brooklands lagoon area draft parks...

Brooklands Lagoon Area Parks Plans Submissions Analysis 15 September 2009

BROOKLANDS LAGOON AREA DRAFT PARKS PLANS – SUBMISSIONS REPORT FOR HEARINGS PANEL SUBMITTERS

ID Ref Submission Received from Organisation Name Organisation Role BL001 Lyall Woodham BL002 Mike Bell BL003 Evana Elvy BL004 G Moreton BL005 Neil Shaskey BL006 Rosemary Fisher BL007 Rob Haines BL008 Edward Colombus BL009 Dennis Hills Guardians of the Styx (Incorporated) BL010 David Hart BL011 Sandra Milne BL012 Brooklands Community Centre Inc Residents Association BL013 Annette Buxton BL014 Diane Kimber BL015 Braden Leonard Community & Public Health Medical Officer of Health BL016 David Dawson BL017 Robin Delamore Spokes Cycling Improvements Convenor BL018 Axel Wilke BL019 Paul Tamagushiku BL020 Nathan Hight Surf Life Saving New Zealand BL021 Grant Edwards Spencer Park Surf Life Saving Club Inc Club President BL022 Steve Leiataua BL023 Debbie Riley BL024 Julie Anderson-Hena BL025 Bill van den Ende BL026 Jan Cairney Christchurch Water Sports Club President/Secretary BL027 Lew Graham Community & Public Health Medical Officer of Health BL028 Ken Lawn Environment Canterbury Director Operations BL028 Andrea Lobb Mahaanui Kurataiao Ltd General Manager

NOTES FOR READING THE SUBMISSIONS SUMMARY AND ANALYSIS The Submitter Comments are largely as written by the submitter, but the following do apply:

• Selected parts of the submission directly relevant to the point being made are used, although all efforts have been made to not take any part out of context. • Some spelling and grammatical corrections have been made. • Some additional explanatory/clarifying text has been added, and this is included in brackets (although some text may have also been written in brackets by the submitter). • Where a small amount of the submitter's text has been removed, for simplification, this is shown as " … ".

Where the staff response involves a recommendation/suggestion for a specific and documented change to text in the draft plans, this is highlighted in bold. Italicised text is actual text in the draft plans, including that proposed to be added (underlined) and deleted (struck-through). The district boundaries of Christchurch City (including the former Banks Peninsula District) extend outward from the land to the line of mean low water springs (MLWS). The boundaries were extended from the line of mean high water springs (MHWS) to the line of mean low water springs by two Local Government Boundary Alteration Notices, in 1996 and 1997. The boundaries cross the mouths of all harbours, bays, streams, inlets and estuaries, including Lyttelton and Akaroa Harbours. Environment Canterbury has responsibility for managing activities that occur on the water, specifically those in the navigable inland waters and coastal marine area. Activities on the water are covered by the Environment Canterbury Navigation Safety Bylaws and Environment Canterbury’s Coastal Management Plan.

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Brooklands Lagoon Area Parks Plans Submissions Analysis 15 September 2009 GLOSSARY (source: Māori Dictionary) mana whenua: territorial rights, power from the land - power associated with possession and occupation of tribal land. (Te Kōhure Video Tapes (Ed. 1): 6) tūrangawaewae: domicile, place where one has rights of residence. (Te Kōhure Textbook (Ed. 2): 243) tangata whenua: local people, hosts, indigenous people of the land - people born of the whenua, i.e. of the placenta and of the land where the people's ancestors have lived and where their placenta are buried. tūpuna: ancestors, grandparents. tauparapara: incantation to begin a speech - the actual tauparapara used are a way that tangata whenua are able to identify a visiting group, as each tribe has tauparapara peculiar to them. Tauparapara are a type of karakia (prayer).

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Brooklands Lagoon Area Parks Plans Submissions Analysis 15 September 2009 SUBMISSIONS SUMMARY AND ANALYSIS Row ID Ref Subject Submitter Comments Staff Response Plan Ref Panel Recommendation

1 BL001 Tracks - Walking

My main concern is the ability to have access to walk around the lagoon.

2 BL001 Dogs Our dog is not a hunter at all, but I have noticed other dogs out on the mudflats.

3 BL001 Dogs It would be great to have a separate 'dog run" area in the lagoon so that we are able to walk with our dogs in an area that we know will not effect wildlife and vegetation as such. A separate dog run track from Brooklands through to the Spencer Park area ( a distance of about 3km ) would be a good idea.

The Dog Control Policy 2008 prohibits dogs within, and surrounding (including Seafield Park, Brooklands Spit and the Styx River mouth), the estuary due to wildlife habitat, except for gun dogs during the game bird hunting season in the estuary and on the spit. Dogs, though, are permitted to be on a leash on the walking track.

Master plan: pp.29-30

4 BL002 Compliments Well done to everyone involved. Looks great. Keep up the great work.

5 BL002 Roads Heyders Road needs the lawns fixed or replaced with stones to beautify. Street work, not park.

6 BL003 Tracks - Horse

Please keep all horse tracks, even if more are put in.


I love walking on the tracks - fantastic - must keep these!

8 BL003 Water Fowl Shooting

Please stop all duck shooting in the area. DoC (land administrator), Ecan (consenting structures such as mai-mais) and Fish & Game Council (hunting regulations) jurisdiction over estuary area.

9 BL003 Plantings More tree planting and vege patches would be great! Hard to comment as we don't know what trees they want and where. Vege patches - not in this landscape.

10 BL004 No comments made.

11 BL005 Support Plan(s)

I fully support the plan as proposed.

12 BL005 Land Protection

I encourage the Council to designate as much land as possible bordering the lagoon as reserve land to preserve it in the state that attracted us to the area and prevent further development.

13 BL005 Tracks - Cycling

A priority should be to create a track suitable for cycling to allow access to Spencer Park and Bottle Lake Forest for Brooklands residents with an interest in mountain biking. The current track has large sandy areas which are not suited to cycling so travelling to existing mountain bike tracks is either by car or via Lower Styx Road, which is a narrow road with the accompanying traffic hazards.

Proposed in landscape concept in draft master plan. Master plan: p.103

14 BL006 Park Maintenance

What concerns me is the upkeep.

15 BL007 Compliments Thank you for excellent communication with stakeholders in our community. Keep up the great work.


I fully endorse the draft plans and look forward to them proceeding.

17 BL007 Proposal; Restoration

I have two sections backing on to the Styx River, which combined has a large river frontage - if you wanted to use our section as a demonstration plot to show the public conversion from willows back to natives, then I am willing to contribute and participate. If this is of interest, please feel free to contact me.

The City Botanist will contact the submitter through the Styx Living Laboratory Trust.

18 BL008 Tracks - Walking; Wildlife

Any proposed walkways around the Lagoon must take into account any impact it will have on the Lagoon. Especially at breeding time for the birds and the wildlife.

19 BL008 Proposal; Tracks - Walking

I would like to see a close down period of the walkway around the Lagoon from 1st August to 31st October if possible.

20 BL008 Dogs Have no dogs permitted on walkway. Provided for in the Dog Control Policy 2008, as long as on leash. Master plan: pp.29-30

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Row ID Ref Subject Submitter Comments Staff Response Plan Ref Panel Recommendation

21 BL008 Vehicle Access

We need an emergency accessway so emergency vehicles can easily reach people in need.

In relation to emergency access in the Brooklands Spit area - if an emergency occurred at the spit end to do with a whitebaiter, for example, a helicopter would be used and an ambulance sent to the end of Heyders Road to meet it. The inland beach track can still be used by a four-wheeled drive vehicle, and the police are able to get access to the beach readily.


We need barriers behind the sand dunes area to stop 4wd vehicles breaking down dunes and damaging the environment (think he is referring to Brooklands Spit - Ed.). Also, would like to see several metal structured gates on the lagoon area. Barriers should be metal posts, not wooden posts.

Although there has long been some type of barrier at the end of the spit area, the elements have been having a big effect.

23 BL008 Facilities I would like to see a small jetty platform on the lagoon for people to admire and enjoy the scenery and wildlife.

Viewing areas along the existing walkway in Mid-Seafield Park are proposed in the landscape concept in the draft master plan. Also, is proposed to erect an observation platform/bird hide on a proposed new walkway from Heyders Road along the eastern side of the lower Brooklands Lagoon, which will provide an alternative to the lower section of the Brooklands Lagoon Walkway on the western side of the estuary. Also planned are a 'Sense of Arrival' viewing platform at the mouth of the Styx River and a jetty next to the Brooklands boat ramp.

Master plan: p.103, p.77, p.96

24 BL008 Community Participation

I would like to put my name forward if there was a committee formed for Brooklands Lagoon.

Would support any initiative for an advocacy group raised by the community and facilitated by volunteers, with staff representation on any such group.

25 BL008 Toilet facilities

We need good toilets at the top end of the Waimakariri River mouth for ladies and men, and for these to be managed and cleaned by the Council.

There is currently one temporary/portaloo-type toilet at the northern tip of Brooklands Spit. Probably impractical/too costly to maintain a more permanent toilet, and would also be an environmental impact.

26 BL008 Rubbish Along walkway track you would need to supply rubbish bins that would be emptied and managed by Park Rangers.

The Council‘s policy of Rubbish-Free Park applies here, and has been, and continues to be, successful. Therefore, rubbish bins will not be provided.

Master plan: p.50

27 BL008 Information/ Interpretation

I would like to see headquarters set up for the public and tourists so they can understand the lagoon and the wildlife.

Information will be provided at the Rangers office/information centre at Spencer Park, and information boards are proposed to be installed at entrances to, and at viewing points in, Seafield Park and in the vicinity of the 'Sense of Arrival' at the mouth of the Styx River.

Master plan: p.103, p.96


At the top (eastern) end of Heyders Road I would like to see the beach access kept for fisherman as it is. The change I would like to see is that there is a no parking area for the public by the 4wd access area and instead direct traffic to the surf club area.

The focus in the planning and concept for circulation at Spencer Park is to direct traffic, by new road alignment, to the surf club area and, past that, to the Bottle Lake Forest boundary. Public vehicle assess, and a level of carparking space, will still be provided at the end of Heyders Road.


29 BL008 Park Management

In the weekend, there needs to be more than one ranger on - for their safety and the users of the beach.


Overall, we consider all three reports (draft plans) to be very good, with the exception of one significant omission and one matter which conflicts with existing council naming policy.

31 BL009 Master Plan Adjustment

Please reference these books in the master plan: (a) Hills, Dennis (2002) "The Styx Story", Styx History Group; (b) Hills, Dennis & Helen (2006), "Settling Near The Styx River", D A & H J Hills

Will be added to the list under "OTHER DOCUMENT AND PUBLICATIONS" in the master plan.


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32 BL009 Naming We believe that information supplied by Ngāi Tahu has been used out of context, and the implication that "Puharakekenui" is the Māori name for the Styx River is both incorrect and in contradiction to existing Council policy using "Pūrākaunui" for that purpose.

The name of "Pūrākaunui" to accompany the name Styx River has been used in documentation, including Council reports and leaflets, to do with environmental work concerning this river as part of the "Styx Project" launched in 1999, is used by the Styx Living Laboratory Trust in its publications and also on the header bar of the "thestyx" website. This name appears to have not been formally adopted by the Council, following Council's naming policy (at this time, though, a naming policy document for the Styx River catchment is in preparation by the Council). Reference in the draft master plan to "Puharakekenui" to accompany the name "Styx River" was provided by the tangata whenua for the Brooklands Lagoon area through Mahaanui Kurataiao Ltd.. Formal adoption of this name for the Styx River would mean adjustment of resource material and documentation referring to the environmental work being undertaken on the river. As "Pūrākaunui" used for the Styx Project work refers to the whole of the Styx River, and "Puharakekenui" applies specifically to the Māori place in the Brooklands Lagoon area, an option is to reflect the difference in the master plan, and for the name for the Styx River to be ultimately confirmed through the naming policy process. The staff suggestion is for two options to be considered: (1) all references in the draft master plan to "Styx/Puharakekenui River" to be replaced with "Styx-Pūrākaunui River"; (2) Council to defer the decision to the process and outcome of the naming policy, and for all references in the draft plans to the river to be to the "Styx River".

33 BL010 Wildlife Support the Brooklands Lagoon plans to support plants and wildlife including fish and game (waterfowl) life in the lagoon areas.

34 BL010 Fishing; Park Access; Water Fowl Shooting

I support the fishing and access to these areas for salmon fishing and whitebaiting as these recreational opportunities, including duck hunting, are why many people live in this area. In many cases, this has been done by families here for many generations.

35 BL011 Dogs Would you please consider a dog park in this area (Brooklands/Spencerville)? - well fenced and somewhere we can take our dogs to run free and socialise.

The Dog Control Policy 2008 limits dog activity in the area, and what is allowed is for dogs to be on a leash only. A city-wide review of the need and opportunities for dog dedicated areas is planned to be undertaken at some stage.



We would like to clarify the proposal to ban motorised vehicles from the Lagoon does not include boats.

Edit the following planning proposal for Brooklands Lagoon (underlined text is added): "Ban all motorised wheeled/normally land-based recreational vehicles from Brooklands Lagoon and its marginal areas (not including such vehicles used for official or authorised purposes). The sensitive wetland areas of Seafield Park, and parts of Brooklands Lagoon, have been severely damaged in the past by recreational vehicles. The banning of motorised wheeled/normally land-based recreational vehicles will promote the recovery of vegetation.".

Master plan: p.77

37 BL012 Pine Removal

The proposal to remove pine trees from the spit in the Lagoon has residents worried. Currently the trees provide some wind breaks, nesting areas for birds and stabilise the sand. We are reluctant to see them go.

The pines from the estuary mouth end of Brooklands Spit are invading the salt meadow areas of the northern part of the spit. Control of the largest of these has already occurred, but, at present, there are a huge number of small wilding pines that it is considered should be removed. It is suggested retaining the pines at the northern tip of the spit, but progressively removing all pines from where the saltmarsh margin begins, all the way to the southern end of the spit. The pines are not needed for shelter by walkers, as the height of the dunes provide this, but do prevent excess sand from blowing into the saltmarsh. Planning and Management Proposal 4 in the draft master plan proposes to remove invasive wilding pines near the inner tip of Brooklands Spit where a complex of small tidal creeks, salt meadow and saltmarsh exists (a habitat type that is rare in Canterbury). Bird usage of this site is limited due to the enclosure by pines. There has been an ongoing programme of poisoning of scattered wilding pines on Brooklands Spit by Council staff. Efforts by staff are now more selective and the focus is working more on the control of spread of pines and increasing the planting of natives in this area.

Master plan: p.77 and p.83

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We would prefer that dead trees (poisoned) be removed as they are unsightly and are a health and safety issue, and also a fire danger.

Active removal would be costly and impacting on the environment. Also, the areas where trees are being poisoned are isolated from where people will be.

39 BL012 Board Walk The board walk proposed for around the 'Muddy Puddle' (Blue Lagoon) restaurant (at the eastern end of Harbour Road) should not extend past the boundary for this property as the shore along the reserve provides good whitebaiting spots.

The potential walkway around 87 Harbour Road is currently under investigation. As indicated on the plan on Page 96 of the draft master plan, it is anticipated that the walkway would extend around 87 Harbour Road on the seaward side then re-enter the reserve.

Master plan: p.96

40 BL012 Historic Sites We would like to see some restoration and protection for the ship wreck graves on the Seafield (Park) sand dunes.


Otherwise we support the proposals.


