Submission Frequently Asked Questions

Frequently Asked Questions about Submissions

Already we’ve had questions about this process so we thought we’d collect them here. New ones will be added as we find out things.

When are the submissions due?

We don’t yet know. At the moment, the application is lodged with the EPA and they have made their recommendation to the Minister for the Environment, Hon. Amy Adams, that the proposal is of national significance and should be “called in” to a Board of Inquiry.  When the Minister makes the formal decision, the application will be notified (a legal term), the independent Board will be appointed and submissions will be called for. We are watching on a daily basis and will update this page when that changes. If you want faster notification, send an email to contact@savekapiti.co.nz and we will add you to our supporters list.

Where do we send them?

We don’t yet know. When the application is notified and submissions called for, the Environmental Protection Agency will advise a specific address. They will also provide an online form that you can use if you prefer. You can create your own submission and attach it to their form, filling in the necessary fields with “see attached”.

Can’t we just sign a general submission that Save Kapiti prepares?

We could do that, but we’re not going to for two main reasons: 1) we want as many individual submissions as we can get to reach the Board so that they can see there is really a sizeable proportion of the residents of Kapiti that are opposed to this project; and 2) this is your single opportunity to state your own case, what the road will mean to your way of life, your home and your environment, and what real concerns you have about the technical effects such as noise, pollution, light spill, vibration, storm-water runoff, wildlife etc. Don’t assume that someone else will say the things that worry you. If you don’t make a submission, your concerns may be overlooked completely.

Have you got a form I can fill in?

We have a template that describes how your submission should be structured but it’s best if it’s in your own words and from your own perspective. 500 identical forms won’t have the same impact on the Board as 50 thoughtful well-argued submissions. Also, you can discuss mitigation for your own particular circumstances in your submission.

How long should it be?

It should be just long enough to say what you want to say. That may be 2 pages, it may be 20. There is no fixed length that is ideal. Be concise and clear and you’ll be doing the Commissioners a favour, as they have to read all of them.

Didn’t we do this already in 2009 and 2011?

No. The “consultation” processes conducted by NZTA was a farce, in our opinion. It was designed to make people feel like we were having input and to tick some boxes regarding process in their application, but it was not at all binding and it’s difficult to see where anything that went into those processes had any impact on the project at all. NZTA admitted in the February 2011 public meeting that we had with them that they regarded the submissions that people made in good faith as “feedback” and that it had no legal standing at all. A suspicious mind might suggest that the multiple rounds of “consultation” were designed to create “submission fatigue” so that residents would be asking precisely this question and saying “why bother?”. This is the only chance we have of making a submission to a body that has the power to do something about this road.

Why should I write a submission?

This is an important question and we created a separate page to answer it.

What’s in it for me?

  • If you have a firmly held belief that the proposal should not be approved, and this is backed up by the documentation that NZTA is providing, this is your chance to bring it to the Board’s attention.
  • If you believe that the proposal is a good idea, this is your chance to say so.
  • If you have specific circumstances (e.g. proximity to the road, asthmatic children etc.) where you want to get special consideration, this is your chance to get it in writing and let the Board assess it.

When they make their decision, it is within their power (if they approve the proposal) to attach conditions to the proposal that NZTA must comply with, and that might be down to the individual property level (for instance, cleaning your house after construction to remove particulate matter).

Where do I find the Resource Management Act?

Here, on the Government Legislation site.
Other information at the Ministry for the Environment (basic information and a usage guide), the Environmental Defence Society,  and (of course) Wikipedia.

How big is the application?

It is truly enormous. At almost 7000 pages (including the maps) and 3 gigabytes in electronic size, it is much larger than the Transmission Gully application. I do not believe any one person can read all of it in the time we have available.

Where do I find it?

The files making up the application are on the NZTA website.  Each tab holds a different set of reports comprising the RMA Forms for the consent applications, the Assessment of Environmental Effects, the Technical Reports, the Management Plans for construction and the Plan Set which has maps and technical diagrams as well as some large scale appendices from the other sections.

Do I have to read all of the application?

No. It is divided into sections based on subject and the plans are ordered by area.

The first thing to note is that the application doesn’t so much refer to specific areas by name (like “Milne Drive”) but to measurements they call “chainage” (a technical term dating back a long time but not much used these days). For example, a feature described as being at chainage 2200m is located approximately 2.2km north of MacKays Crossing. The divisions are:

Sector number Sector name Chainage distance (m) Length (km)
1 Raumati South 1900 – 4500 2.6
2 Raumati/Paraparaumu 4500 – 8300 3.8
3 Otaihanga/Waikanae 8300 – 12,400 4.1
4 Waikanae North 12,400 – 18,050 5.65

(interesting point: “It should be noted that the southern end of the Project commences at chainage 1900m, as the upgrading of the existing section of State Highway 1 to Expressway standards between Mackays Crossing and chainage 1900m will be done separately to this Project as part of the NZTA’s maintenance programme, and will occur fully within the existing designation.”)

Find out, by looking at the plans, what the chainage distance nearest your property is and that will help you focus on the areas of the application that you need to deal with.

There are 2 documents everyone must read – the Assessment of Environmental Effects: Non-Technical Summary and the Guide to the lodgement documentation. These two will point you to other areas of the application you should look at. However, with regard to the Non-Technical Summary, it is only an overview and the devil, as always, is in the details so don’t take it as the only document you should read

Reading the Forms is useful as they will point to the areas of the application that require special consideration by the Board. The rest will depend on what you want to focus on – don’t forget to read the appropriate Technical Report as well as the section of the Assessment of Environmental Effects and the Management Plan for the construction phase.

What do all those strange words mean?

The RMA has lots of language that is specific to its functions and some standard words have come to take on specific meanings within the business of the Environment Court. The application itself has a breakdown of phrases, words and abbreviations used in the Attachments to  the Guide to the lodgement documentation (it’s in the same PDF). Another, external source is on the Quality Planning site

 

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