Before the Environment Court at Wellington

In the Matter of

And

In the Matter of

Lane Neave PO Box 25626 Wellington 6146 Solicitor Acting : Amanda Dewar

section 87G of the Resource Management Act 1991

the direct referral of the Application for resource consents associated with an extension to the runway by Wellington International Airport Limited

(ENV-2016-WLG-00058)

Affidavit of John Clifford Kyle

Email : amanda.dewar@laneneave.co.nz Phone: 03 379 3720 Lane neave.

I, John Clifford Kyle, Director, of Dunedin swear:

Introduction

1. My full name is John Kyle. I am a director of Mitchell Daysh Limited and have

provided resource management advice to Wellington International Airport Limited

(WIAl) in relation to its runway extension project, the subject of these

proceedings. I am authorised to make this Affidavit.

2. I have personal knowledge of the matter set out in this Affidavit and its contents

are true to the best of my knowledge and belief.

3. In April 2018 my firm prepared a report outlining the status of the various

technical reports provided as part of the resource consent application for WIAL's

runway extension project (April Report). I attach a copy of the April Report as

Exhibit A.

4. I have been asked to review the April Report in response to the two strike out

applications. I have reviewed the strike out applications and the accompanying

affidavits.

5. The April Report concluded:

"We are of the opinion that the technical reports that accompanied the

assessment of environmental effects for the Project can continue to be

relied upon, with any new information or updates being presented in

evidence if considered necessary. "

6. I consider the April Report remains valid for the following reasons :

(a) the biophysical effects of the runway extension (such as ecology, coastal

processes) have been assessed and the likelihood that time has

changed the findings of these assessments is very low; and

(b) some assessments such as the economic assessment, and the

forecasting will need to be updated before a hearing is held. Again this

should occur in preparing the evidence.

SWORN at Hamilton

)

this I! day of a{'I?IYJbr 2u!81 2018 befor me: )

J ! hn Clifford Kyle

Kuru ICltu Solicitor Hamilton

)

M I TC HE L L ,L

DAYSH

Exhibit Note

This is the annexure marked "A" referred to in the annexed affidavit of John Clifford

Kyle sworn al HamillO his /I ~ ay of December 2018 before me:

Signature .

A Solicitor of t (Solicitor to gn in part on Exhibit)

Kuru Ketu solicitor

Hamilton

WELLINGTON INTERNATIONAL AIRPORT LIMITED

PROPOSED RUNWAY EXTENSION - STATUS OF TECHNICAL REPORTS

April 2018

REPORT INFORMATION

Report Status Final

Our Reference 6900

File Location Dunedin

Author John Kyle I Claire Hunter

Review By John Kyle

© Mitchell Daysh Limited (2018).

This document and its contents are the property of Mitchell Daysh Limited .

Any unauthorised employment or reproduction, in full or in part. is forbidden.

Status of WIAL Runway Extension Technical Reports L ,

1. INTRODUCTION

As part of preparing resource consent application for the proposed runway extension

project (the Project) at Wellington International Airport (the Airport) a number of technical

assessment reports were prepared. These reports were prepared by independent experts

in order to inform a comprehensive assessment of the environmental effects associated

with the Project. These experts were also engaged to provide recommendations regarding

appropriate mitigation measures and environmental monitoring to be undertaken by WIAL

to manage any actual or potential adverse environmental effects arising as a result of the

Project's construction or operation.

The application for resource consent to enable the proposed runway extension has been

directly referred to the Environment Court. Following a Court of Appeal challenge by

NZALPA regarding the suitable runway end safety area (RESA) length, Wellington

International Airport Limited (WIAL) sought leave from the Environment Court to adjourn

the hearing. Upon receiving the subsequent Supreme Court Appeal decision, WIAL has

now requested a further Environ ment Court adjournment. This will aHow time for WIAL to

seek further consideration by the Director General of Civil Aviation of the acceptable RESA

length at Wellington Airport as part of the Project. The Director has indicated he will take

approximately six months to consider WIAL's request. As such, WIAL wishes to keep the

current application for resource consent "alive" in case the Director determines there are

potential RESA options which would enable the Project to remain in or very near its current

form such that it remains within the scope of the current application.