I would like to confirm that the ban on motorised vehicles on the Lagoon does not apply to boats.


Master plan: p.77


There is a concern that removal of pines on the spit will result in the loss of wind breaks. They also act as stability for the sand dunes and good roosting for birds.

The pines from the estuary mouth end of Brooklands Spit are invading the salt meadow areas of the northern part of the spit. Control of the largest of these has already occurred, but, at present, there are a huge number of small wilding pines that it is considered should be removed. It is suggested retaining the pines at the northern tip of the spit, but progressively removing all pines from where the saltmarsh margin begins, all the way to the southern end of the spit. The pines are not needed for shelter by walkers, as the height of the dunes provide this, but do prevent excess sand from blowing into the saltmarsh. Planning and Management Proposal 4 in the draft master plan proposes to remove invasive wilding pines near the inner tip of Brooklands Spit where a complex of small tidal creeks, salt meadow and saltmarsh exists (a habitat type that is rare in Canterbury). Bird usage of this site is limited due to the enclosure by pines. There has been an ongoing programme of poisoning of scattered wilding pines on Brooklands Spit by Council staff. Efforts by staff are now more selective and the focus is working more on the control of spread of pines and increasing the planting of natives in this area.



We would like the poisoned and now dead trees on the spit to be removed as they are a hazard and a fire risk.

Active removal would be costly and impacting on the environment. Also, the areas where trees are being poisoned are isolated from where people will be.

45 BL013 Board Walk We would not like the proposed board walk past the 'Muddy Puddle' ("Blue Lagoon") restaurant (at the eastern end of Harbour Road) to extend any further than that property boundary on the reserve. Any further into the reserve will restrict property views and inhibit good whitebaiting areas.

The potential walkway around 87 Harbour Road is currently under investigation. As indicated on the plan on Page 96 of the draft master plan, it is anticipated that the walkway would extend around 87 Harbour Road on the seaward side then re-enter the reserve.

Master plan: p.96

46 BL013 Historic Sites We would like the old ship wreck graves in the Seafield walk sandhills to be protected - perhaps with an information board.

Interpretation of these sites could be considered to be added as part of the recreational facility development of the area.

47 BL014 Board Walk That the board walk proposed to go around the "Muddy Puddle Café" should not extend past the boundary fence onto the reserve as this is a very popular and safe whitebaiting area. If the boardwalk extended past the boundary it would also block what small view we have of the lagoon.

The potential walkway around 87 Harbour Road is currently under investigation. As indicated on the plan on page 96, it is anticipated that the walkway would extend around 87 Harbour Road on the seaward side then re-enter the reserve.

Master plan: p.96


The pine trees should not be removed from the spit (reason: windbreak, erosion and fire hazard from poisoned and dead trees).

Wilding pines that are threatening ecological values of the saltmarsh will be removed. Also wilding pine spread along the spit to the south will be halted. This will leave a confined stand of pines at the end of the spit. Efforts by staff on pine removal on the spit are now more selective and the focus is working more on the control of spread of pines and increasing the planting of natives in this area.

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The ban on "motorised vehicles" does not include boats - ie only wheeled vehicles in dunes etc.


Master plan: p.77


With (the) exceptions (indicated in the submission), I support the Draft Plan.


The (plans are) supported because (they) encourage public access to (reserves), and activities in (the) reserves provides a range of positive benefits to public health.

52 BL015 Public Health The reasons for making this submission are to promote the reduction of adverse environmental effects on the health of people and communities and to improve, promote and protect their health pursuant to the New Zealand Public Health and Disability Act 2000 and the Health Act 1956. Specific issues are as follows: (1) The public's use of reserves, particularly those remote from alternative facilities, can bring expectations that toilet facilities and potable quality drinking water will be available; (2) Where reserves include a children's playground, there may be an increased expectation that toilet facilities are available on-site or close by. It is recognised that among the various types and locations of reserves, some within urban areas and some in genuinely remote locations, there will be varying rationales and priorities for providing potable water, public toilets, playgrounds and facilities for the disabled. It is also recognised that there is unlikely to be a single answer that is correct for all of Christchurch City Council’s reserves.

Toilet facilities are currently being constructed at the Brooklands boat ramp. These will be fully accessible, as per Counil’s Parks and Waterways Access Policy.

53 BL015 Public Health; Facilities

It is … recommended that these public health issues are considered on their merits in the Brooklands Lagoon (Planning) Area; and that, where possible, the appropriate facilities are provided.

54 BL015 Public Health ... it is recommended that if potable water supply and toilet facilities are not going to be provided that every effort is made to pre-warn visitors by: a. identifying the absence of such facilities on maps, brochures and websites, b. identifying the nearest alternative facilities available, and c. having signage in place at the reserve to direct the public to these alternative facilities.

55 BL015 Public Health; Facilities

It is ... strongly recommended that if a water supply is available on-site, including (for) hand washing water at toilets, and that this supply is not of potable drinking water quality, then this is made clear by the provision of warning signs that indicate the water is not suitable for drinking without further treatment.

56 BL016 Naming I visited the spit and eastern shore of Waimakariri estuary (called incorrectly "Brooklands lagoon" in the plan).

Historically, when the Waimakariri River exited to the sea at a point midway along what is now Brookland Spit, what is now referred to as "Brooklands Lagoon" was an estuary of the Waimakariri River. Since then, with the shifting of the mouth of the river northward, the estuary has become popularly known as "Brooklands Lagoon", although it is noted in the draft master plan that it is, in fact, an estuary.



The draft master plan is an excellent basis for developing appropriate policies in the area. It is well documented and detailed enough in most places to define the existing situation and options for action. Many of the draft proposals are supported by me.

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58 BL016 Plan Short-comings

Significant issues that are not sufficiently addressed (in the draft master plan) are: • the considerable value and potential value of the vegetation of the spit; • the desirability of extermination, as far as is practical, of exotic plants (especially pines) on the spit; • the uneven quality of the existing studies of vegetation; • the need for any enhancement proposals to take full account of the existing vegetation and its ecology; • the need for restriction of access along the spit and adjacent saltmarsh strictly to walking; • more strict control of dogs; • and reversal of the artificial attempts to build sand dunes along the spit.

The vegetation of greatest ecological value is actually outside the Brooklands Spit ‘park’ as it occurs in the CMA below MHWS. Its values (threatened species, range of vegetation types etc) is acknowledged and recognised. The pines on the spit will be confined and wildings removed. It is too impractical to remove all and there are high risks of erosion. The vegetation of the saltmarsh has been described in detail in a recent report by Worner & Partridge. The land vegetation is predominantly exotic. Vegetation enhancement is not proposed for the ecologically valuable types, but only for terrestrial communities which are almost completely modified. The dunes along the spit protect the estuary and the land across on the western shore so any attempts to reverse maintaining stability are extremely risky.

59 BL016 Naming Support Maori naming, and involvement of Ngāi Tahu in the development, of structures in public spaces in the Brooklands Lagoon planning area.

60 BL016 Plantings Master Plan Proposal 2 (Protection, restoration and enhancement of natural values and Mahinga Kai values in the planning area): The word “endemic” should be omitted, as it is sufficient that a plant is native (indigenous). ... important ... that the planting is proposed in those parts of the area that are most natural and where there is much existing value. Any such proposals should not be adopted without full ecological survey and a reasoned justification.

Remove all reference to "endemic" in the master plan, except in the bird checklist at the end of the plan.

Master plan: p.i and p.40

61 BL016 Research and Monitoring

Fully support proposed (research and monitoring related to tangata whenua values (Master Plan Proposal 4), but note) there seems to be little difference between the “State of the Takiwa” and other “citizen science” monitoring exercises as are undertaken elsewhere in the world. Given this, it would be unfortunately divisive should monitoring become the preserve of one interest group.


Master Plan Proposal 10 (Development of the South-east Picnic Ground area of Spencer Park): Support for the mountain bike track to divert use away from more sensitive areas nearby.


Master Plan Proposal 13 (Development of the southern Brooklands Lagoon margin in Seafield Park): I (do not) support the extension of the mountain bike route along the legal road to the west of the “lagoon”. The legal road route should be stopped, as access to this area has already caused considerable disturbance to the vegetation and to the high tide roosts of birds. Any cycle route on this side of the “lagoon” should be located further west, where it can be screened from the sensitive habitats by existing vegetation, and illicit access to the “lagoon” prevented. The proposals indicated on page 103 of the draft, however, seem acceptable in this regard.

Through Mid-Seafield Park the tracks are back from the estuary margin. For the section between this part of Seafield Park and South Seafield Park, public access is confined to the legal road and there is not the opportunity to shift it further west due to the presence of private land.

64 BL016 Board Walk Master Plan Proposal 13 (Development of the southern Brooklands Lagoon margin in Seafield Park): I support the estuary boardwalk.


Master Plan Proposal 13 (Development of the southern Brooklands Lagoon margin in Seafield Park): I support the … pine tree removal.

Total pine removal is impractical and risky. However wilding spread will be controlled.

66 BL016 Reserve Classification

Support Master Plan Proposals 17 and 18 (changing the classification of the recreation reserve in Mid Seafield Park to, and declaring the parcel of land at the North Seafield Park entrance off Harbour Road, scenic reserve).

67 BL016 Reserve Boundary Survey

Support Master Plan Proposal 19 (surveying the MHWS (eastern) boundary of North/Mid Seafield Park). Footnote 7 page 6 suggests that the Ecological Heritage Sites lie above Mean High Water Springs and so fall within the jurisdiction of the City Plan. This is questionable – throughout most of the area the spring tide highs are expressed across a short distance because of the greater ground slope found there. The map on page 6 shows some area within EHSs which is in fact below mean high water springs. This is made clear in the subsequent more detailed maps. Clearly there is a need to map the Mean High Water Springs more accurately and to bring those responsible for the Coastal Marine Area into this exercise if the saltmarsh, tidal muds and sands and nearshore benthos are to be conserved appropriately.

The seaward boundaries of the Ecological Heritage Sites adjoining the Coastal Marine Area in the Brooklands Lagoon area are defined graphically on the planning maps in the Christchurch City Plan by the MHWS mark, which is the line of the average of the highest tides (known as spring tides). Obviously, this line in the City Plan represents a fixed position, but, in reality, the MHWS line will shift. For that reason, where shown, it can only be an indicative line. The intention for Master Plan Proposal 19 is to survey the MHWS boundary of Seafield Park, which has arisen from the transfer of part of Seafield Park to the Crown under the Foreshore and Seabed Act 2004, and not to survey the MHWS. In terms of achieving the best management of the natural resources on either side of the MHWS, it is desirable to have integrated management by all the agencies involved in the area rather than impose responsibility according to fixed jurisdictions. This is a key role of the master plan.

Master plan: p.59

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Support Master Plan Proposal 20 (the stopping of legal road within North/Mid Seafield Park and adding this to the scenic reserve, but not for this land to be used for a mountain bike route).


Master plan: p.59

69 BL016 Restoration; Facilities; Information/ Interpretation

Support Master Plan Proposals 21 to 24 (habitat restoration, and recreational and interpretation facility development, but not for the land on the margin with the estuary to be used for a mountain bike route).




Support Master Plan Proposal 25 (for the Christchurch City Council to advocate to Environment Canterbury that controlled seasonal shooting in the central area of Brooklands Lagoon, where the majority of the mai-mais are located, shall be permitted). However, the submissions should be explicit as to the allowable zone and the number of maimai to be permitted, as there was a considerable growth of shooting in the 50s and 60s. A return to a low rate of shooting is desirable.

Environment Canterbury (ECan) staff advise ECan does not have any control over seasonal shooting in Brooklands Lagoon, but controls structures, such as mai-mais, in the estuary through the resource consent process under the Resource Management Act 1991 (RMA). However, since the Christchurch City Council (CCC) Local Government Act boundary is Mean High Water, or lower (that is, more seaward than ECan's RMA boundary of MHWS), then the CCC can make Local Government Act (LGA) bylaws over such areas (for example, Brooklands Lagoon).

Master plan: p.77


CCC staff suggest that Master Plan Proposal 25 be adjusted as follows: "For the Christchurch City Council to advocate to Environment Canterbury thatTo investigate potential methods, such as controlled seasonal shooting, to control exotic water fowl populations that compete with rarer native and exotic birds controlled seasonal shooting in the central area of Brooklands Lagoon, where the majority of the mai-mais are located, shall be permitted. Controlled seasonal shooting is a management tool which is used to assist with the control of those exotic water fowl populations that compete with rarer native and exotic birds".

Master plan: p.77


Support Master Plan Proposal 26 (Ban all motorised recreational vehicles from Brooklands Lagoon). However, the policy does not go far enough. Off track cycling, horse riding and various kite or sail powered vehicles are also disturbing to vegetation and birds. It would be more comprehensive to confine access (to) people on foot. I wrote to the then Waimairi County Council in January 1978 on this issue and received a reply from the County Clerk agreeing with my concern (their ref R4/1/3 PD:BF). I wrote again in February 1982 in my capacity then as a DSIR ecologist (ECOL:4/1/48:DGD) again pointing out this, among other, problems. It should be understood that there is no long tradition for access here other than on foot, as is confirmed by my observations from the late 50s to the mid 60s.


Master plan: p.77


Oppose Master Plan Proposal 27 (to develop a new walkway from Heyders Road along the eastern side of the lower Brooklands Lagoon). (There is not) a reasoned justification for this proposal, nor does there appear to be a map illustrating it. I should wish to see such details before commenting, as the existing paths in this area seem adequate (provided illicit access by vehicles is prevented).

CCC staff suggest that Master Plan Proposal 27 be adjusted as follows: Consider dDeveloping a new walkway from Heyders Road along the eastern side of the lower Brooklands Lagoon, which will provide an alternative to the lower section of the Brooklands Lagoon Walkway.

Master plan: p.77

74 BL016 Facilities Partially support Master Plan Proposal 28 (to erect an observation platform/bird hide on a possible new walkway along the eastern side of the lower Brooklands Lagoon). Such a hide would be a considerable asset to this part of the estuary, providing that access to it was appropriately screened from view of birds using the nearby estuarine habitat. It would be appropriate to locate a hide at an elevation set back from the high tide line. However, it would be very difficult to screen a boardwalk and I would like to see full details of location and design to be reassured that disturbance was to be avoided.

Edit Master Plan Proposal 28 as follows: "Consider eErecting an observation platform/bird hide on the above-mentioned proposed possible walkway. There is risk of increasing the impact on a sensitive area, which will need to be overcome with appropriate design. The proposed platform/hide could incorporate a boardwalk over part of the estuary marginal area to provide better observation of the vegetation".

Master plan: p.77

75 BL016 Ecological Protection

Support Master Plan Proposal 29 (the Christchurch City Council advocating that the Brooklands Lagoon and Lower Waimakariri River mudflats are managed in ways consistent with protection of wildlife and wider ecological values).

Master plan: p.77

76 BL016 Education Support Master Plan Proposals 30 (improving public awareness of the special values of the Brooklands Lagoon area).

Master plan: p.77

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Conditionally support Master Plan Proposal 31 (Protect from damage the saltmarshes and salt meadows on the western edge of Brooklands Lagoon). These habitats are largely self-sustaining and restoration would generally require a suitable substrate and water regime, rather than planting. Given this, a detailed justification of any such proposals should be provided. The suggestion that some damage by off-road vehicles may be irreversible (Page 71 (iii)) is contradicted by the history of the area, as much of this vegetation established over the last half of last century on substrates that were previously much more bare. If ground conditions remain suitable, natural re-establishment should be much faster, given the nearby undamaged areas as a source of colonists.

