REPORT TO THE COMMISSIONERS - Manawatu …...Section 42A Technical Report Application Number...

BEFORE THE HEARING PANEL

IN THE MATTER of the Resource

Management Act 1991

AND

IN THE MATTER of applications for

Resource Consent Application APP-

2005011098.01 by AFFCO NZ Ltd –

Whanganui for the discharge of odours and

other contaminants into air from the

operation of AFFCO Whanganui

Processing Works at Imlay Place,

Whanganui

REPORT TO THE COMMISSIONERS

DR BRENT COWIE (CHAIR), MR ANDREW CURTIS AND CR RACHEL KEEDWELL

SECTION 42A REPORT OF NATASHA CACILIA ADSETT - CONSENTS PLANNER

FOR MANAWATU-WANGANUI REGIONAL COUNCIL

4 October 2017

Section 42A Technical Report Application Number APP-2005011098.01 Prepared by Natasha Cacilia Adsett - Consents Planner for Manawatu-Wanganui Regional Council 4 October 2017

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A. INTRODUCTION

1. On 10 March 2017 AFFCO New Zealand Limited (the applicant) submitted an

application to the Manawatu-Wanganui Regional Council (MWRC) seeking to

renew their existing resource consent for the discharge of contaminants into air

from their Whanganui plant, including odour and contaminants from the use of

the gas fired steam boilers and a proposed new packages wastewater

treatment plant. This report provides an analysis of the resource management

issues with respect to the proposal by the applicant.

2. The applicants Air Discharge Permit expired on the 31 July 2017. As the activity

was existing and an application was made between 3-6 months prior to expiry

the applicant has sought and had approved existing use rights under s124 of

the Resource Management Act 1991 (RMA). This means the applicant can

continue to discharge to air in accordance with their existing consent until such

time a decision has been made in regards to this application. A copy of this is

attached in Appendix 1.

3. The assessment and recommendations contained within this report are

intended to help inform the Commissioner with their decision.

4. This report has been prepared after consideration of the Assessment of

Environmental Effects (including associated reports) and submissions received.

The recommendations and conclusions within this report may be reconsidered

following the pre-circulation of Applicant and Submitter evidence and any

presentations at the hearing.

5. This report should be read in conjunction with the reports prepared by Deborah

Ryan, Associate Air Quality Consultant, Jacobs NZ, working on behalf of the

MWRC and Pita Kinaston, Team Leader – Consents Monitoring, MWRC.

Qualification and Experience

6. My name is Natasha Cacilia Adsett. I am employed by the MWRC as a

Consents Planner. I am providing evidence in these proceedings on behalf of

the Regional Council.

7. I hold a Bachelor of Resource Management and Environmental Planning (with

Honours 2:1) from Massey University.


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8. I have been employed by the MWRC since January 2016. Prior to this I was

self employed as a planning consultant.

9. My role at MWRC involves the processing of resource consent application

throughout the Manawatu-Wanganui Region. This involves processing a wide

range of consents including land use consents, water permits and discharge

permits for a number of different industries and sectors. In this role I make

recommendations to the Regulatory Manager and independent hearing panels

as to whether a consent application should be granted or declined and, where

appropriate, conditions.

10. I have approximately nine years resource management experience. This

experience has covered a number of roles including preparation and notification

of a Regional Plan and consent processing. My experience has predominately

focused on planning at a Regional Council level and also overseas in the United

Kingdom where I worked for a private firm providing planning advice.

11. I have read and agree to comply with the Code of Conduct for Expert Witnesses

as contained in the Environment Court’s Consolidated Practice Note (2014).

My qualifications are set out above. I confirm that the issues addressed in this

brief of evidence are within my area of expertise. I have not omitted to consider

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

expressed.


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B. OUTLINE

12. My report has been prepared and covers the following matters:

a. a brief outline of the background to this current application;

b. a brief description of the proposal;

c. a brief description of the site and environment;

d. an outline of the notification process;

e. a summary of the matters raised in submissions made on the consent

application;

f. an assessment of the environmental effects associated with the activities

proposed in the resource consent application;

g. an assessment of the proposal against the planning framework including

the relevant National Environmental Standards, National Policy

Statements, Regional Policy Statements and Regional Plans as they

relate to the resource consent application;

h. an overall judgement; and

i. a recommendation.

13. In accordance with section 42A (1A) and (1B) of the RMA. To minimise the

repetition of information included in the application and where I have considered

it appropriate, adopted that information of any other reports.


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C. BACKGROUND

14. The applicant, on page 2 of their application, describes all activities which

currently occur on site which includes:

a. Stockyards for sheep and lambs, and bobby calves from July to October

b. Truck washing

c. Animal slaughtering

d. By-products rendering

e. Natural gas fired 10.5 MW steam boiler

f. Meat and by-product processing including fancy meats and casing

g. Refrigeration using ammonia

h. Water abstraction covered under resource consents 103224 and 106039;

and

i. Ongoing maintenance of the plant and odour mitigation systems; and

j. Primary wastewater treatment plant (PWTP)

15. In addition to the existing activities on site the applicant is also proposing a

package chemical wastewater treatment plant (CWTP) which is yet to be

installed.

16. The applicant is seeking consent for the discharge of contaminants to air,

including odour and particulate matter, from the activities described above in

paragraph 14 and 15.

17. The applicant advises this application is to replace those currently consented

by 103287 with two notable changes:

a. the fellmongery and associated wastewater operations are no longer

operating; and

b. the option of a new CWTP onsite.


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18. The following table summarises the existing and proposed activities and the

contaminate discharged:1

Table 1: Summary of the existing and proposed activities.

Activity Description Contaminants Discharged

By-products rendering (existing)

Low temperature rendering plant up to 14 tonnes per hour processing by-products sourced from both on and off-site to produce tallow and meal (sheep and beef) and coagulated blood (processed off-site)

Odour

Existing primary waste water treatment plant and proposed chemical wastewater package plant

Site wastewater from slaughter floor, stockyards, rendering, truck wash and boiler blowdown

Odour

Truck washing (existing)

Stock trucks are washed down Odour

Stockyards

(existing)

Sheep and bobby calves up to 10,000 sheep housed at peak season, daily washdown

Odour – animal urine, faeces and sheep

Natural gas fired boiler (10.5 MW net) (existing)

Provide heat and hot water for site Products of gas combustion (PM10, CO, SO2 and NOX)

19. On the 12th of September 2017 a further information under Section 92 was

made to the applicant. Further information was requested in regards to odour

controls on the proposed packaged wastewater treatment plant, the acceptance

of raw material for rendering, clarifying which sources are vented to the main

biofilter, measures for advising the community of breakdowns (e.g. website) and

if anything has changed on site since the application was lodged. A copy of the

s92 letter can be seen in Appendix 2

20. A response to this request was received in draft format on the

29 September 2017 with a formal response provided on the 4th of October 2017.

This response is also contained within Appendix 2.

1 Adapted from the s42A report of Deborah Ryan, Associate Air Quality Consultant of Jacobs on

behalf of the Manawatu-Wanganui Regional Council


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21. The responses to these questions have been considered and incorporated into

my assessment.

Site and Location

22. The AFFCO site is located within the Whanganui City boundary, Imlay Place,

Whanganui. The site is near the Whanganui River mouth to the west of the city

centre.

23. The site is on the boundary between an industrial/manufacturing and residential

area of Whanganui. Residential dwellings are found mainly to the north and

east of the site while industrial and manufacturing sites are located mainly to the

west.

24. Open Country Dairy (OCD) adjoins the AFFCO site directly to the north. The

applicant advises OCD Is the most significant industrial neighbour. OCD also

hold a current Air Discharge Permit.

25. The southern boundary of the site adjoins a public walkway along the

Whanganui River.

26. The portion of the Whanganui River which the AFFCO site borders is part of the

Coastal Marine Area (CMA). However the CMA only extends so far as the bed

of the Whanganui River which the site is not within, only adjacent to. A copy of

Figure I4, taken from the One Plan (2016) and showing the CMA is included in

Appendix 3.

27. A map is provided in Appendix 4 which shows the boundary of the AFFCO site

and demonstrates its proximity to the river surrounding area.

28. I have undertaken two site visits to the site and also spent time visiting the

surrounding streets to help gain an understanding of the area.


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Notification and submissions

29. On the 6 April 2017 the applicant was verbally advised the effects on the wider

environment were deemed to be more than minor based on the draft reporting

of Ms Ryan and Mr Kinaston. The applicant was also advised the parties

deemed directly affected would be those living within a radius of up to 780

metres from the rendering plant. This radius was later finalised to be 750 metres

based on the final reports of Ms Ryan and Mr Kinaston.

30. The applicant requested time to consult with the parties within this radius prior

to MWRC publically notifying the consent.

31. On the 25 May 2017 the consent was publically notified with direct notification to

both owners and occupiers of properties within a 750 metre radius. In addition

to these properties the following parties were also directly notified in accordance

with Form 10 of the RMA:

a. Tupoho;

b. Ngā Tāngata Tiaki o Whanganui;

c. Tama Ūpoko;

d. Whanganui District Health Board;

e. Mid Central Health; and

f. Whanganui District Council

32. Notices of the public notification also appeared in the River City midweek paper

(25 May 2017), Whanganui Chronical (27 May 2017) and on the MWRC

website for the duration of the notification period.

Submissions

33. The submission period closed on the 23 June 2017. A total of 26 submissions

were received. Below, in Table 2, is a list of the submissions received by

MWRC. A summary of the submissions is included in Appendix 5 and a map

showing the location of the submitters in relation to the AFFCO site is included

in Appendix 6.


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Table 2: List of submitters

Sub #

Name Address Support / Oppose

Status (Heard/Not Heard)

1 Anthony Magnoli

26 Bignell Street, Wanganui 4501

Oppose Not identified

2 Graeme Billington 56 Bignell Street, Wanganui 4501

Support Not heard

3 Peter and Caryl Henderson 53 Balgownie Avenue, Wanganui 4501

Oppose Not heard

4. Whanganui District Council PO Box 637, Wanganui Mail Centre, Whanganui 4540

Neutral Not Heard

5 Christine Andrews 4B Kings Avenue, Wanganui

Neutral Not heard

6 Susan Hughes 25 Balgownie Avenue, Wanganui 4501

Oppose Not identified

7 Michael Jones 28 Muir Street, Whanganui 4501

Support Not heard

8 Sandi Black 71 Bignell Street, Whanganui 4501

Oppose Not heard

9 Rodney Emmett 5 Suanders Place, Wanganui 4501

Oppose Not heard

10 Public Health Service, MidCentral Health

Health Protection, Public Health Centre, Private Bag 3003, Whanganui

Neutral Not heard

11 Sharon and Mark Corrigan 59 Bedford Avenue, Whanganui 4501

Oppose Heard

12 Christine Kuzman 49 Balgownie Avenue, Wanganui 4501

Oppose Not Heard

13 Carole Ann Johnston 1 Swiss Avenue, Wanganui 4501

Oppose Not heard

14 Vicki Davies 4A Kings Avenue, Whanganui 4501

Oppose Not heard

15 Julian Emmett 2/5A Duigan Street, Wanganui 4501

Oppose Not heard

16 Lyn Pearson and Graham Pearson

9A Waitai Street, Castlecliff, Whanganui

Oppose Heard

17 Barbara Ann Allan and Alexander Graham Allan

31 Cross Street, Castlecliff, Whanganui

Oppose Heard

18 Te Runanga o Tupoho PO Box 5046, Whanganui Support Heard

19 Sharon Semple 34 Bignell Street, Wanganui 4501

Oppose Heard

20 Robert Jaunay 16 Lucknow Street, Aramoho, Wanganui 4501

Support Heard

21 Stephen Bryson 7 Saunders Place, Gonville, Whanganui

Oppose Not Heard


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22 Reuben Davis 51 Balgownie Avenue, Gonville, Whanganui

Neutral Not Heard

23 Mikolaj Andrzej Glowacki 21B Balgownie Avenue, Gonville, Whanganui

Neutral Not Heard

24 Patricia Mary Marsh 10 Balgownie Avenue, Gonville, Whanganui 4501

Oppose Not heard

25 Three Angels Family Trust 12 Beach Road, Whanganui

Oppose Heard

26 Ainsley Michelle Brunton 12 Beach Road, Whanganui

Oppose Heard

34. In regards to wishing to speak at a hearing, of the 26 submitters, 8 wish to be

heard, 2 have not stated if they wish to be heard or not and 16 do not wish to be

heard.

35. At the time of writing none of the submitters have withdrawn their consent nor

their wish to be heard.

Summary of submissions

36. I have read all of the submissions and undertaken the following analysis in

Table 3 to identify the key issues and points raised by submitters.


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Table 3: Summary of issues raised:

Issue / points raised Raised by submitter Addressed through:

Odour effects 1, 2, 3, 5, 6, 7, 9, 10, 11, 12, 13, 14, 16, 17, 18, 19, 20, 21, 22, 23, 24, 25, 26

See Appendix 7 – Conditions 9 - 13, 19 - 21

Health effects 8, 9, 10, 11, 13, 14, 15, 21 See Paragraph 56 of this report

Benefit AFFCO has to the community

2, 5, 14, 16, 17, 22 See Paragraph 86 of this report

Pollution hotline (or number to call) / Odour monitoring

7, 16, 17, 20, 21, 25, 26 See Appendix 7 – Conditions 20, 23-26

Enforcement by HRC / Consent conditions

7, 8, 11, 15, 16, 17, 18, 19, 22 See Appendix 7 – Conditions 34, 35. See also the s42A report of Pita Kinaston

Property concerns (price/ rent) 6, 13, See paragraph 39 of this report

Proposed mitigations (support and oppose) / Maintenance of existing mitigations/ alternative mitigations

2, 4, 6, 7, 8, 10, 11, 13, 14, 15, 16, 17, 24

See Appendix 7 – Conditions 8, 16-17, 19, 34

Engagement with Iwi 18 See Appendix 7 – Condition 24

Discharge from Milk Plant 21 See Paragraph 40 of this report

Noise effects 3 See paragraph 41 of this report

Onsite Wastewater treatment plant

5, 10, 16, 17, 18, 25, 26 See Appendix 7 – Conditions 8 and 22

Shorter term including declining the application

1, 3, 5, 8, 12, 14, 16, 17, 20, 21, 25, 26

See Appendix 7 – Condition 36

Relocation of the operation / plant closing

1, 21 See paragraph 42 of this report

Livestock trucks 7 See Paragraph 43 of this report

Odour surveys 16, 17 See Paragraph 76 of this report.

Timeline for mitigations discussed within the AEE

16, 17, 20, 24 See Paragraph 61 of this report

Sources of offal and age when reaching site

23 See Appendix 7 – Conditions 12 – 14

37. As shown in column 3 of Table 3, in order to address the issues raised I have,

in Appendix 7, provided a table with my recommended conditions. Alongside

the conditions I have included my reasons and further consideration of the

issues raised by submitters.


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38. Some of the issues however are outside of the scope of what can be addressed

through the resource consent process. I have undertaken an analysis of these

issues below to allow the submitters to understand why I am unable to take into

account their concerns through this process.

39. Submissions 6 and 13 both raised concerns about the effect the odour has on

both property prices and also the ability to rent out a property. While this is

undeniably an effect the submitter may experience I am only able to consider

effects in the context of the RMA (e.g. those on the environment). However the

conditions suggested in Appendix 7 will assist in mitigating the effect of odour

on the local community.

40. Submissions 20 and 21 raised concern about the discharge from the OCD milk

plant site which adjoins the AFFCO site. OCD is a separate operation to

AFFCO and as such has its own separate consent they need to adhere too. As

OCD is a separate site and not subject to this consent I am unable to address

any discharge from the Open Country site as part of this report.

41. Submission 3 raises concerns about noise from the AFFCO site. Under the

RMA duties are split between local (District) and Regional Councils. In this case

any concerns about the level of noise generated by the AFFCO site is beyond

the functions of the MWRC and therefore I am unable to address this issue any

further.

42. Submissions 1, 20 and 21 raise the idea of relocating the plant or closing it. As

explained above under the RMA duties are split between local (District) and

Regional Councils. In this case the zoning of industrial areas is a District

Council function and as such I am unable to address this issue further

43. Submitter 7 raises concerns about ensuring livestock trucks are fully compliant

with relevant regulation for livestock road transportation. This is a function

overseen by the ‘Ministry for Primary Industries’ and not a function MWRC. As

such I am unable to address this issue further.


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D. SECTION 104 - EVALUATION

44. The provisions of section 104 of the RMA must be considered by the consent

authority in making a decision on the resource consent application. In my

opinion, the matters contained in section 104 that are of relevance to the

application include:

45. 104(1)a. Actual and potential environmental effects. An assessment of the

environmental effects has been provided with the application. I have also

considered the section 42A report prepared by Deborah Ryan in regards to

odour and discharges from the boilers, and the report of Pita Kinaston regarding

the compliance history of this site. An assessment of the actual and potential

effects of the activity is given below:

a. National Environmental Standards. I have identified the National

Environmental Standard for Air Quality (NESAQ) as being relevant to this

application.

b. Other regulations. I have not identified any National Regulation as being

relevant to this application.

c. Relevant National Policy Statements. . I have not identified any National

Policy Statements as being relevant to this application.

d. New Zealand Coastal Policy Statement. The New Zealand Coastal Policy

Statements is not relevant to this application due to the discharge not

being in the Coastal Marine Area.

e. Relevant Regional Policy Statements. An analysis of the operative

Regional Policy Statement (Part I of One Plan).

f. Relevant Regional and District Plans. I have undertaken an assessment

of the proposal against the Operative Regional Plan (Part II of the One

Plan).

Any other matters considered relevant. In this section, I address further

information requirements, term and conditions.

E. ACTUAL AND POTENTIAL EFFECTS ON THE ENVIRONMENT

46. In the following sections I will provide an assessment of the actual and potential

effects on the environment from the proposal.

47. In assessing the actual and potential effects of the proposed activities, I have

considered the application, and s42A reports by Ms Ryan and Mr Kinaston.


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48. The following are the headings used to focus on the main effects:

a. Effects from odour;

b. Effects from boilers; and

c. Benefit AFFCO has to the community

Odour effects

49. As reflected in Ms Ryan’s and Mr Kinston’s report odour is a very subjective

matter and the adverse effects can vary greatly between different people. Odour

can also have a very ‘personal’ effect on a person in the sense that it can enter

a person’s private residence and disrupt daily life. From a compliance

perspective odour matters can often be difficult to take action upon as the

effects are influenced heavily by weather and, in some instances, when

responded to the odour will be gone. Unlike other pollutants odour is not

something which can be captured for testing.

50. Ms Ryan has undertaken a comprehensive assessment of odour effects to date

as a result of the plant. Mr Kinaston has undertaken an assessment of the

complaints received by the MWRC between July 2007 and July 2017 (i.e. the

term of the current consent). Both reports are considered necessary to

understand the potential effects resulting from the proposal.

51. Using these two reports I have considered the following components associated

with odour effects:

a. Odour controls in place at the site;

b. Health effects;

c. Mitigations proposed by the applicant;

d. Proposed packaged wastewater treatment plant;

e. Compliance records; and

f. Odour surveys; and

g. Conclusion.


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Odour controls in place at the site

52. Ms Ryan advises the sources of odour from the site will be mostly associated

with the rendering plant. There are three main measures in place to control

odour from the rendering operation:

a. Processing material as fresh as possible. Ms Ryan notes material is

sourced from two local plants being Whanganui and Fielding;

b. Stabilisation of material which is not ‘fresh’; and

c. Use of a point source extraction system and biofilter setup to capture and

neutralise odours.

53. I agree with Ms Ryan that the ability for the site to ensure there is no odour

beyond the property boundary relies on the applicant’s ability to manage the

raw material and ensuring the odour control system is well maintained.

54. Ms Ryan identifies the odour system is sealed and requires careful

management to ensure there are no leaks. This is crucial as any leaks into the

rendering building (which does not otherwise form part of the odour control

system) could result in fugitive odours being discharged directly to the

atmosphere.

55. From Ms Ryan’s evidence it is clear that monitoring and maintenance of the

system is key to minimising the risk of failures resulting in direct discharges of

odour, with the potential to have adverse effects downwind.

Health effects

56. Health effects as a result of the site, particular when odour is discharged

beyond the property boundary in a manner which is deemed offensive and

objectionable to the point it creates an adverse effect, is an issue raised by

several submitters.

57. Ms Ryan identifies, in regards to health effects resulting from odour, repeated

exposure to offensive and objectionable odours can affect people’s general

well-being and may cause feelings of nausea, stress and headaches and

reduced quality of life. This sentiment is reflected in many of the submissions

which raise health effects as a concern and/or object to the presence of odour.


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58. Ms Ryan, however, goes on to state that it is generally accepted that, for

odorous compounds, the human nose is very sensitive to low concentrations of

these compounds, and they are not present in concentrations that would give

rise to harmful physical health effects.

59. Ammonia is one chemical that will be present from the sheep yard operation.

Low concentrations of ammonia can cause coughing, and nose and throat

irritation. However, based on Ms Ryan’s evidence, Ammonia's odour threshold

is sufficiently low to acutely provide adequate warning of its presence2.

60. AFFCO advised during the site visit that they monitor ammonia levels

continuously using gas detectors in the sheep yards to ensure levels do not

build up to harmful levels.

Mitigations

61. As observed on the site visit and also reflected in Ms Ryan’s report

maintenance work on the biofilters was overdue in March 2017 when the

application was lodged and there was a lack of evidence that any work had

been undertaken when both Ms Ryan and I attended a site visit in August 2017.

62. Several submitters have raised the mitigations suggested by the applicant in

their AEE with most agreeing they are appropriate and supporting their

implementation. The mitigations are listed in table 5, on page 27 of the AEE.