A number of section 274 parties to the Environment Court proceedings, have expressed

concerns with regard to this request. Concern has been raised that since WIAL's

application was prepared and filed, significant time has passed, and this may have

implications on the relevance and currency of the accompanying technical assessments.

There is criticism that due to the delay the technical assessments may be outdated and

not reflective of the actual or potential effects of the Project.

The purpose of this report is to consider whether these technical reports would remain

valid in the circumstances where the application is reactivated in its current form (or near

to it) .

2. CONSTRUCTION METHODOLOGY AND APPROACH TO THE

MANAGEMENT OF EFFECTS

The environmental effects associated with the proposed construction activities were

based on a construction methodology developed by the Project engineers AECOM. It was

noted in the relevant technical assessments that subsequent detailed design and contract

innovation may result in alterations to the final construction methodology. However, the

various technical assessments were based on the best estimate of construction which

Status of WIAL Runway Extension Technical Reports L ,

derived from AECOM's worldwide experience with similar projects. Flexibility in the final

design and construction methodologies was and is anticipated as part of the applications.

This is not uncommon in large scale infrastructure projects, because the process of

appointing contractors will almost always yield a degree of innovation in the way the

Project is ultimately delivered. Thus, consent terms and conditions should be designed to

provide sufficient flexibility to enable the benefits of such innovation to be realised, where

this remains consistent with achieving sustainable management of natural and physical

resources.

Based on the anticipated construction methodology and the subsequent operation of the

Project, the findings of the technical assessments (refer Chapter 7 of the AEE) have

concluded that in some cases the actual or potential effects of the proposed runway

extension are such that mitigation, remediation and/or monitoring measures are

necessary. It is proposed that the suite of mitigation and management measures is

formalised through the imposition of conditions on the resource consents that are being

sought by WIAL. Proposed conditions were attached to the application (refer section 8.5 of

Chapter 8 of the AEE), however it was always expected that the conditions would be

subjected to further amendments and refinements as the consenting process progressed

and further consultation with submitters occurred.

2 ,1 PROPOSED CONDITIONS

In summary, the conditions set out the following obligations:

) General construction matters including requirements to adopt best practice methods;

) Management and mitigation of potential construction effects. requirements for

community liaison and the preparation and implementation of an overarching

Construction Management Plan;

) Management and mitigation of ecological effects during construction and

requirements for post construction remediation;

) Management and mitigation of potential amenity and nuisance effects that are likely

to arise during construction e.g. construction traffic, noise, dust;

) Management and mitigation of potential effects on coastal processes including

mitigation to offset the effects on surfing amenity within Lyall Bay;

) Management and mitigation of potential effects on natural character, and landscape

values; and

) A requirement for urban amenity matters to be addressed including requirements for

enhancements to (in particular) the coastal margin.

Status of WIAL Runway Extension Technical Reports L

2 ,

In a number of areas, it is more appropriate to impose conditions which set in place

environmental process standards rather than requiring strict adherence to performance

standards that may not. in the long term. be the best way to mitigate effects.

With respect to the Project this is to be achieved utilising management plans.

2.2 PROPOSED USE OF MANAGEMENT PLANS

The proposed management plans vary in their function. At the most fundamental level

management plans detail the steps that need to be taken to achieve a specified outcome

or bottom line. These management plans have application where there is reasonable

certainty about the steps necessary to complete that process. The role of the

management plan in this context is to provide detail as to how a particular parameter is to

be met. The conditions of consent establish the relevant parameters.

