in the environment court of new zealand wellington ... · (g) the freshwater ecology assessment...

Barristers and Solicitors Wellington Solicitors Acting: David Randal / Thaddeus Ryan / Frances Wedde Email: [email protected] Tel 64-4-499 4242 Fax 64-4-499 4141 PO Box 2694 DX SP20201 Wellington 6140

IN THE ENVIRONMENT COURT OF NEW ZEALAND WELLINGTON REGISTRY I MUA I TE KŌTI TAIAO O AOTEAROA TE WHANGANUI-Ā-TARA ROHE

ENV-2020-WLG-00014 UNDER the Resource Management Act 1991 IN THE MATTER OF a notice of motion under section 87G of the Act

seeking the grant of resource consents to Waka Kotahi NZ Transport Agency for Te Ahu a Turanga: Manawatū-Tararua Highway

STATEMENT OF EVIDENCE OF JUSTINE QUINN ON BEHALF OF WAKA KOTAHI NZ TRANSPORT AGENCY

FRESHWATER ECOLOGY

12 June 2020

BUDDLE FINDLAY .

TABLE OF CONTENTS INTRODUCTION .................................................................................................... 3 EXECUTIVE SUMMARY ........................................................................................ 5 UPDATES AND FURTHER WORK CARRIED OUT SINCE LODGEMENT ............ 8 COMMENTS ON SUBMISSIONS / SECTION 274 NOTICES ............................... 18 COMMENTS ON SECTION 87F REPORT ........................................................... 33 ATTACHMENT JQ.1 – SIMPLIFIED CULVERT TABLE WITH FISH PASSAGE REQUIREMENT (EXPANDED FROM PROPOSED CONDITION EC13) .............. 42 ATTACHMENT JQ.2 – STREAM OFFSET LOCATIONS ...................................... 43 ATTACHMENT JQ.3 – UPDATED SUMMARY REACH BASED ECR CALCULATIONS INCORPORATING FOUR OFFSET SITES AND CHANGES TO DIVERSIONS ........................................................................................................ 47 ATTACHMENT JQ.4 – ASSUMPTIONS ASSOCIATED WITH SEV CALCULATIONS AT OFFSET SITES ................................................................... 53 ATTACHMENT JQ.5 – AQUATIC ECOLOGICAL MONITORING AND RESPONSES FLOWCHART ................................................................................ 54

INTRODUCTION

1. My full name is Justine Louisa Quinn.

2. I am a freshwater scientist at Tonkin and Taylor Limited.

3. I prepared Technical Assessment H Freshwater Ecology ("Technical

Assessment H") as part of Volume V of the Assessment of Environmental

Effects ("AEE"), which accompanied the application for resource consents

lodged with Manawatū-Whanganui Regional Council ("Horizons") on 11

March 2020 in respect of Te Ahu a Turanga: Manawatū Tararua Highway

Project (the "Project").

4. My qualifications and experience are set out in paragraph 4 of Technical

Assessment H.

5. In preparing Technical Assessment H and my evidence I have:

(a) provided advice on freshwater ecology matters related to the Project to

the Te Ahu a Turanga Alliance ("Alliance"), and ultimately Waka Kotahi

NZ Transport Agency ("Transport Agency"), since September 2019;

(b) attended and participated in workshops to inform the freshwater

ecology components of the Natural Character assessment (prepared by

Mr Boyden Evans);

(c) attended and participated in pre-lodgment ecology workshops and hui

with the Director-General of Conservation / Department of

Conservation ("DOC") and Horizons;

(d) attended community days in Dannevirke and Ashhurst;

(e) attended weekly ecology meetings with iwi Project partners;

(f) met with (via video-conferencing) representatives of Nakura Trust

Limited and Massey Farms Limited to investigate additional offset sites;

(g) met with Horizons, including Logan Brown and Kerry Pearce, to discuss

the Transport Agency’s response to section 92 requests regarding

sediment effects, and the Water Quality and Ecology Section 87F

Report prepared for Horizons by Mr Brown (“Freshwater 87F

Report”);1

1 Section 87F Report of Logan Arthur Brown – Water Quality and Ecology (Appendix 3 to the overall Section 87F Report prepared on behalf of Horizons).

(h) reviewed the condition set proposed by Horizons, and discussed these

(and updated proposed conditions on behalf of the Transport Agency)

with Ms Ainsley McLeod as they relate to freshwater ecology matters;

(i) following the receipt of submissions on the resource consent

applications, I have had further discussions with:

(i) DOC and their ecology experts, Dr Tim Martin and Nick

Goldwater, from Wildland Consultants (“Wildlands”);

(ii) Meridian Energy Limited (“Meridian”) and their ecology expert Dr

Leigh Bull; and

(iii) Queen Elizabeth the Second National Trust (“QEII Trust”) and

their ecology expert Shona Myers.

Code of conduct

6. I confirm that I have read the Code of Conduct for expert witnesses

contained in the Environment Court Practice Note 2014. This evidence has

been prepared in compliance with that Code. In particular, unless I state

otherwise, this evidence is within my area of expertise and I have not omitted

to consider material facts known to me that might alter or detract from the

opinions I express.

Purpose and scope of evidence

7. Technical Assessment H informs the regional consenting process by:

(a) describing the ecological values and characteristics of the freshwater

environment;

(b) identifying and assessing the actual and potential ecological effects of

the Project; and

(c) recommending measures to manage those ecological effects.

8. My evidence does not repeat in detail the technical matters set out in

Technical Assessment H. Rather, in this evidence I:

(a) present the key findings of Technical Assessment H in an executive

summary;

(b) provide updates to take into account information received and analysis

carried out more recently;

(c) comment on issues raised in submissions and section 274 notices

received in respect of the Project; and

(d) comment on the section 87F report prepared by Horizons.

EXECUTIVE SUMMARY

9. As noted above, in this section of my evidence I summarise the key matters

addressed in my Technical Assessment H, which assessed the effects of the

construction and operation of the Project on freshwater ecological values.

10. The Transport Agency is proposing to construct an 11.5 km road between

Ashhurst and Woodville via a route over the Ruahine Ranges. The Project is

intended to replace the indefinitely closed section of State Highway 3 ("SH3")

through the Manawatū Gorge.

Existing freshwater ecology environment

11. The Project alignment involves work within nine catchments of the Manawatū

River, including bridges across the Mangamanaia Stream and Manawatū

River.

12. Field surveys were undertaken in 2018 to inform reporting for the notice of

requirement ("NoR") phase. This involved fishing, stream ecological

valuations and macroinvertebrate sampling at eight sites across six

catchments.

13. Further field surveys were undertaken between August and November 2019

following refinement of the Project alignment (to provide for the 'Northern

Alignment') and footprint. Stream ecological valuations and

macroinvertebrate sampling were conducted at 26 sites. Fish surveys were

undertaken at six sites. Stream classifications and basic descriptions were

undertaken for almost all stream length under the Project footprint.

14. Most of the stream catchments are short and steep, with unvegetated

headwaters, modified through agricultural land use. The lower reaches of

these catchments are within the Manawatū Gorge Scenic Reserve ("MGSR")

(outside the Project footprint) and of markedly higher quality. QEII Trust

open space covenants over areas of bush within catchments 7, 6 and 4 are

also of high quality and effects are, for the most part, avoided. Many of the

stream systems are hard-bottom, however fine sediment deposition is

present in most catchments and is expected to influence the fauna present.

15. Macroinvertebrate indices varied across the alignment, with stream length

through areas of agricultural land use indicative of 'poor' to 'fair' water and

habitat quality. Parts of upper catchment 2C and 5 are of surprisingly good

quality with macroinvertebrate communities typical of good water and habitat

quality despite the surrounding land use.

16. Fish communities were more diverse in the lowland areas of Mangamanaia

Stream and Manawatū River. Existing natural and artificial barriers are

expected to have contributed to a reduced diversity in the upper reaches of

headwater catchments. Many of the headwater streams being affected by

the Project have narrow, intermittent channels offering temporary habitat.

Identifying, assessing and addressing effects

17. The potential effects on freshwater ecology resulting from the Project have

been assessed in terms of short- and long-term effects.

18. Short-term effects relate to effects during the construction phase which could

include fish injury and/or mortality, temporary fish passage restrictions, and

water quality effects resulting from sedimentation, hazardous substances and

cut vegetation storage. These construction effects can be minimised through

the implementation of fish salvage protocols, vegetation clearance (and

storage) protocols, hazardous substance procedures and good practice

sediment and erosion control measures. The proposed routine and

responsive monitoring at sediment ponds and within the environment will

assist in the management of potential sediment effects. The proposed

sediment monitoring regime has been updated since lodgment, as discussed

below.

19. Potential long-term effects anticipated to occur from the Project include

reduced fish passage, water quality effects, changes to hydrology and loss of

stream ecological function and habitat area. A variety of measures to avoid,

minimise and mitigate effects are proposed to be implemented, including

provision of fish passage, stormwater management approach developed to a

high standard, electing to construct stream diversions in preference to piping

and where these can be built ensure that they are designed and built so as to

deliver best practicable ecological and conveyance outcomes. The majority

of these proposed constructed stream diversion channels will be designed

and constructed to mimic existing natural situations.

20. While many of the potential effects have been avoided, or minimised and

mitigated to the extent possible, there are residual adverse effects resulting

from the loss and modification of stream habitat. These residual effects are

proposed to be addressed by additional measures aimed at achieving no net

loss of ecological function, referred to as the offset package.

21. The Stream Ecological Valuation ("SEV") and Ecological Compensation Ratio

("ECR") methods2,3 have been used to quantify the enhancement measures

required to achieve no net loss of ecological function by assessing ecological

'losses' at impact sites and ecological 'gains' resulting from the creation of

new stream habitat and enhancement of existing, degraded headwater

catchments.

22. Impacts on 13.207 km4 of intermittent and permanent stream can be offset to

achieve ‘no net loss’ in ecological function through the construction of Type 1,

2 and 3 stream diversions and riparian planting and fencing of intermittent

and permanent streams. The final location and precise composition of the

offset package will be determined following further discussions with

landowners. However, prior to lodgment of the application for resource

consents, two areas were identified (at Ratahiwi Farm and Sproull Farm)

which were modelled to show that sufficient stream length to achieve no net

loss in ecological function can be achieved.