Restoration activities in relation to the saltmarshes will concentrate on repairing the marsh to land interface which has been mostly lost or highly modified. There are some areas near Brooklands where vehicle impacts have compacted the marsh surface and lowered it to below the salt marsh zone. These areas have not been colonised by vegetation.

Master plan: p.77

78 BL016 Ecological Enhance-ment

Conditionally support Master Plan Proposal 32 (to investigate excavating several shallow ponds within the dune areas alongside Brooklands Lagoon to provide additional bird habitat). A reasoned justification should be made. Shallow brackish ponds might be appropriate in some of the few areas of dune slack, but these would be at the expense of existing vegetation.

The area at “The Lagoons” subdivision has used an old cut-off area that was formerly marsh for the creation of bird and salt marsh habitat. There are no plans for doing the same with other areas of dune slack to the south. These are recognised as being different ecosystems with different controlling factors.

Master plan: p.77

79 BL016 Predator control

Support Master Plan Proposal 33, resources permitting, (to establish predator control lines along the Brooklands Lagoon margin and within the new Dartford Street/Beacon Street wetland area). However, big changes in the wildlife have occurred despite no apparent change in the presence of introduced predators, so these lines should not be justified naively on the basis of recorded losses.

Master plan: p.77


Support Master Plan Proposal 34 (to establish monitoring sites in Brooklands Lagoon). Care is needed, however, as monitoring can be a bottomless pit, a plaything of academics, so resources may be better devoted elsewhere. Nowadays much monitoring can be achieved cheaply with aerial photography with “ground truthing”. Also, the greatest need for monitoring is in habitats at risk of invasion by exotics, not in the saltmarsh.

Monitoring will focus on ensuring the proper ecological functioning of the various habitats of plants and animals. For instance. the integrity of the populations of the threatened sedge Carex littorosa and pest plants such as spartina.

Master plan: p.77

81 BL016 Convey-ancing

Support Master Plan Proposals 35 to 37 (to facilitate process to transfer administration of Brooklands Spit to the Christchurch City Council; initiate procedures to have the part of the Crown land area at the southern end of Brooklands Lagoon transferred to the Council; and to protect and manage Brooklands Spit as one landscape/ecological unit).

Master plan: p.82


Support Master Plan Proposal 38 (to restore nesting and roosting habitat for coastal/wetland birds on Brooklands Spit). The greatest scope for this is in two areas. First is the place where most Banded dotterels and Black-backed gulls were breeding in the early 1960s - the site of the previous mouth of the Waimakariri River on the spit 1.65 kilometres north of Heyders Road. Here it would be desirable to remove the artificial foredune & restore the natural landform.

Master plan: p.82


Second is the broader northern part of the spit (starting approximately 1.5 kilometres south of the tip), where invasive pines have ruined extensive tidal flats and a dune system. Exotic plant removal should be pragmatic, however, as most exotic plants play a minor role in the ecology of the area, but some act as ecological engineers in dominating its ecology at the cost of natural and traditional value. Other weed species are so entrenched that it may be difficult to eradicate them (marram grass for example). The section on weeds (Page 45 (of the draft master plan)) also omits tree lupin (Lupinus arboreus), perhaps because it is considered too widespread also. The proposal to replace marram with Spinifex and Pingao (Page 83) would be excellent, but sadly, very difficult to achieve.

Tree lupin is no longer such a major problem since the arrival of the wasting disease that kills most plants each autumn. Spinifex and pingao may be planted in the future, but, considering the dune structure, it is unlikely that they would be able to replace the marram.

Master plan: p.82

84 BL016 Wildlife Support Master Plan Proposal 39 (to undertake protective measures for beach nesting birds). Although it is not clear what is meant by "temporary beach construction".

The full text of Master Plan Proposal 39 is: "Undertake protective measures (such as pest control, indication of safe vehicle routes and temporary beach reconstruction) for the benefit of Banded Dotterels, White-flippered Penguins and other beach nesting birds."

Master plan: p.83

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Support Master Plan Proposal 40 (to remove invasive wilding pines near the inner tip of Brooklands Spit). Total removal of pine is needed urgently to prevent further spread south down the spit and north from Heyders Road. It would be appropriate to extend the pine-free zone northwards by stages, whilst continuing maintenance of the southern pine-free zone. The pines provide no significant habitat. Alternative roosting sites for cormorants (Page 81 (draft master plan)) are available just across the Waimakariri River mouth, and only a few, and mainly introduced, bird species favour the pines as habitat. The proposal to remove pines solely from the wetland areas they threaten in the north of the spit is inadequate for two reasons. First is that the dunes here have greatest potential for restoration back to their condition only 45 years ago, with considerable benefit to native duneland species. Second is that partial removal would leave an abundant source of seed adjacent, requiring expensive removal of seedlings ad infinitum.

Pine control will comprise removing plants and wildings that threaten saltmarsh ecological values, and preventing spread from both the stands on the spit and to the south by removing wilding plants.

Master plan: p.83


Support Master Plan Proposal 41 (to ensure more effective control of human recreation activity, dogs and vehicles on Brooklands Spit). I would advocate a ban on vehicular access north of Heyders Road (all traditional uses can be undertaken on foot, or by row boat). No reference is made to the existing dog control measures (Page 29 (draft master plan)), which seem contradictory to this proposal, at least on the spit. Dogs are a recent problem, coming with new attitudes to pets by dwellers in urban Christchurch, a minority of whom cannot, or do not wish to control their pets. The idea that dogs can be “under effective control” is simply impractical. Dogs should be required to be on a leash anywhere on the spit during the bird breeding season, not just beyond the “crossover”. Although, what caused the decline of the Banded Dotterel remains unclear, the increase in the number of dogs coincides with the decrease of this bird, which used to breed all along the spit. If leashing is difficult to enforce, a ban might be easier. It should be appreciated that dogs can be a significant agent of disturbance to breeding and roosting birds, and other wildlife, and are not part of the natural scene. Horse riding and cycling should also be banned on the spit throughout the year (possibly being allowed only on the wet sand below the high tide line, but this might be difficult to enforce).

Master plan: p.83

87 BL016 Education Support Master Plan Proposal 42 (to improve public awareness of the special values of the Brooklands Spit area).

Master plan: p.83

88 BL016 Environment-al Protection

Support Master Plan Proposal 45 (Seek to protect the Styx Ponding Area from urban development and have it remain essentially as pasture).

Master plan: p.86

89 BL016 Partnerships Support Master Plan Proposal 46 (Develop a Memorandum of Understanding (MOU), or expand on an existing MOU, for the Waimakariri/Styx Rivers confluence area to formalise co-operation between Environment Canterbury, Department of Conservation and the Christchurch City Council for the care and management of the area).

Master plan: p.91

90 BL016 Facilities Support Master Plan Proposal 47 (Investigate constructing a public access board walk over the Brooklands Lagoon mudflat between the end of Harbour Road and the Styx River mouth).

Master plan: p.92

91 BL016 Coastal Area Some comments imply that coastal erosion is necessarily harmful to the area (e.g. Section 2 Page 40 (draft master plan)). However, the history of the landscape, summarised elsewhere in the draft plan, shows that such processes are natural. The extensive work to control flooding and the flow of the Waimakariri River has diverted the natural course of coastal erosion and deposition, and sea level rise will affect the area. However, this site is one of the few left in New Zealand where there is some scope to allow natural processes to continue.

The ecological values of the estuary are at risk from coastal erosion, especially as there is but a single dune ridge along most of the spit. Such instability would then threaten housing and land on the western shore.

Master plan: p.40

92 BL016 Values There appears to be an assumption that cultural, spiritual, historical and natural values are necessarily compromised by increasing use of the area (for example, in the third bullet point on Page 24 (draft master plan)). However Maori values are not just theoretical, but can include practices that may (and perhaps should?) increase. Also, it is nowadays widely recognised that neither historical nor natural values can be divorced from those who celebrate them and that people who are nominally undertaking one activity may be receiving benefit from others. Celebration requires use. Indeed a common definition of biological conservation is “wise use”. So, it is important that the cultural, spiritual, historical and natural values of the area are made accessible to all.

The boundary between use and exploitation is not always clear. Master plan: p.24

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93 BL016 Mahinga Kai In Section 2, Page 40 (draft master plan), reference is made to unspecified mahinga kai gathering in the area and a proposal is made for a Mahinga Kai Cultural Park in the area. Further reference is made to mahinga kai on Page 73. Without further detail, the implications of this remain unclear. It is important that any such tradition in the area be documented and specific proposals be subject to comment. In my extensive experience of the area there was little or no gathering (mahinga kai or otherwise). On the many occasions when my grandfather took me there as a youngster we were the only people gathering. Without a documented tradition there, the cultural park might seem artificial.

Master plan: pp.40, 73

94 BL016 Values I accept that there are legal requirements to consult with tangata whenua, the expression of this in the consultation can be misleading. There is a tendency to typify the tangata whenua relationship with the area as “cultural and spiritual” but, by omission, to deny that others have such a relationship. This is an oversimplification of the tradition in the area, implying two things that may be questionable. The first implication is that cultural and spiritual relationships (I am ignorant of what rights may be afforded to Maori through the law in recent decades, but this is a separate matter and should not be confused with the traditions in the area, nor its history) with the land and water might be confined, or in some way unique, to tangata whenua. The second implication may be that the traditional practices are in some way specially privileged, as they reflect the unique spiritual harmony with nature of an indigenous people. The shorthand “tangata whenua values” or assertions of “tangata whenua importance” are used throughout (the draft master plan) without definition nor evidence, which serves to confuse the reader of the consultation. If the reference is to the need to consult with tangata whenua under law, this should be said and the artificial identification of cultural and spiritual values with one culture should be dropped. If there are indeed values that are newly developed and protected under law, this should be stated and they should be defined clearly.

In order to recognise and respect the Crown's responsibility to take appropriate account of the principles of the Treaty of Waitangi and to maintain and improve opportunities for Māori to contribute to local government decision-making processes, the Local Government Act 2002 (LGA) provides principles and requirements for local authorities that are intended to facilitate participation by Māori in local authority decision-making processes. Under s77 of the LGA, the local authority, where there is the need for a significant decision in relation to land or a body of water, must take into account the relationship of Māori and their culture and traditions with their ancestral land, water, sites, waahi tapu, valued flora and fauna, and other taonga.

95 BL016 Traditional Uses

I am puzzled over the claims for traditional uses in this areas by Maori (Pages 36-39, 60 (draft master plan)). In my extensive visits to the area in the early 1960s there were no such uses. The history of the landform summarised in Pages 31-35 shows that any uses of the “lagoon” and spits must have been greatly disrupted by natural processes of deposition and erosion, and that this was the case known to my grandfather, who reported his use of differing parts as the situation changed. With the sole exception of the Maori Reserve, none of these uses are referred to a defined area or site. Under these circumstances, the claims reported in these pages surely need better evidence than is provided? Perhaps the practices took place in a covert way, longer in the past, or in places now lost through changes in landform? Surely it would be wrong for Maori cultural values to be ignored in any plans, but just as surely it would be wrong to accept claims of actual practices and historical facts, without adequate evidence.

Master plan: pp.(several – see Submitter Comments)


Footnote 4 (on) Page 2 (of the draft master plan) would be more informative if it were made clear that saltmarsh establishes naturally on the upper tidal zone of estuarine mudflats.

Edit Footnote 4 on Page 2 as follows: "A saltmarsh is a special type of wetland ecosystem that naturally establishes on in the upper tidal zone of sheltered estuarine mudflats".

Master plan: p.2


Footnote 5 (on) Page 5 (of the draft master plan) lists just three sources of modification (farming, motor vehicle access and stormwater). This would be best omitted, given that there are very many other influences, some of which could be of greater significance.

Edit Footnote 5 on Page 5 as follows: "Centred on a large natural estuary, which is flanked by vegetated dune ridges, and has had some modification of its margins (from farming and motor vehicle access), and stormwater inputs from adjacent developed areas."

Master plan: p.5


Footnote 6 (on) Page (5) ... lists values in saltmarsh vegetation, but not in dune vegetation, nor the bare muds and sands. ... the implied emphasis may not be desirable.

Footnote 6 (Page 5): "There are significant ecological and landscape values here, such as the saltmarsh and coastal birdlife and habitat, as well as important cultural and spiritual associations and values for the tangata whenua." The reference to "saltmarsh" is just an example of a significant ecological and landscape value.


In Map B, Page 32 (draft master plan), and elsewhere, it is implied that an estuary exists only where there are extensive mudflats. However, the generally accepted definition of an estuary is a water body at the interface between a river and the sea characterised by both a tidal change in water levels and a salinity gradient between fresh and sea water. On this basis, there would always have been an estuary at the mouth of the Waimakariri and Styx Rivers, if not in the precise location of the present day one nor always as big as it.

The reference on Page 32 is taken from a 1993 NIWA report to the Christchurch City Council and Environment Canterbury on sedimentation in the Styx River catchment and Brooklands Lagoon (Hicks, D. M. and Duncan, M. J. (1993)).

Master plan: p.32

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100 BL016 Vegetation The description of the vegetation of the area (Pages 42-45, 78 (draft master plan)) is woefully incomplete, especially for the dune vegetation, (with) remarkably few of the species that occur (being) listed. This lack of documentation risks missing values that should be acknowledged. I undertook limited surveys in the dunes and saltmarsh in the mid 1960s and some of my data were deposited with the herbarium of the University of Canterbury's Department of Botany. No reference is made to Hackwell’s work on vegetation (Knox, Bolton & Hackwell, Estuarine Research Unit, Dept of Zoology, University of Canterbury, Report 16). For example, tauhinau is native to the area, rather than recently introduced, and is still widespread there. The information on the vegetation of the saltmarshes is much better, presumably because of recourse to the teacher research projects (Pages 62-68). These, however, lack a good historical perspective. For example, saltmarsh community “A” was rare and patchy in the 1960s, with its present extent developing progressively (see Hackwell’s work).

Refer to Plan Status on Page 1 of the draft master plan and, in particular, the following (paragraph 6): "This document is not a complete or scientific account of the values and issues of, and needs for, the open space and natural areas that are covered, but serves to give an indication of, and be a starting point for, some of the key ones. Other, more comprehensive references will need to be referred to for more detail." It is acknowledged that, for the purpose of producing a 'wieldable' plan, it cannot be a full and complete record. Tauhinau has been re-introduced to the area after having become extinct. It was not possible in the work of Worner & Partridge to compare previous composition as there had been no previous plot-based studies. Anecdotal evidence is too risky to compare. However, the report did look at extent of marshes, which have changed considerably at the Spencerville end, but remained remarkably stable nearer Brooklands.

Master plan: p.1

101 BL016 Vegetation It would be good to see a good study undertaken of the vegetation of (Brooklands) spit.

The City Botanist may consider a study of this kind, although probably not much of note would be found.

102 BL016 Recreational Activity

In places, the recreation section (Page 48 (draft master plan)) is at odds with my own observations. Whilst it could be that water skiing and yachting began in the “lagoon” in the 1920s and 1930s, water skiing was based in the lower Waimakariri River, not the “lagoon”, in the 50s. I saw none in the “lagoon” until the early 60s, when the base was moved to the western side of the spit opposite the Styx River mouth. During the time I have known the area, yachting has always been predominantly in the Waimakariri River rather than the “lagoon”. It is not stated when the restrictions were placed on water skiing and power boating, but I have observed both activities well to the south of the prescribed area frequently over the years, so the rules (Pages 74 and 75) are either very recent, or not well adhered to. Jet skiing is a recent development and equally uncontrolled. I have seen both jet skis and power boats regularly in the far south of the lagoon frequently on my visits to the area.