The measures include upgrades to the existing biofilter, connection of a force

ventilation fan to the outside raw material bin and inspections and upgrades to

existing systems. All of these matters have been addressed in the conditions as

something which the applicant will be required to take action on. In terms of

meeting their proposed July 2017 timeline I am not aware if these mitigations

have occurred or not. In regards to the other mitigations the applicant may like

to provide an update prior to or at the hearing.

2 Agency for Toxic Substances & Disease Registry, Medical Management Guidelines for Ammonia

(NH3), 2014


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63. Ms Ryan advises, with the exception of requiring covers on the raw receipt bins

at all times and the delivery area not being completely enclosed, overall she

considers that the management and odour control systems in place are

appropriate and in line with the current good practice in New Zealand (i.e. the

use of indirect meal dryers and a WHE for stickwater recovery, with

appropriately sized biofilters).

64. The covering of the raw bin receipt area at all times is a recommendation made

by Golders to improve this practice within the AEE. However during the visit in

August 2017 this did not appear to have been actioned with the covers being

present but not on the bins.

65. Ms Ryan identifies that industry good practice recommends both the bins and

also the receiving area (i.e. the area where a truck may deliver the material and

offload it) should be covered. Therefore the recommendation from the AEE is a

compromise in the sense that fugitive odour could still escape when deliveries

are made.

66. I am of the opinion the upgrading of mitigations as per the AEE and ongoing

maintenance should be included within conditions. A condition which requires

the applicant cover the bins at all times, along with the addition of an enclosed

areas for deliveries and connect this to the odour extraction system has been

included within the set of conditions.

Proposed packaged treatment plant

67. The applicant has an existing primary treatment plant for site waste water. The

applicant proposes a new CWTP to provide additional treatment of wastewater

on-site. If the CWTP is built then the applicant is proposing to install an

additional biofilter to treat air from the balance tanks and mixing tanks. Point

sources of odour within the solids dewatering building are also identified as

needing to be vented to the new biofilter. The applicant has not proposed to

ventilate the clarifier as part of the design and is proposing a “wait and see”

approach to see if this source results in odours requiring treatment once it is

operational.


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68. A ‘wait and see’ approach is not appropriate. In order to ascertain the potential

odour effects of the proposed packages wastewater treatment plant would be I

addressed the matter in a further information request (under s92 of the RMA).

This requested the applicant provide examples of other sites where covering the

clarifier has not occurred and what the resulting odour effects were.

69. After reviewing the further information Ms Ryan has advised the sites Golder

referenced were at Alliance Lorneville, outside of Invercargill and Tuakau

Proteins. Ms Ryan advises both these sites differ from Imlay, in that they are

within rural environments some distance from urban residential areas, whereas

Imlay is within the urban environment

70. Ms Ryan expresses concern that in the event that there are odour issues with

the clarifier, the burden of proof for any enforcement action would be on the

Regional Council, which would likely be time consuming and difficult to

distinguish the source as being the new plant, particularly for a site as complex

as this with multiple odour sources.

71. Ms Ryan has recommended, a precautionary approach be adopted. I agree

with this approach particularly given the sensitivity of the receiving environment

and the level of impact from odour already experience by the community.

72. I have included a condition recommending that if the CWTP is constructed that

the clarifier is to be connected to the odour extraction and control system to

minimise the risk of an additional source of odour extending beyond the

property boundary.

Compliance records including complaints

73. The applicant’s complaint records to date have been relatively poor due to the

large number of complaints received. In reviewing the complaints received while

the applicant has been operating under their current consent I note there have

been some 226 complaints received by MWRC and this has resulted in 12

counts of formal action being undertaken 10 of which resulted in fines.


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74. Many of these incidents can be linked back to breakdowns or failures at the

plants for example breakdowns within the machinery processing the material. It

is noted that if a breakdown occurs mid processing it is difficult to extract the

material being processed. This means once the machinery is fixed the material

‘trapped’ in the system needs to continue through the system which can result

in the processing of old and consequently odorous material being processed.

Mr Kinaston identifies this to be the cause of the incidents associated with

notice numbers AN0670, IN0502, IN00503.

75. Based on the evidence of Ms Ryan and Mr Kinaston, many of the incidents are

linked to the processing of aged materials. This was identified as the cause of

the incidents associated with notice numbers IN00603, IN00604, IN00605,

IN00606, IN00607 and IN00608.

Odour Surveys

76. Submitters 16 and 17 both requested provision of odour surveys. Ms Ryan was

asked to comment on her report in regards to these and has advised:

Odour annoyance surveys measure the percentage of the population annoyed

by odour in a community. There are limitations to the approach including,

obtaining a suitable area representative of a potentially impacted population to

obtain a sufficient sample size. The sample area should not be so large,

however, as to dilute the measured annoyance. There may also be difficulty in

separating annoyance for a particular source where communities are potentially

impacted by a number of odour sources. In addition, it is increasing difficulty to

conduct surveys with statistical robustness due to the reduction in households

that have landlines. While odour surveys initially showed promise as an

objective way of measuring effects of odour, it is my understanding they are not

widely used in New Zealand as a monitoring and assessment tool for odour.

This means there is a limited pool of surveys and of those that have been done

methodologies have varied. As a consequence there is still uncertainty as to

how survey results are to be interpreted and at what level annoyance becomes

unacceptable.

In my view, community engagement through a community liaison group

provides an opportunity for more meaningful, direct and timely feedback for


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understanding the impacts and effects from odour on neighbouring

communities.

77. On this basis I have not recommended including provision for odour surveys in

the recommended conditions in Appendix 7. I have however provided for a

community liaison group.

Conclusion in regards to odour

78. Based on the evidence of Ms Ryan and Mr Kinaston and the compliance history

of the previous consent I am of the opinion that management is a key

component to addressing the odour from the site. With the right management

the site can be adequately managed to ensure no offensive or objectionable

odour occurs beyond the boundary to the extent it causes an adverse effect. I

am of the opinion the applicant needs to undertake a more proactive

management of the site to minimise the potential effects of odour.

79. To ensure the site is proactively managed I have recommended a set of

conditions which creates an ‘umbrella’ approach in the sense of requiring an

overarching site management document which provides for specific

management plans for various aspects of the site which create a plan for

meeting the specific environmental standards required. It is a prescriptive

approach aiming to require the applicant to undertake more proactive

management of the site.

Effects from boiler operation

80. The applicant proposes to continue the use of a single gas fired boiler with a

rating of 10.5MW. This boiler provides steam and hot water for processing and

rendering operations on the site.

81. Ms Ryan has reviewed the method used by the applicant to assess the effects

of the discharges from the gas fired boiler. Ms Ryan reports the effects of air

discharges from the 10.5 MW (net) gas fired boiler were assessed in

conjunction with the discharges to air from the OCD processing plant for NO2

and PM10 due to the close proximity of the OCD site. Ms Ryan notes only PM2.5

from the AFFCO boiler was included, with the powder driers assumed to

contribute negligible amounts of PM2.5. The applicant used the dispersion model


21

‘CALPUFF Version 7.2.1’. Ms Ryan advises this model is routinely used across

Australia and New Zealand for air quality assessments and it is considered

acceptable for use in this assessment.

82. Ms Ryan advises the cumulative impacts for NO2 as 1-hour and 24-hour

averages are shown to be acceptable and the discharges will not cause an

exceedance of the NESAQ.

83. Ms Ryan has considered the maximum predicted PM10 concentrations

cumulatively from both OCD and AFFCO as 24-hour averages are shown to be

10µg/m3 in the residential area to the north. This will not cause an exceedance

of the NESAQ, when considered with the potential background levels.

84. Ms Ryan agrees with the assessment and the conclusions reached by Golder

that the gas fired boiler discharges will have a less than minor effect on air

quality.

85. To ensure the effects of the gas fired boiler remain less than minor I have

recommended conditions which require the boilers to be tuned and tested to

ensure the effects continue to be as predicted.

Benefit AFFCO has to the community

86. Submitters 2, 5, 14, 16, 17, 22 have all raised points about the benefit AFFCO

has to the Whanganui community. This includes AFFCO Imlay being a

beneficial workplace for the community and asking that the site remains open

because of the support it provides to Whanganui and wider region.

87. In section 5.5 of their AEE the applicant outlines the positive effects and note

they employ around 600 staff at the peak season. The AEE also advises the

plant’s financial contribution to the local area is in excess of $10 million per

annum in terms of labour and contractor on site as well as providing an

important service in support of the local and wider farming community.

88. I agree with the applicant conclusion that this is a positive effect of the

application.


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F. NATIONAL ENVIRONMENTAL STANDARDS (NES)

89. Section 104 requires consideration of any NES’s that are relevant. In this case I

consider the National Environmental Standard for Air Quality (NESAQ) to be the

only relevant NES to this application.

90. As the applicants AEE details in section 9.4.2 the NESAQ has a number of

restricted or prohibited activities, none of which include the activities applied for

by the applicant therefore these matters are not applicable in this instance.

91. I also agree with the AEE that regulation 17(1) of the NESAQ requires certain

applications to be declined where there is likely to be an increase in PM10 by

more than 2.5 micrograms per cubic meter in any part of a polluted air shed.

This discharge is not in a gazette air shed therefore this regulation is not

relevant.

92. The AEE also highlights the need to consider Regulation 20 of the NESAQ.

93. Based on the application and Ms Ryan’s evidence I am satisfied the proposed

discharge is not breaching the ambient air quality standards and is also not a

principalle source of NO2 therefore Regulation 20 is not applicable. On this

basis I am of the opinion the NESAQ will not cause any reason to restrict the

granting of this consent.

G. OTHER REGULATIONS

94. Section 104 requires consideration of any other regulations which may be

relevant. In this case I am satisfied there are no other regulations which are

relevant to this application.

H. NATIONAL POLICY STATEMENTS

95. Section 104 requires consideration of National Policy Statements (NPS) that are

relevant. Given the AFFCO site is located adjacent to the coastal marine area

(CMA) I have reviewed the New Zealand Coastal Policy Statement to see if it is

applicable to this consent application. The NZCPS specifically covers the CMA

with no policies which seek integrated management with areas beyond the

CMA. In this case I am satisfied there are no NPS which are relevant to this

application.


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I. REGIONAL POLICY STATEMENT - ONE PLAN PART I

Operative One Plan

96. The One Plan was made fully operative on 19 December 2014. This document

contains the relevant Regional Policy Statement and Regional Plan provisions

applicable to the application.

97. On 28 April 2016 the One Plan was amended to insert the interim policy A4

from the NPS-FM and correct other minor errors. This plan change was non-

notified. Consequently the plan is referred to now as the One Plan (2016) to

reflect the changes made in 2016.

Regional Policy Statement

98. Section 104(i)(v) of the RMA requires consideration of a Regional Policy

Statement (RPS), in this case part one of the One Plan. Rather than repeat the

objectives and policies, I have provided commentary of the relevant objectives

and policies below and the full text of the provisions are contained within

Appendix 8.

99. The following table provides a summary of the relevant Objectives and Policies

of the RPS I consider relevant to this application.


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Table 4: Summary of the Relevant Objective and Policies from Part 1 of the One Plan (2016)

Objective: Policy:

Chapter 2: Te Ao Maori

Objective 2-1: Resource management Policy 2-1 Hapu and iwi involvement in

resource management

Policy 2-2 Wahi tapu, wahi tupuna and

other sites of significance

Policy 2-4 Other resource management

issues and Table 2.1 (f)

Chapter 3: Infrastructure, Energy, Waste, Hazardous Substances and

Contaminated Land

Objective 3-5: Waste, Hazardous

Substances and Contaminated Land

Policy 3-8 Waste policy hierachy

Policy 3-9 Consent information

requirements – waste policy hierarchy and

hazardous substances

Chapter 7: Air

Objective 7-1: Ambient air quality Policy 7-1: National Environmental

Standards

Objective 7-2: Fine particle (PM10) levels Policy 7-2: Regional standards for

ambient air quality

Policy 7-3: Regulation of discharges to air

Chapter 8: Coast

Objective 8-1: Integrated management of

the coastal environment

Policy 8-1: Integrated management of the

coastal environment

100. Chapter 2 of the RPS identifies resource management issues of significance to

hapu and iwi. I agree with the applicant’s identification, in section 9.3.2.1 of their

AEE, of Objective 2-1 and Policies 2-1, 2-2, 2-3 and 2-4(f) and being of

relevance to this application.

101. The applicant has advised the activity is not taking place within a statutory

acknowledgement area, does not contain any heritage items or silent files and I

am not aware of any sites of significance in the immediate vicinity.

102. I note Objective 2-1 and Policy 2-1 strongly encourage Hapu and Iwi

involvement in the resource management process. The applicant has engaged

with Iwi prior to notification and local iwi were directly notified.

103. The applicant has demonstrated a wiliness to engage with local Iwi and Hapu in

accordance with the Objectives and Policies of the One Plan (2016).


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104. Chapter 3 outlines how activities involving infrastructure, renewable energy,

waste, hazardous substances versatile soils and contaminated land will be

managed. I agree with the applicant’s identification, in section 9.3.2.1 of their

AEE, of Objective 3-5 and policies 3-8 and 3-9.

105. This set of objective and policies address the management of waste. In regards

to this activity this is waste generated on site as a result of processing and then

either separated as solids or taken off site or in the case of liquids processed on

site and then discharged through the Whanganui Waste Water Treatment Plant.

106. Chapter 7 addresses air quality and I agree with the applicants AEE that

Objective 7-1 and 7-2 along with Policies 7-1, 7-2 and 7-3(b) are of relevance to

this application.

107. Objective 7-1 concerns ambient air quality. This objective seeks to ensure air

quality, in a broad sense, is maintained and is not which is not detrimental to

amenity values, human health, property or the life-supporting capacity of air and

meets the national ambient air quality standards. From Ms Ryans evidence, the

cumulative impacts for nitrogen dioxide (NO2) as 1-hour and 24-hour averages

are shown to be acceptable and the discharges will not cause an exceedance of

the National Environmental Standards for Air Quality (NESAQ). The proposal

will maintain the existing air quality in terms of the boiler discharge and

therefore is considered consistent with this objective.

108. Policy 7-1 Concerns National Environmental Standards. As stated above in

paragraph 107 I do not hold any concerns that these are not being met.

109. However in the past there has been concern on both neighbours part (as raised

through both complaints and also submissions to this application) regarding the

effect of the air quality from the site, particularly odour, on amenity, health and

property values.

110. The complaints about the site do not support odour being an ongoing, daily,

concern. However it is clear from the report of Mr Kinaston there have been

some significant failures at the site in the past, particularly with breakdowns,

which have compromised air quality. I am of the opinion, with ongoing

maintenance of the odour control system and good site management odour

effects can be mitigated.


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111. Policy 7-2 sets out specific standards for the discharge of Odour, Dust, Smoke

and Water Vapour, Agrichemicals, and Gases and other airborne contaminants.

In this instance I consider the standards for Odour and Gases and other

airborne contaminants to be most relevant to this application.

112. With regards to odour the recommended standard is a discharge must not

cause any offensive or objectionable odour beyond the property boundary to the

extent that there is an adverse effect. It is well acknowledged that the applicant

produces odour on the site. While there are a number of mitigations in place

such as undertaking processing in enclosed buildings and the use of biofilters it

is clear, from the compliance history that the odour has at times travelled

beyond the property boundary. The odour has also, on a number of occasions,

been found to be offensive or objectionable by MWRC.

113. Mr Kinastons report identifies the odour has caused but is not limited to

residents being unable to undertake outdoor activities due to the offensive

nature of these odours, residents being unable to have windows open and

residents being unable to use outdoor clothes line as clothes needed to be

rewashed. These are very direct and invasive effects on individuals.

114. It has been established that the majority of these incidents can be attributed to a

break down at the applicants site with odour resulting from old material retained

in the broken down machinery.

115. With regards to gases and other airborne contaminants the standard is A

discharge must not result in noxious or dangerous levels of gases or other

airborne contaminants beyond the property boundary. Based on the evidence of

Ms Ryan I am satisfied the effects of these are less than minor and therefore

consistent with this part of Policy 7-2

116. Policy 7-3 allows for discharges to air within the region when they are generally

consistent with the guidance given by Policy 7-1 and 7-2. These policies are

very directive and give guidance to the Regional Plan section of the One Plan,

which I address further below. I am of the opinion these policies can be met with

appropriate management of the site in place.


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117. Chapter 8 of the regional Policy Statement concerns the Coastal Marine Area

(CMA). The Coastal Marine Area, in this case, includes the lower portion of the

Whanganui River as shown in Figure I4 of the One Plan and included in

Appendix 3 of this report.

118. While the applicant’s site is not within the CMA it is directly adjacent it and

therefore some of the objective and policies of this chapter are relevant

particularly in regards to compatible land uses.

119. Of relevance is Objective 8-1 and Policy 8-1 which concern integrated

management of the coastal environment. Of particular relevance of Policy 8-

1(b) which seeks to recognising and managing the effects of land uses and

freshwater-based activities (including discharges) on the CMA.

120. In this instance the discharge of odour to air by AFFCO has, in the past,

discharged beyond the property boundary to the extent that has been offensive

and objectionable. I recognise that this has the opportunity to negatively impact

the CMA particularly recreational and amenity values however I am of the

opinion it can be managed with the right site management and processes in

place.

J. REGIONAL PLAN – ONE PLAN PART II

121. The following is an assessment of the proposal against the Objectives and

Policies of the Regional Plan being Part II of the One Plan. Rather than repeat

the objectives and policies in full, I have provided commentary of the relevant

objectives and policies below the full text of the provisions are contained within

Appendix 8.


28

122. I consider that the following Objectives and Policies as set out in Table 5 are of

relevance to this application.

Table 5: Relevant Objectives and Policies from Part II of the One Plan (2016)

Objective: Policy:

Rule

Chapter 12: General Objectives and Policies

Policy 12-5: Consent

durations

Policy 12-6: Consent

review

Chapter 15: Air

Objective 15-1 Air Quality Policy 15-2: Consent

decision-making for other

discharges into air

Rule 15-10 Other

burning activities

Discretionary Activity.

Rule 15-17 Other

discharges

Discretionary Activity

Chapter 12: General Objectives and Policies

123. Provisions in chapter 12 provide guidance on how consent conditions should be

formulated and duration of consent.

124. Policy 12-5 is relevant when considering the consent duration for consents. For

consents related to RMA s15 (Discharge of contaminants into environment) the

policy guides the duration will generally be set to the next common catchment

expiry date which is on 1 July of the given year.


29

125. The applicant’s site is located in the ‘Coastal Whanganui Whai_7b’ catchment

which has a common catchment expiry date of 2015. Policy 12-5 guides, unless

the common catchment date is less than three years away, the expiry date

should be aligned with the common catchment date or the next 10 year

increments in this case 2025. The ‘next’ common catchment expiry date is not

within 3 years. There are exceptions whereby the consent can be granted for a

longer duration and within 10 year increments and Policy 12-5 lists matters to

be considered. These include factors such as the extent to which the activity is

carried out in accordance with good practice, considering the balance between

environmental protection and investments by the applicant, review opportunities

under s128 of the RMA and instances where the activity is a public facility (e.g.

sewerage or storm water plants). In instances where the consent is granted for

longer than 10 years the policy guides review dates should be set, as a

minimum, every 10 years.

126. Policy 12-6 provides additional guidance in regards to review conditions. The

policy sets out the need for review conditions to allow for the council to review

the appropriateness of conditions requiring the consent holder to supply

information to the council, manage any unknown or uncertain adverse effects as

a result of planned for required changes to the activity, review the conditions of

the consent at the same time as consents of a similar nature within the same

water management sub-zone and review the effectiveness of the conditions.

127. Further analysis of an appropriate duration and review dates is provided below

in other relevant matters.

Chapter 15: Air

128. Objective 15-1 seeks to manage air quality and supports the direction given in

the Regional Policy Statement, particularly by Objective 7-1 and Policies 7-1

and 7-2.


30

129. Policy 15-2 provides guidance to the Regional Council in making decisions on

discharges to air. This policy is considered a directive policy stating the

Regional Council must have regard to a number of factors listed in paragraphs

(a) through to (h) when making decisions and setting consent conditions. This

policy is of direct relevance when considering air discharges. Therefore I have

addressed each of these individually below.

130. Paragraph (a) of policy 15-2 requires the Regional Council to give consideration

to the Objectives and Policies of chapter 7 including the degree of consistency

with the approach in policy 7-1 for implementing the National Environmental

Standards^ for ambient air quality. As discussed in the report of Ms Ryan the

cumulative impacts for nitrogen dioxide (NO2) as 1-hour and 24-hour averages

are shown to be acceptable and the discharges will not cause an exceedance of

the National Environmental Standards for Air Quality (NESAQ) . The Policy also

requires the degree of compliance with the regional standards for ambient air

quality set out in Policy 7-2. Based on the assessment above, I consider the

application to be consistent with the ‘gases and other airborne contaminants’

standard and with the right management the applicant can be consistent with

the odour standard.

131. Paragraph (b) requires consideration of the guidelines in Section 15.3 for

managing noxious, dangerous, offensive and objectionable effects^. As detailed

in the s42A report of Mr Kinaston these are the guidelines used by MWRC in

assessing effects of odour complaints. This methodology has been consistently

used by MWRC for assessing complaints and Condition 9 of the recommended

conditions in Appendix 7 is also consistant with this approach.


31

132. Paragraph (c) requires consideration of any national policy statements^,

national regulations^, or nationally-accepted guidelines or codes of practice

relevant to the activity, including the matters in Policy 14-9 for activities

involving an ancillary discharge. Policy 14-9 concerns discharges to water or

land. I am of the opinion this is no relevant to this application. With regards to

national policy statements, regulations and guidelines I am of the opinion the

applicant is consistent with the National Environmental Standards^ for ambient

air quality (as discussed in paragraph 93). I am also of the opinion the Ministry

for the Environment Good Practice Guide for Assessing and Managing Odour

has been utilised and Condition 9 is consistent with these documents.

