auckland council statement of evidence of william (bill ... and project rosedale (tbm (epbm) and...

68
Under the Resource Management Act 1991 In the matter of Notices of Requirement to enable the construction, operation and maintenance of the City Rail Link Between Auckland Transport Requiring Authority and Auckland Council Consent Authority Statement of Evidence of William (Bill) Russell Newns

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Page 1: Auckland Council Statement of Evidence of William (Bill ... and Project Rosedale (TBM (EPBM) and access shafts and outfall structures) and the Huntly North Shaft (caisson sinking and

Under the Resource Management Act 1991 In the matter of Notices of Requirement to enable the construction, operation and maintenance of the City Rail Link

Between

Auckland Transport Requiring Authority

and

Auckland Council Consent Authority

Statement of Evidence of William (Bill) Russell Newns

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Qualifications and Experience

1. My full name is William (Bill) Russell Newns.

2. I am a Chartered Engineer registered with the Engineering Council of

the UK (No. 518790) and I am a member of the Hong Kong Institute of

Engineers (No.M00374030) and the Institute of Professional Engineers

in New Zealand (1011478).

3. My academic qualifications include a Bachelor of Science degree in

Geology from the City of London Polytechnic in 1990, a Master of

Science degree in Mining Engineering from the Camborne School of

Mines in 1994 and a Diploma in Arbitration from the University College

Dublin, gained in 2004.

4. I am the technical secretary and committee member of the

New Zealand branch of the Australasian tunnelling society.

5. I have over twenty years of professional services experience which

includes the design and construction supervision of major civil

engineering projects.

6. My major international civil engineering project experience over the last

two decades includes:

(a) Lantau Airport Railway Mass Transit Railway Corporation Hong

Kong (MTRC) (Tung Chung and Tsing Yi Stations and Tsing Yi

Tunnels (Drill and Blast) (Design + Build (D+B));

(b) Tseung Kwan O Extension MTRC (Black Hill Tunnels and Pak

Shing Kok Tunnels, D+B);

(c) Route 3 Tai Lam Road Tunnels (D+B and caverns);

(d) Tai Lam rail tunnel and caverns (D+B);

(e) Quarry Bay Congestion Relief Works in Hong Kong MTRC

(Tunnel Boring Machine (TBM), D+B and caverns in dense urban

Central Business District (CBD) with modifications to existing live

rail station and many sensitive receivers);

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(f) Dhoby Ghaut Tunnels in Singapore (Earth Pressure Balance

TBM) (EPBM) for metro rail;

(g) Dublin Port Tunnels (TBM + cut and cover tunnels and caverns

beneath residential areas); and

(h) Adelaide Desalination Plant - intake and outfall tunnels (TBM,

slurry and ground treatment to control groundwater ingress).

7. I currently hold the position of Technical Director at Aurecon, a

company I joined in 2005 since moving to New Zealand.

8. My design and construction experience in New Zealand includes the

Browns Bay Trunk Sewer Replacement (extensive pipe-jacking using

micro-TBM, slurry), Project Hobson (TBM (EPBM) and associated

shafts) and Project Rosedale (TBM (EPBM) and access shafts and

outfall structures) and the Huntly North Shaft (caisson sinking and shaft

sinking to 161m).

9. Since 2006, I have also been closely involved in the planning and

subsequent procurement of the Waterview Connection Tunnels (large

diameter TBM tunnel). From 2006-2008 I was the design manager for

concept levels designs for two and three lane running tunnels using

TBM covering all engineering disciplines including fire and life safety.

I also prepared settlement assessments for the AEE. For the 2011

procurement I developed and amended the Minimum Requirements for

the underground works and the TBM (specifications) during

procurement and also prepared the geotechnical baseline report. I also

evaluated both alliance proponent tenders in terms of technical and

programme risk.

10. I have been almost continuously involved with active construction

including supervision of major projects in “greenfield” and urban areas

as either Engineer or Engineer’s Representative or Designer or

Designer’s representative. These projects have typically included TBM

tunnelling, drill and blast operations for quarrying and tunnelling, major

earthworks, diaphragm, secant pile and sheet pile wall installations,

sequential excavation for large diameter caverns, shaft sinking,

pipejacking and major utility diversions. I have therefore direct and

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extensive experience of all of the proposed methods of construction

required for the City Rail Link project.