The second type of management plan is more sophisticated and better suited to those

situations where a degree of flexibility is required in order to respond appropriately to

what is learned from "doing" including from monitoring results. This approach generally

revolves around the use of management plans to guide the way that a development or

resource use occurs at the outset, which is coupled with comprehensive monitoring

requirements and subsequent and ongoing adaptation of management responses to

better achieve predicted or desired outcomes. This approach is referred to as "adaptive

management".

Both forms of management plans are proposed to be utilised to mitigate and manage the

effects of the Project. As indicated earlier our experience with consenting large-scale

projects confirms that this practice is common and considered to be best practice,

including by the Court.

There are a number of elements of the Project which give rise to effects on environmental

values and where the outcome cannot be predicted at the outset (or at any stage) with

absolute certainty due to the dynamic and complex nature of the receiving environment

involved. Where such circumstances exist, an adaptive management approach is a useful

method in ensuring the desired results are attained. The following areas of management

associated with the Project can be the subject of such an approach:

> Effects on the aquatic ecology within the coastal environment affected by the

reclamation; and

> Effects on coastal processes including surfing amenity and seabed and foreshore

morphology.

The approach allows matters of management response to be left until after the consent

approval process. Conditions promoting such as approach are generally coupled with

obligations to collaborate with key interest groups and/or the consent authority to settle

upon the appropriate response given what has been learned. Again, this is not uncommon

Status of WIAL Runway Extension Technical Reports L.

3 ,

with large scale infrastructure projects, and is a particularly good management tool where

a longer lapse date for the consents is also being sought (e.g. 10 - 15 years).

2.3 SPECIFIC MANAGEMENT PLANS

The following management plans were identified as being required to ensure any actual or

potential adverse effects arising from the Project were suitably managed:

) Construction Management Plan (CMP).

) Stakeholder and Communications Management Plan (SCMP).

) Construction Air Quality Management Plan (CAQMP);

) Noise and Vibration Management Plan (NVMP);

) Construction Traffic Management Plan (CTMP);

) Erosion and Sediment Control Plan (ESCP);

) Environmental Mitigation and Management Plan (EMMP);

) Surf Mitigation Adaptive Management Plan (SMAMP);

) Landscape and Urban Design Management Plan (LUDMP); and

) Network Utility Management Plan (NUMP).

The proposed conditions of consent require each management plan identified above to be

finalised prior to construction commencing. In some instances, for example the Surf

Mitigation Adaptive Management Plan, additional baseline monitoring is proposed to be

obtained to further confirm the existing state of the environment The management plan

obligations also require extensive consultation with key stakeholders or the immediately

affected community and will be constructed to adapt to address current concerns and

issues.

It is our view that the requirements of the conditions coupled with the assessments and

future work that is required to prepare the management plans need to be considered in

assessing the currency and ongoing validity of the technical assessments. In short, the

adaptive approach is responsive to change and uncertainty, and it should be. Thus, it is

fundamentally wrong to assume that all of the technical assessments should present the

"final word" as to how the various effects arising from the Project should be managed. We

return to these matters as we discuss each relevant report below.

3. STATUS OF TECHNICAL REPORTS

As mentioned above, a number of technical reports were prepared to accompany the

resource consent applications prepared by WIAL for the Project. These reports consisted

of:

Status of WIAL Runway Extension Technical Reports L

4 ,

> Astral Aviation Consultants - Review of Runway Length

> InterVISTAs - Route Development Assessment

> InterVISTAs - Route Forecasts

> Sapere Research Group - Cost Benefit Analysis

> Raukura Consultants - Cultural Values Report

> TRC- Assessment of Effects on Recreation

> AECOM - Concept Feasibility and Design Report

) Astral Aviation Consultants - Construction Aeronautical Study

> Traffic Design Group - Traffic Assessment

> AECOM - Construction Noise Assessment

> DHI Water and Environment limited (OHI) - Surf Break Impact Assessment

> AirBIZ - Alternatives Airport Sites Investigation

> Raukura Consultants - Cultural Impact Assessment

> DHI - Preliminary Shoreline Assessment

> National Institute of Water & Atmospheric Research Ltd (NIWA) - Coastal Processes