23. One of the proposed enhancement planting sites (Ratahiwi Farm) is within

the Mangamanaia Stream catchment and would involve several headwater

gully systems being retired and planted. This would contribute to catchment

scale benefits beyond just the stream reach (and what the SEV method can

reasonably capture).

24. Further work has been carried out to identify, model and move towards

securing the necessary riparian planting offset locations since lodgment. I

describe the updated position later in this evidence.

25. During the construction process efforts will be made to refine the design to

further reduce effects on streams. Accordingly, the final amount of stream

offset required will be calibrated to reflect the effects of the Project and the

ecological gains that are achieved.

26. Overall I consider that the effects of the Project on freshwater ecology can be

avoided, minimised or mitigated and residual effects can be offset to achieve

a no net loss of ecological function. I consider that the measures proposed

are sufficient to address the effects associated with this Project and will result

2 Storey, R G, Neale, M W, Rowe, D K, Collier, K J, Hatton, C, Joy, M K, Maxted, J R, Moore, S, Parkyn, S M, Phillips, N and Quinn, J M (2011). Stream Ecological Valuation (SEV): a method for assessing the ecological function of Auckland streams. Auckland Council Technical Report 2011/009. 3 Neale, M W., Storey, R G and Quinn, J L (2016). Stream Ecological Valuation: application to intermittent streams. Prepared by Golder Associates (NZ) Limited for Auckland Council. Auckland Council technical report, TR2016/023. 4 Extent of stream impact reduced since lodgement in response to design changes, described below.

in a positive overall outcome within the immediate Manawatū River

catchment.

UPDATES AND FURTHER WORK CARRIED OUT SINCE LODGEMENT

27. Since the application was lodged, I have been involved in further work related

to freshwater ecology. I describe this briefly as follows.

Response to section 92 request for further information

28. In its section 92 request for further information dated 3 April 2020, Horizons

raised a series of requests for further information with specific focus on

sediment effects instream. Together with Mr Keith Hamill and Mr Campbell

Stewart, I addressed these requests related to potential sediment effects.

We discussed our proposed responses in a video-conference with Horizons

representatives on 20 April 2020. A key part of this was to provide further

clarification regarding the proposed monitoring regime. As a result, we

developed an Aquatic Ecological Monitoring and Responses flowchart to

complement the Aquatic Ecology Monitoring Protocols ("AEMP"), which are

part of the Freshwater Ecology Monitoring and Management Plan (“FEMMP”)

in the overall Ecology Management Plan ("EMP"). I discuss this in further

detail below, in my comments on Horizons’ Freshwater 87F Report.

29. As the freshwater ecology expert in the natural character team, I also

contributed to the responses prepared to Horizons’ request for further

information pertaining to natural character.

Further analysis and developments in respect of Project design and offset

proposed

30. At the time of lodgment two offset sites had been identified that provided a

substantial quantum of the stream offset (via riparian planting) determined to

be required (Ratahiwi Farm and Sproull Farm).

31. Since lodgment, there have been refinements to the design of the Project

(and associated riparian planting). There have also been further productive

discussions with the owners of Ratahiwi Farm and Sproull Farm to more

clearly define the areas available for riparian planting, and discussions with

additional landowners in respect of areas available for riparian planting.

32. I discuss these matters below, and give an updated position in respect of the

Project’s riparian planting requirements and available areas for that required

planting.

Design refinements

33. Since lodgment, two key changes have been incorporated into the design

which result in modifications to the length of culverts and stream diversions,

and subsequently the stream offset package:

(a) The roundabout at the eastern end of the alignment (“Eastern

Roundabout”) has been changed from a five-leg roundabout to four-

leg. Consequently there are changes to the length of culverts and

stream diversions within Catchment 1.

(b) Three features between Chainage 9500 and 9600 have changed. Spoil

Site 15 has been removed and the final configuration of Spoil Site 16

has been modified. Consequently the extent of stream impacted has

been reduced by approximately 60 m. Stream diversion SD-MC13-02,

(which was on Spoil Site 16) no longer provides ecological habitat

value and has been removed from the stream offset package.

34. The Transport Agency and Alliance have also had further discussions with

Meridian regarding planting proposed for the Project, some of which I have

participated in. Due to concerns expressed by Meridian regarding changes to

potential bird habitat onsite and proximity to turbines (discussed in more

detail in the evidence of Dr Matthew Baber), the Transport Agency has

agreed to remove some of the previously proposed stream diversion riparian

planting. Riparian planting has been removed from the stream diversions on

proposed Spoil Sites 25 and 28 (comprising 1,568 m of stream diversion).

These diversions will now be unplanted channels, likely to comprise either

rock lined or grassed cut-off drains. As such those diversions have been

removed from the proposed offset package.

35. I have updated the offset package to incorporate these changes, and to

reflect the updated position discussed below in respect of areas available for

riparian planting (of existing stream reaches).

Updated fish passage requirements

36. As a consequence of the changes outlined above, I have reassessed the

need for fish passage to be provided at CU-10 (downstream of Spoil Site 18),

CU-05 (downstream of Spoil Site 25) and CU-13 (downstream of Spoil Site

16). As the upstream channels will not provide suitable habitat for fish,

measures to provide for fish passage are no longer required at these

culverts. This change has been captured in the culvert and fish passage

requirements table I have included at Attachment JQ.1 (discussed below).

Updated natural character assessment

37. Within the team assessing natural character, I provided freshwater ecology

input, addressing three attributes; Exotic Flora and Fauna (“EFF”),

Indigenous Taxa Assemblages (“ITA”); Ecosystem Functioning (“EF”). The

removal of stream diversions and planting within the Te Āpiti Wind Farm

(described above) results in changes to the post-construction state as

considered within the natural character assessment (and as described by Mr

Evans in his evidence).

38. I have completed an updated assessment of these attributes considering

these changes, for each of Catchments 4 and 5, and the specific Crossing

Points 4D and 5B (Table 1 below), using the same approach as previously

described in Technical Assessment I. Commentary on the other attributes

and the overall natural character is provided within Mr Evans’ evidence.

Table 1: Changes to the freshwater ecology attributes to inform the natural character assessment.

Fre

sh

wate

r E

co

log

y

Att

rib

ute

*

Pre

-de

velo

pm

en

t

Po

st-

develo

pm

en

t (a

t

lod

gem

en

t)

Po

st-

develo

pm

en

t

(cu

rren

t s

cen

ari

o)

Comment justifying change in post-development ‘at lodgement’ and ‘current scenario’.

Catchment 4

EFF M M M Much of catchment remains the same, no change at catchment scale

ITA M ML ML Much of catchment remains the same, no change at catchment scale

EF M L L Much of catchment remains the same, no change at catchment scale

Crossing Point 4D

EFF M L VL Complete loss of stream habitat within the crossing point, unplanted channels may be favourable for exotic flora.

ITA M L VL Complete loss of stream habitat within the crossing point, unplanted channels likely to be unfavourable for indigenous taxa.

EF M VL VL Further loss of potential habitat values, but remain at VL.

Catchment 5

EFF H M L At catchment level, reduction in available habitat, unplanted channels may be favourable for exotic flora, planted stream diversions replace only 16% of impact length.

ITA H M L At catchment level, reduction in available indigenous fauna habitat, unplanted channels likely to be unfavourable for indigenous taxa, planted

stream diversions replace only 16% of impact length.

EF H M L At catchment level, reduction in available habitat, unplanted channels will not function like ‘natural’ streams, planted stream diversions replace only 16% of impact length.

Crossing Point 5B

EFF H L VL Further loss of potential habitat values, unplanted stream channel may be favourable for exotic flora, reduce to VL.

ITA H VL VL Further loss of potential habitat values, but remain at VL.

EF MH VL VL Further loss of potential habitat values, but remain at VL.

(*where natural character attributes are assessed as being very high (VH), high (H),

moderate-high (MH), moderate (M), moderate-low (ML), low (L) or very low (VL)).

Further discussion and updated position re Ratahiwi Farm and Sproull Farm

39. Since lodgment further conversations with the owners of Ratahiwi Farm and

Sproull Farm have more precisely identified details such as areas which are

confirmed as being available and practical for the landowner, fence line

locations, access requirements and preferred riparian margin widths. As a

result, the overall stream available for riparian planting on Ratahiwi Farm is

now confirmed in principle at 17.2 km (stream bed area of 8,334 m2).

Discussions to confirm the available area at Sproull Farm are ongoing, my

working assumption is that 6.5 km (stream bed area of 4,400 m2) is

available5.

40. This combined quantum of riparian planting addressed all of the adverse

effects anticipated at time of lodgment, to achieve no net loss of ecological

function as determined by the SEV and ECR methodology. However, in light

of the design changes noted above, the overall quantum of impact, and

length of stream diversion has changed:

(a) a reduction in impact has been achieved through the modifications at

Spoil Site 15 and the Eastern Roundabout, meaning 13,207 m of

stream length (8,230 m2 streambed area) is now being impacted;

(b) however, there has also been a reduction in the length / area of stream

diversions proposed to be planted. The updated position is that

approximately 2,250 m culverts are proposed, along with 6,021 m of

planted stream diversions (providing approximately 8,087 m2

streambed area).

5 Wetlands are also part of the offset package for these sites, and are discussed in the evidence of Mr Markham.

41. Overall, additional riparian planting of existing stream reaches at offset sites

is now required to achieve no net loss. Other sites have been identified to

provide for that additional planting, as discussed below.

Additional riparian planting offset sites

42. Two additional offset sites have been identified to provide the stream length

required for enhancement. These are:

(a) Wharite-Beagley Farm ("Beagley Farm") in the upper Mangapapa

catchment; and

(b) Massey Tuapaka Farm ("Tuapaka Farm") along the Manawatū River.

43. Attachment JQ.2 shows the locations of these sites in relation to the Project

(along with the location of Ratahiwi Farm and Sproull Farm, being the four

identified offset sites).