133. Paragraph (d) of policy 15-2 requires consideration of the location of the

discharge in relation to, and any associated effects on, sensitive areas

including, but not limited to:

a. residential buildings,

b. public places and amenity areas where people congregate,

c. education facilities,

d. public roads,

e. surface water bodies^,

f. wāhi tapu*, marae and other sites* of significance to hapū* and iwi*,

g. domestic, commercial and public water supply* catchments and intakes,

h. rare habitats*, threatened habitats* and at-risk habitats*, and

i. sensitive crops or farming systems (including certified organically farmed

properties* and greenhouses),


32

134. It has been well established in the site description (Paragraph 22) that the

location of the applicants site is in close proximity to the places listed in a-e.

The site has had issues with their air discharges on these sensitive

environments. From the evidence it is clear that odour (in particular) is an issue

that requires proactive management and ongoing maintenance of the system. I

am of the opinion that, with the appropriate management, the effects on these

areas can be managed and mitigated.

135. Paragraph (e) requires consideration of the effects on scenic, landscape,

heritage and recreational values. Ms Ryan advises under normal operation

there will be no visual discharge associated with the gas boiler operation, other

than a heat haze or possibly a steam plume under certain meteorological

conditions. On this basis I am satasifed the application will be consistant with

this section of the policy.

136. Paragraph (f) requires consideration the appropriateness of adopting the best

practicable option^ to prevent or minimise adverse effects^ in circumstances

where:

a. numerical guidelines or standards establishing a level of protection for a

receiving environment^ are not available or cannot easily be

established,

b. insufficient monitoring data is available to establish the existing air

quality with sufficient certainty, or

c. the likely adverse effects^ are minor, and the costs associated with

adopting the best practicable option^ are small in comparison to the

costs of investigating the likely effects^ on air quality,

In this case because a numerical value for odour effects cannot be established,

and the recommended standard for odour is subjective, I consider it appropriate

to assess whether the applicant’s proposal represents good industry practice.

I have also adopted a precautionary approach to my recommendations where

appropriate to minimise the potential for adverse effects from odour. I am

satisfied we have appropriate amounts of monitoring data to be able to establish

appropriate consent conditions.


33

137. Paragraph (g) requires consideration the need for contingency measures to

avoid accidental discharges^, including discharges^ arising from mechanical

failure. As discussed above in pararaph 22 and also in the s42A report of Mr

Kinaston, mechanical failures have in the past contributed to adverse effects

offsite. This has been an issue at this site and I have recommended conditions

which require proactive management to minimise any accidenctal discharges

from the site. A condition has also been recommended to ensure the applicant

continually reviews their systems and makes changes to ensure there are no

‘repeat’ failues..

138. Paragraph (h) requires consideration adverse effects^ on aircraft^ safety from

high velocity vertical discharges^ to air. The activity has long been established

at the site and issues around aircraft safety have not occurred to my knowledge,

therefore, I do not consider it likely that there would be effects on the operation

of the airport as a result of the vertical velocity of AFFCO’s discharges.

139. In conclusion I am of the opinion, with the right proactive management of the

site including ongoing maintenance of the odour control system, the application

is consistent with the relevant objectives and policies.

K. OTHER MATTERS THE CONSENT AUTHORITY CONSIDERS RELEVANT

Ngā Tāngata Tiaki o Whanganui

140. On 5 August 2014, at Ruakā Marae in Rānana, the Crown and Whanganui Iwi

signed Ruruku Whakatupua, being the deed of settlement for the Whanganui

River. Ngā Tāngata Tiaki o Whanganui is the post settlement governance entity

for Whanganui Iwi for the purpose of the Te Awa Tupua (Whanganui River

Claims Settlement) Act 2017.

141. A particularly special element of the Act is Te Pou Tupua. Te Pou Tupua has

the ability to act and speak on behalf of Te Awa Tupua; they uphold Tupua te

Kawa, the innate values of Te Awa Tupua, and promote the health and

wellbeing of the Whanganui River.


34

142. Iwi have been consulted with in regards to this application through both the

applicant prior to lodging the application and through the notification process,

with affected party notices served on three iwi affiliated with the lower

Whanganui River – Tupoho, Ngā Tāngata Tiaki o Whanganui and Tama Ūpoko.

143. A submission was received from Tupho (the resident iwi within Whanganui City)

and they have asked to be heard at the hearing.

144. I have also recommended in my conditions a community liaison group be (re)

formed and Tupoho, Ngā Tāngata Tiaki o Whanganui and Tama Ūpoko all be

given opportunity to participate.

L. CONDITIONS

145. As discussed above the compliance history of the applicant is poor. While I note

there have been periods of time where the applicant has not attracted any

complaints, overall 226 complaints and 12 counts of compliance action in a ten

year period is substantial.

146. As discussed above under section “E – Actual and potential effects on the

environment” I have recommended a set of conditions which creates an

‘umbrella’ approach in the sense of requiring an overarching site management

document which provides for specific management plans for various aspects of

the site which create a plan for meeting the specific environmental standards

required. It is a prescriptive approach aiming to require the applicant to

undertake more proactive management of the site.

147. A full schedule of recommended conditions can be seen in Appendix 7. In the

conditions,

Consent term and review clauses

148. In this section I set out the rationale and matters I consider important in

considering term and explain how I have arrived at regarding the

recommendations I made within.


35

149. As identified above the One Plan (2016) contains strong guidance on the

decision making surrounding the term of a consent. As the site is located in the

‘Coastal Whanganui Whai_7b’ and the activity is a s15 RMA matter, the policy

firmly directs the consent should be given an expiry date of 1 July 2025. This

creates a term of approximately 8 years.

150. I note the applicant has, in their application requested a term of 25 years. Policy

12-5 is relevant for consideration of a term beyond that of the first common

catchment expiry date is suitable, when requested by the applicant.

151. In considering a longer term, in line with the term requested by the applicant,

the policy under (b) directs the decision maker to consider factors such as:

a. the extent to which the activity is carried out in accordance with good

practice,

b. considering the balance between environmental protection and

investments by the applicant,

c. review opportunities under s128 of the RMA; and

d. instances where the activity is a public facility (e.g. sewerage or storm

water plants.).

Points a – c are of direct relevant to this application.

152. I have considered the matters in section (b) and do not believe the application is

contrary to any of the matters listed. The applicant has offered, as part of their

application, a number of mitigations. Ms Ryan, in her s42A report, advises

subject to the improvements recommended by Golder and an upgrade to the

raw materials receipt area, … the site operations do represent good industry

practice in terms of design, however, maintenance and operation of these

systems does not appear to have been in line with good practice .

153. The applicant has also offered yearly s128 reviews as part of their proposed

consent conditions.


36

154. Section (c) identifies the factors for considering a shorter term. This includes

factoring in if the activity needs to cease at a particular time, if the activity is

unpredictable and a precautionary approach is needed, if there is an allocation

issue relating to the resource and compliance history.

155. I have also considered section (c) and I am of the opinion the compliance

history provides considerable weight for the applicant being given a term which

is consistent with the common catchment expiry date as does the opinion of Ms

Ryan that maintenance and operation of these systems does not appear to

have been in line with good practice.

156. Odour is relatively unpredictable and the management of the site is key to

ensuring that the effects on nearby sensitive receiving environment is

appropriately managed. The renewal of this consent is for a similar activity to

the previous consent and the Applicants compliance history is considered poor

as highlighted within Mr Kinaston’s evidence particularly around odour.

157. This is also a matter a number of submitters have objected to. Some submitters

have requested that the term be reduced for a period of between 5 – 10 years.

158. I am of the opinion the applicant needs to demonstrate they can sustain a long

duration of good compliance with their consent before they can be awarded with

long term over and above the common catchment expiry date.

159. I have also considered if it is appropriate for a shorter term outside of the

common catchment date. While I am of the opinion there are grounds to allow

for a shorter term (based on their poor compliance history) I am also of the

opinion they have shown they can operate for periods of time little or no

complaints. Likewise I am also of the opinion the applicant needs to be able to

be given time to show a good and consistent compliance history and

demonstrate proactive management of the site.


37

160. For these reasons I deem it appropriate to recommend a term expiring on 01

July 2025, consistent with the common catchment expiry date. This term would

also recognise the existing value of investment the applicant has on site and the

poor compliance history and enable sufficient time for the applicant to

demonstrate they can be a good operator and reduce the number of complaints

received.

161. I have also considered use of a review under Section 128. The applicant has

offered yearly reviews.

162. In this case, I consider that the proposed annual review included within the

consent conditions will allow the Regional Council to address any unforeseen

effects that may occur. This also allows for the review of the monitoring

requirements.

M. STATUTORY ASSESSMENT

Part 2 of the Resource Management Act 1991 – Purpose and

Principles

163. I am aware of the recent case in the High Court known as Davidson Family

Trust v Marlborough District Council [2017] NZHC 52 [31 January 2017].

164. My understanding of this case is it essentially applies the principles of the King

Salmon case to consents. Therefore a full Part 2 assessment need not be

undertaken provided here is no known illegality, uncertainty or incompleteness

in the relevant part of the One Plan 2016.

165. On this occasion I am satisfied the One Plan provides certainty and is complete

in regards to the matters relating to discharges to air – including the provisions

of the NESAQ – are correctly reflected in the relevant objectives and Policies of

the One Plan.

166. As there are know known illegalities, uncertainties or incompleteness with the

One Plan relating to this consent no further assessment against Part 2 of the

Resource Management Act, 1991 is necessary.


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S104(2A) Value of investments

167. S104(2A) of the RMA states

When considering an application affected by section 124 or 165ZH(1)(c), the

consent authority must have regard to the value of the investment of the

existing consent holder.

168. Section 9.2.3 outlines the value of investment AFFCO has at the Imlay site

including capital value in excess of $75 Million, current peak staffing levels of

600 (and in the past up to 1000) with up to 80% of staff residing in Whanganui.

As detailed in paragraph 86 above they contribute around $10 Million annually

to the local economy.

169. I agree with the applicant that the site represents a major employer within the

Whanganui economy along with being a major financial contributor to the

Whanganui economy.

S105 of the Resource Management Act - Matters relevant to certain

applications

170. S105 (1) of the RMA states:

(1) If an application is for a discharge permit or coastal permit to do something

that would contravene section 15 or section 15B, the consent authority must, in

addition to the matters in section 104(1), have regard to-

(a) the nature of the discharge and the sensitivity of the receiving

environment to adverse effects; and

(b) the applicant’s reasons for the proposed choice; and

(c) any possible alternative methods of discharge, including discharge into

any other receiving environment.

171. s105 is relevant to this application as the discharge to air otherwise contravenes

s15 of the RMA, specifically s15(1)(c) No person may discharge any -

contaminant from any industrial or trade premises into air; or


39

172. With regards to (a) I note the activity is in a relatively sensitive receiving

environment in the sense that the surrounding area includes residential housing

along with areas popular for recreation. I am however of the opinion the set of

recommended conditions in Appendix 7 encourage proactive management of

the site including the existing odour controls in place. I am of the opinion this will

help to mitigate the effects on the surrounding environment.

173. With regards to (b) and (c) the applicant advises, in section 8.0 of their

application

174. The site is established with existing odour controls in place. The proposal for

the discharge of contaminants into air is site specific, and there are no

alternative locations for undertaking the activities that result in the discharge.

The operation of the plant and the odour mitigation measures have been

reviewed, and it is proposed to upgrade and improve the systems in order to

better mitigate odour from the site. On this basis it has been assessed that

there will be no significant adverse effects on the environment. The upgraded

odour mitigation will result in an improvement in the existing odour environment

at the site resulting in only minor adverse effects.

175. There is no alternative receiving environment for the discharge to air from the

activities at the site. The mitigation methods include the discharge passing

through odour control biofilters prior to discharge to air to ensure that the

adverse effects are minor.

176. I agree the site is established and has existing controls in place however it is

clear from the evidence presented there needs to be better management of the

odour controls in order to successfully mitigate odour from the site.

177. I agree the applicant needs to continue using the existing mitigation measures

and also upgrade the odour control system in order to minimise adverse effects

arising as a result of the odour discharge. This, combined with proactive

management as provided for by the recommended conditions in Appendix 7, in

my opinion, will mitigate the adverse effects.


40

N. CONCLUSION

178. I have considered the application, further information from the applicant

received on 4 October 2017 and the Section 42A reports of Ms Ryan and

Mr Kinaston. In addition I have also addressed the following in my report

above:

a. The actual and potential effects of the activities identified within the AEE;

b. The matters raised in the written submissions;

c. The statutory planning framework being the National Environmental

Standard for Air Quality and relevant sections of the Regional Policy

Statement and Regional Plan.

179. In terms of effects, I consider the proposal has the potential for a more than

minor effect as a result of the discharge of odour to air. I also consider that the

proposal will have less than minor effect as a result of the discharge of

particulates to air as a result of the operation of the gas fired boilers.

180. When considering the proposal against the planning framework I consider that

the proposal as it currently stands is broadly consistent with the planning

provisions in terms of the objectives and policies of the relevant regulations,

NES and the One Plan with the exception of the potential effects the discharge

of odour has on the surrounding environment. These effects are often as a

result of mechanical failures at the site and/or mismanagement of processes

such as the acceptance of unsatisfactory material.

181. Overall, after considering the above matters, I am of the opinion that this

consent can be granted, albeit for a term less than requested by the applicant. I

am also of the opinion that many of the concerns and causes of odour effects

can be adequately mitigated through the inclusion of conditions which require

far more proactive management than has been required of the site in the past.


41

O. RECOMMENDATION

182. I recommend that this consent be granted, with appropriate conditions requiring

more comprehensive management of the site including proactive management

by the consent holder, for a term expiring on 1 July 2025 for the reasons

identified above.

APPENDIX 1 - Section 124(2)e Letter and Response

8 March 2017 AFFCO New Zealand Ltd C/- Golder Associates (NZ) Ltd PO Box 2281 Christchurch 8140 Attention Jane West Dear Jane,

ATH-2007010926.00 JMM:YKS

Section 124(2)(e) – Continued Use Rights – Resource Consent No. APP-2005011098.00 (Previously 103287) – AFFCO Imlay, Whanganui. AFFCO Imlay, has requested that, pursuant to Section 124 (2) of the Resource Management Act 1991 (RMA), Horizons exercises its discretion to allow AFFCO to continue to operate under its resource consent APP-2005011098.00 allowing the discharge of contaminants to air to allow for the review of a draft application to be submitted prior to final lodgement. This is to confirm that pursuant to Section 124(2)(e) of the Resource Management Act 1991 that the Manawatu-Wanganui Regional Council agrees to exercise its discretion in respect of resource consent number APP-2005011098.00. It is important to note that a completed application relation to the above permit will need to be with Horizons no later than 30 April 2017. Failure to do so will result in these activities being unauthorised. If you have any questions in relation to this matter please do not hesitate to contact me on either 06 952 2871 or email [email protected]. Yours sincerely,

Greg Bevin Regulatory Manager

mailto:[email protected]

APPENDIX 2 – S92 Letter and Response

12 September 2017

AFFCO NZ Ltd - Wanganui PO Box 425 Wanganui 4540

Dear Sir / Madam, Additional Information Request for Application APP-2005011098.01

With regard to your resource consent application for AFFCO Whanganui Processing Works Renewal, we have determined that in order to fully assess the effects of your proposal additional information is required. The additional information is listed below and is requested under section 92(1) of the Resource Management Act 1. In section 4.3.2 you have proposed not to place an odour control measure on the

clarifier associated with the proposed packaged wastewater treatment plant. Please provide information or examples where odour control on clarifiers has/has not been needed to maintain an acceptable level of effects from odour on the environment. In particular, we would be interested in seeing information or examples from similar systems and circumstances. Please include comment on the nature and scale of any effects from odour in those circumstances and how they relate to your proposal.

2. Could Affco please provide the normal and maximum operating temperatures for the render vessel and the dryers? Is there scope to operate at lower temperatures as in general, the lower the temperature, the lower the odour potential?

3. We understand from the compliance history that raw material acceptance procedure in terms of age and or quality are not always met, and that it appears that out-of-specification material is processed, rather than implementing the contingency plan of sending to landfill. We are aware that raw materials that are degraded has been linked to odour complaint incidents.

a. It would be helpful if AFFCO could provide clarification and/or confirmation

of raw materials acceptance, preservation, monitoring and rejection practices eg confirm if all material sourced from off site is dosed with preservative chemical or is this age dependent? How is material age and adequacy of dosing confirmed?

b. How are the appropriate dosage rates of chemical set? Is there adequate mixing?

c. How is on-site generated raw material managed when there is a plant breakdown and rendering has to cease?

d. How is raw material age determined for compliance with age limits in the consent?

e. How many times has material been rejected due to not meeting age/quality requirements and where has it been sent? How many occasions has there been disposal to landfill in the last 10 years?

f. If landfill is not considered practical due to the expense, does AFFCO have any alternative to processing?

g. On start-up following a breakdown, is there any alternative to processing material that is already in the rendering plant and equipment? If not, how long does it take before the material is cleared and how often are these types of event envisaged?

h. Does processing of out of specification raw material result in rejection of meal or tallow due to poor quality? If product is rejected, how is this handled?

4. The schematic on page 12 of the AEE shows that sources other than the dryers on the dry-side of the building are ventilated to the main bio filter and include meal storage and building air – however, the figure differs from the description given, in that the text only discusses extraction of the meal handling facilities. Can you please confirm which is correct?

5. Have AFFCO considered any proactive measures for advising the community of

breakdowns eg. Notifications on website or an automated text message service people can sign up to?

6. Since the application was lodged can you please advise of anything has changed on

site that could have an effect on the potential for effects from odour to occur and if any complaints have been received by AFFCO within this time period?

Under the Resource Management Act, you must, within 15 working days of the date of this letter, take one of the following options:

a. provide the information; -OR- b. advise in writing that you agree to provide the information (at which point

we would negotiate a reasonable time within which the information will be provided); -OR-

c. advise in writing that you refuse to provide the information.

It would be appreciated if you could provide this information by or before the 27th of September 2017 so it can be incorporated into our reports for the hearing. You are obliged by the Resource Management Act 1991 to provide the information 10 days prior to the hearing i.e. The 16th of October 2017.

If you have any questions in regards to the determination or wish to discuss any aspects of this letter, please contact our office on 0508 800 800. Yours faithfully, asha Adsett Natasha Adsett CONSENTS PLANNER

APPENDIX 3 – CMA Whanganui

Figure I:4 Whanganui River and Whangaehu River mouth^ locations, cross-river CMA

boundaries and extent of the Estuary Water Management Sub-zones*

APPENDIX 4 – AFFCO Site Maps

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BEACH RDIMLAY PL

HEADS RD

BIGNELL ST

TAWA ST

KINGS AVE

SWISS AVE

CAIUS AVE

ABBOT ST

GONVILLE AVE

KARORO RD

BEAC

H RD

MUIR ST

DUIGAN ST

BALGOWNIE AVE

HARPER ST

PRINCE ST

BEDFORD AVE

GUNN

ST

CAMBRIDGE STELM

ST

LEAMINGTON ST

RATA ST

CENTRAL AVE

WORDSWORTH ST

MEULI ST

SAUN

DERS

PLBEAUMARIS AVE

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Whanganui

NOTE TO USERS: Land Parcel boundariesare indicative only and do not necessarilyshow a legal title EXCLUSION OF LIABILITY ARISING FROMSUPPLY OF INFORMATION: HorizonsRegional Council endeavours to provideuseful and accurate information. HorizonsRegional Council shall not, however be liablewhether in contract, tort, equity or otherwise,for any loss or damage of any type (includingconsequential losses) arising directly or indirectlyfrom the inadequacy, inaccuracy or any otherdeficiency in of the cause. Use of informationsupplied is entirely at the risk of the recipient andshall be deemed to be acceptance of this liabilityexclusion.

www.horizons.govt.nzImage supplied by MW LASS Ltd 2016

Prepared for ConsentsBy Catchment Information

27 Sept 2017, CI Ref: CI20384Contains Crown Copyright Data

AFFCO SITE (WHANGANUI) AREACONSENTS MAP

±0 100 m

AFFCO SITEAFFCO SITE

!( LOC-0000063717AFFCO Site

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Whanganui


www.horizons.govt.nzImage supplied by MW LASS Ltd 2016

Prepared for ConsentsBy Catchment Information

20 Sept 2017, CI Ref: CI20384Contains Crown Copyright Data

AFFCO SITE (WHANGANUI)CONSENTS MAP

±0 50 m

TRUCK WASHTRUCK WASH

STOCKYARDSSTOCKYARDS

SLAUGHTER BOARDSLAUGHTER BOARDRENDERING RENDERING

PLANTPLANTBUILDINGBUILDING

PRIMARYPRIMARYWASTEWATERWASTEWATERTREATMENT TREATMENT

PLANTPLANT

COVERED DRYERCOVERED DRYERBIOFILTERBIOFILTER

MAINMAINBIOFILTERBIOFILTER

APPENDIX 5

APP-2005011098.01 – Submission summary – AFFCO discharge to air.