Background and role

11. The City Rail Link (CRL) project is a 3.4km underground passenger

railway (including two tracks and three underground stations) running

between Britomart Station and the North Auckland Line (NAL) in the

vicinity of the existing Mount Eden Station. The CRL also requires an

additional 850m length of rail modifications within the NAL. The stations

included in the CRL NoR have been temporarily named Aotea Station,

Karangahape Station, and Newton Station.

12. Aurecon NZ Ltd was engaged by Auckland Transport (in February

2012) as Principal Advisor (PA) for the CRL project. The PA is led by

Aurecon NZ Ltd and comprises the principal partners of Aurecon NZ

Ltd, Mott MacDonald, Jasmax and Grimshaw. The PA reports directly

to Auckland Transport’s Infrastructure Delivery work stream which is

responsible for delivery of the CRL project. The PA is also supporting

the Notice of Requirement (NoR) and Property work streams.

13. Since February 2012 I have been the Design Manager for the PA team

for CRL which developed the NoR Concept Design. In that capacity,

and with the assistance of the PA team of engineers and architects and

Auckland Transport’s team of planners and expert advisors I have been

responsible for developing the NoR concept designs and the indicative

construction methodology and programme.

14. I was also involved in a similar capacity (albeit with a smaller team) for

the CRL Project in 2008 for ARTA1 and Kiwirail2 which established the

alignment within Albert Street.

15. I am familiar with the project location, track alignment and the site

specific locations for each proposed station. I have walked the

proposed route and visited all proposed station sites many times and

1 The former Auckland Regional Transport Authority.

2 New Zealand Railways Corporation.

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am familiar with the context within which the CRL station concept

designs have been developed.

16. I have read the Code of Conduct for Expert Witnesses as contained in

the Environment Court Consolidated Practice Note (2011), and I agree

to comply with it as if this hearing was before the Environment Court.

My qualifications as an expert are set out above. I confirm that the

issues addressed in this brief of evidence are within my area of

expertise. I have not omitted to consider material facts known to me

that might alter or detract from the opinions expressed.

Scope of Evidence

17. My evidence will address the CRL Concept Design for the Notices of

Requirement (NoR) in respect of the existing land use constraints. In

more detail, my evidence will cover:

(a) The Concept Design - Principles and Process;

(b) Design Constraints;

(c) The Concept Design;

(d) Indicative construction methodologies including worksite locations

and activities;

(e) An indicative construction programme;

(f) Response to submissions;

(g) Response to Planner’s Report; and

(h) Proposed conditions.

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City Rail Link (CRL) – Concept Design Principles and Process

18. The CRL alignment and design has been developed with reference to a

range of design considerations and physical constraints, particularly

topography, ground conditions and man-made structures including

building substructures and significant utilities. The Concept Design

Report (CDR)3 contains a description of the concept design developed

for the CRL Project. In addition, the CDR contains the indicative

construction methodology and programme.

19. The concept design also establishes engineering and architectural

design parameters which will provide an ‘envelope’ for future design

iterations as the CRL project moves through its various design phases.

20. The concept design has been informed by two past studies for the

CRL, namely:

(a) CBD Rail Tunnels – Aotea Station Extension Study, 2008,

prepared by Aurecon (formerly Connell Wagner), ARTA;

(b) Auckland CBD Rail Link Study – Option Evaluation Report, 2010,

and Concept Design for Preferred Alignment and Station

locations, 2010, prepared by Aecom, Parsons Brinckerhoff; and

Beca (APB&B), ARTA and KiwiRail.

21. An objective for the Design team was to establish design ‘robustness’

in consideration of options. This typically involves considerations of

cost, flexibility and practicality in view of a reasonably high level of

uncertainty or risk. Elements of uncertainty may include for example

the understanding of ground conditions and the position and nature of

utility services particularly within the CBD.

22. Another key objective has been to determine a coherent set of designs

across the architectural and engineering disciplines. In that respect,

the Design of underground railways including underground stations is

particularly interdependent with design aspects having significant

influences on other design aspects.

3 Appendix 13: Volume 3 CRL NoR suite of documents.

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23. In order to support the NoR process, the concept design should be

robust (as described above) but flexible so as not to overly constrain

construction techniques, methods or staging particularly for temporary

construction activities (which enable provision of the permanent CRL

structures) as this is where the constructor can add significant value

during the tendering and procurement phases of the project.

24. Therefore, reasonable construction tolerances have been provided

within the NoR concept design using local knowledge and experience

of the range of techniques that may be applied and inputs from the

wider PA team. An objective in that process is the identification and

characterisation of key constraints.

25. The design of the permanent works is driven primarily by the rail

alignment which is largely fixed at either end by the existing rail

infrastructure.