The rules for operating motorised vessels or motorised vehicles in the Coastal Marine Area came into effect with the Regional Coastal Environment Plan for the Canterbury Region becoming operative on 30 November 2005. Also, the Environment Canterbury Navigation Safety Bylaws 2005 control, for safety and navigation purposes, vessels operating in the Brooklands Lagoon estuary. Inappropriate vehicle use in the estuary and on the surrounding areas is an issue, and this has been raised in the draft master plan. One of the purposes of the plan is to highlight this issue through documentation, and, through a planning proposal, re-emphasise the requirement that there be no motorised wheeled/normally land-based recreational vehicles in the estuary, other than those used for official or authorised purposes.

Master plan: pp.48; 73-77

103 BL016 Wildlife The references to fish, shellfish and birds in the introduction to the section on Brooklands “lagoon” on Pages 60 and 61 is anecdotal and inadequate. For example, the shellfish are distributed more widely than is reported here and the wording implies wrongly that these two species do not tolerate salt water.

By necessity, the information on values in each of the Key Planning Area Elements sections in the draft master plan is brief and not intended to be a comprehensive account. Suggest, though, editing of the first paragraph on Page 61, as follows: "Shellfish, such as pipi and cockles, can be found in sandy patches close to the estuary mouth, and elsewhere. Eels (tuna), brown trout and yellow-eyed mullet, which can tolerate the higher concentration of salt water, feed around the mouth of the Styx River." Also remove the duplication of the text in this paragraph from the first paragraph of the second column of this page (this is an editing error).

Master plan: p.61

104 BL016 Wildlife There is passing reference to inanga spawning on Page 61 (of the draft master plan). This is an important issue in the area, as past flood control works have greatly reduced the extent of spawning grounds in and around the estuary. This is a serious consideration, which the plan should address.

A planning proposal in this section of the draft master plan proposes that the Christchurch City Council advocate that the Brooklands Lagoon and Lower Waimakariri River mudflats are managed in ways consistent with protection of wildlife and wider ecological values.

Master plan: p.77

105 BL016 Wildlife In the description of the mid Brooklands “lagoon” (Page 61 (draft master plan)) the role of the Caspian Tern is incorrect. It roosts there at low tide, and flies off to fish at high tide, not only in the estuary, but in the surrounding waters.

Edit the third paragraph of the second column on Page 61, as follows: "The mid-Brooklands Lagoon area contains a mixture of saltmarsh and open mudflats that, at low tide, form the main feeding ground for birds such as godwits, South Island pied oystercatcher (torea), Caspian tern (taranui) and the banded dotterel (tuturiwhatu)." Also remove the duplication of the text in this paragraph from the first paragraph of the second column of this page (this is an editing error).

Master plan: p.61

106 BL016 Brooklands Spit

The stabilisation of the dune system of the spit is referred to as the result of the planting of marram and pine and the construction of fencing (Pages 63, 64, 65 and 79). This could be misleading, as only the marram and fencing were put there for this purpose. The pines originate from a small number planted to shelter the water skiing hut from the wind in the early 60s. Their spread from there was natural and probably unintended, but the cline in maturity and density of pines from the northern tip of the spit to the south is evidence for this origin.

The pines have, in fact, played a major role in finalising the stabilisation process for Brooklands Spit. It is acknowledged that the original plantings was not for that purpose.

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107 BL016 Brooklands Lagoon

The section on options for the management of Brooklands “lagoon” on Pages 69 to 76 (of the draft master plan) is generally excellent, but marred by some errors.


On Page 71 (of the draft master plan) reference is made to the pines providing a bird “refuge”. In fact, there is no such significant value, and none is specified. In contrast, the habitat that was displaced by the pines was of value to native birds such as the Banded Dotterel, White-faced Heron, Pipit, Harrier, Kingfisher and Wrybill, and could be restored were the pines to be totally removed. So, there is no important conflict between bird conservation and pine removal.

Master plan: p.71


There is also supposed to be a value in the pines preventing the blowing of sand into the saltmarshes. This is very strange, as I see the issue as being quite the opposite. When sand could be blown more readily, not only were the geomorphological processes and the dune vegetation more natural, but the saltmarshes were rejuvenated in a patchwise fashion, and the resulting open habitat was much used by species such as the Wrybill, Banded Dotterel and other wading birds. Prevention of natural processes has led to accelerated ecological succession of the saltmarsh vegetation to taller species of less value to wading birds. There is no biological conservation reason to retain any pines on the spit and, indeed, total removal would be the best option, as otherwise there would be a permanent requirement to remove seedlings recruited from the retained pines.

Yes, there is no biological value in the pines, but there is also no guarantee that the effects of letting sand invade to 'rejuvenate' the marshes will produce acceptable outcomes. There are too many risks to the ecosystem.

Master plan: p.71

110 BL016 Wildlife On page 76 (of the draft master plan) it is suggested that changes in the population of several bird species, especially waders, over the last 80 years has been the result of loss of bare mudflat habitat. Whilst this may have been a contributing factor for some species it should be clear that there was little or no loss of mudflat before the 1960s (rather an increase), nor are the losses of the birds well documented. I attach (see the full submission) my own preliminary analysis of changes in standardised bird counts for the spit and estuary between the first half of the 60s and 2005. This shows many large changes, both positive and negative, but many of these reflect national trends, and the cause may well not be a local one. For those species that buck the national trends, there seems to be no single explanation for the change. Many of these species are visitors to the estuary and the cause here may be found in some nearby place. Even if the cause is local, changes to the extent of mudflat habitat are just one possibility. There have also been great changes to the vegetation of the spit, and significantly increased disturbance. The invasion of mudflats by three-square has been significant, but is a natural process, unlike most of the other threats to wetland bird populations in the area, and much mudflat remains.

Suggest editing the the following issue for Brooklands Lagoon in the draft master plan (in first column on Page 76): "Reductions in Brooklands Lagoon‘s populations of several bird species, particularly waders, over the last eighty years are probably the result of a number of causes. These include local causes, such as the loss of bare mudflat habitat, changes to vegetation (for example, the natural invasion of mudflats by three-square) and increased disturbance. The change in bird numbers for some species may reflect national trends linked to a reduction in the total area of mudflat. This habitat loss has occurred through both the reconfiguration of the estuary mouth area in the 1950s, and through the invasion of formerly bare mudflats in the southern and central parts of the estuary by three-square marsh."

Master plan: p.76


The planning proposal on Page 77 (of the draft master plan) to restore damaged saltmarsh is provided without detail of what is suggested. Restoration of an appropriate landform and water regime should lead to a natural restoration of saltmarsh, as it is most threatened by accelerated ecological succession as a result of dune stabilisation. Planting is generally not needed.

Add to the planning proposal on Page 76, as follows: "Restore and enhance destroyed or severely degraded saltmarsh and salt meadow habitats, by establishing an appropriate landform and water regime that leads to a natural restoration of saltmarsh without the need for planting." Planting will only be done to help restore the marsh to land interface, which has been almost completely lost around the estuary.

Master plan: p.77


On page 80 (of the draft master plan) it is stated that the former Kairaki spit was obliterated. This is not so – the new mouth divided the spit from its base, so it became Kairaki, or perhaps Brooklands, island, later to join with the southern spit.

The wording in the draft master plan - "1. The creation of a new mouth for the Waimakariri River at Kairaki, which delivered the full force of the river to the ocean and obliterated the former Kairaki Spit.", was sourced from the unpublished Christchurch City Council report: Brooklands Lagoon Wetland Complex: An overview of the site’s importance to birdlife with habitat management recommendations (Crossland A. C. (2008)). The intention, it is taken to be, was to describe the cutting of the spit from its base with the use of the word "obliterated", as the resulting island was, obviously, no longer a 'spit'.

Master plan: p.79


Spokes strongly supports the provision of an off-road shared walking and cycling path between Spencer Park and Brooklands. We suggest that the path generally follow the topography so that it is suitable for families (that is, be flat or undulating rather than humped with canted corners as in parts of Bottle Lake). It would be great to see the path linked with the existing path along the coast through Bottle Lake Forest Park, and eventually with the proposed path down the Waimakariri River from McLean's Island.

14




In my opinion, (the) proposed (mountain bike) track(/route) should not be built to a standard suitable for mountain biking, but the target market should be family groups of all levels of ability. The reason that I say that is: - there is already ample mountain biking opportunity present in the adjacent Bottle Lake Forest, and - given that the track will eventually connect to the Waimakariri Regional Park and thus to the soon-to-be-built clip-on onto the old Waimakariri Bridge, (which) will then be a link to the cycle track proposed in the Waimakariri District that runs from the old Waimakariri Bridge along the (river) to the coast and ... then up the Ashley River. The length of the route and the outstanding landforms along it would make this a candidate for one of the elements of the National Cycleway. The target market for the National Cycleway, though, is mostly family groups. I would further envision that this family-friendly track would also extend south through Bottle Lake Forest, with a suitable path built there, too.

As most of proposed track between Bottle Lake Forest Park and Brooklands will cater for both walkers and cyclists, it will need to be of a standard suitable for both users. Therefore, it will not be built to standard for specialised, high level mountain biking, nor promoted as such.

Master plan: p.109

115 BL019 Park Ranger's office

Although, I agree that the current office is not big enough, is not in the best location, and there is an ancillary benefit to the camping ground (with) expansion of the shop, I would strongly disagree that the ‘park house’ (on the Seafield Park side of Heyders Road) to be the best location for the Ranger’s office on the following basis: a. The safety of pedestrians: Heyders road is a public road. In my view it is not prudent to expect park users, particularly children to walk across this road to reach the rangers’ office/information centre. In my many years of service at Spencer Park, I have witnessed a number of near misses/accidents involving motor vehicles and pedestrians on that section of road. The potential danger can also be interpreted in Sub-section 3.7 (Access) of Section 3 (Values & Issues) of the Spencer Park Management Plan 2009-Draft “…the roading pattern at the entrance and reception area of the Park is complex. This area acts as a focus for both pedestrian and vehicle activity, and a high intensity of use occurs at peak periods”.

The issue of the inadequacy of the existing Spencer Park Ranger's office is raised in the Draft Spencer Park Management Plan 2009. Development Proposal 6, as part of the Spencer Park and South Seafield Park landscape concept, is to utilise the house on the north side of Heyders Road. This is a proposal only, and a final decision would be made following consideration of all viable options.

Master plan: p.108


b. Public visibility/access perspective: As mentioned in the above paragraph, the ‘park house’ is situated on the other side of the public road from the park. Therefore, it does have limited visual lines and an unsatisfactory access from the main park from a pedestrian perspective. c. Cost of conversion of the existing building: This existing ‘modern’ house has been extensively renovated five years ago. Being a three bedroom house/home, the cost of the conversion (to an office/info centre) would be excessive. d. Onsite/living ranger for emergency/security: There is a need to have an onsite/living ranger for the purpose of emergency and security aspect. Over the last five years I have responded to numerous (after hours) situations, for example, rescues and fires. The public/park users and emergency organisations (that is, police, ambulance and fire services) regard this level of ‘service’ extremely valuable. It is an unquantifiable service that undoubtedly always brings positive feedback to the Christchurch City Council. I believe the Rangers’ office should be located ... adjacent to the existing utility storage area (next to the existing Rangers' office site). This (location) is ideal as it has good visual lines and is practical and safe for both park users and ranger staff. Given the size (that would be) needed for the building, the capital cost should not be too excessive. It may also be possible to modify the existing storing ‘green’ shed into the new office. Such implementation would certainly contribute to the minimization of building footprints. I believe the additional issues to consider and evaluate before moving the existing Rangers’ office to a new location are: 1. The potential relocation of staff (2 rangers) to the Coastal Rangers Team at Bottle Lake Forest H/Q. 2. The feasibility of Christchurch Holiday Parks Ltd formally obtaining a ‘variation’ to the camping ground lease for the use of the existing Rangers’ office space.

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117 BL020 Spencer Park Surf Lifesaving Club

Surf Life Saving New Zealand (SLSNZ) is supportive of (the) CCC's approach in enhancing functionality of buildings. Where there is a public dollar being invested into a public facility, options should always be explored to identify the positive contribution that facility can make to the community through its various uses. With regard to the surf life saving club structure, it is paramount that the primary use of this facility is retained for surf life saving services in order for SLSNZ and Spencer Park SLSC (Surf Life Saving Club) to retain and enhance coastal public safety in the Spencer Park Area.

118 BL020 Signs Arrival Signage/Water Safety Signage. SLSNZ would recommend that (the) CCC extend the signage project to include water safety signage in accordance with the NZ Water Safety Signage Standard NZS8690:2003. An extension of the work that has gone in to Sumner/Scarborough with aquatic safety messaging and patrol information included in access signage, along with CCC animal control and other ordinances, would be appropriate. SLSNZ will be able to directly provide CCC with the appropriate signage specifications/symbols etc for inclusion on the signs at no cost using the data collected through Spencer Park’s recent coastal public safety assessment.

119 BL020 Beach Access

Beach Access. Surf Life Saving New Zealand would like to reinforce our support of a) controlled (gated) vehicle access onto the beach (with permit system for authorised users) and b) the policy that all access tracks will be defined/formalised to reduce informal access over the active dune etc. The benefit of this, from a safety perspective, is that if formal access ways are also signposted, then all beach users get to see the hazard information displayed on the signage before they get on to the beach. Where there is 'free for all' access over dunes, it is very hard to manage safety messaging, which leads to a lower level of coastal public safety.

120 BL020 Car Parking Surf Life Saving New Zealand would recommend increasing the quantity of car parks relative to the safest bathing area of the (Spencer Park) beach. In the draft (master) plan there is relatively limited car parking to be available in close proximity to the surf club and 50-100 metres north or south (which is the safest space for aquatic users).


Surf Life Saving New Zealand recommend that horses/dogs not be permitted to use the beach within 100 metres of the designated safe swimming area during the summer season (for example, between 9am-7pm). Beach users should be able to use an area of the beach (sunbathing, beach games, sand castles, etc) and not have to come into contact with horses and/or dogs. With a significant amount of beach available both northward and southward, and daylight hours available both before and after beach patrols begin/end, this does not seem unreasonable. To achieve a non-thoroughfare by horses, it may be necessary to provide alternative beach access for horses at the south end of the (beach). Whilst many dog/horse owners are extremely well aware of the impact their animals have on other beach users, there are ongoing conflicts occurring on the beach, which need to be effectively managed by all stakeholders moving forward.

The beach (below the high tide mark) is ‘land’ that is not administered by the Council and is outside the jurisdiction of the draft plans, other than in an advocacy context. The Council, therefore, cannot control (or limit) access along the beach, but can control beach access points on Park land. It can, though, have bylaws in place for areas within its territorial area (that is the Christchurch City District), which extends outward from the land to the line of mean low water springs (MLWS). The preference is to limit the crossing points for horses across the coastal dune belt to one (at the Heyders Road end) and avoid having horses crossing parts of the Park where there will be potential conflict with other users and damage to land and vegetation, except along the designated horse routes shown on the landscape concept plan on Page 110 of the draft master plan.


We (Spencer Park Surf Life Saving Club Inc.) further endorse the issues raised (with respect to the surf lifeguard building at Spencer Park Beach) as detailed in Pages 120-124 (of the draft master plan).