The submissions can be broadly grouped into the following areas of

support/oppose/neutral:

Support 2/26

Opposed 17/26

Neutral 5/26

Support and oppose 2/26

The submissions can be broadly grouped into the following areas of heard and not

heard or not stated:

Heard 8/26

Not heard 16/26

Not stated 2/26

The submissions can be broadly grouped into the following issues:

Issue / points raised Raised by submitter

Odour effects 1, 2, 3, 5, 6, 7, 9, 10, 11, 12, 13, 14, 16, 17, 18, 19, 20, 21, 22, 23, 24, 25, 26

Health effects 8, 9, 10, 11, 13, 14, 15, 21

Benefit AFFCO has to the community 2, 5, 14, 16, 17, 22

Pollution hotline (or number to call) / Odour monitoring 7, 16, 17, 20, 21, 25, 26

Enforcement by HRC / Consent conditions 7, 8, 11, 15, 16, 17, 18, 19, 22

Property concerns (price/ rent) 6, 13,

Proposed mitigations (support and oppose) / Maintenance of existing mitigations/ alternative mitigations

2, 4, 6, 7, 8, 10, 11, 13, 14, 15, 16, 17, 24

Engagement with Iwi 18

Discharge from Milk Plant 21

Noise effects 3

Onsite Wastewater treatment plant 5, 10, 16, 17, 18, 25, 26

Shorter term including declining the application 1, 3, 5, 8, 12, 14, 16, 17, 20, 21, 25, 26

Relocation of the operation / plant closing 1, 21 0

Livestock trucks 7

Odour surveys 16, 17

Timeline for mitigations discussed within the AEE 16, 17, 20, 24

Sources of offal and age when reaching site 23

Sub #

Name Support / Oppose

Status (Heard/Not Heard)

Submission summary

1 Anthony Magnoli Oppose Not identified

In opposition to the application “due to the proximity of these odours and contaminants to our property”. The submitter has requested a shorter term than the 25 year term requested by the applicant. The applicant has requested the operation be moved to a more ‘rural or industrial area’ or ensuring there is stricter regulation of the “foul odour.. and.. contaminants”.

2 Graeme Billington

Support Not heard The submitter notes they live near the plant and are subjected to odour therefore they support the proposed upgrades particularly if it reduces odour. The submitter also notes the Imlay plant (AFFCO) is a beneficial workplace for Whanganui.

3 Peter and Caryl Henderson

Oppose Not heard The submitter raises concerns about the odour and noise pollution. The submitter seeks the application is not renewed.

4 Whanganui District Council

Neutral Not Heard No objection to the granting of the discharge permit subject to appropriate mitigation measures including suitable [consent] conditions to support appropriate odour management practices.

5 Christine Andrews

Neutral Not heard Supports continued operations at the AFFCO site due to the employment it creates. However the submitter opposes the odour created by the site. The submitter seeks the applicant:

- Contain and treat their waste water on site; and - Eliminate odour discharge to air.

The submitter seeks the application be declined unless they can remove the discharge of odour to air and also treat their wastewater to ensure no contamination of water.

6 Susan Hughes Oppose Not identified

The submitter advises the odour is very bad and seems to be getting worse in the 18 years she has lived in Balgownie Avenue. The submitter advises, because of the smell, it is difficult for her to rent a property she also has in the vicinity. The submitter seeks consent is not issued for the next 25 years and the applicant finds an alternative method to discharge their pollution.

7 Michael Jones Support Not heard No opposition to the application however he notes concern about the odour from the site. The submitter makes the following requests:

- Ensure upgrades and monitoring, as per the application, are implemented; and - Improvement of the operational maintenance of plant and equipment; and - There are both programmed and random inspections of the site; and - Ensure livestock trucks are fully compliant; and - Ensure the pollution hotline operators understand the issues and show concern and empathy. The

submitter also seeks the hotline become a joint operation between the Regional Council and District Council.

8 Sandi Black Oppose Not heard Opposes the application for the following reasons: - A 25 year term is too long, suggests a shorter term with the requirement for annual reviews to take

into account updated laws/ rules/ best practice and implement these immediately; and - The current measures to control odour are ineffective. Requests further controls and mitigations are

put in place to control odour. The submitter also questions what the contaminants are and if they are contributing to odour.

9 Rodney Emmett Oppose Not heard Opposes both the discharge of odour and contaminants to air. The submitter is concerned about what is discharged and wishes for him and his family to inhale only clean air and not to have respiratory conditions aggravated. The submitter seeks a total ban on the discharge of odour and contaminants to air and notes it could result in health concerns.

10 Public Health Service, MidCentral Health

Neutral Not heard The submitter advises the primary concern from the discharge of contaminants and odours to air is the potential for odour nuisance to the Whanganui community. The submitter acknowledges the site, by nature, has odour producing potential and while there is no direct health effect there can be an affect on a person’s quality of life. The submitter acknowledges there are some odour control systems installed at the site which represent good industry practice and design however a recent review of the systems had indicated significant room for improvement. The submitter advises the bio filters are operating above their loading design capacity and require maintenance, specifically weed maintenance. The submitter also advises they have some concern regarding the install of another potentially odorous activity on site, namely the on-site wastewater treatment. The submitter notes while mitigation is proposed, the ability to assess that mitigation will be limited to after the operation is installed. With regards to contaminants the submitter advises the gas-fired steam boilers at the site have adequate stack height and dispersion modelling of emissions indicate that they are unlikely to cause adverse health effects.

11 Sharon and Mark Corrigan

Oppose Heard The submitter opposes the discharge of odour and contaminants due to the negative impact on their environment and health. The submitter seeks:

- More appropriate filters are used; and - Necessary health and environmental checks are carried out on the discharge of contaminants; and - A shorter term is given for any consent

12 Christine Kuzman Oppose Not Heard The submitter advises, when the wind blows towards her house, the smell is terrible. The submitter seeks consent not be granted to AFFCO for the next 25 years.

13 Carole Ann Johnston

Oppose Not heard The submitter opposes the application and advises even when the odours from the site are under control they can be quite strong, and when they are not under control it is nauseatingly disgusting. The submitter raises other concerns including:

- Property value; and - The safety of resident’s health from the contaminants.

The submitter seeks AFFCO be required to control odour and contaminants as has been done. The submitter also requests a report be undertaken on the legalities of disposing contaminants to air and addressing if the contaminants are hazardous to health?

14 Vicki Davies Oppose Not heard The reasons stated for the opposition are: - The pollution of the environment from the discharge of odour and contaminants; and - The odour is offensive and objectionable; and - There needs to be more protection for people’s health. The submitter states a number of concerns

regarding health effects. The submitter seeks:

- Improvement of management processes by AFFCO; and - Reduce or eliminate the discharge; and - Reducing the consent term to enable improvements. Suggests a 5 year term; and - Make AFFCO responsible for the pollutants associated with the industry; and - To ensure AFFCO remains open as it supports the Whanganui community.

15 Julian Emmett Oppose Not heard Opposes the application and raises concerns including: - Effects on residents health; and - Questions if all options for disposal have been considered?

The submitter seeks:

- Investigation of all possible options; and - If the application is granted, ensuring the applicant follows all the rules.

16 Lyn Pearson and Graham Pearson

Oppose Heard The submitter seeks a shortened term of 5 years and imposition of conditions requiring AFFCO to make on-going improvements with the aim of achieving zero-emissions as soon as possible. The submitter acknowledges the contribution the applicant makes to the region including employment and also the recent improvements made to the emissions in recent years. The submitter seeks:

- Emission control methods are updated as new technology becomes available along with the use of best practice and early adoption of new technological solutions to odour control and other pollutant effects; and

- Should the consent be granted, Horizons to continually review the applicants performance to ensure effects are avoided or mitigated; and

- To ensure the biofilters are well maintained; and - Require the applicant to undertake process monitoring to prevent system failure; and - Include a condition of consent requiring the applicant to avoid objectionable and offensive effects

beyond the property boundary; and - The use of best practical options which consider both the applicant and communities perspectives;

and - Wider public knowledge of complaint lines which go direct to AFFCO and/or the Regional Council.

The submitter also seeks answers to a number of questions concerning:

- What modifications could be made on site to reduce odour? For example storage areas for tallow and stick liquor?

- Would additional biofilters help with odour emissions? What is the trigger for this to occur? - Will the on site waste water treatment plant create more odour? - In addition to monitoring could there also be odour surveys undertaken in the local community? - The AEE offers a number of recommendations which include July 2017 completion dates. Have

these been met?


Oppose Heard

18 Te Runanga o Tupoho

Support / Oppose

Heard The submitter makes points which both support and oppose the application. The submitter supports as follows:

- in part the application for discharge to air; and - the development of the proposed package WWTP as identified in 2.3.3, as this will mean better

quality effluent into the new WDC WWTP The applicant opposes the application in regards to:

- the development of a new River pipeline and find the activity to be offensive to Te Awa Tupua, iwi and tangata whenua; and

- the discharge of treated wastewater from AFFCO to the ocean fall as this will require the development of a new River pipeline which we fully oppose; and

- the proposal of Consent Considerations that 1 (one) iwi representative be present when iwi and tangata whenua hold manawhenua within the lower Whanganui River catchment and coastline

The submitter seeks further engagement with the applicant in regard to these matters.

19 Sharon Semple Oppose Heard Opposes all aspects of the proposal due to the odour experienced at her residence. The submitter advises she does not see improvements even when AFFCO are fined and questions where the money from the fines go.

20 Robert Jaunay Oppose/ Support

Heard The submitter notes ongoing issues with odour at the site and in the past has experienced a ‘nauseating stink’. The submitter notes they were not aware of the ability to complain about the site. The submitter supports all of the recommendations for improvement given in the AEE. However they question why these improvements have not already been done prior to applying for consent? The submitter seeks:

- Restricting the term to be a maximum of 10 years; and - More awareness of the complaints procedure and community liaison group in the community (ie.

displayed at local notice boards).

21 Stephen Bryson Oppose Not Heard The submitter notes ongoing issues with odour at the site with complaints to the Regional Council being ineffective. The submitter seeks:

- restricting the term to far less than 25 years; and - require the plant to close within a notified number of years; and - locate a pollution control officer closer to the site (rather than being based in Palmerston North);

and - investigate the discharge of milk solids from the plant and require standards which ensure there is

no effect on residents health.

22 Reuben Davis (Late submission)

Neutral Not heard The submitter advises he is in support of the application and AFFCO’s committal to Wanganui however he would like assurance the notifiable events won't increase and sufficient controls have be invested in, in view of minimal disturbance to the public. The submitter seeks consent is granted with strict conditions and management to minimise disturbance.

23 Mikolaj Andrzej

Glowacki

Neutral Not Heard The submitter advises he is neutral to the application with no opposition to the discharge of contaminants from the boilers. The submitter advises he has concerns about the rendering activity at the plant and the odour which is produced, particularly that of a rotting meat smell and sometimes a sour milk smell (although acknowledges this may be the milk factory). The submitter also raises concerns about the fact that raw material is brought in from processing from other sites and it may be partially decomposed by the time it reaches the site. The submitter seeks stricter measures for the discharge of odour and possibly a restriction on the products rendered at the site eg. locally produced products only.

24 Patricia Mary

Walsh

Oppose Not heard The submitter advises they oppose the application in its present form. The submitter advises they feel stricter controls on odour emitted from the site are necessary and over due. The submitter is concerned as to why the improvements listed in the application such as improvement of processes on site and upgrading of the biofilters have not already happened – particularly since they already have complaint and other data. The submitter questions the likelihood of the upgrades occurring. The submitter advises the odour is often released for short periods of time and as a result the response from Horizons Regional Council is too late. The submitter questions why staff at the Whanganui office of Horizons are unable to attend. The submitter notes often by the time Horizons attends if the odour has gone there is the assumption/ conclusion that if no smell is found there was no smell in the first place. The submitter feels it is a waste of time complaining. The submitter advises the odour can be physically sickening The submitter outlines their concerns about the five mitigations measures listed in the application. With regards to the rendering the submitter notes the applicants plan to better control the products entering the site for rendering. The submitter questions this given this is a long standing rendering site and why does this not already happen? The second measure concerns the maintenance of the systems at the site and the statement “Maintenance of the systems for efficient extraction, cooling and bio filter treatment of concentrated source emissions from rendering including the hot meal dryer exhaust”. The submitter is concerned what this statement actually means and what is currently in place in terms of a maintenance plan. The submitter seeks for AFFCO to put a comprehensive plan in place. Thirdly, the submitter is also concerned how the existing bio filters will manage with the extra load from the proposed chemical wastewater treatment plant. The fourth mitigation concerns daily wash-down of stock yards and waste collection channels. The submitter questions if this currently happens and if not what will the impact be of this extra volume on the proposed chemical wastewater treatment plant. Lastly the submitter questions the removal of the fellmoungery waste as a mitigation measure for odour given this has not operated at the site for some time (as per the executive summary)

The submitter concludes the mitigations are unspecific and best practice rather than best practicable option.

25 Three Angels

Family Trust

Oppose Heard The submitter advises they oppose the 25 year term and also odour complaints. The submitter seeks that the term be reduced to 5-10 years and that external monitoring of odour complaints takes place to give Horizons a clear indication if odour complaints are being upheld in accordance with the consent. The submitter notes they also oppose the new package chemical treatment plant.

26 Ainsley Michelle

Brunton

Oppose Heard The submitter advises they oppose the 25 year term and also reporting methods for odour complaints. The submitter seeks that the term be reduced to 5-10 years and that external monitoring of odour complaints. The submitter notes Horizons should be more transparent in their reporting. The submitter notes they also oppose the new package chemical treatment plant.

APPENDIX 6 – Submitter Locations

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MAY ST

HINAU ST

KAURI ST

TAWA ST

GIBBONSCRES

BEAUMARISAVE

MAIRE ST

KINGS AVE

JACKS

ON ST

DUST

IN ST

TUIPL

SWISS AVE

PHARAZYN

ST

CAMBR

IDGE ST

WALTERNASH PLMATIPO ST

MUIR ST

BANKSPL

BALGOWNIE AVE

KAWATIRI AVE

BENNETT ST

GUNN

ST

COLLINS ST

ARMSTRONG

PL

AKATEA ST

HARPER ST

DUIGAN ST

GORRANAVE

HARRIS PL

TAWHERO ST

MAHOE PL

ANDREWSPL

CENT

RAL A

VE

PRINCE ST

WATKIN ST

ABBOT ST

ELMST

SMITHFIELD RD

POYNTERPL CARLTON

AVE

OWEN

ST

TITOKI ST

BIGNELL ST

PURIRI ST

NIKAU STTOTARA ST

RATA ST

KARORO RD

BEDFORD AVE

CAIUS AVE

KOROMIKO RD

7

3 126

521

11

82

119

13

15

9

14

22

24

232526

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AFFCO Consent Submitters

±Prepared by Catchment Information

July 2017CIRef : CI18221

Contains Crown Copyright Data0508 800 800www.horizons.govt.nz

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Sub # Name Address Support / Oppose

Status

1 Anthony Magnoli 26 Bignell Street, Wanganui 4501 Oppose Not 2 Graeme Billington 56 Bignell Street, Wanganui 4501 Support Not heard3 Peter and Caryl Henderson 53 Balgownie Avenue, Wanganui 4501 Oppose Not heard4 Whanganui District Council PO Box 637, Wanganui Mail Centre, Neutral Not Heard5 Christine Andrews 4B Kings Avenue, Wanganui Neutral Not heard6 Susan Hughes 25 Balgownie Avenue, Wanganui 4501 Oppose Not 7 Michael Jones 28 Muir Street, Whanganui 4501 Support Not heard8 Sandi Black 71 Bignell Street, Whanganui 4501 Oppose Not heard9 Rodney Emmett 5 Suanders Place, Wanganui 4501 Oppose Not heard10 Public Health Service,

MidCentral HealthHealth Protection, Public Health Centre, Private Bag 3003, Whanganui

Neutral Not heard

11 Sharon and Mark Corrigan 59 Bedford Avenue, Whanganui 4501 Oppose Heard12 Christine Kuzman 49 Balgownie Avenue, Wanganui 4501 Oppose Not Heard13 Carole Ann Johnston 1 Swiss Avenue, Wanganui 4501 Oppose Not heard14 Vicki Davies 4A Kings Avenue, Whanganui 4501 Oppose Not heard15 Julian Emmett 2/5A Duigan Street, Wanganui 4501 Oppose Not heard16 Lyn Pearson and Graham

Pearson9A Waitai Street, Castlecliff, Whanganui

Oppose Heard


31 Cross Street, Castlecliff, Whanganui Oppose Heard

18 Te Runanga o Tupoho PO Box 5046, Whanganui Support Heard19 Sharon Semple 34 Bignell Street, Wanganui 4501 Oppose Heard20 Robert Jaunay 16 Lucknow Street, Aramoho, Support Heard21 Stephen Bryson 7 Saunders Place, Gonville, Oppose Not Heard22 Reuben Davis 51 Balgownie Avenue, Gonville, Neutral Not Heard23 Mikolaj Andrzej Glowacki 21B Balgownie Avenue, Gonville, Neutral Not Heard24 Patricia Mary Marsh 10 Balgownie Avenue, Gonville, Oppose Not heard25 Three Angels Family Trust 12 Beach Road, Whanganui Oppose Heard26 Ainsley Michelle Brunton 12 Beach Road, Whanganui Oppose Heard

APPENDIX 7

Recommended Condition Schedule

In the conditions, I have included an explanation of the purpose of the condition along with noting how I have sought to address submitters concerns. I also expect there

will be further work on the consent conditions or the applicant and submitters may wish to provide comment on them. If so, I will provide an update to the commissioners

at or during the hearing if anything changes.

Condition Explanation and reasoning Link to submitter concerns

Descriptive Specification Heading

n/a

For the purpose of this consent the following definitions apply: Air Discharge Permit: the term ‘Air Discharge Permit’ encompasses the following:

ATH-2007010926.01 - Discharge Permit to discharge odour to air: The discharge of odour to air associated with activities occurring at the AFFCO site, Imlay Place – Whanganui. ATH-2017201595.00 - Discharge Permit to discharge contaminants to air: The discharge of contaminants to air associated with the operation of gas fired boilers located the AFFCO site, Imlay Place – Whanganui.

Site: the term ‘site’ refers to the AFFCO - lmlay plant on land legally described as Lot 1 DP 500721 at approximate map reference NZTopo50: BL32:729-757 and as shown on Map LOC - 0000063717 (Appendix 4) CLG - Community Liaison Group EMP – Environmental Management Plan EMS - Environmental Management System MWRC – Manawatu-Wanganui Regional Council OCS&BMP - Odour control system and Biofilter operation manual

This section sets up the definition of ‘Air Discharge Permit’ and ‘Site’ upfront so it is clear to the reader how these are defined for the purpose of this consent. I have also listed any acronyms used within the consent so these can be easily referred to.

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OCP - Odour contingency plan RMP - Rendering Management Plan

Advice Notes relating to all conditions of this consent: ADVICE NOTE: Any reports required by this permit can be sent to the Manawatu-Wanganui Regional Council via email [email protected] –OR- by mail, addressed to: C/- The Regulatory Manager, Manawatu-Wanganui Regional Council, Private Bag 11025, Manawatu Mail Centre, Palmerston North 4442. ADVICE NOTE: The Consents Monitoring Team can be contacted 24 hours 7 days a week by free phone 0508 800 800. ADVICE NOTE: For the purpose of this consent the definition of working day is the same as give in section 2 of the Resource Management Act 1991. ADVICE NOTE: Where written feedback is required it can either be provided in the form of an email or a written letter. ADVICE NOTE: Any variance from the location, design concepts and parameters, implementation and / or operation may require a new resource consent or a change of consent conditions pursuant to section 127 of the Resource Management Act 1991.

Advice notes are often provided within consents, below applicable conditions, to provide advice on where to send reports or how to contact a particular person. To save repetition I have stated advice notes, which apply to multiple conditions, at the start of the condition schedule.

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1. The activities authorised by these Air Discharge Permits shall be restricted to the discharge of contaminants to air, including odour, from the site. The discharges to air covered by these Air Discharge Permits are those associated with the following processes:

a. animal slaughter; b. by-product rendering; c. truck washing; d. the primary wastewater treatment plant;

This condition sets out clearly what is allowed to contribute to the discharge of odour and other contaminants to air.

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e. a proposed package wastewater treatment plant f. the holding of livestock in yards; g. other emission producing activities such as ventilation; and h. the combustion of natural gas by three module steam boilers with a

combined net heat output of 10.5 MW producing carbon monoxide, oxides of nitrogen and trace levels of particulate matter.

2. The Permit Holder must undertake the activity in general accordance with the Resource Consent Application and AEE, including all accompanying plans and documents first lodged with the MWRC on 10 March 2017 and subsequent further information supplied on 4 October 2017 by Email responding to the further information request dated 12 September 2017, or through the hearing. Where there may be inconsistencies between information provided by the applicant and conditions of the resource consent, the conditions of the resource consent will apply.

This condition requires the permit holder to act in accordance with the application as proposed and any further information provided after the application being lodged and/or at the hearing.

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Pre-Development Assurance Heading.

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3. The Permit Holder must update and maintain an Environmental Management System (EMS) which satisfies the requirements of ISO 14001:2015 or any subsequent updates. The objective of the EMS shall be to provide a management system which includes organisational structure, planning activities, responsibilities, practices, procedures, processes and resources for developing, implementing, achieving, reviewing and maintaining the environmental policy. A copy of the EMS must be submitted to the Regulatory Manager of MWRC by 1 February 2018. The EMS shall be subject to an annual external audit to be undertaken by 30 April each year commencing 1 May 2018. The Audit shall be undertaken by a suitably qualified and experienced auditor with the audit team having experience in environmental management and process engineering. The audit scope shall cover the following:

An Environmental Management System (EMS) is defined as “The part of an organisations overall management system that includes organisational structure, planning activities, responsibilities, practices, procedures, processes and resources for developing, implementing, achieving, reviewing and maintaining the environmental policy.”

The applicant has an existing EMS for the site. The EMS establishes general management of the site as a whole. The EMS condition also allows for independent auditing on an annual basis, the results of which are required to be included in the annual report. This gives an independent perspective on how the site is operating and will help to highlight any concerns to the MWRC.