26. The location of station precincts was determined by the 2010 APB&B

Option Evaluation Study. Therefore the Concept Design alignment was

developed from determining the position (and length) of the rail station

platforms within the governing geometric rules for rail grades

(described below).

27. Following confirmation of the station platform positions, options for

station form were established and preferred options selected (as

discussed in the evidence of Mr John Fellows). These were then

considered alongside potential alignment constraints of the adjoining

rail tunnels (running tunnels) which I also describe below (e.g. existing

infrastructure such as building basements, the Orakei Main Sewer and

the Central Motorway Junction).

28. The Concept Design rail alignment is thus one possible solution with a

degree of design flexibility within the NoR envelope. Having said that,

the alignment flexibility has fairly narrow tolerances given the overall

challenge of topography as noted above but also given the knock-on

impacts to the overall scheme. A general principle was to maximise the

extent of the rail alignment within road reserve, where practicable.

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29. A fuller description of the options analysis that was undertaken is

provided in the report authored by Auckland Transport titled City Rail

Link: 2012 Option Evaluation Summary Report.4

Design Constraints

30. The following are the key technical considerations that have informed

the concept design rail alignment:

(a) Minimum desirable speed (50km/hr);

(b) Maximum vertical grade (compensated for curvature) of the

alignment within tunnels (3.5%);

(c) Maximum vertical grade at stations (1%); and

(d) Platform length at stations (150m).

31. It is characteristic of CRL that rail gradients are near the maximum limit

(3.5%) for Electric Multiple Units (EMU) in order to connect Britomart to

the NAL at Mt Eden, a vertical climb of some 70m.

32. The CRL electrification will be integrated into the Auckland rail system

25 kV AC traction power network.

33. Signalling and a range of information and communication technologies

have been applied to the indicative CRL design. Section 3 of the CDR

provides a list of the matters that have been taken into account.

34. Key physical constraints, being natural or man-made features, and

which have been considered as part of the concept design include:

(a) Natural topography (which results in an approximate 70m vertical

climb between Britomart and the NAL);

4 Appendix 13: Volume 3 CRL NoR suite of documents.

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(b) Geological conditions5;

(c) Significant structures and buildings including:

(i) The Central Post Office (CPO) in Lower Queen Street;

(ii) The Zurich Building (21 Queen Street) and the HSBC

building;

(iii) Bluestone retaining wall on Albert Street (Wyndham Street

to midway between Durham and Victoria Street West) and

Lower Albert Street;

(iv) Access to and structural foundation constraints of buildings

lining the route particularly Albert Street;

(v) Central Motorway Junction Motorway Structures;

(vi) Heritage buildings and structures scheduled under the New

Zealand Historic Places Act or Auckland Council District

Plans (including the bluestone retaining wall in Albert

Street); and

(vii) Other sensitive buildings or buildings classified as having

character merit by either the New Zealand Historic Places

Trust or Auckland Council;

(d) Utilities including:

(i) The Watercare Orakei Main Sewer on Victoria Street West;

(ii) Vector Tunnel at Mayoral Drive;

(iii) The Auckland Council 1500-1665mm stormwater drain in

Albert Street;

5 Investigations indicate the presence of fill, alluvial clays and silts and below these the

bedrock of East Coast Bays Formation (ECBF) (in various states of weathering) along the

alignment. Basalt rock and ash is present in the South near Mt Eden.

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(iv) The Watercare 375mm bulk water supply main in Pitt

Street;

(v) The Watercare 1300mm bulk water supply main in Nikau

and Ruru Streets; and

(vi) The Auckland Council 1950mm stormwater drain in Nikau

and Ruru Streets;

(e) Existing operating rail lines at Britomart and NAL; and

(f) Major road intersections.

35. With respect to the various technical matters and physical constraints

listed above, I note that the concept design detail has been developed

at a high level. As such, further more detailed investigation and design

work is required. This work will likely include a combination of further

site investigation into underlying ground conditions, detailed

vulnerability assessments of buildings and utilities and further design

and constructability reviews.

