Planning Committee

4 Draft Minerals Plan Change (PC102) – GBC Winstone Overburden Proposal

Reporting officer: Nina Murphy (Policy Planner) Date of meeting: 8 June 2016 1 Purpose

To seek a decision on whether to include the extension to Otaika Quarry in the plan change.

2 Recommendation 1. That the Planning Committee declines to include the extension to Otaika Quarry, for

overburden, in the notification of the proposed minerals plan change (PC102).

3 Background

A Council briefing was held on 6 April 2016. The draft plan change for minerals was considered. A proposal by GBC Winstone to add an area for overburden disposal to their existing Mineral Extraction Area at Otaika Quarry (ME3) was also considered. Refer to Summary of Proposal and Report on Briefing (Attachments 1 & 2). In May, public feedback was sought on the draft plan change including the proposed overburden area at Otaika Quarry. Eight written comments were received. Four had comments on the plan change in general, which is not covered by this agenda item. The matters raised will be considered as part of the notification process. Six comments (Attachment 3) were primarily on the overburden proposal:

Four were from adjoining landowners and were in opposition.

Two expressed concern about the effects on Ruarangi; a site of significance to Maori (though not currently shown on the district plan maps). There are recorded archaeological sites near to the Peagram Block. One is listed as a Maori burial/cemetery site which sits within a network of limestone caves, which could extend under the Peagram Block.

GBC Winstone sought that the placement of overburden should be a controlled activity.

Planning Committee

A public information evening was held on 12 May for those affected by the proposal (refer notes in Attachment 4). This meeting was attended by around 20 members of the public. Council staff felt the overall comments could be summarised as:

Support in general for the existing quarry operations at Otaika.

Concern at loss of property values for those adjoining the Peagram Block.

Concern at potential adverse effects such as dust, noise and visual outlook.

Lack of consideration of alternative sites for overburden disposal.

4 Considerations

There are three options to be considered for the GBC Winstone overburden proposal:

1. Accept the proposal and add to proposed PC102 for notification.

2. Modify the proposal and add to proposed PC102 for notification.

3. Decline the proposal and do not add to PC102.

In accordance with the Resource Management Act 1991 (RMA) a section 32 assessment has been prepared on the proposal (Attachment 5). It concludes that the best option is to decline the proposal at this stage.

When the plan change is notified anyone can make a submission. This will allow GBC Winstone to put forward their proposal, with a cultural impact assessment, and whatever modifications are necessary to address potential adverse effects on tangata whenua, the community and the environment.

4.1 Financial/budget considerations

If Council accepts the GBC Winstone proposal it will be required to pay for any subsequent technical reports required to support the proposal at the Hearing.

There is the potential for the cost of appeals. This applies to any plan change. 5 Significance and Engagement

This matter is significant to an identified community of interest. Overall the decisions of this Agenda do not trigger the significance criteria outlined in Council’s Significance and Engagement Policy, and the public will be informed via Agenda publication on the website.

The RMA contains specific process for public notification of a proposed plan change. This will be followed at the time of notification.

6 Attachments 1. Summary of the GBC Winstone proposal to extend Otaika Quarry TRIM 16/56030 2. Briefing Report TRIM 16/55020 3. GBC Winstone proposal - Comments TRIM 16/56142 4. Notes from public information evening 16/53515 5. Section 32 Assessment of GBC Winstone proposal 16/55055

OTAIKA QUARRY – PROPOSED FUTURE

DEVELOPMENT Presentation May 2016

Otaika Quarry

• Quarry Manager – Selwyn Dodd

• Otaika Quarry has operated as a quarry since the 1950’s

• Currently operates 5½ days/week

• Manufactures a full range of aggregates for the use in roading,

civil construction, concrete, drainage and building markets.

• Employs 14 – 18 fulltime staff and 5 – 6 contractors

(+/- depending on aggregate demand).

Key Facts

• Well established resource

– Significant reserves - 50+ years resource remaining

– Mineral extraction is essential for Northland’s continued development

– Located close to market

• Location

– Transport is the single largest cost associated with aggregate products;

– Rule of thumb, cost of aggregates doubles for every additional 30km;

– Otaika Quarry is the largest quarry in Northland and is well positioned to

Whangarei with good access to State Highway 1

Future Development Constraints

• Access to overburden disposal capacity

– Overburden disposal capacity is essential for any quarry operation

– No overburden disposal capacity remaining at Otaika Quarry

• Overburden disposal options

– Peagram land (owned by GBCWinstone and leased to a local farmer)

• What is Overburden?

– Vegetation, Topsoil, Clay and Highly weather rock (that can’t be processed into

saleable product)

• Overburden is expensive to remove and disposal costs increase exponentially the further away it is placed.

Site Overview

Otaika Quarry

Peagram block

Future Resource

Proposal

• To place overburden within the Peagram block

• Series of phases known as ‘campaigns’, typically lasting 3- 6 months, usually once every 3 – 4 years (depending on market demand)

• Overburden will be contoured to be sympathetic to the existing contours of landform.

• Placed overburden will be progressively returned to pasture and where appropriate, trees will be planted.

• example video

• Proposed enduse – farmland (similar to current situation)

Concept Design

• We are currently in the early design stage

• Concept design informed by:

– Engineering and geotechnical constraints

– Acoustic constraints (to comply with District Plan Rules)

– Landscape & Visual Impact Considerations

• Community feedback & cultural considerations will

inform further concept designs

Concept Plan

• Design Principles – Ensuring that there are no physical constraints to overburden

placement

– Staging of overburden placement

– Maximising height and volume of fill in the north-western part of the site close to the quarry and where there are no adjoining residential properties

– Acoustic bunds for noise mitigation

– Accommodating main water course to provide site drainage;

– Minimising the potential visual effects on the wider landscape views from residential properties

• Design Principles (continued) – Storing topsoil stripped to be used in site rehabilitation

– Avoiding effects on any features identified in NZ Archaeological Association records

– Defining a maximum area that would be exposed at any one time

– Re-grassing each stage and returning it to pasture

– Retaining individual and groups of existing tall trees wherever possible;

– Preparing a site rehabilitation plan as part of the resource consent application

Proposed Future Development

Cross Sections

Overburden

Existing Section

Cross Sections

Overburden

Existing Section

Resource Consent Application

• Assessment of effects – noise, ecology, landscape,

traffic

• Comprehensive landscape and visual assessment

• Representative viewpoints from surrounding area

• Preparation of visual simulations

• Visual catchment - Zone of Theoretical Visibility (ZTV)

