northland regional council · penstock intake clear of weed and debris (see figure 2). penstocks...
TRANSCRIPT
31 October 2018
Attention: Stuart Savill/Glenn Mortimer
Northland Regional Council
ref. 14119.blh
Email: [email protected]
Dear Stuart/Glenn
RE: WAIRUA HEPS – RESPONSE TO REQUEST FOR FURTHER INFORMATION – APP.004845.01.02
This is a response to the request for further information contained in your letter dated 10
September 2018.
Each of the items is addressed as follows:
1. The infrastructural elements of the HEPS as it now exists are well explained in the
Assessment of Environmental Effects (AEE) but it is understood that several structural
changes have occurred since the current consents were issued, e.g. canal widening,
automated penstock grid weed clearance and, possibly, weir height raising by
700mm. For the sake of completeness, please list and explain the purpose of any water
use-related structural changes made to the HEPS since 1993 when the station was
purchased by Northpower.
Answer:
Table 1 lists and explains the purpose of the water use-related structural changes made to the
HEPS since 1993 when the HEPS was purchased by Northpower.
Table 1 Structural changes made to HEPS since 1993
Component Description
Auxiliary Spillway Northpower installed the Auxiliary Spillway in 1995 in accordance with Permit
00.004845.01.01.
No structural changes have been made to the auxiliary spillway since its construction (see
Figure 1).
Diversion Weir
(Consisting of the flap
gates and vertical
gate)
Changes were made to the diversion weir structure (consisting of the flap gates and
vertical sluice gate) between 1995 and 2008 to improve the ability of Northpower to control
water levels. The HEPS was fully automated by 1995.
The installation of hydraulic actuators and the removal of the counter weight was also
undertaken and completed in 2008.
The flap gates were replaced in 2008. The dimensions of the flap gates were unchanged
and were fitted into the existing concrete weir structure. This change had no effect on the
capacity of the scheme or the river storage (see Figure 1).
Canal Intake and
Canal Maintenance
Following the installation of a fourth generator and a storm event in 2007, canal
maintenance works were undertaken during 2008 and 2009 to address erosion and
seepage issues. Approximately 15m of the canal (beginning at the intake structure) was
lined with concrete and the canal wing walls were repaired (see Figure 1).
Headpond Northpower raised the headpond wall 75mm in 2013. The purpose of this change was to
accommodate the height of the existing penstock intake wall.
The existing fish migration facility was installed at the same time. A siphon pipe was installed
between the Headpond and the trough to allow for migrating eels to enter when
operated. This facility provides for the capture and transfer of eels past the HEPS and for
cultural harvest (see Figure 2).
Headpond Spillway As a result of rock slippage at the Headpond, spillway chutes and the cliff face were
reinforced in 2003. Northpower also installed a plunge pool to provide for migrating eels at
the same time (see Figure 2).
Penstock Intake Repairs to the automatic weed rake at the penstock intake were completed in 2008. The
purpose of the automatic weed rake is to ensure the penstock intake is kept clear of weed
and debris. The weed rake is triggered by a differential pressure sensor at the penstock
intake screens. The sensor is activated by the differential water level across the intake
screens. The automation of the weed rake replaced the manual requirement to keep the
penstock intake clear of weed and debris (see Figure 2).
Penstocks & Generator Generator 4 (G4) was installed by Northpower and completed in 2007. At the same time
the Generator (G3) penstock was also replaced and repositioned to allow for the
installation of G4 (see Figure 3).
Figure 1 - An aerial view of the HEPS. In view is the diversion weir, canal intake, the canal and auxiliary spillway. Structural changes made to these
HEPS scheme components between 1993 and present are also noted above.
Canal Intake Structure
Canal – 15m concrete lining,
canal wing walls repaired.
Diversion Weir Structure – Flap Gates
replaced and automated along with the
Vertical Sluice Gate.
Flap Gates
Auxillary Spillway
Vertical Sluice Gate
Figure 2 - An aerial view of the HEPS. In view is the Headpond, Penstock Intake, Fish Migration Facilities.
Weed Dump Penstock Intake
Penstock Intake Screens &
Automatic weed rake
Penstock Trough & Fish Migration Facilities
Figure 3 - An aerial view of the HEPS. In view is the Headpond, Penstock Intake, Fish Migration Facilities and Penstock Pipes.