These are issues raised by the Club. Master plan: pp.120-124


We recommend that the CCC undertake to work closely with us with the objective to rebuild a new surf lifeguard facility at or near its current location.

This will be addressed as part of the processing of the renewal of the site occupation agreement for the facility.


That the rebuilding of the Surf Life Saving Club building be included under Proposed Developments, Page 106 (of the draft master plan).

At this point in time, the proposed rebuilding of the surf club building is not a Council-initiated project, but rather a proposal by an existing Park occupier, which is being considered in the process of renewal of the occupation agreement. This is why it is not included in the Spencer Park and South Seafield Park landscape concept.

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125 BL021 Park Access We support the proposed new Park road layout in order to effectively direct traffic to (pedestrian) beach access (beside) the surf life saving club. This is very important as the current beach access point at the end of Heyders Rd leads the public to an un-patrolled area of the beach some 300 metres north of the patrolled area. We recommend that within the new road layout, (that access to) the (section of the) existing Heyders Road (proposed to be stopped, but the surface retained,) be limited to further ‘encourage’ beach goers to proceed to the patrolled area at the surf club location.We recommend that additional signage be erected to properly direct public to the patrolled beach swimming area, this includes clearer signage and routes from the main picnic area and camping ground. We recommend that provisions are made for additional car parking (in proximity to) the surf life saving club. The existing car park will not be enough when you consider the intent to redirect public parking from the end of Heyders Road to the surf club.

The intention, with the proposed roading realignment in Spencer Park, is to shift the destination focus for vehicles to the surf club location and Bottle Lake Forest Park, but not to restrict vehicle access to the Heyders Road end. Rather, the Council is seeking to encourage a shift in focus through road design and signage. It is not intended to restrict in any way access, other than to motorised vehicles, along the section of Heyders Road proposed to be stopped. As part of detailed site design planning, if the proposed development is included in a future LTCCP, the level of requirement for facilities such as parking areas will be undertaken.



Horse access on the beach – this is an ongoing concern from a public safety point of view and the master plan has not addressed this. During the summer months, we continue to observe the inappropriate manner by which some horse riders are riding through a concentrated public area of the beach. We recognise that the beach is for use of all (the) public, which includes a number of different recreational activities; however, a number of incidents (occur) every year. Spencer Park Beach has been used for many years by horse trainers (with sulkies) and recreational horse riders and we do not want to prevent them from using the vast stretch of beach; however, we must ensure that the use of horses is properly regulated in the best interest of public safety. We use a very small portion of the beach (approx 500 metres of beach in front of the club) for the provision of public safety and to carry out our club activities and feel that horses should not be permitted within this small area during certain times. They have 5 kilometres of free beach north and 5 kilometres south of the club, which should give horse riders ample space to meet their needs.


The (Spencer Park and South Seafield Park landscape) concept plan (Page 110 of the draft master plan) clearly shows horse riding routes in both directions from the Heyders Road beach access. We strongly oppose this concept of ‘free’ access (for horses) and make the following suggestions: • Only allow ‘free’ access during certain times of the year and during certain hours of the day during the warmer months, much like dog control. • When accessing the beach from Heyders Road, limit the direction to the north only, during the limited periods. • Create another horse access point south of the surf life saving club (adjacent (to the proposed) southern car park area, (Proposed Development 3, Page 107, draft master plan)) and limit the direction to the south only, during the limited periods. • Provide a horse track to link these two access points. • Impose fines / penalties of non compliance. We feel that this compromise is in the best interest of the public, (for) which we as a club provide a volunteer service to protect. The Spencer Park and Bottle Lake area provides an extensive array of horse tracks and beach area for what is a small portion of recreational users of the area and this must be considered when areas of conflict are being addressed.

The beach (below the high tide mark) is ‘land’ that is not administered by the Council and is outside the jurisdiction of the draft plans, other than in an advocacy context. The Council, therefore, cannot control (or limit) access along the beach, but can control beach access points on Park land. It can, though, have bylaws in place for areas within its territorial area (that is the Christchurch City District), which extends outward from the land to the line of mean low water springs (MLWS). The preference is to limit the crossing points for horses across the coastal dune belt to one (at the Heyders Road end) and avoid having horses crossing parts of the Park where there will be potential conflict with other users and damage to land and vegetation, except along the designated horse routes shown on the landscape concept plan on Page 110 of the draft master plan.


128 BL022 Roads (Close) Heyders Road off from the (Spencer) Park entrance way. Presumably the submitter means stopping the legal road from that point and managing the road as a park road, instead of as a public road through the park. Would give the park managers more ability to control access, particularly after hours, by, for example, installing a gate at the park entrance, but this level of restriction may not be acceptable to all. Would also put the park road management cost on to the Council's Transport and Greenspace operational budget.

129 BL022 Park Access (Have) a better bus service out (to Spencer Park) from Northlands and The Palms (shopping centres, and) on a more direct route.

130 BL023 Dogs How will (the dog policy/bylaw) be enforced, as there is no control over dogs at present?

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(Keep) the pines on (Brooklands) spit as they stabilise the dunes; (remove) all poisoned dead trees ... as they are a huge fire risk, and they are falling over on their own in areas where people go.

The intention is not to remove the main body of trees towards the pine tip, but instead invasive wilding pines near the inner tip of Brooklands Spit, as well as scattered trees further south along the spit. Active removal would be costly and impacting on the environment. Also, the areas where trees are being poisoned are isolated from where people will be.


Dredge key areas of (the estuary) to help water flow for boating and fish. This is a matter for Environment Canterbury to consider, and not something the draft parks and open space plans advocate - the focus, instead, is on natural processes taking place.

133 BL023 Historic Sites Preserve and respect the graveyard in the dunes along (the) walkway (through Seafield Park).

With the planning for, development of, and provision of recreational activities in, the parks and open space areas covered by the draft plans, all cultural and historic sites that are significant and known to be present should be taken account of, wherever possible, including through receiving specialist advice, as part of good practice.


Stop camping anywhere on (Brooklands) spit. Stop all fires being lit in this area and vehicles accessing the (estuary) side of the spit.

These are all unauthorised activities, and the long term objective will always be to manage these with sufficient resources. This will helped when the tenure of Brooklands Spit is transferred to the CCC and is classified as scenic reserve, as proposed in the draft master plan.

135 BL023 Land Tenure The Crown should maintain control and ownership of land etc in this area, not the Christchurch City Council.

Areas below Mean High Water Springs (MHWS), that is, in the Coastal Marine Area, are Crown land. Much of the area above MHWS is already land owned by the CCC and classified as reserve under the Reserves Act 1977. Other areas, such as Brooklands Spit, proposed to come to the CCC, is already managed by the CCC. The CCC works with the other agencies responsible for public areas - ECan and Doc - to achieve integrated management of these areas according to legislation.

136 BL023 Board Walk The position of the boardwalk on the plan approved by the Shirley/Papanui (Community) Board is the only one that will offer an experience to the public worth the cost of this structure.

Master plan: p.96

137 BL023 Facilities There should be no more commercialisation in the Spencer Park/camping (ground) area. This area is about families spending time together. A cafe will detrimentally affect the values set out by the Council.


The cost of the Ranger's office upgrade seems very excessive.

139 BL024 Dogs It is understandable that dogs are prohibited in Seafield Park due to wildlife habitat. There are, however, many homes in Brooklands with dogs. Could there be a small area incorporated as a dog park - perhaps Harbour Reserve? At present we have to drive considerable distances to let our dog experience the freedom, fun and socialisation of a dog park available in other areas. The dogs are not noisy - they are too busy having fun and owners are still responsible for cleaning up after them. Just needs a fenced area.

The Dog Control Policy 2008 limits dog activity in the area, and what is allowed is for dogs to be on a leash only. A city-wide review of the need and opportunities for dog dedicated areas is planned to be undertaken at some stage.


140 BL024 Consultation As (the) homeowner adjacent to (the proposed) decked area at end of Harbour Road, I would like to be consulted as to the detailed plans for construction and landscaping that will adjoin my property. I support the proposal as it will enhance a particularly ugly area; that is, the end of Harbour Road.

All statutory requirements for consultation will be met. Master plan: pp.95-98

141 BL025 Naming (Draft Master Plan) Proposal P1 (Māori naming and involvement of Ngāi Tahu): Agree, but consideration should also be given to Early European History where appropriate.

Master plan: p.i

142 BL025 Mahinga Kai (Draft Master Plan Proposal) P2 (Mahinga kai values): Wherever possible, economic species habitat (and) mahinga kai should be enhanced and restored.

Master plan: p.i


(Draft Master Plan Proposal) P4 (Research and monitoring tangata whenua values): Monitoring should be extended to include sedimentation and other aspects of mahinga kai.

Master plan: p.ii

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144 BL025 Spencer Park; Seafield Park

(Draft Master Plan Proposals) P5 to P24: Agree with all development proposals for Spencer Park and Seafield Park).

Master plan: pp.ii-v

145 BL025 Facilities (Draft Master Plan Proposal) P28 (Observation platform/bird hide): Would like to see a number of observation platforms around (the estuary and) on walkways.

Master plan: p.vi


(Draft Master Plan Proposals) P25 to P34 (Planning - Brooklands Lagoon): Agree with.

Master plan: pp.v-vi


(Draft Master Plan Proposal) P37 (Protect and manage Brooklands Spit as one landscape/ecological unit): Support.

Master plan: p.vii


(Draft Master Plan Proposal) P41 (Control of activity on Brooklands Spit): Consider ‘no-go’ areas during critical (bird) nesting periods.

Master plan: p.vii


Restoration, weed control (is) important (on Brooklands Spit). Master plan: p.vii


Draft plans are very comprehensive documents.

151 BL026 History We submit that due to this history that the association of the Water Sports Club has with the lagoon and the associated land, (this) should be recognised in the (Seafield Park) Management Plan (/ draft master plan) and that this plan should provide for the continued operation of the Club in the locality so that it may continue to turn out waterskiing competitors of a national standard.

The Seafield Park Management Plan refers only to the reserve areas that make up the Park, and not to activity on private land. Although the master plan employs a more encompassing integrated approach, covers a wider area and a range of resources, it is still dealing with just public land and its use. Also, although mention is briefly made of recreational activities in places such as the estuary, including various water sports, the plan's focus is on highlighting key issues and raising proposals for these public areas. Due to this, and in order to keep the plan smaller and focused, there is minimal mention of history in the draft master plan. If we highlighted the Christchurch Water Sports Club history and operations, we would need to give copy to other groups too. There is nothing to stop the CWSC writing its own historical account, though.


... the Christchurch Water Sports Club has a long standing history with the site that is of regional and national importance in terms of sporting history and this relationship should continue to be recognised in the Seafield Park) Management Plan(/draft master plan). We submit that, as a minimum, this relationship is recognised by making the following amendments to the draft (master) plan. Page 48 - Recreation. This section should be amended to reflect the long standing history of the Water Sports Club and its importance to the history of New Zealand Water Skiing Champions. We will be happy to provide you further details of this history. The planning objectives and values for the area are on Page (5) of the (draft master plan) document. We request that an additional value is added along the lines of: “recognising the long standing history of the Christchurch Water Sports Club with Brooklands Lagoon and Lot 1 DP 27026 and the role this location has played in local and national sporting history”. An additional objective should also be inserted along the lines of – "Enable the Christchurch Water Sports Club to be able to continue to utilise the lagoon and its surrounds to practice and train so that they may continue to produce competitors of a national standard while ensuring that these activities occur in a manner complementary to protecting the natural values of the area. This may involve providing exclusive use days and/or areas for the use of club only".

The Seafield Park Management Plan refers only to the reserve areas that make up the Park, and not to activity on private land. Although the master plan employs a more encompassing integrated approach, covers a wider area and a range of resources, it is still dealing with just public land and its use. Also, although mention is briefly made of recreational activities in places such as the estuary, including various water sports, the plan's focus is on highlighting key issues and raising proposals for these public areas. Due to this, and in order to keep the plan smaller and focused, there is minimal mention of history in the draft master plan. If we highlighted the Christchurch Water Sports Club history and operations, we would need to give copy to other groups too. There is nothing to stop the CWSC writing its own historical account, though. Also, in addition to not including objectives promoting private activity on private/public land, the estuary, and the activities on it, is addressed in plans administered by Environment Canterbury and the Department of Conservation. The Christchurch City Council, through the draft master plan, is able to advocate actions/proposals to those administering agencies.

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(Water) skiers have to compete with the jet skiers who use (the Christchurch Watersports Club) slalom courses as a fun area and they also now go over our jump, which has resulted in extensive damage (even after being asked not use both areas). Jet skiers even head down (to the southern part of the estuary) past our slalom course at enormous speed.

The rules for operating motorised vessels or motorised vehicles in the Coastal Marine Area came into effect with the Regional Coastal Environment Plan for the Canterbury Region becoming operative on 30 November 2005. Also, the Environment Canterbury Navigation Safety Bylaws 2005 control, for safety and navigation purposes, vessels operating in the Brooklands Lagoon estuary. Inappropriate vehicle use in the estuary and on the surrounding areas is an issue, and this has been raised in the draft master plan. One of the purposes of the plan is to highlight this issue through documentation, and, through a planning proposal, re-emphasise the requirement that there be no motorised wheeled/normally land-based recreational vehicles in the estuary, other than those used for official or authorised purposes.


We would like to get back to where the Christchurch Watersports Club had the exclusive use of the area from the jump downwards inclusive of our two slalom courses (which is adjacent to our land) …

The Regional Coastal Environment Plan for the Canterbury Region 2005 and the Environment Canterbury Navigation Safety Bylaws 2005, which are administered by Environment Canterbury, apply to recreational activity on the estuary. Any comment on use of the estuary would need to be put to Environment Canterbury.

155 BL026 Land Acquisitions

We have had previous discussions with the CCC in regard to either selling the land to the CCC or transferring the title of the land to the CCC in lieu of the Council providing us (the Christchurch Watersports Club) with a more suitable site for us to use for waterskiing. One area which was to be considered was Lake Roto Kohatu (or perhaps other land in that area which could be made available to us exclusively for water skiing). This proposal would still be preferred as it gives the CCC the opportunity to complete the link (between North and Mid-Seafield Parks). Our land creates an obstacle for the Council for any future development of that area. We could alternatively sell the land to a third party, who is most likely to develop the site and would be less open to enabling (the) Council to obtain access for walkways or any other recreational purposes.

This has been considered in previous years by Council staff. Purely from the point of view of "filling the gap" in the Seafield Park open space resource and guaranteeing permanent continuous public access between Spencer Park and the Styx River mouth, this land is a strategic area for potential future negotiations for purchase to add to the Park. Also, some of the better native vegetation communities in the area occur on this land. On these grounds, the reopening of considerations for this land is supported by planning staff, but it is acknowledged that this will need to be considered within the context of organisational priorities for open space acquisition.

156 BL026 Land Acquisitions

We (the Christchurch Watersports Club) would be interested in ... finding an alternative suitable area for our training and club activities, which would potentially benefit both parties. The area as stated above that would be the most desirable to relocate to would be Lake Roto Kohatu or in the vicinity of this lake (at the end of Sawyers Arms Road). We would also be happy to work in conjunction with another water sport activity in achieving this. The water ski area that we would need to achieve this would be an area that has an abundance of water close to ground level, a lake size of 800 metres long, by 75-100 metres wide and 1.5 metres deep.

This will be a 'condition', it appears, of any potential future successful negotiated acquisition of the Christchurch Watersports Club owned land - that is, finding a new site for their activity.