Visual Catchment

Process & Next Steps

• Community feedback & engagement - Feedback is

important to help inform final design

• District Plan Review (Whangarei District Council)

• Detailed design process

• Resource Consent Process

Whangarei District Council Briefing 6 April 2016 16/37615

1. Report: Whangarei District Council Briefing Wednesday 6 April 2016

Report of a Briefing to the Whangarei District Council held in the Council Chamber, Forum North on Wednesday 6 April 2016 at 9.00am Present: Her Worship the Mayor S L Mai, Crs S J Bell. S J Bretherton, C B Christie (9.08am), P A Cutforth, S J Deeming, S M Glen, P R Halse, C M Hermon, G C Innes, G M Martin, B L McLachlan, S L Morgan and J D T Williamson In Attendance: Chief Executive (R Forlong), Group Manager Support Services (A Adcock), Group Manager Positive Growth (J Thompson), Governance Manager (J Marris), Legal Counsel (K Candy), Policy and Monitoring Manager (P Waanders), Resource Consents Manager (A Hartstone), Team Leader District Plan (M McGrath), Policy Planner (N Murphy), Policy Planner (R Burgoyne), Support Assistant (L McColl) and Senior Meeting Co-ordinator (C Brindle) 1 Elections 2016 – Protocols for Elected Members during pre-election period Facilitators: Her Worship the Mayor K Candy Power Point presentation: 16/34904 Her Worship the Mayor convened the meeting. K Candy covered the content of the Briefing as outlined in the power point presentation and agenda report. Ms Candy provided an overview of both the organisation and elected members responsibilities to ensure political neutrality during the pre lection period. Ms Candy asked Members to direct any queries to either herself or the Governance Manager Jason Marris.

Whangarei District Council Briefing 6 April 2016 16/37615

2 Whangarei District Plan – Draft Minerals Plan Change Facilitators: HWM P Dell Power Point presentation: 16/37811 The purpose of the Briefing is to work through the draft plan change and finalise a consultation path to follow. Her Worship the Mayor convened the meeting. P Dell by way of introduction spoke about the history of the 500m setback in regards to quarries and questioned whether Council should retain the buffer zone as well as 500m setback. The purpose of the buffer zone was to externalise noise effects, an additional 500m buffer was given to prevent reverse sensitivity and encroachment of development. It was clarified that the proposed plan changes would not affect smaller quarries, the proposed changes would only affect large quarries. N Murphy covered the content of the Briefing as outlined in the agenda item and power point presentation. Ms Murphy re-iterated that the aim is to protect the mineral extraction areas from reverse sensitivity. The regional direction is to show regionally significant mineral resources on District Plan maps. Iwi Management Plans – iwi will be notified. The draft new rules require Cultural Impact Assessments (CIA) district wide, CIA’s will assist in determining the scale of the activity. There was some discussion about whether a CIA is necessary for all mineral consents. Concerns raised that the requirement for a CIA may delay the process. P Dell acknowledged further work/fine tuning to be done on CIA’s and how it could be linked to the Sites of Significance work. Mining cannot be undertaken in Sites of Significance to Maori. Sites of Significance and Mineral Extraction areas need to be aligned. It was clarified that land within the buffer zones is not necessarily owned by the quarry. Rules apply to areas within Mineral Extraction Areas (outlined on pages 27 – 34 of the agenda). You cannot currently build a house within a buffer zone without Resource Consent. There needs to be clarification with regards to the building of habitable developments versus non habitable buildings. P Waanders provided an explanation on the difference between operating within a Mineral Extraction Area (MEA) and outside of an MEA. All extraction greater than 5,000m2 would require a resource consent. Previously the volume was 500m2 but this was increased to align with the Regional Council volume and also better reflected smaller operations. It was confirmed that the MEA rules are applicable to all mining including mercury mining, sand and limestone quarries. In response to a question from the floor about the number of resource consents council has issued for mineral extraction A Harstone clarified very few (if any) for new quarry, a few for expansion of quarry. The proposed amendment to GBC Winstone Mineral Extraction Area was discussed. Two options were presented – option 1 – adopt the overburden area (becomes part of Council’s plan change and must be notified by council), option 2 – do not adopt overburden area at this stage – requirement to consult GBC’s responsibility and they could then submit on the Plan Change. Discussion on the best process to take this forward ensued.

Whangarei District Council Briefing 6 April 2016 16/37615

Her Worship invited Ian Wallace of GBC Winstone to comment from the public gallery. Mr Wallace outlined the future plans for the quarry. Winstones want to expand so the future quarry is not restricted to the current overburden area blocking expansion, the intention is to start placing overburden on the site within 2 years. Technical studies and consultation with residents is still needed. Draft plans only at this stage, work in progress. The difference between option 1 and 2 is that option 1 requires staff and resources. P Dell was of the opinion that option 2 is a better process however he accepts that if staff work closely with the company to resolve the landscape issue and undertake a pre- consultation programme option 1 could be a viable option. Mr Dell reminded council of the necessity for the plan change to be finalised in order to progress the rural strategy by July 2016. Councillors opinions on the two options were mixed, as Council cannot make decisions at Briefings the Chief Executive advised staff would take on board comments made today and would use their discretion to determine the most appropriate way to proceed. The Briefing closed at 11.07am

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From: Gemma SandsSent: Wednesday, 11 May 2016 3:28 p.m.To: Nina MurphyCc: Paul McDonald; Robin RawsonSubject: Parks Comments on Minerals Plan change PC102 Good Afternoon Nina,

Parks have received the consultation material for the Minerals Plan Change and the Extension to the Otaika Quarry. It is

understood that Winstones are seeking to re-zone the Peagram Block to provide for Overburden activities by way of Plan Change

which would then enable them to make resource consent applications for this area.

We have concerns about the potential effects that activities on the Peagram Block may have on the Otaika Sportsfield which is

adjacent to this area, and find there is a lack of information to enable us to make an accurate assessment of the potential effects of

these activities on the Otaika Sportsfield in order to make an informed comment on the proposed plan change.

The information below highlights some of the information we consider necessary to make an informed assessment of this proposal.

While it is understood that a further resource consent would be required before Winstones were able to commence operations, an

effects assessment on the actual suitability of the Peagream site for overburden operations should be provided at the Plan Change

level before the area is rezoned to provide for applications for such activities to be made.

Works Programme

We would like to see a programme of works for the operation and use of the overburden area, including information relating to the

timeframe the area would be used for overburden activities, sequence of campaigns, proposed use of this land and rehabilitation

requirements upon completion.