Assessment

> NIWA - Marine Sediments and Contaminants (Lyall Bay)

> NIWA - Technical Report on Coastal Hydrodynamics and Sediment Processes in Lyall

Bay

> NIWA - Ecological Character Report

> Aquatic Environmental Sciences (AES) - Assessment of Ecological Effects

> NIWA - Assessment of Ecological Effects arising from the Proposed Submerged Wave

Focussing Structure

> AECOM - Construction Air Quality Assessment

> Kevin Jones - Archaeological Assessment

> Boffa Miskell limited - Urban Design Assessment

> Boffa Miskell limited - Landscape and Visual Assessment

> Frank Boffa - Natural Character Assessment

> Marshall Day Acoustics - Operational Noise Assessment

An assessment of whether these reports have, and will continue to endure the test of time

to accommodate the requested additional time is set out below:

Status of WIAL Runway Extension Technical Reports L

5 .,

3.1 RUNWAY DESIGN AND LOCATION

Relevant Reports

) Astral Aviation Consultants - Review of Runway Length

> Astral Aviation Consultants - Construction Aeronautical Study

) AirBIZ - Alternatives Airport Sites Investigation

The reports prepared by Astral Aviation Consultants assess the runway extension length

options to determine which configuration would allow viable operations of long haul flights

from Wellington to east Asian and western North American destinations. These reports

also establish appropriate construction parameters associated with working within an

operational airfield. It is not anticipated that technology regarding the type of aircraft, or

construction techniques will significantly change within the timeframes that are being

sought by WIAL with the Court and therefore the findings of these reports will remain valid

to the consideration of the runway extension project.

The AirBIZ report builds on an earlier study an earlier study undertaken by Works

Consultancy Services in 1992. This original study encompassed the establishment of

selection criteria for feasible airport sites, a search for such sites within the Wellington

region, and a high level economic evaluation of candidate locations. Seven sites were

identified following review of the region's topography to find the preferred location. The

conclusions of the 1992 study supported retention of Wellington Airport at its current

location. The work undertaken by AIRBIZ in 2013 further confirmed that the current

location of the Airport remains the most appropriate, due to its close links to the

Wellington CBD, and the existing investment and infrastructure already established at the

site. The conclusions of this report are unlikely to change.

3.2 FORECASTING

Relevant Reports

) InterVISTAs - Route Development Assessment

) InterVISTAs - Route Forecasts

The reports prepared by InterVISTAs provide an assessment of the potential demand from

the airline's perspective for a longer runway at Wellington Airport. These assessments use

relatively up to date passenger and aircraft data. so it would be appropriate that the

conclusions reached in these reports are revisited. These assessments however

contribute to the rationale ed for the Project, and any changes to the conclusions found in

Status of WIAL Runway Extension Technical Reports

L 6 .,

these reports can likely be adequately addressed in evidence. rather than the preparation

and circulation of a new report.

3 .3 ECONOMIC ANALYSIS

Relevant Reports

> Sapere Research Group - Cost Benefit Analysis

Sapere Research Group prepared the cost benefit analysis for the Project. This

assessment and report was based on up to date market data and forecasts at the time the

application was filed and would be expected to be updated regardless of the length of the

adjournment. As a result, it is appropriate that the analysis is revisited prior to the hearing

proceeding and can likely be presented in evidence. rather than the preparation and

circulation of a new report.

As a result. it is appropriate that the conclusions reached in th is assessment are revisited

prior to the hearing proceeding. Such findings can likely be presented in evidence, rather

than the preparation and circulation of a new report.