There is already a walkway that ... encroaches on our land (-) in the past we have had discussions with the CCC regarding the (public's) access across our land - we never gave written permission for this access to occur, yet the walkway is still encroaching on our land and being used by the public with no remuneration to our Club to this date. We have also been advised that the Christchurch Watersports Club is legally liable if anyone injured themselves on our land while using this walkway, and the Club are therefore considering ensuring this walkway (is) fenced off in the near future.

There are options for public access to bypass this land via a circuitous route on roads on the western side, and via Crown land and unformed legal road on the eastern side (subject to the tide), but this is not as good as a route through the land in question.


The (draft master and Seafield Park management plans are) supported because encouraging public access to, and activity in, reserves provides a range of positive benefits to public health.

159 BL027 Facilities It is recommended that the following public health issues are considered in relation to the (draft master and management plans); and that, where possible, the recommended facilities are provided: Mosquitoes: The existence of suitable mosquito larvae habitat, particularly areas of water conducive to mosquito breeding, relatively close to international ports of entry such as Christchurch airport may enhance the potential for exotic mosquitoes to become established in Canterbury and become vectors of mosquito transmitted human disease.

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160 BL027 Facilities It is recommended that the (following further) public health issues are considered in relation to the (draft master and management plans); and that, where possible, the recommended facilities are provided: Safe drinking water and other water sources: (Visitors to) rural and semi rural environments may have expectations of town quality drinking water. If ... not available, they may unwittingly drink unsafe water and thus be at risk of waterborne diseases. The good quality of the Brooklands settlement and Spencer Park reticulated water supplies is acknowledged, but if there are any other water sources used by visitors to the (public parks) it needs to be made clear which are suitable for drinking and which are not. Public toilets: The public’s use of (parks), particularly those remote from alternative facilities, can bring expectations that toilet facilities will be available. It is important that where toilet facilities are not available onsite then visitors are pre-warned on websites, and in promotional material, and by signage at the site itself. Where alternative toilet facilities are available off-site but nearby, then this information should also be provided. Shade policy and trees: The efforts of Christchurch City Council to retain and replace trees on the (parks) are supported, particularly in relation to the public health benefits of providing shade and minimising exposure to excessive UV radiation. In picnic, play and similar areas where natural shade (trees) is not available, then alternative shade should be provided. Facilities for the disabled: Disabled members of the public who visit (parks) may have expectations of the disabled facilities available. If the disabled are to be catered for it is recommended that a range of facilities, including disabled toilets, are provided.

161 BL027 Facilities It is recommended that the (following final) public health issue is considered in relation to the (draft master and management plans); and that, where possible, the recommended facilities are provided: Children’s playgrounds: The provision of children’s playgrounds and other facilities that encourage outdoor activity among the young, and not so young, is supported. Constructed and maintained to appropriate safety standards, such as NZS5828:2004, they provide positive health benefits with minimal risk.


Environment Canterbury supports the development of a Brooklands Lagoon/Te Riu O Te Aika Kawa Area Parks Masters Plan.

163 BL028 Dogs Environment Canterbury advised Christchurch City Council staff prior to the review of the CCC Dog Control Bylaw 2008 that dogs, except for gun dogs during the game bird hunting season, should be prohibited from its lands, identified ... as ... Reserve 4231, ... Pt Res 4234 and ... Pt Rural Section 7428. Map reference 4 Pt Rural Section 7428 This was not only to ensure the protection of non-target birds, which include threatened native species from uncontrolled dogs, but also to ensure that target species carcasses are removed from the saltmarsh rather than remain un-retrieved to support musteloid species. There is some ambiguity within the table on Page 29 (of the draft master plan) and the accompanying map on Page 30. The table identifies that dogs are prohibited/leashed in the Brooklands Spit and Lagoon area, except for gun dogs during the game bird hunting season, while dogs are prohibited/leashed (at the) Styx River Mouth, with no provision for gun dogs during game bird hunting season. However, on the map on Page 30 there is no distinction between these areas. Environment Canterbury has not changed its position on this matter.

All content in the draft master plan relating to the Christchurch City Council's dog policy and bylaw comes from information that is accessible by the public on the Council's website. The table reference on Page 28 of the Dog Control Policy 2008 referring to dogs needing to be on a leash on the walking track along the stock bank in the "Styx Rivermouth" Sub Area is noted. Environment Canterbury (ECan), in its submission, indicates it had advised prior to the bylaw review that dogs, except for gun dogs, be prohibited on its land (parcels of which are identified in its submission). Council staff can advise that the walking track referred to is on legal road and not on ECan's land.


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164 BL028 Tracks - Cycling; Tracks - Walking

Environment Canterbury supports the establishment of walkways and cycleways from Seafield Park and the Styx River Corridor into the Waimakariri River Regional Park(, and, )specifically, the proposed mountain bike route between the Waimakariri River Regional Park and Bottle Lake Forest Park (Page 109 (draft master plan)).

Master plan: pp.51 and 109


Environment Canterbury supports the transfer of reserve land for river protection administered by Environment Canterbury to the Department of Conservation, (as raised in Brooklands Spit Planning and Management Proposal 2).

Planning and Management Proposal 2: "Facilitate the process for this reserve for river protection purposes, which is administered by Environment Canterbury, being transferred to the Department of Conservation as Crown land, then for the part that is above MHWS to be transferred to the Christchurch City Council for addition to scenic reserve.".

Master plan: p.82

166 BL028 Manage-ment; Partnerships

Environment Canterbury has established a Memo of Understanding with the Department of Conservation (as land owners or managers) to provide for the protection of the Waimakariri River salt marsh by incorporating its day to day management into the Waimakariri River Regional Park. This will allow for a consistent and collaborative approach to the management of the Waimakariri River biodiversity while ensuring Environment Canterbury and the Department of Conservation objectives and statutory responsibilities for the area are met. The MOU also provides for policy and plans for the management of the saltmarsh to be consulted with the wider community for inclusion into the Waimakariri River Regional Park Management Plan. Environment Canterbury supports the investigation into the feasibility and appropriateness of constructing a boardwalk for public access over the Brooklands Lagoon mudflat between the end of Harbour Road and the Styx River mouth.

Update Waimakariri River/Styx River/Brooklands Lagoon confluence planning proposals in the draft master plan to reflect Environment Canterbury's current advice provided in its submission.

Master plan: pp.51 and 109

167 BL029 Manawhenua This submission has been prepared by Mahaanui Kurataiao Ltd (MKT) and lodged on behalf of Te Ngāi Tūāhuriri Rūnanga and Te Hapū O Kati Urihia Ahu Whenua Trust (the Rūnanga and the Ahu Whenua Trust). Te Ngāi Tūāhuriri Rūnanga has manawhenua and represents tangata whenua within the Brooklands Lagoon / Te Riu O Te Aika Kawa area covered by the master plan. Te Hapū O Kāti Urihia Ahu Whenua Trust represents the hapū and whanau of Kāti Urihia, that have manawhenua within this area and whose tūrangawaewae is Puharakekenui Maori Reserve (MR982).


The Rūnanga and Ahu Whenua Trust generally support and acknowledge the purpose and approach of the draft master plan; support many of the objectives and planning provisions in the plan; and support the general scope of the master plan and the inclusion of the lower waterways, river mouth, estuary and spit, along with the particular parks and open space components of this area. This is preferable to taking a piecemeal approach to managing open space in this area.

169 BL029 Management The features within the planning area - the lower Styx River/Puharakekenui, Waimakariri River mouth, coastal estuary (Brooklands Lagoon/ Te Riu 0 Te Aika Kawa) and Kairaki Spit - consist of a dynamic coastal environment, hydrological system and vulnerable ecosystems that demand a holistic and integrated approach to management. The important cultural values associated with this place, combined with the pressure for increasing recreation and development of the area, mean that an integrated approach to protection of natural and cultural values is needed.

170 BL029 Values The Rūnanga and Ahu Whenua Trust ... seek, in general, that, where protection of natural and ecological values is proposed, tangata whenua values are also included, as this will ensure appropriate recognition to Ngāi Tahu interests.

In order to recognise and respect the Crown's responsibility to take appropriate account of the principles of the Treaty of Waitangi and to maintain and improve opportunities for Māori to contribute to local government decision-making processes, the Local Government Act 2002 (LGA) provides principles and requirements for local authorities that are intended to facilitate participation by Māori in local authority decision-making processes. Under s77 of the LGA, the local authority, where there is the need for a significant decision in relation to land or a body of water, must take into account the relationship of Māori and their culture and traditions with their ancestral land, water, sites, waahi tapu, valued flora and fauna, and other taonga.

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171 BL029 Master Plan Vision

The Rūnanga and Ahu Whenua Trust support the general thrust of the vision for the master plan, but suggest it could be worded as a more 'visionary' outcome statement and include the traditional Māori name for this place, as follows: “The natural, landscape, cultural and recreational values of the Brooklands Lagoon/ Te Riu o Te Aika Kawa area are protected and enhanced in the integrated management (of) parks and open spaces.”

Replace the vision on Page 5 ("The Brooklands Lagoon area of parks and open space is managed through the application of a zoning approach for the differing natural, landscape, cultural and recreational values and uses that occur in the distinct parts of the area.") with the following text, as follows: "The natural, landscape, cultural and recreational values of the Brooklands Lagoon / Te Riu o Te Aika Kawa area are protected and enhanced in the integrated management of parks and open spaces."

Master plan: p.5

172 BL029 Styx River Planning

... it must be noted that the master plan does not directly relate to management of the Styx/Puharakekenui catchment. This also is a highly significant area for Ngāi Tahu, and there has been past deep concern that planning for this area has excluded the Rūnanga and the Ahu Whenua Trust. It is sought that the management planning for the Styx/Puharakekenui area takes into account the values and approach recommended for this area, and that more opportunity for involvement of the Rūnanga and the Ahu Whenua Trust is created and developed through working with MKT and engagement with the Rūnanga and Ahu Whenua Trust at appropriate times.

To be forwarded to Council staff dealing with the planning for the Styx River.

173 BL029 Integrated Catchment Planning

Another important aspect of Council work for this area is in the integrated catchment management planning process (ICMP) - and greater integration between this master plan, the reserves planning and management for the Styx/Puharakekenui area, and the Styx ICMP and coastal ICMP is to better reflect the Ngāi Tahu philosophy of 'ki uta ki tai' ('from the mountains to the sea'). The Rūnanga and the Trust are therefore taking this opportunity to identify another area of Council planning and management that they wish to ensure involves appropriate engagement from Council.

To be forwarded to Council staff dealing with the planning for the Integrated Catchment Management Plans.


The tangata whenua section currently lacks specific recognition of the original tupuna of the area and provisions for the protection of cultural heritage sites from development and management activities within Council parks and reserves within the Master Plan area. It is understood that this was an inadvertent omission in the preparation of the draft. It is therefore requested that the following text be included in the tangata whenua section as follows: Page 36: “ .... In the case of Puharakekenui Reserve, the list of original owners is small, with the Te Aika whanau comprising around half of the original ownership, and four other whanau represented - Whitau Kahaki, Te Hua, Rehu and Tarapuhi.” Page 38 in Ngāi Tahu planning objectives after bullet 3 - new bullet point: “protecting wahi tapu and cultural heritage sites from earthworks and other development.”

Edit the text at the end of the second to last paragraph on Page 36 of the draft master plan, as follows: "In the case of the Puharakekenui Reserve, the list of original owners is small, with the Te Aika whanau around comprising half of the original ownership, with and four other whanau represented - Whitau Kahaki, Te Hua, Rehu and Tarapuhi." Add a new Ngāi Tahu objective after the third bullet point in the middle column on Page 38 of the draft master plan, as follows: "Being aware of wahi tapu and cultural heritage sites that may be affected by planned earthworks and other development, and taking advice from Ngāi Tahu on avoiding adverse effects on such sites." The nature of the Ngāi Tahu objectives in the draft master plan is to highlight the need for Council to take heed of information on tangata whenua values, rather than necessarily being directly involved itself in wahi tapu and cultural heritage site protection. “Taking heed of information” may mean that measures are authorised to be put in place to ensure such sites are not impacted upon. It needs to be noted here that the wording suggested to be employed differs from that requested to be inserted by Ngāi Tahu.

Master plan: pp.36, 38

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To support the (proposed to be added Ngai Tahu planning objective), it is also requested that the following planning proposal be included in the master plan: “Protection of cultural heritage sites The Council consult with the Te Ngāi Tūāhuriri Runanga and Te Hapū O Kāti Urihia Ahu Whenua Trust about proposed development activities in parks and reserves to avoid adverse affects on cultural heritage sites.” “The Council adopt an Accidental Discovery Protocol (ADP) for development and maintenance activities involving earthworks (including planting) in parks and reserves so that in the event cultural materials or koiwi (human remains) are discovered, work is stopped immediately and Te Ngāi Tūāhuriri Rūnanga, Te Hapū O Kāti Urihia Ahu Whenua Trust, and New Zealand Historic Places Trust, are contacted for advice.”

Add a new planning proposal in the Tangata Whenua section of the draft master plan, as follows: "Protection of cultural heritage sites The Council consult with the Te Ngāi Tūāhuriri Runanga and Te Hapū O Kāti Urihia Ahu Whenua Trust about proposed development activities in parks and reserves to avoid adverse affects on cultural heritage sites.” “The Council adopt an Accidental Discovery Protocol (ADP) for development and maintenance activities involving earthworks (including planting) in parks and reserves so that in the event cultural materials or koiwi (human remains) are discovered, work is stopped immediately and Te Ngāi Tūāhuriri Rūnanga, Te Hapū O Kāti Urihia Ahu Whenua Trust, and New Zealand Historic Places Trust, are contacted for advice."



It is requested that the title of Planning Proposal 1 (Page 39 of the draft master plan) be re-written as follows: “Naming, and involvement of Ngāi Tahu in the development of amenity features in public spaces, in the Brooklands Lagoon/Te Riu O Te Aika Kawa planning area.”

Edit Planning Proposal 1 in the Tangata Whenua section of the draft master plan, as follows: "Naming, and involvement of Ngāi Tahu in the development, of structures amenity features in public spaces in the Brooklands Lagoon/Te Riu O Te Aika Kawa planning area."

Master plan: p.39


It is requested that Proposal P1 (in the Summary of Proposals section) be amended as follows: "Naming, and involvement of Ngāi Tahu in the development of amenity features in public spaces, in the Brooklands Lagoon/Te Riu O Te Aika Kawa planning area." "Use of Māori names in documents and information/publicity material, provision for tangata whenua to give advice on public space naming, and proposal for Christchurch City Council to collaborate with tangata whenua to investigate establishing a river trail (Te Ara Toi, Te Awa Whakaairo) along the Styx River Puharakekenui with Ngāi Tahu stories/markers/artworks."

Amend the text for Proposal P1 in the Summary of Proposals section of the draft master plan, as follows: "Maori naming, and involvement of Ngāi Tahu in the development, of structures amenity features in public spaces in the Brooklands Lagoon/Te Riu O Te Aika Kawa planning area." and "Use of Maori names in documents and information/publicity material, provision for local Maori1 tangata whenua to give advice on public space naming, and suggestion for the Christchurch City Council to consider a possible collaboration with local Maori tangata whenua to investigate establishing a river trail along the Styx River/Puharakekenui with Ngāi Tahu stories/markers/artworks." and remove accompanying footnote.