44. As described in Mr Lonnie Dalzell’s evidence, the owners of both properties

have expressed a clear willingness to make their land available for riparian

planting (and the ‘in perpetuity’ protection of that planting) for the Project.

45. Since lodgment, I have been involved in discussions with these additional

landowners and have overseen fieldwork on these sites (and Sproull Farm) to

confirm the appropriateness of the streams for riparian offset planting.

Fieldwork and analysis have involved:

(a) mapping of streams;

(b) assessment of approximate stream width (based on late summer

flows6) and restoration potential; and

(c) at some locations, SEVs have been undertaken.

Additional work undertaken to inform offset

46. For each of the four identified offset sites, the total ‘available’ stream length

has been mapped based on a review of aerial photography, and field

surveys, to identify actual stream extent following the approach described at

paragraph 73 of Technical Assessment H. I have followed the same

approach as described in Technical Assessment H in calculating the stream

riparian planting required to achieve no net loss of ecological function7. I

6 Stream assessments undertaken in late summer will have a narrower wetted stream width compared to stream widths assessed in winter/late spring. This means that the area of streambed habitat available for offset is likely to be an underestimate of that available, if the assessments had been undertaken winter/spring, which is the time at which impact sites were assessed. Confirmation of the wetted width during winter/spring will be provided in updated offset calculations. 7 Refer paragraph 104 to 113 of Technical Assessment H.

describe the specific approach undertaken for each of the offset sites as

follows.

47. Of the originally proposed approximately 23 km, 17.2 km has now been

confirmed as being available at Ratahiwi Farm:

(a) Fence lines and access tracks have been identified by the landowners.

(b) Building on work reported in Technical Assessment H,8 SEVm-P9

scores have been updated to reflect the proposed enhancement

measures including 20 m riparian planting and stock exclusion fencing.

48. Approximately 6.5 km of stream length is potentially available for

enhancement at Sproull Farm:

(a) Some of the stream length originally identified as being available at

Sproull Farm was determined to be inappropriate for enhancement.

Further, Mr Sproull acquired an additional property following our

original assessment. The available stream length reflects these

changes.

(b) SEVm-C10 scores have been determined by field survey at two

representative sites within the farm.

(c) SEVm-P scores have been modelled based on the proposed

enhancement measures. This includes either 10 m or 20 m riparian

planting and stock exclusion fencing. Some stream reaches have only

10 m margins to facilitate continued farm operation. SEVm-P scores

reflect these two riparian planted width scenarios.

49. Approximately 6.9 km of stream length is potentially available for

enhancement at Beagley Farm:

(a) Streams within one corner of the Beagley Farm were identified as being

appropriate for stream offset. This ‘corner’ is in the Upper Mangapapa

catchment and adjacent to the Ratahiwi Farm. All streams within this

part of the farm were mapped. There is more stream length available

for riparian planting within the wider Beagley Farm; that stream length

has not been mapped and is not included in the 6.9 km figure.

8 Refer paragraph 119 to 122 of Technical Assessment H. 9 SEVm-P is the potential (modelled) SEV value for the stream reach where the ecological offset measures are proposed. 10 SEVm-C is the current (measured or representative) SEV value for the stream reach where the ecological offset

measures are proposed.

(b) SEVm-C scores have been determined by field survey at two

representative sites. The permanent stream SEV was conducted within

the main stream flowing northwest to southeast. An SEV from the

neighbouring Ratahiwi Farm was used as a representative SEV for the

intermittent streams. This is because the intermittent streams have

similar characteristics and are located within the same catchment.

These representative SEV have been applied to permanent and

intermittent stream lengths within the farm.

(c) SEVm-P scores have been modelled based on the proposed

enhancement measures of 20 m riparian planting and stock exclusion

fencing.

50. Approximately 28 km of stream length is potentially available for

enhancement at Tuapaka Farm:

(a) Possible stream length available for enhancement has been mapped

based on aerial photographs. Fencing constraints resulting from steep

topography, existing easements and ongoing post-graduate research

may restrict use of the full 28 km of estimated stream length for offset.

Notwithstanding, discussions with the farm manager have been positive

and indicate that a substantial quantum of stream length is available

across the site. Approximately 11 km of stream has been ‘ground

truthed’ through field surveys and is considered appropriate for offset.

SEVm-C scores have been determined by field survey at two

representative sites, one on a permanent stream and one on an

intermittent stream11. These representative SEV have been applied to

permanent and intermittent stream lengths within the farm.

(b) SEVm-P scores have been modelled based on the proposed

enhancement measures 20 m riparian planting and stock exclusion

fencing.

51. These sites are shown on Attachment JQ.2. The data collected from each

site has been used in determining the updated indicative proposed offset

package (which I have set out below).

11 Stream ecological valuations on intermittent streams are recommended to be undertaken between July and October when peak flows are present. SEV undertaken at some of the offset sites were undertaken outside this recommended timeframe. SEV were undertaken only in reaches where water was present and were comparable in value to SEV undertaken during the appropriate timeframe. Therefore I consider that the SEV are representative of the current, and consequently potential, ecological values likely to be gained following enhancement.

52. The final composition of the offset package will be finalised in consultation

with landowners and iwi Project partners. For the purposes of providing

confidence that no net loss of ecological function can be achieved, ECR have

been calculated using stream length in the following order; Ratahiwi Farm,

Sproull Farm, Beagley Farm, and Tuapaka Farm.

Updated overall position

53. I have updated the offset calculations proposed in Technical Assessment H

to reflect the design changes and updated position in respect of offset sites

outlined above. In the order of 34.3 km of stream (streambed area of 17,386

m2) riparian planting is proposed to achieve no net loss of ecological function.

54. For each of the 194 impact reaches a corresponding offset reach has been

identified to provide a 'loss' to 'gain' specific ECR and corresponding offset

amount to achieve no net loss. This is summarised by catchment in Table 2

below. An updated version of Appendix H.4 (from Technical Assessment H)

has been appended to this evidence as Attachment JQ.3 which identifies

the relative impact and offset reach and Attachment JQ.4 which identifies

the SEV values predicted at each site.

Table 2: Summary of updated proposed offset and range of ECR calculated for each catchment.

Catchment Streambed area impacted (m2) (‘loss’)

Proposed offset measures (‘gain’)

ECR range

Catchment 1

922 1,581 m2 streambed enhancement via riparian planting

567 m2 new stream creation

1.09 to 2.91

Catchment 2


1,492 m2 new stream creation

1.28 to 5.32

Catchment 3

181 348 m2 streambed enhancement via riparian planting


2.03 to 5.36

Catchment 4



1.41 to 6.60

Catchment 5



2.10 to 6.62

Catchment 6


3.7 to 5.25

Catchment 7

639 177m2 streambed enhancement via riparian planting


1.97 to 2.98

Catchment 8



1.01 to 2.06

Catchment 9


5.25

55. In sum, the updated stream12 offset package includes riparian planting of

existing stream length across four sites13 as follows:

(a) Ratahiwi Farm: 17.2 km stream planted to 20 m margins;

(b) Sproull Farm: 6.5 km stream planted to 10 m or 20 m margins;

(c) Beagley Farm: 6.9 km stream planted to 20 m margins; and

(d) Tuapaka Farm: 3.7 km stream planted to 20 m margins.

56. I consider that the offset proposed across these four sites is consistent with

the offsetting principles, as described at paragraph 303 of Technical

Assessment H and repeated here for ease of reference:

(a) Stream enhancement results in an improvement to habitat that is

ecologically equivalent to that being impacted, so meeting the principle

12 Wetland enhancement is also proposed at some of these sites and is discussed in the evidence of Mr Markham. 13 The final quantum of riparian planting provided at each site will be confirmed in discussion with landowners.

of ‘like for like’. Each site includes a combination of intermittent and

permanent, headwater streams.

(b) The enhancement works would not otherwise be undertaken, so the

works are additional.

(c) The enhancement is, for the most part, at a gully scale demonstrating

ecological benefit beyond the reach scale. The ecological benefits

gained by the proposed offset riparian planting package has been

quantified as providing no net loss of ecological function.

(d) These sites are all within the Manawatū catchment and more

specifically in catchments where impacts are occurring. Therefore the

principle of proximity is met and the ecological benefits will be

measurable within the impact catchment.

(e) There are benefits beyond those measured using the SEV and ECR

accounting framework, including reduction in nutrients, temperature

and water quality improvements at a large scale, reduction in

sedimentation, and connecting existing ecosystems to improve

corridors, which has benefits for terrestrial fauna as well.

57. Discussions are continuing with all four landowners to confirm the extent,

location and composition of the riparian planting proposed. As these

discussions progress, final fencing alignments, riparian margin widths and

legal agreements will be confirmed. Updated SEV and ECR calculations will

then be undertaken to verify the ecological gains offered at each farm to

ensure no net loss of ecological function.

58. The proposed resource consent conditions14 provide certainty that despite

some currently ‘moving parts’, there are processes in place to ensure the

outcome of no net loss of ecological function will be achieved.

Updated EMP

59. The EMP has been updated in response to submissions and the changes

outlined above. Specifically I have updated the following:

(a) the FEMMP, and in particular the AEMP15 to include the new Aquatic

Ecological Monitoring and Responses flowchart and refinements to the

monitoring regime – for ease of reference I also attach that updated

flowchart to my evidence as Attachment JQ.5;

14 Proposed resource consent conditions EC15(c) and (d). 15 Section 10.7 of the EMP.

(b) the Fish Recovery Protocols ("FRP"16) in response to the submission

from DOC (see below);

(c) Table 10-2 to remove the stream diversions no longer considered part

of the offset package (discussed above) and to confirm riparian widths;

and

(d) sections17 related to the offset sites and quantum of riparian planting

being proposed.

60. Like all updates to the version of the EMP that was lodged with the consent

applications, these updates are shown as ‘tracked changes’ in the updated

EMP attached to the evidence of Dr Baber.

