Online Submission Form Your Contact Details Name Michael Hide Organisation Fonterra Co-operative Group Limited Address P O Box 33 Temuka Post Code 7948 Do You Want to Speak to Council? I do wish to be heard in support of my submission Preferred Speaking Date. 402 21 April 2015 Fonterra Co-operative Group Limited P O Box 79026, Avonhead, 8841, New Zealand www.fonterra.com LTP Submissions Southland District Council 15 Forth Street INVERCARGILL 9810 Dear Sir / Madam, Southland District Council Long-Term Plan Consultation Document 2015-25 Thank you for the opportunity to participate in the Long-Term Plan consultative process. Please find our submission attached. We wish to be heard in support of our submission, and look forward to having the opportunity to address you in person. Yours faithfully Stuart Gray airs Canterbury (Acting Southland/Otago) 403 Fonterra Co-operative Group Fonterra Submission – Long-Term Plan 2015 / 2025 Consultation Document Full Name of Submitter Fonterra Co-operative Group Limited Contact Person Michael Hide Title Manager, Regional Relations Full Postal Address Fonterra Co-Operative Group Limited P O Box 33 Temuka 7948 1. FONTERRA 1.1 Fonterra Co-operative Group Limited ("Fonterra") is the world's largest milk processor and dairy exporting company, 100% owned by 10,721 New Zealand dairy farmers. Fonterra's approximately 18,200 staff work across the dairy spectrum, from advising farmers on sustainable farming and milk production, to ensuring Fonterra meets exacting quality standards and delivers dairy nutrition every day in more than 140 markets around the world. 1.2 Fonterra collects more than 17 billion litres of milk from New Zealand, exporting more than 2.4 million tonnes of dairy product annually. Globally, Fonterra processes more than 22 billion litres of milk and owns leading dairy brands in Australasia, Asia, the Middle East and Latin America. In the 2013 / 2014 financial year, Fonterra's global revenue was over $22 billion. Our presence in the Southland District 1.3 Dairy farming in the Southland Region represents approximately 942 dairy herds (11.2% of New Zealand’s total dairy herds). Approximately 704 of these dairy herds are located within the Southland District.1 1.4 It’s important to note that as a co-operative, each of these farmers are also shareholders in Fonterra. While we are New Zealand’s largest company and operate on the global stage, our roots are firmly embedded in rural New Zealand. As it says at the gate of every one of our farms, it starts here. 1.5 We’re proud of the contribution we make in our communities. Fonterra Shareholders have directly contributed to the Southland community as outlined below. Milk for Schools 1.6 The Fonterra Milk for Schools programme offers Year 1 to 6 students a free serve of Anchor milk every school day. The programme also provides schools with free delivery, fridges to chill the milk, and collection of used packages for recycling. Fonterra Milk for Schools has been rolled out nationwide with kiwi kids benefiting from delicious dairy nutrition. There are over 1450 schools taking part across New Zealand. 1 DairyNZ Statistics 2013/2014. 404 Page 1 Fonterra Co-operative Group KickStart Breakfast Programme 1.7 KickStart Breakfast is the only school breakfast programme of its kind within New Zealand. Fonterra and Sanitarium partnered in February 2009 to provide a free school breakfast of Anchor milk and Weet-Bix to all New Zealand schools. Alongside support from the New Zealand Government, we work together with local school communities to provide healthy breakfasts to children. 1.8 There are currently 16 schools within the Southland region involved in our KickStart Breakfast Programme. In total, the programme has over 800 schools participating and has fed over 25,000 students 4 million breakfasts at schools across New Zealand. Grass Roots Fund 1.9 The Fonterra Grass Roots Fund is a New Zealand-based sponsorship programme focusing on rural communities. It has been running since 2007. The fund opens doors for a wide range of community projects with grants of between $500 and $5000. 1.10 Administered out of manufacturing sites, the Fonterra Grass Roots Fund has supported numerous initiatives across New Zealand since its establishment in 2007, across four themes including: Innovation and Science, Caring for our Environment, Bringing Communities Together, and, Safer Communities. 1.11 In the last year alone we’ve supported 273 initiatives, with a wide range of groups receiving grants for projects. Recent examples in Southland include the provision of resources to the Dipton Playgroup to develop a community vegetable garden, and funding a defibrillator for the Winton Community Centre. Economic Contribution 1.12 Our business also plays an import role in the local economy. Over the last 4 years, the average value of dairying to the Southland District has been significant, with the following farmgate figures being received:2 2010 / 2011 – 135,714,960 kg of milk solids was produced within the region. At an average payout of $7.89, this had a farm gate value of approximately $1.07 billion. 2011 / 2012 – 147,810,670 kg of milk solids was produced within the district. At an average payout of $6.40, this had a farm gate value of approximately $945 million. 2012 / 2013 – 161,366,208 kg of milk solids was produced within the district. At an average payout of $6.18, this had a farm gate value of approximately $997 million. 2013 / 2014 – 169,169,088 kg of milk solids was produced within the district. At an average payout of $8.47 per kg of milk solids, this had a farm gate value of approximately $1.43 billion. 1.13 A report by the New Zealand Institute of Economic Research (Dairy’s role in sustaining New Zealand) assessed the contribution of dairying within the Southland District to employment (directly related to dairying) as being 3,253 jobs.3 Dairy farming and processing is a fundamental driver of the Southland district's economic prosperity and underpins key aspects of the regions social and cultural identity. It is likely to remain so for the foreseeable future. 2 DairyNZ Statistics 2010/2011; 2011/2012; 2012/2013 and 2013/2014. Fonterra employment data by region, 2013 / 2014. 3 405 Page 2 Fonterra Co-operative Group National Initiatives 1.14 Fonterra also has a number of national programmes that are contributing to the success of the industry in the Southland District. Supply Fonterra 1.15 Fonterra has developed the Supply Fonterra programme to support and drive on farm change. The Supply Fonterra programme is designed to support farmers to meet the expectations of our communities, regulators, markets and wider industry. 1.16 The programme uses a combination of one-to-one support, education, auditing and minimum standards to ensure the sustainable production of high quality, safe milk, with healthy animals. Every year our farms are assessed during their annual Farm Dairy and Environmental Assessment. This on-farm assessment ensures every farm is meeting specific milk quality and environmental standards. Where they are not, we work with farmers to help them meet the required standards. 1.17 In the sustainability area, Supply Fonterra has the following key programmes: Effluent Management commenced in 2010 and involves an annual check of the effluent system during the annual Farm Dairy Assessment. Where any risks are identified an improvement plan is developed with the farmer. Waterways Management commenced in 2011 and has targeted the exclusion of stock from significant waterways. Under this programme, 97% of all significant waterways are now permanently stock excluded (99% in Southland Region). This programme will focus on Riparian planting in the coming years. Nitrogen Management also commenced in 2011 and aims to accurately model the nitrogen losses from our supplying farms and support farmers to improve their practices over time. Sustainable Dairying: Water Accord 1.18 Our commitment to water quality is reflected in the Sustainable Dairying: Water Accord ("SDWA") and its predecessor, the Clean Streams Accord. The SDWA was launched in 2013 and is a commitment to New Zealand to enhance the overall performance of dairy farming as it affects freshwater through continuous improvement and partnership. The Accord is a voluntary environmental initiative designed to contribute towards clean, healthy freshwater resources including streams, rivers, lakes, groundwater and wetlands in dairying areas. 1.19 The Accord has targets focused on effluent management, nutrient management, water use efficiency and waterway management, and Fonterra will deliver against these targets through our Supply Fonterra programme. Living Water 1.20 In March 2013, Fonterra launched its Living Water commitment to New Zealand. This programme is our long-term commitment to caring for New Zealand's waterways ensuring dairying works alongside natural habitats and ecosystems of healthy, living water, now and into the future. Living Water has brought about a partnership between Fonterra and the Department of Conservation, with Fonterra committing $20 million over 10 years to delivering community expectations in the following five sensitive catchments. 406 Page 3 Fonterra Co-operative Group The Kaipara Harbour Tikapa Moana - Firth of Thames Waikato Peat Lakes Te Waihora- Lake Ellesmere Awarua-Waituna Lagoon 1.21 We are working with our communities in these areas including farmers, iwi, councils and environmental care groups to deliver measureable biodiversity benefits. 2. FONTERRA'S SUBMISSION 2.1 We thank the Council for this opportunity to comment on their Long Term Plan 2015/25 Consultation Document. 2.2 We are generally supportive of the direction of travel for the Council set out in the consultation document, and have these specific comments to make Roading Network 2.3 The rural roading network is critical to the success of Fonterra. Our farmers rely on rural roads for the delivery of goods and services and strong local community. For the milk our farmers produce, rural roads provide the critical first leg in a journey that will often end on the other side of the world. 2.4 It is also important that these roads are as safe as they can be for our farmers, employees and the wider community. 2.5 The options proposed by the Council will see a shift in spending from roads that have lower volumes of traffic to those with higher traffic volumes, while also attributing a higher proportion of the costs of road maintenance to the dairy sector. In some situations this will result in our farmers paying additional costs for a reduced level of service. 2.6 However, we appreciate the position that the Council is in due to the reduction in NZTA funding and the increasing pressures being placed on the districts roads. 2.7 We acknowledge the Council for taking a pro-active approach to management of the districts roads and the positive relationship that exists between the Council and Fonterra on these issues. 2.8 We are therefore confident that the changes proposed will not have a significant impact on our farmers or transport operations. We request that: 2.9 The Council proceed with the proposed options set out on pages 11 and 13 of the consultation document. 2.10 The Council continue to work collaboratively with Fonterra to assist in the safe and efficient management of the road network, while also ensuring that future investments are well targeted. Infrastructure Management and Funding Depreciation 2.11 We support the Councils move to extend the life of its assets where there is sufficient information to do this without adverse impacts on the levels of service delivered. 