Master plan: p.i


It is requested that Proposal P3 (in the Summary of Proposals section) be amended as follows: "Tangata whenua input to parks planning and management, and tangata whenua values taken into account." "Tangata whenua are involved in further planning ... "

Amend the text for Proposal P3 in the Summary of Proposals section of the draft master plan, as follows: "Maori Tangata whenua input to parks planning and management, and tangata whenua values taken into account.." and "Local Maori Tangata whenua are involved in further planning ...".

Master plan: p.i


Inclusion of a tauparapara (incantation or karakia) in the master plan would provide a direct acknowledgement of Ngāi Tahu manawhenua and tupuna and in doing so, confirm and enhance tangata whenua input into this document. It would be greatly appreciated if the Council would consider adding a tauparapara at the front of the document. If this is agreed, MKT will liaise with Ngāi Tūāhuriri to provide this to include in the preparation of the final master plan.

Recommend that a tauparapara (prayer) be added to the front of the master plan document.


The Rūnanga and Ahu Whenua Trust support, in principle, Planning Proposal 3 on Page 82 (of the draft master plan) to initiate the transfer of the Crown land area at the southern end of Brooklands Lagoon/Te Riu O Te Aika Kawa (Area 3 on (the) plan on Page (78)) to be transferred to the Council for the purpose of adding (it) to a proposed scenic reserve. Ngāi Tahu strongly supports the protection and management of the area by Council. The Rūnanga and Ahu Whenua Trust wish to be consulted prior to the Council initiating the transfer process to identify options to achieve tangata whenua objectives in the designation and planning for the use of this highly important area. It is therefore requested that the following proposal be incorporated into the Master Plan: "Consult with Te Ngāi Tūāhuriri Rūnanga and Te Hapū o Kāti Urihia Ahu Whenua Trust prior to initiating the process of transfer of the Crown land area at the southern end of Brooklands Lagoon/Te Riu O Te Aika Kawa to identify options to achieve tangata whenua objectives in relation to this area.".

Amend Planning and Management Proposal 3 in the Coastal Strip (including Brooklands Spit) section of the draft master plan, as follows: "Initiate procedures to have the part of the Crown land area at the southern end of Brooklands Lagoon that is above the MHWS to be transferred to the Christchurch City Council for the purpose of adding to a proposed future scenic reserve covering Brooklands Spit. Consult with Te Ngāi Tūāhuriri Rūnanga and Te Hapū o Kāti Urihia Ahu Whenua Trust prior to initiating the process of transfer of the Crown land area at the southern end of Brooklands Lagoon/Te Riu O Te Aika Kawa to identify options to achieve tangata whenua objectives in relation to this area.".

Master plan: p.82

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181 BL029 Management ... the Ahu Whenua Trust have strong interests in the management of any land, and the lagoon, along the eastern boundary of Puharakekenui Maori Reserve (most of which is currently within the area of Crown land (at the southern end of the estuary)). The Ahu Whenua Trust wish to be involved at the outset of any proposal to change the status of this land and the provision of any accessways or recreational facilities in this particular area. This is to ensure that the rights of access and use of the (Maori) Reserve will not be adversely affected by any proposals for the adjoining area.

Other than the area of Crown land at the southern end of Brooklands Lagoon (that is, the part above MHWS), there is no intention, or ability, of the Christchurch City Council to change the area's status or develop facilities in that area, because the area is in the Coastal Marine Area. Developments proposed to be undertaken by the Council, such as tracks and plantings, will be on Council held/administered land (scenic reserve or legal road).

182 BL029 Management The Rūnanga and Ahu Whenua Trust ... support, in principle, ... Brooklands Spit/Kairaki ... is managed as a single landscape and ecological unit. However, the Rūnanga and the Ahu Whenua Trust strongly oppose the addition of this land to the Spencer Park Reserve at any stage.

The proposal is for all land making up Brooklands Spit that is above MHWS to ultimately be transferred to the Christchurch City Council and classified scenic reserve. It will be a separate reserve to Spencer Park, which will remain a recreation reserve.

183 BL029 Consultation Ngāi Tahu request that Council ensure appropriate consultation with Te Rūnanga o Ngāi Tahu and Te Ngāi Tūāhuriri Runanga in its work with other agencies in the receiving of or transfer of lands, to ensure compliance with the Ngāi Tahu Claims Settlement Act, and to enable the identification of opportunities for collaboration and co-management with Ngāi Tahu to be identified and explored. It is important that this occurs before land is designated for reserve purposes, to ensure the statutory classification can adequately reflect Ngāi Tahu interests where appropriate.

All statutory requirements for consultation will be met.


The Rūnanga and Ahu Whenua Trust strongly support the ... Planning Proposal on Page 77 to ban all motorised recreational craft from the (estuary)

The planning proposal for Brooklands Lagoon is edited, as follows: "Ban all motorised wheeled/normally land-based recreational vehicles from Brooklands Lagoon and its marginal areas (not including such vehicles used for official or authorised purposes). The sensitive wetland areas of Seafield Park, and parts of Brooklands Lagoon, have been severely damaged in the past by recreational vehicles. The banning of motorised wheeled/normally land-based recreational vehicles will promote the recovery of vegetation.". This proposal is simply reflecting, but intended also to emphasise, the rules for operating motorised vessels or motorised vehicles in the Coastal Marine Area, which came into affect with the Regional Coastal Environment Plan for the Canterbury Region becoming operative on 30 November 2005. Also, the Environment Canterbury Navigation Safety Bylaws 2005 control, for safety and navigation purposes, vessels operating in the Brooklands Lagoon estuary.

Master plan: p.77

185 BL029 Dogs The Rūnanga and Ahu Whenua Trust would like Council to review the bylaw controlling dogs if the existing permitted use continues to result in adverse effects on the natural and cultural values of the (estuary) and surrounding lands.

186 BL029 Management The Rūnanga and Ahu Whenua Trust also strongly support the planning proposals on Page 77 (of the draft master plan) that seek to protect the lagoon, mudflats, and its margins from degradation and to protect the wildlife and ecological values, and request that tangata whenua values be added to this.

Add to the third planning proposal in the middle column on Page 77 of the draft master plan, as follows: "For the Christchurch City Council to advocate that the Brooklands Lagoon and Lower Waimakariri River mudflats are managed in ways consistent with protection of wildlife and wider ecological and tangata whenua values.".

Master plan: p.77

187 BL029 Pests The Rūnanga and Ahu Whenua Trust are concerned about both plant and animal pests in the (Brooklands Lagoon) area and therefore support planning proposals that seek to control and eradicate these and, in particular, wish the Council to ensure that such programmes are put in place as soon as possible.

188 BL029 Proposal ... the Rūnanga and Ahu Whenua Trust strongly support the following planning proposals identified in the summary of proposals starting on page i: P1-4; P25; P26; P29-31; P32 (with agreement of tangata whenua - detail of concept needed); P33; P34 (with tangata whenua input); P35 & 36 (with appropriate Ngāi Tahu consultation); P37; P38 & 39 (with appropriate Ngāi Tahu consultation on the method proposed); P40; P41; P42; P44; P45 (needs further consultation with Ngāi Tahu); P46 (ensure appropriate Ngāi Tahu involvement).

Selected planning proposals from draft master plan: P32 ("Investigate excavating several shallow ponds within the dune areas alongside Brooklands Lagoon to provide additional bird habitat."); P34 ("Establish monitoring sites in Brooklands Lagoon."); P39 ("Undertake protective measures for beach nesting birds."); P45 ("Seek to protect the Styx Ponding Area from urban development and have it remain essentially as pasture."); P46 ("Develop a Memorandum of Understanding (MOU), or expand on an existing MOU, for the Waimakariri/Styx Rivers confluence area to formalise co-operation between Environment Canterbury, Department of Conservation and the Christchurch City Council for the care and management of the area.").

Master plan: pp.i-ix

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189 BL029 Development Impacts

The Rūnanga and Ahu Whenua Trust are concerned about the impacts of increasing residential development and use on the lagoon and waterways of the area, and wish the Council to ensure that development proposals include identification and assessment of the impacts of such developments on tangata whenua values when considering plan changes, subdivisions or land use.

Matter for consideration in the wider context than just the Brooklands Lagoon Area parks and open space planning.

190 BL029 Master Plan Adjustment; Seafield Mgt Plan Adjustment, Spencer Mgt Plan Adjustment

The use of the terms "Māori", "Ngāi Tahu" and "Tangata Whenua" should be consistent and appropriate, and the Rūnanga and the Ahu Whenua Trust request that Council staff work with MKT to ensure that the final plans contain appropriate use of these terms. Use of the following dual place names throughout the final master plan and park management plans would also be appreciated: Brooklands Lagoon/Te Riu O Te Aika Kawa Styx River/Puharakekenui Brooklands Spit/Kairaki It would be appreciated if macrons can be used correctly for Māori words used in the finalised master plan and management plans (MKT can assist in the identification of the correct use of Te Reo), including: Māori Te Hapū o Kāti Urihia Ahu Whenua Trust Te Ngāi Tūāhuriri Rūnanga Te Rūnanga o Ngāi Tahu Wāhi tapu Kī Uta Kī Tai Hapū Takiwā Tūpuna

Staff can work with MKT on correct pronunciation in the final plans. There is an issue with the use of the name of Puharakekenui (supported by Submitter BL029) to accompany the name Styx River, as the name of "Pūrākaunui" (supported by Submitter BL029) to accompany the name Styx River has been used in various documentation, including Council reports and leaflets, to do with environmental work concerning this river as part of the "Styx Project" launched in 1999, and is used by the Styx Living Laboratory Trust in its publications and also on the header bar of the "thestyx" website. This name appears to have not been formally adopted by the Council, following Council's naming policy (at this time, though, a naming policy document for the Styx River catchment is in preparation by the Council). Formal adoption of this name for the Styx River would mean adjustment of resource material and documentation referring to the environmental work being undertaken on the river. As "Pūrākaunui" used for the Styx Project work refers to the whole of the Styx River, and "Puharakekenui" applies specifically to the Māori place in the Brooklands Lagoon area, an option is to reflect the difference in the master plan, and for the name for the Styx River to be ultimately confirmed through the naming policy process. The staff suggestion is for two options to be considered: (1) all references in the draft master plan to "Styx/Puharakekenui River" to be replaced with "Styx-Pūrākaunui River"; (2) Council to defer the decision to the process and outcome of the naming policy, and for all references in the draft plans to the river to be to the "Styx River".

191 BL029 Seafield Mgt Plan Adjustment, Spencer Mgt Plan Adjustment

There is little direct recognition of Ngāi Tahu as manawhenua in the park management plans themselves, although they do refer to the Brooklands Lagoon/Te Riu O Te Aika Kawa Area Parks Master Plan. It is proposed that a summary of the tangata whenua section in the master plan be incorporated in both plans. In addition, the plans would benefit from consistent objectives and policies that recognise and provide for the values tangata whenua have in relation to these park areas. This allows these plans to work as stand-alone documents and is in keeping with the approach the Council takes with other reserve management plans.

192 BL029 Seafield Mgt Plan Adjustment

It is requested that the following section, titled 'Tangata whenua', be incorporated into the 'Overview' section in both plans (that is, to replace the section on 'Culture/Heritage' in the Seafield Park Management Plan). ''Tangata whenua In the area of this management plan, the tangata whenua ('people of the land') are Ngāi Tahu. The iwi of Ngāi Tahu comprises whanau who descend from both the northern ancestor, Tahu and the peoples who were here before the Ngāi Tahu southern migration - Ngāti Mamoe and before them Waitaha. Te Rūnanga o Ngai Tahu (TRONT) was established by the Te Rūnanga o Ngāi Tahu Act 1996 as the legal identity of Ngāi Tahu to represent the tribal collective of Ngāi Tahu Whānui. Te Rūnanga o Ngāi Tahu is made up of eighteen Papatipu Rūnanga, who represent the whanau and hapū interests of particular areas. For matters of local significance and local resource management issues, TRONT require engagement with the local Papatipu Rūnanga. Te Ngāi Tūāhuriri Rūnanga is the Papatipu Rūnanga for the area of Spencer Park/Seafield Park. In addition, the whanau of Kāti Urihia hapū of the Rūnanga have some specific interests, including property rights in the nearby Puharakekenui Māori Reserve."

Edit Management Issue 7 (in the Overview section) on Page 4 of the Draft Seafield Park Management Plan, as follows: "7. Culture/HeritageCultural/Heritage ValuesThere is a need to strike a balance between promoting the values of Seafield Park, along with facilitating public access to the Park for recreational and educational reasons, and ensuring the protection of sites of historic and cultural importance. Also, on the one hand, there is a lack of common public knowledge about such sites and values; on the other hand, it is necessary to ensure these sites and values are not impacted upon by public access, and that the wishes of those with a stake and interest in the sites and values are acknowledged and respected.Furthermore, the values and sites of historical and cultural importance are not exclusive to Seafield Park, but extend over a range of environments and land tenure in the wider area centred on Brooklands Lagoon. Therefore, planning for the historical and cultural values and sites also needs to be undertaken in this wider context. For information pertaining to this, see the Draft BrooklandsLagoon Area Parks Master Plan 2009 and, in particular, the Tangata Whenua section of that plan.".

Seafield mgt plan: p.4

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Insert the following text after the fourth paragraph on Page 2 of the Draft Seafield Park Management Plan 2009: "Tangata whenua In the area covered by the Draft Seafield Park Management Plan 2009, the tangata whenua ('people of the land') are Ngāi Tahu. The iwi of Ngāi Tahu comprises whanau who descend from both the northern ancestor, Tahu and the peoples who were here before the Ngāi Tahu southern migration - Ngāti Mamoe and before them Waitaha. Te Rūnanga o Ngai Tahu (TRONT) was established by the Te Rūnanga o Ngāi Tahu Act 1996 as the legal identity of Ngāi Tahu to represent the tribal collective of Ngāi Tahu Whānui. Te Rūnanga o Ngāi Tahu is made up of eighteen Papatipu Rūnanga, who represent the whanau and hapū interests of particular areas. For matters of local significance and local resource management issues, TRONT require engagement with the local Papatipu Rūnanga. Te Ngāi Tūāhuriri Rūnanga is the Papatipu Rūnanga for the area of Spencer Park/Seafield Park. In addition, the whanau of Kāti Urihia hapū of the Rūnanga have some specific interests, including property rights in the nearby Puharakekenui Māori Reserve. Park Management".


194 BL029 Spencer Mgt Plan Adjustment


Insert the following text after the last paragraph on Page 1 of the Draft Spencer Park Management Plan 2009: "Tangata whenua In the area covered by the Draft Spencer Park Management Plan 2009, the tangata whenua ('people of the land') are Ngāi Tahu. The iwi of Ngāi Tahu comprises whanau who descend from both the northern ancestor, Tahu and the peoples who were here before the Ngāi Tahu southern migration - Ngāti Mamoe and before them Waitaha. Te Rūnanga o Ngai Tahu (TRONT) was established by the Te Rūnanga o Ngāi Tahu Act 1996 as the legal identity of Ngāi Tahu to represent the tribal collective of Ngāi Tahu Whānui. Te Rūnanga o Ngāi Tahu is made up of eighteen Papatipu Rūnanga, who represent the whanau and hapū interests of particular areas. For matters of local significance and local resource management issues, TRONT require engagement with the local Papatipu Rūnanga. Te Ngāi Tūāhuriri Rūnanga is the Papatipu Rūnanga for the area of Spencer Park/Seafield Park. In addition, the whanau of Kāti Urihia hapū of the Rūnanga have some specific interests, including property rights in the nearby Puharakekenui Māori Reserve.".