3 .4 CONSTRUCTION METHODOLOGY AND EFFECTS

Releva nt Reports

> AECOM - Concept Feasibility and Design Report

> AECOM - Construction Noise Assessment

> AECOM - Construction Air Quality Assessment

As mentioned earlier in this report. the construction methodology has been developed

based on AECOM's experience with other similar reclamation projects around the world .

However, it was recognised in the application documentation that subsequent

investigations, detailed design and contractor innovation may result in alterations to the

construction methodology. The CMP will confirm construction methodologies. plant and

equipment to be utilised and construction timeframes, as well specific measures to be

employed to avoid, remedy or mitigate adverse effects.

It should also be noted that the environmental assessments (e.g. construction noise and

traffic assessments) that have relied on this construction methodology have been

assessed on the worst-case basis (e.g. all fill material will be land based and transported

on the road network. rather than being marine based and barged to the site. and the

Status of WIAL Runway Extension Technical Reports ...

7 "I

requirement for stone columns to stabi lise the reclamation) and are therefore considered

to be conservative. As such, in our assessment the AECOM work can be relied upon even

if the Court hearing is further delayed.

3.5 CULTURAL AND ARCHAEOLOGICAL ASSESSMENTS

Relevant Reports

) Raukura Consultants - Cultural Values Report

) Raukura Consultants - Cultural Impact Assessment

) Kevin Jones - Archaeological Assessment

A Cultural Values Report and Impact Assessment accompanied the application to extend

the Airport's runway. The values report identified historical and current uses of the

immediate and surrounding area and identified the cultural significance of the site. The

historical facts presented in this report will not alter, nor will the cultural significance of the

immediate or surrounding site. Current uses are largely associated with gathering kai

moana, and although there may be fluctuations in the abundance and availability of such

resources, the effects of the proposed runway extension in this regard (Le. loss of an area

of habitat. restriction of the coastal marine area during construction etc) are well known

and understood. Such effects are not expected to differ if there is a further delay in the

hearing proceedings.

The archaeological assessment is also based largely on historical facts, and any findings in

this regard are unlikely to change necessitating a revisit of this assessment.

3.6 RECREATIONAL ASSESSMENT

Relevant Reports

) TRC4 Assessment of Effects on Recreation

The Recreational Assessment identified that Lyall Bay is popular for a number of

recreational activities including walking, running, surfing, kite surfing, surf lifesaving,

swimming, fishing, drives, picnics, visiting cafes and aeroplane watching. The CMA around

Moa Point is also used for diving, snorkel ling, fishing and gathering of seafood. The report

also identified various activities resulting from the construction and/or operation of the

runway extension that could adversely affect these pursuits. While the popularity of the

identified activities may alter (due to weather patterns, new retall or cate activities in the

area), the nature of the activities undertaken in the area will remain relatively constant and

Status of WIAL Runway Extension Technical Reports l­

S .,

as such the assessment of actual or potential adverse effects on such activities will remain

valid.

Due to the original author of the recreational report relocating overseas, WIAL

commissioned another recreational expert to peer review this work and provide evidence

at the hearing. While this may result in slightly differing conclusions being reached as to

the extent and/or severity of effects, the type of recreational activities that occur in the

area and the nature of the effects arising from the construction and operation of the

runway extension are not anticipated to alter to any significant extent.

Furthermore, WIAL has and is continuing to discuss the impacts of the proposal with key

recreational groups and stakeholders such as the Wellington Boardriders Club. Such

parties represent a wide range of individuals, and although there may be new members or

surfers to the area since the applications were first lodged who may not have made an

individual submission or joined as a section 274 party, it is considered that their interests

are likely to be sufficiently covered via the submissions of such stakeholders and the

ongoing consultation with representatives.

Key management plans, for example the CMP, SCMP, CTMP, and the SMAMP, establish

measures to mitigate potential adverse effects on recreational activities (Le. timing of

heavy traffic to avoid congestion and safety issues with pedestrians and cyclists) and also

require that WIAL consult with key stakeholders and communicate with the affected

community and recreational groups prior to and throughout the construction of the Project.