407 Page 4 Fonterra Co-operative Group 2.12 We also support the move to fully fund depreciation to provide for the replacement of infrastructure when it reaches the end of its serviceable life. This approach is more equitable and provides for the future replacement of assets when the time comes. 2.13 The phasing in of this approach over the life of the plan is appropriate to reduce the impact of the transition in the coming years. We request that 2.14 The Council proceed with the proposed option set out on page 19 of the consultation document. 2.15 Fonterra wishes to be heard in support of this submission. Fonterra Co-operative Group Limited 21 April 2015 Michael Hide Manager, Regional Relations 408 Page 5 Tuesday 19 May Afternoon Your Feedback Roading Service Levels Preferred Option: Option One - Move to an 80/20 principle Comment: See attached submission Roading Rate Model Preferred Option: Option One - Proposed Model Comment: See attached submission Sealing the last section of the Catlins road Preferred Option: No preferred option Comment: Ageing Infrastructure - Funding of depreciation Preferred Option: Phased funding of depreciation Comment: See attached submission Draft Development Contributions Policy Comment: Draft Maori Freehold Land Policy Comment: Draft Rates Remission Policy Comment: Draft Revenue and Financing Policy Comment: 409 Early Repayment of Rates Policy Comment: Fees and Charges Schedule Comment: Other Feedback Is there anything else you think we should consider over the next 10 years to help build a better Southland?. Comment: Help us improve this plan! How easy was the Consultation document to read? Very Easy Please comment on how we can improve the plan: 410 TE AO MARAMA INC Ngāi Tahu ki Murihiku Resource Management Consultants 20 April 2015 Southland District Council P O Box 903 INVERCARGILL 9840 REFERENCE: Submission – Southland District Council (Te Rohe Pōtae o Murihiku) – Draft Long Term Plan 2015-2025 Tena koe Steve Ruru This submission is presented on behalf of Te Ao Mārama Incorporated (Tami) representing the four Murihiku Ngāi Tahu Papatipu Rūnanga – Awarua, Hokonui, OrakaAparima and Waihopai. The takiwā of Awarua, Hokonui and Oraka-Aparima are included in the Southland District. Tami based its review of the Southland District Council Long Term Plan 2015-2025 looking at consistency with the following documents: Tiriti o Waitangi, Te Tangi a Tauira: Ngai Tahu ki Murihiku Natural Resource and Environmental Iwi Management Plan, He Huārahi mō Nga Uri Whakatupu (Charter of Understanding between Te Ao Mārama Inc and the local government authorities of Murihiku), and relevant sections within the Local Government Act 2002 and the Resource Management Act 1991. Within these legislative and regional agreements and plans contains the concepts of shared decision-making and consultation with Māori. We support the need to further foster Maori capacity through regular engagement, maintaining existing protocols, commitment to funding and the continued acknowledgement of Maori cultural landscape through the commitment to display Maori taonga at your offices. Environmental health is regarded as a priority area for Tami. Grants funding to programmes like Enviroschools, High Value Areas, Biodiversity Southland, Southland Coastal Heritage Inventory Project are supported, these provide for the maintenance and strengthening of Environment Health. We support the continued goals set in environmental health to improve the quality and level of satisfaction to customer. The continued analysis of freedom camping and the need to provide support in areas which are receiving increased demands due to popularity is required. Catlins and areas like Waikawa are examples of this need. Demands on infrastructure and the environment is likely to increase with the proposed sealing of the Haldane –Curio Bay road. Tami agree with the need to seal this section of the road to provide safe travelling for residents and tourists. Tami supports the sealing of 411 the Haldane-Curio bay road but note some significant wetland remnants next to the road that need to be considered. Sealing of the Haldane-Curio Bay Rd and upgrades in facilities at Curio Bay will increase visitor numbers to the area. The Council has foreseen this and are installing a new wastewater plant which is commended by Tami. It will benefit the local community, also recreational users, water quality and the outstanding environment. The wastewater plant should be funded appropriately and any shortfall in costs funded by a loan (page 213). A focus of the plan is water, including the related issues of sewerage, solid waste management, stormwater and water supply. In each of these activities there are problems of ageing plant, risk of failure, contamination of rivers, streams and estuaries and other health hazards of varying degrees in rural communities. We acknowledge the investments Council makes into their town sewage treatment plants. These include Riversdale, Te Anau, Riverton, Ohai, Nightcaps and Curio Bay that Tami have been involved with in recent consultation. We seek that Council maintain a strong focus on water quality discharge, with discharge to land in the first instance. Infrastructure should be maintained or replaced to ensure positive human and environmental health outcomes. Tami also support option 1 of the proposal for remission and postponement of rates on Maori freehold land. Te Ao Mārama Inc wishes to be heard in support of this submission. Nāku noa, nā Dean Whaanga for and on behalf of Te Ao Marama Inc Murihiku Marae, 408 Tramway Road - P O Box 7078, South Invercargill/Waihopai 412 Submission 104 Draft LTP 2015-2025 Online Submission Form Your Contact Details Name Pamela Callahan Organisation Address Maranui Valley R.D.1 Tokanui Post Code 9884 Do You Want to Speak to Council? I do not wish to be heard in support of my submission Your Feedback Roading Service Levels Preferred Option: Option Two - Maintain the Status Quo 413 Submission 104 Draft LTP 2015-2025 Comment: Roading Rate Model Preferred Option: Option Two - Current Model Comment: Sealing the last section of the Catlins road Preferred Option: Fund the Sealing of the road Comment: Ageing Infrastructure - Funding of depreciation Preferred Option: No preferred option Comment: Draft Development Contributions Policy Comment: Draft Maori Freehold Land Policy Comment: Draft Rates Remission Policy Comment: Draft Revenue and Financing Policy Comment: Early Repayment of Rates Policy Comment: Fees and Charges Schedule Comment: Other Feedback Is there anything else you think we should consider over the next 10 years to help build a better Southland?. Comment: 414 Submission 104 Draft LTP Plan 2015-2025 I totally support the proposed funding of the Curio Bay Waste water system. Please ban all freedom camping within a certain distance from a registered camping ground. Close Waikawa Domain to all campers as it is causing issues with the Hall users. Help us improve this plan! How easy was the Consultation document to read? Very Easy Please comment on how we can improve the plan: 415 Submission 106 Draft LTP 2015-2025 416 Federated Farmers of New Zealand Submission on Southland District Council’s Draft 10 Year Plan 2015-2025 21 April 2015 417 SUBMISSION TO SOUTHLAND DISTRICT COUNCIL ON THE DRAFT 10 YEAR PLAN 2015-2025 To: Southland District Council [email protected] Submission on: Draft 10 Year Plan 2015-2025 Date: 21 April 2015 From: Federated Farmers of New Zealand (Southland Province) Contact: Russell MacPherson Southland Provincial President Federated Farmers of New Zealand PO Box 176, Invercargill 9840, New Zealand WE WISH TO BE HEARD IN SUPPORT OF THIS SUBMISSION Federated Farmers Submission to the Southland District Council Draft 10 Year Plan 2015-2025 Page 2 418 SUBMISSION TO THE SOUTHLAND DISTRICT COUNCIL ON THE DRAFT 10 YEAR PLAN 2015-2025 1. ROADING SERVICE LEVELS 1.1 Roading is vital to the Southland economy, given our reliance on primary production and associated processing and distributing. 1.2 We acknowledge the increasing cost pressures Council is facing to maintain the roads in Southland, as a result of a reducing funding assistance rate from the NZTA, and the significant expenditure required for Southland roading. 1.3 Federated Farmers (Southland) is concerned about the impact that changes to the NZTA financial assistance rate will have for Southland’s councils, ratepayers, road users, economic productivity, and communities. Federated Farmers of New Zealand has submitted to both phases of the NZTA’s review of the funding assistance rate outlining our concerns with the impacts that the FAR allocation regime will have on rural councils and communities. 1.4 Southland District is driven by primary land use which relies heavily on the roading network. We consider that Southland’s transport infrastructure and services (across the entire roading network) play a pivotal role in the regions’ quality of life and prosperity, and that this needs to be recognised and provided for within the draft 10 Year Plan. 1.5 Federated Farmers (Southland) is concerned about the Council’s proposal to prioritise 20% of the roading network and spend less on the other 80%. We consider that since the council’s roading roadshows last year, consultation has been lacking. This is a serious concern, particularly as ratepayers were promised focus groups to continue community discussions on roading issues. 1.6 We anticipate that most farmers will live on the 80% of roads that will receive less funding for maintenance. Yet farmers carry most of the roading rate burden in the district. This year it is proposed that they pay for 71% of the total roading rates, despite only making up 25% of the District’s total rateable units. 1.7 Farmers also pay their share to central government’s roading revenue through road user charges, fuel taxes, registration and licensing. To a large extent, these factors guide rural road users’ expectations on roading levels of service in their areas. 1.8 We are not advocating that rural roads should offer the same level of service as key arterial routes. However, we do seek to ensure that the 10 Year Plan recognises the tremendous economic value of rural roads, that there is an awareness of the contributions farmers make to roading costs and that farming makes to the economic wellbeing of the community. 1.9 SDC’s roading service levels should recognise that roading, particularly the local roading network, is important not only for Southland’s urban and rural-based Federated Farmers Submission to the Southland District Council Draft 10 Year Plan 2015-2025 Page 3 419 businesses, but also from a social perspective. It connects neighbours and communities, and links isolated rural communities to education, social and emergency services and other basic needs. This underlines road user’s expectations for a minimum acceptable level of roading service. Given these factors our members expect that all Southland roads should be maintained to a minimum guaranteed level and this should guide SDC’s roading maintenance regime. 1.10 Council is signalling there will be significant reductions in levels of service for many rural road users. The impacts of these changes will differ significantly between communities and between ratepayers, and there is a requirement for Council to front up directly to rural ratepayers and explain what is happening, why it is happening, and what these changes mean. 1.11 This is not a role rural representatives like Federated Farmers can fulfil for the Council. Council should have been undertaking these discussions with affected communities over the past two years, when it was already clear there would have to be material changes to the rural roading maintenance regime. We support our members’ submissions on the level of road servicing they consider appropriate in their areas, and we underline the way the farmer’s contributions (both through rates and through central government’s road use derived revenue) underpin an expectation for a reasonable level of service for roading. Recommendations 1.12 Federated Farmers supports a ‘whole of network’ approach to the maintenance of Southland’s roads which enables a realistic and minimum standard of roading. 