Hi Otago miners,
The Otago Regional Council currently has a poorly considered Plan Change 7 out for consultation., Submissions close on 4 May.
The guts of this submission is for those with dredges (and consents) when it comes to renewing your applications, the Council will
- only give a 6 year term maximum, and
- treat it as a non-complying activity.
This is a problem as firstly your take is non-consumptive (this applies to some Otago land based operations too) and that it will make you go through a consenting process with what is probably the most disfunctional Council in the South Island with a culture of conservatism and being difficult. It will mean your other consents i.e disturb the bed and discharge sediment will be out of synch (given they are probably 10 year terms). As a non-complying activity it is more complex to prepare applications and you will need a consultant to get the legal and technical aspects right or the Council wont accept your application. This will cost you, and for no environmental benefit.
The points I put into mine reads as:
“The Plan Change and s32 analysis does not acknowledge or understand the numerous suction dredge gold miners in Otago who are forced to seek consent, including for non-consumptive water takes. The proposed policies and rules do not provide any policy support to these non-consumptive takes and force them via a non-complying consenting pathway and a maximum duration of six years. Given the costs associated with renewing consents this presents an unnecessary burden on hobby gold dredgers with no environmental benefit.”
“Provide for non-consumptive takes such as suction gold dredging as a permitted or controlled activity and adopt a sensible term of consent for these takes rather than a blanket 6-year term that is commensurate with the (if any) effects on the environment.”
“Your plan change has not considered non-consumptive takes that have no impact on the environment but require a resource consent. It would be counter-intuitive to force a non-consumptive take via a non-complying consent process and require a maximum duration of 6 years. Many non-consumptive takes are in conjunction other consents, and a 6-year maximum term will require the cost and frustration of having to seek further consents from your Council outside the natural consenting cycle.”
Mine is more polite than it deserves. Make sure you have your say or be prepared to pay these guys another 5-8k for consent and consultant fees every 10 years…