Peter Witehira Submission / Ngapuhi 2013

BEFORE THE HAMILTON CITY COUNCIL
IN THE MATTER

of the Resource Management Act 1991

AND
IN THE MATTER

Submissions and further submissions
lodged by Pita Witehira and Te Runanga a
Iwi o Ngapuhi and Tom Roa, Chief
Negotiator, Waikato/Tainui

STATEMENT OF EVIDENCE OF PITA WITEHIRA
FOR
Te Runanga a Iwi o Ngapuhi and Tom Roa, Chief Negotiator, Waikato/Tainui
19 November 2013

Introduction
1.

My full name is Pita Witehira. I am a member of Te Runanga a Iwi o Ngapuhi. I have
been authorized to represent Te Runanga a Iwi o Ngaphu and Tom Roa in respect to
these proceedings. I reside in Hamilton.

2.

I am a Technology Consultant and Inventor.

3.

I have extensive experience in a number of fields including building and construction,
telecommunications, automotive and general engineering, light beam transmission
systems, television and video technology, electrochemical systems and product design
and prototyping.

4.

I am the first New Zealander to be awarded an R&D 100 Award in the United States.

5.

I have a strong interest in history and matters of heritage. My wife and I are the
founders of „The Temple View Heritage Society‟ and I am the original sponsor of the
„Rangi Parker‟ collection of historical artefacts in respect to the early history of the
Church of Jesus Christ of Latter Day Saints (herein after referred to as the LDS or the
Church) and its missionary efforts in New Zealand. I understand this collection was

Submission to Hamilton City Council PDP – November 2013 – Page 1

recently purchased from Mrs Parker by the Church and now forms the basis of the
proposal by the LDS for a Church History Centre at Temple View.
6.

I was born at Mataraua, near Kaikohe. My family moved to Hamilton when I was nine.
I attended Rhode Street Primary School when it first opened, then Maeroa
Intermediate and then Church College of New Zealand, (CCNZ).

7.

I left school and joined the building industry as an apprentice at the age of 15 in 1966.

8.

I served a mission for the Church in the Cook Islands from 1972 to 1974. I have held
some leadership positions in the Church including as a Stake Mission Leader, a
Councillor to a Bishop, a Stake High Councilman and a High Priest Group Leader. I
am familiar with the governing systems of the Church.

9.

Following the announcement in 2006 that CCNZ was to close at the end of 2009, my
wife and I were asked to submit proposals for the repurposing of the campus.
Subsequently we, along with a large number of Temple View and other citizens,
initiated a process which resulted in positive Government support for a special
character, full composite school based on a Christchurch model to occupy the campus
with Government and parent funding. This initiative was however unexpectedly
blocked by the Church following an announcement in 2008 that they in fact intended to
demolish all the buildings and return the land to pasture. I believe the decision had
been made before the announcement of the closure, but we were not told that at the
time. I produce here a copy of the original application by the LDS to demolish all the
buildings that make up the former campus of CCNZ (see Appendix 1). The application
is dated 21 July 2009. The application was withdrawn following public resistance not
contemplated by the Church at the time and also following the passing of Variation 7 of
the Hamilton City Operative Plan. Note the Heritage report attached by the Church to
the demolition application which is in contrast somewhat to the evidence of Mr Dawson
for the Church at this hearing.

Some History of the Church in New Zealand and its efforts amongst the Ngapuhi and
Tainui People
10.

LDS Church missionaries arrived in New Zealand in about 1854, not long after
establishment of a settlement in what is now known as „The Salt Lake Valley‟ Utah.
LDS missionaries also landed in the Hawaiian Islands, Tahiti and Australia at just


before or around the same time. Missionary work amongst the European settlers in
Australia and New Zealand was not productive initially. By the 1880s however the
LDS missionary efforts were directed towards the Maori. This resulted in a building
membership particularly within the Waikato and the Bay of Islands. The first Maori
converts to the Church were at Cambridge and Huntly. The Utah missionaries focused
their efforts on the Maori at a time of disillusionment amongst many Maori in respect to
the European Christian churches and the perceived impact of a loss of control over
land rights and a suspicion that Maori were being marginalized. These suspicions
were sometimes fuelled by the LDS missionaries and resulted in some retaliation by
the elected members of the Government against the Church at the time. (see history of
the Church in New Zealand by Josephs and others) Nevertheless by 1899, my
Grandfather on my Father‟s side, Hemi Whautere Witehira („Whautere‟), along with
some of his siblings and his Mother, converted to the LDS Church away from the
Anglican Church. My Grandfather later joined the LDS mission effort and walked from
Kakohe to Porirua as a 20 year old where he converted some of the Wellington Maori
to the LDS. During the early 1900s LDS Church members, mainly Maori constructed
their own meetinghouses for use as LDS chapels. These small wooden buildings were
prominent on farm settlements in the Bay of Islands.
11.