1.13 We note that farmers contribute high amounts of money to roading through road user charges, fuel taxes, registration, licensing, and rates (currently approximately 70% of the roading rate burden). To a large extent, these factors guide rural road users’ expectations on roading levels of service in their areas. 1.14 We believe Council needs to engage with impacted members directly to discuss the implications of the new roading maintenance regime and we support our members’ individual submissions on the level of service delivery needed for their local roads. 2. FUNDING OUR ROADS 2.1 Federated Farmers (Southland) considers that roading costs should be based on a ‘user pays’ system, i.e. those who use the road should meet the costs in line with that use. Our concern with the Council’s current Morrison Low model is that it is not an accurate capture of road use. 2.2 In its current form, Council’s roading model means that the District’s commercial interests (for example, those in the tourism industry and medium to heavy traffic commercial operators servicing the urban and rural area including agricultural contractors), are not contributing enough towards the costs of maintaining the roading network based on actual use. Federated Farmers Submission to the Southland District Council Draft 10 Year Plan 2015-2025 Page 4 420 2.3 Under the current model, the commercial sector has 2.95% of the District’s total rateable units and this year would pay only 2.5% of the roading rates. Yet the benefit derived from the tourism, supermarkets, and freight companies through use of the local roads far exceeds 2.5% of the total benefit derived from road use. This leaves a significant proportion of local roading costs sitting with the primary sector, unjustifiably. 2.4 The Council’s proposed new model (a modified Morrison Low model), would increase the commercial sector’s contribution to roading rates by 0.5%. Federated Farmers (Southland) considers that despite this increase the sector is still ‘underpaying’ for the significant benefit derived from use of the local roading network and as a result the current and proposed allocation models are inequitable. 2.5 The industrial sector comprises 2.1% of the District’s total rateable units, and this year would pay 4.0% of the roading rates. Industrial companies tend to have small lots which do not accurately reflect the amount of traffic their industry creates. Despite this, the Council’s proposed model would reduce the industrial contribution to roading rates, down to 3.0%. Again our concern is that by inaccurately capturing the benefit derived from the industrial sector’s use of roading the primary sector is being asked to contribute too great a proportion towards the costs of the local network. 2.6 Compared to the revised Morrison Low allocation model, an alternative model, the PWC/MWH/GHD model, estimates the commercial and industrial sectors should be paying for approximately 11 or 12% each of the roading rates bill, based on the number of heavy vehicles used in each industry and frequency of trips made. To clarify, milk tankers and agricultural contractors’ heavy vehicles fall within the commercial or industrial sectors, i.e. those businesses that operate heavy vehicles on roads. 2.7 Under the Council’s current model, dairy farmers and non-dairy farmers are paying 71.5% of the District’s roading costs. This is despite only accounting for a combined 25% of the District’s total rateable units, and owning/operating only a tiny percentage of the number of light and heavy vehicles in the District. 2.8 An independent review of the two models, the Kennaird report, has highlighted the PWC/MWH/GHD model as being more accurate at identifying users and beneficiaries of the roading network, and highlighted the shortcomings of the Morrison Low model. The Kennaird report noted that the Morrison Low model does not identify users or beneficiaries of the District’s roading network in a recognised technical manner. Recommendation 2.9 Federated Farmers (Southland) opposes Council’s use of the Morrison Low model to allocate costs. We ask that Council use the more accurate GHD amended PWC/MWH model. Federated Farmers Submission to the Southland District Council Draft 10 Year Plan 2015-2025 Page 5 421 Amendments to the Morrison Low model 2.10 While Federated Farmer’s primary submission is that Council move to adopt the GHD amended PWC/MWH model, there are a number of possible amendments to the Morrison Low model which would reduce the inaccuracies of that model and create fairer outcomes. These are, as above, shifts that would better capture the relative benefit of all ratepayer categories from use of the local roading network. 2.11 Council uses land value as an approximation of the impact and utilisation of aggregates. Our members consider that this is a blunt tool to address this area of roading funding. A large scale property in Te Anau may source its aggregate on the property, or from a neighbouring property, yet it will fund a larger proportion of aggregate simply because it is a large property, with a large land area. Our members contend that they source a lot of their aggregate on farm and therefore the extent of the farming sector’s impact is substantially overstated. 2.12 Federated Farmers (Southland) suggests that Council also fund part (20%) of general costs portion on a flat targeted rate across each land use to “flatten” or offset the impact of variations in capital value. This would also recognise that there is a significant benefit to all road users in the District regardless of land use, and that the model does not accurately capture some of the use of the District’s roads, use which should not be left for those ratepayers who are measured to pay for. 2.13 Tourism is currently captured under the commercial category, but it is clear that tourist operations are significant beneficiaries of a working district roading network, and demonstrably contribute to the amount of traffic on the district’s roads. Federated Farmers recommends council introduce a new differential category that targets accommodation and tourist businesses to recover costs associated with tourisms impact on the roading infrastructure. Recommendation 2.14 Federated Farmer’s (Southland) primary submission is that Council move to adopt the GHD amended PWC/MWH model. If Council decides to retain the Morrison Low model, there are a number of amendments that would reduce the inaccuracies of that model and create fairer outcomes. Amendments to the amended Morrison Low model (Anthony Byett’s model) 2.15 Federated Farmers (Southland) supports the improved transparency of the Morrison Low model as a result of Anthony Byett’s proposed changes. It is inappropriate for Council to make manual adjustments to the Morrison Low model each year that have no rational basis and are derived from subjective views on heavy vehicle usage. 2.16 We strongly oppose the decrease in the UTR for the proposed roading rate model. Under the current model the UTR comprises 10% of the total roading revenue required by Council (approx. $87.68, including GST). As noted above, we consider this does not adequately reflect the general benefit that the roading network provides to all ratepayers and recommend that it is increased to 20%. Federated Farmers Submission to the Southland District Council Draft 10 Year Plan 2015-2025 Page 6 422 2.17 The proposed model would decrease the UTR to approximately 6.8% of the total roading revenue required by Council (approx. $87.61, including GST). The draft 10 Year Plan states that “This reflects 10% of the amount required after the Council has calculated the heavy vehicle differential.” The UTR is intended as a measure of general benefit – we cannot see any valid reason why the UTR should only be considered a measurement of general benefit after the heavy vehicle usage is taken out. 2.18 The general benefit of the roading network to all ratepayers is woefully underestimated by the Morrison Low model and the proposal to decrease the UTR further is not supported by any discussion or rational. A person living in rural Southland needs our roads to get to their job in Invercargill, just as much as a concrete operator needs to use them to collect gravel, just as much as a dairy company needs them to pick up milk from a farmer each day. 2.19 We oppose the tonnage rate being set at $1.20. Council has offered no reasoning why it has increased the tonnage rate from $1.00 originally set by Byett and presented to Council at its roading workshop in November last year. Reductions in the FAR rate should not automatically be subsidised by the heavy vehicle differential, considering the significant benefit derived from the local roading network through light vehicle use. The Morrison Low model underestimates the benefits of the capital costs of the roading network for all users and Council should seek to increase the UTR portion of the roading rates to recognise that all ratepayers ultimately benefit from the roading network and the communities and economy that are supported by it. 2.20 It is inappropriate for the Byett model to use tonnage rates from the primary production sector, and not use tonnage information from other sectors. We consider that the industrial and commercial sectors’ roading rates are significantly underestimated as a result. Under the Byett model these costs fall back on farmers. 2.21 It is imperative that Council improves the reliability and soundness of the Byett model by obtaining tonnage data for the Commercial and Industrial sectors, and proportionately increasing their share of the heavy vehicle usage rates, thereby improving the fairness of the model. Until such time as these improvements are made we believe the heavy vehicle differential should be evenly distributed across the primary, commercial, and industrial sectors through a UTC. 2.22 We oppose the “other use” component added to the dairy sector roading rates (which results in an increase in dairy tonnages of 10%). The LTP states that this is “applied to the dairy sector to reflect input tonnage such as grains, feed and livestock moved for wintering and on Gypsy Day.” However, all other tonnage data for the Morrison Low amended model is sourced from outputs (e.g. milk solids and beef and lamb). 2.23 It is inappropriate for the dairy sector to be required to pay for other sectors’ outputs – e.g. wintering is an output of a grazier, Gypsy Day stock movements are livestock transport companies outputs, fertiliser is an output from fertiliser companies, and grains and feed are stock feed businesses’ outputs. Federated Farmers Submission to the Southland District Council Draft 10 Year Plan 2015-2025 Page 7 423 2.24 As outlined above, we particularly support the use of targeted rates in the tourism sector to ensure that other road users are not subsidising the roading rates of those businesses that directly benefit from tourism in the region. Recommendations 2.25 We strongly oppose the decrease in the UTR for the proposed roading rate model, and recommend that Council increases the UTR portion of the roading rates to 20%, to recognise that all ratepayers benefit from the roading network, not just farmers. 2.26 Federated Farmers (Southland) recommends that the proposed tonnage rate of $1.20 is reduced to the original amount proposed by Anthony Byett of $1.00. 