Our submission on Tūpuna Maunga Authority / Auckland Council's 2023/24 Draft Operational Plan and Budget
Here is our submission on Tūpuna Maunga Authority’s 2023/24 Draft Operational Plan and Budget. Both the Authority and Auckland Council have invited public submissions on their budgets so we encourage you to have your say. While you are welcome to use our submission to inform your own, please do not simply copy our submission.
Table of contents
Introduction / executive summary
Proposed financial changes to the 2023/24 draft budget
Considerations re: the revegetation programme’s capital expenditure
Considerations re: pest-proof fencing short- and long-term budgetary implications
Considerations re: Love Your Maunga events
How the recent slips reveal safety and legal liability risks inherent in tree removal
A call for there to be integrity in TMA and Auckland Council’s “consultation” processes
How to make a submission
Introduction/executive summary
This submission is made against the backdrop of Auckland Council needing to overcome a budget shortfall of $295 million in the 2023/24 financial year. The Council has signalled this issue may require significant cuts to be made to many regional services such as community and education programmes, regional events, economic development, and social services activities such as homelessness funding, community empowerment and funding for youth centres, etc.
All parts of the organisation and Council-funded entities (including Tūpuna Maunga Authority) have been asked to cut costs, with budget ‘no go’ areas including any new operational or capital spending not locked in with contracts, and to pause work which has started, if possible. Furthermore, spending on “professional services” and using money unspent in existing budgets is also not allowed.
It is important to note Tūpuna Maunga Authority’s requested 2023/24 budget is more than last year’s budget, which in itself was 20% above the previous year’s budget (even though Auckland Council was in cost-cutting mode last year too). See the full document here.
Our submission proposes savings of $1,119,693 from the following budget lines:
• “Network-wide vegetation restoration programme capital expenditure to remove vegetation and reinstate and/or revegetate”
• “Pest proof fencing”.
• “Love Your Maunga events”.
• “Ōwairaka - Annual vegetation maintenance including control of cherry and privet”.
• “Ōwairaka pest management - undertake animal and pest control.”
In addition to providing the rationale for our budget cut recommendations, we also discuss:
• The need for more clarity, consistency increased accuracy and less ambiguity in how the operational plan and budget information is presented, particularly regarding the vegetation-related budget lines. We propose ways to better present this information.
• How the recent slips reveal significant safety and liability risks inherent in tree removal.
• A call for there to be integrity in TMA and Auckland Council’s “consultation” processes.
Proposed financial changes to the 2023/24 draft budget
We recommend the following financial changes be made:
| Budget type | Total requested | What we propose | Savings | Notes |
|---|---|---|---|---|
| Total budget requested Ref page 24 of the TMA’s Draft Operational Plan and budget |
12,878,000 | 11,758,307 | 1,119,693
As detailed in the rows below |
The TMA’s requested budget represents an increase over last year’s budget of 12,475, which in itself was a 20% increase over the previous year’s budget. |
| Network-wide vegetation restoration programme to remove vegetation and reinstate and/or revegetate
Ref page 26 |
1,160,000 | 160,000 for planting only | 1,000,000 | For more information see below under: Considerations re: the revegetation programme’s capital expenditure. |
| Pest proof fencing Ref pages 26 and 30 |
50,000 | 0 for planting only | 50,000 | See comments below. Note the plan indicates this budget will rise to $2 m next year. |
| Love Your Maunga events Ref page 28 |
82,499 | 35,000 | 47,000 | See comments below. |
| Ōwairaka - Annual vegetation maintenance including control of cherry and privet Ref page 63 |
7,399 | 0 | 7,399 | The cherries are not listed pests and TMA documentation lists only 1 privet on the maunga, which is a small tree that could be removed at little cost. |
| Ōwairaka pest management - undertake animal and pest control Ref page 63 |
16,294 | 1,000 for animal pest control (rabbits). | 15,294 | Engage local community volunteers for possum and rodent trapping. $0 for plant pest control, given there are very few ARPMP listed plants on the maunga. The budget should provide separate animal / plant pest control budgets, particularly if different suppliers do each of these activities. |
If we can find $22,693 worth of savings specific to Ōwairaka then it would suggest similar savings may also be possible on the other maunga, potentially resulting in six-figure savings.
Considerations re: the revegetation programme's capital expenditure
As shown on page 26, $1,160,000 capex has been allocated for vegetation removal / revegetation in the coming financial year (with similar amounts allocated in future years). It is important to take the following considerations into account when considering this budget line:
• This budget should be separated into two separate lines: 1. Planting 2. Vegetation removal.
