Notice of Requirement Submission Watercare Southwest Wastewater Treatment Plant at 372 Glenbrook Beach Road

Notice of Requirement Submission Watercare Southwest Wastewater Treatment Plant at 372 Glenbrook Beach Road

Submission on a requirement for a designation or an alteration to a designation subject to full or limited notification - Sections 168A, 169, 181, 189A, 190 and 195A of the Resource Management Act 1991
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APPLICANTS DETAILS
This is a submission on a notice of requirement:

By: Watercare Services Limited For: Southwest Wastewater Treatment Plant

Address of Application: 372 Glenbrook Beach Road, RD 1, Waiuku, Auckland - Lot 1 DP 367461

Application Details: Watercare Notice of Requirement to designate 56 hectares of land at 372 Glenbrook Beach Road, RD 1, Waiuku from horticulture to allow for the construction and operation of a wastewater treatment pant to service a population of 60,000 people for the next 35 years.
I/we OPPOSE the Notice of Requirement*

Yes - I OPPOSE the Notice of Requirement in its entirety
Do you wish to be heard in support of your submission?*

Yes - I wish to be heard in support of my submissionNo - I do not wish to heard in support of my submission
The specific parts of the above notice of requirement that my submission relates to are:

Notice of Requirement lodged by Watercare Services Limited to designate land at 372 Glenbrook Beach Road, RD 1, Waiuku, Auckland (Lot 1, DP 367461)
The specific parts of the above notice of requirement that my submission relates to are:*

Assessment of Environmental EffectsIndicative Design ReportAssessment of Alternatives Report and AddendumAssessment of Alternatives Report AppendicesStakeholder Engagement Report and Appendices 06.10.23Mitigation Planting StrategyGraphic SupplementLandscape and Visual ReportEcology AssessmentArchaeological AssessmentAir Quality AssessmentStormwater & Flooding ReportAcoustic AssessmentTransport AssessmentI reserve the right to add further information regarding, or relating to any of the items listed at the hearing, or beforehand,as per the RMA process.Other
The reason(s) for my views are:*

