Whataroa Logging Submission January 2014

To : The Chief Executive

Marlborough District Council,

P.O. Box 443, Blenheim,

New Zealand

23 January 2014

Resource Management Act 1991




Name:                          Port Underwood Association

Postal Address:           PO Box 59 Blenheim 7240

Telephone Number:    0221 306508

E-mail Address:          port.underwood.association@gmail.com

Address for Service:    As above

Applicant’s Name:     NZ Forestlands Limited (NZF)

Application Number: ref. 7/10/290 dated 27 July 1979 and associated Change of Use letter dated 8 November 1979 (Planning Consent).

Note:                           Final application has yet to be submitted by the applicant.

Location of Proposal:Whataroa, Port Underwood, Marlborough.

Proposal or activity under application: To make limited use of the public road network in Port Underwood, Marlborough to facilitate the extraction of logs harvested from the applicant’s prospective Whataroa forest in Port Underwood, Marlborough.

Relevance of the Submission: The submitter is the association for a significant proportion of owners of property in Port Underwood. The submission follows the AGM held by the Association and the comments made by members at that meeting. The members of the submitter is affected by the proposed activity.

Comments on the submission

It is noted that an application has not yet been made and the Association requests that it is kept informed of any submission and receives a copy of any application made.

The Port Underwood Association recognizes that there will be the use of the roads for log extraction.

The purpose of the submission is to minimize the impact upon residents of the use of the roads.

Export Logs

It is understood that all export logs are to be removed by barge. How is this to be monitored and what are the consequences for removal by road?

Can a binding undertaking be given by NZF that all export logs will be removed by barge?

Other Logs

Other logs are to be removed by truck and the following points have been made by members of the association:

Number of vehicles

It is understood that there will only be ten loaded trucks a day. It is the Association’s view that this should be a maximum figure not an aimed for figure nor an average figure.

We would expect NZF to give a binding commitment that ten loaded trucks is a maximum number of loaded vehicles.

The Association believes that a commitment for there to be a maximum of ten truck movements into the Port Underwood area and ten loaded trucks leaving Port Underwood each day. Please also see the note below regarding types of vehicles.

The Association would appreciate a commitment from Marlborough District Council (MDC) that it will monitor the number of log trucks.

Types of vehicles

It is understood that other vehicles will use the roads. This includes vehicles bringing equipment and cars/utes for workmen. The association would like a commitment from NZF regarding the numbers of these vehicles and would also expect that any restrictions or requirements that apply to logging trucks also apply to these vehicles.

The Association would appreciate an undertaking from NZF that the maximum number of vehicles (ten a day in each direction) will apply to not only log trucks but also to any heavy vehicles (i.e. those that are not cars or utes) associated with the logging operation and NZF.

Marking of vehicles and equipment

The Association believes that all vehicles (log trucks, machinery, transporters, fuel and service vehicles, cars and utes etc.) should be marked so it is clear that they are associated with the logging operation. This is so that if an incident occurs it can be clearly ascertained that it is a vehicle associated with the logging operation or, if not marked, it is not associated with the logging operation. The Association believes that it would be appropriate for NZF to require staff and contractors to carry such identification marks. The identification marks should clearly state that it is a NZF vehicle, give an identification number and a contact number for members of the public to contact NZF if an issue needs to be raised concerning the vehicle.

All vehicles associated with the logging operation should be equipped with RTs for communication, and drivers instructed to use road location markers in situ on the road to communicate between vehicles.

Time of road use

The Association would like NZF to give a binding commitment that there will be no road use by any vehicles (log trucks or other vehicles) except between the hours of 0700 hrs and 1700 hrs.

In addition, road use should be minimized through the Waikawa Road school zones between 0815 and 0900 hrs and 1500 and 1545 hrs on school days by all vehicles associated with the logging operation.

Furthermore, there should be no road use by any vehicle associated with the logging operation under any circumstances on Sundays or public holidays (including Marlborough Anniversary Day). In addition, there should be no road use by any vehicles over an extended period over the Christmas, New Year, Easter, Labour Day and Queens Birthday weekends. These periods are subject to heavy road use by holidaymakers and temporary residents. The Association would like to agree a period where there is no use in these periods. It should, however, be, at a minimum, the Saturday, Sunday and Monday of the public holiday (plus the Friday for Easter). It is suggested that a period of four days before and after Christmas day and New Years day should also be excluded periods.

Convoys and pilot vehicles

The adverse impact upon the local area can be minimized by requiring vehicles to operate in convoys and to use a pilot vehicle. There is a natural laagering point at the Port Underwood Road saddle for vehicles to meet and create a convoy.

The Association also believes that vehicles should also be leave in convoy from the logging area.

The Association believes that all vehicles should operate in convoy. This includes the cars and utes used by forestry workers. This should reduce the incidence of speeding, especially when workers are leaving at the end of the day.

Wet weather restrictions

It is proposed that there will be no road use within 24 hours of 10mm of rain. The level of rainfall in Port Underwood can vary significantly from that in Picton or Blenheim. The Association would appreciate NZF to give an undertaking that there wil be no road movements within 24 hours when there has been 10mm of rain in the Port Underwood area. The Association would also wish to ascertain how it is to be determined, and by whom, when 10mm of rain has fallen and in what location.

Code of conduct

The Association suggests that NZF should require all employees and contractors to be bound by a code of conduct concerning road use. This should include times of use, speed, consideration of other users, compliance with use times, maintenance of identification marks on vehicles, drug and alcohol free travel, etc. The Association would expect NZF to take disciplinary action against any contractor or employee breaching the code of conduct. The Association would suggest that a report be made (possibly on a quarterly basis) to The Marlborough District Council concerning breaches of the code of conduct and also compliance with the conditions for granting consent (detailing items such as the number of vehicles using the road’s, breaches of time and weather restrictions on use etc).


The Association believes that the use of public roads should be minimized. The proposal states that there will be no use of the public road between Jerdans Bay and Ngakuta Bay. The use of public roads can be reduced further by using the internal road network and extending the network to the Port Underwood Road saddle.

It is noted that the application suggests the use of an internal high altitude forest road network within Whataroa, George Yorke and Matariki -Queen Charlottte Forest blocks from Jerdans Bay to Ngakuta Bay. The applicant suggests that public roads will be used from this point, but this can be avoided as the high altitude road continues through the Queen Charlotte Forest via the Charles Saddle to the boundary with the Underwood Farm Block. This would connect the saddle between Hitaua Bay and Opihi Bay with the Port Underwood Road Saddle, leaving only a relatively short distance to connect the Underwood Farm road at the Hitaua saddle with existing high altitude road leading to the Charles saddle in the Matariki – Queen Charlotte Forest. This connection would form a contiguous high altitude mid slope road network from Whataroa to the Port Underwood Road Saddle over 200 meters above sea level capable of log extraction for its entire length. This internal road network would negate the use of 23 kilometers of public road (Tumbledown Bay Road and Port Underwood Road) from Jerdans Bay to the Port Underwood saddle. The remaining extent of public road needed to be traverse would be limited to the 15.5 kilometer downhill section from the Port Underwood saddle to Picton.

The use of this route would minimize the problems on the public road. The Association strongly urges the use of this option and the creation of this high altitude road network to minimize road use.

Contact details

The association suggests that contact details for NZF and Marlborough District Council should be published, disseminated to residents in Port Underwood and noted on vehicle identification marks. This is to enable members of the public to contact both NZF and Marlborough District Council if they have issues to raise.

This is the submission of the Port Underwood Association. This does not restrict the Association from making further comments or submissions. The Association welcomes discussion with NZF and Marlborough District Council regarding this and any future application or applications.

John Davison


Port Underwood Association

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