Cultural - CIA (Cultural Impact Assessment)

Tangata whenua

Comments:

We recommend revising the CIA to incorporate this critical information before any final decisions are made or consent is granted. There is key information that was not provided by the Applicant for proper consultation

Cultural Impact Assessment (CIA) – comments

Contents:

1) Cultural Landscape Area – Alert Karapiro Stream.. 1

2) Waipā District Plan Rule Assessment. 4

3) Pekapeka-tou-roa (long-tailed bats). 5

4) River Stream Corridor / Catchment Area. 6

5) Horotiu Pā Site. 9

6) Archaeological Findings. 12

7) Flora/Fauna. 14

8) Water Take – Application to take water and process. 14

9) Good clear photos of the site in question. 15

10) Public Backlash. 15

11) Conclusion. 15

1) Cultural Landscape Area – Alert Karapiro Stream

We would like to identify that a portion of the proposed mine/quarry site falls well within the designated "Cultural Landscape Area – Alert Karapiro Stream." This policy establishes a 50-meter exclusion zone on both sides of the Karapiro Stream to protect the cultural significance of the area.

This crucial information should have been provided by the Applicant, as it is noted on their land title, and should have been incorporated into the CIA. We expect the Applicant did not provide a copy of Certificate of Title for this property, or provide this important information for inclusion into the CIA as its not part of the Appendix of the CIA.

The Applicant is not only planning to extract resources from within this protected area but is also permanently altering and damaging a landscape that cannot be restored once removed and sold.

This critical policy point was not adequately addressed in the current Cultural Impact Assessment (CIA). Notably, the Waipa District Council’s decision for Public Notification explicitly identified the “Cultural Landscape Area Alert" as a key policy relevant to this area, highlighted on the front page.

We have included maps extracted from the Waipa District Council website below as supporting documentation.

Rather than adhering to the required 50-meter setback from the Karapiro Stream, the Applicant is proposing a mere 10-15 meters, as outlined in point 2. This doesn’t just breach the 50-meter requirement—it significantly undermines the Policy.

Source: Waipa District Council

Intended mine site – note permanent removal of large historic River Banks and inside the Cultural Landscape Area.

FYI, the 50m-wide Cultural Landscape protection zone extends approximately to the top of the riverbanks. However, this was not clearly marked or identified in the CIA we believe the Applicant did not disclose this information for the CIA. If the Applicant leaves these historic cultural riverbanks intact, they would fall outside the 50m protection zone and be positioned away from the streams and waterways. This again, was not presented as an option in the CIA as not provided/disclosed by the Applicant.

The images also provided by the Applicant into the CIA do not clearly illustrate the site, they are unclear.

Any plans to permanently damage/remove part of the cultural landscape would require extensive environmental and cultural issues to be clearly identified in the current CIA. Gaining consent for such an activity would likely be difficult/impossible given the area's protections under the current Policy, environmental and public backlash. In many other countries, this would not be permitted.

2) Waipā District Plan Rule Assessment

In addition, the intended site has triggered six areas where the Application fails to meet the Waipa District Plan. We have highlighted two key points related to waterways below as provided by the Waipa District Council, which we believe should be clearly identified in any CIA.

Once again in defence of the CIA and author, we believe this type of critical information should have been provided by the Applicant for inclusion in the CIA, as both the Applicant and their paid consultants were fully aware of these important points.

It is also worth noting that the Application proposes activity only 10-15 meters from a waterway, specifically the Karapiro Stream, which raises serious environmental concerns. Once again, we don’t believe this was clearly explained (if at all) by the Applicant during consultation.

Source: Waipa District Council – Notification Report, dated 4th September 2024.

3) Pekapeka-tou-roa (long-tailed bats)

Current Status: Nationally Critical – most severely threatened, facing an immediate high risk of extinction.

The CIA does not explicitly confirm the presence of long-tailed bats at the specific quarry site. However, we believe the Applicant has not fully disclosed their presence during consultation, despite being aware of it.

We believe the CIA should clearly identify the presence of Pekapeka-tou-roa (long-tailed bats) at this specific site, as they are critically endangered. These bats hold significant cultural importance to Māori, who associate them with the mythical night-flying bird, hokioi, a symbol of death or disaster.

It should be noted that long-tailed bats use the Karapiro Gully as a flight path and depend on riverbanks, gullies, and streams as navigational corridors. The removal of large sections of riverbanks/gullies, along with operating within 10-15 meters of the stream, would significantly and negatively impact their habitat and movement.

