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Table 5: List of submissions

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Submission no.

Submitter

Position / heard

Reason

Relief sought

24

Birdsall, Mr Anthony and Koster, Mrs Linda

Not stated

Risk of groundwater contamination.

Devaluation of property.

Local groundwater bores monitored with Contact to supply water if contaminated.

Wish to be heard

Visual impact and noise.

Station relocated to eastern boundary.

H2S increase.

Structures screened – banks/tree planting.

9

Department of Conservation

Neutral

Supports resulting decrease in discharge to the Waikato River (and increased deep reinjection) by decommissioning Wairakei.

None.

Do not wish to be heard

Supports use of more advanced technology than Wairakei.

 

8

Dutton Price, Miss Lynley; Dutton Price, Miss Alison

Oppose

Devaluation of property.

Visual impact.

Compensation for loss of lifestyle and devaluation of property.

Do not wish to be heard

Noise and smell.

Pollution of water supply.

13

Ellery, Mr Grant and Mrs Francis

Oppose

Devaluation of property (so a private company can make profits for shareholders).

Compensation for disruption and loss of property value.

Inadequate consultation – work started before consultation.

Shelterbelt for visual and noise screening.

Wish to be heard

Disruptions of rural lifestyle – construction noise, dust, too close.

Likely contamination of water bore by reinjection.

Provision of alternative water supply if current supply contaminated.

12

Energy Efficiency and Conservation Authority

Support

New Zealand demand for energy will increase.

Generation capacity needed.

Proposal consistent with sustainable energy policies and strategies.

Approve applications.

Wish to be heard

Result in nationally significant benefits due to contribution to 90% renewable energy target, security of supply and positive effect on climate change.

 

4

Environment Waikato

Neutral (EW applications)

To promote consistency with councils geothermal policies and existing consents.

Consents to be consistent with council geothermal policy.

Wish to be heard

Conditions to be enforceable and compatible with existing consents.

7

Fish & Game NZ, Eastern Region

Support

Alternatives to hydro generation should be promoted.

Not identified.

Do not wish to be heard

No fisheries or game bird resources or their habitat will be adversely affected.

19

Geotherm Group Ltd

Mixed

Opposes any aspect of the project that adversely impacts on Geotherm Project.

Specific reinjection locations not defined.  Modelling not cover all reasonably feasible reinjection scenarios.

Reinjection should be limited to those locations modelled. Condition to ensure reinjection does not adversely affect Geotherm Consent.

Contact has not allowed for different development options under Geotherm consents.

Condition to protect range of development options available to Geotherm.

Wish to be heard

Need to calibrate model against actual emissions.  Modelling of H2S emissions needs to take additional factors into account.

Ambient monitoring.  Condition to ensure combined effects with consented Geotherm discharge does not adversely affect air quality or Geotherm consent.

Cumulative noise effects with exercise of Geotherm consents not assessed.

Conditions to ensure cumulative noise levels from Te Mihi and existing consented activities do not exceed District Plan levels and impact on Geotherm’s ability to meet its consent noise limits.

Significant geothermal features in area

(eg, Craters of the Moon).

Conditions to assist in determination of any impacts on these areas, such as a monitoring programme, established in consultation with other users.

Constraints on national grid and ability for Geotherm to export from the site.

Conditions to ensure project does not adversely affect Geotherm’s ability to export electricity (inefficient use under s7(b) RMA).  Discounting of benefits of Contact and/or Geotherm project if it does.

5

Hansen, Mr Graham and Mrs Isobel

Oppose

Construction and operation noise effects will disrupt rural quiet.

Compensation for disruption and loss of property value.

Do not wish to be heard

Reduction in property value.

Work already commenced before consents being granted.

18

Houghton, Mr Ray

Opposes

Discharge of steam will detract from rural landscape.  Cumulative adverse effect with the existing discharge.

Adverse traffic effects and safety concerns.

Decline the full proposal.

Wish to be heard

Cumulative odour effects on neighbours.

