have a site within the valley which is used for clay shooting and centre-fire ranch and bench rest facilities. This provides a place for the training of young/ new members in gun safety and will be very difficult to replace.
1.2.
Waianiwaniwa valley
1.2.1.
Biodiversity.
Although Waianiwaniwa valley does not have any large areas of native
vegetation, the wetland areas in the valley bottom provide a significant
habitat for the regionally rare Canterbury mudfish and other native fish
species such as eels. Within the valley,
trees, shrubs and other plants, both native and non-native, along with
the wetland areas, create pockets of bird habitat with higher levels of native
birds than on the plains. The destruction of the Waianiwaniwa valley would
negatively impact on local biodiversity values.
1.2.2.
Historical values
The Waianiwaniwa valley has important sites that show its historical
role in the region from the time of the Maori onwards. This sense of history
adds to the richness and uniqueness of the Malvern Hills. Local residents would
keenly feel their loss. Within the Waianiwaniwa valley the following sites are
of particular importance to the MHPS;
¨ The Maori ovens and other sites significant to local
Maori
¨ The Coalmines (both disused and current)
¨ The Deans family home (Tara),
¨ The Robertson’s renovated home ( a 140 year old triple
brick house originally built as a shepherds cottage by the Deans family)
¨ A number historically significant trees with
protection orders on them.
1.2.3.
Social impact on valley residents
Of grave concern to the MHPS is the displacement of a number of the
valley farmers who will lose their homes and heritage. It will be difficult, if
not impossible, for these families to purchase viable equivalent farm
properties within the area and the long term impact on these families will be
serious especially when they are faced with the loss of family connection to
the area and the land.
Other valley residents are facing loss of road access to their homes and
farms, with alternative transport routes in or out of their properties (e.g.
via Whitecliffs) likely to have a negative impact on
farm viability.
1.2.4.
Equity issues
The MHPS considers that it is
inequitable for established viable and stable productive family farms to be
destroyed to make way for intensive corporate farming on the plains. It is
estimated that if the scheme were to be built then more than 60% of the land
within the scheme area will be on-sold. It is also of concern that the loss of
the land will be primarily to allow land intensification on the plains not for
drought proofing dryland farm operations. The MHPS
believes that private land should only be taken for genuine public need not for
private greed.
1.2.5.
Permanent loss
of naturally drought proof productive land
The land within the valley has higher
rainfall than the plains. It often remains green during the summer months. Many
of the farmers within the valley have bought land specifically to provide back
up during dry times for their farms on the plains, and move their sheep into
the valley during the summer. Farmland that is naturally drought-proof and can
be reliably farmed without irrigation should be protected not destroyed.
1.2.6.
Selwyn
Plantation Board land
1.3.
Coalgate
1.3.1.
Loss of scenic backdrop and natural character of area
The proposed dam wall will have a major impact on the local landscape,
which is highly valued by the MHPS and local residents. The hills that flank
the entrance to the Waianiwaniwa valley provide a sheltered background to the
village of Coalgate and are visible from nearly all points of the village.
On the site of the proposed dam wall is beautiful mixed woodland over
100 yrs old. This woodland is very visible from the main road through Coalgate
(Bridge st) and from a large proportion of properties
within Coalgate village.
The woodland is also very visible
from the Coalgate Walkway forming an attractive background to the Village.
The loss of this woodland to make way for the dam wall and the loss of
the natural contour lines of the surrounding hills would be keenly felt by
local residents and would have a major impact on the character of the village.
The 2km long straight line of the top of the dam wall would be completely out
of keeping with the rolling contours of the hills abutting the dam wall.
The proposed dam wall will have a gravel surface, and regardless of the
type of gravel used, the dam will be a grossly unsightly replacement for the
existing woodland and rolling hills. A
gravel heap of the size proposed will have the appearance and feel of residing
within a construction area even after the dam is completed. The are major
concerns that during construction and after construction the dam wall will be a
major source of dust that will blow over Coalgate during Nor’west
winds.
1.3.2.
Disruption to village during construction
Local residents are extremely concerned about the disruption that the construction of the dam wall and level head race will cause. The application states that there could be heavy machinery operating up to 24 hours a day, 7 days a week. The noise and dust from the earthworks and heavy trucks rumbling pass homes will be hugely disruptive and will potentially cause damage to walls and foundations of buildings within the area. Coalgate and Glentunnel villages have many families with young children who freely walk and cycle around the villages. There is concern that the increased road traffic will increase the likelihood of a serious or fatal accident.
1.3.3.
Loss of quiet rural character
Most residents of Coalgate and Glentunnel
villages rate very highly the quiet rural character of the area. There is a
significant proportion of retired people many of who have moved into the area
because they appreciate the quiet and peaceful surroundings. They do not want
to spend their last few years in the middle of a giant construction zone and do
not have the energy/ ability to ‘start all over again’ at a new place. Parents
with young children also have similar concerns about the effect of the
construction activities for such a significant proportion of their children’s
upbringing.
1.3.4.
Dam safety, evacuation, compensation and liability
issues.
There is widespread concern about living in the zone of ‘extreme devastation’ in the event of a dam breach. There are concerns about the wisdom of building such a potentially dangerous structure immediately above a village when the area is due for a major seismic event in the next 50 years. These concerns are heightened by the fact that there are a number of fault lines both within and near the valley. There are concerns that a collapse similar to that of Opuha dam could occur during or after construction. There are concerns that the actual dam built will not be the same as is claimed on paper – that to safe costs the company will take short cuts (for example a cheaper infill used) and that this will impact on dam safety.