COMMENTS ON SUBMISSIONS / SECTION 274 NOTICES

61. I respond below to freshwater ecology matters raised in submissions on the

Project made by:

(a) DOC (and Wildlands on behalf of DOC);

(b) Meridian;

(c) Royal Forest & Bird Protection Society of New Zealand Inc ("Forest

and Bird");

(d) QEII Trust; and

(e) Dr Samuel Hill.

62. In a later section of my evidence I comment also on the Freshwater 87F

Report, specifically in respect of freshwater ecology matters.

63. Additional commentary on these submissions and the Freshwater 87F Report

are made by others in their evidence including:

(a) Dr Baber, in relation to terrestrial ecology values and effects;

(b) Mr Markham, in relation to offset and compensation proposed to

address terrestrial ecology effects;

(c) Mr Campbell Stewart in respect of erosion and sediment controls;

(d) Mr Hamill in relation to water quality;

16 Section 11 of the EMP. 17 Section 12 of the EMP.

(e) Mr David Hughes in relation to stormwater and fish passage; and

(f) Mr McGahan and Ms McLeod in respect to planning and condition

matters raised.

Director-General of Conservation

64. The DOC submission (which includes a memorandum prepared by Wildland

Consultants) ‘generally supports’ the approach to addressing effects on

freshwater ecology18. I am pleased that DOC is in this position, which in my

view reflects the time taken by DOC and Wildlands to discuss the Project with

the Transport Agency and its consultant experts in the lead-up to lodgment.

That open dialogue was very helpful and provided an opportunity to respond

to potential concerns up-front.

65. Notwithstanding its general support, DOC raises some concerns (largely

relating to matters of detail) in its submission that warrant further

commentary, which I provide below. The relevant submission points relate

to:19

(a) Details in respect of riparian planting (minimum width and area, and

time to establish the canopy and DOC’s ability to review draft plant

schedules);

(b) Independent review of culvert design in respect of fish passage;

(c) Details in respect of fish trapping and relocation methodology (as well

as rat control at any kākahi relocation sites); and

(d) Critical standards / controls being included in conditions rather than left

to the EMP (a matter which is addressed primarily in the evidence of

Ms McLeod).

Riparian offset planting details

66. DOC’s submission states that the methodology proposed for offsetting

residual effects of stream loss “follows key principles of best practice”, and

that the “‘catchment scale’ approach to the restoration of headwater gullies”

is particularly supported20. I consider that the proposed updated offset

package across the four different farms maintains this catchment scale

approach and targets gully systems as much as practicable.

18 DOC submission at paragraph 20. 19 DOC submission at paragraphs 21 – 25. 20 At paragraph 21.

67. DOC’s outstanding concerns regard the details of the proposed conditions

related to riparian planting (Condition EC15). DOC seeks:

(a) A minimum width for riparian planting, as well as a minimum overall

area of riparian planting; and

(b) A shorter post-construction period to achieve 80% canopy cover.

68. Proposed Condition EC15 establishes the standards for the offsetting of

residual effects on freshwater ecology values (the detailed methods for

achieving and measuring the outcomes are specified in the EMP)21. Clause

a(i) relates to new stream channel and clause a(ii) relates to stream

restoration.

69. For new constructed stream channels, the riparian width of margins (for each

bank) is provided in Table 10-2 of the FEMMP (Section 10 of the EMP).

Table 10-2 confirms that no margin is less than 5 metres in width on either

bank. Proposed Condition EC15(a)(i) has been updated to reflect this

minimum.

70. In respect of stream restoration, the SEV/ECR calculations include modelled

potential values based on the riparian margin widths the landowners are

willing to offer, as discussed above. Where the width is narrower, the amount

of stream required to be restored increases, and vice versa. In speaking to

landowners, I have sought a 10 m minimum width, but it is important and

appropriate to remain flexible in order to secure the necessary landowner

agreements.

71. In respect of providing a minimum area of riparian planting, my preference is

to refer instead to the area of streambed that is required to be enhanced to

achieve no net loss. This is because the aquatic habitat is the feature being

impacted, whereas the riparian margin is a means to addressing the effect.

The SEV/ECR drives the area of streambed required to be restored, which in

turn, determines the area of riparian planting at a given margin width.

Condition EC15(c) provides for changes to be made based on this method.

72. Condition EC15(b)(iv) has been worded to provide confidence that all riparian

planting will be at 80% cover within 10 years of construction commencing,

rather than from the time plants go into the ground. The intention of this was

not to have a long establishment period, rather a performance standard

against a common starting point. A suggested alternative would be to edit to

21 In particular, the FEMMP (Section 10.6.1), the Planting Establishment Management Plan (Chapter 4), the REMMP (Chapter 12).]

read “riparian planting must achieve an 80% canopy cover within 10 five (5)

years following the completion of planting at the site”. I have discussed this

condition amendment with Ms McLeod, who has reflected it in her updated

set of proposed conditions.

73. Finally, riparian plant schedules were provided via email to Dr Martin

following lodgment. These were discussed in further detail on 14 May with

DOC. DOC raised concerns regarding the appropriateness of the species

proposed, with emphasis on whether the species were appropriate to the

ecological district.

74. For riparian planting, while the species are important to achieve terrestrial

biodiversity objectives, I am most concerned with the riparian margins

contributing to the aquatic ecological function, achieved by appropriate

densities, survival and riparian margin width. Mr Markham and Dr Baber

have worked with DOC and its consultants to further develop the plant

species list and I rely upon their assessment.

Culvert design and fish passage

75. I have discussed the culvert and fish passage design with Mr Hughes and

his team. I understand that culvert design work is well underway, but that

further work is required to confirm the specific details of each culvert.

Attachment JQ.1 shows the basic fish passage provisions proposed22.

However, I support that proposed review by an independent fish passage

specialist. I discuss this further in the context of the Freshwater 87F Report.

Fish and kākahi trapping and relocation methodology

76. I have no objection to specifying fine-mesh fyke nets in the fish recovery

methodology. The proposed fish salvage method will be determined on a

site-by-site basis depending on the available habitat, fauna expected and

extent of works. The FRP (in the EMP) have been updated to reflect this.

77. It is unlikely that kākahi will be found in the streams being impacted as they

have not been identified to date and the majority of streams being impacted

are intermittent, cobble bottom streams. Kākahi burrow into sediment and so

are typically found in parts of rivers where the bed is sandy or silty. They also

rely on certain fish species as part of their lifecycle, and only a low diversity of

fish have been recorded within the Project area. Therefore, the kākahi

protocol was included as a back stop ‘just in case’.

22 Attachment JQ.1 is a simplified version of the table submitted as Table H.14 of Technical Assessment H to reflect the fish passage provisions specifically.

78. I do not consider it necessary for rat control to be specifically required to be

undertaken at release sites prior to kākahi being transferred. I note that Mr

Brown (in the Freshwater 87F Report) states that he is not confident that rat

control to benefit relocated kākahi is practical, or a reasonable requirement.23

That being said, in the event that kākahi are found, there is an opportunity to

take advantage of pest control that is already proposed to be carried out in

relation to the Project. With that in mind, the FRP have been updated to

include specific reference to kākahi being preferentially located to suitable

habitat in areas where pest control is being undertaken.

Meridian Energy Limited

79. Meridian raises concerns centered around the creation of additional wetland

or forest bird habitat that could potentially result in increased bird strike

through turbine collisions. For the most part, these concerns are addressed in

Dr Baber’s evidence.

80. Of relevance to freshwater ecology is that much of the proposed ‘forest bird

habitat’ is associated with riparian planting along proposed stream diversions.

The stream diversions (and associated riparian planting) are proposed to

contribute to the offset package to address effects resulting from stream

habitat loss and modification. One of the key principles of offsetting is that of

proximity, being that offset measures are undertaken close to the impact. The

Te Āpiti Wind Farm is located across catchments 4 to 6, and so was one of

my first choices for offset measures.

81. Stream diversions within the Te Āpiti Wind Farm are required to facilitate

natural flows from streams around, under, or along the road alignment. As

part of the constructed part of the Project, these diversions were considered

appropriate to be planted and therefore provide ecological function to

contribute to the offset package.

82. The stream diversions (and associated riparian planting) are a key

component of the offset package designed to address stream habitat loss.

The diversions (and associated planting) provide new habitat which replaces

that being lost, which differs from riparian planting of existing stream reaches,

which provides for enhancement of existing habitat.

83. Stream diversion planting within the Te Āpiti Wind Farm was proposed to be

of vegetation no greater than 1.5 m in height. That was intended to mirror the

23 At paragraph 144(b) of the Freshwater Section 87F Report.

NoR condition in relation to landscape planting within the Wind Farm, 24

thereby recognising Meridian’s concerns in respect of possible turbine strike

and ‘reverse sensitivity’ as expressed through the NoR process. Similarly,

riparian planting along existing stream channels within the Te Āpiti Wind

Farm was not proposed.

84. Notwithstanding the efforts to limit the planting extent (to only constructed

streams) and with short stature vegetation, Meridian maintains that there

remains risk of bird strike which might trigger ‘reverse sensitivity’ issues in

respect of the Wind Farm (including possible future repowering of the Wind

Farm)25.

85. Following several discussions with Meridian, proposed riparian planting along

some of the originally proposed stream diversions has been removed (as

described above). In sum, 1,796 m of stream diversion planting (of an original

2,874 m within Te Āpiti Wind Farm) has been removed, leaving 1,078 m

constructed stream channel along the road edge with planted riparian

margins of no more than 10 m on each bank.26 I note that most of the

planting that has been removed is on land over which Meridian has property

rights that allow it to prevent any planting; as such I see little merit in

continuing to propose that planting in light of Meridian’s position.

86. I understand that Meridian and Dr Bull are comfortable with this updated

configuration of the riparian planting within the Te Āpiti Wind Farm site.

87. As explained above, I have changed the stream offset package to account for

the updated configuration of stream diversions (and associated riparian

planting) within the Te Āpiti Wind Farm site.

Royal Forest & Bird Protection Society of New Zealand Incorporated

88. Forest and Bird raise several points of concern in respect of freshwater

ecology in their submission,27 primarily around two key points:

(a) A concern that the freshwater ecology assessment of species and

values is ‘inadequate’; and

(b) Concerns regarding the location and number of spoil sites across the

Project and what freshwater ecological values may be impacted.