Reverse sensitivity – further development potential impacted by need for Contact’s written consent as affected party and restricted covenants.

Mitigate traffic effects of 200 employees using intersection.  Taupo District Council and Transit solution.  Change to intersection layout.

1

Macphal, Ms Sarah; Campbell, Mr Ian

Oppose

Impact on environment.

None stated.

Do not wish to be heard

Loss of value of property.

 

21

Major Electricity Users' Group

Neutral

Call-in was unwarranted.  Reliance on New Zealand's obligations under the Kyoto Protocol obligations is not sufficiently material to call it in and is a minor effect to be considered by the Environment Court.

Board of Inquiry should give little weight to the Minister’s reasons for the call-in when balancing effects.

Do not wish to be heard

The 90% renewable target is a “political vision” (not a national policy statement in terms of the RMA) and only one of a number of possible future scenarios.  Relying on ad hoc political targets as criteria for call-in or putting weight on these reasons will allow key developments to be dictated by Ministerial whim.  Board of Inquiry should test robustness of effects across other scenarios than 90% renewable target.

While this is a large geothermal project other large geothermal projects have been consented recently without call-in.

10

McGrath JJ and JM and Family

Oppose Environment Waikato applications

Object to discharges to land and groundwater.

Air discharges will cause unacceptable pollution.

Re-injection should be to well or bores into the subterranean formations of same system as geothermal waters taken from.

Wish to be heard

Should confine operation to areas identified in applications.

Definition of geothermal system by Judge Whiting.

Not stated.

15

McLachlan, Mr Alistair; McLachlan, Ms Ava Marie; MacPower Ltd

Oppose in part

Wish to protect Geotherm Group consents and to ensure there are no adverse cumulative effects with other existing and consented uses.

Conditions to meet concerns:

Air quality – current discharges of gas from Poihipi power station exceed current consent limits.

Air – ensure that cumulative adverse effects have appropriate limits.

Reinjection – potential constraint on Geotherm power station reinjection.

Reinjection – contact presently discharges contaminants without landowners’ authorisations.

Reinjection – control reinjection so as not to constrain Geotherm consents or other existing consents on the same system and require that no generation activities occur until Contact has all necessary authorisations from landowners for reinjection of power station fluids.

Noise – cumulative with effects of other activities both occurring and consented.

Noise – controls on cumulative effects.

Transmission – query adequacy of transmission capacity to meet project and Geotherm and other existing and consented generators.

Transmission – require Contact to prove that adequate transmission exists for project, Geotherm and other consents.

Where consent has potential to inhibit or adversely affect existing consents.  Cumulative effects with existing users.

Require consent to ensure it does not adversely affect the exercising of Geotherm’s consents and is consistent with controls on other consented activities.  Appropriate controls on cumulative effects generally.

 

 

Wish to be heard

Project involves extension of land areas associated with Poihipi power station and activities.

Extension of land areas – ensure such expansion is warranted and consistent with existing Court decisions re that station.  Specify uses to which particular land areas may be put consistent with past decision and the demonstrated needs for any expansion.

Contact has recently drilled a new well within a short distance of the Geotherm boundary, contrary to undertakings given by Contact to Reconsenting Hearing 2001.

Board of Inquiry should check use to be made of new well (on Geotherm boundary) and which power station it is associated with and conditions should address proximity of any new well to Geotherm boundary.

6

Ministry of Economic Development

Support

National benefits of a viable and renewable resource by making use of viable and renewable energy source, security of supply and avoiding greenhouse gas emissions.

Approve the application for land-use consent.

May wish to be heard in clarification

Board of Inquiry should take into account the contribution Te Mihi will make to achieve the Government’s energy objectives.

22

Tauhara North 3B Trust

Mixed

Rights of Nga hapu o Ngati Tuwharetoa.  Key feature of the Treaty of Waitangi claims concerned dispossession and loss of rangatiratanga over the geothermal resource, degradation of geothermal taonga and exclusion from use and development of the resource.

Consultation and communication and regular update on reinjection plans and monitoring adjacent to the interests of the Trust.