As discussed under section “E – Actual and potential effects on the environment” of my s42A report I have recommended a set of conditions which creates an

A number of submitters (being submitters 4, 7,8,11,15,16,17,18,19 and 22) have requested either

1. Stricter controls on the consent and/or

2. Improve processes for managing odour controls.

I am of the opinion conditions 3 through to 7 require the consent holder to be proactive in their management of the site which in turn will


a. The EMS status; b. Consent compliance; c. Adherence to procedures in the EMP; and d. General site environmental risks including the need for machine

maintenance.

The findings of the audit shall incorporated into in the Annual Report required by Condition 34.

‘umbrella’ approach. These conditions, being conditions 3 through to 7, require an overarching site management document which provides for specific management plans for various aspects of the site which create a plan for meeting the specific environmental standards required. It is a prescriptive approach aiming to require the consent holder to undertake more proactive management of the site.

help assure the odour control system works at an optimum and reduce the risks for fugitive odour.

4. The Permit Holder must develop an Environmental Management Plan (EMP) to identify all systems and procedures that the Consent Holder has in place to reduce the risk of odours that could result in adverse effects beyond the site boundary. The purpose of the Environmental Management Plan is to set out a framework for the plans and processes for ensuring compliance with conditions of these permits, particularly Condition 9, regarding odour is achieved. The EMP must detail:

a. Specific information, procedures and practices relating to the overall operation of the site consistent with the Environmental Management System detailed in Condition 3 and the AEE submitted with this application; and

b. Procedures in place to deal with complaints to ensure compliance with Condition 26-28.

Details of how the conditions of the consent will be meet must be detailed in site specific management plans as set out in c-e.

c. Odour control system and Biofilter operation manual (OCS&BOM) as detailed in Condition 5

d. Odour contingency plan (OCP) as detailed in Condition 6 e. Rendering Management Plan (RMP) as detailed in Condition 7

It is anticipated that these plans should be complementary rather than repetitive.

The EMP shall be provided to the Regulatory Manager of the MWRC by 1 February 2018 for technical certification and thereafter within 5 working days of any content within the EMP changing.

An Environmental Management plan is defined1 as ‘A site or project specific plan developed to ensure that appropriate environmental management practices are followed during the construction and/or operation of a project.

These require the Permit Holder to be proactive in managing their discharges and ensure ongoing maintenance of the site.

This condition gives clear guidance on what is expected in the EMP and what it will provide for and why. This is followed by the requirement of three plans which all have the aim of avoiding or mitigating the effects of odour.

The EMP must be provided to MWRC for technical certification to ensure it is compasses what is required within the condition.

The condition links to the conditions to allow for clear compliance assessment by the council as it can easily be identified what conditions apply.

As above – under Condition 3

1 NSW Department of Infrastructure, Planning and Natural Resources, Guideline for the preparation of Environmental Management Plans. 2004


The Permit Holder must comply with the certified EMP at all times.

5. The Permit Holder must develop an Odour Control System and Biofilter Operation Manual (OCS&BOM). The OCS&BOM must provide for the following:

a. A general overview of the odour extraction, cooling and control systems including the biofilters;

b. A system to ensure the stockyards are cleaned daily and recorded in order to meet Condition 10

c. Details of the recommended design flowrates for odour extraction at each point source as set out in Table 3: Concentrated odour source extraction – Recommended design flows as detailed in the Resource Consent Application and AEE dated 10 March 2017.

d. Procedures to visually monitor for fugitive odours (steam)associated with the rendering building and annual monitoring of biofilter flowrates and vacuums at extraction points in accordance with Conditions 20 and 31 respectively.

e. Documentation and identification of the normal operating ranges for the evaporator vacuum pump draught (kPa), stickwater level within the evaporator (% of maximum), final stickwater concentration (% of solids); non-condensable gas temperature; and waste heat evaporator vapour temperature.

f. Documentation for recording regular inspections, and measurements and design operating levels of inlet air to biofilters, condensate temperature, biofilter temperature, bed back-pressure, pH and moisture content to ensure the system meets the standards set in Conditions 15, 16 and 17.

g. A system for recording any maintenance undertaken, any periods of malfunction, the reasons for malfunction and the remedial action taken to ensure the malfunction does not reoccur. The records must also note any notifications made to the Regulatory Manager of the MWRC under Condition 20. The records shall be made available to the Consents Monitoring staff of the MWRC on request and as part of the Annual reporting requirements in Condition 34. The log shall be kept for the term of these Air Discharge Permits.

h. Documentation and planning to ensure the yearly testing required

This condition requires the development of an Odour Control System and Biofilter Operation Manual (OCS&BOM).

This plan sets out an overview of them system (as per (a)). This will then follow with details of how specific environmental standards will be met with cross references to the conditions which we seek specifics on how they intend to meet.

This is to require for proactive management of the site – ensuring that they have processes in place to meet the environmental standards of this consent and making it clear which standards the consent holder needs to meet and demonstrate how they will meet them.

The OCS&BOM must be provided to MWRC for technical certification to ensure it is compasses what is required within the condition.



of the biofilters in Condition 30. A copy of the OCS&BOM shall be forwarded to the Regulatory Manager of the MWRC by 1 February 2018 for technical certification. Once certified the OCS&BOM must also be submitted for technical certification within 5 working days of any changes. The Permit Holder must comply with provisions of the certified OCS&BOM at all times.

6. The Permit Holder shall develop and submit an Odour Contingency Plan (OCP) which identifies foreseeable incidents where unauthorised emissions to air may occur that might constitute a breach of one or more conditions of these Air Discharge Permits. The OCP must be prepared by a suitably qualified Process Engineer with experience in odour control and management. The OCP must include:

a. contingency measures when raw material is received by the Low Temperature Rendering Plant (LTRP) which does not meet the requirements of Conditions 12 and 13.

b. Contingency measures to deal with any mechanical breakdowns including the handling of any material trapped within the LTRP.

c. Document the process for notifying the MWRC Consents Monitoring Team in order to meet Condition 23.

d. Any other measures that will minimising adverse effects on the environment likely as a result of incidents that may breach this consent

A copy of the OCP shall be forwarded to the Regulatory Manager of the MWRC by 1 February 2018 for technical certification. Once certified, the OCP must also be submitted for technical certification within 5 working days of any changes. The Permit Holder shall comply with provisions of the certified OCP at all times.

While it is not desirable for any breaches of the consent to occur this condition requires the development of a contingency plan so that in the event of a malfunction or receipt of raw material it is deal with in a expedient manner.

The intention here is to provide for proactive management of the site – ensuring that they have processes in place in the event of an incident to ensure appropriate parties are notified and any resulting odour is managed in a way which minimises the duration and effects.


7. The Permit Holder shall develop and submit a Rendering Operation and Management Plan (RMP).

The RMP shall document the decision making process for the acceptance and handling of raw material to ensure compliance with conditions of these Air Discharge Permits including:

a. Specific management controls on raw material quality and raw material preservation, including (but not limited to) a procedure for

Similar to Condition 4 and 5 this condition requires the development of a Rendering Operation and Management Plan (RMP)

This plan specifically sets out how rendering material will be handled on site to ensure the material does not result in a breach in consent conditions, particularly where the material does not meet Conditions 12 and



recording raw material quality and compliance with requirements as per Conditions 12 and 13 of these Air Discharge Permits.

b. Recognising the need for implementing the OCP in Condition 6 in instances where the material is not of acceptable quality.

c. A process to ensure the Condition 11 is met regarding the cleaning of rendering facilities including a daily log confirming cleaning has taken place.

d. A monitoring programme of key process criteria, including provision for a daily log to record the matters set out in Condition 33.

e. Provision to record the process operating temperatures for the rendering and drying equipment as per Condition 21.

A copy of the RMP shall be forwarded to the Regulatory Manager of the MWRC by 01 February 2018 for technical certification. Once certified the RMP must also be submitted for technical certification within 5 working days of any changes. The Permit Holder shall comply with provisions of the certified RMP at all times.

13 (eg. is over 24 hours old).

Again this is to provide for proactive management of the site – ensuring that they have processes in place to meet the environmental standards of this consent and making it clear which standards I seek them to meet.

8. Three months prior to the installation of the package wastewater treatment plant the Permit Holder shall provide a report detailing the design and sizing of the odour control system for the package wastewater treatment plant, gas extraction rates and biofilter sizing and design for technical certification by the Regulatory Manager of the MWRC.

The package wastewater treatment plant odour control system shall ensure compliance with the conditions of this consent and at a minimum meet the following requirements:

a. A maximum biofilter loading rate of 35 cubic metres of air per cubic meter of bed volume; and

b. A minimum depth of 0.6m; and c. Enclosure and extraction of all point odour sources including:

i. wet solids storage, ii. transfer conveyors,

iii. dewatering decanters; and iv. final dewatered solids storage; and v. the clarifier .

The report must also detail all procedures the consent holder has in place to

This condition to ensure the new package wastewater treatment plant does not result in any additional effects – particularly odour.

The condition requires minimum requirement for odour control and requires they operate in accordance with the plan at all times.

Before installing the package wastewater treatment plant the permit holder must be able to demonstrate they can meet the standards required within the condition and also show how the odour will be managed including updates to the OCS&BPM.

A number of submitters (5, 10, 16, 17, 18, 25, 26) commented on the addition of a packaged wastewater treatment plant to the site with many concerned about the odour generated.

This condition requires the permit holder to show full compliance with the standards in this condition prior to installation.


reduce the risk of offsite odours including details of how the package wastewater treatment plant sludge will be managed.

The OCS&BMP must be updated to incorporate the additional odour system and source and submitted alongside the aforementioned report.

Environmental Standards Heading

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9. The Permit Holder shall ensure there is no discharge to air of odour, or particulate matter (including meal dust from any vent) that is objectionable to the extent that it causes an adverse effect at or beyond the boundary of the AFFCO Imlay site. ADVICE NOTE: When assessing compliance with this condition, a MWRC officer will consider the Frequency, Intensity, Duration, Offensiveness and Location of the odour (i.e. the FIDOL factors) in determining the adverse effect of objectionable odours.

This condition requires there is no discharge to air which is deemed objectionable to the extent that it causes an adverse effect at or beyond the boundary of the AFFCO Imlay site.

This condition is consistent with the Ministry for the Environment, Good practice guide for assessing and managing odour (November 2016).

Please refer to the reports of Deborah Ryan, and Pita Kinaston for more information on how this is assessed.

Odour, and the adverse effects of it is an issue addressed by the majority of submitters.

This condition makes it clear that odour which is objectionable to the extent that it causes an adverse effect beyond the boundary of the AFFCO site is not permitted under this consent.

10. The Permit Holder shall ensure that the stockyards are thoroughly cleaned of animal waste at the end of each day, as a minimum requirement, on any day on which animals are held for processing, in order to ensure compliance with Condition 9.

This is an environmental standard which seeks to ensure the stockyards are well maintained and ammonia build-up does not occur. This standard is provided for in Condition 5 (the OCS&BOM)

As above - under Condition 9

11. All equipment processing areas used for the receipt and processing of animal matter in the rendering operations shall be cleaned thoroughly (by way of water blasting or pressure hose) on at least one occasion every day on which processing occurs and at the cessation of the daily processing operation, and shall be kept free of accumulated or deposited material.

This is a condition which seeks to ensure the rendering area is kept clean. This is to help with minimising odour.

This standard is provided for in the RMP in Condition 7. The RMP requires a process to be in place which ensures this happens and is logged.

As above - under Condition 9.

12. All raw material to be processed on site must met the following criteria:

a. all soft offal shall be processed within six hours of kill, unless it has been stabilised as detailed in Condition 13;

b. stabilised soft offal shall be processed within 24 hours of receipt; and

c. hard offal shall be processed within 48 hours of receipt.

This environmental standard seeks to ensure material accepted onto site is of acceptable quality and with the aim of minimising odour.

The requirement to process material within 6 hours of kill (or stabilise within 6 hours of kill) helps to ensure material is ‘fresh’ and reduce the risk of old material being processed.

This standard is provided for in the RMP in Condition 6 where the consent holder is required to outline the measures they will take to ensure this standard is met including the provision for a log.

The age of the material being processed was an issue raised by submitter 23.

Evidence, including compliance action, shows The age of the material can have a direct impact on the odour produced which most submitters are concerned about.

This condition, coupled with Conditions 13, 14 and 33, requires the permit holder to be proactive in monitoring the age of the material it processes.

13. Stabilisation of soft offal, referred to in Condition 12 , is deemed to be adequate if:

a. stored material is cooled to a temperature of 20 degrees Celsius or lower as soon as practicable but no later than six hours after the kill of the animal from which it is derived; or

b. stored material is treated with acid to ensure a pH of 4.5 or less; or c. any equivalent stabilisation method to (a) and (b) above which has

been given technical approval by the Regulatory Manager of the MWRC.

This environmental standard seek to ensure where material is older than 6 hours old it is stabilised to mitigate odours.

This standard is provided for in the RMP in Condition 7 where the consent holder is required to outline the measures they will take to ensure this standard is met including the provision for a log.

As above - under Condition 12

14. If raw material does not meet the requirements of Condition 13 the OCP required under Condition 6 must be implemented by the Permit Holder.

This condition makes a clear link back to the OCP to make it clear the consent holder needs to be proactive in mitigating any issues before they arise.

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15. The Permit Holder shall ensure that the pre-cooled inlet air to all biofilters shall be maintained at a temperature not exceeding 35 degrees Celsius (35°C) for 95 % of the time as recorded via the SCADR, with a maximum temperature not exceeding 40oC. Furthermore, all condensate from the condensers shall be discharged via a covered drain and maintained at a temperature not exceeding 40 degrees Celsius (40°C). Measurements shall be kept in accordance with Condition 29.

Ms Ryan advises in her report

“Gaseous emissions extracted from the meal dryers are condensed in a waste heat evaporator (WHE). The WHE concentrates stickwater by evaporation to enable product recovery from this stream. Emissions from the WHE and other sources are cooled in various condensers to below 40⁰C prior to biofiltration. Maintaining the

A number of submitters commented on the current odour controls including the biofilters.

Submitter 10 has noted the current bofilters appear to be overloaded

discharge to the biofilter below 40⁰C is important for maintaining the health complement of microorganisms within the biofilter; at higher temperatures the microorganisms metabolise odour less efficiently and ultimately die at higher temperatures.”

Based on this advice I have included this condition to ensure the bofilter is able to operate at a optimised level.

and require maintenance. Submitters 16 and 17 also seek to ensure the biofilters are well maintained.

Condition 15 – 18 set out standards for both the operation and maintenance of the biofilters to ensure they are working at an optimum

The conditions also require this data to be fed back to the MWRC on an annual basis so ongoing performance can be checked.

16. The biofilters shall be maintained to the following standards: a. Media moisture content shall be maintained at 50 to 65 % dry

weight basis throughout its depth; b. The pH shall be greater than or equal to 5 in the top 2/3rd layer of

the biofilter media; c. The static pressure (back pressure) of the biofilters determined in

the inlet duct, shall not, under normal moisture conditions, exceed 150 mm/wg;

d. A maximum biofilter loading rate of 35 cubic metres of gas per hour per cubic meter of bed media;

e. A minimum bed depths of 0.7 m and 0.6 m for the Main and Dryer biofilters respectively;

f. a maximum backpressure across the bed media of 50mm water gauge pressure; and

g. The bio filters must remain weed free.

The biofilters are a key element to mitigating odour from the site.

This condition requires the consent holder to maintain the function of the biofilters to minimise odour. These standards ensure the biofilters are operating at an optimum level.

The standards are based on the recommendations given in Table 4 of the applicants AEE and the advice provided by Ms Ryan.

It would be helpful if the applicant were able to clarify how they currently weed the biofilters. Additional recommendations may be made depending on their response.


17. The Permit Holder shall undertake monitoring and inspection for all biofilters as follows:

a. back-pressure on all bio-filters shall be continuously recorded; b. daily manual back-pressure checks, visual inspection for moisture

content, leakage and odour discharge. c. moisture content and pH shall be monitored and recorded at least

once a month commencing November 2017 d. monthly inspection and recording of biofilter condition ie. weeds,

compaction, pugging or fissures, commencing November 2017; and e. annual air flow rate measurements and balance checks on all

process and main extraction ducts. All findings shall be recorded and detailed in a log.

As above – under Condition 16 As above – under Condition 15

18. The bio filter operation and maintenance logs shall be made available to the Regulatory Manager of MWRC or MWRC officers on request at any time. The operation and maintenance logs must also be supplied as part of the annual report required by Condition 34

This requires the permit holder to provide a copy of the logs at any time and also as part of the annual report.

Coupled with Condition 34 (annual maintenance of the biofilters) it will allow the permit holder to demonstrate they have been undertaking proactive management of a key odour mitigation for this site.


19. The Permit Holder shall operate and maintain a point source emission extraction system to extract all gaseous and vapour emissions from point sources of odour to the odour control system i.e. condensers, heat exchangers and biofilters as detailed in the Resource Consent Application and AEE dated 10 March 2017 as follows:

a. on the wet-side of the rendering process, sources shall include the internal raw bin, pre-cooker, the rotary drier, conveyors, decanter, decanter tank, separator tank, wastewater drains and separator.

b. Plans showing the raw bin connected to the point source extraction system shall be provided to the council on or before 1 January 2018

c. The external raw bin shall be connected and air extracted to the main biofilter as detailed in the plans in (b) by 1 March 2018 and remain covered at all times apart from when open for deliveries.

d. As of 1 May 2019 the delivery area for raw material must be fully enclosed in a building. The building must be large enough to allow for a delivery to occur with the doors fully shut.

e. On the dry side of rendering the sources shall include the meal dryer exhaust, meal storage bins and the filtered building ventilation air.

This condition ensures the Permit Holder maintains and operates their point source extraction system – responsible for mitigating odour.

The condition is written to be consistent with their AEE and recommendation made in the AEE and those of Ms Ryan in her 42A report. .

Good operation of this system are essential to ensure odour effect are mitigated.

As discussed above odour is an issue raised by the majority of the submitters.

When operating correctly the point source extraction system should mitigate adverse effects of odour.

Conditions 19 and 20 set out standards, monitoring requirements and upgrades required of the permit holder in order for this system to operate correctly.

f. Extraction rates from all enclosed point sources shall be sufficient to ensure a vacuum is maintained within the enclosure system, with a minimum vacuum of 100 Pascal gauge.

g. Doors to the rendering plant (dry and wet sides) must be kept shut at all times when not in use. Advice Note: Fugitive odour should be kept to a minimum in order to ensure compliance with Condition 9 of these Air Discharge Permits.

20. The Permit Holder must: a. visually check for any leaks of odorous gases and vapours from all

enclosed point sources in rendering on a daily basis on days when the plant operates; and

b. Advise the MWRC Consents Monitoring Team of any maintenance work which may result in odour release to the atmosphere at least 12 hours prior to the works commencing; and

c. Keep a log of the above checks details in (a) and (b).

Any remedial actions are to be undertaken in accordance with the procedures set out in the Odour Contingency Plan required by Condition 6. Results of these checks and remedial actions shall be logged daily. Logs shall be made available to the Regulatory Manager of the MWRC or MWRC officers on request at any time. The log must also be supplied as part of the annual report required by Condition 34.

Evidence of Ms Ryan demonstrates the odour control system must remain fully enclosed to ensure there are no leaks into the rendering building itself which have the possibility to escape to atmosphere due to the way the building is vented.

Visual checks will identify any odour laden steam.

Should any odour or steam be identified this condition requires the consent holder implement their contingency plan.

In the past issues have arisen where planned maintenance work resulted in odour being released. (b) requires the consent holder to advise the MWRC of these works prior to commencing. This ensures proactive management of any potential odour effects.

In the s92 request I have also questioned if a text system or update system on a website is an option. The applicant has advised, in their response, they are open to discussions about this.

It would be good if the applicant were able to provide some thoughts on what approach would work best for them.

Depending on the answer to this I may update my recommendations to reflect the need to advise the community (or those who sign up to such a service, if implemented) of matters such as maintenance work – again seeking for the Permit Holder to be proactive in managing any odour effects and also give the


community a pathway to discuss any issues with the consent holder should they arise. Taylor Preston in Wellington has a good example of a website to inform neighbours and collate information such as complaints (https://taylorpreston.co.nz/neighbours/)

Checks must also be logged and made available to the regional council upon request and supplied as part of their annual report.

21. The process operating temperatures for the rendering and drying equipment shall meet the following standards:

a. The rendering vessels shall be operated at the lowest temperature practicable, and in any event shall not be operated above 100 oC; and

b. The meat and bone meal dryers shall be operated at the lowest temperature practicable, which is consistent with MAF (or any future replacement regulatory body with relevant functions) sterilisation requirements, and to prevent burning of meal.

The temperature of the rendering vessels and dryers shall be continuously monitored and recorded. These records shall show the correct time and date. The records shall be made available to the Regulatory Manager of the MWRC or of MWRC officers on request at any time. The records must also be supplied as part of the annual report required by Condition 34.

This condition is based on the recommendations made in the report of Ms Ryan, Paragraph 88.

Ms Ryan advises the process operating temperatures for rendering and drying have an impact on the potential odour emission rates.

Ms Ryan has provided the parameters in (a) and (b) to help mitigate the odour potential of this equipment.

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Operational Restrictions Heading

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22. The odour control system and biofilter, relating to the package wastewater treatment plant, shall be operated at all times that the package wastewater treatment plant is in operation.

The package wastewater treatment plant is a proposed addition to the site.

This condition ensures that if added, while operating, it has an odour control system which is also operating allowing mitigation of any odour.

A number of submitters (5, 10, 16, 17, 18, 25, 26) commented on the addition of a packaged wastewater treatment plant to the site with many concerned about the odour generated. This condition ensures

https://taylorpreston.co.nz/neighbours/

the correct odour mitigations are in operation at all times when the package wastewater treatment plant is in operation.