3.7 TRAFFIC AND TRANSPORTATION ASSESSMENT

Relevant Reports

> Traffic Design Group - Traffic Assessment

The key matter arising with regard to effects on the transportation network from the

Project is the haulage of fill material through the state highway and local road network to

the Project site. As set out in the application the method for the transportation of fill

material to the site will not be finalised until a construction contract is awarded and the

details around the source of construction material is confirmed. If dredged material is

utilised, then this wou ld likely result in a significant reduction of fill material transported via

the road network. The traffic assessment assumed a 'worst case scenario' whereby all fill

material would be transported to the construction site by road.

Key matters that informed the preparation of the traffic assessment included road capacity

and road safety. While baseline traffic results are not anticipated to alter significantly within

the timeframes being proposed by WIAL, WIAL has used the delay in the current

proceedings to work closely with the NZTA to develop and try to agree conditions relating

Status of WIAL Runway Extension Technical Reports L.

9 "I

to the haulage of material to the site. As part of this ongoing consultation, the NZTA

identified that because WIAL is seeking a 10 - 15 year lapse date, conceivably the Project

construction may be some time away and therefore additional modelling of the anticipated

future road capacity (e.g. the road network in 2016 vs 2026) was required. Such modelling

is underway, and this will assist in informing the impacts of haulage traffic on general road

capacity. intersection delays and speed impacts in this future environment. Such data and

conclusions relating to effects on this future environment can be presented at the hearing

via evidence.

In addition to this work that is underway, the proposed CTMP will detail controls for

construction traffic , including provisions for temporary traffic management, driver protocols

and monitoring. This Plan will appropriately account for where fill material is being

sourced, and accurately detail and manage the expected construction vehicle movements

and resulting effects on the surrounding environment.

This area of assessment is necessarily dynamic in nature due to the fact that road user

characteristics continually evolve. This is an iterative process that builds upon the original

assessment and is necessarily collaborative, particularly with the NZTA and with the

Council as road controlling authorities.

3.8 SURF AND SHORELINE ASSESSMENTS

Relevant Reports

) DHI Water and Environment Limited (OHI) - Surf Break Impact Assessment

) DHI - Preliminary Shoreline Assessment

Utilising data obtained by NIWA, DHI undertook numerical modelling to assess the impact

of the proposed runway extension on the wave climate, swimmer safety and surf quality of

the surf breaks at Lyall Bay. This modelling was based on robust physics and an

understanding of the local surf environment, and although the data was obtained some

time ago (e.g. 2014) changes to the surf environment within Lyall Bay are not anticipated to

occur rapidly to the extent that the conclusions reached by DHI with regard to the

potential effects on the surfing amenity within Lyall Bay will be significantly altered.

Furthermore, the findings of this report are that Airport Rights surf break will be losl, and

there will be a decrease in wave peakiness due to reduced refraction to the east

elsewhere in the Bay. This ultimately results in an adverse effect on the surfing quality

with in Lyall Bay. Those most directly affected by this, in particular organisations which

represented the views of a number of individuals and community members such as the

Wellington Boardriders Club and the Lyall Bay Surf Lifesaving Club were closely involved

Status of WIAL Runway Extension Technical Reports I-

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in consultation with WIAL at the outset of the Project and the sharing of information with

regard to the DHI reporting.

To mitigate or offset these effects a submerged wave focusing structure is proposed. WIAL

is still committed to this mitigation, and via ongoing consultation with key stakeholders

such as the Wellington Boardriders Club, has developed detailed conditions requiring the

preparation of a SMAMP. As detailed design of the proposed structure has not yet been

undertaken, in preparing the SMAMP WIAL is required to undertake further, more detailed

baseline monitoring. It has been generally agreed that the conditions and subsequent

preparation of the SMAMP, which also requires extensive stakeholder input and review,

are an appropriate mechanism for addressing the key concerns of the local surfing

community affected by the proposal. Again, an adaptive management response is

proposed. and responses necessarily evolve as more is learned. This approach has been

endorsed in the submission by the Wellington Boardriders Club.