• We note that none of the maunga-specific budgets provide full transparency on individual maunga capital expenditure. Maunga by maunga capex is provided for things like boardwalks and pest proof fencing, but there is only network-wide detail relating to the revegetation programme. There should be a consistent and transparent approach to all maunga-specific capital and operational expenditure, which means revegetation programme budgets should be provided for each maunga.
• Information gained during various official information requests show that vegetation removal costs by far outweigh revegetation costs. It is therefore assumed that vegetation removal costs comprise the bulk of this budget line.
• This budget line should be considered in the context of the Authority’s October 2022 public consultation around its tree felling intentions on four maunga (Ōwairaka Mt Albert / Ōtāhuhu Mt Richmond / Puketāpapa Mt Roskill and Te Tātua a Riukiuta Big King). That consultation received overwhelming public opposition to the tree felling, with 93% of nearly 1600 submitters being against and only 6% for (1% were out of scope). A number of those against felling the trees self-identified as affiliating to Tāmaki iwi.
• Similar opposition levels have been seen in the annual budget consultations.
• More than 11,000 people have signed online / hard-copy petitions against felling Ōwairaka’s trees.
• As the past 3.5 years have shown, there is almost no public appetite for felling the maunga trees. If the Authority proceeds, then significant additional budget will be required in relation to major public protests and potential legal action.
• Last year DoC announced it would fund the TMA $3 million for pest eradication on the maunga.
There needs to be more clarity and less ambiguity in how the operational plan and budget information is presented
The budget’s vegetation information is presented in a confusing and opaque manner that makes it difficult to understand what is intended. In every TMA related consultation from 2020 onwards, submitters have highlighted concerns about ambiguous wording, inaccuracies, obfuscation, etc., and requested the wording be amended to be clear and accurate. Despite this, neither TMA nor Auckland Council ever directs any action to rectify these issues.
The Court of Appeal specifically highlighted concerns about the Authority’s ambiguous wording in relation to its tree felling intentions, yet those very same words remain in this draft budget and plan. Members of the public should not need to be familiar with judicial decisions and the IMP in order to be able to interpret the annual operational plan and budget. Even those such as HTM who are deeply familiar with these documents are still none-the-wiser over which trees TMA intends to fell, on which maunga, and when. This poor practice opens up both TMA and Auckland Council to the risk of legal action in future and further widens the public lack of confidence and trust in this co-governance entity and also in Auckland Council.
We propose the following vegetation-related budget lines are all presented in a transparent and unambiguous manner that provides network-wide grand totals and associated sub-totals for each individual maunga.
• Routine vegetation maintenance operational expenditure (lawn-mowing, grass trimming, etc.)
• Non-routine vegetation maintenance contingency operational expenditure (e.g. arboriculture for damaged or fallen trees, etc.)
• Vegetation capital expenditure - planting (currently listed as ‘vegetation restoration’)
• Vegetation capital expenditure – tree removal
• Love Your Maunga events
Additional corrections and comments
| Page | Correction |
|---|---|
| 15, 18, 19, etc. | There are a number of references to “inappropriate exotic trees”, “Pests” and “weeds” throughout the document. Judges in the Court of Appeal hearing commented on this ambiguous language in the Authority’s plans, yet nothing has changed.
These terms need to be clearly defined so there are no ambiguities. For example, the Authority recently has signalled that some exotic specimen trees may be retained but given no indication of how many, where, or what the criteria is. It is therefore unclear which exotic trees are deemed “inappropriate” and which are not, and what constitutes being “inappropriate”. Furthermore, the terms ‘pests’ and ‘weeds’ are used interchangeably – they are not the same and these terms should be used correctly. |
| 63, 67, 70, 78 | All references to cherry removal should be removed from throughout the operational plan, particularly for Ōwairaka. The TMA is very well aware that Ōwairaka’s Japanese cherries are a sterile cultivar Prunus Serrulata, which is not listed as a pest in the Auckland Regional Pest Management Plan 2020-2030. It appears the same Japanese cherry cultivar also grows on other maunga. |
Considerations re: pest-proof fencing short- and long-term budgetary implications
The TMA’s draft operational plan for Matukūtururu Wiri maunga shows an intention to put a kiwi sanctuary on the maunga in 6-10 years’ time, with the requested $50,000 being the beginning of the fencing project process and rising to $2 million next year. These figures are in addition to the $100,000 already allocated in the current year’s operational plan and budget. Yet this draft operational plan allocates no budget to revegetation on that maunga despite there only being small areas of native plantings.