23. In the event of any incident, mechanical breakdown or complaint that has or could have resulted in a condition or conditions of this consent being breached the Permit Holder shall:

a. Notify the Regulatory Manager or consent monitoring staff at the MWRC within 1 hour of the Permit Holder becoming aware of the incident and advise what action is being taken to rectify the situation; and

b. Forward an incident report to the Regulatory Manager of MWRC. The incident report must detail the cause of the breach and what actions the Permit Holder has undertaken order to ensure it does not reoccur. The report must be received within 2 Working Days of the MWRC being notified under (a).

This condition requires the Permit Holder to be proactive in notifying the Regional Council of any breaches it observes prior to any complaints being received.

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Post-Development Assurance Heading

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24. The Permit Holder shall provide co-ordination and administrative support for the Community Liaison Group (CLG) including a dedicated contact point at the site, provision of a meeting point and overseeing any administration associated with the group. The general purpose of the CLG shall be for the Consent Holder to inform the CLG of:

a. the odour generating activities being undertaken within the lmlay site,

b. the current odour management processes and procedures being used for those activities, and

c. any proposed alterations to those activities, processes or procedures.

The Permit Holder shall invite all persons who submitted on the notified air discharge applications in 2017, an iwi representative from Tupoho, Ngā Tāngata Tiaki o Whanganui and Tama Ūpoko, and one representative from each of the MWRC and the Whanganui District Council to join the CLG. The information provided to the CLG shall include a copy of the Complaints

This condition allows for the formation of a community liaison group to assist in informing the community about the applicants activities on site.

A condition similar to this is contained both within the current consent and also offered by the applicant in their application.

I am of the opinion it is important for the community to remain informed, especially when it is the community affected by any adverse effects that may arise from the operation. It also assists with the proactive management of the site by the consent holder when there is a requirement to inform the community.

Submitters 7, 16, 17, 20, 21, 25 and 26 all made a suggestion regarding a way to provide feedback to the Regional Council or the Permit Holders themselves. Submitter 18 also requested iwi be liaised with. Conditions 24 through to 28 allow for the operation of both a liaison group and a complaints line for odour. This is in addition to the

Register for the period since the last meeting. Meetings of the CLG shall be held annually in March and upon receiving a written request for a meeting from the MWRC or by request of a CLG member. A CLG meeting shall be convened by the consent holder within four weeks of any such request being received from the MWRC or CLG member or as otherwise agreed with the MWRC.

pollution line also operated by the Regional Council on a 24 hour basis.

25. The Permit Holder shall maintain a dedicated and direct 24 hour telephone number that is available for public complaints regarding odours emanating from the Permit Holder's site. The telephone number shall be attended on a 24 hour basis by a person when the site is operating and additionally a suitably qualified and experienced person shall be available to respond to and investigate all complaints received on a 24 hour basis. The telephone number must be published in the following locations:

a. the White Pages of the Whanganui Telephone Book, and b. its existence and purpose shall be advertised in newspapers

circulating in Whanganui one month and three months following the commencement of these Air Discharge Permits and annually thereafter in July commencing in 2018; and

c. On the AFFCO website; and d. Readily displayed on signage outside of the site in a location which

faces a publically accessible road.

This condition requires the consent holder to maintain a telephone number for complaints.

This condition is also contained in the current consent and is offered by the applicant in their AEE. I note some submitters do not appear to be aware of the existence of the phone number.

In addition to requiring the publishing of the number in the white pages and the local phone book I have also required it be placed on their website and readily displayed in a public location outside of the site.

In the s92 request I have also questioned if a text system or update system on a website is an option. Depending on the answer to this I may update my recommendations to reflect the need to advise the community (or those who sign up to such a service, if implemented) of matters such as maintenance work – again seeking for the Permit Holder to be proactive in managing any odour effects and also give the community a pathway to discuss any issues with the consent holder should they arise. Taylor Preston in Wellington has a good example of sing a website to inform neighbours and collate information such as complaints (https://taylorpreston.co.nz/neighbours/)

I have required provision for the complaint number to be more widely advertised than previously required in the old consent (as per submissions 16, 17 and 20). I also require the consent holder to demonstrate proactive management. While submissions 25 and 26 request this is independent of the consent holder I am of the opinion this set of conditions will allow the MWRC to clearly be able to tell if the consent holder is compliant by way of the annual reporting required in Condition 34.

26. The Permit Holder shall maintain a Complaints Register for any complaints received including any complaints either received or directly referred to the Permit Holder by the Whanganui District Council or the MWRC. For each complaint received the Consent Holder shall record:

a. the name and address of the complainant (if given); b. the location where the complaint occurred;

Conditions 26 and 27 requires the consent holder to record any complaints received and take proactive action in resolving it.

Condition 27 requires the permit holder to provide this feedback to both MWRC and the complainant.

This condition was based on the condition proposed in


https://taylorpreston.co.nz/neighbours/

c. the date and time that the odour was encountered or if that information is not given, the date and time that the compliant was received;

d. the wind speed and direction at the AFFCO lmlay site when the odour was encountered;

e. a description (if given) of any odour character, strength and persistence; and

f. Copies of any feedback given as per Condition 27.

the application. It would be good if the applicant would provide feedback on how the wind speed and direction is currently obtained including how accurate the data is.

27. For each complaint received the Permit Holder shall: a. investigate the most likely source of the odour; b. if the source of the odour is identified as being within the site

undertake remediation or mitigation measures designed to prevent or minimise the risk of the odour reoccurring; and

c. provide written feedback, within two working days of receiving a complaint, to the complainant regarding whether or not the source of the odour was identified and what actions were undertaken by the Permit Holder in order to ensure the incident does not reoccur.

Copies of the written feedback provided to the complainant shall be included in the Complaints Register. Copies of the complaint record and response shall be provided to the Regulatory Manager of the MWRC within 2 working days of the complaint being received.

As above.


28. A copy of the Complaints Register shall be provided to the Manawatu-Whanganui Regional Council upon request. The Complaints Register for the year ending 30 April shall be provided to the Regulatory Manager of the MWRC as part of the annual reporting required by Condition 34.

This condition requires the Permit Holder to provide a full copy of the complaints register as part of their annual report below

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Monitoring Provision Heading

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29. The Permit Holder shall measure and record temperatures as specified in Condition 15 including from the condensers associated with odour control systems and log via the rendering plant SCADA system. Electronic records of temperature versus time and data shall be made available to the Regulatory Manager of the MWRC or a MWRC Officers on request.

Ms Ryan has advised the SCADR system, used by the applicant, is appropriate to record of biofilter parameters, including temperature and inlet pressure.


30. The Permit Holder shall undertake a comprehensive assessment of the media properties within the biofilters on an annual basis prior to 30 March. The assessment shall involve an evaluation of the media size distribution and composition of media including microbial density (cfu/g) and the organic carbon to nitrogen ration. The analysis of samples shall be undertaken by an appropriately qualified testing laboratory and sampling

Ms Ryan advises in her report Biofilters require routine monitoring and maintenance to ensure maintain efficient odour treatment overtime.

Given the biofilters are an integral part in ensuring odour is mitigated from the site I have required a yearly, independent, assessment of the biofilters take


undertaken as specified in the BOP&OMS. Accepted methods shall be used for measurement of media properties that are certified by the Regulatory Manager of MWRC . The assessment shall be undertaken by a person who is independent, appropriately qualified and experienced in the operation and maintenance of biofilters. The results of the assessment, including a summary of the findings, details of any action(s) to be taken to improve the efficiency of the biofilters, and a timetable for those actions to be undertaken; must be submitted to the Regulatory Manager of MWRC as part of the annual report in Condition 34. Any remedial actions much have a timeframe of 6 weeks or less and the Permit Holder must demonstrate the works have been completed within these timeframe in the annual report.

place.

I have also recommended that any actions to improve the bioflters occurs within 6 weeks of the report date and the Permit Holder demonstrates the completed works in their annual report to the council under Condition 34.

31. The Permit Holder shall, annually prior to 30 March, measure and record the vacuum (pressure) at all enclosed equipment items that are extracted by the odour control systems as follows:

a. Pressure shall be measured in the head space of the equipment items that are targeted by the extraction systems. The measurements shall be undertaken by an independent, appropriately qualified and experienced person following industry best practice for measurements of this type.

b. The Permit Holder shall prepare a report on the findings and critically analyse the results (including a comparison with historical data) and if required, make recommendations as to the adequacy of the extraction rates, whether pressures are sufficiently negative and whether additional sealing/enclosing of any rendering plant process area is needed to ensure adequate extraction and compliance with conditions of this consent.

This report must be submitted Regulatory Manager of MWRC as part of the annual reporting required by Condition 34.

This condition requires an annual check to ensure the odour control system is accurately pressured and operating at an optimum level.

See above – Condition 19

32. The gas combustion units on the boiler shall be tuned and tested, prior to 30 April annually, to maintain efficient combustion of fuel. A report summarising boiler test results shall be supplied to the Regulatory Manager of the MWRC as part of the annual report in Condition 33.

This condition requires an annual check to ensure the boiler is accurately pressured and operating at an optimum level.

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33. The Permit Holder shall monitor the quality of raw material that is processed in the rendering plant to ensure compliance with Condition 12. The following parameters for all raw materials received at the rendering plant shall be recorded as part of the Environmental Log required by Condition 7.

a. type, quantity and source of raw materials received in each load; b. temperature, pH, visual appearance and odour of soft offal held in

receiving bins; c. approximate age of raw materials upon receipt and the expected

time before processing; d. details of any stabilisation, where required; and e. acceptance or rejection of material and if rejected where and when

its disposal occurs. The log shall be made available to the Regulatory Manager of the MWRC or of MWRC officers on request at any time. The log must also be supplied as part of the annual report required by Condition 34.

Condition 12 requires strict control on what raw material is accepted onto the site for processing.

This condition requires a log to be kept of this material which must be made available to the MWRC on request and also supplied as part of the annual report in Condition 34.

This allows the MWRC to see clearly the details of the material should an issue arise and also for the consent holder to be able to demonstrate full compliance with Conditions 13 and 14.

See above – under Condition 12

34. The Permit Holder shall prepare an Annual Report summarising performance in relation to the discharges allowed under this resource consent. The Annual Report shall be provided to the Regulatory Manager of the MWRC by 1 June each year from the commencement of this consent. The report shall cover the period 1 May – 30 April. The Annual Report shall include but not be limited to:

a. a copy of the EMS audit required by Condition 3; b. a summary of all biofilter performance, maintenance and

monitoring as collated in the log required by Condition 18 and the annual assessment required by Condition 30;

c. a copy of the log required by Condition 20 regarding daily site checks;

d. a copy of the process operating temperatures for the rendering and drying equipment log as required in Condition 21;

e. a summary of any notifications made to the MWRC in accordance with Condition 24;

f. a copy of any notes recorded during the annual meeting of the CLG under Condition 24;

g. a summary of odour complaints received and the outcome of investigations and responses required by Condition 28;

This condition provides for the consent holder to assess and demonstrate compliance with the c permits for the previous year.

I have required full transparency in their report with a requirement to provide all information and reporting relevant to the operation.

The condition also requires the permit holder to summarise any breaches of the consent (including complaints along with condition non-compliance) and outline the remedial measures they propose along with a clear timeline.

I have proposed all work be undertaken within 9 months of the report date so evidence of this work can be demonstrated in the following years annual report.

I have also recommended this report be supplied by 1 June annually to allow the Regional Council time to review the report and to exercise a review under Condition 36 should the need be identified.

Submitter 15 has requested there is assurance the consent holder follows the conditions of consent. Submitter 7 and 24 want to see assurance that proposed upgrades occur. The annual report is a chance for the consent holder to self report and show they have met the requirements of the consent. The condition also requires self assessment of any breaches with a requirement to undertake remediation

h. Reporting undertaken as part of Condition 31 regarding the vacuum (pressure) at all enclosed equipment items;

i. instrument calibration records as required by Condition 32 j. a production summary for the rendering plant over the previous

12 month period as required under Condition 33; k. Any other relevant information; and l. From 1 June 2019 onwards, a summary of the breaches identified in

the pervious years annual report along with evidence of undertaking the remedial work proposed within the timeline stated.

The Permit Holder shall finalise the report with a summary of breaches and a clear timeline in how these will be addressed. All timelines should be a term of 9 months or less in order for the remedies to be addressed in the following years annual report (as per (j) above).

within 9 months or less.

Review Heading

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35. The MWRC, under section 128 of the Act, may initiate a review of all conditions of these Air Discharge Permits Annually in the month of July for the term of these Air Discharge Permits. The review shall be for the purpose of:

a. reviewing the effectiveness of these conditions in avoiding or mitigating any adverse effects on the environment;

b. reviewing the adequacy of the monitoring and reporting required by these Air Discharge Permits;

c. reviewing the frequency of the CLG meetings; d. reviewing the findings of audit reports required under Condition 3; e. reviewing the effectiveness of odour extraction, cooling and

biofilter treatment systems at controlling odour discharges to levels that cause less than minor effects beyond the site boundary;

f. reviewing the requirement to seal the rendering plant building and extract the process air within that building and treat it in a biofilter;

The review of conditions shall allow for:

g. the deletion or amendment to any conditions of these Air Discharge Permits; and

h. the addition of new conditions as necessary to avoid, remedy or mitigate any adverse effects on the environment; and

i. the implementing of any recommendations of the annual report

Section 128 of the Resource Management Act 1991 allows councils to review consents during the consent term. Generally this condition would be used if the need were identified as a result of the annual report supplied in Condition 34 or as a result of enforcement action taken by MWRC.

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required under Condition 34. j. If necessary and appropriate, the adoption of best practicable

options to avoid, remedy or mitigate and adverse effects to the environment.

Duration Heading

36. The resource consent will expire on 1 July 2025. This condition sets out the consent expiry date.

Reasoning for the date recommended is provided for in paragraph 148 of my report.

Submitters 1, 3, 5, 8, 12, 14, 16, 17, 20, 21, 25 and 26 commented on term. Most suggested a shorter term with no given number of years. Submitters 4, 16 and 17 suggested 5 years while 25 and 26 suggested 5 to 10 years and submitter 20 suggested 10 years. Submitters 3 and 5 suggested a decline of consent.

S42A TechnicalReport – Appendix 8: Planning Provisions Application No. APP-2005011098.01 Prepared by Natasha Adsett – Consents Planner, Horizons Regional Council 4 October 2017

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APPENDIX 8 – Planning Provisions

REGIONAL POLICY STATEMENT

2 Te Ao Māori1 - Resource Management Issues of Significance to Hapū* and Iwi*

Objective 2-1: Resource management

Whāinga 2-1: Te whakahaere rauemi

(a) To have regard to the mauri* of natural and physical resources^ to enable hapū* and iwi* to provide for their social, economic and cultural wellbeing.

Kia aro atu ki te mauri o ngā rauemi māori - ōkiko hoki - hei oranga hapori, ōhanga hoki, tikanga hoki mō ngā hapū me ngā iwi.

(b) Kaitiakitanga^ must be given particular regard and the relationship of hapū* and iwi* with their ancestral lands^, water^, sites*, wāhi tapu* and other taonga* (including wāhi tūpuna*) must be recognised and provided for through resource management processes.

Ka mate ka tino arohia te kaitiakitanga, ā, ka mate ka whakamanatia te hononga o ngā hapū me ngā iwi ki ō rātou whenua tūpuna, wai, papa, wāhi tapu hoki me ētahi atu taonga (pērā i ngā wāhi tūpuna), ā, ka whakaratongia mā ngā tukanga whakahaere rauemi.

Policy 2-1: Hapū* and iwi* involvement in resource management

Kaupapa 2-1: Te whakauru mai o ngā hapū me ngā iwi ki roto i te whakahaere rauemi

The Regional Council must enable and foster kaitiakitanga^ and the relationship between hapū* and iwi* and their ancestral lands^, water^, sites*, wāhi tapu* and other taonga* (including wāhi tūpuna*) through increased involvement of hapū* and iwi* in resource management processes including:

Ka mate ka tutuki i te Kaunihera ā-Rohe - ka atawhaitia hoki - te kaitiakitanga me te hononga o ngā hapū me ngā iwi ki ō rātou whenua tūpuna, wai, papa, wāhi tapu hoki me ētahi atu taonga (pērā i ngā wāhi tūpuna) mā te piki ake o te whakauru mai o ngā hapū me ngā iwi ki roto i ngā tukanga whakahaere rauemi, arā, ko:

(a) memoranda of partnership between the Regional Council and hapū* or iwi* which set clear relationship and communication parameters to address resource management objectives,

ngā manatū rangapū i waenga i ngā hapū me ngā iwi hei whakatakoto i te āhua o te hononga me te whitiwhiti kōrero hei whakatutuki i ngā whāinga whakahaere rauemi,

(b) recognition of existing arrangements and agreements between resource users, local authorities and hapū* or iwi*,

te aro atu ki ngā whakaritenga me ngā whakaaetanga kei te tū tonu i waenga i ngā kaiwhakamahi rauemi, ngā mana takiwā, me ngā hapū, iwi rānei,

1 Te Ao Māori - The Māori World.


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(c) development of catchment-based forums, involving the Regional Council, hapū*, iwi*, and other interested groups including resource users, for information sharing, planning and research,

te whakarite wānanga ā-takiwā e whai wāhi ai te Kaunihera ā-Rohe me ngā hapū, ngā iwi, me ētahi atu tira whai pānga pērā i te hunga whakamahi hei tuari pārongo, hei whakatakoto mahere hoki, rangahau anō hoki,

(d) development, where appropriate, of hapū* and iwi* cultural indicator monitoring programmes by the Regional Council,

te whakahiato a te Kaunihera ā-Rohe i ngā kaupapa aroturuki tohu tikanga - hapū mai, iwi mai hoki - i ngā wā e tika ana,

(e) assistance from the Regional Council to hapū* or iwi* to facilitate research, projects, seminars and training,

te tuku āwhina a te Kaunihera ā-Rohe ki ngā hapū, iwi rānei ki te whakahaere rangahau, kaupapa hoki, awheawhe hoki, whakangungu hoki,

(f) development of joint management agreements^ between the Regional Council and hapū* or iwi* where appropriate,

te whakahiato whakaaetanga whakahaere ngātahi i waenga i te Kaunihera me ngā hapū, iwi rānei e tika ana,

(g) the Regional Council having regard to iwi management plans* lodged with Council,

te aro atu a te Kaunihera ā-Rohe ki ngā mahere whakahaere ā-iwi kua tukuna ki te Kaunihera,

(h) involvement of hapū* or iwi* in resource consent^ decision-making and planning processes in the ways agreed in the memoranda of partnership and joint management agreements^ developed under (a) and (f) above, and

te whakaurunga o ngā hapū, iwi rānei ki roto i ngā tukanga whakatau whakaaetanga rauemi i runga i ngā tikanga i whakaaetia i roto i ngā manatū rangapū me ngā whakaaetanga whakahaere ngātahi i whakahiatongia i raro i te (a) me te (f) kei runga nei, me,

(i) the Regional Council advising and encouraging resource consent^ applicants to consult directly with hapū* or iwi* where it is necessary to identify:

te mahi a te Kaunihera ā-Rohe ki te tuku aratohu, ki te akiaki i ngā kaitono whakaaetanga rauemi ki te kōrerorero me ngā hapū, iwi rānei e tika ana kia tautuhia:

(i) the relationship of Māori and their culture and traditions with their ancestral lands^, water^, sites*, wāhi tapu* and other taonga* (including wāhi tūpuna*), and

te hononga o te Māori ki tōna ahurea me ngā tikanga e pā ana ki ngā whenua tūpuna, ngā wai, ngā papa, ngā wāhi tapu me ētahi atu taonga (pērā i ngā wāhi tūpuna), me

(ii) the actual and potential adverse effects^ of proposed activities on those relationships.


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ngā pānga kino ki aua hononga mai i ngā ngohe ka marohitia - ka whakatinanahia, ka pāngia kinotia pea hoki.

Policy 2-2: Wāhi tapu*, wāhi tūpuna* and other sites* of significance

Kaupapa 2-2: Ko ngā wāhi tapu, wāhi tūpuna hoki me ētahi atu papa hirahira

(a) Wāhi tapu*, wāhi tūpuna* and other sites* of significance to Māori identified:

Kua tautuhia ngā wāhi tapu me ngā wāhi tūpuna me ētahi atu wāhi hirahira ki te Māori:

(iii) In the Regional Coastal Plan and district plans^,

(iv) as historic reserves under the Reserves Act 1977,

(v) as Māori reserves under the Te Ture Whenua Māori Act 1993,

(vi) as sites recorded in the New Zealand Archaeological Association’s Site Recording Scheme, and

(vii) as registered sites under the Historic Places Act 1993

(i) kei roto i te Mahere Takutai ā-Rohe me ngā mahere ā-takiwā,

(ii) hei Historic Reserves i raro i te Reserves Act 1977,

(iii) hei Māori Reserves i raro i Te Ture Whenua 1993,

(iv) hei wāhi kua rēhitatia mā te Site Recording Scheme o te New Zealand Archaelogical Association, ā

(v) hei wāhi kua rēhitatia i raro i te Historic Places Act 1993

must be protected from inappropriate subdivision, use or development that would cause adverse effects^ on the qualities and features which contribute to the values of these sites*.

ka whakamarumarutia i te hē o te wehewehe whenua, te whakamahi whenua, whakaahu whenua rānei e puta ai pea he pānga kino ki ngā painga me ngā āhuatanga ka pā ki te ūara o ēnei wāhi.

(b) The Regional Council must facilitate hapū* and iwi* recording the locations of wāhi tapu*, wāhi tūpuna* and other sites* of significance to Māori in an appropriate publicly-available database.