2.27 We recommend Council urgently seeks to address the inequity of the model by obtaining tonnage data for the Commercial and Industrial sectors, and reallocating the roading rate costs each year as the data is collected. 2.28 Council removes the “other use” component from dairy sector roading rates, as it is inequitable to require the dairy sector to pay for other sectors’ tonnages. We suggest this portion of heavy vehicle road funding is sourced through a UTR. 2.29 Introduce targeted roading rates for the tourism sector so that those businesses benefitting from additional traffic on the roads are paying for the additional maintenance and safety measures required as a result. 3. SEALING THE CATLINS ROAD 3.1 Federated Farmers has no view on whether the remainder of the Catlins road should be sealed. 3.2 If the decision is made to proceed with the project, Federated Farmers supports Council seeking an increased subsidy from government for sealing the route along the Catlins road from Nugget Point through Curio Bay and along the Alternative Coastal Route. As noted in the 10 Year Plan, this is a popular tourist route with a high number of crashes, particularly amongst tourists. We consider these road safety concerns justify increased funding from central government. 3.3 Considering the significance of the road as a tourist route, and that the main issue is road safety in relation to tourist use, we consider that central government should fund the majority of the new seal. 3.4 If Council is required to pay 46.5%, as discussed in the Plan, this would result in an increase of $5.23 per rating unit in 2016/17 and $10.66 per rating unit after that. This is unacceptable. While we acknowledge that there would be some wider benefit to the region in terms of “encouraging economic growth by making key tourist attractions more assessable [sic]”, it will not make a tangible difference to general ratepayers in the district. Federated Farmers Submission to the Southland District Council Draft 10 Year Plan 2015-2025 Page 8 424 3.5 We support the use of a targeted rate for the commercial sector (most likely to directly benefit from tourism) to pay for Council’s contribution to sealing the Catlins Road. Recommendations 3.6 Federated Farmers has no view on whether the remainder of the Catlins road should be sealed. 3.7 If the decision is made to proceed with the project, we support Council seeking additional funding from the Government to seal the remainder of the Catlins road. 3.8 We recommend that Council’s contribution to the sealing of the road comes from a targeted rate from all commercial businesses located along the whole Southern Scenic Route. 4. FUNDING OUR INFRASTRUCTURE 4.1 Federated Farmers supports the Council adopting a policy of pushing out asset renewals as much as possible by having better information on the assets’ condition and performance. 4.2 Replacing all assets when they are “theoretically due to be replaced” is unlikely to be the most cost-effective option. With regular maintenance, and sound, up-to-date information, the life of some assets could be able to be extended without impacting on the service provided to ratepayers. 4.3 Council also needs to keep in mind that the implementation of the National Policy Statement for Freshwater may require upgrades of urban water/sewerage systems (as well as potential cost impacts on farms). Council needs to consider when engaging in the limit-setting discussion what small urban town residents can afford, and how soon they can afford it. 4.4 We do not agree with Council that the 20/80 model proposed for road maintenance is a reflection of a policy of delaying renewing of assets. The 80/20 model targets specific roads, while the maintenance approach will apply to all infrastructure based on available evidence. Recommendation 4.5 Federated Farmers supports the Council adjusting its schedule of asset renewals based on better information on the assets’ condition and performance. 5. FUNDING DEPRECIATION 5.1 Federated Farmers supports in part the proposal to fund depreciation, rather than funding capital projects by rates as they occur. We support the proposed phased Federated Farmers Submission to the Southland District Council Draft 10 Year Plan 2015-2025 Page 9 425 approach to this change in policy. Funding depreciation can help to ensure that the rates impact of major capital projects on future ratepayers is not overwhelming. 5.2 We note that the uses of debt for capital projects can also be useful as it spreads the cost out over the useful life of the asset, so today’s ratepayer isn’t paying for the benefit of tomorrow’s ratepayer. So a balance is required, but variable capital expenditure is good practice to start funding depreciation for key assets, along with some debt funding when the time comes. 5.3 We recommend Council undertakes further consultation on how it intends to fund depreciation, if Council decides to proceed with the proposal. There are many considerations that will affect the policy, e.g. which assets should be funded through depreciation and how much of the asset’s worth should be funded through this mechanism. 5.4 In addition, depreciating newly acquired or constructed assets is relatively straightforward. However, trying to create a regime for assets constructed historically will be difficult. As it is rates that will stock-piled to fund depreciation, we consider that ratepayers should have a say on the details of the policy. Recommendation 5.5 Federated Farmers supports a mixed model of funding capital projects through depreciation and debt to ensure that current and future ratepayers are paying appropriate amounts for key assets. 5.6 We recommend Council undertakes further consultation with ratepayers on the details of the depreciation policy. Federated Farmers would like to specifically be involved in this conversation. 6. WHAT’S PROPOSED FOR YOUR WARD 6.1 We support our members’ submissions on proposed local and district projects. 7. RATES 7.1 In the 2015/16 year, Council is proposing to increase the total rates by 3.44%. The Council proposes to increase rates for the remainder of the Plan by between 3.19% and 3.54%. We note that this is better than the 4.0% – 5.7% increases forecast in the last LTP, however, we remain opposed to this increase, especially considering the rates rises over the past few years. 7.2 Comparatively, the Local Government Cost Index is 2.0% in 2015/16, and we would expect Council would seek to cut non-essential spending next year to provide a lower increase. Compared with other Territorial Local Authorities, it appears the Southland District spends a large proportion of operating expenditure on Community Development Federated Farmers Submission to the Southland District Council Draft 10 Year Plan 2015-2025 Page 10 426 and Corporate Support. We consider there should be an effort on the part of Council to economise and reduce spending in these areas. 7.3 Many farmers are going to be significantly worse off than other ratepayers in 2015/16 with total rates rises for small non-dairy farms, and many dairy farms being in the vicinity of 6-8%. This combined with higher property values means that these rates increases will run well into the hundreds of dollars for some farmers. Rates increases like this year after year is unsustainable, especially in the current economic climate where farmers are struggling to break even. 7.4 We note that Council is proposing a maximum rate increase of the Local Government Cost Index plus 2%, which could lead to total rates increases of 5.5% by 2024/2025. Over the next 10 years, if Council achieves its forecast rates will increase by well over 30% in just 10 years. This is unacceptable and suggests Council needs to reconsider its priorities, funding options, and funding constraints. Over this same time period the CPI is expected to increase from approximately 1.75 to 2.5%. Council should aim to keep rates increases within the Local Government Cost Index. Recommendations 7.5 We oppose the forecast rates increases for farmers and consider these are inappropriate and unsustainable. 7.6 Overall, Federated Farmers considers that the Council needs to do more to curb rates increases. We recommend that Council reviews its non-core expenditure and works to finds efficiencies in operations. Uniform Targeted Rate (UTR) 7.7 Council's revenue from the uniform annual general charge and certain targeted rates set on a uniform basis is 25.50% in 2015/16, down from 27.8% in 2014/15. Federated Farmers opposes the proposed drop in the use of the UTR, and considers that Council should set the level of uniform rates at 30% of total rates revenue. 7.8 Apart from 2014/15, Council has reduced the amount of rates recovered through the UTR, to the effect that a larger proportion of rates are allocated on a property value basis. Because farmers are reliant on land for production, this in turn shifts the cost of council activities onto farmers and other ratepayers with relatively high capital values. 7.9 This is not a sound application of funding policy, and does take into account the actual income or financial situation of the ratepayer. Council has only one narrow measure of wealth, that of property value, and this narrow measure provides no accurate indication of a ratepayer’s relative ability to pay. 7.10 Federated Farmers contends that a farming property should not contribute a disproportionate amount to the activities funded by it, where that property has no greater impact than that of a residential property, or where the direct benefits are not captured by the farming property. Federated Farmers Submission to the Southland District Council Draft 10 Year Plan 2015-2025 Page 11 427 Recommendation 7.11 Federated Farmers believes that where Council activities benefit all residents equally, ratepayers should pay the same amount, for example, District Leadership and Support, and Representation and Advocacy. Federated Farmers believes that the UTR is the most appropriate method of funding these activities. Federated Farmers submits that Council can and should fund all of these activities’ costs currently attributed to the general rate using a UTR. Community Services 7.12 Federated Farmers notes that Council has included an additional $250,000 in the plan to assist with the rebuild of Stadium Southland. There is also an increase in the annual grant to assist with ongoing maintenance and renewal costs of Stadium Southland, from $50,000 to $75,000. 7.13 Council notes that “as a regional facility, it benefits the whole of Southland”. As such, we consider that this additional funding should be sourced through a UTR, so that all ratepayers pay the same amount regardless of the value of their property. Recommendation 7.14 Additional funding of Stadium Southland and other Community Services, where the entire community benefits equally, should be sourced through a UTR, so that all ratepayers contribute equally. Funding of Community Development 7.15 Federated Farmers does not consider that destination marketing, community promotions, or business development are core council services, and the provision of these services diverts funding from the provision of vital infrastructure, like roading. If Council is concerned about the impact of increasing cost pressures, these activities should be considered for reduced funding. 7.16 In regards to funding, Federated Farmers considers that the correct funding tool for most Community Development activities is the UTR. However, destination promotion and related activities should be funded as a targeted rate paid only by those commercial ratepayers deemed to receive direct benefit from the promotion of the District as a tourism destination. 