Wish to be heard

Waitangi Tribunals report He Maunga Rongo: Report on Central North Island Claims has important findings.

Concerned about the discharge of contaminants and waste water onto land and into the aquifers linked to Taupo nui a Tia and effects on surface features.

17

Taupo District Council

Neutral

Part 1 – Taupo District Council consents

Board has regard to environmental effects on local and wider environment, including traffic, earthworks, visual, noise, hazardous substances, natural hazards, cultural and cumulative effects.

Ensure that assessment of the application considers the objectives and policies of the District Plan.  With appropriate conditions of consent the adverse effects of the proposal can be appropriately mitigated.

Subject to appropriate conditions, consents should be granted.  If appropriate conditions are not imposed, land-use consents applications under the Taupo District Plan should be declined.

Traffic effects.

Control traffic / Traffic Management Plan.

Earthworks and construction effects.

Earthworks Management Plan.

Visual and landscape effects.

Landscape Management Plan.

Noise effects.

Consideration of noise effects.  Mitigation measures implemented.

Hazardous substance storage and use – minor with appropriate management.

Hazardous Substances and Emergency Management Plan, Council approval prior to works.

Natural hazards.

Development within geothermal area to be assessed.

Existing infrastructure.

Effects should include decommissioning Wairakei plant.

Cultural effects.

Protocol for discovery of historical sites during construction.

Cumulative effects.

Can be mitigated.

 

 

Wish to be heard

Part 2 – Environment Waikato consents

Primary concern is effect on Taupo town being located above a geothermal system and possible subsidence.

 

Infield injection is required to stop current and prevent future subsidence.

The 6,500 tpd of cooling water blowdown and condensate onto land should instead be reinjected.

Contact has not modelled effects of increased reinjection on subsidence (identified in AEE) and this should have been included in AEE – refer Court decisions.

 

Contact plans to continue discharges to the Waikato River which is inappropriate in the modern plant being proposed.

 

14

Te Kapa o Te Rangiita ki Oruanui

Neither supports nor opposes (neutral)

Clarify issues in consent applications that were not resolved in pre-consultation process.  Issues are:

 

Clarification of Land Trusts within the consented area.

Clarify Land Trusts within consent application area.

Consider staged reinjection for particular surface features and potential for enhancement of taonga/surface features.

Consider taonga or surface features in Spa area and Onekeneke valley which may benefit from staged reinjection.

Exclusion zones for reinjection – possible enhancement of taonga/surface features.

Clarification of exclusion zones for reinjection, exclude Wairakei Valley?

Discharges to land and integrity of groundwater.

Clarify chemical constituents of discharge water.

Sewage discharge in areas/site of significance in cultural impacts assessment.

Identification of septic tank locations in cultural impact assessment.

Wish to be heard

Air modelling in areas/sites of significance.

Drawing showing discharge modelling on cultural impact assessment map.

Cultural impacts assessment should include air discharge from Poihipi Road station.

Cultural impact assessment  report for air discharge from Poihipi Road station.

Geothermal steamfield.

Identification of historical sites in relation to steam field.

Te Rau o te huia stream / traditional fishery.

Clarify – monitoring, take and use from stream.

Lack of consultation prior to lodging s127 variation.

Request pre-hearing meeting to discuss issues.  Place the application on hold until the applicant can provide an opportunity to discuss the issues raised by Te Kapa o Te Rangiita ki Oruanui.

Geothermal resource is taonga and have customary interests, including a right to develop.  Decisions made now on future allocation may affect their relationship with taonga.

 

23

Toyota, Anna and Karz

Support TDC consents and 116791 / oppose EW (except 116791)

Do not wish to be heard

No information provided.

None stated.

11

Transit New Zealand, Hamilton Regional Office

Oppose

Construction traffic will utilise the Poihipi Rd/SH1 intersection which has known safety and capacity issues.  The transportation assessment prepared by Traffic Design Group does not offer appropriate conditions to avoid, remedy or mitigate the traffic effects at the Poihipi Road/SH1 intersection.

