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To: Stewardship land classification panels: West Coast

Public Submission: Save the Denniston Plateau from opencast coal mining

I add my name to Coal Action Network Aotearoa's submission (below) calling on the independent and mana whenua panels considering the reclassification of West Coast stewardship land to protect the land from future coal mines.

(Photo: Denniston Plateau - Neil Silverwood)

Why is this important?

The Department of Conservation has begun its review and reclassification of the status of its “stewardship land”, starting on the West Coast. This includes the Denniston Plateau, which has already been partially destroyed by the mothballed Bathurst Resources’ Escarpment coal mine.

The rest of the plateau is of high conservation value, and it, along with nearby Deep Creek, also contains some of the last unmined coking coal measures in the country, with mining permits held by BT Mining - a company set up by Bathurst Resources and Talley’s. Bathurst recently had to close a coal mine in Canterbury because it had breached so many consents.

The coal mining industry wants these areas to be classified “Conservation Park”, which is the current recommendation, but in the words of mining lobby group Minerals West Coast:
“Some reclassification categories - such as "conservation park", would still allow for mining under existing legislation.”
Right now, the draft classifications for these areas are indeed only for "Conservation Park".

The Denniston Plateau contains a unique sandstone plateau and rare wetlands, full of endangered and endemic creatures like our giant snail and the unique Avatar Moth, found nowhere else in the world. Also present are the great spotted kiwi and fern birds, and a rare skink found nowhere else, along with a giant snail.

Experience in this part of the world shows us that any claims by a coal company that they will “rehabilitate” the land after mining are empty promises. These unique areas would be destroyed, the streams polluted, and the animals in them gone.

The world is moving away from coal. We are in the midst of a climate emergency and we must protect our most precious areas both from the impacts of climate change - and from being dug up for coal that will only increase emissions at a time when we need to reduce them.

⏩ BELOW is the public submission to sign onto:

Dear Panel members West Coast,

The three areas we are concerned about all sit atop considerable coal measures, coal that if burned would contribute to climate change, at a time when governments around the world are attempting to reduce emissions to get the world onto a 1.5˚C warming pathway.

We note the government’s Emission Reduction Plan (ERP) specifically refers to “working with nature” to help reduce emissions as part of solving our climate crisis:

“Looking after these forests is one of the most important contributions Aotearoa can make to combating global climate change. We also have a significant opportunity to develop native forests that both act as long-term carbon sinks and support biodiversity…”

★ We therefore strongly recommend a much stronger protection regime for the following areas:

🌏 1. Kaw_10 - Waimangaroa - Granity

This area contains Deep Creek, a highly biodiverse area, with coal measures under the land.

Given the main habitat of the Powelliphanta augustus was obliterated by the Stockton Mine, and rehabilitation efforts have failed, and the majority of the remainder of this species are still living in fridges, it is absolutely critical to preserve, in perpetuity, this last remaining habitat of this critically endangered species.

The very nature of the DOC description: “high ecological values” and “overwhelmingly natural and largely intact” brings into question its lowly recommended classification of Conservation Park. A scientific reserve would preserve this area in perpetuity, especially as it would preclude the area from being stripped bare in an opencast coal mine.

We therefore recommend that this be classified as an ecological area (under Part 4, S21 of the Conservation Act) with a scientific reserve on the remainder of the Stockton Plateau (sandstone pavement) including Upper Deep Creek/Whirlwind Creek (under Part 3, S21 of the Reserves Act)

🌏 2. Kaw_17-Mount Rochfort, Old Denniston School Site

Again, we consider the recommendation of “Conservation Park” is in contradiction to the high biodiversity values of the area.

The great spotted kiwi and weka are both found here, along with the Avatar Moth, a species unknown anywhere else in the world, and only identified in 2012. It is also home to the Denniston skink, another species found nowhere else, and the giant snail Powelliphanta Patrickensis We consider this biodiverse area must be protected, not least from being stripped bare by a coal mine, which would likely render at least some of these species extinct.

The Denniston plateau contains valuable wetland peatland areas found nowhere else. Not only should they be protected from coal mining, but we note the Government’s Emissions Reduction Plan specifically points to a strategy of wetland and biodiversity protection as part of our climate strategy and to protect them as valuable carbon sinks.

We recommend that the Denniston plateau component be declared a Scientific Reserve and that the remainder be classified as an ecological area.

We also recommend that the Old Denniston School area be declared as an Historic Reserve (under Part 3, S18 Reserves Act)

🌏 3. KAW_26 - Ballarat

Again, we find it odd the recommended classification is only "Conservation Park", given the “high landscape and ecological value” supporting “rare and distinct species.”

We recommend that Conservation Area Ballarat be classified as an ecological area.

Lastly, and importantly, we also make a wider recommendation that the Government changes our legislation covering these areas: the Reserves Act, the Conservation Act, and the National Parks Act, so they all honour and respect Te Tiriti O Waitangi - the Treaty of Waitangi. Such changes should reflect the rights of Māori to be able to access these areas for cultural purposes such as mahinga kai and medicinal plants for rongoā - without having to seek permission.

Ngā mihi

How it will be delivered

We will include all the names as part of the Coal Action Network Aotearoa submission.




2022-07-21 08:16:37 +1200

1,000 signatures reached

2022-07-19 16:26:56 +1200

500 signatures reached

2022-07-09 14:38:02 +1200

100 signatures reached

2022-07-09 11:43:53 +1200

50 signatures reached

2022-07-09 10:49:38 +1200

25 signatures reached

2022-07-08 21:26:38 +1200

10 signatures reached