7.17 Targeted rates are ideal for the funding of council activities where there are identifiable direct beneficiaries, and a significant ‘private good’ (as opposed to public good) component to the activity. Tourism promotion is a good example of this type of activity. 7.18 Council does this with the Te Anau local rate, where a differential is charged on each of the Residential, Commercial and Accommodation rateable properties in the area. This approach could be easily extended to the entire District for the funding of destination promotion. Federated Farmers Submission to the Southland District Council Draft 10 Year Plan 2015-2025 Page 12 428 7.19 Not only is this more transparent and equitable, but it allows tourism bodies the ability to influence levels of expenditure as appropriate without creating issues of affordability for other ratepayers. A targeted rate also reduces the cost impact of tourism promotion on ratepayers who receive no direct benefit. 7.20 Council justifies using a District – wide rate to fund these activities on the basis of ‘strong spill over benefits from economic development and stronger communities for the District as a whole. Federated Farmers submits that this is no justification for a lack of targeted rating, especially as neither Council nor Venture Southland have undertaken any analysis to ensure that the value added to the District as a result of this promotion spend exceeds the opportunity cost of rating the money from other commercial enterprises, or from households. Recommendation 7.21 We recommend that destination promotion and related activities should be funded as a targeted rate paid only by those commercial ratepayers deemed to receive direct benefit from the promotion of the District as a tourism destination. 8. ABOUT FEDERATED FARMERS 8.1 Federated Farmers welcomes the opportunity to comment on the Southland District Council’s Draft 10 Year Plan 2015-2025 and we acknowledge any submissions from individual members of Federated Farmers. 8.2 Federated Farmers of New Zealand is a voluntary, member-based organisation that represents farming and other rural businesses. Federated Farmers has a long and proud history of representing the needs and interests of New Zealand farmers. 8.3 The Federation aims to add value to its members’ farming businesses. Our key strategic outcomes include the need for New Zealand to provide an economic and social environment within which: Our members may operate their business in a fair and flexible commercial environment; Our members' families and their staff have access to services essential to the needs of the rural community; and Our members adopt responsible management and environmental practices. Federated Farmers Submission to the Southland District Council Draft 10 Year Plan 2015-2025 Page 13 429 Public Health South Dunedin: Private Bag 1921, Dunedin 9054 Invercargill: PO Box 1601, Invercargill 9840 Queenstown: PO Box 2180, Wakatipu, Queenstown 9349 SUBMISSION ON SOUTHLAND DISTRICT COUNCIL’S 10 YEAR PLAN 2015-2025 To: Southland District Council PO Box 903 INVERCARGILL 9840 Details of Submitter: The Southern District Health Board Address for Service: Public Health South Southern District Health Board PO Box 1601 INVERCARGILL 9840 Contact Person: Dr Leanne Liggett Our Reference: 15Mar10 Date: 13 April 2015 Introduction Southern District Health Board (Southern DHB) presents this submission through its Public Health Service. This Service is the principal source of expert advice within Southern DHB regarding matters concerning Public Health. Southern DHB has responsibility under the New Zealand Public Health and Disability Act 2000 to improve, promote and protect the health of people and communities. Additionally there is a responsibility to promote the reduction of adverse social and environmental effects on the health of people and communities. With 4,250 staff, we are located in the lower South Island (South of the Waitaki River) and deliver health services to a population of 306,500. Public health services are offered to populations rather than individuals and are considered a “public good”. They fall into two broad categories – health protection and health promotion. They aim to create or advocate for healthy social, physical and cultural environments. This submission is intended to provide general commentary to the Southland District Council (SDC) relating to the consultation document Working together for Southland’s future. General Comments We wish to commend SDC for the consultation document, it was well set out and easy to read. It clearly identified the key issues and localised activities that council wishes to focus on into the future across the district. The document content reflects the fiscal pressures of the roading network together with managing in an environment of decreasing funding support from the New Zealand Transport Agency. Submissions on Proposed SDC Long Term Plan 2015-25 by Southern DHB Page430 1 of 3 We acknowledge that roading is an important asset for the community and commend the council for taking steps to seal the last section of the Catlins Road as this will have positive safety outcomes for road-users and the local community. Given this increased expenditure, Council has identified it will looking at ways of making existing funding go further. We are of the view that deferring renewals of sanitary works beyond their recognised life-span (through ongoing maintenance) is not seen as a viable long-term solution. All councils have legislative obligations to meet certain statutory requirements. For example, the implementation of approved Water Safety Plans (WSPs) for drinking water supplies cannot be deferred by any council. It is the Ministry of Health’s view that the “affordability clause” is not a valid reason to defer/delay improvements for the drinking water supplies. The council has indicated they will be reviewing assets in communities that have reducing populations. We support current levels of infrastructure provision and maintenance, however, we appreciate that as populations change, alternative infrastructure may need to be considered. As the consequence of reducing maintenance or service provision is highly likely to have detrimental consequences to the public health of affected communities, we will need to be consulted on any proposed changes to public health infrastructure. In the forthcoming Environment Southland 2014/15 Environmental Compliance Monitoring Report, we note that the Wastewater Treatment Plants in areas of Tuatapere and Edendale/Wyndham do not have funding associated with them for ongoing maintenance despite both communities being identified as being in partial or full breach of their conditions of consent in recent reports1,2,3. Recommendations That SDC consult the Public Health Service them when reviewing changes to existing infrastructure which may have an effect on the public health of the community. That SDC continues to prioritise the provision of appropriate infrastructure to fulfil acceptable standards aimed at protecting the public health of communities. We wish to also commend the council with the progress they have made in supporting the Governments vision of Smoke-free Aotearoa 2025 through the provision of policy and display of signage which means: - Our children and grandchildren will be free from tobacco and enjoy tobacco free lives. That almost no-one will smoke (less than 5% of the population will be current smokers); and It will be very difficult to sell or supply tobacco. Enabling active communities through the support of the around the mountain cycle trail and the upgrading of playgrounds is also to be commended. It is, however, noted that beyond the funding shown in the 2015/16 budget, there appears to be no provision for ongoing maintenance. We assume that in future resources will be obtained/allocated to ensure the track, associated facilities and our environment do not bear the consequences of a lack of ongoing maintenance and continue to support active communities. Summary In conclusion we wish to highlight the value gained by our community and our own organisations of working in partnership with local government. This is highly beneficial when considering the impact of various council activities and plans on population health. Positive community health outcomes accrue when local government remains mindful of its potential to impact upon the health of citizens. We value our existing relationships with staff within SDC and 1 2 3 Environment Southland. (2012) Environmental compliance monitoring report 2011/12 Environment Southland. (2013) Environmental compliance monitoring report 2012/13 Environment Southland. (2014) Environmental compliance monitoring report 2013/14 Submissions on Proposed SDC Long Term Plan 2015-25 by Southern DHB Page431 2 of 3 would like to build on this by supporting a Health in all Policies (HiAP) approach being adopted by council and welcome future opportunities to discuss this further with you. We will wish to be heard in support of this submission. Yours sincerely, Dr Leanne Liggett Public Health Analyst Submissions on Proposed SDC Long Term Plan 2015-25 by Southern DHB Page432 3 of 3 Submission 109 Draft LTP 2015-2025 Online Submission Form Your Contact Details Name Southland District Youth Council Organisation Address 15 Forth St, Invercargill Post Code 9810 Do You Want to Speak to Council? I do not wish to be heard in support of my submission Your Feedback Roading Service Levels 433 Submission 109 Draft LTP 2015-2025 Preferred Option: Option One - Move to an 80/20 principle Comment: We, the Southland District Youth Council would like to indicate our support of the proposed plans for maintaining and funding Southland District’s roading network in Council’s 10 Year Plan 2015 – 2025. We believe maintaining and funding the District’s roads is the biggest issue Council will face in the next 10 years. As teenagers living in rural areas, we frequently travel long distances to get to school, to participate in sports and other extracurricular activities, and for social purposes. It is important that Council continues to maintain its roads to the best possible standards that we can afford, to ensure our ability to participate fully in our communities does not decrease. It is crucial that Council continues to maintain its roading network to the best possible standards, to ensure the continued safety of residents. We support Council’s proposal to shift to an 80-20 funding model, which would see funding prioritised based on usage levels. We believe it is crucial that the maintenance of gravel roads also remains at current levels. Roading Rate Model Preferred Option: No preferred option Comment: Sealing the last section of the Catlins road Preferred Option: No preferred option Comment: Ageing Infrastructure - Funding of depreciation Preferred Option: No preferred option Comment: Draft Development Contributions Policy Comment: Draft Maori Freehold Land Policy Comment: Draft Rates Remission Policy Comment: 434 Submission 109 Draft LTP 2015-2025 Draft Revenue and Financing Policy Comment: Early Repayment of Rates Policy Comment: Fees and Charges Schedule Comment: Other Feedback Is there anything else you think we should consider over the next 10 years to help build a better Southland?. Comment: Help us improve this plan! How easy was the Consultation document to read? Very Easy Please comment on how we can improve the plan: 435 Submission 110 Draft LTP 2015-2025 Online Submission Form Your Contact Details Name John and Nancy McHugh Organisation Central Southland Lodge limited Address 232 Great North road Winton Post Code 9720 Do You Want to Speak to Council? I do wish to be heard in support of my submission Preferred Speaking Date. Tuesday 19 May - Morning 436 Submission 110 Draft LTP 2015-2025 