Worksites

36. Appendix A to my evidence indicates the locations of the proposed

worksites along the length of the proposed CRL route. With reference

to Figure 1 below the worksite locations are described as:

(a) A - North Auckland Line Surface Connections (west);

(b) B - North Auckland Lines Surface Connections (east);

(c) C - Mt Eden TBM worksite;

(d) D1 – Newton Station (Mt Eden Road Main Entrance Shaft);

(e) D2 – Newton Station (Dundonald Street Egress and Ventilation

Shaft);

(f) E1 – Karangahape Road Station (Beresford Square Main

Entrance Shaft);

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(g) E2 – Karangahape Road Station (Mercury Lane Egress and

Ventilation Shaft);

(h) F – Albert Street South including Aotea Station;

(i) G - Albert Street North to Customs Street;

(j) H –Downtown Shopping Centre, Lower Albert Street and Queen

Elizabeth II Square; and

(k) J - Britomart Station.

37. Worksites A, B and C, adjacent to the NAL corridor are envisaged to

support the entire CRL construction programme as it is envisaged that

the rail fitout will be largely undertaken from this end of the Project.

Fitout activities for stations will largely occur at each station supplied

from either end.

The Concept Design

38. In this section of my evidence I describe the rail alignment and

associated design and construction considerations which have been

developed for the CRL project.

39. The indicative construction methodologies and sequence for the CRL

project has been developed for the purposes of defining the land

required for the construction works, informing the Assessment of

Environmental Effects (AEE) accompanying the Notices of

Requirement (NoR), identifying actual and potential effects resulting

from the construction of the CRL and any potential management

methods, to appropriately mitigate such effects. The methodologies

have assisted in defining the proposed designation footprint and

enabled various technical experts to undertake assessments relevant

to the project so that the potential effects of the project can be

understood and avoided, remedied or mitigated including through the

use of appropriate management measures.

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40. Section 3.2 of the CDR sets out the indicative alignment design and I

attach the indicative route plan and rail concept drawings as

Appendix A to my evidence.

41. I will now describe the concept design and indicative construction

methodology for each section of the CRL starting at the northern end

(Britomart).

Britomart Station Precinct

42. To suit operational requirements to maintain terminating rail services

within Britomart Station, platforms 1 and 5 will be used to connect the

CRL to the NAL.

43. It is noted that the track along this section of the alignment sits at a

depth of approximately 10m. The method of construction in this

location is expected to be “cut and cover” using diaphragm walls for

watertightness (refer indicative construction methodology below) given

the shallow depth and as the alignment runs through old reclamation fill

hydraulically connected to the Waitemata Harbour.

44. Cut and cover methodologies are typically employed where there is

insufficient/unsuitable ground cover to enable tunnelling without

disproportionate cost and risk.

45. Cut and cover construction techniques involve the installation of two

walls (sheet, soldier or secant piles or diaphragm walls) after which the

ground between is excavated. Depending on the depth of the

excavation, propping may be required across the excavation width at

periodic intervals to enable a safe environment for construction of the

permanent works which may (other than for sheet piles) comprise part

of the permanent works themselves. These vertical walls are required

where the ground is not self-supporting in soils and fill which overlie the

underlying bedrock or where there is insufficient space for an open cut.

It is noted that excavation in the underlying East Coast Bays Formation

(ECBF) bedrock will be required using mechanical excavators. The

ECBF may be supported either with vertical supports in the form of

soldier piles and or local rock bolts and/or shotcrete as required by the

exposed conditions.

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46. ‘Cut-off’ walls will be required to seal groundwater during the temporary

phase of construction for the section of works beneath the CPO

connecting to the existing secant pile walls of Britomart Station. These

cut off walls install a barrier of relatively impermeable clays. This

operation is likely to require temporary closure of Galway Street and

Tyler Street at different times for a period of the order of 1-2 months.

47. The most complex part of the required modifications to Britomart

Station involves underpinning foundations of the CPO building to

remove foundation clashes. This is a very sensitive heritage building

which was modified and strengthened for seismic resistance during

Britomart construction. In developing the structural modifications for

CRL the PA team has involved engineers who designed and oversaw

construction of the structural modifications for Britomart. I consider that

the scale (and risks) of the modifications to the CPO needed for the

CRL are of a similar order as those that were necessary as part of the

original modifications for Britomart Station.

48. The running tunnels pass westward from under the CPO into a cut and

cover structure (refer below) within Queen Street that houses

ventilation equipment required for fire and life safety purposes for

Britomart Station. The alignment then passes into Queen Elizabeth

Square and runs below the existing basement level of the Downtown

Shopping Centre site, generally heading southwest to the corner of

Customs and Albert Street. A feature of this part of the route is the

presence of a reverse curve6 in order to reduce impacts upon adjacent

buildings (namely the Zurich building) and to reduce the operational rail

footprint required through the Downtown Shopping Centre site by

bringing the running tunnels closer together.