24 Designation Condition 17(b)(v), which generally limits planting required by the Landscape Management Plan to 1.5 m in height at maturity within the Wind Farm (unless otherwise agreed by Meridian). 25 Discussed further in Dr Baber’s evidence. 26 I understand that this retained proposed planting is all located on land the Transport Agency intends to acquire on a permanent basis under the Public Works Act 1981. 27 See in particular paragraphs 20 – 23 of the Forest and Bird submission.

89. In sum, Forest and Bird state that without further information, the actual and

potential effects of the Project on freshwater ecology cannot be adequately

assessed. I address this point and those above with reference to the more

detailed points, below.

90. As discussed by Mr Dalzell in his evidence, the Transport Agency attempted

unsuccessfully to arrange a meeting with Forest and Bird to discuss its

submission points. As such, my responses below relate to the written

submission only and do not reflect any discussions with Forest and Bird.

Adequacy of assessment

91. Forest and Bird’s submission contends that the assessment of freshwater

ecology species and values is inadequate, referring to the following specific

matters:

(a) freshwater invertebrates and native freshwater plants:

(i) presence and threat status;

(ii) what actions are being taken to avoid / remedy / mitigate (ahead

of offset) effects on invertebrates and plants, and limits to

offsetting and compensation to give effect to section 6(c) of the

RMA; and

(b) freshwater fish:

(i) the potential for additional fish species to be present, by

reference to the lack of DNA testing in streams, and to an

analysis of DOC’s Freshwater Environments of New Zealand

("FENZ") predictions for the likely presence/absence of native fish

species.

Freshwater invertebrates and plants

92. Forest and Bird raise concerns that a full species list of freshwater

invertebrates and freshwater plants and associated threat status has not

been provided.

93. Macroinvertebrate data collected for the Project followed standard sampling

and processing protocols28 to determine overall stream health and ecological

value. This method does not provide for a species level of taxonomic detail

required to compare to the conservation status. For many taxa or younger

28 As described at paragraphs 78 - 85 of my Technical Assessment H

instars,29 identification to that level is either not easy or impossible30. This is

reflected in the DOC Threat Classification, where just under 40% of the

freshwater invertebrates are data deficient or have the qualifier ‘data poor’31.

94. I agree that protection of threatened species should be a consideration of the

Project. One of the biggest threats to freshwater invertebrates is modification

of habitats32. Noting the aforementioned issues with the threat classification

when applied to freshwater invertebrates, I consider that retaining similar

habitats to those being impacted is likely to protect similar macroinvertebrate

communities33. That is, if threatened macroinvertebrates are present in the

impact areas, they are likely to also be present upstream or downstream in

similar habitats that are being retained.

95. The majority of New Zealand’s threatened native freshwater-dependent

plants are found in wetlands or lakes;34 my comments here relate to stream

systems.

96. During field surveys, the proportion of each stream reach with macrophytes

(aquatic plants) was recorded as 0, 0 to 25, 25 to 50, or >50% coverage.

Photos were taken of these habitats and visual assessments undertaken,

however taxonomic surveys to determine community composition were not

undertaken. Those reaches with higher coverage of macrophytes were those

that were heavily influenced by agricultural landuse. Given that habitat

degradation, including through eutrophication, is a ‘major contributor’ to

decline of native aquatic plants35, it is very unlikely that any of the aquatic

plants encountered are threatened or at risk. As for macroinvertebrates, if

threatened aquatic plants are present in the impact reaches, they are likely to

also be present upstream or downstream in similar habitats that are being

retained.

97. Not every component of an ecosystem can be captured when quantifying

ecological value and offset requirements. Sufficient investigation has been

undertaken to determine the ecological values of the different catchments

29 Instar = a stage in the life of arthropods between two periods of moulting (shedding of the exoskeleton in order to grow). 30 Pers comms J. D. Stark. Via email, 6 May 2020. 31 Grainger, N, Collier, K, Hitchmough, R, Harding, J, Smith, B, & Sutherland, D (2014). Conservation status of New Zealand freshwater invertebrates, 2013. New Zealand Threat Classification Series 8. Wellington: Department of Conservation. Retrieved from www.doc.govt.nz. 32 Collier, K.J., Probert, P.K. and Jeffries, M. (2016). Conservation of aquatic invertebrates: concerns, challenges and conundrums. Aquatic Conservation: Marine and Freshwater Ecosystems. 26: 817-837. (DOI: 10.1002/aqc.2710) 33 Supported by J D Stark. 34 https://niwa.co.nz/freshwater-and-estuaries/freshwater-and-estuaries-update/freshwater/update/freshwater-update-56-january-2013/conserving 35 Gerbeaux, P., Champion, P., and Dunn, N. (2016) ‘Conservation of fresh waters’ in. P. G. Jellyman, T.J.A. Davie, C.P. Pearson, J.S. Harding (eds) 2016. Published by New Zealand Freshwater Sciences Society and New Zealand Hydrological Society, pg 573.

https://niwa.co.nz/freshwater-and-estuaries/freshwater-and-estuaries-update/freshwater/update/freshwater-update-56-january-2013/conserving

https://niwa.co.nz/freshwater-and-estuaries/freshwater-and-estuaries-update/freshwater/update/freshwater-update-56-january-2013/conserving

being impacted. I consider that similar communities are likely to be present in

downstream reaches, compared to impact reaches. Therefore, the ecological

values of these catchments will remain in the stream reaches being retained.

98. For those values that are not specifically addressed, the ‘like for like’

approach to offsetting requires that habitat types being enhanced are similar

to those being impacted, and therefore the ecological values are likely to be

addressed. I am comfortable that the approach to effects management is

appropriate.

Freshwater fish

99. Forest and Bird suggested some additional data and methods to complement

the freshwater fish data obtained (DNA testing, and reference to FENZ data

which Forest and Bird has provided). DNA testing can provide further

certainty regarding particularly cryptic species or in areas where surveying

can be challenging. I do not consider it is necessary in this case as surveys

were undertaken in relatively confined aquatic systems, and supplementary

data from the NZ Freshwater Fish Database ("NZFFD") was used to inform

my analysis of species likely to be present but which were not captured

during Project specific surveys36.

100. The FENZ data supplied by Forest and Bird provides further confidence that

the species expected to be present based on those either identified during

surveys or recorded in the NZFFD are accurate. Interestingly, FENZ did not

predict redfin bullies, despite them being recorded within the Project surveys.

There are two additional species predicted to be present by the FENZ data,

Cran’s Bully and inanga.

101. Inanga are classified as At Risk Declining. They typically do not travel far

inland, rather sticking to coastal areas37, as they are limited by their poor

climbing ability. There are a few NZFFD records adjacent to the Project area:

(a) two records in the upper Pohangina River are from sites at just over

200 metres above sea level, near the maximum elevation for this

species; and

(b) one additional record downstream of the Project.

102. If inanga were present, I expect they would be only in the lower lying reaches

of the Pohangina River or the Manawatū River as they are poor climbers.

Catchments 3 through 7 are highly unlikely to have any inanga, given the

36 Combined NZFFD and survey data presented at Table H.5 of Technical Assessment H. 37 https://niwa.co.nz/freshwater-and-estuaries/nzffd/NIWA-fish-atlas/fish-species/inanga

presence of natural barriers which will restrict access. It is my view that, the

Project area is not a population stronghold however if inanga were identified

during salvage, they would be relocated as per the FRP.

103. Cran’s bullies have been recorded in neighbouring Mangapapa Stream and

Pohangina River catchments. Like the upland bully, Cran’s are non-

diadromous, and their ability to move between different river systems is

limited.

104. The potential presence of these additional species does not change the

ecological values, my assessment of effects or the proposed approach to

effects management as set out in Technical Assessment H. I note that Mr

Brown (for Horizons) considers that ‘the fish monitoring information and

related conclusions drawn in the application regarding fish population are

robust’38.

105. Overall, I am confident we understand the species likely to be present within

the Project area and that the measures proposed to address effects on fish

are sound.

Spoil sites

106. Forest and Bird expresses concern in respect of the number, location and

selection of spoil sites (with a particular focus on spoil site 25), and an overall

lack of clarity as to the Project’s proposed approach to spoil management. I

acknowledge that the discussion regarding spoil site 25 (at paragraph 165 of

Technical Assessment H) was brief; I provide clarification here, but also refer

to Appendix C to the Design and Construction Report (Volume II of the

application documents) for further discussion regarding spoil site selection.

107. I understand that fifteen39 spoil sites are proposed for the Project, out of 31

that were originally under consideration. The final locations of spoil sites were

determined using a multicriteria analysis ("MCA"), which included ecological

considerations (as described at paragraph 164 of Technical Assessment H).

One of the initial pieces of advice provided by the ecology team in relation to

spoil site selection was to seek to avoid streams and wetlands. This was

factored into the MCA.

108. Specifically in relation to Spoil Site 25, as Catchment 5 was recognised as

having a higher ecological value than other spoil sites, an alternative option

was explored in further detail. I led the freshwater ecological discussions on

38 At paragraph 142(b) of the Freshwater 87F Report. 39 At time of lodgement, 16 sites were identified, but as described above and in the evidence of Mr Watterson Spoil Site 15 has been removed from the Project.

the consideration of the alternative Spoil Site 8 option. When asked to

determine my preference between Spoil Site 25 and Spoil Site 8, I

considered that Spoil Site 25 had less adverse freshwater ecological effects

than Spoil Site 840. Spoil Site 8 would have resulted in a larger streambed

area being impacted and would more severely fragment the catchment,

impacting fish passage and ecological connectivity.

109. Forest and Bird also refer to concerns regarding long-term erosion and

sediment loss resulting from stream diversions on spoil sites. During

construction, erosion and sediment controls will be in place to reduce

potential sediment loss (described by Mr Stewart). Post-construction, the

stream diversions will be stabilised and will be constructed to mimic the pre-

construction environment and in line with Stream Design Principles (outlined

at section 10.6.1 of the FEMMP within the overall EMP). Therefore, I consider

that there are no inherent risks to freshwater ecology relating to long-term

erosion and sediment from stream diversions.