It is important to note that Maori adopted Christianity in large numbers shortly before
the signing of the Treaty and my family on both my parents sides were directly
involved in those matters as they are related to the prominent Ngapuhi chiefs and early
European settlers of the time. Hemi Whautere Witehira is the grandson of one Robert
Bruce, a Scotsman and the „Mission Printer‟ at the Kerikeri Mission home and
Waimate North Mission School. (See History of the Bay of Islands, Hocken Library,
Dunedin) This relationship proved to be important for the efforts of the LDS among
Ngapuhi in the Bay of Islands following Whautere‟s conversion. It also has a
relationship to the construction of the Church College of New Zealand at Tuhikaramea.

12.

Leading into the 1920s and 30s, Whautere was one of the first Maori of Ngapuhi to be
ordained an Elder in the LDS Church. Due to his family‟s previous involvement with
early Christianity in the Bay of Islands, Whautere assisted the LDS with language
training and translation for American missionaries.

Whautere is one of the Maori

Elders in the photograph taken at Turangawaewae, Ngaruawahia in 1921 featuring
LDS Church leader David O McKay and inadvertently produced in evidence by LDS


representatives to this hearing on Friday last week. Note this photograph is part of a
series involving Church negotiations with Princess Te Puea at Turangawaewae Marae.
The relationship of Iwi to each other in New Zealand and the interaction between
Ngapuhi and Tainui subsequent to the land wars of the 1860s
13.

I want to now call on Matai Ariki Rawiri Kauae Te Toki, Kaumatua, of Hauraki who will
explain the relationship between Iwi throughout New Zealand particularly in terms of
the protection of Taonga (heritage treasures). He will also explain the peace
settlement between Ngapuhi and Tainui at the centenary of the signing of the Treaty
which was the result of tensions following the musket wars of the 1820s. This has a
significant impact on the interaction between Hamilton City Council and their dealings
with the various Maori Hapu residents in this city. It should be noted that the LDS
Church through its Labour Missionary developments at Temple View had a major
impact on the influx of and settlement of Maori from throughout New Zealand within
Hamilton and is partly responsible for Hamilton having the largest per capita Maori
Population of any of the Major Cities in NZ today. Mr Te Toki.

Schedule 8 of the Hamilton City Council Proposed District Scheme
14.

I wish to refer now to Schedule 8 of the proposed district plan, in particular the listing of
historic and heritage buildings and structures. Clearly Schedule 8 indicates no or very
limited consultation with Iwi in respect to the built heritage and structure listings. This
lack of consultation has left a huge and in my view very unfortunate gap which
undermines the Council‟s efforts to instigate a comprehensive heritage policy
particularly for the most Maori populated city (per capita) in New Zealand. There are
many dwellings and shops and other buildings with very little significance to Maori.
Most other Maori I have spoken to about this matter are not aware of any publicity
surrounding the process leading up to the selection of the buildings and structures
listed in Schedule 8. This could be in breach of the consultation requirements of the
RMA and in particular the Minister‟s recent recommendations and guidelines in respect
to proper consultation with Iwi over these matters in particular. (see Improving our
resource management system 2013

15.

In our submissions we listed a number of buildings and structures which are of
significance and important to Maori, some of which have national significance but


which do not appear on the Schedule 8 list of the PDP. These buildings include
important Marae meeting houses, central city structures and places steeped in Maori
architectural heritage. I have attached the list as an Appendix 2 to this statement.
16.

The list of course includes buildings that make up the former CCNZ campus. I will
detail those buildings and their significance later. However in order to help this hearing
I will summarize the list we have prepared for consideration as additions to Schedule 8
outside of the Temple View Heritage Zone. These include:
a. Te Hui o Te Rangiora Marae
b. Kirikiriroa Marae
c. Te Puea Room and Wharekai, 50 Colombo Street, Frankton
d. Tainui Group Holdings House at 4 Bryce Street
e. Hamilton Girls‟ High School Wharenui/Marae at Ward Street
f.