Weed Dump
Fourth Penstock & Generator installed
Penstock Intake & Automatic weed rake
Penstock Trough & Fish Migration Facilities
2. Details of the actual day-to-day operation of the river diversion elements (as
opposed to the power generation elements) are not made clear in the AEE. In
particular:
a. please explain the differing purpose(s) and use of the vertical sluice gate versus
the diversion weir gates.
b. please explain how operational decisions are made with respect to raising or
lowering the vertical sluice gate and/or the diversion weir flap gates during:
i) medium to high flows;
ii) low flow periods including droughts.
Answer:
The layout of the diversion weir structure (consisting of the flap gates and the vertical sluice
gate) is shown below in Figure 4. Figure 4 also indicates the location of the auxiliary spillway.
Figure 4 - An aerial view of the HEPS. In view is the diversion weir, canal intake and auxiliary spillway.
Diversion Weir - Vertical Sluice Gate
The vertical sluice gate is a flushing gate for the purpose of allowing water to flow past the
diversion weir at the lowest point in the river. The vertical sluice gate will stop or regulate flow
when required. Prior to the automation and replacement of the flap gates, the vertical sluice
gate was the primary water level control. The current operation of the vertical sluice gate
allows for maintenance of the flap gates and full river flow during periods of high flow.
Diversion Weir – Flap Gates
During operation the flap gates control the water level at the diversion weir to provide water
flow down the canal intake. During floods, the flap gates are down to allow river flow past
the diversion weir.
The flap gates are operated automatically and rise or drop in order to maintain a certain
flow at the canal intake. The flow is based on an operating river level set point of 2.2m
Flap Gates
Canal Intake Structure
Vertical Sluice Gate Auxillary Spillway
measured at the canal intake by Northpower’s Supervisory Control and Data Acquisition
(SCADA) system1.
Figure 5 - Diversion Weir Structure consisting of Vertical Sluice Gate and Flap Gates
Operational monitoring and decision making - medium to high flows
Northpower’s SCADA and security systems monitor the HEPS, including diversion weir water
levels, tail water level, canal flow, gate positions and generation output. In addition,
Northpower considers national and regional rain fall, river levels and weather forecasts.
Northpower also considers communications from neighbouring landowners and community
relating to high water levels.
Northpower undertakes monitoring and responds accordingly during medium to high flows
as set out below:
1. Northpower regularly monitors forecasts provided by MetService (including the Severe
Weather Outlook, Severe Weather Watch, Coastal Warnings and Oceanic Warnings)
and is in regular communication with Civil Defence Northland and local lifelines
colleagues. In the event of a MetService Severe Weather Warning, Northpower staff or
contractors are dispatched to the HEPS to “man” the station during the anticipated
flood event.
2. Northpower also monitors pre-storm event river levels at the diversion weir and station tail
water levels. Those levels are compared to the river level and flow rate on the Wairua
River at the Northland Regional Council’s Purua Monitoring Station. This monitoring
particularly considers the rate of increase in flow and river level rise. In the event of high
river levels (exceeding 50.2m RL), Northpower will override the automatic controls and
manually lift the vertical sluice gate if it is considered that the river level is rising too
quickly and/or debris is collecting at the diversion weir and needs flushing past the weir;
3. In the event of an emergency, at the request of the District or Regional Councils, Civil
Defence Northland or emergency services, Northpower can override the HEPS
automatic controls.
1 (see Attachment 1 for a screen shot SCADA system)
Vertical Sluice Gate Flap Gates
Diversion Weir Structure
Operational monitoring and decision making - low flows
Northpower undertakes the following monitoring and responds accordingly during periods of
low flows:
1. Northpower’s SCADA and security systems monitor the HEPS;
2. During periods of low flows, Northpower monitors MetService Severe Drought weather
warnings;
3. If there is not enough flow to efficiently run a generator, Northpower will pond the river
to keep it at a consistent level of 2.0m at the canal intake. Northpower can raise the
vertical gate and allow flow past the diversion weir. The continuation flow of 30L/s is
maintained via the vertical sluice gate orifice;
4. If the water level at the canal intake reduces below 1.0m, Northpower will reduce
generation to ensure the continuation flow of 30L/s is maintained through the vertical
sluice gate orifice.