110. I have assessed actual and potential freshwater ecology effects resulting

from the 15 proposed spoil sites, and these have been addressed within my

Technical Assessment H. The proposed approach ensures that freshwater

ecological effects are mitigated or offset, and achieves no net loss of

ecological function.

QEII Trust

111. QEII Trust has raised four key points of concern pertaining to freshwater

ecology in its submission:41

(a) that adverse effects on stream values in the two areas subject to QEII

open space covenants (within the Project footprint) have not been

adequately addressed;

(b) that sedimentation effects will be high, and have been underestimated

due to an “overall” approach to effects assessment;

(c) monitoring of sediment and erosion controls should include contingency

measures, in the event the controls are inadequate; and

(d) the riparian planting proposed (at Ratahiwi Farm) is in a different

catchment to the impact, the location is still to be confirmed and no

contingency is provided.

40 Explained at paragraph 165 of Technical Assessment H. 41 Refer to paragraph 4 of Attachment 1 to the QEII Trust submission.

112. I address each of these points below.

Addressing adverse effects including sedimentation

113. Beyond the general points raised in respect of sedimentation effects and

monitoring of sediment and erosion controls, I am unsure as to the basis on

which QEII Trust consider that adverse effects on stream values within the

open space covenants have not been adequately addressed. The

assessment of effects across all freshwater systems is, in my opinion,

commensurate with the scale and significance of the Project.

114. To ensure that the different ecological values of the various catchments is

accurately captured, including those with high ecological values in the open

space covenants, I have undertaken the effects assessment at a catchment

scale. In following the Ecological Impact Assessment Guidelines (“EcIAG”),

a transparent and consistent approach to the effects assessment has been

applied. In discussion with QEII Trust’s expert, I understand that the use of

this assessment methodology is supported.

115. In respect of sedimentation effects, my approach to the effects assessment

has followed the EclAG which has been prepared by independent,

experienced impact assessment practitioners42. I consider that it is an

appropriate methodology to use as it is transparent and standardised,

providing for consistency in approach.

116. In preparing Technical Assessment H, I engaged in detailed discussions with

Mr Stewart and Mr Hamill in respect of the sedimentation that the Project

may generate, and the measures in place to address those potential effects. I

assessed the potential magnitude of change resulting from sediment effects

for each of the affected catchments, as per the EcIAG. In respect of

catchments 6 and 7 specifically, I determined that during construction the

effects are likely to be of a ‘moderate’ magnitude, being representative of a

‘partial change’ in the receiving environment during the construction period.

When considered against the ‘high’ ecological value of these QEII Trust open

space catchments, this results in an overall effect of ‘high’ in these

catchments during the construction period.

117. This has been reported in Table H.12 of Technical Assessment H but I note

that the ‘overall effect’ for catchment 6 was incorrect and should be ‘high’.

The same approach has been applied to all other catchments, with the

42 The use of the EcIAG in assessing the effects of this Project is explained at paragraph 56 to 63 of Technical Assessment H.

magnitude varying between low and moderate depending on the scale of

works proposed. I note that Mr Stewart considers that the sediment yield

estimates used, which have informed my assessment, are likely to be an

overestimate of the sediment that could be discharged to the environment.

Therefore, I do not consider that the ecological effects have been

underestimated and I am of the opinion that the approach to effects

management (set out further below) is appropriate.

118. I discuss sediment and erosion controls, including in respect of contingency

measures, in response to the Freshwater 87F Report below. That discussion

includes specific reference to catchments 6 and 7, and detail regarding the

proposed receiving environment monitoring has been provided. This includes

more information related to what measures will be implemented if effects are

greater than those anticipated.

Riparian planting locations and certainty

119. QEII Trust raises concerns about the proximity of the proposed offset riparian

planting to the affected streams, that the sites for riparian planting are still to

be confirmed, and that no contingency or alternatives have been provided43.

QEII Trust also raises questions about mechanisms to secure offset sites

generally, and to ensuring offset measures deliver intended outcomes44.

120. I have set out above the updated position in respect of intended riparian

planting offset sites.

121. The offset principles include consideration of landscape context, including

proximity to impact site, but do not strictly detail ‘how close is close enough’.

In some instances, “spatially distant offsets may provide the best

conservation outcome” and therefore may be a more appropriate option45.

That said, in my view, the intended riparian planting sites are appropriately

proximate to the Project / impact site. In terms of the impacted catchments

within QEII Trust open space covenant areas:

(a) Stream habitat modification/loss within catchment 7A specifically is

completely offset through diversions (which will be planted) located

within Catchment 7. Riparian planting is not proposed for the QEII

areas specifically, therefore all of the effects within the QEII area are

offset within the immediate catchment.

43 Paragraph 4(d) of Attachment 1 to the QEII Trust submission. 44 Paragraph 5(j) and (k) of Attachment 1 to the QEII Trust submission. 45 Maseyk, F, Ussher, G, Kessels, G, Christensen, M, and Brown, M (2018). Biodiversity offsetting under the Resource Management Act – A guidance document September 2018

(b) Offsetting for Catchment 6 offset relies on riparian planting of existing

stream lengths as diversions are not proposed within the catchment.

The remainder of Catchment 6 is either within Te Āpiti Wind Farm land

(where riparian planting of existing stream lengths is not proposed, as

discussed above), or existing ecological values are high and therefore

planting will not achieve demonstrable ecological improvement.

122. Across the wider Project area, diversions have been targeted within the same

or adjacent catchments as impacted streams in the first instance. Riparian

planting of existing stream length at offset sites is only proposed for those

effects that cannot be addressed by diversions. Due to existing legal

restrictions within some parts of the alignment, riparian planting cannot be

undertaken within the relevant catchment. As a result, areas close to the

Project area were identified for restoration. Ratahiwi Farm is one such site; it

is located in the upper reaches of Catchment 2, which is affected by the

Project.

123. As discussed above, since lodgment I have been involved in further

discussions with landowners near the Project to secure additional restoration

sites. Riparian planting of existing stream is proposed at Ratahiwi Farm,

Sproull Farm, Beagley Farm and Tuapaka Farm.

124. These sites are all within a short distance of the Project area and within the

Manawatū River catchment. The stream offset sites are located within the

same Water Management Zones as the impacts being Mana_9c (Catchment

2, Ratahiwi Farm) and Mana_10a (being Catchments 3 to 8, Sproull Farm,

Tuapaka Farm). Beagley Farm and a small portion of Ratahiwi Farm are

located in the upper reaches of the Mangapapa catchment (Mana_9b),

referred to in my assessment as Catchment 1. I consider that the ecological

benefits gained at the offset sites contribute to the same environment as

those being impacted and the approach to freshwater ecology offset is

consistent with the offset principle of proximity.

125. I understand that the riparian planting sites, including their permanent

protection, will be secured through formal agreements with the landowners,

and a registered title instrument (so that the agreement binds any

subsequent owners). This is consistent with the approach taken on previous

Transport Agency projects and provides certainty in respect of the ongoing

protection of the riparian planting.46

46 Including the Mt Messenger Bypass Project and the Peka Peka to North Ōtaki Expressway project.

126. Where planting is proposed outside the designation corridor, on land not

intended to be acquired by the Transport Agency (as with all the offset

riparian planting to occur along existing streams on the aforementioned

Farms), the riparian planting agreements will be entered into on a voluntary

basis. As explained above, discussions with the four identified landowners

are well progressed and the ecological gains expected at each site have

been modelled to inform the overall quantum. There is also additional area

potentially available for riparian planting at these sites, should that ultimately

prove necessary following the process set out in conditions for confirming the

necessary extent of riparian planting. Similarly, stream diversions will be

constructed in line with stream design principles to provide instream habitat

and to achieve ecological gains.

127. As discussions continue, Site Specific Ecology Offset and Compensation

Plans (“SSEOCPs”) will be developed for each of the properties utilised for

riparian planting, to confirm the final extent and type of riparian enhancement,

location of fences and timeframes for implementation.47 The SSEOCPs will

include clear direction in respect of intended outcomes and measures of

success, including (but not limited to) the integrity of the riparian planting.

SSEOCPs will be prepared in consultation with Project iwi partners and DOC;

and subject to certification by Horizons.48

128. The performance measures proposed to ensure those outcomes are

achieved are included in the Residual Effects Management and Monitoring

Plan (“REMMP”) (section 12 of the EMP) and conditions of consent.49

Dr Samuel Hill

129. Dr Hill raised overall concerns about impacts the Project will have on ecology

and more specifically the loss of old-growth forest and wetlands.

130. Dr Hill refers to reports prepared in respect of the NoR phase, following which

the alignment was modified to reduce effects on old growth forest. Dr Baber

addresses this further in his terrestrial ecology evidence.

131. In respect of freshwater ecology, when compared to the alignment proposed

through the NoR phase, the Northern Alignment reduced effects on the

higher value streams within QEII Trust open space covenants, by avoiding

crossings mid-catchment and affecting areas of lower ecological value rather

47 SSEOCPs are required to be prepared under proposed Condition EC16. The detail of SSEOCP’s is included within the REMMP at section 12 of the EMP. 48 Proposed Conditions EC16(c) and EC17. 49 Proposed Condition EC15.

than streams within mature vegetation. Mitigation of many of these

freshwater ecology effects is proposed, and residual effects are to be offset

through creation of new and enhancement of existing stream habitats.

COMMENTS ON SECTION 87F REPORT

132. I have addressed many of the matters raised in the Freshwater 87F Report

within my evidence, however for clarity I repeat these here and provide

further assessment or clarification as required.

133. My understanding of Mr Brown’s assessment is that there is a general

consensus with the majority of the conclusions within Technical Assessment

H, including:

(a) The majority of effects on freshwater ecology can be avoided, remedied

or mitigated, with stream habitat loss requiring offset.

(b) The proposed approach to fish passage through culverts is appropriate,

in that fish passage is provided except for where the upstream habitat

is limited to short sections of intermittent or constructed stream habitat.