Hamilton School of Education Marae at Waikato University

We wish to further add:
g. Fairfield College Marae at Bankwood Road
17.

While the 42a Report indicates that no supporting research is included in the
submissions in respect to the adding of these places of historical significance, we
submit that apart from the fact that these are well known buildings in Hamilton and
have been so for a significant number of years, the 42a Report glosses over the
significance of buildings important to Maori. However the Historic Places Trust in their
submissions rightly recommend further investigation by the Council into the inclusion
of these places at Appendix 8.

18.

We submit that this is an important request given the weight of impact that these
buildings, including all of the buildings at Temple View, have on the heritage of
Hamilton City.

19.

For example, the Wharenui and Marae at Hamilton Girls‟ High School have literally
hosted thousands of girls during their teenage years who have gone on to recognise
their connection to the City of Hamilton through their Maori experience. They also


learned in those buildings the important history of Tainui and the special architectural
features of Wharenui.
Chapter 5, Temple View Special Character
20.

Turning now to Chapter 5. It is our contention that the CCNZ campus and its
associated buildings, structures and landscapes together with the New Zealand
Temple and grounds and associated structures form part of an expansive and primarily
coordinated architectural layout that is not only unique in New Zealand but also in the
world. Added to the uniqueness is the significance of the buildings and landscape to
Maori and Pacific Island peoples. The United Nations has listed criteria for
consideration by governments contemplating heritage status in respect of places of
national and international significance and I quote as follows

Some United Nations Selection criteria for nations contemplating heritage status:
to represent a masterpiece of human creative genius;
to exhibit an important interchange of human values, over a span of time or within a
cultural area of the world, on developments in architecture or technology,
monumental arts, town-planning or landscape design;
to bear a unique or at least exceptional testimony to a cultural tradition or to a
civilization which is living or which has disappeared;
to be an outstanding example of a type of building, architectural or technological
ensemble or landscape which illustrates (a) significant stage(s) in human history;
to be an outstanding example of a traditional human settlement, land-use, or sea-use
which is representative of a culture (or cultures), or human interaction with the
environment especially when it has become vulnerable under the impact of
irreversible change;
to be directly or tangibly associated with events or living traditions, with ideas, or with
beliefs, with artistic and literary works of outstanding universal significance.
to contain superlative natural phenomena or areas of exceptional natural beauty and
aesthetic importance;
(see United Nations Heritage Assessment recommendations, www.unitednations.org)


The protection, management, authenticity and integrity of properties are also
important considerations.
21.

Since 1992 significant interactions between people and the natural environment have
been recognized as cultural landscapes.

22.

It is also important to note at this point that a quick overview of world heritage sites
include a large number of religious buildings as places of significance.

European

countries such as Germany, France, Spain and Italy have very stringent rules in place
to protect heritage sites, the majority of which have a religious history.
23.

We submit therefore that given the substantial expansive and coordinated layout and
architectural designs in respect to the buildings, walls and landscaping involved, the
Temple View Heritage Zone and all buildings constructed prior to 1965 within that zone
require heritage protection and need to be added to Schedule 8 of the PDP. We
submit that removing any of these buildings from the landscape will break the heritage
which is significant to all citizens of New Zealand and in particular Maori and Pacific
people.

24.

The heritage in respect to the CCNZ campus, teacher houses, Temple and associated
buildings that were constructed by primarily volunteer Maori trainees under supervision
of international and local tradesmen is unique in New Zealand history.

25.

The architectural designs and layout are also unique in the world and include
significant influence to the groundbreaking design signatures of the most famous post
modernist American Architect, Frank Lloyd Wright.

26.

I want to now call on the Chairman of the Waikato/Bay of Plenty Institute of Architects
Andrew Bydder who will outline the importance of Temple View as an Heritage area of
significance.

He will also reference his attempted consultation with LDS Church

Representative‟s in an effort to help the Temple View Community. Mr Bydder.
27.