One of the key reasons this consent is being publicly notified is the presence of long-tailed bats in the area, including at this site. However, the CIA does not mention their presence at the specific site, only in a general sense. Forest & Bird NZ has become involved and is formally objecting to the application.

4) River Stream Corridor / Catchment Area

Title: River Stream Corridors

Key: red is the proposed site, blue are the river corridors/catchments with dark blue the Waikato River, i.e. the site feeds into the Waikato River.

Source: Waipa District Council District Plan

Over 75% of the proposed quarry/mine site falls within the “River Stream Corridor” that feeds into the Waikato River (dark blue represents the Waikato River), in addition they are mining within 10-15m of the Karapiro Stream and wetlands once they remove the Cultural Landscape River Banks.

Additionally, the Waikato Regional Council (WRC) identifies this property as part of the “key priority area” within the Karapiro and Mangaonua Stream Catchments. The fact that the proposed quarry/mine is located inside a key priority catchment area was not clearly highlighted in the CIA. However, we don’t believe the Applicant fully disclosed this.

This area also falls under the Waikato River Authority (WRA), in which iwi play a significant role. The proposal somewhat contradicts the vision of the WRA, which states:

“Our Vision is for a future where a healthy Waikato River sustains abundant life and prosperous communities who, in turn, are all responsible for restoring and protecting the health and wellbeing of the Waikato River, and all it embraces, for generations to come” (source: https://waikatoriver.org.nz/visionandstrategy/)

Title: Map of the WRA Rivers

Source: https://waikatoriver.org.nz/catchment/

Therefore, Waipa District Council, Waikato Regional Council and the Waikato River Authority clearly identify but the CIA specifically does not for this particular site.

In addition, this river / section floods a number of times per year, the river banks play a critical role in filtering runoff and maintaining water quality. Removal of vegetation or land from the riverbank could negatively impact the water quality of Karapiro Stream and, by extension, the Waikato River. Once again, we know the Applicant was sitting on key information.

5) Horotiu Pā Site

The provided information in the CIA about the location of the Horotiu Pā site is inconsistent. In the CIA it shows a distance of 1.5 to 2 km from the proposed site, whereas the actual officially marked site is less than 1 km away, with a clear direct view of the proposed site.

The official marked site has been jointly endorsed and sign posted by Ngāti Korokī Kahukura, Ngāti Hauā Iwi Trust, Waipa District Council (WDC), Waikato Regional Council (WRC) and New Zealand Transport Agency (NZTA).

However, none of this detail about this officially marked site is included in the current CIA. We know the Applicant and Waipa District Council (WDC) know about this site. Afterall the WDC maintain this site which is on DOC administered land. It’s a very interesting and good site, lots of relevant information and details the importance of the area.

Title: Horotiu Pā Site – officially marked site

At the Horotiu Pa site it refers to Te Ara Noa (the clear pathway). However, since the Applicant intends to permanently remove and sell the River Banks/ Te Ara Noa. This again is not clearly identified in the CIA, i.e. removing the Te Ara Noa at this particular site as would fall into a giant 35m+ hole.

6) Archaeological Findings

Another significant issue arises from the current Cultural Impact Assessment (CIA), which fails to acknowledge the presence of important artifacts on the subject property. During the construction of the Cambridge expressway/bypass 10 years ago, an extensive investigation confirmed archaeological findings on this site. This investigation is detailed in the government-funded report titled “Waikato Expressway, Tamahere–Cambridge Sections: Archaeological Monitoring and Investigations, 2013 and 2014 (HPA authority 2013/855).” The report clearly confirms the presence of artifacts on the property. However, the CIA surprisingly reports no archaeological findings on this site. The Applicant knows about these reports but again guessing did not provide them for inclusion and consultation.

Additionally, another cultural report (222 pages) in 2009, titled “Cultural Effects Report Cambridge Bypass,” prepared by Te Ohu Ara Awhio o Kemureti for Nga Iwi Toopu o Waipa, further contradicts the information within the CIA. This report also confirms the location of Horotiu Pā and the presence of archaeological artifacts, which the current CIA overlooks.

Some of the names in this detailed report/study include Wiremu Clarke, Rangitionga Kaukau, Ringi Gillett, Rose Tuineau, Karaitiana Tamatea, Gaylene Roberts, Karaitiana Tamatea, Rangitionga Kaukau, Pateriki Rangi, Rahui Papa and Te Ao Katoa Te Amopiu.

Both of these comprehensive, government-funded reports identify the cultural significance importance and existence of artifacts on the subject property. Yet, the current CIA claims there is no archaeological significance here, while acknowledging artifacts on surrounding properties.