Visual Effects

The Otaika sportsfields are recognised as a gateway to the city, and Council is embarking on an entranceway project to improve

the amenity of this area to enhance the experience of people entering the city. Overburden activities would form a backdrop to this

entrance point, with earthworks on the Peagram having the potential to have a detrimental effect on the visual amenity of the

sportsfields, but also of the entranceway to the city. A landscape and visual effects assessment of the overburden activities should

be provided in order for Parks to understand the potential visual effects on the site and locality, the likely final landform, and ways

in which adverse visual effects would be avoided or mitigated, including any rehabilitation and landscaping requirements.

Noise

The sportsfields are a receiver to noise generated within the MEA. As such, a noise assessment should be provided in order to

identify any potential adverse effects of overburden activities on the use and enjoyment of the sportsfields.

Water Quality

Overburden activities associated with earthworks may have an adverse effect on water quality on the stream running through the

sportsfields. The sportfields are the downstream receiver to Winstones operations, and concerns are raised in relation to potential

effects (both ecological and visual) of reduced water quality on watercourses through the sportsfields. Further information should

be provided to demonstrate that overburden operations will not have downstream effects on water quality.

Dust

Dust associated with overburden operations may compromise the use and enjoyment of the sports park if not managed

appropriately. Further information is required in order to establish whether dust generated by earthworks within the overburden

area would pose a nuisance effect to users of the sportsfields.

Stormwater

The Otaika sportsfields are susceptible to flooding which compromises their use over the winter seasons. It is unknown whether

landform modification or changes to overland flow paths as a result of overburden activities on the Peagram Block would have an

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adverse hydrological effect on the sportsfields and further consideration of this matter is required.

Conclusion

Based on the lack of information available, Parks are unable to identify whether the environmental effects of overburden activities

on the Peagram Block would be sufficiently internalised within the boundaries of the Winstones site to the extent that the amenity,

use and enjoyment of the sportsfields would not be compromised. Whilst it is recognised that the sportsfields are within the buffer

area of the quarry, it is not acceptable for adverse effects of overburden operations to be externalised onto the sportsfields.

Further information is required to demonstrate this will not be the case.

Has a full Section 32 analysis of the overburden proposal been undertaken?

We look forward to receiving more information to enable a more informed consideration of this proposal and potential effects on the

sportsfields to be undertaken.

Kind Regards,

Gemma

Gemma Sands

Team Leader Planning- Infrastructure and Services | Whangarei District Council

Private Bag 9023 | Whangarei 0148 | http://www.wdc.govt.nz

P: 09 430 4230 ext. 8213 | E: gemmas@wdc.govt.nz

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A division of Fletcher Concrete and Infrastructure Ltd

20 May 2016 Ms Nina Murphy, Policy Planner, District Plan, Policy and Monitoring Whangarei District Council Dear Nina RE: FEEDBACK ON DRAFT PLAN CHANGE 102 – MINERALS OF THE WHANGAREI

DISTRICT PLAN Thank you for this opportunity to provide feedback on the Draft Plan Change 102 – Minerals of the Whangarei District Plan (‘Draft PC 102’).

Please note this feedback on these draft provisions is provided on a ‘without prejudice’ basis. GBC Winstone will make a formal submission on Plan Change 102 when it is finalised and can be considered in conjunction with PCs 85A-D, 86 and 87 which it is understood will be notified concurrently.

This feedback is further to previous feedback already provided by GBC Winstone to the following draft provisions that have been released for feedback by the Council.

Draft Plan Changes 85A – D - Rural Area - Strategic Rural Industries Environment - Rural Production Environment - Rural Village Residential Environment

Draft Plan Change 86 – Rural Urban Interface Environment Draft Plan Change 87 – Coastal Environment

This feedback is additional to suggested amendments already provided by GBC Winstone to Council, in regard to extending the current Mineral Extraction Area, (‘MEA’) at Otaika Quarry to include land to the northeast of the current MEA, known as the ‘Peagram Block’ as set out in the report.1 GBC Winstone recognises many of the suggested amendments in this report have

1 Otaika Quarry Overburden Disposal, Suggested amendments to provisions for Mineral Extraction Area, Review of Whangarei District Plan, prepared by GC Winstone, dated 4 March 2016’. 1

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been incorporated into PC 102. Further GBC Winstone wishes to acknowledge the time and effort of the Council officers in the discussions and consultation undertaken with the company, affected parties and the wider community in regard to these new provisions. The feedback set out below is intended to be constructive and the company hopes this feedback assists the Council in the further development of the draft provisions prior to public notification, later this year. Suggested track changes to the draft provisions are also attached for the consideration of Council as Attachment 1 - Suggested changes to the Mineral Provisions – Draft Plan Change 102, Minerals, May 2016. FEEDBACK 1. Proposed introduction of a new ‘Overburden Area’ provision and extension to ME3 at

Otaika to include the Peagram block. GBC Winstone generally supports the overall planning direction in draft PC 102 particularly the proposed introduction of a new ‘Overburden Area’ provision and extension to ME3 at Otaika to incorporate this ‘Overburden Area’ and other associated provisions as mentioned above2. One exception is that GBC Winstone sought that overburden placement within the Overburden Area be assessed as a controlled activity. However draft PC 102 proposes the activity of the placement of overburden in the newly created Overburden Area within an MEA be assessed as a ‘discretionary activity’.

In respect to GBC Winstone applying for a resource consent for the placement of overburden on the Peagram block‘ under the Operative District Plan, the GBC Winstone note the rules in the currently Operative Whangarei District Plan, in summary, provides for ‘Mineral Extraction (being the full range of mineral extraction activities including overburden disposal) within a ‘Buffer Area’ of a MEA as a ‘Restricted Discretionary Activity’, within the ‘Countryside Environment’ zone (outside of an MEA) as a ‘Restricted Discretionary Activity’ and within the ‘Living 3’ zone (outside of an MEA) as a ‘Discretionary Activity’. The rules in PC 102 as drafted, appear to make Mineral Extraction activities including overburden placement on the ‘Peagram block’, more restrictive than in the Operative District Plan. Having provided detailed technical information in support of the introduction of the Overburden Area GBCWinstone considers that the placement of overburden within that area should be a Controlled Activity. This is consistent with the approach taken for the Active Area of the MEA (now Mining Area) where mineral extraction is treated as a controlled activity. 2. ‘avoid, remedy or mitigate’

2 ‘Otaika Quarry Overburden Disposal, Suggested amendments to provisions for Mineral Extraction Area, Review of Whangarei District Plan, prepared by GC Winstone, dated 4 March 2016’.