Going back to the history associated with Temple View at Tuhikaramea, it is critically
important in our view that the Maori heritage is not broken, particularly through what
appears to be an orchestrated plan by the LDS to destroy the buildings, initially
piecemeal through a softer PR campaign than the first effort, but then destruction of


the major structures to replace them with a property development of no significance or
respect for the Maori and Pacific history associated with the land and buildings.
28.

As the volunteers were primarily Maori and Pacific people who were promised a school
for the long term an honest expectation of good faith was created in terms of the care
and long term maintenance of the buildings and landscape. They were never told the
school would be closed after 50 years or that it would be left to deteriorate by way of
demolition by neglect. In our view, the approach taken by the Church today is an
outrageous insult to Tainui, Maniapoto, Ngapuhi, and all the other Iwi of New Zealand
and the Pacific people who contributed to the project. Some of these people sold land
and farm equipment to donate to the Temple View project. They even donated trees
for timber in their overwhelming support and deep love for their fellowmen and hope
for the future of their children and grandchildren.

29.

Contrast the proposed demolition plans with the Anglican St Pauls College in Hamilton
which was opened just a year after CCNZ and remains open in pristine condition
today. It is ironic that St Pauls recently celebrated its 50th anniversary with thanksgiving
directed at the pioneering efforts and sacrifices made by the founders of the school.
Yet at the same time, the LDS property investment arm have undertaken a polarizing
campaign within its membership similar to the colonial attitudes of the past and which
has led us here today. That attitude is now long fading from the culture of New
Zealand partly through education, tolerance, better consultation and a realization that
Maori are and always have been loyal to the traditions and treasures that honour this
country‟s heritage.

30.

The Temple View area is listed as a tourist site in NZ tourism publications, one of very
few within the Hamilton City boundaries. The preservation of the campus and Temple
in a secure heritage schedule will not only honour the sacrifices made, but also the
evolving technology it started. The cultural connection to Maori volunteerism and the
promotion of intertribal cooperation towards a better New Zealand will flourish when
generations walk through the workmanship in years to come. The removal of any
structures will destroy that opportunity for Hamilton.


Consultation by the Church
31.

In terms of consultation, neither the Church nor unfortunately in our view, Council have
properly consulted with Iwi on all matters particularly in respect to the listing of heritage
buildings and structures; (The Living Maori Architectural Heritage). At one attempt by
Council planning staff to consult with Tainui, I was invited by Tainui to attend.
However Council staff claimed that Ngapuhi, in their efforts to submit their interest in
the PDP were claiming “Mana Whenua” over Tainui. Clearly this term was stirred up in
the minds of council staff without a proper understanding of the concept. However it
did underline our suspicions that the Church‟s property investment arm had an
overarching impact on the process that was being put in progress. This was also
borne out by the original application to demolish the entire site and turn it back to
pasture.

32.

We also note that the evidence produced by Mr Dawson in response to questions on
Friday was somewhat misleading particularly in terms of the demarcation line near the
Mendenhall library.

That line was not selected for “topographical reasons” as

suggested by Mr Dawson. The line formed part of the development plans presented to
Ngapuhi in Whangarei by the Church in 2012. The plan was rejected by the Chairman
as it involved the removal of buildings of significance to Maori.
33.

I invite the Commissioner to read through the 2008 application to demolish and
compare it with what is being presented by Church representatives today. The words
and presentations today are more carefully structured and fluffy, but the intent is the
same!

34.

We want to help the Hamilton City Council better achieve more effective and
meaningful Iwi/Maori participation in plan-making processes upfront and reduce
downstream costs and tensions. We are also willing to present options for repurposing
of the buildings that make up the campus and thereby create an iconic and useful
place with great world heritage significance. I must add that my experience with LDS
management and procedures indicates that the present processes being followed to
undermine and talk down the history and heritage values, of what was one of the
greatest examples of voluntary effort in New Zealand‟s history, is at odds with the
Church‟s stated articles. The LDS Church claims the „absolute moral high ground‟ and
to this end have had a good and respectful record in the past for honouring pioneering


and volunteer efforts, historic buildings and places of national significance in the
United States. The approach in New Zealand is not the same and the Hamilton City
Council has an opportunity to once again hold the line against wonton destruction of
architectural heritage. I am confident that the Church will if asked produce a better
plan that will not require or create divisions in the community.
35.