5. If the water level at the canal intake is likely to reduce below 0.9m, Northpower
suspends generation to ensure that the continuation flow of 30 L/s is maintained
through the vertical sluice gate orifice.
3. Please explain the basis for the 30 cumec diversion rate applied for when the
combined turbine outflow with all four units operating is apparently
16 cumec (Hawthorn and Geddes Report s4.1 Table 1) and it is indicated in AEE
Appendix 11 Consultation Information that a 20 cumec rate has been actively
considered.
Answer:
Northpower approached consultation openly and actively and considered both a reduced
diversion rate based on generation output and an unchanged diversion rate. Following
consultation and further technical assessment Northpower have applied for an unchanged
diversion rate on the basis of the following considerations:
• Northpower is continually maintaining and repairing its assets, indeed, the
maintenance of operational technology and repairs to penstock equipment is one of
the reasons for this application (see AEE, section 2.1.2). Such maintenance and repairs
may in the future include installation of new technology generators. It is likely that such
generators would require higher inflows (potentially up to 20 cumecs). So as not to
preclude such future upgrades, Northpower decided to maintain the existing diversion
rate;
• The results of the assessment of environmental effects determined that the effects of
the HEPS operating with an unchanged diversion rate would be no more than minor
and can be adequately managed by proposed mitigation measures and proposed
conditions of consent;
• The continued operation of the HEPS and the continued benefits it provides to the
Northland community and the Northpower Trust relies on the HEPS being economically
viable. Lower diversion rates will ultimately reduce the amount of renewable electricity
generated by the HEPS and threaten its future viability.
4. Similarly, please provide comment on why a higher continuation flow than the current
30 L/s has not been actively considered within the AEE.
Answer:
The continuation flow is derived from three sources being:
1. An orifice located within the diversion weir gates; and
2. Leakage from around the diversion weir gate structures; and
3. Tributary inflows between the Wairua Falls and the point of discharge from the HEPS.
The orifice allows Northpower to ensure that a 30 L/s continuation flow is maintained at all
times. It is not possible to accurately measure the contributions in flow from the latter two
sources. However, their influence means the continuation flow is greater than 30 L/s at all
times.
The application seeks all necessary resource consents to continue the status quo operation
of the Wairua HEPS without making physical alterations to the gates/orifice. With current
operational behaviour, the continuation flow is likely to be in the order of 150 L/s or more for
much of the time. However, Northpower cannot currently ensure that a continuation flow
above 30 L/s is achieved at all times without physically altering the gates/orifice.
As set out in section 2.1.2 of the AEE, critical repairs and maintenance of the HEPS are
immediately required, including the maintenance of operational technology and repairs to
penstock equipment to the life span of the scheme components.
5. In AEE s8.1 (second bullet point), it is stated that concerns of one landowner about effects
of flooding were allayed. Who was the landowner and how were their concerns
specifically allayed?
Answer:
The concerned landowner was Richard Booth. Mr Booth owns a farm which is predominantly
located on the western side of Tokiri Road. Mr Booth also owns land immediately adjacent to
the penstocks on the northern side of the canal.
Mr Booth had queried whether the diversion weir was causing the Wairua River to overtop its
western bank in extreme rain events, spilling across Wairua Falls Road, and ultimately flooding
properties further to the west (including his own).
Northpower representatives and an engineer from Hawthorn Geddes (Conal Summers) met
with Mr Booth at his property on 10 August 2017. Mr Summers explained that the modelling
carried out by Hawthorn Geddes, supported by detailed survey information, showed that the
diversion weir was having no influence on the flooding experienced to the west of the HEPS
during extreme rain events.
6. In AEE s8.3, there is a brief discussion of the relationship between the HEPS operation
and the WDC 'emergency' water take from the Wairua River (using the Maungatapere
water take infrastructure) during drought situations. What management arrangements
have been agreed between the parties?
Answer:
The arrangements between Northpower and the Whangarei District Council (WDC) are
informal. Northpower provided support in principle for WDC’s Water Permit application for
extraction from the Wairua River upstream of the HEPS on 3 October 2017.