The MHPS have been informed that the dam will take 53 days to empty. If for any reason the dam is deemed ‘unsafe’ and needs to be emptied in order to undertake repairs.
The MHPS has a number of unanswered questions.
1) Who will supervise the construction and make sure that construction conditions are fully complied with?
2) If at any stage the dam is considered unsafe, will villagers need to be evacuated while the dam is emptied and repaired?
3)
Will the cost
of alternative accommodation for villagers and the potential loss of income for
people who are self-employed be covered? If so by whom?
4)
In the event of
any damage occurring to properties as a result of the dam construction or
failure who will be held legally liable for covering the resulting costs?
5)
In the event of
any loss of life as a result of the dam construction or failure who will be
responsible for determining appropriate levels of compensation and who will be
held legally liable?
1.3.5.
Psychological impact of dam, feelings of insecurity,
powerlessness.
A major impact of the proposed scheme and dam has been the psychological impact on many local people. They do not want the dam, which they feel is being foisted upon them. Despite assurances by the scheme proponents that the dam will be safe local people have no means of independently verifying this for themselves. This has resulted in feelings of powerlessness and stress – for some people this has taken the form of vivid images of destruction of their homes and persistent feelings of insecurity. There are people who feel so oppressed by the thought of living so close to such a potentially dangerous structure that they feel that they will have to sell their much loved homes and move away from the area.
1.3.6.
Water quality in reservoir
The MHPS has serious concerns about water quality in
the proposed reservoir. Opuha dam had ongoing problems with poor water quality
arising from toxic minerals, phormidium and algae developing from anaerobic water conditions.
It is understood that water quality in the reservoir will be improved if all
topsoil (a source of nutrient) is removed from the valley floor before
construction and a means of mixing water from different levels is introduced.
1.3.7.
Impact of recreational activities
MHPS are concerned that the proponents of the scheme are proposing that the reservoir be used for a number of recreational activities such jet boating and water skiing which are out of keeping with the quiet rural character of the area. Such forms of recreation would draw numbers of people into the area for the day to indulge in intrusive activities upon local residents. It is very difficult to enforce noise restrictions and elsewhere-other residents have had ongoing difficulties obtaining relief from excessive noise from recreational activities.
1.3.8.
Impact of Climate change
The MHPS is concerned that the scheme has been based upon river and rainfall data for the last 30 years. Changes in rainfall patterns may mean that reservoir is empty for a large proportion of the time as there may not be enough water in the rivers to fill the reservoir. This in turn would reduce any recreational value that the reservoir may have and increase problems with wind blown dust from the reservoir
1.3.9.
Pumps – noise issues
The possibility of pumps being used to pump water into the reservoir from the level headrace raises concerns about background noise for nearby residents.
1.3.10.
Drop in property values during construction.
There are concerns that residents near the construction area will experience a drop in property values during the construction of the scheme. This is of particular concern to residents who do not want to remain in the area should the scheme proceed. Any comparative drop in property values may result in them being unable to purchase a similar lifestyle property elsewhere in Canterbury, as there are few locations that offer comparable lifestyle values to the Malvern Hills.
1.3.11.
Impact of level head race on Selwyn River
1.4.
Impact on Surrounding areas including Sheffield and Homebush
1.4.1.
Safety issues
There are major concerns about the safety of the level headrace and network canals close to Sheffield township and the primary School.
Although the AEE states that embankments etc. will be designed to withstand seismic activity, it does not state the magnitude of movement the structures will take.
There is concern about the effects of breaching elevated sections of canals or the vulnerable points such as watercourse crossings. There is concern that such breaches could result in significant damage or loss of life.
1.4.2.
Visual / heritage impact of canals/tunnel
1.4.3.
Impacts of construction of canals and tunnel
There are concerns about the noise dust and fumes resulting from the use of heavy machinery and traffic and drilling during construction of the canals and the tunnel. There are concerns about the damage that may occur to house foundations and the length of time people will be subjected to noise pollution.
1.4.4.
Loss of productive farmland taken for canals
Productive farmland will be taken to make way for canals and this will have a negative impact on many farms.
1.4.5.
Loss of production on farms during construction
Many farm operations will be disrupted during construction with a negative impact on farm operation. Will compensation be offered to landowners affected during construction?
1.4.6.
Social impacts.
The uncertainty and confusion arising from the different maps and
proposals being floated around is causing significant stress to local people.
Property development has been placed on hold and the tensions have resulted in
a seriously divided community. While the increased production associated with dairy conversions
in Southland has brought more jobs the lack of permanence associated with
sharemilkers has really hurt communities with a high turnover resulting in social instability. There are
concerns that the scheme will result in a high turnover of land and associated
instability.
1.4.7.
Impacts on the Hawkins River
There is concern that the proposed canal siphon will affect the ability of the Hawkins River to carry away floodwaters.
1.4.8.
Impacts on cemeteries , reserves, paper roads
Since there are several versions of where the canals may go there is concern that significant public land such as cemeteries, reserves or paper roads will be taken for the scheme.
2
Wider Impacts
2.1 Waimakariri
River – flat-lining of the flow.
The MHPS is concerned about the likely serious impacts on the ecology and intrinsic character of the Waimakariri river as a result of the take bringing the river flow down to minimum flow for extended periods of time.
2.2 Intake
structures – including loss of public access
The MHPS considers that there is not enough information provided to determine the full impact of the intake structures on a range of values including public access.
2.3