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GBC Winstone acknowledge that the Council has generally sought to carry over the objectives and policies in Operative District Plan in relation to minerals into draft PC102. However the company is concerned with suggested changes to Policy 18.4 1 of the Operative District Plan, now reproduced in draft PC 102 as MIN 1.3 Policy 1 and MEA 1.3 Policy 3, particularly the deletion of the words ‘to the extent practicable’. Due to the nature of the mineral extraction activities, it is not always possible to avoid, remedy or mitigate all adverse effects of the activity. Indeed it is acknowledged in the provisions in the Operative District Plan and the Descriptions and Expectations in draft PC 102, that some adverse effects such as noise, vibration and visual effects may be evident beyond the boundary of the site of the mineral extraction activity. Accordingly, it is not appropriate in all circumstances to require mineral extraction activities to ‘avoid, remedy or mitigate the adverse effects of mineral extraction …’ as now proposed in Draft PC 102 particularly MIN 1.3, Policy 1 and MEA 1. 3, Policy 3. 3 GBC Winstone suggest that either the wording ‘to the extent practicable’ be retained or that a test of ‘significance’ be included, or that adverse effects ‘be minimised’4 in these and other relevant policies as is the approach that has been adopted in other District Plans across the country. 3. ‘safe and efficient’ mineral extraction.

It is recognised that Objective 18.3.2 of the Operative District Plan states “Subdivision, use and development of land should not compromise existing safe and efficient mineral extraction or unduly constrain potential access to, and the development of, identified significant mineral resources.’ (underlining added for emphasis).

It is considered that the test of ‘safe and efficient’ are not appropriate matters for the assessment of mineral extraction activities under the RMA. The phrase “safe and efficient” could be replaced by the word “lawful” or “lawfully established” which imposes an objective rather than a subjective qualification. It is suggested that MIN 1.2, Objective 3 be altered accordingly. 4. Requirement of CIA for all resource consent applications for mineral extraction. GBC Winstone notes the inclusion of Policy MIN.1.3 2 and Information Requirement MIN.1.4 1 which relate to the provision of a cultural impact assessment (CIA). GBC Winstone accepts that there are occasions when CIAs are the appropriate means to demonstrate meaningful consultation with Mana Whenua and the assessment of the effects of

3 The approach ‘to minimise’ is adopted in the objective and policy provisions in relation to minerals in the Proposed Auckland Unitary Plan (‘PAUP’). 4 Refer ‘Developing objectives and policies to avoid, remedy or mitigate quarrying and gravel extraction effects’ in QP- The RMA Quality Planning Resource – The Quality Planning Website.

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a proposal on their interests. However a CIA is only one of numerous ways in which effects may be assessed. Requiring the provision of a CIA written by/prepared by the relevant tangata whenua and kaitiaki for the area is arguably ultra vires. The CIA requirement lacks certainty, in that it is not defined, there is no structure provided within the plan for its preparation or provision, and there is no explanation as to how the provision of a CIA will give effect to the policy. The inference drawn from the wording of the policy is that the CIA will be adopted by the Council to meet tangata whenua interests thus providing tangata whenua with a decision making role in relation to their interests. However it is the Council’s role to assess all information provided and make appropriate decisions on all aspects of an application. There is no legal obligation upon tangata whenua to provide a CIA and, unlike other professional advisers, there is no pool of appropriate providers to draw from. The requirement to provide a CIA is effectively an obligation to consult with tangata whenua. While this may be best practice, it is clear from Section 36A of the RMA that an applicant is not obliged to consult. It is unreasonable to require a CIA only in relation to mineral extraction without regard to other activities which may also have impacts upon tangata whenua values. It is also unreasonable to impose it as a blanket requirement on every mineral extraction resource consent application, even when there may be no tangata whenua values affected by the proposal. GBC Winstone does not support the inclusion of the CIA provisions in their proposed form. 5. “Avoid adverse effects on significant areas” to Maori Draft PC 102 MIN 1.3 – Policy 3, states “To avoid adverse effects on significant areas”. It is recommended that this policy refer to “Sites of Significance to Maori’ and not all significant areas. This side, GBC Winstone generally supports avoiding mineral extraction in identified sites of significance to Maori.

6. Objectives and policies regarding encroachment of ‘Sensitive Activities’. GBC Winstone support the carry-over of the objectives and policies in the Operative District Plan regarding the encroachment of incompatible activities (now Sensitive Activities) into draft PC 102 including MIN 1.3, Objectives 3 and 4. Further GBC Winstone supports in principle, the approach proposed by Council of seeking to now ensure ‘Sensitive Activities’, as defined in Chapter 4 – Meaning of Words be included in the relevant objectives, policies and rules in reviewed District Plan. 7. Clarity provided by mapping the former Active Areas, Buffer Areas and the newly created

‘Overburden Area’ in the Planning Maps.

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GBC Winstone supports mapping the former Active Areas, Buffer Areas and the newly created ‘Overburden Area’ in the Planning Maps which provides clarity to the relevant provisions in the District Plan. It is also suggested that the newly named Mining Area (formerly the Active Area in the Operative District Plan) be renamed ‘Extraction Area’ as this more closely aligns with the term ‘Mineral Extraction Activities’ used in the District Plan. 8. Clarity provided by mapping the 500 metre setback that will apply to the establishment of

Sensitive Activities within Rural Environments and the setback from the . GBC Winstone supports the draft PC 102 in that 500 metre setbacks be taken from the former Active Area ( now named a Mining Area) , and not include the former Buffer Areas), where these Buffer Areas exists within the identified MEAs. 9. Rules in draft PC 102 GBC Winstone acknowledges that the rules are in a draft stage of development in PC 102. However the company does note that overall the activity status of Mineral Extraction Activities is generally more restrictive than under the operative plan, with the removal of the activity class of ‘restricted discretionary activity’. In addition to the comments provided above in Feedback Point 1 on the activity status rules for ‘overburden placement’, the following additional feedback is provided on the draft rules.

(i) It is suggested that the “Assessment Criteria for Discretionary Activities“ be more closely aligned with the matters which “Control is Reserved Over” in MEA 2.4 of draft PC 102. In particular, Point 11 “The extent to which the effects of the height can be mitigated by setbacks, planting, design or the topography of the site.” – could be rewritten more along the lines of “The extent to which potential adverse effects on the amenity of land adjoining the mineral extraction area can be mitigated by setbacks, screening and planting, design or the topography of the site.”

(ii) It is acknowledged that the rules requiring compliance with ‘Mineral Extraction

Management Plans’ in the Operative District Plan, have now been changed to Information Requirements in draft PC 102. It is noted that clause 2 sets out the matters the Management Plan “shall include”. These matters may not be relevant or necessary for “all applications for mineral extraction landuse” – and it is suggested that this rule be amended to refer to “could include” or “as relevant”.