49. The locations for construction sites in this area are centred around the

Downtown shopping centre. (Refer Drawings 101 and 102 in

Appendix A attached). These may be in place for 3 to 4 years which is

a similar timeframe to that required to demolish and re-develop the

entire building site.

6 A series of two curves in opposite directions.

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50. The Downtown Shopping centre would be demolished in order for CRL

to be constructed and it naturally becomes a CRL worksite.

51. The most efficient arrangement and use of the Downtown Shopping

Centre as a worksite will be dependent upon the final design and

programme of the re-developed Downtown Shopping Centre.

However, we have developed the NoR designs around the 2008

Westfield development that incorporates a multi-level car parking

basement.

52. There are various means of providing equivalent service access to the

basement level of 21 Queen Street which is currently from Albert Street

during construction by using temporary ramps and decks around the

CRL works.

53. A worksite in Lower Albert Street may be used to serve the Albert

Street cut and cover excavations and the worksite can operate

independently of the Downtown Shopping Centre demolition and re-

development.

54. If the Downtown shopping centre site has been redeveloped then this

would put greater emphasis on and constrain the worksites (particularly

in respect of construction vehicle movements) between Lower Albert

Street and Queen Elizabeth II Square. This is because a benefit of the

Downtown Shopping centre as a worksite during CRL construction (in

terms of traffic movements) comes from linking Queen Elizabeth

Square with Lower Albert Street.

55. The QEII worksite is necessary to support construction works across

Lower Queen Street and the adjacent Britomart modification works and

CPO underpinning.

56. The Worksites are envisaged to be operating up to 24 hours a day 7

days a week. However, not all activities would be undertaken 24/7 and

some activities would only be undertaken between the hours of 7am

and 7pm.

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57. The Worksites can be used to stockpile construction materials and

generally to support construction activities and are anticipated to

include;

(a) General storage of construction materials;

(b) Fuel storage;

(c) Reinforcing steel storage, bending and fixing;

(d) Bentonite and cement for grout and piled wall construction;

(e) Pile casings;

(f) Spoil stockpiling from the excavation. However spoil will be taken

for off-site consented disposal on a daily basis;

(g) Construction plant e.g., piling rigs, mobile cranes, shotcreting

plant, compressors etc;

(h) Maintenance facilities and stores;

(i) Water treatment plant; and

(j) Site offices and workers’ facilities.

58. It is worth noting that larger worksites are less constrained, i.e. are

typically more productive and are less dependent upon external traffic

movements in order to operate efficiently, i.e. to supply labour and

materials and to remove spoil.

59. It is expected that ready batched concrete and shotcrete will be brought

to these worksites as will the material used to backfill the ‘bottom-up’

cut and cover tunnels.

60. Based on the indicative programme and the need to support the Lower

Albert Street cut and cover works, the Downtown site demolition and

reconstruction, and the Queen Elizabeth Square cut and cover tunnels

it is expected that vehicle movements to the site will be a maximum of

around 200 truck movements to site per day – the majority of which

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(say 75%) being associated with off-site spoil removal using rigid trucks

carrying the equivalent of 8m3 of spoil only.

61. It is noted that Ian Clark has assumed more movements (about 25%

more) in his assessment and I consider this is appropriate in order to

provide flexibility to the project programme and robustness of his

assessment.

Albert Street Running Tunnels

62. The CRL alignment needs to have relatively tight curves to connect

Britomart with Albert Street. The radius of the curve is in the order of

130m. The vertical alignment of this section of the route sits at a depth

of approximately 18m below existing ground level along this section of

the route. At the southern end of this section of the CRL (prior to

connecting to the proposed Aotea Station) the alignment needs to pass

above the Orakei Main sewer that runs across Albert Street at Victoria

Street. Passing below (deepening the alignment) would mean

unacceptably high rail gradients in order to connect to the NAL at Mt

Eden.

63. An alignment for concept design was selected to avoid (to the East) the

Bluestone Wall situated at the top of Durham Street (refer below).