3,9 COASTAL PROCESSES AND COASTAL ECOLOGY

Relevant Reports

> National Institute of Water & Atmospheric Research Ltd (NIWA) - Coastal

Processes Assessment

> NIWA - Marine Sediments and Contaminants (Lyall Bay)

) NIWA - Technical Report on Coastal Hydrodynamics and Sediment Processes in

Lyall Bay

) NIWA - Ecological Character Report

> Aquatic Environmental Sciences (AES) - Assessment of Ecological Effects

> NIWA - Assessment of Ecological Effects arising from the Proposed Submerged

Wave Focussing Structure

NIWA was commissioned to undertake various assessments into the coastal processes,

marine environment and aquatic habitat that would be directly affected by the proposed

runway extension. Although the investigations that underpin these assessments were

undertaken some time ago (N2014 - 2016) changes to coastal processes and habitat are

generally slow moving unless there is sudden anthropological interference. Temporal

changes are not expected to be more than gradual, even evolutionary. The area

immediately adjacent to the existing runway comprises rocky reef habitat and as such

does not experience any significant aggregation or degradation of material depOSition,

and the species composition in this immediate area due to this habitat is also likely to

remain relatively consistent within this timeframe. Given this, the findings of these

assessments are likely to remain valid.

Status of WIAL Runway Extension Technical Reports L

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It is acknowledged however that there could be land use changes or other natural

phenomenon that result in reasonably instantaneous responses from the coastal

environment (e.g. discharges of material which could alter the current species composition

or habitat; or an earthquake resulting in a new reef formation). If this was to occur, then it

would be reasonable for WIAL to undertake further assessment of the impacted coastal

marine area. These are likely to result in reasonably obvious responses in the receiving

environment; and no such changes are currently known to have occurred since the

applications were filed.

3.10 LANDSCAPE AND NATURAL CHARACTER

Releva nt Reports

> Boffa MiskellUmited - Urban Design Assessment

> Boffa Miskell Limited - Landscape and Visual Assessment

) Frank Boffa - Natural Character Assessment

Construction of the Project will extend the existing runway further out into the CMA. The

landscape and natural character assessments concluded that this will change perspectives

of the area from certain viewpoints and in particular. from residential properties which

currently overlook the area from both the east (Moa Point, Strathmore Park) and west (Lyall

Bay. Houghton Bay) of the Airport. The visual and landscape assessment includes a

detailed visual assessment, taken from a broad range of identified key viewpoints.

The most pronounced visual effects will arise from those living closest and with direct

views to the Project site and those using public spaces near it, to the east of the site. Moa

Point residents will be most affected by the visual effects of the reclamation. If the footprint

of the proposal remains the same or similar then these findings are unlikely to change.

The only thing that could change is the receivers themselves. We understand that the

possibility of recent and ownership cha nges might be able to be addressed through

succession or waiving time limits so that any new owners are not denied an opportunity to

participate in the hearing, should they wish to do so. Having said that we are not aware of

Moa Point residential property ownership changes, aside from the fact that WIAL is actively

continuing to acquire these properties.

As would be expected the assessment of the effects of the Project on natural character

focusses on changes that will result to natural processes and natural forms. There have

been no significant changes occur to baseline conditions in this regard and one can

reliably expect that the assessment report would remain current and fit for purpose,

despite the delay in proceedings, due to the fact that it largely deals with changes to the

bio-physical receiving environment.