Spencer mgt plan: p.1

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It is requested that the following section titled 'Ngāi Tahu associations and values' be incorporated into section 3 of both plans ('Issues' in Seafield Park Management Plan and 'Values and Issues' in Spencer Park Management Plan): “Ngāi Tahu associations and values Ngāi Tahu values are strongly connected to land, water and the natural environment, and are strongly linked to whakapapa relationships and historical associations. Values held for this area include wāhi tapu and wāhi taonga sites, the Puharakekenui Māori Reserve, ecological and mahinga kai values of the estuary and river and lands, the mauri of the area and the ecological integrity and quality of the land and water. Ngāi Tahu have associations with the Spencer Park/Seafield Park area that date from Waitaha times. Whanau of Ngāi Tūāhuriri trace their whakapapa (ancestry) to tupuna (ancestors) that had associations with the area, primarily through Urihia, son of Turakautahi (a son of Tuahuriri) and Hinekakai. Another tūpuna, a descendant of Urihia, is Te Aika. The traditional name of Brooklands Lagoon - Te Riu O Te Aika Kawa ("the area of Te Aika protocols or authority") - reflects the strong relationship of Te Aika and his descendants with this coastal estuary and the Puharakekenui (Styx River). The location of Puharakekenui Māori Reserve between the lagoon and the Styx River/Puharakekenui signals the strong turangawaewae (place of the people of the land) for the original grantees of the reserve - the tūpuna of the Te Aika, Whitau Kahaki, Te Hua, Rehu and Tarapuhi whanau - and their strong relationship with the resources of the area. The reserve was granted to acknowledge the loss of land and access to resources suffered by their tupuna who had established their traditional claim. Brooklands Lagoon/Te Riu O Te Aika Kawa and the Styx River/ Puharakekenui were highly valued for mahinga kai (gathering of food and other resources), including tuna, kanakana, koura and flax. The traditional relationships were, expressed through occupation, use and naming of areas. Today the Ngāi Tahu people of this area - Te Ngāi Tūāhuriri Rūnanga and the hapū of Kāti Urihia - continue to hold strong values for the area, its land, waters and the natural environment, as well as for their whakapapa (ancestral) connections to their tūpuna, cultural heritage and special sites. They continue to carry out their traditional cultural and spiritual practices in this area, including gathering of mahinga kai. The current owners of Puharakekenui Reserve also hold specific cultural and legal rights in relation to this land, and these are managed through a maori land trust called - Te Hapū O Kāti Urihia Ahu Whenua Trust. The Brooklands Lagoon/Te Riu O Te Aika Kawa Area Parks Master Plan, under which this reserve management plan sits, is significant for Ngāi Tahu in that it addresses the potential affects on tangata whenua values from use and development of the area, including Spencer Park/Seafield Park. Ngāi Tahu supports the broader integrated management and protection and enhancement approach toward ecological and cultural values of the Brooklands Lagoon/Te Riu O Te Aika Kawa area taken in the master plan. The master plan should be referred to for more information on Ngāi Tahu values and specific planning proposals that address tangata whenua issues and values in this area.

Insert the following text after the first paragraph on Page 17 of the Draft Seafield Park Management Plan 2009, and as a new sub-section in the "Values and Issues" section (starting on Page 22) of the Draft Spencer Park Management Plan 2009: "Ngāi Tahu associations and values Ngāi Tahu values are strongly connected to land, water and the natural environment, and are strongly linked to whakapapa relationships and historical associations. Values held for this area include wāhi tapu and wāhi taonga sites, the Puharakekenui Māori Reserve, ecological and mahinga kai values of the estuary and river and lands, the mauri of the area and the ecological integrity and quality of the land and water. Ngāi Tahu have associations with the Spencer Park/Seafield Park area that date from Waitaha times. Whanau of Ngāi Tūāhuriri trace their whakapapa (ancestry) to tupuna (ancestors) that had associations with the area, primarily through Urihia, son of Turakautahi (a son of Tuahuriri) and Hinekakai. Another tūpuna, a descendant of Urihia, is Te Aika. The traditional name of Brooklands Lagoon - Te Riu O Te Aika Kawa ("the area of Te Aika protocols or authority") - reflects the strong relationship of Te Aika and his descendants with this coastal estuary and the Styx River. The location of Puharakekenui Māori Reserve between the lagoon and the Styx River signals the strong turangawaewae (place of the people of the land) for the original grantees of the reserve - the tūpuna of the Te Aika, Whitau Kahaki, Te Hua, Rehu and Tarapuhi whanau - and their strong relationship with the resources of the area. The reserve was granted to acknowledge the loss of land and access to resources suffered by their tupuna who had established their traditional claim. Brooklands Lagoon/Te Riu O Te Aika Kawa and the Styx River were highly valued for mahinga kai (gathering of food and other resources), including tuna, kanakana, koura and flax. The traditional relationships were, expressed through occupation, use and naming of areas. Today the Ngāi Tahu people of this area - Te Ngāi Tūāhuriri Rūnanga and the hapū of Kāti Urihia - continue to hold strong values for the area, its land, waters and the natural environment, as well as for their whakapapa (ancestral) connections to their tūpuna, cultural heritage and special sites. They continue to carry out their traditional cultural and spiritual practices in this area, including gathering of mahinga kai. The current owners of Puharakekenui Reserve also hold specific cultural and legal rights in relation to this land, and these are managed through a Maori land trust called - Te Hapū O Kāti Urihia Ahu Whenua Trust. The Brooklands Lagoon/Te Riu O Te Aika Kawa Area Parks Master Plan, with which this reserve management plan is associated, is significant for Ngāi Tahu in that it addresses the potential effects on tangata whenua values from use and development of the area, including Spencer Park/Seafield Park. Ngāi Tahu supports the broader integrated management and protection and enhancement approach toward ecological and cultural values of the Brooklands Lagoon/Te Riu O Te Aika Kawa area taken in the draft master plan. The draft master plan should be referred to for more information on Ngāi Tahu values and specific planning proposals that address tangata whenua issues and values in this area.".

Seafield mgt plan: p.17; Spencer mgt plan: p.22

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In general, the Rūnanga and Ahu Whenua Trust support the vision and goals of these management plans in so much as they provide for the protection and enhancement of natural character and ecological values of the parks, and support recreational use, provided this does not compromise these values. However, there is a need to include specific objectives and polices that provide for the protection of tangata whenua cultural values, as follows: The following changes to the "Primary Management Objectives" for each plan are requested: Seafield Park Management Plan: "To protect and enhance the scenic, ecological and cultural values of Seafield Park to compliment Brooklands Lagoon's environmental values." Spencer Park Management Plan: "To manage Spencer Park as a multi-faceted recreation resource for the benefit and enjoyment of the public by: • .... • Protecting and enhancing the natural and cultural values that are special to the Park and its locality."

Make changes to the "Primary Management Objectives" of the draft management plans, as follows. For the Seafield plan, add the following text to the first objective on Page 8: "To protect and enhance the scenic and ecological and cultural values of Seafield Park to compliment Brooklands Lagoon‘s environmental values." For the Spencer plan, add the following text to the third bullet-point of the objective on Page 5: "Protecting and enhancing the natural and cultural values that are special to the Park and its locality."

Seafield mgt plan: p.8; Spencer mgt plan: p.5


It is also requested that the following policies be incorporated in the plans: Tangata whenua Recognise the manawhenua status of Te Ngāi Tūāhuriri in the management of Seafield/Spencer Park, and protect and restore values significant to tangata whenua." (both plans) "Consult with Te Ngāi Tūāhuriri Rūnanga and Te Hapū o Kāti Urihia Ahu Whenua Trust about appropriate ways of recognising their manawhenua and cultural values, including through indigenous plantings, interpretation and appropriate Māori names." (Spencer Park plan) ”Consult with Te Ngāi Tūāhuriri Rūnanga and Te Hapū o Kāti Urihia Ahu Whenua Trust about appropriate ways of recognising their manawhenua and cultural values in all park management activities, including through indigenous and mahinga kai plantings, built amenities, interpretation and use of appropriate Māori names." (Seafield Park plan) “Adopt an accidental discovery protocol (ADP) whereby if any archaeological or cultural material or koiwi (human remains) is found during work programmes on the reserve, work should be stopped and Te Ngāi Tūāhuriri Rūnanga, Te Hapū O Kāti Urihia Ahu Whenua Trust and the New Zealand Historic Places Trust contacted immediately for advice." (both plans)

Insert the following policies in the Cultural and Heritage policies sub-section (Page 12) of the Goals, Objectives and Policies section of the Draft Seafield Park Management Plan 2009: "Recognise the manawhenua status of Te Ngāi Tūāhuriri in the management of Seafield Park, and protect and restore values significant to tangata whenua." ”Consult with Te Ngāi Tūāhuriri Rūnanga and Te Hapū o Kāti Urihia Ahu Whenua Trust about appropriate ways of recognising their manawhenua and cultural values in all park management activities, including through indigenous and mahinga kai plantings, built amenities, interpretation and use of appropriate Māori names." “Adopt an Accidental Discovery Protocol (ADP), whereby, if any archaeological or cultural material or koiwi (human remains) is found during work programmes on the Park, work should be stopped and Te Ngāi Tūāhuriri Rūnanga, Te Hapū O Kāti Urihia Ahu Whenua Trust and the New Zealand Historic Places Trust contacted immediately for advice.".



It is also requested that the following policies be incorporated in the plans: Tangata whenua Recognise the manawhenua status of Te Ngāi Tūāhuriri in the management of Seafield/Spencer Park, and protect and restore values significant to tangata whenua." (both plans) "Consult with Te Ngāi Tūāhuriri Rūnanga and Te Hapū o Kāti Urihia Ahu Whenua Trust about appropriate ways of recognising their manawhenua and cultural values, including through indigenous plantings, interpretation and appropriate Māori names." (Spencer Park plan) ”Consult with Te Ngāi Tūāhuriri Rūnanga and Te Hapū o Kāti Urihia Ahu Whenua Trust about appropriate ways of recognising their manawhenua and cultural values in all park management activities, including through indigenous and mahinga kai plantings, built amenities, interpretation and use of appropriate Māori names." (Seafield Park plan) “Adopt an accidental discovery protocol (ADP) whereby if any archaeological or cultural material or koiwi (human remains) is found during work programmes on the reserve, work should be stopped and Te Ngāi Tūāhuriri Rūnanga, Te Hapū O Kāti Urihia Ahu Whenua Trust and the New Zealand Historic Places Trust contacted immediately for advice." (both plans)

Insert the following policies in a new Cultural and Heritage policies sub-section of the Goals, Objectives and Policies section (starting Page 4) of the Draft Spencer Park Management Plan 2009: "Recognise the manawhenua status of Te Ngāi Tūāhuriri in the management of Seafield Park, and protect and restore values significant to tangata whenua." ”Consult with Te Ngāi Tūāhuriri Rūnanga and Te Hapū o Kāti Urihia Ahu Whenua Trust about appropriate ways of recognising their manawhenua and cultural values, including through indigenous plantings, interpretation and appropriate Māori names." “Adopt an Accidental Discovery Protocol (ADP), whereby, if any archaeological or cultural material or koiwi (human remains) is found during work programmes on the Park, work should be stopped and Te Ngāi Tūāhuriri Rūnanga, Te Hapū O Kāti Urihia Ahu Whenua Trust and the New Zealand Historic Places Trust contacted immediately for advice.".


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Cultural and Heritage Policy Request a change to this policy as follow: “Sites of cultural and/or historical significance shall be identified, recorded, researched, protected and promoted and interpreted, as appropriate and according to specialist advice, and in consultation with Te Ngāi Tūāhuriri Rūnanga and Te Hapū O Kāti Urihia Ahu Whenua Trust with respect to sites of importance to tangata whenua."

Add to Policy 40 in the Draft Seafield Park Management Plan 2009, as follows: "All sites of cultural and/or historical significance shall be allowed to be identified, recorded, researched, protected, and promoted and interpreted as appropriate and according to specialist advice, and in consultation with Te Ngāi Tūāhuriri Rūnanga and Te Hapū O Kāti Urihia Ahu Whenua Trust with respect to sites of importance to tangata whenua.". NOTE: “allowed to be” has been raised by Council staff as a suggested insertion to the policy to reflect that it cannot necessarily be the Council that undertakes such work, but that the Council, as the land administrator, is able to permit such work to be done.



Endorse section (in the Draft Seafield Park Management Plan) on pre-European history (5.5.1 Before European settlement, p 39)


201 BL029 Mid-Seafield Park Draft Landscape Concept

The Rūnanga and Ahu Whenua Trust support, in principle, the proposed developments and restoration initiatives outlined in the (Mid-Seafield Park) draft landscape concept plan. Consultation with Ngāi Tahu ... will ensure that these proposals provide for the manawhenua and cultural values of tangata whenua. It is important that this occur particularly when access and structures are proposed.


202 BL029 Mid-Seafield Park Draft Landscape Concept

It should be noted that Ngāi Tahu wish to express their disappointment with respect to the development of the Beacon Street Wetland that occurred without prior consultation with Ngāi Tūāhuriri Rūnanga. The artificial wetland is not in keeping with the original marshlands in this area nor the natural character of the Brooklands Lagoon/Te Riu O Te Aika Kawa. Ngāi Tahu therefore asks that there be no further wetlands created on the margins of the estuary or Styx River/Puharakekenui without consultation.

This development has come out of the consent for the residential development of the original lot, which included the area now developed as a wetland landscape. The draft master and management plan preparation has played no part in this wetland development, but, rather, the draft landscape concept has noted the development. The planning for, and commencement of construction of, the wetland began before the Council's approval of the draft plans for consultation. The site is now classified scenic reserve (as is the majority of Mid-Seafield Park), although the decision on the wetland development was made when the site was vested in the Council as Local Purpose (Environment and Habitat Protection) Reserve.


Park interpretation (section 3.3) The list of features for potential interpretation at the park (wetlands, dune system, animal enclosure, plantation and other) does not include tangata whenua history and associations with the area. Request that this be included as follows: "Tangata whenua: The history and associations of Ngāi Tahu with the area."

Add a further row to the table in Sub-section 3.3 (Park interpretation) in the Draft Seafield Park Management Plan 2009, as follows: "Human history: The history and associations of Ngāi Tahu, and others, with the area.".


204 BL029 Implementation

Other than those (that have been) referred to specifically ... , the large number of planning proposals (in the draft master plan) were not individually evaluated by Ngāi Tahu to determine their relative merit or implications for tangata whenua rights or interests. Therefore, it is recommended that as the planning proposals are scheduled in the LTCCP and annual plans for implementation, the implications for Ngāi Tahu values and interests set out in the master plan is assessed for each proposal.

205 BL029 Engagement Ngāi Tahu would like to congratulate the Council on the positive engagement process used in the development of the Brooklands Lagoon/Te Riu o Te Aika Kawa Area Parks Master Plan. This included the initiative of Council officers in identifying the need for tangata whenua information and advice, the commissioning of a cultural values report, the work of officers with MKT to develop the draft Master Plan, and a consultation hui as part of the public consultation process. This has resulted in draft Master Plan that Ngāi Tahu is please to largely endorse. For an area of such importance to some of the whanau of Te Ngāi Tūāhuriri, the strong reflection of their values and aspirations in the Master Plan is highly significant. From the perspective of tangata whenua, this marks a real turning point in the approach to planning in this area; an approach that we hope signals a positive change for the future management of this area.

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brooklands lagoon area draft parks...

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