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:


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.


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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