Status of WIAL Runway Extension Technical Reports 12 ,

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3.11 OPERATIONAL NOISE

Relevant Reports

) Marshall Day Acoustics - Operational Noise Assessment

The noise assessment by Marshall Day determines that the proposed runway extension

and Code E aircraft would not cause a significant change to overall noise exposure (Lon) in

the community and noise from aircraft operations would comply with the current Air Noise

Sounda.y (ANS) for a sufficiently long period of time. Unless in the intervening period there

has been significant variance in aircraft type or technology likely to use the runway

extension (and there has not). the findings of this assessment are unlikely to change in the

period of time that has elapsed between the assessment report being completed and the

likely hearing date.

4. SUMMARY

A number of technical reports were prepared by a range of independent experts in order

to inform a comprehensive assessment of the actual or potential effects on the

environment arising from the Project. These assessments were based on the construction

methodology that was provided by the Project engineers AECOM. The AECOM

methodology was based on that firm's extensive global experience with land reclamation

and infrastructure development projects. These assessments have been utilised in the

knowledge that subsequent detailed design and contractor innovation would likely result

in alterations to the final construction methodology. These assessments also assume a

'worst case' construction methodology regarding certain aspects of the Project, for

example that all fill material would be from land-based sources and therefore transported

to the site via the road network. On this basis the reporting for various aspects of the

Project is considered to be conservative.

The expert assessments also recommend various methods to avoid, remedy or mitigate

adverse effects on the environment. In a number of cases, the reporting recommends the

use of an adaptive management approach, whereby further monitoring and investigation,

and the development and refinement of mitigation is identified as the Project development

progresses. It is intended to respond to the state of the environment at the time the

construction of the Project commences. Th is is appropriate and not uncommon with large

scale infrastructure projects. particularly where a longer lapse date (of 10 -15 years) is also

being sought. A number of management plans are proposed in this regard.

Against this background, it is our view that there are very limited circumstances where the

technical reporting related to the Project will become outdated, even in light of the

timeframes proposed. We are of the opinion that the technical reports that accompanied

Status of WIAL Runway Extension Technical Reports

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the assessment of environmental effects for the Project can continue to be relied upon,

with any new information or updates being presented in evidence if considered necessary.

The key reasons for this are as follows:

> Technical matters relating to the construction and management of an operational

airfield are unlikely to alter.

> Ecological and coastal processes - although the investigations that underpin these

assessments were undertaken some time ago (N2014 - 2016) changes to coastal

processes and habitat are generally slow moving unless there is sudden

anthropological influence. Temporal changes are not expected to be more than

gradual.

> Cultural, heritage and archaeological assessment are largely based on historical facts

and events, and therefore the findings of these reports are unlikely to significantly

change.

> The economic environment in which the Project exists may be subject to external and

internal fluctuations, and therefore it would be appropriate to revisit these matters. We

think that this updating can be done in evidence without any prejudice to the parties.

This is a typical situation in our experience.

> With regard to recreational effects, landscape, natural character, visual amenity and

construction related amenity effects. it is accepted that there may be some changes

to the receiving environment (Le. the neighbouring property owners may change),

however the findings with regard to the nature, scale and intensity of such effects are

unlikely to significantly change. It is also noted that WIAL is committed to continually

working with the affected community prior to and during construction in particular to

ensure they remain informed and any commitment with regard to mitigation (i.e. noise

mitigation or property relocation during particularly noisy periods) is successfully

implemented. These measures are to be guided by the management plans proposed .

We also understand that there are legal means to address change in land ownership

and involvement in the proceedings within the affected community.

> During consultation the NZTA has expressed concern that the road network and

traffic environment could alter within the 10 - 15 year lapse date that is being sought

by WIAL with regard to the Project. WIAL is continuing to work with the NZTA and

modelling of the expected future road network is underway. These findings are to be

presented in evidence in due course. Neither the NZTA nor the Councils have raised

any difficulty with this iterative approach. Certain matters, such as the submerged

wave focussing structure were always intended to be subject to further site

investigation, monitoring and consultation with key stakeholders as set out in the

relevant management plan.

L. Status of WIAL Runway Extension Technical Reports

14 ,