We are not sure why such a big difference but know the Applicant knows about these other reports and suspect once again the Applicant did not provide these as part of the consultation.

Furthermore, in one of these reports it states “This area was rich in bird life; wetlands held water fowl and eels; fertile soils for growing kumara; and kahikatea forests, tawhara, ti kouka and berries abounded. Te Kaapo Clark26, states that c1500, Ngati Kahupungapunga had many settlements along the Waikato River”.

We also suspect the Applicant failed to disclose the soils at this site are LUC 1 or 2, high class protected soils which is consistent to the history which mentioned they are fertile soils.

This inconsistency directly contradicts both the signage at Horotiu Pā and the findings of these official reports. It’s important to note that these were government-funded, thorough investigations.

However, we did note this sentence in the report in the Appendix of the CIA from Sian Keith (Principal Archaeologist) which raises questions and supports the other Government funded reports “The scale of the project is extensive, and a significant section of the gully margin will be impacted. There is potential for archaeological evidence to be located in this area of the proposal, evidenced by the general attractiveness of the location and the potential pit features identified in the test pit, additionally the proximity of extensive gardens and recorded paa in the wider landscape”.

Title: Archaeological Reports (front pages) for easy reference.

7) Flora/Fauna

The CIA fails to clearly mention the presence of both shortfin and longfin eels (tuna) at this particular site.

We believe at least the longfin eel should be mentioned in the CIA at the site. Longfin eels are considered At Risk – Declining under the New Zealand Threat Classification System. They are native to New Zealand and have significant cultural importance to Māori as a taonga species.

Once again, we don’t believe the Applicant fully disclosed they are present.

8) Water Take – Application to take water and process

The Applicant has already installed 11 large commercial bores, designed to extract up to 1.2 million litres of water per day. The current application only seeks approval for water extraction from these already installed bores. However, the Resource Consent for this significant commercial installation was not publicly notified or consulted upon—it was carried out quietly and dated 24th Nov 2021 under Resource Consent number APP143939. This Resource Consent was non-notified, had no mention about any cultural values/investigation or requirements for observations, they just drilled away with their very large drilling equipment and the overflow when testing just flowed straight into the Karapiro Stream/waterways.

The CIA also does not mention that the Applicant had already installed these commercial bores / resource consents. In defence of the CIA and its author, we believe this omission occurred because the Applicant did not disclose this information during consultation.

Additionally, the Applicant purchased and delivered key mining equipment to the site (refer below image) before initiating in any Cultural Impact Assessment (CIA) or engaging in any meaningful consultation with iwi or other stakeholders.

This is fundamentally a matter of principle, as the Applicant should have adhered to and respected the correct process. While this may not be a significant issue for everyone, the Applicant’s actions were not identified in the CIA, likely because this information was also not disclosed along with majority of the other points raised.

9) Good clear photos of the site in question

This lacked in the CIA to clearly identify the site, the policies and the environmental and cultural impacts.

Once again though, these images were not provided by the Applicant as part of the consultation.

The images in the CIA should show clear before and after photos. We are happy to assist in this area.

10) NPS-HPL (High Class Soils)

The propsed site is located on high class soils that are protected under the National Policy Statement for High Productive Land (NPS-HPL), soil class for this site is LUC 2.

Under 3.3, Tangata whenua involvement is required, but we find no mention of the NPS-HPL in the CIA or any other document.

11) Conclusion

In defense of the current CIA, the author(s) and the people that signed off on this CIA we believe the Applicant failed to fully provide and disclose key information that should have been included for proper consultation and a comprehensive CIA. Refer the "Silica", "Traffic" and ""Resources" sections of this website for other examples of this.

This critical information should form part of the decision process.

The site is located within a Cultural Landscape Alert Area that is part of Policy and fails to meet two further areas in the District Plan relating to waterways. These are not specifically mentioned in the CIA, likely due to incomplete disclosure by the Applicant. Additionally, the site is situated on high class soils and within a water catchment area for the Waikato River and is only 10-15 meters from a waterway that feeds into it.

Moreover, the presence of Pekapeka-tou-roa (long-tailed bats), classified as ‘Nationally Critical,’ and longfin eels (tuna), considered ‘At Risk – Declining’ and of significant cultural importance to Māori as a taonga species, further heightens the sensitivity of this application.

While the CIA does broadly reference some of these matters in relation to the region, it does not specifically confirm their presence at this particular site, which could significantly impact the decision-making process.

We recommend full disclosure by the Applicant, further investigations, and a revision of the CIA to include the above information before any final decisions are made.

Its only through our investigations we have discovered some of this information, we are not ruling out the Applicant has more critical information they have not disclosed.