Northpower recognise the regional significance of WDC’s water supply and the need to
maintain that in the event of a drought or Civil Defence Emergency scenario. In the past
Northpower and WDC have collaborated on this aspect of the HEPS’s operation and WDC’s
‘emergency’ water take, and will continue to do so, as follows:
Northpower is prepared to work with WDC to ensure that, if required, sufficient flow is
available for the community water supply;
1. In the event of drought circumstances occurring and coinciding with water levels in the
Whau Valley Dam reducing to less than 55% of its full capacity, WDC may contact
Northpower to advise it of the situation and request support;
2. Northpower will then operate the diversion weir to control the water level and hold
water back to allow WDC to take water. Northpower will suspend generation operations
if necessary during this time.
Northpower is aware that previous modelling undertaken has indicated that WDC will require
the ‘emergency water take’ approximately once every 12 years.
7. In the Kessel Ecology report, at s3.6, the gauging results for the Downstream A and B
sites are presented with the recorded flow at the Downstream B site roughly double
that of the Downstream A site. Please provide comment on the likely contribution of
the Motukutuku Stream outflow to this difference, as the stream mouth is between Sites
A and B.
Answer: (provided by Tonkin & Taylor Limited, previously Kessels & Associates Limited):
It is presumed that the question is intended to refer to the Matukutuku Stream (rather than
the Motukutuku Stream). As far as we are aware, flow gauging has not been undertaken
within the Matukutuku Stream. We have therefore relied on modelled data from the NZ Rivers
Maps website, which is run by NIWA and based on published literature. Several sites are in
proximity to the HEPS and Matukutuku Stream (Error! Reference source not found.).
Based on modelled data, the Matukutuku Stream has a catchment area of 4.06 km2
compared to the 726 km2 catchment for the Wairua River (at the Downstream point as
shown on Figure 6). That is equivalent to ~0.6% of the total contributing catchment.
The data reported in section 3.6 of the Kessels report was collected in March 2016, and is
therefore considered to be representative of lower in-stream flows. We have therefore
considered the proportion of flow that the Matukutuku Stream contributes under mean
annual low flow (MALF) and 5 year low flow conditions. Using this information, we can then
estimate what proportion of the measured 155.3 L/s (at Downstream B in March 2016) came
from the Matukutuku Stream as requested in the question above.
During MALF conditions, the Matukutuku Stream is estimated to contribute 10 L/s to the
Wairua Stream, and during 5 year low flow conditions, 5 L/s. This contribution comprises 33%
and 17% (for each flow measure) of the flow between the upstream and downstream points
(Table 1). Using those percentages, it is estimated that 39 L/s of the measured 155.3 L/s is
contributed by the Matukutuku Stream assuming the MALF scenario or 22 L/s of the
measured 155.3 L/s is contributed by the Matukutuku Stream assuming the 5 year low flow
scenario.
These figures further support the conclusion at section 3.6 of the Kessels report that the 72.4
L/s recorded at the Downstream A site is an inaccurate representation of the flow
downstream of the Omiru Falls.
Table 1: Summarised results from modelled flow assessment. A
Upstream
B
Downstream
C
Difference
D
Matukutuku Stream
(L/s and % of
difference)
E
Flow before
Matukutuku Stream
contributions
F Contribution to 155
L/s from Matukutuku
Stream
MALF 2330 L/s 2360 L/s 30 L/s 10 L/s (33%) 116 L/s 39 L/s
5 year low
flow
1240 L/s 1270 L/s 30 L/s 5 L/s (17 %) 133 L/s 22L/s
A and B = modelled flow data from Figure 6
C = difference between A and B
D = proportion (L/s and %) that Matukutuku Stream contributes to the difference (C).
E = flow in diversion reach before the Matukutuku Stream enters it (based on the measured flow of 155 L/s divided by (1 + % of difference)).
F = the contribution from the Matukutuku Stream to the 155 L/s measured flow reported by Kessels (based on the formula of 155 L/s minus E).
Figure 6 - Modelled flow data for the HEPS area. Data sourced from
https://shiny.niwa.co.nz/nzrivermaps/
8 Please provide electronic copies of:
a. Williams, E. et al. 2013. Tuna Populations in the Wairua and Mangakāhia Rivers. Prepared
for Ngā Kaitiaki o Ngā Wai Māori, Northland Regional Council, Northpower & Ministry of
Primary Industries. NIWA Report HAM 2013 - 109.
b. Williams, E. et. al, 2018. Understanding Elver Populations in the Wairua River Catchment –
Year 1: 2017 Elver Survey Results. Prepared for Ngā Kaitiaki o Ngā Wai Māori Incorporated
Society. NIWA Report.