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CONCLUSION

GBC Winstone greatly appreciates the opportunity to provide comments on the provisions in draft Plan Change 102 – Minerals of the District Plan Review and would welcome the opportunity to discuss this feedback, further with Council as appropriate. Please phone or email, Ian Wallace or Theda Hall at GBC Winstone at the contact details provided below. Yours sincerely

Ian Wallace Theda Hall Environmental Project Leader Environment and Sustainability Coordinator GBC WINSTONE GBC WINSTONE Ian.wallace@gbcwinstone.co.nz Theda.Hall@gbcwinstone.co.nz 021 673430 027 2070926

1

ATTACHMENT 1

Suggested changes to the Mineral Provisions – Draft Plan Change 102, Minerals, May 2016

2

MIN.1 Minerals

MIN.1.1 Description & Expectations

The management of mineral resources is divided between several pieces of legislation.

Access to Crown-owned minerals is legislated under the Crown Minerals Act 1991, but the

mining activity itself is managed under the Resource Management Act 1991.

Minerals are expressly excluded from 'sustainability' in section 5(2)(a) of the Resource

Management Act 1991, in terms of sustaining the potential of natural and physical resources

to meet the needs of future generations. However, by being included in section (2)(c),

minerals are included in 'sustainability' as it applies to avoiding, remedying or mitigating any

adverse effects of activities on the environment. To this extent, the activity of exploration,

quarrying, mining and any other disturbance of land would be covered by the Resource

Management Act 1991, and can therefore be addressed and regulated in District Plans.

The Whangarei District contains mineral deposits that may be of considerable social and

economic importance to the District, and the nation generally,(regionally significant mineral

resources in the RPS). The use and development of minerals that could be constrained by

conflicting land uses. Mineral development, and associated land restoration, can provide an

opportunity to enhance the land resource and landscape, and has done so in the past.

However, the development of mineral resources has the potential to have significant adverse

effects upon soil, water and air resources, and landscape and heritage values, if not

appropriately controlled/ managed. The four iwi/hapu management plans for the Whangarei

District identify the lack of control of minerals within their rohe, the adverse effects from

mining and the rehabilitation of sites as significant issues.

Regionally significant mineral resources that are being extracted are identified on District Plan

Maps and provided for through District Wide provisions (refer following section MEA). This

recognises the benefits and the need for aggregate resources to be available for infrastructure

and development. It also allows for the management of reverse sensitivity effects. Regionally

significant mineral resources that are not currently being extracted are not identified on District

Plan Maps due to the information not being available.

Smaller scale mineral extraction activities are provided for and assessed in accordance with

the relevant Environment provisions. District Wide provisions may apply more restrictive rules

due to the presence of significant or sensitive features.

3

MIN.1.2 Objectives

1. Exploration, extraction and processing of minerals avoids, remedies or mitigates to

the extent practicable any adverse effects on the environment and community.

2. Exploration, extraction and processing of minerals avoids, remedies or mitigates to the

extent practicable any adverse effects on the relationship of tangata whenua with

their ancestral lands, sites, water, waahi tapu and other taonga.

3. New subdivision, use and development of land does not compromise existing lawfully

established safe and efficient mineral extraction.

4. The potential access to, and development of, regionally significant mineral resources is

not unduly constrained by new subdivision, use and development.

MIN.1.3 Policies

1. To avoid, remedy or mitigate to the extent practicable, the adverse effects of

exploration, extraction and processing of minerals on the ecological, landscape,

heritage and amenity values of surrounding areas and on the amenity values of

existing residential areas by applying Environment and District Wide provisions.

2. To avoid, remedy or mitigate significant adverse effects of exploration, extraction and

processing of minerals on the relationship of tangata whenua with their ancestral

lands, sites, water, waahi tapu and other taonga by requiring a cultural impact

assessment written by the relevant tangata whenua and kaitiaki for all resource

consent applications for mineral extraction.

3. To avoid adverse effects on significant area to Maori, by prohibiting mineral

extraction within identified Sites of Significance to Maori.

4. To manage conflicts between the effects of mineral extraction activities and other land

uses by ensuring that activities that are incompatible with the effects of mineral

extraction activities are not established close to quarries or mines.

5. To rehabilitate sites historically used for mineral exploration and extraction to enable

the land to be used by other activities.

6. To identify and provide for regionally significant mineral resources (where extraction

rates are known) by mapping as Mineral Extraction Areas and applying provisions

that provide for the appropriate mineral extraction activities .

MIN.1.4 Landuse Application Information Requirements

1. All applications for mineral extraction landuse shall include a cultural impact

assessment prepared by the relevant tangata whenua and kaitiaki for the area.

4

5

MEA.1 Mineral Extraction Areas

MEA.1.1 Description & Expectations

The nine Mineral Extraction Areas (MEA) shown on the District Plan Maps identify existing

quarries extracting regionally significant mineral resources (refer Appendix 1). The extent of

the MEA indicates the area within which the effects of mineral extraction activities will

generally be contained, although some effects such as noise, vibration and visual impacts

may be evident beyond the boundary of the MEA.

The purposes of identifying MEA are to minimise the encroachment of incompatible land uses,

to define the area within which the effects of mineral extraction activities are contained as far

as practical, and to facilitate the operation of regionally significant commercial mineral

extraction activities.

It is important to note that there are rules applying to the underlying Environment and other

District Wide rules that must be taken into account. For example, the Rural Area rules on

hazardous substances, signs and lighting are particularly relevant.

Specific exemptions from rules within the underlying Environment are provided for some

components of mineral extraction activities. For example, stockpiles for mineral extraction

purposes, in MEA, are excluded from the rules applying to outdoor storage in the Rural Area.

In some instances where the underlying Environment allows for a greater level of

development, the activity will be exempt from the MEA provisions and assessed in accordance

with the provisions in the underlying Environment.

The MEA rules do not apply to earthworks which are not an integral component of mineral

extraction activities, as defined in Chapter 4.

Any proposals for extensions, or changes, to existing Mineral Extraction Areas, or new Mineral

Extraction Areas, will require a Plan Change process to be undertaken. This will provide an

appropriate opportunity to consider the extent to which effects should be avoided, remedied or

mitigated.

MEA.1.2 Objectives

1. The extraction and processing of identified regionally significant mineral resources is

provided for while ensuring that the adverse effects associated with these activities are

avoided, remedied or mitigated to the extent practicable.