Ka mate ka tūāpā te Kaunihera ā-Rohe te mahi mā ngā hapū me ngā iwi hei hopu kōrero kia pupuritia ki tētahi pātengi raraunga tika - ka taea hoki e te iwi te tono - kei hea aua wāhi tapu, wāhi tūpuna, me ērā atu papa hirahira ki te Māori.

(c) Potential damage or disturbance (including that caused by inappropriate subdivision, use or development) to wāhi tapu*, wāhi tūpuna* and other sites* of significance to Māori not identified (for confidentiality and sensitivity reasons) by hapū* or iwi* under (a), above, must be minimised by the Regional Council facilitating the compilation of databases by hapū* and iwi* to record locations which need to remain confidential.

Ka mate ka whakaitingia e te Kaunihera ā-Rohe - e tūāpā ana i te whakahiato pātengi raraunga a ngā hapū me ngā iwi hei hopu kōrero mō ngā wāhi me noho muna - ko te pitomata ka tukitukia, ka raweketia (pērā ki tērā ka hua mai i te hē o te wehewehe whenua, te whakamahi, te


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whakaahu rānei) ngā wāhi kāore i tautuhia (mō te noho matatapu me te whakaaro rauangi te take) e ngā hapū me ngā iwi ki tā (a) kei runga nei, ka whakamarumarutia i te torohū ka pakaru, ka rawekengia rānei mā.

(d) The Regional Council must ensure that resource users and contractors have clear procedures in the event wāhi tapu* or wāhi tūpuna* are discovered.

Mā te Kaunihera ā-Rohe e mahi kia hua ai kua whai tukanga mārama te hunga whakamahi rauemi me ngā kaikirimana me aha ā te wā ka kitea he wāhi tapu, wāhi tūpuna rānei.

Policy 2-4: Other resource management issues

Kaupapa 2-4: Ētahi take whakahaere rauemi anō

The specific issues listed in 2.2 which were raised by hapū* and iwi* must be addressed in the manner set out in Table 2.1 below.

Ka mate ka whakatauria ngā take motuhake e rārangitia ana ki 2.2, kua whakaarahia e ngā hapū me ngā iwi Māori, i runga hoki i te takoto o Table 2.1 kei raro nei. Table 2.1 highlights issues of significance to the Region’s hapū* and iwi*, provides explanations in the context of Māori belief and demonstrates how the Regional Council must address these matters. The issues and explanations do not in any way represent a complete picture of hapū* and iwi* concerns, but they offer possible explanations as to the depth of feeling and connection hapū* and iwi* have with the Region’s natural resources. Ka tīpako a Table 2.1 i ngā take hirahira ki ngā hapū me ngā iwi o te Rohe, ka whakamārama hoki i runga i te whakaaro Māori, ā, ka whakaatu ka pēhea te Kaunihera ā-Rohe e whakatutuki pai i ēnei take ka tika. Ehara i te mea mā ngā take me ngā kōrero whakamārama kei konei e whakaatu i te katoa o ngā māharahara o ngā hapū me ngā iwi. Heoi, ko tāna he tuku whakamārama pea mō te kaha o te whakaaro aroha me ngā hononga o ngā hapū me ngā iwi ki ngā rauemi māori o te Rohe.


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Table 2.1 Resource management issues of significance to hapū* and iwi*

Ngā Take Whakahaere Rauemi e Hirahira ana ki ngā Hapū me ngā Iwi

Resource issue of significance to hapū* and iwi* He take rauemi e hirahira ana ki ngā hapū me ngā iwi

Resource issue in the context of tikanga Māori^ He take rauemi me te tikanga Māori

Relevant part of One Plan where issue is addressed Te wāhanga o te One Plan ka kōrerotia te take

(a) Management of water^ quality and quantity throughout the Region does not provide for the special qualities significant to Māori. Kāore te whakahaeretanga o te kounga me te nui o te wai huri noa i te Rohe i te whakarato wāhanga ki ngā āhuatanga e hirahira ana ki te Māori.

Mauri* Mauri Wai Māori (pure water) is essential to hapū* and iwi* in the Region to ensure activities conducted for cultural purposes, such as spiritual cleansing, baptismal rituals and food gathering, are achievable. He mea nui te Wai-Māori ki ngā hapū me ngā iwi o te Rohe kia hua ai ka taea te whakatutuki i ngā mahi tikanga Māori pērā i te whakanoa, te tohi, me te kohikohi kai. Mauri* acts as a balancing agent to ensure the life-supporting qualities within the water^ are maintained. Ko tā te Mauri he whakatautika kia hua ai ka puritia tonutia ngā āhuatanga tuku oranga o te wai. Human activities, application of impure agents, loss of water^ capacity, and contaminants^ all affect the ability of the mauri* to perform its role effectively, therefore resulting in a standard of water^ not suitable for hapū* and iwi* to perform their relevant tikanga Māori^ or cultural activities associated with its use. Ka pāngia kinotia te mauri me tōna āhei ki te whakatutuki pai i tōna kaupapa e te mahi a te tangata me te whakamahi mea paruparu, te mimiti o te wai hoki, me te uru mai o ngā paru kino. Ko te hua he wai kāore i te pai ki ngā hapū me ngā iwi hei whakatutuki i ō rātou tikanga e pā ana ki te whakamahi i te wai.

Surface water^ quality Te kounga o te wai mata Chapter 2 - Te Ao Māori Objective 2-1 Policy 2-3 Chapter 2 Methods Chapter 5 - Water Objective 5-1 Policy 5-1 Chapter 5 Methods Rules, Chapter 14 - Discharges to Land and Water Wāhanga 2 - Te Ao Māori Whāinga 2-1 Kaupapa 2-3 Ngā mahi kei Wāhanga 2 Wāhanga 5 - Wai Whāinga 5-1 Kaupapa 5-1 Ngā mahi kei Wāhanga 5 Ngā ture kei Wāhanga 14 - Te Tuku Parakaingaki ki te Whenua me ngā Wai


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(b) Hazardous substances^ and nitrate run-off need to be better managed to avoid contaminants^ entering water^. Me pai ake te whakahaere matū mōrearea me ngā rerenga pākawa ota hei pare i te uru o ngā paru kino ki roto i ngā wai.

Surface water^ quality Te kounga o te wai mata Chapter 5 - Water Objective 5-2 Policy 5-8 Chapter 5 Methods Rules, Chapter 14 - Discharges to Land and Water Wāhanga 5 - Wai Whāinga 5-2 Kaupapa 5-8 Ngā mahi kei Wāhanga 5 Ngā ture kei Wāhanga 14 - Te Tuku Parakaingaki ki te Whenua me ngā Wai

(c) Lakes^ and streams (for example, Punahau/Waipunahau (Lake Horowhenua and Hokio Stream) have suffered degradation which continues and are considered culturally unclean. Kua hemo haere ngā roto me ngā manga (hei tauira, ko Punahau/Waipunahau, arā, ko Lake Horowhenua me te manga o Hokio) i te whakakinotanga - kei te mahia tonutia hoki, ā, kua pokea te tapu.

Surface water^ quality Te kounga o te wai mata Chapter 5 - Water Objectives 5-1 and 5-2, Policies 5-1 to 5-5 and 5-8 to 5-10 Chapter 5 Methods Rules, Chapter 14 - Discharges to Land and Water Wāhanga 5 - Wai Whāinga 5-1 and 5-2 Kaupapa 5-1 ki 5-5 me 5-8 ki 5-10 Ngā mahi kei Wāhanga 5 Ngā ture kei Wāhanga 14 - Te Tuku Parakaingaki ki te Whenua me ngā Wai


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(d) Access to and availability of clean water^ to exercise cultural activities such as food gathering and baptismal rituals have diminished. Kua mimiti haere te putanga ki te wai me te wātea o te wai mō te hāpai i ngā tikanga pērā i te kohikohi kai, te tohi tamariki, te mea, te mea.

Surface water^ quality Te kounga o te wai mata Chapter 5 - Water Objective 5-2 Policies 5-2 to 5-11 Chapter 5 Methods Wāhanga 5 - Wai Whāinga 5-2 Kaupapa 5-2 ki 5-11 Ngā mahi kei Wāhanga 5

(e) Marae groundwater bore supply is affected in some areas during seasonal drought. I ngā wā kōpaka o te tau ka pāngia ngā poka waiopapa o ngā marae i roto i ētahi takiwā.

(f) Excessive groundwater

abstractions can adversely affect water^ and existing groundwater users. Mā nui rawa o te waiopapa ka tangohia e raru ai te wai me ngā kaiwhakamahi wai o nāianei.

Manaakitanga (hospitality) Manaakitanga The hau kainga (home people) will always ensure the essential needs of their manuhiri (visitors) are accommodated during their stay at the marae, whether it be for hui (social gatherings), tangihanga (funerals), or wānanga (learning institutions). This is a sign of mana*. Ahakoa he hui, he tangihanga, he wānanga rānei, i ngā wā katoa ka manaakitia te manuhiri e te hau kāinga i runga i ngā marae. He tohu whai mana tēnei. In some circumstances, water^ shortages have affected the ability to meet these needs. I ētahi wā, nā te iti o te wai, kāore i taea te whakarato hei whakaea i ēnei matea.

Water^ allocation Te tuaritanga o te wai Chapter 5 - Water Objective 5-3 Policy 5-21 Chapter 5 Methods Wāhanga 5 - Wai Whāinga 5-3 Kaupapa 5-21 Ngā mahi kei Wāhanga 5

(g) Water^ diversion from one catchment to another is considered culturally abhorrent. Ko te whakaaro he mea kiriweti te whakataha i te rere noa a te wai mai i tētahi takiwā ki tētahi atu takiwā.

Mauri* Mauri Hapū* and iwi* may have differing views on the diversion of water^ from one catchment to another. If more information is required on the issue of diverting water^ from one catchment to another, consultation with the relevant hapū* or iwi* may clarify their position on this matter. Kei tēnā hapū, kei tēnā iwi ōna ake whakaaro pea mō te whakataha wai mai i tētahi takiwā ki tētahi atu takiwā. Ki te pīrangitia ētahi pārongo anō e pā ana ki te take nei o te whakataha wai mai i tētahi takiwā ki tētahi atu takiwā, mā te kōrerorero tahi me ngā hapū, iwi rānei ka whai pānga e whakamāramatia ō rātou whakaaro mō tēnei take.

Water^ diversions Te whakataha wai Refer to rules regarding water^ diversion in Chapter 16 - Takes, Uses and Diversions of Water, and Bores Tirohia ngā ture e pā ana ki te whakataha wai kei roto i Wāhanga 16 - Te Tango, te Whakamahi, me te Whakataha Wai, Poka hoki


8




(h) Sewage disposed to water^, in treated form or otherwise, is culturally abhorrent. Land-based treatment is preferred. Ko te whakaaro he mea kiriweti te tuku parakaingaki - ahakoa kua tangohia ngā paru, aha rānei - ki roto i ngā wai. Pai kē ake te whakapai ki uta.

Mahi tautara (sewage waste) There are serious physical and spiritual connotations to hapū* and iwi* associated with human sewage discharge^ to water^. The act of doing so intentionally is, in itself, regarded as poke - an act of spiritual and physical uncleanliness (this term may vary between iwi*). Land-based treatment of sewage is preferred. Ki ngā hapū me ngā iwi Māori, arā ētahi āhuatanga taha ōkiko, taha wairua hoki e pā ana ki te tuku rukenga parakaingaki tangata ki roto i ngā rerenga wai. He poke, arā, he whakaparu wairua, he whakaparu ōkiko hoki te āta mahi pērā (ka rerekē pea te whakamahi a tēnā iwi, a tēnā iwi i tēnei kupu). Pai kē ake te whakapai ki uta. The physical and spiritual effects on hapū* and iwi* can be wide-ranging. The best method of avoiding these effects is the prevention of direct discharge^. Maha kē ngā pānga ōkiko me ngā pānga a-wairua ki ngā hapū me ngā iwi. Ko te tikanga kia āraia te tuku rukenga ki roto tonu i te wai hei pare i ngā pānga.

Sewage discharge^ Te rukenga parakaingaki Chapter 5 - Water Objective 5-2 Policy 5-11 Chapter 5 Methods Rules, Chapter 14 - Discharges to Land and Water Wāhanga 5 - Wai Whāinga 5-2 Kaupapa 5-11 Ngā mahi kei Wāhanga 5 Ture, Wāhanga 14 Te rukenga parakaingaki ki te Whenua me te Wai


9




(i) More riparian retirement and planting is needed to protect river^ banks from erosion. Several iwi* believe harakeke (flax) would provide the most desirable outcome. Ko te tikanga me whakarite wāhi whakatū rākau, me whakatō rākau hoki, hei whakamarumaru i ngā parenga i te horo whenua. Ko te whakapono o ētahi iwi mā te harakeke e tutuki pai ai tēnei.

(j) Land^ management plans need to be encouraged to ensure consistent land^ management practices Region-wide. Me kaha akiaki te whakatakoto mahere whakahaere pāmu kia hua ai ngā tikanga rite mō te whakahaere whenua.

(k) Adverse effects^ of land^ use continue to have a detrimental effect^ on traditional food gathering areas, native habitats and ecosystems. Mā te whakamahi i te whenua me ōna pānga e raru ai tonu ngā wāhi nō mai rānō ka kohikohia he kai, ngā nohonga taketake me ngā pūnaha rauropi.

Manaaki whenua (nurturing the land^) Manaaki whenua Hapū* and iwi* would like to see more measures put in place to plant river^ banks throughout the Region to avoid bank erosion and silt build-up in rivers^. Harakeke (common New Zealand flax) would be the ideal choice. Ko te pīrangi o ngā hapū me ngā iwi kia whakatauria he ritenga mō te whakatō tupu ki ngā parenga o ngā awa huri noa i te rohe hei pare i te horo whenua o ngā pārengarenga me te pikinga o te parahua i roto i ngā awa. Ko te harakeke te tupu tino pai rawa atu mō tēnei mahi. Land^ management plans give hapū* and iwi* more certainty that landowners have an holistic land^ use management approach. Mā ngā mahere whakahaere whenua ngā hapū me ngā iwi e āta mōhio ai kei ngā kaipupuri whenua tētahi tikanga whakahaere e manaakitia ai te whenua. Traditional food gathering sites* and associated native habitats and ecosystems are valued very highly by Māori. He mea tino whai wāriu e te Māori ngā wāhi nō mai rānō ka kohikohia he kai, me ngā nohonga taketake, me ngā pūnaha rauropi hoki.

Surface water^ quality Te kounga o te wai mata

Chapter 5 - Water Objective 5-2 Policy 5-8

Rules, Chapter 14 - Discharges to Land and Water and Water^ Quality Standards in Schedule D Wāhanga 5 - Wai Whāinga 5-2 Kaupapa 5-8

Ture, Wāhanga 14 Te rukenga parakaingaki ki te Whenua me te Wai Taumata Kounga kei roto i te Pukapuka Āpiti D

Land^ use management Te whakahaere i te whakamahi whenua

Chapter 4 - Land Objective 4-1 Policy 4-1 Chapter 4 Methods

Rules, Chapter 13 - Land Use Activities and Indigenous Biological Diversity

Wāhanga 4 - Whenua Whāinga 4-1 Kaupapa 4-1 Ngā mahi kei Wāhanga 4

Ture, Wāhanga 13 - Ngohe Whakamahi Whenua me te Kanorau Koiora Taketake


10




(l) The removal, destruction or alteration of wāhi tapu* and wāhi tūpuna* by inappropriate activities continues to have a detrimental effect^ on those sites* and upon hapū* and iwi*. Ka pāngia kinotia tonu ngā wāhi, me ngā hapū me ngā iwi hoki - i te tango, te wāwāhi, te whakarerekē rānei i ngā wāhi tapu me ngā wāhi tūpuna.

Wāhi tapu* and wāhi tūpuna* Wāhi tapu me ngā wāhi tūpuna Hapū* and iwi* view wāhi tapu* and wāhi tūpuna* as western cultures view cemeteries and churches - as locations that are a significant part of history which require protection and preservation. Wāhi tapu* are sites* that remain tapu (sacred), given the nature of their location and purpose. Ki tā te hapū titiro - ki tā te iwi titiro hoki - āhua rite te wāhi tapu ki tā tauiwi titiro e pā ana ki ō rātou urupā, whare karakia hoki, arā, me whakamarumaru, me tiaki hoki ngā wāhi pērā ka tika. Te mutunga iho ka noho tapu tonu aua wāhi tapu i runga i te āhua o aua wāhi me te kaupapa o aua wāhi. Ancient urupā (burial sites*) are prominent throughout the Region and their locations more often than not remain the intellectual property of hapū* or iwi* members charged with keeping them safe from harm. Maha kē ngā urupā o nehe huri noa i te Rohe. Te nuinga o te wā nō ngā hapū me ngā iwi ake te mōhio kei hea aua wāhi nei, ā, nō rātou hoki te kawenga kia tiaki i aua wāhi tapu kia noho haumaru.

Land^ use management Te whakahaere i te whakamahi whenua Chapter 4 - Land Objective 4-1 Policy 4-1 Chapter 4 Method Rules, Chapter 14 - Discharges to Land and Water Wāhanga 4 - Whenua Whāinga 4-1 Kaupapa 4-1 Ngā mahi kei Wāhanga 4 Ture, Wāhanga 14 Te rukenga parakaingaki ki te Whenua me te Wai Chapter 6 - Indigenous biological diversity, landscape and historic heritage Objective 6-3 Policies 6-11 and 6-12 Method 6-10

Wāhanga 6 - Kanorau Koiora Taketake, tohu whenua, hītori tuku iho Whāinga 6-3 Kaupapa 6-11 me 6-12 Mahi 6-10

Rules and conditions^ protecting wāhi tapu* throughout the Plan. Ngā ture me ngā tikanga puta noa i te Mahere hei whakamarumaru i ngā wāhi tapu


11




(m) The transfer of indigenous plants from rohe* to rohe* is considered culturally unnatural. Kāore i te tika ki te whakaaro ahurea Māori te whakawhiti tupu taketake mai i tētahi rohe ki tētahi atu rohe.

Tapu (sacred) Tapu The transfer of indigenous plants from one rohe* to another can result in the cross-pollination of plants native to a particular rohe*, affecting elements of tapu. The act of artificially cross-pollinating plants including trees or removing and planting them away from their points of origin is not common practice to hapū* and iwi*. Ideally they would like the integrity of each rohe* preserved in its natural state. Ka pāngia rawatia ētahi āhuatanga o te tapu e te whakaaiai whitiwhiti i ngā tupu taketake mai i tētahi rohe ki tētahi atu rohe. Ehara i te mahi māori noa ki ngā hapū me ngā iwi te whakaaiai whitiwhiti i ngā tupu, pērā i ngā rākau, te tango i ērā mai i tētahi rohe me te whakatō ki wāhi kē. Ko tō rātou pīrangi ake kia tiakina te rohe kia tūturu tonu te taiao. Hapū* and iwi* are advocating for assistance via policy and funding to protect the integrity of indigenous plants and animals from human activity and pest plants and pest animals. Kei te tohe tonu ngā hapū me ngā iwi kia tautokona ā-kaupapa nei, ā-putea nei hoki te whakamarumaru i te ngā tupu taketake me te aitanga kararehe i ngā mahi a te tangata, ngā otaota, me ngā orotā.

Chapter 6 - Indigenous biological diversity, landscape and historic heritage Objective 6-1 Policies 6-1 to 6-5 Chapter 6 Methods Rules, Chapter 13 - Land Use Activities and Indigenous Biological Diversity Wāhanga 6 - Kanorau koiora taketake, tohu whenua, hītori tuku iho Whāinga 6-1 Kaupapa 6-1 ki 6-5 Ngā mahi kei Wāhanga 6 Ture, Wāhanga 13 - Ngohe Whakamahi Whenua me te Kanorau Koiora Taketake

(n) Indigenous plants and animals continue to be under increased threat by human and pest activity. Kei te whakawetia tonutia ake ngā tupu taketake me te aitanga kararehe taketake e te mahi a te tangata me te orotā.

Indigenous biological diversity^ Te kanorau koiora taketake Chapter 6 - Indigenous biological diversity, landscape and historic heritage Objective 6-1 Policies 6-1 to 6-5 Chapter 6 Methods Rules, Chapter 13 - Land Use Activities and Indigenous Biological Diversity Wāhanga 6 - Kanorau koiora taketake, tohu whenua, hītori tuku iho Whāinga 6-1 Kaupapa 6-1 ki 6-5 Ngā mahi kei Wāhanga 6 Ture, Wāhanga 13 - Ngohe Whakamahi Whenua me te Kanorau Koiora Taketake


12




(o) Further research on preventing saltwater intrusion into coastal aquifers is a necessity. Ka mate ka rangahaua tonutia te ārai i te urunga waitai ki roto i ngā kahupapa takutai moana.

Manaaki manuhiri (caring for your visitors) Manaaki manuhiri Saltwater intrusion is a significant issue for hapū* and iwi* as many marae situated close to the coastal environment rely on groundwater bores as their primary water supply. Hapū* and iwi* encourage proactive research to ensure this situation is avoided. He take nui te urunga waitai ki ngā hapū me ngā iwi, nō te mea, he maha ngā marae e noho tata nei ki te taiao takutai moana e tango ana i te waiopapa i ngā poka i te tuatahi hei whāngai i ngā marae. Ka akiaki ngā hapū me ngā iwi i te mahi rangahau kia hua ai ka parea tēnei āhuatanga.

Groundwater quality Te kounga o te waiopapa Chapter 5 - Water Objective 5-2 Policy 16-7 Rules, Chapter 16 - Takes, Uses and Diversions of Water, and Bores Wāhanga 5 - Wai Whāinga 5-2 Kaupapa 16-7 Ture, Wāhanga 16 - Te Tango, te Whakamahi, me te Whakataha Wai, Poka hoki

(p) Biodiversity research needs more funding. Me whai putea anō te rangahau e pā ana ki te kanorau koiora.