(c) The determination of the quantum proposed and the overall approach

to stream offsetting is appropriate.

(d) Agreement regarding the magnitude of effect that sediment can have

on freshwater environments.

(e) The proposed approach to stormwater management will see an

improvement in the stormwater quality compared to the current

situation.

(f) The proposed approach to management of potential effects from

concrete and vegetation clearance is appropriate to manage effects.

(g) The freshwater ecology assessment undertaken to inform the natural

character assessment is robust and transparent.

134. Notwithstanding the general agreement, Mr Brown identifies some areas of

concern and I discuss these, as they relate to freshwater ecology and

informed by my discussion with Mr Brown and others on 2 June 2020, below.

Fish passage

135. Mr Brown recommends that final fish passage designs are signed off prior to

construction commencing, and that passage should be maintained for the

lifetime of the structure. Mr Brown has recommended conditions to address

this.

136. I support requiring the review of final fish passage designs. Following

discussion with the Project design team, including Mr Hughes, I understand

that detailed design is occurring concurrently to this consenting process. With

that in mind, the review of final fish passage can occur through the consent

process, with the results of that review being reflected in the consented

Project design. That would mean there is no need for a consent condition

providing for a later review of fish passage design; it would also allow for fish

passage design to be confirmed as soon as practicable within the design

process. Therefore, and in keeping with the submission point raised by DOC,

a fish passage expert will be engaged to provide independent advice.

137. A table of culverts is proposed to be included in the conditions.50 This Table

is based on Table H.14 from Technical Assessment H. As outlined above, as

detailed design progresses, there are some minor refinements to some of the

specific culvert details. The proposed conditions version of Table H.14

specifies the culvert name and its requirement for fish passage; it does not

include the precise details of culvert length and grade, which may change

slightly. This proposed conditions table (with some additional detail) is

included for ease of reference at Attachment JQ.151. I consider that this

provides the assurance to Horizons that fish passage will be provided as

described, without restricting the ability of the design team to implement

better outcomes (such as shorter culvert length) through their detailed

design.

138. I agree with Mr Brown that for fish passage effects to be managed the

structures need to function for the life of the culvert. The Transport Agency

will maintain all culverts; the detail of which will be provided within a

comprehensive stormwater drainage operation and maintenance plan

prepared prior to commissioning of any assets52.

KiwiRail culvert

139. The Freshwater 87F Report also includes specific reference to a culvert that

has been identified running under the KiwiRail line, where Catchment 7

enters the Manawatū River. Mr Brown seeks a condition requiring fish

passage to be provided for that existing culvert. Improvements to that culvert

would require KiwiRail’s approval; I understand that conversations with

KiwiRail in that respect are still progressing. I agree with Mr Brown that

provision for fish passage through the KiwiRail culvert would provide

50 This has been added to proposed Condition EC13. 51 This table is also in the FEMMP at Table 10-1. 52 At paragraph 113 of Technical Assessment B.

additional benefits (positive effects). However, I have not relied on provision

of fish passage through the KiwiRail culvert in my assessment of effects

within Catchment 7.53

Fish salvage and relocation

140. Mr Brown identifies that the proposed approach to fish recovery is sound,

however recommends that some of the principles within the FRP are carried

into resource consent conditions. I have no concerns regarding capturing

these as conditions; they have been included in the proposed condition EC13

appended to Ms McLeod’s evidence.

Stream offset proposal

141. Mr Brown considers that the use of the SEV and ECR is appropriate to

assess the loss of stream habitat and the quantum of offset required. As

described above, there have been changes to the impact, diversions and

consequently the riparian planting proposed. These changes have been

quantified using the SEV and ECR.

142. To confirm54, the ecological benefit proposed at each offset site has been

modelled using the SEV method based on the specific ecological

enhancement measures proposed. That is, a stream reach with a riparian

margin width of 5 m has a lower ecological ‘gain’ compared to a reach with a

width of 20 m. This is then reflected in the amount of enhancement required

to achieve no net loss of ecological function (as calculated by the ECR). This

applies to both constructed stream diversions and riparian planting along

existing stream reaches. I am confident that the ecological gains used to

inform the quantum of offset required are an accurate representation of what

might be required to provide for no net loss of ecological function.

143. As described above, the riparian planting at offset sites has progressed since

lodgement and four offset sites are now identified. I consider that the offset

proposed at these sites meets the offset principles and in particular, is like for

like and proximate to the impact sites.

Post-construction monitoring of stream offset measures

144. Mr Brown considers that post-construction monitoring of the stream offset

measures is essential to ensure that the purported ecological values are

achieved. He proposes this would involve undertaking SEVs at the

restoration sites (both riparian planting and stream diversions) to ensure that

53 Ms McLeod explains in her evidence why no condition is proposed in respect of the KiwiRail culvert. 54 And as requested by Mr Brown at paragraph 61.

predicted SEV values are met at 10 years post-construction. I have some

concerns regarding the practicality of and need for this proposal, and its

ability to capture the ecological benefits proposed in the timeframe.

145. Riparian planting is generally accepted as being a key enhancement action to

result in aquatic ecological improvement. Catchment scale enhancement, as

proposed for many of the offset sites, has a greater influence on ecosystem

function compared to many small-scale (reach based) enhancement efforts55.

For example, where reach scale efforts can result in shade across the stream

cross section, 1 km of planting (with 75% shade) can result in an instream

temperature reduction of 5oC56.

146. As riparian planting is a key driver of aquatic ecosystem improvement the

REMMP provides for monitoring of planting success. With the successful

implementation of riparian margins as proposed, the in-stream benefits are

expected to be realised.

147. That is, the conditions and REMMP require monitoring to ensure that the

planting achieves a certain density and shading57. That planting density and

shading (together with fencing to exclude stock) consequently provides for

improved in-stream conditions, including (for example) reduced

temperatures, organic matter input, reduction in nutrients from overland flow.

148. The SEV values proposed are tied to a combination of native planting at

various successional stages, including late stage succession. Table 4.1 of the

Planting Establishment Management Plan (within the EMP; provided as

Table 2 in the Freshwater 87F Report), identifies that at 10 years, a ‘clear

trajectory towards the outcome state’ is expected. So while the riparian

vegetation may have reached the anticipated density at 10 years, the in-

stream ecological function may not have been met. As such, SEV values

measured in-stream after 10 years may not reflect the maximum SEV value

anticipated (as recommended by Mr Brown; Horizons’ proposed condition

EC15(e)), rather these may still be on the trajectory towards the anticipated

SEV values.

149. Similarly, for constructed streams, the in-stream habitat features will be

constructed in line with what is proposed in the modelled SEVm-P scores,

55 Doehring, K., Clapcott, J. E., and Young, R. G. (2019). Assessing the functional response to streamside fencing of pastoral Waikato streams, New Zealand. Water 11, 1-22 56Collier, K.J., Cooper, A.B., Davies-Colley, R.J., Rutherford, J.C., Smith, C.M., and Williamson, R. B. (1995). Managing riparian zones: a contribution to protecting New Zealand’s rivers and streams. Vol 2. Department of Conservation. 57 At Section 12.4 and 12.5 of the FEMMP.

however until such time that the riparian margins are established, the in-

stream ecological function may not reflect the maximum SEV value.

150. As such, and in line with Ms McLeod’s updated proposed conditions58 and

the REMMP57, I propose that the performance measures are tied to the

physical interventions, which are well-recognised as contributing to aquatic

ecosystem health and function improvements. In my view, this is the

appropriate form of monitoring in respect of the stream offset measures.

Sedimentation

151. I understand that Mr Brown and I are in general agreement that discharge of

sediment into streams can have substantial effects on ecological function and

faunal communities. I note his concern that an existing ‘degraded state’ may

be used to justify further degradation (in respect of water quality)59, however

that is not the case in my assessment. I also understand that Mr Brown is

satisfied that the freshwater ecology values of the site have been

appropriately assessed60.

Effects assessment

152. In respect of the application of the effects assessment, Mr Brown considers

that I have double counted the short-term nature of the effect in determining

the overall level of ecological effect. This is not entirely correct, and I explain

as follows how my assessment was undertaken.

153. Ecological effects were reported on a sub-catchment scale in Technical

Assessment H, but specifically related to the affected reaches (i.e. those

downstream of the earthworks extent for example). I considered the effect

during the period of potential sediment discharge. Over that time (maximum

four years) I consider that the magnitude of effect would result in no more

than a partial change in baseline condition, consistent with a ‘moderate’

magnitude of effect, during construction.

154. I did not include a longer-term assessment of effects, because I consider that

the duration of the activity was a more accurate reflection of the timeframe of

the effect. I agree with Mr Brown that the effects of sedimentation can be

reversed if the source of sediment is stopped61. That was the basis for my

assessment that further measures were not required beyond the monitoring

(and possible response) proposed.

58 Proposed Conditions EC15 and EC19(a) and EC19(b). 59 At paragraph 26 of Freshwater 87F Report. 60 At paragraph 30 of Freshwater 87F Report. 61 At paragraph 80 of Mr Browns evidence.

155. I have re-assessed the magnitude of effect, considering the effect following

the completion of earthworks and cessation of potential sediment discharges.

I have reviewed literature related to the recovery of stream systems in

response to sediment inputs. While there is plenty of data pertaining to

monitoring and development of sediment related triggers, there is less in

relation to recovery following sediment discharge. In my review of various

reports from 1991 to 2019, a general theme emerged that rapid recovery to a

pre-sediment state can be achieved, where conditions allow. This varies

based on the size of the stream, the frequency of flushes, the area of open

catchment (for example in the case of exotic forestry) and whether multiple

stressors are preset or not.

156. The only ‘stressor’ caused by the Project is the effects associated with

earthworks. That is, there is not going to be a change in riparian cover in the

majority of these streams (as might be the case with a forestry activity). The

streams within the Project area are typically small and steep, and many may

not be flowing during the peak earthworks period. With all else remaining

constant (as it relates to the Project), these streams are more likely to

respond rapidly following earthworks, when the source of sediment is

removed. I refer to Mr Stewart’s evidence, whose view is that the USLE

calculations used to inform my assessment are conservative; as such, the

potential effects as assessed may not eventuate (or fully come to pass).