Your Feedback Roading Service Levels Preferred Option: No preferred option Comment: Roading Rate Model Preferred Option: No preferred option Comment: Sealing the last section of the Catlins road Preferred Option: No preferred option Comment: Ageing Infrastructure - Funding of depreciation Preferred Option: No preferred option Comment: Draft Development Contributions Policy Comment: Draft Maori Freehold Land Policy Comment: Draft Rates Remission Policy Comment: Draft Revenue and Financing Policy Comment: Early Repayment of Rates Policy Comment: Fees and Charges Schedule Comment: 437 Submission 110 Draft LTP 2015-2025 At the central southland lodge we hold on & off Licences. The charges for these licences have risen by over 300% We understand that the Liquor licencing fees are set under the sale and supply of alcohol Act .We also no that our council have the Discretion to assign fees to a premises that is one level lower On premise sales in southland are experiencing a huge decline and there for the Risk must be a lot lower. As for off licence we are on the same risk level as the local supermarket. This supermarket has the Biggest Beer and wine sales in southland. We are aware that some racing and sports clubs have already had there original fees changed by the southland district council.. We are also seeing some organisations reverting back to BYO events because of the cost and process of getting a special licence. Another concern is the increase in the fee for a duty manager to apply or renew a manager certificate In southland we are losing good managers every week particular part time manager most say it is no longer viable to renew there licence. We all no that the country hotel is a focal point of most communities. Were most meeting.. fundraiser .and the likes are held( most times free of charge) And we would like to see that continue. Thank you for the opportunity to submit on the 10 year plan. John &Nancy McHugh Central Southland Lodge. Other Feedback Is there anything else you think we should consider over the next 10 years to help build a better Southland?. Comment: Help us improve this plan! How easy was the Consultation document to read? Easy Please comment on how we can improve the plan: 438 Submission 111 Draft LTP 2015-2025 Online Submission Form Your Contact Details Name Anke Nieschmidt Organisation The Enviroschools Foundation Address PO Box 4445 Hamilton East Post Code 3247 Do You Want to Speak to Council? I do not wish to be heard in support of my submission Your Feedback Roading Service Levels Preferred Option: No preferred option 439 Submission 111 Draft LTP 2015-2025 Comment: Roading Rate Model Preferred Option: No preferred option Comment: Sealing the last section of the Catlins road Preferred Option: No preferred option Comment: Ageing Infrastructure - Funding of depreciation Preferred Option: No preferred option Comment: Draft Development Contributions Policy Comment: Draft Maori Freehold Land Policy Comment: Draft Rates Remission Policy Comment: Draft Revenue and Financing Policy Comment: Early Repayment of Rates Policy Comment: Fees and Charges Schedule Comment: Other Feedback Is there anything else you think we should consider over the next 10 years to help build a better Southland?. Comment: 440 Submission 111 Draft LTP 2015-2025 Please find attached a submission from The Enviroschools Foundation. Help us improve this plan! How easy was the Consultation document to read? Very Easy Please comment on how we can improve the plan: 441 Submission 111 Draft LTP 2015-2025 Submission to Draft Long Term Plan Southland District Council 2015-25 Name: The Enviroschools Foundation Contact person: Kristen Price, Operations Manager Postal Address: PO Box 4445, Hamilton, 3247 Physical Address: Lockwood House, 293 Grey Street, Hamilton We do NOT wish to speak to this submission Recognising your support for the Enviroschools Programme We would like to acknowledge Southland District Council (SDC) for supporting young people in your region to be part of the Enviroschools network since 2007. The Enviroschools Programme is a nationwide action-‐based education programme where young people plan, design and implement sustainability projects and become catalysts for change in their communities. Enviroschools was originally developed in the late 1990’s by councils in Waikato as a non-‐regulatory tool and has now been adopted by 51 councils, including most of the larger councils and two-‐thirds of the total sector. The programme is managed nationally by The Enviroschools Foundation (a charitable trust). The Foundation has funding from the Ministry for the Environment and works closely with the Department of Conservation. Regional implementation of Enviroschools is through partnerships with Local Government and other community agencies. This multi-‐sector collaboration has enabled nearly 1,000 schools and early childhood education (ECE) centres to now be involved – representing 30% of the school sector and 5% of the large early childhood sector. Locally, 13 schools are part of the Enviroschools network in Southland district, this is 31% of schools in your area. These schools are part of a wider network of 27 Enviroschools in Southland region. This submission encourages SDC to maintain its involvement in Enviroschools along with the other regional partner agencies – Environment Southland, Invercargill City Council, Gore District Council, Department of Conservation and the Southland Kindergarten Association. Highlights from recent programme evaluation The Enviroschools Foundation has been working with a team of external evaluators to quantify the actions undertaken and record the beneficial outcomes of the programme observed by schools and ECE participating in Enviroschools. In late 2014 a nationwide survey of all Enviroschools was conducted as part of the evaluation process. The survey is very robust, with a 73% response rate and highlights include: 1 • Wide participation -‐ Schools were equally able to participate in the Enviroschools Programme across all deciles, sectors and regions. • All age groups (early childhood, primary and secondary) are taking environmental action – across a wide variety of areas including waste, water, biodiversity, food production, energy and eco-‐ building. • Community collaboration-‐ Enviroschools fosters significant community collaboration, creating leadership pathways for students and real connections to families, outside agencies and communities. • Zero Waste – Almost all Enviroschools (100%)1 are taking actions to reduce waste. • Food production – Most Enviroschools (97%) are growing and harvesting produce from their gardens/trees for cooking, selling and gifting. Due to rounding -‐ of 688 schools surveyed, 686 are taking actions to reduce waste. Page 1 of 2 442 Submission 111 Draft LTP 2015-2025 • Biodiversity projects are well developed, with clear links to community – 96% of respondents had biodiversity projects with 86,859 trees planted in 2014 (86% of which were native trees). • Successful water projects – Three quarters of Enviroschools (75%) are undertaking a range of actions for water quality and conservation, including 19,264 meters of riparian planting in 2014. • Tackling energy usage – Just over two-‐thirds of Enviroschools (69%) are involved in energy projects, including actions for sustainable transport (47%) and energy conservation actions (34%). • Enviroschools is contributing to a range of other outcomes including citizenship, health, cultural understanding, motivated learners and community participation. • Depth of practice is related to the extent of outcomes -‐ Results showed that the depth of practice increases with the length of time a school or ECE centre is involved in Enviroschools. Nearly two thirds of participating schools/centres (62%) report ‘quite well developed’ or ‘deep embedded’ practice. Further, the survey results show a clear link between depth of practice and the extent to which the programme is contributing to outcomes. This reinforces the value of the long-‐term approach of the Enviroschools Programme. “The strength of Enviroschools lies in the collaborations and multiple relationships that have been established and continue to be nurtured through its model of facilitated, networked and distributed leadership, engaging communities, schools and other stakeholders in action aimed at creating sustainable communities.” The evaluators, Kinnect Group Name change for The Enviroschools Foundation During April 2015 the name of our organisation is changing from The Enviroschools Foundation to Toimata Foundation. The new name will take effect fully on 1 May 2015. The two programmes currently supported by the Foundation, Te Aho Tū Roa and Enviroschools, are retaining their current names, logos and identities. We are writing to the Mayor/Chair and Chief Executive of all our partner councils in the week of 20th April with more information about this change. Conclusion The Enviroschools Programme has a proven track record of being an effective approach for engaging schools and communities in environmental and social action. With the backbone support of The Enviroschools Foundation, and a network of councils around the country, the programme catalyses learning and action among thousands of young people, their families and communities from early childhood to secondary school. By connecting and coordinating resources and people, openly building and sharing knowledge across communities, widespread action is enabled on a broad scale. As a funder, the partnership with Enviroschools provides SDC with multiple points of leverage across the Southland community, extending the possible impact of its funding beyond what might be expected with a more traditional approach. Page 2 of 2 443 Online Submission Form Your Contact Details Name Brendon McDermott Organisation Sport Southland Address PO Box 224, Invercargill Post Code 9840 Do You Want to Speak to Council? I do wish to be heard in support of my submission Preferred Speaking Date. 444 Tuesday 19 May - Morning Your Feedback Roading Service Levels Preferred Option: No preferred option Comment: Roading Rate Model Preferred Option: No preferred option Comment: Sealing the last section of the Catlins road Preferred Option: No preferred option Comment: Ageing Infrastructure - Funding of depreciation Preferred Option: No preferred option Comment: Draft Development Contributions Policy Comment: Draft Maori Freehold Land Policy Comment: Draft Rates Remission Policy Comment: Draft Revenue and Financing Policy Comment: Early Repayment of Rates Policy Comment: Fees and Charges Schedule 445 Comment: Other Feedback Is there anything else you think we should consider over the next 10 years to help build a better Southland?. Comment: Please see attached submission Help us improve this plan! How easy was the Consultation document to read? Easy Please comment on how we can improve the plan: 446 Submission to Southland District Council’s 10 Year Plan 2015-2025 from Sport Southland 447 SPORT SOUTHLAND Southland’s Regional Sports Trust Sport Southland sees the Southland District Council as a key strategic partner in fulfilling both of our respective visions to “have thriving, healthy communities” and “for more Southlanders to be actively engaged in sport and recreation.” The research is clear about the value that sport and recreation has to offer across the multitude of areas in our community including health and wellbeing, economic and social. We are very interested in working more collaboratively with Council in future and within this submission you will find a number of ways in which we could look to do so. 1.0 Support the ongoing Heads of Agreement between Venture Southland and the three contributing Territorial Authorities Refers to: Community Development Activity Profile, P2 (1.4. How We Manage Our Services) Sport Southland has developed a positive working relationship with Venture Southland and strongly supports its position around shared services on behalf of the three Territorial Authorities, its priorities and specific projects that contribute to enhancing the Southland region’s development and quality of life of its communities. 