Mining Lignite Should Be Prohibited In Plan
The Southland District Council's mayor, Frana Cardno, is a passionate supporter of the natural environments within her jurisdiction. She has put her weight behind the save Fiordland campaign and has openly expressed concerns about lignite mining. The Government has removed the ability of the RMA to recognise climate change has also removed the four well-beings. Mayors and councils who truly want to operate in the real interests of their people and the natural environment are now hugely restricted.
Coal Action Murihiku provided a submission to the Southland District Council Plan that we hope may provide stronger protections to the local environment and support the long term health of the people. We hope our recommendations are adopted:
SUBMISSION TO THE PROPOSED SOUTHLAND DISTRICT PLAN
2012
This submission to Southland
District Council’s proposed plan is on behalf of Coal Action Murihiku (CAM), a
group of Southland residents who are concerned about the adverse effects of
coal and lignite mining in the region. CAM is a subgroup of the national
organisation and incorporated society, Coal Action Network of Aotearoa that has
around 1650 members.
INTRODUCTION
The Southland District
Council rightly identifies the rich resources within the geographical area it
administers. In managing those resources it has a responsibility to duly
consider the needs of future generations and the wider economic and
environmental trends that are occurring at a national and global level.
We are seeing growing demand
for food and the arable land on which it is produced as the world’s population
grows and new markets are developed. Southand’s on-going potential as a major
food producer needs to be protected.
The major environmental concern
facing all inhabitants of this planet is climate change and this is already
having a serious affect on the world’s weather patterns and sea levels.
Accompanying this is the growing loss of species diversity within the living
world. Climate change, mono-cultural farming methods and destruction of
ecosystems through poorly managed commercial developments have contributed hugely
to biodiversity loss.
In managing Southland’s
resources the Southland District Council needs to ensure the sustainability of
our agricultural land, the protection of our unique environments and indigenous
flora and fauna and the wise use of our mineral wealth.
There is also value in our
existing landscapes for both tourism and the well-being of the Southland
people. Significantly altering our landscape through land use or construction
must be considered carefully.
This submission largely
supports the content of this proposed plan, which, we acknowledge, addresses a
number of our concerns. We believe, however, that if we are going to truly
protect and enhance the Southland region for future generations, some stronger
protections will be necessary.
SECTION 2.2 – Biodiversity
We support the majority of
this section where it establishes the importance of maintaining and protecting
our indigenous biodiversity. It is especially important for the protection of
our pristine World Heritage Park, Te Wahipounamu, where the unaltered
environment was responsible for gaining this status. Much of this section is
devoted to the protection of existing indigenous environments but we would like
to have the inclusion of three additional ways of supporting biodiversity.
i)
Riparian strips.
In lowland areas these strips are hugely significant as buffers in lowland
areas between the natural ecosystems of rivers and streams and increasingly
intensively farmed land. It should be a priority to have these strips planted appropriately
to help preserve and protect the last wild areas of our Southland plains.
ii)
Road verges.
These areas are largely managed by the council and there is potential to
develop a biodiversity within them that is both attractive for road users and
has the kind of environment that may support our wider economy, especially
agriculture. While the focus in most of the plan’s biodiversity section is on
indigenous biodiversity this may not necessarily be the focus for road verges
where a range of plantings may support insects such as pollinators or provide
food for native birds.
iii)
Contemporary
farming increasingly promotes industrial and monocultural farming practices
(especially dairying). Encouraging mixed farming will ensure more sustainable
farming methods, put less stress on the land and increase biodiversity.
SECTION 2.8 -
Waste, Hazardous Substances and Contaminated land
Rule HAZS.4 - Prohibited Activities (a new section)
Given that the medical
practitioners have identified health risks from the mining of coal and the fact
that carbon dioxide produced by burning fossil fuels is the the main
contributor to climate change, we would like any new coal and lignite mining
specifically listed as a prohibited activity.
Southland should also learn
from the experiences of coal mining in the Hunter Valley and Queensland in
Australia where numerous communities have been destroyed and irreparable harm
has been caused to the agricultural future of the areas mined.
The areas in Southland where
the largest lignite reserves have been discovered are beneath some of our most
productive farmland. The value of the soil for food production is far more important
over time than the short-term value of the lignite.
Burning
lignite and coal contributes to ocean acidification through the reaction of
carbon dioxide with seawater. The effects of lignite mining causing ocean
acidification are contrary to part 2 of the RMA as it damages the life
supporting capacity of the ocean, damages the significant habitats of indigeous
fauna such as marine reserves, damages the capacity of the oceans to provide
food for people and can cause associated economic effects on marine food
industries.
Southland fresh water is a
precious commodity and supports natural environments, industry and people. Any
frackingcarried out in Southland would involve the use of large volumes of
water, the introduction of potentially harmful substances and the risk of
damage damage to aquifers. We would like to see fracking specifically named as
a discretionary activity so that these effects are subject to strict controls
and monitoring.
SECTION 2.9 – Energy, Minerals and infrastructure
There is no specific mention
of coal and lignite, as there was in the old plan, and no reference to gas
extraction. Given the recent proposals to access lignite and the exploratory
licenses in Northern Southland (in relation to coal seam gas and fracking) it
is important that these are identified in the new plan.
In the report on fracking by
the Parliamentary Commissioner for the Environment (2012), Dr Wright states:
“However I have significant concerns about how
fragmented and complicated the regulatory environment for fracking is and about
how these rules are being applied. If fracking is not done well it can have
significant environmental impacts including polluting water and triggering
earthquakes. I am also concerned that regulation may be too light-handed,
particularly if fracking opens the door to a large-scale and widespread oil and
gas boom with a lot of different companies involved.”
Given the rapid growth of the industry the council will
need to be fully prepared for the regulatory responsibility and monitoring of
future fracking developments.
The following content was in
old plan and should be re-included:
“For discretionary activity applications must include full assessments
of effects including CO2 emissions and other potential impacts on
climate/atmospheric conditions, description of all alternative energy production
methods considered and alternative sites.
Council lists a wide array of matters to be
considered – Part 2, impacts on communities and infrastructure and services,
ecosystem and habitats, amenity values (including visual and noise), HSE,
central government policy on greenhouse gas emission, potential loss
of/irreversible damage to landscape and landforms, the sustainability of the
energy source and energy production method, the need for the facility, the
benefit to the District, and on-going effect on climate change, land
instability, list of a particular landscape, disturbance of vegetation.”
While there is some economic
value in the fossil fuel deposits found throughout Southland it is important
that the council is able to consider the value more sustainable, low carbon
industries will provide for the region as identified in the BERL report “A View to the South: Potential low carbon
growth opportunities for the Southern Region economy”.
Coal Action Murihiku would
be grateful if this submission receives due consideration and we would like the opportunity to
speak to it.
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