1.My full name is Diane Jean Lucas. I am a landscape planner with someme 24 years of experience. I hold a Master of Landscape Architecture (planning)(1994), a Bachelor of Science (botany), and am a Fellow of the New Zealand Institute of Landscape Architects (1988).

2.I am principal of Lucas Associates, a landscape planning, design and resource management practice, established in Canterbury in 1979, based in Christchurch and working throughout New Zealand.

3.The practice has particular skills in landscape assessment, landscape ecology, heritage management, community-based planning, exploring creative and acceptable change, and, sustainable design.

4.Research work I have undertaken includes developing management approaches to the archaeological landscape; land pattern planning frameworks; investigating landscape experience; and, identification of acceptable landscape change.

5.I have been an appointed member of the New Zealand Environmental Council and the New Zealand Conservation Authority.

6.Since its establishment in 1990, I have chaired the Nature Heritage Fund (formerly the Forest Heritage Fund), a contestable ministerial fund for the voluntary protection of significant indigenous ecosystems on private land. I have also been a member of the Nga Whenua Rahui committee assisting Maori landowners in the protection of their indigenous ecosystems. Each Fund has successfully helped in the protected of more than 100,000 ha. These funds involve assessment of areas throughout New Zealand.

7.I have undertaken region and district wide landscape assessments, including that undertaken jointly with Boffa Miskell for the Canterbury Region (1993), for which we received national professional commendation (1995).

8.I have undertaken a number of assessments of natural character in relation to s.6(a) and headed the team which developed the natural character framework for the Marlborough Sounds (1997).

9.Recently I have headed the team that has developed the framework for managing and monitoring the ecological integrity of the Bay of Plenty Region (1998).

10.From experience as a rural designer and at the request of rural land user groups, my development of the first rural landscape guidelines - "Landscape Guidelines for Rural South Canterbury" (1981). I produced guidelines for landscape change for various rural activities, including structures and forestry, for example, with a series of 16 separate guideline sheets for farm development design (1984) and "Woodlots in the Landscape" (1984 and 1987).

11.I have visited most of the Wellington Region and had some involvement in a range of special sites (in Rimutaka, Tararua, Wairarapa and Wellington landscapes), as well as in some specific planning such as in relation to Mana Island, the Waikanae-Otaki coastal plain including the dune lake country extending north, and, in Wellington hill country (Eastern bays, Island Bay, etc.). We are currently developing a framework to enable better understanding of the nature of Wellington city lands.

12.I have perused the various drafts of the Regional Landscape Plan and accompanying reports. I appear today at the request of the Makara Guardians Inc. to comment particularly on the appropriateness of outstanding and significant landscape delineations and associated guidelines.

13.The area for which the Makara Guardians seek outstanding landscape status is here termed the "Makara/Terawhiti landscape", including the coastal environment from Makara Beach south to Cape Terawhiti and inland including Terawhiti Hill and Quartz Hill.

14.The scope of my evidence involves comment on the Wellington Regional Landscape Plan methodology, including the proposed amendments; comment regarding analysis of the values and significance of the Makara landscape; and, comment on the appropriateness of including guidelines and of identifying regionally significant effects (Appendix F).

INTRODUCTION

I would firstly like to congratulate Wellington Regional Council on taking the initiative to prepare a Regional Landscape Plan under the Resource Management Act 1991, with a sensible recognition of the diverse valuing of landscape beyond visual quality. I commend the intent of developing an effects based plan.

The Wellington Region includes dramatic landscapes as well as important landscapes that are valued by locals, other New Zealanders, and by visitors. It is important that these landscapes are recognised in total, so that some direction is given to managing change. A Regional Landscape Plan is an appropriate forum for this direction.

It is important this Plan gives broad, but adequate, direction. I appreciate the difficulty of achieving this balance.

I endorse the Council's requirement that the landscapes must meet a reasonably rigorous test to be specifically identified as significant. I endorse the approach that the Plan address more than just those landscapes identified as "outstanding". I would prefer that potential regionally significant effects on the wider landscape resource be recognised.

Because of the importance of the whole landscape resource of the more natural dimensions of Wellington Region, it is important there are mechanisms for managing regionally significant effects on the general landscape resource of Wellington Region, not just the specific bits identified as regionally significant.

That is, both regionally significant places and potential regionally significant landscape effects need to able to addressed. The Plan recognises potential effects only within the particular places, and in my opinion, this does not adequately address the landscape management responsibilities. To ignore potential regionally significant effects beyond the delineated list of places is to ignore the Council's wider landscape responsibilities. It suggests the Council has no landscape interests beyond the places delineated, yet this is not the case.

Potentially significant landscape effects could occur, such as construction of complexes of enormous structures on skylines not recognised as regionally significant. These could affect the landscape resource of the whole region.

I thus suggest that potential regionally significant effects in general, as well as regionally significant landscapes specifically, would preferably be addressed by the Plan.

However, the Plan has taken a targetted approach on places alone, and not considered effects in this way.

Whilst policies on coastal landscapes were included in the draft Plan, these have since been deleted. However, through the submission process, the community has demonstrated certain coastal enviornments that are considered outstanding. From their analysis, their inclusion is now sought - that is, the Makara/Terawhiti landscape.

LANDSCAPE CRITERIA

In the regional and district landscape assessments in which I have undertaken, we have developed 6 criteria have been identified as a basis for identifying outstanding landscapes. The criteria developed are:

In this approach, a landscape does not need to be outstanding in all 6 to be recognised as regionally outstanding. A landscape may be exceptional on several criteria but not on another and still be considered "outstanding".

The criteria proposed in the Wellington Regional Landscape Plan addresses amost of the dimensions listed above. Although the "shared and recognised" values (5) less explicitly. Recognising shared values may provide a different emphasis, for example, a mountain that people see prominently may be much more valued than one that is not, even though the latter may have a more dramatic profile or be higher. The Background Report provides substantiation of the shared and recognised values of only those the places selected as Outstanding Landscapes in the Region.

AESTHETIC

I support the definitions in the Plan including of "aesthetic", that recognises perceptual dimensions other than visual, for example, of smell and sound.

OUTSTANDING

The Background Report quotes (Appendix 2) from our 1993 study in interpreting "outstanding". From subsequent work in this area, I continue to endorse this interpretation.

SIGNIFICANT LANDSCAPES

The Plan provides a language difficulty in recognising "regionally significant landscapes" that are defined to include both regionally outstanding and regionally significant landscapes. It may be more user friendly to instead define the overall grouping of regionally significant landscapes as "regionally important landscapes". This would then include both the "regionally outstanding" and the "regionally significant" landscapes. I also recognise the practicality of signalling that all of the landscapes or features of particular importance to the Council are "regionally significant". Thus, whilst clumsy, I accept the dual terminology may be considered necessary.

The approach taken to include both the outstanding and other landscapes of regional significance with regard to Part II matters is supported. I endorse the approach taken in including the context of significant natural features.

METHODOLOGICAL CONCERNS

In determining the level of significance, the Council has required that a landscape meet all criteria to justify being outstanding. Given the experience of other landscapes and landscape assessments, I question this requirement.

TYPICAL & FAMILIAR LANDSCAPES

A difficulty in addressing landscape significance is that often it is the everyday landscapes, the ones that people closely associate with, that may be the most important and the most vulnerable in people's attachment to places. To require landscapes to be exceptional on all criteria may thus be inappropriate. (For example, the lands of the Wellington Harbour landscape may is less naturally exceptional but still accepted as outstanding.)

Outstanding natural features and landscapes as recognised by s.6(b) have been increasingly interpreted by professionals and the Environment Court, as not necessarily just the beautiful, the dramatic, but the meaningful. Therefore it is crucial that community values be recognised. The most visible and dramatic are not the only regionally important landscapes.

It is important the Regional Landscape Plan recognises that landscapes are dynamic, therefore it is essential there be the aim of maintaining and/or enhancing landscape values.In some instances, landscape restoration is occuring through native forest recovery following fire, grazing or earthworks, or, is possible through removal of now superfluous structures - old buildings, masts, etc.. The Coastal Policy Statement provides a lead for this in recognising restoration as part of preservation of natural character.

COASTAL LANDSCAPES

The RMA provides particular emphasis for the preservation of the natural character of the coastal environment. In fulfilling this requirement, the Council can assist by delineating the extent and values of the coastal character, and this can be contributed substantially through the Regional Coastal Plan. However, the Proposed Plan does not identify some particularly important coastal landscapes as "outstanding", in particular, the coast of the Makara/Terawhiti landscape.

The assessment methodology may have not adequately recognised coastal landscape significance. As in one District landscape assesssment I undertook, I identified broad types of country as the Wellington Regional study has done. However, through public consultation it became clear that coastal hills and coastal plains were perceived quite differently to non-coastal hills and plains. Therefore, in my study, the coastal hills were then addressed as a separate landscape type to those inland. Whilst the Wellington Regional Council has continued to state the importance of coastal landscapes generally, the lack of specificity has been highlighted through the submission process. Greater inclusion of coastal landcsapes has been sought by community. This response appears consistent with landscape analyses elsewhere where coastal landscapes have been identified as particularly important.

Wellington's coastal landscapes had been clearly identified in the public draft as of regional importance. However, surprisingly few coastal landscapes were delineated in the Proposed Regional Landscape Plan - just Castle Point, Cape Palliser, around Wellington Harbour, and, Pauatahanui Inlet. In addition, the coastal escarpments on the south-west coast were identified as significant landforms. This delineation appears to confine consideration to a narrow coastal band. It does not recognise the coastal landscape.

A year ago in the "Background Report", council stated that more information was needed on coastal landscapes. The submission and hearings process has provided the opportunity for further information to be provided on what are considered particularly important coastal landscapes. It is my opinion that with the public process followed, the information and analysis provided, and my own analysis, it is now appropriate to delineate the Makara/Terawhiti landscape as an outstanding landscape.

It has been Council policy to distribute the draft document to inform landowners of the proposals. I am uncertain of earlier consultation with landowners in the coastal landscapes. However, with inclusion of the coastal escarpment in the Proposed Regional Landscape Plan, the landowners of the Makara/Terawhiti landscape (which includes and extends this delineation) will have been consulted and had opportunity to make comment on the Proposed Plan and the outstanding delineation sought by the Makara Guardians.

The identification and analysis of values undertaken in support of this delineation provide the basis for the Council to proceed with amending the Plan to include the Makara/Terawhiti landscape as an outstanding landscape.

The officers report suggests (I/84) further investigations and a possible variation in the future. This seems an unnecessary step when the locations and information on values of this particular landscape have been clearly articulated through the submission process.

The officers' report recognises that the Makara coastal landscape requires further investigation. I suggest that the identified shared and recognised values through the recreational and park potential data for this coastal landscape contributes substantially to its landscape importance.

The coastal environment can be taken to extend to the first ridge, and thus include substantial areas of the Makara/Terawhiti landscape. It is important that the fuller landscapes be recognised, not merely the coastal escarpment. The Landscape Plan provides an appropriate mechanism to recognise the larger landscape complex of the Makara/Terawhiti landscape.

LANDSCAPE VALUES OF THE MAKARA/TERAWHITI LANDSCAPE

The major peneplain remnant of Quartz Hill and also of Terawhiti Hill are of importance not just to science, but to their telling of the story of the Wellington landscape. They help understand this place. Their legibility and major contribution to the Wellington region's landscape is vulnerable through potentially inappropriate land use activities.

Submissions and attachments already presented by the Makara Guardians demonstrate the depth and diversity of landscape values. I have reviewed these.

This landscape is a crucial resource and context for the city of Wellington, the rural and natural lands connecting the city to the wild and natural coast. The entire Makara/Terawhiti landscape would be appropriately recognised as an outstanding landscape.

The Makara/Terawhiti landscape can be analysed in terms of its uplands and its lowlands. The lowlands include the Makara Stream estuary and flats which provide a very important focus. Their landscape values have been documented in the Makara Guardians submission, and I support this analysis.

The uplands include the Quartz Hill Peneplain, Terawhiti Hill, and coastal escarpments. Their landscape values have been documented in the Guardians submission, and I have no problems with the analysis.

Quartz Hill is the major focus and pivot for the coastal landscape as accessed by thousands from Wellington. It is the focus for road views from the city, and for foot and boat traffic in the surrounding area. The clear silhouette is an important and vulnerable resource. Not a dramtic peak, but a flat summit, means the Hill may be less recognised under traditional landscape aesthetic criteria as noteworthy. A fuller landscape analysis now recognises such values.

The landscape continuity from the coast, the escarpment, the spurs, valleys and slopes up to the summit of Quartz Hill, I consider requires recognition. Quartz Hill is an essential part of the coastal environment, the coastal landscape.

The clarity of the silhouette of the summit and spurs is a very important landscape value. The drama of this great landform feature so close at hand means it is vulnerable to effects from landscape intrusion. Quartz Hill is an outstanding landscape with potentially regionally significant adverse effects from development particularly on the summit.

Terawhiti Hill forms the stunning south-western hill, sea surrounded, that is the North Island's finale and the link hill across to the South Island. Terawhiti forms a spectacular skyline, it is visually dramatic and a very important landscape. Terawhiti forms the crucial context to the beatiful bays and escarpments of Ohau, Te Ika a Maru, and Opau. Whilst not on a road corridor, Terawhiti is a major natural landscape contributor, whether viewed by air, by sea or by foot. Terawhiti meets the criteria for outstanding aesthetic, sense of place, legibility and natural values.

The escarpments cannot be considered separately from the bays and beaches below nor the slopes above.

DELINEATION

The visual catchment approach taken for delineation of landscapes associated with regionally significant rivers and lakes is also considered appropriate for regionally significant landforms. To sustain their integrity, recreational and aesthetic value of a landform, the landscape context must be recognised.

As noted in the Background Report (Appendix 4, footnote 5) "The visual catchment is ... to provide a generalised impression of the are that is likely to be experienced as part of that landscape." This is supported and would be one mechanism whereby the coastal environment of the Makara/Terawhiti landscape could be immediately recognised as a regionally significant landscape.

Thus, the coastal escarpment of the Makara/Terawhiti landscape which has been delineated as regionally significant, as a minimum, the recognition of this should explicitly include the visual catchment of the escarpment. That is, the regionally significant landscape would extend inland to include the peneplain summit.

The coastal escarpment is not merely enjoyed from the shore below, but by thousands from above as they walk along above the escarpment, and by many from beyond as they enjoy it when viewed from seawards. As well as the shore and sea below, the hill slopes and peneplain above create the landscape context for the escarpment.

REGIONAL EFFECTS

The Landscape Plan has guidelines for major types of change - subdivision, structures, earthworks and vegetation clearance. The Plan recognises the two tasks, identifying regionally significant places, and identifying potential regionally significant effects within these. The potential effects of built change are noted.

Structures have the potential to seriously degrade landscape values. In some landscapes, even rather small structures that contrast with the surrounding chracatre can affect an extensive landscape. The Makara landscape is more robust, and has accommodated a range of built development within its valleys and lower slopes - the concave slopes, the landscape niches. Mainly single houses and farm building groups, these are not a major landscape issue because of their small scale, niche locations and sparseness. The effects are very localised and thus generally not of regional significance.

However, located on the convex slopes, on the summits and spurs and prominent headlands, built development can affect an extensive landscape. If structures are of substantial scale or of a character that substantially contrasts with the surrounding landscape (in shape, colour, etc.) then it can adversely affect major landscapes and their values.

Many of the hill slopes, the spurs of the Makara landscape are just 100 m high. Thus large structures can very easily belittle this landscape. The introduction of large structures would change people's relationship to the hills and to the valleys. The predominance of a natural character would be threatened. Introducing structures that can visually dominate or visually compete with the natural characteristics of the Makara/Terawhiti landscape, has the potential to have major adverse effects of at least regional importance. The summits, spurs and crests are particularly vulnerable to such effects.

As stated by EECA (Energy Efficiency & Conservation Authority, "visual impact is one of the most problematic aspects of wind energy development". In addition, "people may have strong feelings or associations with respect to some areas. For example, areas may have wilderness or remoteness values, historic associations, or may contribute to the "sense of place" for a nearby settlement. These values are often difficult to identify and define, but are "intrinsic" to the area. effects on intrinsic values should not be equated with visual impacts."

Because of the potential for wind generation around Wellington, it is appropriate there are siting and design guidelines to direct the planning effort and minimise potential adverse effects.

Installations do not affect actual landform, but affect the expression of landform. The relationship. The landscape experience of landform. Therefore there are potential landscape effects on landform from structures. Also on landcover and landuse.

Thus, because of the potential for major landscape effects from large structures such as the ever-larger wind power structures being developed, the potential adverse effects need to be recognised. I therefore support the inclusion of guidelines for wind turbines.

I work in finding creative solutions that allow win-win solutions. The Plan should be encouraging the avoidance of significant landscape effects. However, the proposed wording for structures on skylines allows for major adverse effects that this Landscape Plan will not address.

I see this as a major failing of the Plan, and one that will put into question the existence of the Plan.

Landscape absorption of wind turbines is a specific landscape management task.

The expression and legibility of the peneplain remnants and their coastal association are very important in the Wellington landscape. Whilst construction of large structures may interfere minimally with the actual geo-morphological feature, the experience of that feature can be seriously affected.

Guidelines are considered necessary for assessing wind turbines against their effects on the integrity of the landscape. The effects of the introduction of man-made structures to previously natural or naturalistic landscapes, particularly ridgelines and skylines require careful management. Such structures could, through contrast in such aspects as scale, form, association and character, change dramatically the character of an extensive landscape.

Skyline structures are currently proliferating. The skyline is a crucial landscape dimension that is highly vulnerable. The D2. guideline for structures, the officers' report recommends accepting "Structures with a functional requirement for a high position may be sited on the skyline but are co-sited where possible." I do not support this recommendation. It is a nothing statement, encouraging a rather free proliferation of large structures. There is no encouragement to site off the skyline, no encouragement to reduce the scale, the visibility or the potential effects on landscape experience. Co-siting is of course supported, but avoidance is the first preference.

I support the inclusion of good practice guidelines for landscape change and management, to guide users and to assist in assessing appropriateness.

The officers' report states that the potential effects will be considered at resource consent time. However, the District Plans may well have not been drafted with wind turbines in mind. Consideration of farm buildings, houses, and other typical small structures are totally different than consideration of complexes of very large wind turbines. Whilst the design of wind turbines may be able to be assessed in the resource consent process, the siting may not.

As the landscape is an important Regional resource, and as Wellington Region has been identified as a likely location for major wind energy production, it is appropriate the Council provide greater direction through guidelines for the location and design of wind turbines.

In my opinion, it is appropriate to include landscape guidelines for the siting of wind turbines in Wellington Region.

Regional recreation studies show the need for places and open space with visual and psychological freedom - without noise or detrimental visual intrusions. Bush and skylines must be protected. The coast is the most popular landscape resource. The more rugged areas provide important wilderness and solitude opportunities.

That a Makara regional park was proposed indicates the landscape values of the area "expansive wilderness on the Region's doorstep with remoteness feeling" to address diverse values provided by tussock grassland, hills, exposed coast and history. The Makara Walkway is already in the very high usage category of Wellington City.

CONCLUSION

I support the development of a Regional Landscape Plan for Wellington and its substantiation and delineation of regionally significant, including outstanding, landscapes, however these are incomplete and the generic landscape has been ignored.

Assessment on the basis of criteria for aesthetic, recreation, natural, and tangata whenua are strongly supported. However, I do not consider it essential that each landscape be outstanding on each criterion to qualify as an outstanding landscape.

Rather than further investigations and a variation, it is appropriate that the Plan be amended to include these areas.

It is also recommended that thge Plan explicitly include the landscape context of regionally significant landform features, not merely that of freshwater body features.

The delineation of regionally significant landscapes is a useful guide, however it needs to be expanded to include other landscapes that clearly meet the criteria. Those that have been assessed and signalled for inclusion through the submission process, in particular the Makara/Terawhiti landscape, should be included in the Wellington Regional Landscape Plan and not held to await a plan change or variation process.

I support the inclusion of White Rock Hill as a fragment of recognition of the peneplain, but find that this recognition should be substantially extended to include Quartz Hill and surrounds in particular, and also Terawhiti Hill.

From my knowledge and involvement nationwide, I assess that the Makara/Terawhiti landscape qualifies for inclusion as a regionally outstanding landscape and the component landscape features recognised.

My analysis supports the addition of a Makara Outstanding Landscape.

Recognition of potential regionally significant effects for the wider landscape is also desirable.

Inclusion of design guidelines for structures is supported. Wind generation is a potentially major new presence in the landscape. It can potentially be an attribute, and it can potentially be a serious detractor from landscape values. It is appropriate the Regional Council address the potential effects on important landscape resource through inclusion of guidelines that address wind energy installations. If not well-located, the wind turbines can dominate extensive landscapes and their effects cannot be mitigated.

Where such landscape features as shelterbelts and buildings may have been addressed, with wind generation structures being considered that are perhaps 20 times taller than these, and dispersed over a considerable area, in my opinion there is a duty for the Council to recognise that sustaining the landscape resource requires recognition of major potential effects.

Because of the potential for regionally significant adverse landscape effects, I support the inclusion of guidelines for the siting of wind power stations, as submitted by the Makara Guardians.

Appendix F, defining regional significance is a useful inclusion, and I recommend it remain within the Plan.