2. Subdivision, use and development of land does not compromise or unduly constrain

the development of identified regionally significant mineral resources.

6

MEA.1.3 Policies

1. To provide for the continued extraction and processing of regionally significant mineral

resources by identification as MEA Mining Extraction Area, Buffer Area and

Overburden Area.

2. To manage conflicts between the effects of mineral extraction activities and other land

uses by ensuring that Ssensitive Aactivities are not established close to MEA.

3. To avoid, remedy or mitigate to the extent practicable, the adverse effects of mineral

extraction within MEA, on the ecological, landscape, heritage and amenity values of

surrounding areas and o n the amenity values of existing residential areas.

4. To remedy, avoid or mitigate adverse visual impacts from MEA on significant

landscapes, significant natural areas or significant natural features by applying District

Wide provisions.

5. To provide for the height requirements of mineral extraction activities, such as

overburden placement and buildings such as silos, while mitigating the potential

adverse effects by requiring setbacks, and considering screening and topography in

site design.

6. To avoid compromising the safety and efficiency of the roading network by limiting

traffic movements on minor roads and by providing for traffic controls and forming or

upgrading roads in the vicinity of the MEA, where needed.

7. To provide for the efficient provision of infrastructure by ensuring all relevant matters

relating to infrastructure and engineering are designed in accordance with Council’s

Environmental Engineering Standards 2010.

MEA.1.4 Guidance Note

The following shall form the basis for the assessment of resource consent applications for landuse

and subdivision in Mineral Extraction Areas:

1. The objectives, policies and provisions for Mineral Extraction Areas and other

Resource Areas in the District Plan.

2. The objectives, policies and provisions for Environments in the District Plan.

3. The District Wide objectives, policies and provisions in the District Plan.

The objectives, policies and provisions for other Resource Areas, Environments, and the District

Wide objectives, policies and provisions in the District Plan apply in so far as they support the

objectives, policies and provisions for Mineral Extraction Areas in the District Plan.

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MEA.2 LANDUSE

MEA.2.1 Eligibility Rules

1. Mineral extraction activities within the Strategic Rural Industries Environment are

exempt from MEA.2.5.1 and MEA.2.5.3 and will be assessed by applying the Strategic

Rural Industries Environment provisions.

2. Activities that are not controlled activities or discretionary activities are permitted

activities.

1. All mineral extraction activities are subject to the notif ication tests of the RMA.

MEA.2.3 Controlled Activities

1. The disturbance or removal of more than 5,000m 3 of material within the Mining Extraction Area in any 12 month period.

MEA.2.4 Control is Reserved Over:

When assessing resource consent applications for a controlled activity, landuse control is

reserved over the following matters:

1. The extent to which off-site effects (such as dust, odour and glare) adversely affect the

amenity values of sites in the vicinity.

2. The extent to which off-site effects, which are not managed by other rules in the Plan,

will inhibit the use of surrounding land for the carrying out of other activities.

3. The extent of adverse visual impacts on significant landscapes, significant natural

areas or significant natural features.

4. The extent of any adverse effects on land stability.

5. The extent of any adverse effects on ecological values or water quality, arising from

the land use.

6. The extent of any adverse effects on historic and cultural heritage.

7. The extent to which landscape proposals including the height, shape and form of

topography and screening, and the provision of setbacks mitigate potential adverse

effects on the amenity of land adjoining the Mineral Extraction Area.

8. The extent to which any rehabilitation programme will enable the land to be returned to

a state suitable for use by other activities.

8

MEA.2.5 Discretionary Activities in the Mining Extraction Area

1. Traffic generation from the site in any 24 -hour period:

a. Exceeds 100 traffic movements, where the site does not directly connect to a

public road with a sealed carriageway of at least 6 metres wide.

b. Exceeds 100 traffic movements, where any vehicle manoeuvring does not occur

within the site.

2. Establishment of any access, road and/or parking space or associated facility which

does not comply with the Environmental Engineering Standards 2010.

3. Construction or alteration of any building used for mineral extraction purposes that:

a. Exceeds 15 metres in height.

b. Is set back less than 10 metres (up to a maximum building height of 10 metres)

from the boundary of the Mining Extraction Area.

c. Is set back less than 20 metres (up to a maximum building height of 15 metres)

from the boundary of the Mining Extraction Area.

4. Any stockpile set back less than 10 metres from the boundary of the Mining Extraction Area.

5. Excavation of a quarry face set back less than 20 metres from the boundary of the

Mining Extraction Area.

6. Establishment, construction or alteration of a sensitive activity (excluding non-

habitable buildings).

MEA.2.6 Discretionary Activities in the Buffer Area

1. Establishment, construction or alteration of a sensitive activity (excluding non-

habitable buildings).

MEA.2.7 Discretionary Activities in the Overburden Area

1. The placement of more than 5,000m 3 of overburden material in any 12 month period.

2. Establishment, construction or alteration of a sensitive activity (excluding non-

habitable buildings).

MEA 2.8 Landuse Application Information Requirements

1. All applications for mineral extraction landuse shall include a Mineral Extraction

Management Plan.

2. A Mineral Extraction Management Plan shall include as appropriate a description of

the extent of the mineral extraction to be undertaken, and the means by which the

Consent Holder will comply with the relevant rules in the plan and the conditions of

9

the consent.

In particular, it shall include as appropriate:

a. A plan showing the boundaries of the MEA including the Mining Extraction Area,

any Buffer Area and any Overburden Area.

b. A plan showing topography, drainage, natural watercourses, existing vegetation

cover and any other significant landforms or features.

c. The design and location of buildings and any plant or machinery to be used in a

fixed position.

d. The anticipated life span of operation, the estimated volume of material to be

excavated, and any staging of works.

e. The proposed location and dimensions of overburden storage and deposition

areas and stockpiles of mineral material.

f. The proposed location and dimension of areas of excavation, including pits and

faces.

g. Any proposed setbacks, landscaping or screening measures.

h. Assessment of slope stability, including, where applicable, a slope stability

analysis allowing for an appropriate surcharge.

i. Proposed access to the MEA, and internal circulation within it.

j. The anticipated average daily number of vehicle movements to and from the site.

k. The number of people proposed to be employed, and parking spaces provided

on-site.

l. A description of the proposed methods of overburden stripping and mineral

extraction.

m. A description of the excavation and blasting programme.

n. A description of the methods by which the environmental effects of the operation

will be managed and controlled, to comply with all relevant rules of the plan and

the conditions of consent and to avoid, remedy or mitigate any adverse effects in

regard to those matters which are relevant to the Council’s assessment.

o. A description of the methods for protecting and maintaining areas of significant

landforms or features.

p. A description of any future objectives for the Mining Extraction Area of the

MEA and any proposed rehabilitation programme.