2.0 Support for the Around the Mountains Cycle Trail Refers to: Main Document, P17: Around the Mountains Cycle Trail Sport Southland supports the completion of the Around the Mountains Cycle Trail. We believe this will be a valuable asset for the community, providing excellent recreational opportunities. We support the completion of this trail, that it showcase the best that Southland has to offer but with minimal disruption to existing recreational groups and activities in the affected area. Collaborative approach: Sport Southland has an in-house events team that is experienced in co-ordinating and supporting recreational events. Sport Southland could potentially partner with Venture Southland to develop an event to promote usage of the trail. 2 Sport Southland Our Purpose: For more Southlanders to be actively engaged in sport and recreation 448 3.0 Recommend that the Southland District Council name Sport Southland as a collaborative partner in documents of importance Refers to: Community Development Activity Profile, P5; Section 3.1 – Community Development Sport Southland would like to be considered a key collaborative partner in community development activities, and named as such within this document. We refer specifically to the section under Activity Customers in the Community Development Activity Profile. 4.0 Support funds being set aside to contribute towards Stadium Southland as a regional asset Refers to: Community Assistance Activity Profile, P4; Section 2.2 Activity Profile Highlights and key assumptions Sport Southland congratulates Council for seeing the wider benefits of Stadium Southland as a key regional facility, which benefits the entire Southland community. 5.0 Recommend steps be taken to develop a Regional Sport and Recreation Strategy Sport Southland sees a need for the development of a Regional Sport and Recreation Strategy and recommend the scoping of this work be included in Southland District Council’s 10 Year Plan. We would also seek a commitment to start this work within the next three years. We will be making this recommendation across all three Territorial Authorities as we believe regional buy-in will be integral to any such strategy. Sport Southland would be interested in playing a lead role in any such strategy, which could encompass the following (including, but not limited to): 3 Facilities; in particular ageing sport and recreation facilities and strategies around ongoing maintenance and future proofing Southland Regional Facilities – financial support across all three Territorial Authorities towards key identified regional sport and recreational facilities Framework for funding of new or upgrading of existing facilities from regional sporting bodies and clubs Usage statistics and the sustainability of facilities, in particular bowling clubs, golf clubs, swimming pools (school and community), rugby clubs and squash clubs Parks, playgrounds and recreational space Declining volunteer rates Sport Southland Our Purpose: For more Southlanders to be actively engaged in sport and recreation 449 Barriers and perceived barriers to participation in sport and recreation Changing demographics (including age and ethnicity) and potential impact on participation in sport and recreation 5.1 Support for the development of a Regional Cycle Way Strategy Refers to: Community Development Activity Profile, P3: Joint projects to be delivered over the short-term future Sport Southland sees benefit in a Regional Cycle Way Strategy and support the development of such a strategy across all three Territorial Authorities. We believe such a strategy would sit well within a wider Regional Sport and Recreation Strategy (as per Recommendation 5.0 in this submission) that identifies existing infrastructure, community interest including current levels of participation and a wider framework of good practice. Collaborative approach: Strategic region-wide work focussing on sport and recreation is an area Sport Southland is interested in working more closely with Council on in the future. We would like to be considered as a key partner in the development of any strategic, regional document relating to sport and recreation and would be interested in playing a key role with this work. 6.0 Support for the ongoing grant towards the Learn to Swim programme in Southland Whilst this is not referenced specifically in the 10 Year Plan, we would like to acknowledge and thank Council for its recent continuation in support of the rural Learn to Swim Programme in Southland. Sport Southland continues to play a key role in this programme, which is reaching thousands of primary-school aged children in Southland and teaching them potentially life-saving skills. Southland continues to be the only region that provides quality swim instruction to each of its primary aged children regardless of where children live and learn. 4 Sport Southland Our Purpose: For more Southlanders to be actively engaged in sport and recreation 450 Online Submission Form Your Contact Details Name David Pannett Organisation Creative New Zealand Address Level 10, Aorangi House 85 Molesworth Street Wellington Post Code 6011 Do You Want to Speak to Council? I do not wish to be heard in support of my submission 451 Your Feedback Roading Service Levels Preferred Option: No preferred option Comment: Roading Rate Model Preferred Option: No preferred option Comment: Sealing the last section of the Catlins road Preferred Option: No preferred option Comment: Ageing Infrastructure - Funding of depreciation Preferred Option: No preferred option Comment: Draft Development Contributions Policy Comment: Draft Maori Freehold Land Policy Comment: Draft Rates Remission Policy Comment: Draft Revenue and Financing Policy Comment: Early Repayment of Rates Policy Comment: Fees and Charges Schedule Comment: 452 Other Feedback Is there anything else you think we should consider over the next 10 years to help build a better Southland?. Comment: Help us improve this plan! How easy was the Consultation document to read? Very Easy Please comment on how we can improve the plan: 453 21 April 2015 Southland District Council 15 Forth Street INVERCARGILL 9810 Via online submission Submission on: Southland District Council’s Draft Long Term Plan 2015-2025 From the: Arts Council of New Zealand Toi Aotearoa (Creative New Zealand) 1. Creative New Zealand welcomes the opportunity to consider and make submissions on Southland District Council’s Draft Long Term Plan 2015-2025 (the Plan). 2. Creative New Zealand does not wish to be heard in support of this submission. 3. The key contact person for matters relating to this submission is: Name: Position: David Pannett Senior Manager, Planning, Performance and Stakeholder Relations Submission 4. While the purpose of local government under the Local Government Act 2002 (as amended in 2014) is ‘to meet the current and future needs of communities for good-quality local infrastructure, local public services, and [the] performance of regulatory functions’, we note that local authorities are also required under the same legislation to take into account the ‘cultural interests of people and communities’ (section 14(1)(h)(i), Local Government Act 2002). This provides a legislative basis for supporting local arts and culture. 5. There is also a growing body of research relating to the contribution of the arts to a community’s social cohesion as well as to an area’s economic prosperity. This research includes the findings of our own triennial survey, New Zealanders and the Arts. The most recent survey was carried out in late 2014 and is due for publication this June, and tells us that: most New Zealanders (71 percent) want their local council to continue to support the arts; this response has not changed since the study began in 2005 69 percent of people agree with the statement ‘My community would be poorer without the arts’ the majority of New Zealanders continue to be very positive about all aspects of the arts, which is driving high levels of engagement with the arts in New Zealand 454 there have been significant increases in the levels of both attendance and participation in the arts among New Zealanders since 2011 89 percent have attended or participated in at least one arts event in the last 12 months compared to 85 percent in 2011. 6. Over the years, Creative New Zealand has taken an active interest in local authorities’ strategic plans, and the ways in which they support arts and culture in their respective districts. We also support the development of specific arts and cultural strategies, to further clarify local authorities’ commitments in these areas. 7. We note that Council’s spending on community services increases over the life of the Plan, through modest annual increases over the 10-year period. While this is pleasing to see, it is difficult to see specifically where the arts fit within this broader umbrella (and therefore to properly comment on Council’s commitment to the arts in the Southland District). We would therefore encourage Council to make specific reference to the arts and arts related activities within the Long Term Plan, in recognition of the important contribution such activities make to Southlanders’ wellbeing (ie, they ‘contribute to Southland’s communities being desirable places to grow up, work, run a business, live, raise a family, retire and enjoy a safe and satisfying life’). 8. Creative New Zealand has identified the Southland region as one of two regions in which to deliver a two-year regional pilot programme. Our Audience Atlas research tells us there is a large ‘culture market’ in the Southland region, with 98 percent of adults (73,000 people) attending at least one cultural event or place within the last three years (this is compared to 94 percent in 2011). Through our regional pilot programme, we planning to invest an additional $400,000 into the Southland region, on top of our other investments and grants made to local artists and organisations. 9. Our consultation in Southland has highlighted some priorities in the area with regard to arts and culture. These include: support for the establishment of a regional arts development body, audience and market development for key arts organisations, capability building of local artists and arts organisations, and support for regional arts projects that increase access and participation. We encourage Council to develop strategies and policies to address these priority areas and which take account of the economic and social benefit that a strong arts sector can bring to a district. 10. Finally, Creative New Zealand provides and annual allocation of $26,729 to Council as part of the Creative Communities Scheme. These funds go via Council to directly support local arts activities. We are grateful for your assistance in this important work, and for recognising the importance of the arts in enabling thriving, healthy communities. Background on Creative New Zealand 11. Creative New Zealand is New Zealand’s arts development agency, responsible for delivering government support for the arts. Creative New Zealand is an autonomous Crown entity continued under the Arts Council of New Zealand Toi Aotearoa Act 2014. 12. Creative New Zealand receives funding through Vote: Arts, Culture and Heritage, and the New Zealand Lottery Grants Board. In 2013/14, Creative New Zealand invested over $39 million in the arts sector nationally. 