Application is declined.

Wish to be heard

Alternatively, require the upgrade of the intersection of Poihipi Road and SH1 in accordance with Stage 1a of the Western Kinloch Arterial Designation to the satisfaction of TDC (in consultation with Transit).  Or ensure no construction traffic uses this intersection.

16

Tuwharetoa Maori Trust Board

Neither supports nor opposes (neutral)

Opportunity for Te Kapa o Te Rangiita ki Oruanui to clarify their issues not resolved in pre-consultation process.

 

Clarification of Land Trusts within the consented area.

Clarify Land Trusts within consent application area.

Consider staged reinjection for particular surface features and potential for enhancement of taonga/surface features.

Consider taonga or surface features in Spa area and Onekeneke valley which may benefit from staged reinjection.

Exclusion zones for reinjection – possible enhancement of taonga/surface features.

Clarification of exclusion zones for reinjection, exclude Wairakei Valley?

Discharges to land and integrity of groundwater.

Clarify chemical constituents of discharge water.

Sewage discharge in areas/site of significance in cultural impacts assessment.

Identification of septic tank locations in cultural impact assessment.

Wish to be heard

Air modelling in areas/sites of significance.

Drawing showing discharge modelling on cultural impact assessment map.

Cultural impacts assessment should include air discharge from Poihipi Road station.

Cultural impact assessment report for air discharge from Poihipi Road station.

Geothermal steamfield.

Identification of historical sites in relation to steam field.

Te Rau o te huia stream / traditional fishery.

Clarify – monitoring, take and use from stream.

Lack of consultation prior to lodging s127 variation.

Geothermal resource is taonga and have customary interests, including a right to develop.  Decisions made now on future allocation may affect their relationship with taonga.

Request pre-hearing meeting to discuss issues.  Place the application on hold until the applicant can provide an opportunity to discuss the issues raised by Te Kapa o Te Rangiita ki Oruanui.

2

Vanner, Mr Brett and Mrs Heather

Neutral (TDC applications)

Construction of structures and potential for visible structures (such as pipes) to devalue property.

Give careful consideration to construction of visible structures.

Do not wish to be heard

Place pipes underground if possible.

20

Waikato Raupatu Trustee Company Ltd (Tainui)

Not stated

The Waikato River is te tupuna awa, the ancestral river of the Waikato-Tainui.

Ensure the consents if granted and other associated and varied consents are consistent with the Waikato River Settlement and realigned with its outcomes and objectives.

Concerns with discharges of geothermal fluids into the river.

Include a clause as follows: “Within 12 months of the Crown settling any claim made under the provisions of the Treaty of Waitangi Act (1975) WRC may, following service of notice on the consent holder, commence a review of the conditions of this consent pursuant to section 128(1)(a) of the RMA, for the purpose of ensuring that this consent is in alignment with the provisions of any such settled claim.”

Irrigation of condensate to pasture may lead to additional nitrogen run-off to the river causing algal blooms.  Algal blooms directly impact relationship of Waikato-Tainui with the River.

Wish to be heard

Agreement in principle reflects a commitment by Crown and Waikato-Tainui to enter new era of co-management of the River.

Conditions to cover staged reduction in operation of Wairakei.

Reinjection of steam condensate from both Wairakei and Te Mihi to the Wairakei-Tauhara field.

3

Wind Farm Developments (Australia) Ltd

Neutral

Wish to be heard

WFD is a third owner of the Hawke's Bay Wind Farm Ltd wind farm, approved for 75 turbines on the Maungaharuru Range.  It is not clear that any adverse effects on the Hawke's Bay project are satisfactorily avoided, remedied or mitigated.  Te Mihi’s contribution to national benefits will be reduced or not applicable if the development results in any constraining of output from the Hawke's Bay Wind Farm project.

Should the Board of Inquiry approve the proposal WFD requires a consent condition that “the project shall not result in the loss of generation from any existing or approved renewable generation projects as at the 7/03/08”.