3. The Mineral Extraction Management Plan may be reviewed and updated by the

Consent Holder and the updated version of the Mineral Extraction Management Plan

provided to the Council.

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MEA.2.9 Assessment Criteria for Discretionary Activities

When assessing resource consent applications for discretionary activities the assessment

shall include (but is not limited to) the matters in MEA.2.4 and the following matters (where

relevant):

1. Hours of operation of the activity.

2. The outlook, privacy, health, safety and amenity of adjoining and adjacent neighbours.

3. Reverse sensitivity effects from new sensitive activities establishing in close proximity

to existing mineral extraction activities.

4. Effects on river maintenance and hazards.

5. Effects on the natural functioning of ecosystems.

6. Type, frequency and timing of traffic.

7. Effects of increased traffic on road safety, maintenance and efficiency.

8. Need for forming or upgrading roads in the vicinity of the site.

9. Need for traffic control, including signs, signals and traffic islands.

10. The scale and bulk of the building in relation to the site.

11. The extent to which the effects of height can be mitigated by setbacks, planting, design or

the topography of the site. The extent to which the effects potential adverse effects on

the amenity of land adjoining the Mineral Extraction Area can be mitigated by the

height, shape and form of topography, planting and screening, and the provision of

setbacks.

MEA.3 Subdivision

MEA.3.1 Eligibility Rules

1. All subdivision within a MEA is a discretionary activity.

MEA.3.2 Notification Rules

1. All subdivision activities are subject to the notification tests of the RMA.

MEA.3.3 Assessment of Discretionary Activities

1. When considering subdivision within Mineral Extraction Areas, the potential for

subdivision to compromise mineral extraction activities needs to be recognised. Any

subdivision should only occur if it is capable of avoiding, remedying or mitigating

adverse effects on mineral extraction activities.

Note: where the underlying Environment of the MEA is within the Rural Area also refer to

RA.4.2 for Assessment of Discretionary Activities.

A14078B_Attchment__Feedbk_PC102_19052016 page 11

Appendix 1 - Schedule Of Existing Mineral Extraction Areas

Quarry Name Mineral Extraction

Area

Planning Map Number

Noise Limit

GBC Winstone – Portland Quarry

MEA1 15, 50 Daily, between the hours of 0630 and 2130 - 55dB LAeq; and

Daily, between the hours of 2130 and 0630 - 45dB LAeq; and 70dB LAFmax.

GBC Winstone - Wilsonville Quarry

MEA2 7, 28 The noise limit imposed by Land Use Consent LU 00/573

GBC Winstone – Otaika Quarry and access way

MEA3 12, 45 Daily, between the hours of 0630 and 2130 - 55dB LAeq; and

Daily, between the hours of 2130 and 0630 - 45dB LAeq; and 70dB LAFmax; and

Subject to any restrictions on night time operation of the access way contained in LUC RC38907, as may be amended from time to time.

McBreen Jenkins – Takahiwai Quarry

MEA4 15 Daily, between the hours of 0630 and 2130 - 50dB LAeq; and

Daily, between the hours of 2130 and 0630 - 40dB LAeq; and 65dB LAFmax

United Carriers Woods Road Quarry

– MEA5 11

Balance Agriculture Mata Quarry

– MEA6 15

Mountfield Rd Quarry MEA7 18

Dicksons Transport – Dicksons Road Quarry

MEA8 12, 36 The noise limit imposed by Land Use Consent RC 37434

J Pullman – Robsons Quarry, Otaika

MEA9 45 The noise limit imposed by Land Use Consent LU 98/904

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TRIM 16/53515

File note Subject Meeting Notes – Public Consultation Meeting PC102 Otaika Quarry

Date 16 May 2016

Ref PC102 Minerals

Meeting: Pre-Consultation Meeting – Overburden Area Request from GBC Winstones

Date: 12 May 2016

Venue:

WDC Attending – Paul Waanders, Nina Murphy, Melissa McGrath (WDC), Peter Ibbotson (Marshall Day), Mike Farrow (Littoralis Landscape )

GBC Attending – Ian Wallace (GBCWinstone), Catherine Clarke (Boffa Miskell), Boyden Evans (Boffa Miskell) Damian Ellerton (Marshall Day), Jay Masters (Quarry Engineer)

Interested Parties Attending - Residents of the surrounding area

6.30pm Opening Statement by Paul Waanders, Presentation by Nina Murphy

Noise Question: What is reasonable noise? Not dozens of trucks.

Peter: Reasonable is established by research and caselaw.

Comments: Quarry is working outside of normal hours, crushers are running, trucks make more noise when empty, sealed road entrance has quietened some of the noise. Noise is intermittent. Timing conditions are important so are noise limits.

Dust is a main concern.

Removing the buffer is stupid.

Landscape Question: What is the potential to contain adverse landscape effects?

Barry Reiher spoke about landscape, stated that Winstones opposed development in the surrounding area of 1ha lot sizes (UTE), the ridge has decreased as a result of quarrying, Winstones cannot contain the effects. Why can’t they rehabilitate the existing quarry areas particularly at the frontage. Landscape effects are also the weeds introduced, Winstones should be looking at mitigating the effects. Loss of the buffer is a big concern.

Mike: Explained his consideration of the overburden area, he had to establish potential to accommodate the volumes of overburden with no specific proposal.

Comments: Quarry is important especially for building construction, need to be realistic and work with Winstones to form something nice once the metal is quarried.

Nina: Explained that the buffer is not to protect properties, but allows the quarry to externalise effects beyond their boundary.

7.15pm GBC Winstones Presentation

Quarry Question: What is the lifespan?

Ian: Approximately 50 years under the current consent requirements. Possibly more resource available.

Ian explained that the area to the front of the property (where Barry requested rehabilitation) is a stockyard for storage of products. GBC do have a planting regime but not proposing to rehabilitate areas within the processing area.

Overburden Question: How close to the boundary will the overburden construction go?

Ian indicated: approximately 30m from the nearest house at Acacia Grove.

TRIM 16/53515 2

Comments: It is going to increase the difficulty to insure houses. The volume of truck movements will increase, Winstones are not looking after the site.

Overburden Question: How long are you talking about? (Using the area to dump overburden?)

Ian: Overburden campaigns are undertaken in short bursts (6 months). Confirming that a campaign would be finished, the slope battered and grassed in-between campaigns.

Overburden Question: Is the overburden going to be contoured?