Answer:
These documents are attached.
9. The Kessels Ecology report deals in some detail with potential effects on eels and eel
migration upstream and downstream but does not expressly evaluate effects on other
native climbing fish species, e.g. Banded Kokopu and Koaro. Please provide comment
on how the NEPS may affect migration of these species, including whether or not the
eel capture system provides some mitigation (if needed), i.e. also captures these other
species?
Answer: (provided by Tonkin & Taylor Limited, previously Kessels & Associates Limited).
Advice has also been sought from Jacques Boubee (formerly of NIWA) in the preparation of
this response as he is most familiar with the trap and transfer systems at the HEPS. During his
time with NIWA, Jacques was instrumental in improving the trap and transfer system at the
HEPS shown in Figure 7.
Figure 7 - Location of elver traps at HEPS. Figure provided by Jacques Boubee, 12 October 2018.
All climbing fish species, including banded kokopu, giant kokopu, short jawed kokopu and
kōaro as well as shrimps, are able to use Trap 1 set up at the tailrace (if they are present in the
tailrace). Other species including some bullies and koura may also be able to use Trap 1.
Trap 2 at the penstock was installed after the discovery that a large number of elvers were
being trapped in this location. It is unclear how elvers reach this location although it is
possible that there is an underground drainage channel. Regardless, the installation of Trap 2
has been very successful and now catches more elvers than Trap 1.
It is rather difficult to determine let alone enumerate how many fish other than eels are in a
trap when large number of elvers are present. As such, the number of species other than eel
has not been quantified to date.
It is not possible for non-climbing fish species such as smelt and Inanga to use the existing
traps. This approach is deliberate as the Omiru Falls are a natural barrier to ‘non-climbers’
and these species would never have made it over the Omiru Falls in its natural state.
In respect of downstream migration, the only species of concern at this site is eels as they
migrate downstream as adults. Larval fish, such as kōaro and banded kokopu, will pass
through the turbine. Mechanical strike impact is not a concern with these small fish.
In summary, it is considered that the HEPS does not adversely affect migration of non-eel
species as upstream passage is provided for by the trap and transfer system or naturally
limited by the Omiru Falls, and larval fish are small enough to pass downstream without
mechanical strike impact.
10. Table 16 of the Kessel Ecology report refers to 'missed fish' of differing species, which
make up the majority of those recorded during the fish survey. However, the meaning
of the term is not explained in the text. Please explain.
Answer:
‘Missed fish’ are those that were observed, but not captured and identified during electric
fishing surveys. The site is bouldery and some areas had a high coverage of filamentous
algae, making it difficult to successfully capture all fish. It is best practice to record their
presence but, without a confident identification, they are just included as ‘missed fish’.
11. Section 5.1.1 of the Kessel Ecology report sets out proposed offset mitigation (riparian
planting) but notes that potential mitigation sites have yet to be identified. However,
please provide a general indication of the types of sites to be considered and an
evaluation of where within the Wairua River catchment these are known to be, or likely
to be, located.
Answer: (provided by Tonkin & Taylor Limited (T+T), previously Kessels & Associates Limited):
Northpower has reviewed the parcels of land in the immediate vicinity of the HEPS and
prepared the attached indicative map2 showing the extent and ownership of parcels of land
that may be appropriate for offset planting to be undertaken. T+T has reviewed aerial
photographs of these parcels to assess whether there is benefit in undertaken ecological
restoration.
A combination of road reserve and Department of Conservation (DOC) land could provide
approximately 2 km of available planting upstream of the diversion canal. Planting could be
undertaken on the true right bank (TRB) and would provide shading to the river, as well as
inputs of woody debris. This land is road reserve and so additional water quality benefits
could be achieved as road runoff would filter through the riparian planting. The true left bank
(TLB) is reserve land administered by DOC, which would also benefit from planting.
Some infill planting and enhancement could be undertaken within DOC reserve land
located between the diversion canal and the outflow. Given the existing planting, this option
is likely to be less beneficial to the enhancement of aquatic biodiversity values and
ecosystem function compared to other sites.
Approximately 3 km downstream of the outflow, further road reserve area is available for
planting (in the order of 3 km). Multiple benefits could be achieved by planting along this
section, however planting would be limited to one side of the river.