In reviewing the procedures being followed by other major cities in New Zealand, in
this regard we have noted that Dunedin City for example has initiated full consultation
with Iwi in respect to the built heritage of the City and have started listing Marae in their
heritage schedules. This by the City with the lowest per capita (it‟s cold there) Maori
population. The heritage policies being implemented by Dunedin form a major part of
the tourism economy of Otago. But in Hamilton tourists too often pass us by.

Evidence provided to this hearing by the LDS Trust Board
36.

The LDS Trust Board in New Zealand operates under the control of the Presiding
Bishop in Salt Lake City, Utah, through its New Zealand Area Office administrators.
There is uncertainty within the general Church membership as to the financial
investments and overall business dealings regarding the commercial arm of the
Church, known as Property Reserve Investments (PRI).

The accounts of this

organization are not published however it is widely reported by public media outlets
that PRI continues to make major investments in property development with some
developments of up to $US2b on one shopping complex in downtown Salt Lake City
and a recent purchase of a significant land holding in Florida for $US500m. As a
Church funded by voluntary contributions, it has been able to amass property holdings
initially by appreciation of land values after the land was purchased with donated
funds.

The capital gains through these escalating land values have provided the

Church with a reputation of extreme wealth and a question mark about its charitable
status.
37.

The above business structure and methods were not in place during the construction
of the College and Temple in New Zealand. That programme required donated cash,
labour and materials. The technology had to allow for a „Lego‟ type of construction
which was new to New Zealand at the time. The effort worked as it dovetailed well
with a volunteer labour force sectioned off into different modules that provided a
cohesive construction schedule over an expansive green field site. This technique has


been somewhat copied by the construction industry today whereby houses in
particular are now primarily built by sub-contractor teams.
38.

It is however important to note that this approach to labour was compatible with Maori
tradition and therefore resulted in the Temple View construction programme being
embedded in the positive achievements of post war growth and a quiet sense of pride
throughout Maori settlements in New Zealand. There was also a building sense of
awe at what had been achieved. Indeed even when I was a student at CCNZ, tour
busses would drive through the campus. I once heard one tourist point to a group of
us from a bus window when calling out to other passengers “Look, there‟s some
Maoris”

The distinctive architecture of the campus, its flow through and connection to the
Temple
39.

The LDS have made submissions to this hearing in respect to the PDP and matters
that affect their ongoing plans for demolition of heritage buildings and structures. We
note that they have in fact provided no good reason to demolish buildings on the
CCNZ campus. A common sense approach has not been taken. The only reasons
given are:
a. The buildings are old and run down.
b. They are not able to be repurposed for alternative use and for example the
David O McKay building does not serve a purpose in the future of Temple
View. (What, every town would like to have a building like that!)
c. The houses need replacing with modern imitation versions of themselves.

40.

We submit those are bad excuses and fall very short of the requirements of the RMA
which require efficient use of land and resources. If every property owner was allowed
to tear down structures because they are over 50 years old then our country would end
up being ruled by ruthless organizations that keep pushing people around in righteous
indignation and contempt for fair and reasonable use of resources. Even Communist
Russia saved many of its religious heritage places despite the fact that God was
removed from the land.


41.

Las Vegas, a city first settled by LDS pioneers, allows destruction of new buildings
willy nilly however that city does have strict protection over older buildings and native
heritage buildings and places.

Church Land Holdings at Temple View
42.

We note that in his evidence to this forum on Friday, in respect to the 42A report Mr
Dawson confirmed that the Church is a large landholder at Tuhikaramea. Mr Dawson
however somewhat skirted around the fact that this landholding includes over 100
hectares of land across the road on an elevated site located adjacent to the present
Temple View settlement. This is on the north-western side of Tuhikaramea Road. The
land was previously reserved for expansion of the subdivision and also for the building
of a new chapel/stake centre.

43.

There is also a large flat field of about 20 hectares on Foster Road next to the existing
Temple View Chapel. This field was previously tested and confirmed as being suitable
for light timber frame type construction. So why destroy the Heritage site? Importantly
Church property development representatives have claimed extensive consultation
with members of the Temple View community in respect to their plans to build a new
stake centre along the ridge on the eastern side of Tuhikaramea Road. Initially the
community, Ngapuhi and Tainui was told the building was to be constructed on the flat
near the tennis courts. However we were later told it needed to be moved up to the
ridge and the houses there would need to be removed “…due to the danger of
liquefaction…”

Mr Dawson later presented the ongoing demolition plans by way of a

slide showing extensive housing and apartments rising to heights of over 6 meters on
the „liquefaction‟ flat area near the sports fields.
44.