Watercare's notice of requirement hearings process as required by Auckland Council shall not commence until the Hydrodynamic Model for the entire Manukau Harbour is 100% operational and accessible by the community, expert witnesses and water quality scientists. This was promised in 2016, by then CEO of Watercare, Raveen Jaduram and the General Manager of Auckland Counci's Healthy Waters Division, Craig McIlroy.The late Dame Nganeko Minhinnick of Ngati Te Ata, the Iwi responsible for this part of the Manukau Harbour, was adamant that any further discharges from land based sources (e.g. treated/untreated wastewater) were to be discharged into the Tasman Sea and not the Manukau Harbour. Watercare as a good corporate citizen must abandon its consent to discharge into the Waiuku River adjacent to the 12th hole off the Clarks Beach Golf Course and above a scallop bed.Watercare's Assessment of Environmental Effects has not adequately determined the scale and significance of the effects on the environment.Watercare's proposed wastewater treatment plant at 372 Glenbrook Beach Road is to be relocated back to the existing Waiuku Waste Treatment Plant next to the Steel Mill. This location was Watercare's original best practicable option from 2016 to 2021. The Waiuku site is a 17 hectare site currently designated as a waste treatment facility. It adjoins the NZ Steel Mill site that has significant unused open green space and is already zoned as industrial. Watercare should not be granted a change in designation by Auckland Council for the land at Glenbrook Beach Road when their existing 17 hectare Waiuku site does not require a change in designation.By relocating the proposed Glenbrook waste treatment plant back to the existing Waiuku site, this provides greater flexibility for future opportunities for treated water reuse at the Steel Mill. The treated wastewater could be used by NZ Steel to supplement their daily take of water from the Waikato River and reduce its annual water take requirements from the river.By relocating adjacent to the Steel Mill, the Waiuku Waste Treatment Plant could become an electricity energy hub supplied by local solar farms or wind turbines on the Awhitu Peninsula and the proposed offshore windfarm located in the Tasman Sea off the Awhitu coastline.Watercare advised the community in 2016 that the Waiuku site was the best location for their new plant and it continues to the best site, for both economic and environmental reasons. Watercare's assessment of alternative sites which determined Glenbrook as the preferred location is flawed.The 56 hectare site at 372 Glenbrook Beach Road is currently defined as Land Use Capability 2 (LUC-2 Prime 2 Soil) by Auckland Council and it is used for food production purposes. Throughout the region there is a limited supply of Prime 2 soil. Watercare are seeking to change the existing designation of mixed rural and rural coastal to a waste treatment plant.. If this designation is granted, then the community will not be permitted to have any other opportunity for consultation for any future development of the site.Watercare are proposing to trench 22km of local roads for their wastewater pipes connecting Kingseat, Clarks Beach, Waiau Pa, Glenbrook and Waiuku over a 2 year period. These ongoing roadworks will be very disruptive to the communities with 'stop/go' operations over the 2 year period. These communities rely on one road in/one road out and the disruption of the roading corrider will be significant and a Health & Safety risk for motorists, cyclists, pedestrians, school children, emergency services, deliveries, rubbish collection and more.Watercare's ecological assessment has not taken steps to recognise and address a previously destroyed wetland on the Glenbrook site. If the project goes ahead, Watercare should be required to restore the artificial ponds to their 2011 state.Watercare have not allowed an adequate odour buffer for the properties surrounding the Glenbrook site. Watercare have proposed an odour buffer however this will not mitigate odours from the site. The proposed location at Glenbrook is unsuitable as I believe the effects will be more than minor on the large number of properties and population surrounding the site.Watercare state that during construction, there will be excessive noise from fans, trucks and machinery. There is also believed to be substantial noise from fans that will be operating continuously from the site once operational. This is unacceptable for those who live in close proximity to the site.There will be no planting along a significant distance of the roadside at 372 Glenbrook Beach Road. Watercare claim this is for sightlines for traffic leaving their site while also stating that the traffic from their site will be minimal once it is operating. I believe plantings or a bund in this area is essential to immediately block the plant from view and that Watercare drivers should exercise the same reasonable caution that locals do when leaving their properties.There is also a conveyancing consent associated to this project for the pipeline. These two projects will overlap and a unified traffic assessment is required to determine the combined effect. The project must not proceed until the community is able to give feedback on these combined traffic effects.I request public notification of the conveyancing consent. The current documents lodged by Watercare to Auckland Council do not provide adequate mitigation of effects including, but not limited to traffic mitigation, overall design and health and safety effects.I would support the use of the existing road corridor for the conveyancing pipeline if notified through the RMA consultation process and would like all services/utilities and infrastructure required to go in the road corridor be implemented in an integrated plan.Watercare have stated that their plant only requires approximately 6 hectares of land however their notice of requirement relates to the entire 56 hectares of land at 372 Glenbrook Beach Road. If this is granted, then the community will never have another opportunity to be consulted on any further development of the site. I request that if the notice of requirement is granted, that it is restricted to just the 6 hectares of land that Watercare state their plant requires.Watercare needs to avoid excavating the local roads and use their legal position that allows them to thrust or directional drill the pipes or lay them in the Harbour. If the Harbour route was adopted for their pipe(s), it would provide an opportunity to stabilise badly eroding sandstone cliff faces adjoining the Waiuku River, especially Auckland Council's Esplanade Reserves that border the Harbour. This could also provide a pedestrian and cycle pathway connecting Kahawai Point in Glenbrook Beach to Waiuku township. There are vast amounts of marine sediments from these eroding sandstone cliff faces that could be used to produce Mudcrete which has been successfully used by Auckland Council to better manage similar engineering problems.Other
I/we seek the following recommendation(s) from Auckland Council:*

That Watercare withdraw the Notice of Requirement application.The Notice of Requirement and the associated works and activities are modified or amended (including conditions) to give effect to the concerns outlined in my submission.Other
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I accept and agree that by taking part in this public submission process that my submission (including personal details, names and addresses) will be made public. By completing this form, I accept and agree that this form will be submitted on my behalf to Auckland Council and Watercare. I also agree that if required by Auckland Council, the above information can be used to populate a Form 21 on my behalf to ensure my submission is valid.
Note: Making a submission on a Notice of Requirement: Any person or organisation may make a submission on the notice of requirement, but a person who is a trade competitor of the requiring authority may do so only if that person is directly affected by an effect of the activity to which the requirement relates that (a) adversely affects the environment and (b) does not relate to trade competition or the effects of trade competition.*

I/we are not a trade competitor of the applicantI/we are a trade competitor of the applicantI/we are directly affected by an effect of the proposed activity that adversely affects the environment, and that effect does not relate to trade competition or the effects of trade competition
I also wish for myself and my views to be represented as an unpaid member of the Stop Polluting the Manukau Harbour Society Incorporated. If yes, we will contact you separately to formalise this.*

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Notice of Requirement Submission Watercare Southwest Wastewater Treatment Plant at 372 Glenbrook Beach Road

SUBMITTER DETAILS

APPLICANTS DETAILS

The specific parts of the above notice of requirement that my submission relates to are: