Monthly Archives: May 2016

Submission to ICC on the draft ‘Code of Practice’

Subsequent to my original submission below, I submitted a further response in writing on the day of my spoken submission, as I found the council’s response to be evasive, dismissive and generally unsatisfactory:

The Southland Times has picked up on this, and has written an article here:

Here’s the comment I’ve posted on the article:

I’ll be very interested to see how the residents of Invercargill feel about this issue that I raised in my submission to ICC – thanks to The Southland Times for assisting in publicising this issue! – I’d like to suggest a change: probability is twice as high as the one-in-ten recommended by Standards New Zealand.” should probably read: “The probability is twice as high as the one-in-ten recommended by Standards New Zealand, which means the intensity of the event is around 1/3 LOWER. As such, drains installed to the ICC 5% AEP will flood with a much smaller event, leading to significantly more surface water ponding.”

This is based on my understanding from the High Intensity Rainfall Dataset from NIWA,4,6/IFD which also demonstrates how rainfall intensity will increase with increased mean air temperatures.

Just carrying on with a particular design standard, especially one that is below the NZS recommendation from 2010, and just ‘because it’s been done like this for 30 years’ is in no way defensible in the face of the challenges that Climate Change (and other ‘Planetary Boundaries’) and resource depletion (as I outlined in my submission to the council’s Long Term Plan last year: pose to our current way of life.

This was also only one of several issues that I raised in my submission ( We need to think a LOT harder about these issues as a community, and that process starts by having public debate on the issues, and coming to a mutual understanding. In the council’s response to my original submission, their summarisation of my comments for councillors misrepresented my views in several key areas, and I submitted a further response on the day of my spoken submission

The predicted effects of climate change will be very difficult to deal with, and I have sympathy for ICC’s predicament with regard to how and where to expend the ratepayers capital effectively, it’s a very hard problem… It also mirrors the more general predicament we all face, which is that what has worked in the past is no longer working in many respects, and this situation will only worsen over time. These are symptoms of biophysical Limits to Growth that we face, and are an issue I continue to work with the Wise Response society to publicise to the general public. The New Zealand parliament would do well to form something similar to the UK’s All Party Parliamentary Group.
“Four and a half decades after the Club of Rome published its landmark report on Limits to Growth, the study remains critical to our understanding of economic prosperity. This new review of the Limits debate has been written to mark the launch of the UK All Party Parliamentary Group (APPG) on the Limits to Growth. It outlines the contents of the Club of Rome’s report, traces the history of responses to it and dispels some of the myths surrounding it. We unravel the arguments that have raged for forty years in its aftermath and explore more recent findings which relate to the original hypothesis. As Prof Tim Jackson summarises the report in his recent CUSP blog, if the Club of Rome is right, the next few decades are decisive. One of the most important lessons from the study is that early responses are absolutely vital as limits are approached. Faced with these challenges, there is also clearly a premium on creating political space for change and developing positive narratives of progress. A part of the aim of the APPG is to create that space.”

Even though central government isn’t taking these things seriously, local and regional government can and should act to educate itself and others on the implications and positive responses. My submissions aim to assist this process.

The newly forming discipline of Transition Engineering as described by Susan Krumdieck, Daniel Kenning and others ( approaches these complex systems challenges as a ‘systemic’ problem, and doesn’t shy away from dealing with the complexity. It also respects the fundamental constraints that nature imposes on our future ‘solution spaces’ and aims not to pursue options the fundamentals don’t support. Here’s an excellent talk by Susan on the subject: – I love her ‘flying elephant’ test. Already a classic, up there with ‘if you’re in a hole, stop digging’…

Original Submission follows:

Schema Consulting Ltd
Nathan Surendran
60 Dublin Street
021 209 6286

16 March 2016


I wish to be heard by the Councillors and Mayor in support of my submission.


By not giving a larger portion of the copyrighted standard in the consultation document, giving the context for proposed amendments, the council has failed to provide a fair ‘public’ consultation. This biases the responses to professionals who have access to the full document, and excludes the views of the citizens of the city who do not have

Despite having followed periodically the consultsouth website (why isn’t there a ‘subscribe via email’ option?!) informing people of consultations, and the council’s Facebook page, I only found out about this consultation on Thurs 14th, 1 day before it closed. As I stated last year, the council needs to signal these consultations much better…

My submission to the council’s draft LTP ( last year identified 3E’s – Economics, Energy, and Ecology that will shape the solution spaces available to us as a city. NZS 4404:2010 is designed for ‘Green Streets and Livable Communities’ (Hall

As Prof Susan Krumdieck (University of Canterbury –, Prof Charles Hall ( and other leading academics and industry specialists are communicating, declining Energy Return On Investment ‘EROI’ for our fossil fuel supply means we will have to work within a much reduced energy budget. This is quite aside from the imperative to reduce industrial pollution such as CO2 emissions to prevent negative ecosystem impacts. Both of these limitations on future activity come at a time when the economic ponzi scheme that has created mostly cheap credit (in financial terms) since the dropping of the gold standard in the 1970’s is ‘topping out’, leading to a potentially quite prolonged period of stagnation as limits to credit expansion are reached and breached globally. We will have no option but to work within the much reduced number of ‘solution spaces’ that this confluence of issues leaves open to us in subsequent decades. This will require us to change substantially the narrative we live by, the story we tell ourselves of who we are. This change from a ‘Sacred Money and Markets’ story, to a ‘Sacred Life and Living Earth’ story, over time, in response to the limits imposed on us by our finite planet, will alter radically the trajectory we are currently on. It will give us cause to explore significantly different urban forms, which I mention as ‘Agrihoods’ or villages (even within the city’s current boundaries), to use the more mundane title. This was the subject of a recent 15 minute presentation I gave recently at an Innov8 Invercargill event (presentation and a voice recording:

Specific comments:

1.9 Bonds and charges – Amend clauses as below 1.9.1 Uncompleted works The amount of the bond shall be 150% of the estimated value of the uncompleted work or a value agreeable to the TA plus a margin to cover additional costs estimated to be incurred by the TA in the event of default.

Who is to be the arbiter of what is ‘agreeable to the TA’? How are the public supposed to comment on this proposal if no indication of the potential size of the financial impact (as a percentage of the estimated value, for example) is given? Does it introduce the potential for restrictions to developments proceeding?

I propose this amendment be removed from the code of practice document, as it gives the potential for a perception of restrictive amounts being demanded arbitrarily, or for political or anti-competitive reasons.

Table 3.2 – Road design standards

  1. The changing of the minimum road widths to 3 and 6m from the recommendation in the NZS is going to cost the rate payer an additional 8%  (approximately; 5.5/6=0.9167) for the upkeep and maintenance of future roads developed which are vested with the council.
  2. I understand that wider roads are seen as a feature of the city, giving it a different character. The historic basis as I understand it was the turning circle of a horse drawn cart.. There are clear trends in car ownership, and particularly future cost rises in the price of ashphalt, reductions in vehicle ownership through passenger vehicle automation, declining affordability / availability of fuel due to resource depletion, etc . For future developments, given these undisputable trends, please provide rationale as to why the council is proposing this amendment?
  3. Please advise if there is other rationale that I am not aware of, and please also give an estimate of projected roading infrasturcture increases, so this can be communicated as a potential future liability to rate payers…


4.3.5 Design criteria

The following is to be added to the end of the clause.

The design shall be based on the Rational Formula,

i.e. Q=k*C*i*A where…

  1. Please provide reference as to the origin of this formula. If it wasn’t included in the NZS, why does the council feel it necessary to insert it? Without rationale for this change, how can the proposed amendment be assessed by a member of the public? (I’m aware that a google search provides answers like these: – I’m pointing out the poor quality of the consultation document). Design storms

All new primary stormwater systems shall be designed to cope with climate change adjusted design storms of at least the annual exceedance probability (AEP) set out in table 4.1 unless specific approval has been obtained from the TA. with a 20% annual exceedance probability (AEP), a 20% AEP design storm has a return period of 5 years. All new secondary systems shall be designed to cope with 1% AEP (100 year return period) design storms.

Table 4.1 Recommended AEP for design Storms Not part of Code

  1. I dug out Table 4.1 – took a while…

NZS 4404_2010 - Table 4.1 AEP's.png

  1. It is unclear, to say the least, why the council is choosing to go from “at least 10% (where no secondary path exists)”, to only “20%” of the AEP in this proposed amendment. As I pointed out in my submission to the ICC LTP last year, rainfall intensities are set to increase, due to the increased moisture carrying capacity of a warmer climate.
  2. One possibility that comes to mind is that the council has decided to accept the reality of having to abandon large parts of the city to climate change induced sea level changes within the next 50-100 years, and is willing to reduce the infrastructure provision to induce localised flooding events to incentivise people to move, and reduce its drainage expenditure.
  3. Another is that the council is suffering from denial about the ongoing changes to weather patterns in a broad sense (notwithstanding the 30+ years without a major flooding event in Southland – not to be taken as a sign that such events won’t happen), and wishes to change the weather by changing its code requirements…
  4. Why specifically did they choose to go to a higher probability, lower impact event, which is the opposite direction to other TA’s such as QLDC (below), Hamilton, and probably others? Vegetated swales Rain gardens Minimum pipe sizes Minimum gradients and flow velocities


  1. For the above clauses, refer to my comments on Design storms Minimum cover

6.3.3 Future development

AND ALL OTHER CLAUSES AFFECTED BY THE STATEMENT “Replace clause with the following

  1. Replace what clause with the following!!! How are we supposed to comment on this? Design flow

based on 0.7 litre/second/hectare (l/s/ha).

  1. What is the basis for this figure? Needs rationale to be appropriate for comment…



  1. As I noted in my comments to the LTP last year, the council should consider rainwater collection as a serious alternative to mains water supply, and as a future resilience upgrade for the city, which could be encouraged in the place of the proposed secondary water supply for the city that is included in council plans elsewhere. I do not accept the council’s rationale for dismissing my proposal in its response to by submission on a fire fighting basis as other cities in drier parts of NZ that have adopted this approach have clearly considered this, and found a way around it.



  1. In line with other TA’s globally, recognising the threat to their citizens from sole reliance on the supermarket infrastructure and gardening for food supply, I request that the council consider introducing an incremental experiment with edible planting for the parks department. Allocate an initial 5% of the planting budget for an experiment with edible planting, and increase this yearly, as species and locations that ‘work’ in the local context are identified.
  2. Consider putting an emphasis on edible planting for new residential developments, and limiting grass as a percentage of total section size, as is currently done with hard cover % to stabilise drainage. This would also go some way to reducing the issue I raise regarding the 20% AEP above, as planting for perennial and annual edibles increases soil porosity and organic matter content relative to grass cover, reducing runoff. Perhaps insert something into 7.2.1 Approval regarding this?


Due to the inadequate time available, I have been unable to review this document past page 36. I will try to find time over the weekend to make some brief comments on this, which I will submit as an addendum to this submission.


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