We submit that this evidence is misleading. Both this evidence and that evidence read
to this hearing on Friday 15th was less than honest in our view and leaned heavily
towards creating a pathway to allow destruction of Maori heritage.

45.

We also note a major disclosure by the Church at the Friday hearing. In response to
questioning, Mr Dawson admitted the Church investment property arm has in fact been
planning to sell the land in question to property developers once, we assume,
demolition is approved.

This is new information and has never previously been

disclosed to the wider community. Indeed in a campaign to divide the community


Church representatives have presented grandiose plans and pictures that give the
impression that the Church will pay for the expansion and subdivision. We submit that
submissions in support of the demolition plans at Temple view are misleading and
should be put aside given this disclosure.
46.

Finally, we wish to state that we have a great respect for the missionary efforts of the
Church of Jesus Christ of Latter Day Saints, the Missionary Society of London and the
Catholic and other Christian denominations that helped build a respect for life and
goodwill through the transition to shared resources that we are building in New
Zealand today. We reject however any effort to undermine the ongoing struggle of our
people to be properly heard even if we may not fully understand or follow to the letter
the formal procedures or finer details in the legal process. We are not claiming divine
authority, but we support and seek after those things that are good for the wellbeing of
all New Zealanders and the City of Hamilton.

Recommendations
a.

Council include all the Maori architectural buildings and structures outlined in the
submissions by Ngapuhi, Tom Roa, (Head negotiator for Waikato/Tainui) and myself to
schedule 8 of the PDP with an „A‟ Ranking;

b.

Council amend all relevant parts of Chapter 5 of the PDP to better reflect the
significant history of Tuhikaramea in consultation with Tom Roa Head Negotiator for
Waikato Tainui and other affected Iwi;

c.

The Church of Jesus Christ of Latter Day Saints be required to refrain from
undermining the democratic processes of New Zealand through their „Divine
Intervention‟ church-house instructions to Church members for the purposes of mass
circulation of duplicated submissions to this commission. (We note that Church
members were asked to send in copied submissions from a single address and clearly
without proper agency being exercised particularly on the part of some Maori and
Pacific people. This in itself is a breach of LDS Church Policies and Procedures);

d.

Require the Church to provide the Hamilton City Council with a full Comprehensive
Development Plan in respect to all their landholdings within the Hamilton City
boundaries, said plan to include full and proper consultation with members and non
members of the Church in Temple View and the wider community. Include a credible


plan to back up the useful purpose in the future of Temple View. Full and honest
consultation with The Temple View Heritage Society, full and proper consultation with
Iwi including lead negotiators for Tainui and Ngapuhi and others throughout New
Zealand (not just with one or two Kaumatua around a meal table). It should be noted
here that the Church in their meetinghouse presentations claimed that consultations
had taken place with Ngapuhi and implied their support. This is not correct. Mr Kent
Money representing the Church was clearly told that Ngapuhi objected to their
destructive plans. Mr Roa was also quoted out of sequence at those Church house
meetings. These Church tactics have resulted in significant downstream costs to all
involved and increased tensions;
e.

Adopt all recommendations relevant to these submissions as presented By Dr Ann
McEwan;

f.

Request central government assistance with the assessment of any national
significance in respect to Maori living architecture and for the purpose of heritage
protection. Consult with other Cities in this regard in order to achieve consistency
throughout the country;

g.

Issue an Heritage Order over all buildings built before 1965 and within Chapter 5
„Temple View Heritage Zone‟ until such time that full fair and proper consultation with
Iwi and central government in respect to the national significance and importance to
Maori advice is received and in order to avoid ongoing heritage collapse;

h.

Appoint Maori Heritage Experts to the Advisory Board;

i.

Visit the Marae and other buildings listed in our submissions and accept the
recommendation of the Historic Places Trust to research these buildings and places
with a view to ensuring that their significance is not lost to the City and reject the
Church of Jesus Christ of Latter-Day Saints Trust Board submissions that the buildings
of significance to Maori not be included in Appendix 8.

Pita Witehira
19/11/2013


Peter Witehira Submission / Ngapuhi 2013

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