There are significant ongoing budget and other considerations to be considered in relation to voting budget for putting kiwi on any maunga given that the urban locations make these flightless birds particularly vulnerable to theft.
The following questions also need to be asked in relation to this budget request:
• Will pest-proof fenced areas require ongoing ratepayer funded budget for permanent security on the fenced sites?
• Will public access to these areas be restricted?
• In future, will the public be required to pay entry to areas where there are kiwi or other endangered species?
• We already have a zoo in the city – do ratepayers need to be funding another, especially when Auckland Zoo is likely to experience funding cuts going forward?
• Has the Authority sought expert advice to confirm that kiwi populations could be sustained in a small, fairly open area such as Matukūtururu Wiri? Are any such reports or advisories available to decisionmakers?
• Has consideration been given to how ongoing care will be funded for kiwi and other wildlife within the pest proof fenced areas? These are small rather dry areas, so ensuring adequate food and water will be an ongoing issue.
Also, has consideration been given to how kiwi sanctuaries on any maunga fit within the overall biodiversity plan for Auckland? It is important to bear in mind that the maunga do not exist in isolation of the rest of Tāmaki Makaurau Auckland; they are a vital and integral part of the region’s biodiversity corridor from north to south and for migratory species that travel across the Hauraki Gulf.
As can be seen in the Appendix A photos below, Matukūtururu Wiri is very weedy and overgrown at present and has only a small area of new native plantings. We support budget for paths and native plantings but question any budget being allocated to pest proof fencing and/or kiwi sanctuaries given:
• the current state of the maunga
• the lack of produced expert advice and assessment of the viability of such a project
• how it fits with Zoo funding
• its long-term cost consequences to a cash strapped Auckland Council
There are also potential liability issues (e.g. compliance with the Wildlife Act 1953) that TMA members and Auckland Councillors need to be comfortable about before making a decision on this proposal.
Also, we note that the draft operational plan signals that next year’s budget will allocate an additional $100,000 to begin the process of installing pest proof fencing on Puketāpapa Mt Roskill (ref page 66). Despite it being required under the Reserves Act, there is no individual maunga plan for Puketāpapa Mt Roskill beyond some broad tree-related specifics included as an amendment to the TMA’s Integrated Management Plan. This means there is no context for what purpose pest proof fencing will serve at that maunga. Furthermore, the same issues apply to proposals to put kiwi on Puketāpapa/Mt Roskill apply to our comments, in the paragraph above, on pest proof fencing relating to Matukutūruru/Wiri.
Considerations re: Love Your Maunga events
As seen on page 17 of the draft operational plan and budget, $82,499 has been allocated to a target of 30 events.
Given deep cuts being made to Auckland Unlimited and other public services, and the associated job losses, we question this level of event funding in the TMA’s proposed budget.
This is especially given that many of the previous “Love Your Maunga” events have been poorly promoted and poorly attended. For example, at this pictured Love your Maunga event at Mangere in February 2020, most attendees were either tree protestors or people who were clearly closely associated with the Authority.
An event held at Puketāpapa Mt Roskill not long afterwards appeared to have no members of the public at all besides Honour the Maunga and other tree protectors.
How the recent slips reveal safety and legal liability risks inherent in tree removal
The January deluge resulted in numerous slips on various maunga, including a large one on Ōwairaka Mt Albert that resulted in several homes being red/yellow stickered. The Maungakiekie One Tree Hill and Ōhinerau Mt Hobson slips resulted in significant damage to archaeological features such as terracing and middens.
All TMA and Governing Body members have been sent a letter detailing our concerns. Since that letter was sent, a leading geologist Bruce Hayward analysed the Maungakiekie One Tree Hill slips and noted the correlation between the slips and a lack of trees on the slip affected areas. In addition to the points raised in our letter (refer to Appendix B), please also take the following matters into account when considering the 2023/24 draft operational plan and budget.
In a recent television interview, the TMA representative misleadingly attempted to imply that exotic trees were to blame for the slips even though all slips occurred on un-treed sections of steep slopes. Surrounding trees (which were, for the most part, exotic) played a vital role in preventing the slips being wider or from flowing further down the slope. This was certainly the case at Ōwairaka, where a group of trees further down the slope were uprooted when the slip came down onto them but stayed upright and played a vital role in stopping the slip from progressing further into people’s properties.
At present there are three live resource consents for felling trees on Ōtahuhu Mt Richmond, Puketāpapa Mt Roskill and Te Tātua a Riukiuta Big King (Ōwairaka Mt Albert’s was set aside as a result of the Court of Appeal ruling). The fact that the Court of Appeal set aside the Ōwariraka resource consent should give Auckland Council cause to revisit the other active resource consents as similar facts apply to each resource consent granted to the TMA for maunga exotic tree clearances. None of the TMA resource consents for exotic tree clearance include any reference to geotechnical or hydrology reports for these maunga. As has been seen, bare maunga slopes are slip-prone – a risk that will be significantly increased if trees are removed from those slopes.
In addition to their climate management contributions, mature native and non-native trees are well-known to reduce stormwater runoff and increase slope stability, particularly on steep slopes.
Continuing to support the TMA’s current tree felling programme creates significant future liability and slip remediation risks for both Tūpuna Maunga Authority and Auckland Council – not to mention increased health and safety risk to the public.
Note that the recent extreme weather events saw a small number of trees come down across the maunga network in areas not affected by slips. This should not be used as an excuse to fell more trees. We have received the following advice from arboriculture and parks management experts in relation to native vs non-native trees’ weather resilience:
1. There is no research comparing native New Zealand trees' root systems or weather-related resilience with non-native ones.
2. Removing either native or non-native trees from a group puts all the remaining trees at risk because the trees' root systems support each other. It takes time for the remaining trees to adapt to no longer having the root system support of the removed ones, thus putting them at greater risk of disease or falling.
3. Any tree (whether native or non-native) will be at increased risk of either falling over or having branches drop off if they are poorly maintained.
4. Tree safety is always measured against standard weather conditions. In extreme weather such as a cyclone any tree is at risk of falling due to high winds and/or ground saturation.
5. There are 345 exotic trees on Ōwairaka of which 2 failed because of the wind and ground saturation from runoff (as opposed to the slip). That’s a failure rate of only 0.6% during Auckland’s highest-ever recorded rainfall and wind.
Going forward we request that Auckland Council consider implementing a requirement that a ground and slope stability assessment plus hydrology reports for stormwater runoff and intermittent streams be produced BEFORE any mature tree is removed on maunga and other slopes in Auckland. It is particularly important when a number of trees are to be removed in one clearance event. Council is also requested to implement this requirement in all resource consent applications as a health and safety and legal liability protection for Auckland Council its residents and ratepayers.
A call for there to be integrity in TMA and Auckland Council’s “consultation” processes
For the past three years Tūpuna Maunga Authority and Auckland Council have completely ignored the hundreds of public submissions relating to the tree felling aspects of the Authority’s operational plan and budget, with not so much as a full stop being changed.
Last year we recommended ways the Authority and Auckland Council could reduce the Authority’s budget by nearly $2 million – at a time the Council was making deep cuts to other budgets. Not a cent was cut.
Late last year the Authority conducted a consultation around its tree felling intentions on four maunga. This consultation was suspiciously timed to coincide with the local body elections, with the decision making rammed through in the final days of the previous TMA members’ terms. The Authority’s response gave the illusion of making concessions to the over-whelming public opinion against felling the maunga trees, yet the Integrated Management Plan amendments were carefully worded in a way that provides for all of the exotic trees to be felled.
In other words, the consultation appeared designed to try and prevent future legal action by ticking the public consultation boxes, while not making any substantial changes. This is evidenced by the Authority’s proposed vegetation budget for 2023/24 being very similar to last year’s operational plan and budget.
It seems Tūpuna Maunga Authority and Auckland Council’s public consultations around anything to do with the TMA have been nothing but box-ticking exercises to date. It is our sincere hope that there will be integrity to this year’s consultation process, which will see:
· Public feedback genuinely taken into account and acted upon
· Auckland Council applying the same rigour to this budget as it does to all other budgets.
· Auckland Council and TMA members requiring financial reporting on the implementation of TMA’s operational plans and budgets (for example, we have observed numerous budget items over the years that appear not to have been actioned). Council treatment of the surplus budget from previous years in relation to TMA must be treated in exactly the same way as all other organisations facing Council budget cuts, requests to pause projects and/or freezes on previous years unused budget.
There should also be transparency around the other ways that Auckland Council provides significant financial support to the Authority that is not currently included as part of the Authority’s financial reports or budgets. Examples of known support include staffing, use of Council premises, legal costs, etc. This additional financial support – is well in addition of $1 million per annum - should be taken account of when considering the Authority’s annual operational plan and budget, and future historical reporting.
Appendix A - Matukūtururu / Wiri Mountain
Photos left and centre: Overgrown, very weedy rough track on Matukūtururu Wiri, which peters out into grass. This is typical of the walking experience at that maunga.
Photo right: Some of the small area of native plantings at Matukūtururu Wiri. We support budget being assigned to more native plantings at this maunga, particularly of tree species.