157. Following completion of earthworks, and removal of the Project-related

sediment sources, I consider that the potential magnitude of effects will reach

a magnitude of ‘negligible’ in all catchments, resulting in an overall level of

effect of ‘low’ or ‘very low’. That is there may be a very slight change, but that

the change is barely discernible from existing baseline condition62. On this

basis, still being considered a ‘temporary’ or short-term effect 63, I remain of

the view that further mitigation, offset, or compensation of the ‘moderate’ or

‘high’ effects during construction is not warranted.

Baseline data

158. I agree with Mr Brown that understanding deposited sediment (as well as

visual sediment coverage) is important to determining effects. Mr Brown

raised concerns that insufficient deposited sediment baseline data had been

obtained64. That is why I recommend use of the quorer method to inform

baseline condition of streams in the AEMP (as at Section 10.7.3 of the AEMP

62 As per the description of a negligible magnitude of effect at Table 8 of the EcIAG. 63 As described at Table 9 of the EcIAG. 64 At Paragraph 85 of Freshwater 87F Report.

within the overall EMP). This data will complement the visual deposited

sediment data. Both methods are proposed due to the limitations of some

sites, where there may be currently high levels of visual deposited sediment

or sites where the quorer method may be less effective.

Discharge limits

159. Mr Brown considers that ‘more oversight’ is required to ensure effects are

managed and recommends discharge limits based on information presented

in Technical Assessment C (prepared by Mr Hamill). I understand from the

evidence of Mr Hamill and Mr Stewart that Mr Brown’s proposed use of

those total suspended solids (TSS) numbers is invalid for various reasons

they explain. Those values were not central to my assessment of effects,

rather I relied on a wide range of data from both Mr Stewart and Mr Hamill in

determining the magnitude of effects.

160. Mr Stewart and Mr Hamill describe the limitations and challenges with

assigning a discharge limit to the sediment retention devices. Specifically,

they identify that imposing a discharge limit (as proposed by Mr Brown) is not

practical and could not be complied with. Rather, a suite of monitoring is

proposed to incorporate preventative, responsive and routine monitoring

which I discuss below.

161. It is my view that while discharge limits may provide an appealingly simple

‘standard’ for compliance officers, discharge values that are not linked to the

existing environment (which naturally varies65) do not directly correlate with

ecological effects. It is my opinion that the best course of action to safeguard

that effects are no more than anticipated, is through the implementation of an

effective monitoring regime (as discussed below).

Monitoring Framework

162. In discussion with Mr Stewart and Mr Hamill, I have prepared a flowchart

presenting the Aquatic Ecological Monitoring, Management and Response

Framework (“Framework”, Attachment JQ.5), which was initially provided

as part of the section 92 response. The Framework should be read in

conjunction with the AEMP and the Erosion and Sediment Control Plan.66

163. The Framework combines monitoring intended to be preventative (i.e.

through inspection of erosion and sediment devices), responsive (i.e. to

‘events’ such as device failure, or device triggers being breached during

65 As described by Mr Hamill in relation to the turbidity loggers in Catchments 2 and 7. 66 The Erosion and Sediment Control Plan is a separate management plan, not part of the EMP.

intense rain events), and routine (i.e. to capture potential longer term

changes in the receiving environment).

164. Following discussion with Mr Brown and others at a meeting on 2 June 2020,

modifications were made to the Framework submitted with the section 92

response. These changes are intended to address some of Mr Brown’s

concerns including:

(a) the time taken from identifying an effect to implementing a response,

particularly as it relates to ‘event’ triggers;

(b) comparable data restricting the ability of an assessment of change to

be made;

(c) absence of a clear ‘bottom line’ upon which further remedial measures

must be implemented; and

(d) a clearer feedback loop of required actions.

165. Monitoring of both physical parameters (i.e. deposited sediment) and

biological responses (i.e. macroinvertebrate communities) are proposed to

provide a full picture of potential effects.

166. The Framework sets out an approach to implementing next steps to

addressing effects if they occur (as determined by deviation change from

baseline condition), which includes reporting, further investigation,

consideration of onsite controls and further mitigation, offset or compensation

if required. In the event that an effect is detected, the first step will be to

investigate what on-site controls can be implemented.

167. The monitoring proposed in the AEMP includes monitoring for one-year post

earthworks. After this time, I expect that any sediment that may have entered

the receiving environment from Project works will have been flushed from the

system through natural processes. Mr Stewart and Mr Hamill agree that this

timeframe is reasonable. Mr Brown proposes that monitoring continue for

longer than one year if bottom lines are not met67, after which time further

mitigation or offset measures be implemented.

168. A slightly modified version of Mr Brown’s Table 3 and approach to monitoring

has been incorporated into the AEMP. A maximum two years is proposed for

post-construction monitoring. If within this time period the effects are greater

than anticipated, measures will be put in place to address adverse effects.

67 At Table 3 of the Freshwater 87F Report.

This is intended to ensure that if an effect is observed, that measures will be

put in place to remediate, mitigate or if required, offset the effect.

169. I consider that the approach taken to assessing and addressing potential

sediment effects is sound. The proposed approach to monitoring provides a

backstop to ensure additional measures be put in place if effects beyond

those anticipated occur.

Justine Quinn

12 June 2020

ATTACHMENT JQ.1 – SIMPLIFIED CULVERT TABLE WITH FISH PASSAGE

REQUIREMENT (EXPANDED FROM PROPOSED CONDITION EC13)

Culvert ID FISH SPECIES FISH PASSAGE TREATMENT

ADDITIONAL TREATMENT

STREAM CATCHMENT

CU-01 NOT REQUIRED N/A N/A 8A

CU-02 NOT REQUIRED EMBEDMENT N/A 8A

CU-03 CLIMBERS EMBEDMENT SPAT ROPE 7B

CU-04 CLIMBERS EMBEDMENT BAFFLE 5B

CU-05 NOT REQUIRED N/A N/A 5B


CU-07 CLIMBERS EMBEDMENT SPAT ROPE 5A

CU-08 SWIMMERS EMBEDMENT BAFFLE 4A

CU-08A CLIMBERS EMBEDMENT SPAT ROPE 4A

CU-09 CLIMBERS EMBEDMENT SPAT ROPE 4C

CU-10 NOT REQUIRED N/A N/A 4D


CU-12 CLIMBERS EMBEDMENT BAFFLE 4E

CU-13 NOT REQUIRED NOT REQUIRED N/A 4F


CU-15 CLIMBERS EMBEDMENT SPAT ROPE 3A


CU-17 CLIMBERS EMBEDMENT SPAT ROPE 2C

CU-17A SWIMMERS EMBEDMENT BAFFLE 2B

CU-17B SWIMMERS EMBEDMENT BAFFLE 1B

CU-18 SWIMMERS EMBEDMENT BAFFLE 1B



ACU-01 CLIMBERS EMBEDMENT 8A

ACU-03 CLIMBERS EMBEDMENT SPAT ROPE 5B

ACU-04 NOT REQUIRED N/A N/A 5B

ACU-05 SWIMMERS EMBEDMENT BAFFLE 4A

ACU-05A SWIMMERS EMBEDMENT BAFFLE 4B

ACU-06 CLIMBERS EMBEDMENT BAFFLE 4B

ACU-07 CLIMBERS EMBEDMENT 3A

ACU-08 NOT REQUIRED N/A N/A 3A

ATTACHMENT JQ.2 – STREAM OFFSET LOCATIONS

Figures showing approximate and possible locations of stream length and offset

opportunities within each of the four offset sites; followed by an overview showing

the location of all sites in the landscape.

ATTACHMENT JQ.3 – UPDATED SUMMARY REACH BASED ECR CALCULATIONS

INCORPORATING FOUR OFFSET SITES AND CHANGES TO DIVERSIONS

Changes from lodgement are shown in track changes overleaf.

ATTACHMENT JQ.4 – ASSUMPTIONS ASSOCIATED WITH SEV

CALCULATIONS AT OFFSET SITES

SEVm-C values measured and representative SEVs assigned to similar stream

reach length within each site. Modelled SEVm-P scores based on ecological values

anticipated to be achieved with either 10 or 20 m riparian margins as discussed

with landowners to date. The final configuration of stream enhancement to be

undertaken as part of the offset package will be developed following further

consultation with the landowners. SEV and ECR numbers will be updated to reflect

this as the discussions progress.

Type Proposed offset site

Offset site name

Length potentially available (m)

Area available (m2) SEVm-C SEVm-P

Permanent Ratahiwi SEV1 394 275 0.57 0.94

Permanent Ratahiwi SEV1a 3644 2634 0.57 0.92

Permanent Ratahiwi SEV1b 730 1096 0.57 0.88

Permanent Sproull SEV1c 901 354 0.57 0.82

Permanent Ratahiwi SEV2 5 6 0.62 0.92

Permanent Ratahiwi SEV2a 1642 2035 0.62 0.90

Permanent Sproull SEV2b 1309 719 0.62 0.79

Intermittent Ratahiwi SEV3 1291 229 0.42 0.88

Intermittent Ratahiwi SEV3a 3460 761 0.42 0.87

Intermittent Sproull SEV3b 194 19 0.42 0.75

Intermittent Ratahiwi SEV4 3750 646 0.61 0.86

Intermittent Ratahiwi SEV4a 2322 653 0.61 0.85

Intermittent Sproull SEV4b 219 53 0.61 0.74

Intermittent Sproull SEV5a 539 278 0.44 0.79

Permanent Sproull SEV7 3336 2977 0.47 0.71

Permanent Tuapaka SEV9 4864 2432 0.56 0.82

Intermittent Tuapaka SEV10 6762 2029 0.45 0.75

Permanent Beagley SEV11 4208 4489 0.71 0.89

Intermittent Beagley SEV12 2765 409 0.44 0.91

ATTACHMENT JQ.5 – AQUATIC ECOLOGICAL MONITORING AND

RESPONSES FLOWCHART

[Overleaf]

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