13. Creative New Zealand’s Strategic Plan 2013–16, Te Mahere Rautaki 2013–16, identifies the four outcomes we are seeking to achieve on behalf of all New Zealanders: New Zealanders participate in the arts 2 455 14. high-quality New Zealand art is developed New Zealanders experience high-quality arts New Zealand arts gain international success. Creative New Zealand contributes to achieving these outcomes by delivering programmes in the following areas: funding for artists, practitioners and organisations capability-building for artists, practitioners and organisations advocacy for the arts. Thank you again for the opportunity to comment. Please do not hesitate to contact me if you wish to discuss this submission. Yours sincerely David Pannett Senior Manager, Planning, Performance and Stakeholder Relations 3 456 Online Submission Form Your Contact Details Name Sarah Hannan Organisation Southland Chamber of Commerce Address 150 Tay Street Post Code 9840 Do You Want to Speak to Council? I do not wish to be heard in support of my submission 457 Your Feedback Roading Service Levels Preferred Option: No preferred option Comment: Roading Rate Model Preferred Option: No preferred option Comment: Sealing the last section of the Catlins road Preferred Option: No preferred option Comment: Ageing Infrastructure - Funding of depreciation Preferred Option: No preferred option Comment: Draft Development Contributions Policy Comment: Draft Maori Freehold Land Policy Comment: Draft Rates Remission Policy Comment: Draft Revenue and Financing Policy Comment: Early Repayment of Rates Policy Comment: Fees and Charges Schedule Comment: 458 Other Feedback Is there anything else you think we should consider over the next 10 years to help build a better Southland?. Comment: Submission is attached Help us improve this plan! How easy was the Consultation document to read? Very Easy Please comment on how we can improve the plan: Excellent document, easy to follow and understand 459 21 April 2015 Southland Chamber of Commerce Submission on the Southland District Council Long Term Plan 2015-2025 The Long Term Plan is business-like and provides a sound platform on which to build and explore scope for improved efficiency, work smarter and be more innovative, and do it in a way that tells the Southland Council story of what it is seeking to do better to live within its means; and at the same time acknowledge Council has limited resources. Council is setting a good example and giving certainty to the business community in limiting annual rate increases to 2% - the Consumer Index. There is scope to extend the shared services statement with other councils to achieve economies of scale in areas such as roading repairs, materials, office supplies, administration, computer services etc. There is also scope to explore alternatives to dependence on rates. Council states that it will limit rates to less than two-thirds of revenue. This gives certainty, but with looming concerns about ‘aging infrastructure’, now might be the time to explore specific options that build on the commitment to introduce a culture to work smarter and be innovative. Review the potential opportunity to look at a strengthened inflation-indexed cost for core services, and reduce the 2% even lower which could provide the opportunity to retain rate increases for clearly beneficial capital works within specified time frames for them. The document stresses the importance of funding of roads, the concerns on aging infrastructure and whether to provide new water supply and wastewater schemes. There could be options to invite private sector participation/ investment to provide ‘user pay’ services? Similarly, there is mention about the need to improve energy supply for Stewart Island. Is this an opportunity to look at ‘renewable’ energy self-sufficiency options for the Island? The price of renewable energy supply options has been coming down recently; in the 10-year time frame it could be a very competitive option? What is the status of the Venture Southland renewable energy project? Thank you for the opportunity to submit our views on the Southland District Council Long Term Plan 2015-2025. We would ask for a review of Southland District Council Consultation Process to allow sufficient time for public submissions. Kind regards Sarah Hannan Chief Executive 460 Online Submission Form Your Contact Details Name Fiona Morton Organisation Hospitality NZ Address PO Box 426 Invercargill Post Code 9840 Do You Want to Speak to Council? I do not wish to be heard in support of my submission 461 Tuesday 21st April 2015 Southland District Council 10 Year Plan Submission The Hospitality New Zealand Southland Branch welcomes the opportunity to submit on the Southland District Council 10 Year Plan. Membership of Hospitality New Zealand is voluntary, is primarily funded by member subscriptions and comprises predominantly small to medium size businesses. Members include restaurants, café bars, taverns, country hotels, motor inns, off-licensed premises and accommodation providers. Hospitality New Zealand provides advice to its members on a wide variety of industry and compliance issues. Service delivery to members is provided through a team of eight Regional Managers based at local branches around New Zealand, supported by a service team in Wellington. Service is delivered through personal visits, telephone, email and other contact. Through membership servicing, Hospitality New Zealand is able to gauge the views and experiences of a wide variety of hospitality businesses in New Zealand. The Southland Branch of Hospitality New Zealand covers from Stewart Island to Raes Junction and from the Catlins through to Milford Sound. The branch consists of 90 members with 44 of these members in the Southland District Council region. The membership consists of bars, taverns, restaurants, cafes, B&Bs, hotels, bottle stores through to five star luxury lodges. Hospitality New Zealand Southland Branch has considered the key issues provided in the Southland District Council 10 Year Plan and will comment specifically on the Fees and Charges Schedule section of the Plan. Hospitality New Zealand Southland branch recently held a meeting with members to discuss concerns with the dramatic increase in licensing fees that were introduced with the Sale and supply of Alcohol Act 2012. Some members have had an increase in licensing fees of 300% plus. While it may be observed that the Sale and Supply of Alcohol Act (the Act) increases the range of monitoring and enforcement activity, Hospitality NZ Southland Branch also observes that the Act has also increased compliance with increased penalties and sanctions for non compliance meaning that licensees now face greater consequences for licensing breaches. As 462 a result, licensees have more at risk – including their entire business in some cases. Accordingly, licensees have taken on board this development and are even more focused on compliance. These higher levels of compliance therefore reduce the need for monitoring and enforcement activity and subsequent costs accordingly. Hospitality New Zealand Southland branch also believes that there should be an additional column in the fees table for the yearly renewal. The cost of the yearly renewal verses the application fees should be very different due to there being less work involved. It is agreed that when an application for a license is made there is a longer process and support the cost recovery of this process. However, for a yearly renewal there will be minimal work required and the yearly fee should reflect this. Hospitality New Zealand Southland branch strongly believes there should be a discount for business for good behaviour. In the Southland Branch there are many businesses that operate successful and safe environments for their patrons. Why should these businesses that have a clean record be penalised for staying open past 1am when they operate a good business with no holdings? A country hotel in Winton that trades past 1am will not have the same issues as an Auckland bar that trade in the Viaduct, so why should they have to pay the same fee? It is agreed that liquor licensing fees are set under the Sale and Supply of Alcohol Act (Fees) Regulations 2013, however as a Council you will agree that one size does not fit all. At an Industry breakfast held in Invercargill in July 2013, the Southland District council indicated that the fees set out were too high and would be seen as a money making exercise. Hospitality New Zealand Southland branch advise that there are two options available to Council to resolve these issues: 1. Hospitality New Zealand Southland branch would like to see these fees set regionally through a local bylaw that are specific to the Southland District Council region. The fees should be cost recovery only and there will be varying costs associated for each council, which is why Hospitality New Zealand Southland branch believe they should be set regionally. 2. Under the Sale and Supply of Alcohol Act (Fees) Regulations 2013 the Council has the ability to drop licensing fees by one level at its discretion: 6 Fees categories for premises (4) A territorial authority may, in its discretion and in response to particular circumstances, assign a fees category to premises that is 1 level lower than the fees category determined under subclause (1); but no premises may be assigned a category lower than very low. Central Otago District Council have done this already for all licensees, as the fees prescribed in the Act are too high for the region. Hospitality New Zealand Southland branch strongly request that this should be adopted for all liquor licenses in the 463 Southland District region. This would be the most effective way in reducing licensing fees, without the additional cost on the rate payer if it had to go to a bylaw change. Hospitality New Zealand Southland branch also has strong concerns over the fees to apply for or renew a managers certificate. In Southland we are struggling to find good employees who want to hold a mangers certificate, due to the increase in pressures from the Policing of licensed premises. Add in the increase in fee to $316.25 to apply or renew a managers certificate and you can see why we are losing those good part time/casual employees from the industry as they cannot afford to hold a license. The Southland Branch is aware that these fees are set under the Sale and Supply of Alcohol Act (Fees) Regulations 2013, but feel that it is important that it is drawn to your attention. Hospitality New Zealand Southland branch thank you for the opportunity to submit on the Southland District Council 10 Year Plan. Kind regards, Fiona Morton Regional Manager On behalf of Hospitality NZ Southland Branch 464 Your Feedback Roading Service Levels Preferred Option: No preferred option Comment: Roading Rate Model Preferred Option: No preferred option Comment: Sealing the last section of the Catlins road Preferred Option: No preferred option Comment: Ageing Infrastructure - Funding of depreciation Preferred Option: No preferred option Comment: Draft Development Contributions Policy Comment: Draft Maori Freehold Land Policy Comment: Draft Rates Remission Policy Comment: Draft Revenue and Financing Policy Comment: Early Repayment of Rates Policy Comment: Fees and Charges Schedule Comment: 465 Other Feedback Is there anything else you think we should consider over the next 10 years to help build a better Southland?. Comment: Help us improve this plan! How easy was the Consultation document to read? Very Easy Please comment on how we can improve the plan: 466
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