2 Refer to Attachment 2
Northpower has approached both Whangarei District Council (WDC) and Kaipara District
Council (KDC) to gauge their interest in Northpower undertaking planting of land in the road
reserve and both WDC and KDC agreed in principle that such planting could be feasible.
Northpower is also meeting with DOC to discuss planting on its land.
In respect of the Guidance on Good Practice Biodiversity Offsetting in New Zealand (GBBPO)
principles, all of the sites identified to date are located along the Wairua River and are
proximate to the impact area. Therefore, the principles of proximity can be met.
The intent of the offset work is to address the HEPS’s effect of a reduction in aquatic habitat
available and modification to the dissolved oxygen and temperature within the river (Table
20 in the Kessels report). The anticipated proposed planting will address the biodiversity
values affected by the impact. It is intended that riparian planting be undertaken in one
location, rather than numerous sites. This approach is beneficial as a longer riparian margin
provides for a more connected ecosystem and in-stream effects (such as temperature
reduction) are better realised. For planting alongside road reserves, there may be additional
benefits beyond those that must be accounted for, including the potential for road runoff to
receive a level of treatment prior to it entering the Wairua River via sheetflow.
Riparian planting undertaken in conjunction with a maintenance and monitoring programme
is considered to be low risk in respect of achieving a successful outcome.
T+T considers that there is sufficient land available to plant along the Wairua River in the
immediate vicinity of the HEPS to achieve the recommended 3 ha of planting. The
preference is to have planting on both sides of the river, where possible, to provide additional
shading and availability of habitat along stream margins. However, the configuration of the
land available (i.e. the availability of one bank, or both banks) will be confirmed following
discussions and formal agreements with relevant landowners.
We trust this provides sufficient certainty that the proposed offset works can be achieved as
recommended.
12. The written comments from the Whatitiri Resource Management Unit, dated 3
September 2018, on the HEPS application place considerable emphasis on river and
diversion canal (and adjoining DoC reserve) access restrictions allegedly made in 2013
for health and safety reasons. Please provide an outline of what restrictions were
instituted and why.
Answer:
The comments from the Whatitiri Resource Management Unit (WRMU) about public access
are not relevant to the resource consents being sought from the Northland Regional Council.
However, for completeness, information on those comments is provided below.
Access to the DOC Scenic Reserve
Vehicle access to the HEPS is via Lot 7 DP 172748 (highlighted yellow in Figure 8) and through
the Scenic Reserve (highlighted green in Figure 8).
Lot 7 DP 172748 is owned by Northpower Ltd. While two private residential properties to the
south have a legal right to use Lot 7 for access (and they have been issued with a key), there
is no right of, or obligation to provide, public access across Lot 7 (see the certificate of title
attached). The gates were already in place when Northpower purchased the HEPS and
adjoining land (including what is now Lot 7). Northpower replaced the gates in 2016. These
gates enable the appropriate restriction of access to the HEPS, as is in keeping with good
health and safety practice.
Northpower’s access to the HEPS continues from Lot 7 across the Scenic Reserve by way of a
registered easement which it has the benefit of (highlighted magenta in Figure 8). That
easement allows for right of way, electricity supply and telecommunications. Northpower has
the right to pass over this area, but does not prevent any other person from using this area.
Figure 8 - Ownership and rights to land relating to access issues raised by WRMU
Public access to the Scenic Reserve is provided by an unformed paper road (highlighted
peach in Figure 8 above). The usability of the paper road is an issue that will need to be
addressed by the Department of Conservation and/or Whangarei District Council. In
summary, Northpower has no obligation to provide public access across its private land to
the Scenic Reserve and is not restricting legitimate public access.
Regarding public access to the head pond above the penstocks, Northpower notes that:
1. There is an unformed paper road on the western side of the head pond. This road is not
fenced (see Figure 9);
2. The head pond and canal are owned by Northpower. There is no right of public access
to these areas and they are fenced for health and safety reasons.
Figure 9 - Headpond
Yours sincerely
Brett Hood
Director
ATTACHMENT 1 – NORTHPOWER SUPERVISORY CONTROL AND DATE ACQUISITION (SCADA) SYSTEM
ATTACHMENT 2 – INDICATIVE MAP PUBLIC RESERCES AND ACCESS
ATTACHMENT 3 – CERTIFICATE OF TITLE LOT 7 DP 172748