Ian: Yes

Overburden Question: What is the land good for once the overburden is dumped?

Ian: Same as the current use – pasture.

Ian: Confirmed that the current approach was to commence at the lower portion, fill, then move towards Smeaton Drive over a period of 13 years. Top soiling and grassing on each area.

Overburden Question: Where will the water run?

Ian: Through the site, down the driveway and onto SH.

Overburden Question: How will storm events be dealt with?

Ian: The consent application will have to have a stormwater catchment plan.

Overburden Question: What is the specific height of the noise bund?

Not specified in the current design.

Comments: Concerned about height of the bund and loss of amenity.

Overburden Question: When applying for resource consent, will it specify volumes?

Ian: yes

Overburden Question: Don’t want overburden to be trucked in from other sites.

Ian: Not proposed for any overburden other than Otaika.

Overburden Question: What about dust?

Ian: Managed at the consenting phase, GBC liable for damages.

Overburden Question: Will the consent be easy to decline?

General discussion – Nina explained the difference in consent classifications.

Comments: Concerned about the increased exposure of residential, Living 1 Environment with children playing, to dust and noise. The overburden activity will be more disruptive than the quarry itself.

Winstones planning to set up a community working group.

8.15pm GBC Winstones Leave – General Discussion with Council

Paul explained the options, Council include in plan change or not, and explained the scope of submissions.

General Comments:

Land values will drop due to works on neighbouring site. Different information is coming from GBC, they want the underlying zone to change. This is just another step to being able to quarry the area. General support for the existing quarry operations. If the area must be used, then landowners would be happier if the overburden area was reduced. Can Winstones appeal? Yes Very negative impact on property values, house will be looking at the bund not farmland. Council is not monitoring the current noise issues. Council should drop the rates due to loss of value. People who had purchased a few months ago, would not have done so. What about the investigation of alternative areas? Increased setbacks should be considered.

Meeting Closed 8.50pm

Section 32 Assessment – GBC Winstone Overburden Area Proposal

A full section 32 evaluation has been completed for PC102, this concludes in accordance with s32(1a) that the proposed objectives of PC102 are considered to be the most appropriate way to achieve the purpose of the Act.

An assessment of GBC Winstone’s overburden proposal is required under s32(1b). S32(1b) states: 1) (b) examine whether the provisions in the proposal are the most appropriate way to achieve the objectives by—

(i) identifying other reasonably practicable options for achieving the objectives; and

(ii) assessing the efficiency and effectiveness of the provisions in achieving the objectives; and

(iii) summarising the reasons for deciding on the provisions; and

(c) contain a level of detail that corresponds to the scale and significance of the environmental, economic, social, and cultural effects that are anticipated from the implementation of the proposal.

2) An assessment under subsection (1)(b)(ii) must—

(a) identify and assess the benefits and costs of the environmental, economic, social, and cultural effects that are anticipated from the implementation of the provisions, including the opportunities for—

(i) economic growth that are anticipated to be provided or reduced; and

(ii) employment that are anticipated to be provided or reduced; and

(b) if practicable, quantify the benefits and costs referred to in paragraph (a); and

(c) assess the risk of acting or not acting if there is uncertain or insufficient information about the subject matter of the provisions.

Three options have been identified for assessment:

1. Adopt proposal.

2. Modify proposal (for example include smaller area for overburden disposal where effects can be mitigated, remedied or avoided).

3. Do not adopt proposal.

ALTERNATIVES EVALUATION

Costs Benefits

Option 1:

Add overburden area

Environmental Potential for significant adverse effects on visual amenity of adjoining landowners and residents. Does not meet objective MEA 1.2.1 of PC102. Reverse sensitivity effects of a new mineral extraction activity taking place in close proximity to an existing sensitive landuse (residential and rural residential development). Economic Loss of property values for adjoining property owners. Social Loss of enjoyment of views/amenity for adjoining landowners and residents. Cultural Potential adverse effects on site of significance to Maori.

Environmental None known. Economic Provides certainty for GBC Winstone investment decisions. Allows for continued extraction of regionally significant resource. Social None known. Cultural None known.

Option 2: Amend proposal

Environmental Could still result in some effects on adjoining property owners/residents. Economic Could still be some loss of property value for adjoining landowners. Uncertainty for outcome for GBC could impact on investment decisions, resulting in less extraction of regionally significant resource. Social Could still lead to some loss of enjoyment/amenity for adjoining landowners and residents. Cultural Could still result in adverse effects on site of significance to Maori.

Environmental May allow adverse effects to be avoided, remedied or mitigated. Economic May allow for continued extraction of regionally significant resource. Could lessen loss of property values for adjoining properties. Social May limit the scale of effects or number of people adversely affected. Cultural May allow adverse effects to be avoided, remedied or mitigated.

Option 3: Do not adopt proposal

Environmental None known. Economic Uncertainty may influence investment decisions, resulting in less extraction of regionally significant mineral resource Potential for increase in cost of aggregate for development projects. Social Higher housing and development costs . Potential for less jobs to be created. Cultural None known.

Environmental Avoids adverse effects on adjoining landowners and residents. Economic No impact on property values of adjoining landowners. Social No adverse effects on amenity for adjoining property owners and residents. Cultural Avoids potential adverse effects on site of significance to Maori.

ALTERNATIVES EVALUATION

Efficiency Effectiveness

Option 1: Option 1 is not considered to be an efficient method of achieving the outcomes PC102 as there is potential for adverse effects.

Option 1 is not considered to be effective in achieving the outcomes of PC102 as there is potential for adverse effects.

Option 2: Option 2 is not considered to be an efficient method as there is insufficient information to determine if the outcomes of PC102 can be achieved.

Option 2 is not considered to be an effective method as there is insufficient information to determine if the outcomes of PC102 can be achieved.

Option 3: Option 3 is considered to be efficient in achieving the outcomes of PC102.

Option 3 is considered to be effective in achieving the objectives of PC102.

Economic Growth and Employment Opportunities

Option 1: This option provides medium growth and employment opportunities, as it allows for the development of a regionally significant mineral resource.

Option 2: This option provides low to medium growth opportunities. The opportunities are dependant on how the proposal is amended and how this affects the development of the regionally significant mineral resource.

Option 3: This option provides low economic growth and employment opportunities. It does not provide for overburden disposal in the area proposed. The opportunities for economic growth and employment are reliant on GBC finding another solution for overburden disposal.

Risk of acting and not acting if there is uncertain or insufficient information

There is risk of acting due to insufficient information for Option 1 and 2.

Overall, it is concluded that Option 3 (do not adopt the proposal) is the best option.