Tiro whakamua (a glance at the future) Tiro whakamua Many Māori landowners are actively involved in restoring and preserving wetlands^ to maintain native habitats for future generations. Tokomaha ngā kaipupuri whenua Māori e kaha whakahou ana, e tiaki ana hoki i ngā papa waiwai hei pupuri i ngā wāhi noho pēnei mā ngā whakatupuranga e haere mai nei.

Threatened indigenous biological diversity^ Te kanorau koiora ka whakawetia Chapter 6 - Indigenous biological diversity, landscape and historic heritage Objective 6-1 Policies 6-1 to 6-4 Chapter 6 Methods Rules, Chapter 13 - Land Use Activities and Indigenous Biological Diversity Wāhanga 6 - Kanorau Koiora Taketake, tohu whenua, hītori tuku iho Whāinga 6-1 Kaupapa 6-1 ki 6-4 Wāhanga 6 ngā ture Ture, Wāhanga 13 - Ngohe Whakamahi Whenua me te Kanorau Koiora Taketake


13




(q) Monitoring and enforcement of environmental standards, including those contained in regional plans^, district plans^ and resource consents^, are insufficient at times. I ētahi wā he iti rawa te aroturuki me te ūruhitanga o ngā taumata taiao pērā ki ērā kei roto i ngā mahere rohe, ngā mahere takiwā, me ngā whakaaetanga rauemi.

Te aroturuki me te ūruhitanga (monitoring and enforcement) Te aroturuki me te ūruhitanga Māori wish to see a greater level of monitoring undertaken for resource use activities. Many Māori also wish to see those who do not comply with resource consent^ or permitted activity^ conditions^ undertake remedial work to remedy their actions. Ko te pirangi o te Māori kia nui ake te aroturuki ka mahia hei ngohe whakamahi rauemi. Ko tētahi pirangi anō o te Māori kia mahi te hunga kore whai i ngā whakaritenga whakaaetanga rauemi me ngā mahi ka whakaaetia ki te whakatikatika i ā rātou mahi hē.

Monitoring and enforcement Te aroturuki me te ūruhitanga Chapter 12 Policy 12-8 Wāhanga 12 Kaupapa 12-8


14

3 Infrastructure, Energy, Waste*, Hazardous Substances* and Contaminated Land

Objective 3-5: Waste*, hazardous substances* and contaminated land^

The Regional Council and Territorial Authorities^ must work together in a regionally consistent way to:

(i) minimise the quantity of waste* generated in the Region and ensure it is disposed of appropriately,

(ii) manage adverse effects^ from the use, storage, disposal and transportation of hazardous substances*, and

(iii) manage adverse effects^ from contaminated land^.

Whāinga 3-5: Te para, ngā matū mōrearea, me ngā whenua tāhawahawa

Ka mahi tahi te Kaunihera ā-Rohe me ngā Mana Takiwā i runga i te tikanga rite

huri noa i te rohe ki te:

(i) whakaiti i te rahi o te para ka puta mai huri noa i te Rohe, kia hua ai hoki

ka tika te whakawātea

(ii) whakahaere i ngā pānga kino nā te whakamahi, te putu, te whakawātea,

me te kawe i ngā matū mōrearea, me te

Policy 3-8: Waste* policy hierarchy

Wastes*, including solid, liquid, gas and sludge waste*, must be managed in accordance with the following hierarchy:

(a) reducing the amount of waste* produced

(b) reusing waste*

(c) recycling waste*

(d) recovering resources from waste*

(e) appropriately disposing of residual wastes*.

Policy 3-9: Consent information requirements - waste* policy hierarchy and hazardous substances*

Where a proposal has the potential to give rise to significant adverse effects^ on the receiving environment^, an assessment must be required, as part of the consent information requirements for all discharges^ to air, land^, water^ and the coastal marine area^, of:

(a) reduction, reuse, recycle and recovery options for the discharge^ in

accordance with Policy 3-8, and

(b) any hazardous substances* that may be present in the discharge^, and alternatives to those hazardous substances*.


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7 Air

Objective 7-1: Ambient air* quality

A standard of ambient air* quality is maintained which is not detrimental to amenity values^, human health, property or the life-supporting capacity of air and meets the national ambient air* quality standards.

Whāinga 7-1: Te kounga hau o-waho

Ka tiakina tētahi paenga kounga hau o-waho kāore he whakawhara ki ngā ūara

Taonga* whakaahuru, te hauora tangata, ngā rawa, te oranga tonutanga rānei o te

hau – ka eke hoki ki ngā paenga kounga hau o-waho o te motu.

Objective 7-2: Fine particle (PM10*) levels

(a) Fine particle levels in Taihape and Taumarunui are reduced to comply with the national ambient air* quality standard for PM10* by 1 September 2013

2.

(b) Fine particle levels in other areas are managed in a manner which ensures ongoing compliance with the national ambient air* quality standard for PM10*.

Whāinga 7-2: Ngā taumata ira meroiti (PM10*)

(a) Hei mua mai i te 1 o Hepetema 2013 ka whakahekea iho ngā ira meroiti i Taihape me Taumarunui kia hāngai tonu ki te paenga kounga hau o-waho

(PM10*) o te motu.

(b) Ka whakahaeretia ngā taunga ira meroiti i wāhi kē kia hua ai ka hāngai

tonu ki te paenga kounga hau o-waho (PM10*) o te motu.

Policy 7-1: National Environmental Standards^

The National Environmental Standards^ set out in Table 7.1 must be adopted as ambient air* quality standards for the Region and ambient air* quality must be:

(a) maintained or enhanced in those areas which meet the standards, and

(b) enhanced in those airsheds which do not meet the standardsin accordance with the air quality categories and designated responses in Table 7.2.

2 The date of 1 September 2013 for achieving compliance with the national ambient air* quality

standard for PM10*, is set in the Resource Management (National Environmental Standards Relating to Certain Air Pollutants, Dioxins, and Other Toxics) Regulations 2004.


16

Table 7.1 National Environmental Standards^ for Ambient Air* Quality3

Contaminant^ Threshold Concentration Permissible Excess

Carbon monoxide 10 mg/m3 (running 8-hour mean)

One 8-hour period in any 12-month period

Nitrogen dioxide 200 µg/m3 (1-hour mean)

Nine 1-hour periods in any 12-month period

Ozone 150 µg/m3 (1-hour mean)

Not to be exceeded at any time

Fine particles (PM10*) 50 µg/m3 (24-hour mean)

One 24-hour period in any 12-month period

Sulphur dioxide 350 µg/m3 (1-hour mean)

Nine 1-hour periods in any 12-month period

570 µg/m3 (1-hour mean)

Not to be exceeded at any time

Table 7.2 Air Quality Categories and Designated Response

Category Measured Value Designated Response

Unacceptable Greater than the threshold concentration in the National Environmental Standards^ for Air Quality, and exceeds the permissible excess in Table 7.1

Enhance

Establish long-term strategy

Monitor

Publicly notify exceedances

Degraded 66% to 100% of the threshold concentration in the National Environmental Standards^ for Air Quality in Table 7.1, with one exceedance

Maintain, and enhance where practicable

Establish awareness programmes

Monitor where practicable

Acceptable Up to 66% of the threshold concentration in the National Environmental Standards^ for Air Quality in Table 7.1, with one exceedance

Maintain

3 Resource Management (National Environmental Standards Relating to Certain Air Pollutants,

Dioxins, and Other Toxics) Regulations 2004


17

Policy 7-2: Regional standards for ambient air* quality

In addition to the National Environmental Standards^ set out in Policy 7-1, ambient air* quality must be managed in accordance with the regional standards set out in Table 7.3.

Table 7.3 Regional Standards for Ambient Air* Quality

Contaminant^ Regional Standard

Odour A discharge^ must not cause any offensive or objectionable odour beyond the property* boundary.

Dust A discharge^ must not cause any noxious, offensive or objectionable dust beyond the property* boundary.

Smoke and water^ vapour A discharge^ must not result in any objectionable or offensive smoke or water^ vapour beyond the property* boundary.

Agrichemicals* A discharge^ must not give rise to noxious or dangerous levels of agrichemicals* in terms of human health, non-target plants or animals, or property*.

Gases and other airborne contaminants^

A discharge^ must not result in noxious or dangerous levels of gases or other airborne contaminants^ beyond the property* boundary.

Note: There are guidelines contained within Chapter 15, Section 15.2 that assist

in defining the terms noxious, dangerous, offensive and objectionable.

Policy 7-3: Regulation of discharges^ to air

Discharges^ of contaminants^ into air will be generally allowed, provided:

(a) the effects^ of the discharge^ are consistent with the approach set out in Policy 7-1 for implementing the National Environmental Standards^ for ambient air* quality, and

(b) the discharge^ is consistent with the regional standards for ambient air* quality set out in Policy 7-2.


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8 Coast

Objective 8-1: Integrated management of the coastal environment

Achieving integrated management of the coastal environment by:

(a) providing a consistent, efficient and integrated management framework, and

(b) recognising and managing the effects^ of land^ uses and freshwater-based activities (including discharges^) on the CMA.

Whāinga 8-1: Te whakahaere kōmitimiti i te taiao takutai moana

Ka tutuki pai te whakahaere kōmitimiti i te taiao takutai moana mā te:

(a) whakarato i tētahi anga whakahaere kōmitimiti whai auautanga, whai tikanga whakamau hoki, me te

(b) aro atu, te whakahaere hoki i ngā pānga o te whakamahi whenua me ngā

ngohe ā-wai māori (ehara tonu ko ngā rukenga parakaingaki) ki runga i te CMA.

Policy 8-1: Integrated management of the coastal environment

Integrated management of the coastal environment must be sought, including through:

(a) provisions in this chapter and the provisions of the Regional Coastal Plan (Chapter 18 and Schedule I as well as Chapters 11, 12 and 19 and the relevant definitions in the Glossary),

(b) provisions in other chapters of this Plan address water^ quality, erodible land^ (including the coastal foredune*), natural hazards^, indigenous biological diversity^, landscapes and natural character, air discharges^, and infrastructure^, energy and waste* (including hazardous substances*),

(c) provisions in district plans^ that identify the landward extent of the coastal environment, sustainably manage land^ use activities and, where appropriate, avoid subdivisions or development in any existing or potential hazard risk area, protect coastal dunes and avoid sprawling subdivision along the coastal edge, and

(d) joint initiatives where resource management issues arise and are not addressed within the existing management frameworks of the respective regional plans^ and district plans^.


19

Policy 8-2: Activity Management Areas

Activities in the CMA must be managed using Activity Management Areas.

The Activity Management Areas comprise:

(a) a Port Activity Management Area for the purposes of enabling the efficient and practical operation* of Wanganui Port and associated industries and boating facilities, as shown in Schedule I: Part B, by providing for activities which:

(i) facilitate the operation* of the Wanganui Port and marina, including restricting public access where it is necessary for safety reasons

(ii) involve maintenance dredging and associated disposal to maintain a navigational depth

(iii) involve the maintenance*, upgrade* or extension of existing structures^.

(b) various Protection Activity Management Areas for the purposes of protecting the ecological and other important characteristics within each specified Area (as shown in Table I.1 of Schedule I: Part B). These Areas are sensitive and must be protected from adverse effects^ of activities other than activities which:

(iv) appropriately enable or restrict public access, or

(v) are essential for public safety, or

(vi) are intended to restore or conserve a site* or characteristics within a site*, or

(vii) have no more than minor adverse environmental effects^ on the characteristics to be protected in each Protection Activity Management Area.

(c) a General Activity Management Area for the purposes of managing activities in all areas other than areas covered by the Port Activity Management Area and Protection Activity Management Areas. The purpose of the General Activity Management Area is to ensure that adverse effects^ are avoided as far as reasonably practicable and, where they cannot be avoided, are remedied or mitigated.


20

A. REGIONAL ONE PLAN

12 General Objectives and Policies

Policy 12-5: Consent durations

(a) Other than as provided for under (b), the Regional Council will generally grant resource consents^ for the term sought by the applicant unless reasons are identified during the consent process that make this inappropriate.


21

(b) Resource consent^ durations for applications required under ss13, 14 and 15 of the RMA will generally be set to the next common catchment expiry date listed in Table 12.1. The dates listed in Table 12.1 show the initial expiry or review dates for consents within the catchment. Future dates for expiry or review of consents within that catchment must occur again every 10 years thereafter. Consents granted within three years prior to the relevant common catchment expiry date may be granted with a duration to align with the second common expiry date (that is the number of years up to the next expiry date plus 10 years). Dates may also be extended in 10 year increments where a term longer than 10 years can be granted after considering the following criteria:

(i) the extent to which an activity is carried out in accordance with a recognised code of practice, environmental standard or good practice guideline;

(ii) the most appropriate balance between environmental protection and investment by the applicant;

(iii) the provision of s128 review opportunities to enable matters of contention to be periodically reviewed in light of monitoring and compliance information; and

(iv) whether the activity is infrastructure^; water^, sewage or stormwater treatment plants and facilities; or publicly accessible solid waste* facilities including landfills*, transfer stations and resource recovery facilities.

For a consent which is granted for a duration longer than 10 years, review of the consent must occur, as a minimum, on the review date in Table 12.1 and every 10 years thereafter until consent expiry. Extra review dates may be set in accordance with Policy 12-6.

(c) Matters to be considered in determining a shorter consent duration than that requested under (a):

(i) whether it is necessary for an activity to cease at a specified time;

(ii) whether the activity has effects^ that are unpredictable and potentially serious for the locality where it is undertaken and a precautionary approach is needed;

(iii) the risks of long-term allocation of a resource whose availability changes over time in an unpredictable manner, requiring a precautionary approach; and

(iv) in the case of existing activities, whether the consent holder has a good or poor compliance history in relation to environmental effects^ for the same activity.

Table 12.1: Common expiry/review dates for consents in Water Management Sub-zones*

Water Management Zone* Water Management Sub-zone* Expiry / review (1 July)

Mangatainoka Upper, Middle and Lower Mangatainoka and Makakahi 2010


22

Policy 12-6: Consent review

In addition to the reasons specified in s128(1)(a)(i) and (ii) RMA, the Regional Council will, under s128(1)(a)(iii) RMA, generally impose consent conditions^ that specify a review of consent conditions^ during the term of the consent for:

(a) reviewing the appropriateness of any condition^ requiring the consent holder to supply the consent authority^ with information relating to the exercise of the resource consent^;

(b) reviewing any unknown or uncertain adverse effects^ caused as a result of planned or required changes or upgrades* to the activity;

(c) reviewing the conditions^ of a consent at the same time as review of other consents within the same Water Management Sub-zone* - for example, at a common catchment expiry or review date*; and

(d) reviewing the effectiveness of consent conditions^ to avoid, remedy or mitigate any adverse effects^ of the activity on the environment^.

The Regional Council will generally initiate reviews of conditions^ when monitoring results or other evidence demonstrate a review is required.


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15 Discharges to Air

Objective 15-1: Air quality

The management of air quality in a manner that has regard to:

(a) maintaining or enhancing ambient air* quality in a manner that safeguards the health of the Region’s community,

(b) meeting the regional ambient air* standards (Table 7.3) and National Environmental Standards^ (Table 7.1),

(c) managing air quality so that it is not detrimental to amenity values^, and

(d) managing fine particle (PM10*) levels to ensure that they are reduced in unacceptable airsheds and managed in other areas to ensure compliance with the national ambient air* quality standard for PM10*.

Policy 15-2: Consent decision-making for other discharges^ into air

When making decisions on resource consent^ applications and setting consent conditions^ for discharges^ of contaminants^ into air, the Regional Council must have regard to:

(a) the objectives and policies of Chapter 7 including:

(i) the degree of consistency with the approach set out in Policy 7-1 for implementing the National Environmental Standards^ for ambient air* quality,

(ii) the degree of compliance with the regional standards for ambient air* quality set out in Policy 7-2, and

(iii) for discharges^ of fine particles, the approaches for managing fine particles (PM10*) in Policies 7-5, 7-6 and 7-7, and the likely contribution of the proposed discharge^ to cumulative adverse effects^ in an unacceptable airshed or degraded area as identified under these policies,

(b) the guidelines in Section 15.3 for managing noxious, dangerous, offensive and objectionable effects^,

(c) any national policy statements^, national regulations^, or nationally-accepted guidelines or codes of practice relevant to the activity, including the matters in Policy 14-9 for activities involving an ancillary discharge,

(d) the location of the discharge^ in relation to, and any associated effects^ on, sensitive areas including, but not limited to:

(i) residential buildings,

(ii) public places and amenity areas where people congregate,

(iii) education facilities,

(iv) public roads,

(v) surface water bodies^,

(vi) wāhi tapu*, marae and other sites* of significance to hapū* and iwi*,

(vii) domestic, commercial and public water supply* catchments and intakes,

(viii) rare habitats*, threatened habitats* and at-risk habitats*, and

(ix) sensitive crops or farming systems (including certified organically farmed properties* and greenhouses),


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(e) effects on scenic, landscape, heritage and recreational values,

(f) the appropriateness of adopting the best practicable option^ to prevent or minimise adverse effects^ in circumstances where:

(i) numerical guidelines or standards establishing a level of protection for a receiving environment^ are not available or cannot easily be established,

(ii) insufficient monitoring data is available to establish the existing air quality with sufficient certainty, or

(iii) the likely adverse effects^ are minor, and the costs associated with adopting the best practicable option^ are small in comparison to the costs of investigating the likely effects^ on air quality,

(g) the need for contingency measures to avoid accidental discharges^, including discharges^ arising from mechanical failure, and

(h) adverse effects^ on aircraft^ safety from high velocity vertical discharges^ to air.

15.3 Guidelines for Managing Noxious, Dangerous, Offensive and Objectionable Effects

Several rules in this section use the terms “noxious”, “dangerous”, “offensive” and “objectionable”. While these terms are included in s17 RMA, they are not defined. These terms are also not defined in the Glossary of this Plan because the assessment of whether an activity is noxious, dangerous, offensive or objectionable is subjective and must take account of case law precedent as it develops.

Definitions of these terms can be found in the dictionary - for example (from the Concise Oxford Dictionary, New Edition, 1978):

noxious means “harmful, unwholesome”

dangerous means “causing danger, unsafe”

offensive means “giving or meant to give offence, disgusting, ill-smelling, nauseous, repulsive, unpleasant or disgusting to the senses, causing annoyance or anger, insulting”

objectionable means “undesirable, unpleasant, offensive, disapproved of”.

Offensive and objectionable

Case law has established that an odour is deemed offensive or objectionable only if a reasonable ordinary person, who is neither sensitive nor insensitive, would be offended or find it objectionable. It is not enough for a neighbour or some other person within the relevant environment to consider the activity or matter to be offensive or objectionable.

In determining whether an odour is offensive or objectionable, a council enforcement officer may consider the following:

frequency - how often an individual is exposed to odour,

intensity - the strength of the odour,

duration - the length of a particular odour event,

offensiveness/character - the character relates to the hedonic tone of the odour, which may be pleasant, neutral or unpleasant,


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location - the type of land use and nature of human activities in the vicinity of an odour source,

the sensitivity of the receiving environment, including reverse sensitivity,

the Good Practice Guide for Assessing and Managing Odour in New Zealand (Ministry for the Environment, 2003).

In determining whether a discharge is resulting in any objectionable or offensive smoke, water vapour, dust, gases or airborne contaminant, a council enforcement officer may consider the following:

frequency, intensity, duration, offensiveness/character and location of exposure,

the Good Practice Guide for Assessing and Managing the Environmental Effects of Dust Emissions (Ministry for the Environment, September 2001),

the sensitivity of the receiving environment, including reverse sensitivity,

adverse effects, including effects on road visibility and aircraft flight paths.

Noxious and dangerous

In determining whether a discharge causes any noxious or dangerous levels of contaminants a council enforcement officer may consider:

the Workplace Exposure Standards (Occupational Safety and Health Service, 1994 and as updated in January 2002): as a guide the concentration of any contaminant specified in the Workplace Exposure Standards should not exceed one thirtieth of the time-weighted average for the short-term exposure standard on adjacent properties or on public land,

the Ambient Air Quality Guidelines (Ministry for the Environment, 2002) as they relate to hazardous substances,

any relevant National Environmental Standards,

the frequency, intensity, duration, and location of exposure,

the sensitivity of the receiving environment,

relevant provisions under the Hazardous Substances and New Organisms Act 1996,

advice provided by Territorial Authority environmental health officers and district health boards.


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B. Regional Rules

Rule Activity Classification Conditions/Standards/Terms Control/Discretion

Non-Notification

15-10

Other burning activities

The discharge^ of contaminants^ into air and any subsequent discharge^ of contaminants^ onto land^ pursuant to ss15(1) or 15(2A) RMA from burning activities which either:

(a) are located on industrial or trade premises^ and are not addressed by any other rule^ in this Plan, or

(b) do not comply with one or more conditions^, standards or terms of a permitted activity^ rule^, but which are not expressly classified as a discretionary activity^, non- complying activity^ or prohibited activity^.

Discretionary

15-17

Other discharges^

The discharge^ of contaminants^ into air pursuant to ss15(1) or 15(2A) RMA and any subsequent discharge^ of contaminants^ onto land^ from activities which either:

(a) are located on industrial or trade premises^ and are not addressed by any other rule^ in this Plan, or

(b) do not comply with one or more conditions^, standards or terms of a permitted activity^ rule^, but which are not expressly classified as a controlled activity^, restricted discretionary activity^, discretionary activity^, non-complying activity^ or prohibited activity^.

Discretionary


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Rule Activity Classification Conditions/Standards/Terms Control/Discretion

Non-Notification

Discharges^ that are covered by this rule^ under (a) include, but are not limited to, those activities listed in the rule^ guide following this rule^ table.

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