64. The horizontal (plan) alignment generally sits within the centre of Albert

Street to enable practicable traffic access to be provided to adjacent

properties during construction (refer Drawings 10, 11 and 12 in

Appendix A and below). The design acknowledges that ground

conditions within Albert Street are variable. Just past the old cliff line

(Customs Street) rockhead (the upper surface of unweathered bedrock)

is near to the surface. By Swanson Street the rockhead level dips and

there is an infilled channel of softer alluvium and weathered bedrock

which extends south to beyond Aotea Station. These softer soils are

one of the main reasons for the two existing retaining walls which are

present in Albert Street, the Bluestone Wall (refer below) and the Lower

Albert Street retaining wall adjacent to Aotea Station. The variable

level of rockhead and limited ground cover are significant risk factors to

mined tunnelling within the lower parts of Albert Street as softer ground

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and less ground cover requires more complicated support and results

in slower tunnelling progress. Along Albert Street the tunnels are

expected to be constructed by cut and cover methods (already

described) and the choice of this method is heavily influenced by the

presence of an old stormwater line within the rail envelope (i.e. the

operational space required for the trains, egress and maintenance

walkways and rail systems). The stormwater line extends for the full

length of Albert Street and may clash with rail alignments between

Customs Street and Victoria Street. As-built records indicate the

stormwater line is in the order of 2m in diameter but there is also an

associated large pump chamber present within Customs Street. There

remains considerable uncertainty with regard to the presence of steel

within the pipeline. Steel may also be present as a result of temporary

works left in the ground outside the permanent lining. This uncertainty,

and the pipe’s position (particularly where it is above the rail alignment

in the northern part of Albert Street) presents significant risks for

tunnelling methods other than cut and cover.

65. The stormwater line was diverted as part of the America’s Cup

programme into Swanson Street. The East-West connection to

Swanson Street would also clash with the rail alignment and so would

be required to be diverted ahead of tunnel construction. This may be

undertaken using a new pipejacked line further to the East of Albert

Street, connecting again at Swanson Street. The presence of the new

line itself then presents a further constraint to rail alignments within

Albert St.

66. Enabling works are required to clear clashes with street furniture and

perhaps remove building canopies where necessary. A critical step is

the provision of guide walls and to clear and divert utility services as

necessary to ensure continuity of supply. These enabling activities will

be undertaken in linear blocks of around 100m long on the east and

west sides of the street in turn. Each block would be expected to take

about 3 weeks to complete. These activities are analogous to a minor

utility trench diversion in the CBD and around 2m deep. The activities

involve installing temporary traffic management, removing any street

furniture and canopies etc that clash, saw-cutting the road surface and

excavation with hand tools to expose services.

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67. Temporary guide wall supports may be installed (sheet piles or a ‘drag-

box’). Once excavated to confirm that piling will not strike any services,

the trench would be backfilled with a sand cement mix (a guide wall for

piling). Fixings for the subsequent installation of the traffic barrier

between the construction zone and the service lane may then be

installed for the construction hoarding. Once the guide wall is

complete, the hoarding and traffic barrier could be erected to isolate the

construction works from the service lane which may be largely serviced

from the northern end of Albert St, although construction access and

egress from the Albert St service lane will be required.

68. The construction of the soldier piles will be undertaken inside the newly

placed construction hoardings using a 65t piling rig achieving around

5m linear progress per day.

69. Once the piles are installed, excavation starting from the North end of

Albert St and working progressively South to install the first level of

propping (between east and west walls) and waling beams that run

longitudinally along the walls would be undertaken.

70. Excavation would proceed in lifts (between each strut level nominally at

4m vertical spacing) serviced from a principal worksite at the North end

of Albert St. The walers would be coupled to the soldier piles and

props would be placed between the walers at the end of each

excavation stage. Excavation would then recommence beneath the

newly placed prop/strut.

71. Once the excavation is at the required level for the rail alignment a

water proofing membrane would be placed and a reinforced concrete

base slab poured. The walls and roof of the cut and cover tunnel would

then be undertaken and the waterproofing membrane sealed around

this. The membrane would be protected and backfilling operations

would commence undertaken in lifts to ensure suitable compaction.

This would involve light excavators (25T 150hp) and earth compactors

(12.5t 150hp)

72. The duration of this activity is likely to be 8-10 months with backfilling

occurring around prop removal over about 16 weeks.

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73. The dimensions of the cut and cover tunnels have been carefully

considered within Albert Street in order to provide vehicle service lanes

of minimum 3m width, and pedestrian walkways of minimum 1.5m

width either side of the central construction trench (and the construction

hoarding) at the ‘tightest’ location in the vicinity of the Durham Street

Bluestone Wall but also on the West side of Albert Street between

Swanson Street and Customs Street. Elsewhere along this section of

Albert Street there is the ability to provide wider walkway widths as

required.

74. The dimensions of the cut and cover trench have been designed in

view of the indicative ground conditions assuming ‘soldier piles’

(although other wall retention methods are possible). This method

uses ‘augers’ to excavate the ground. The resulting cylindrical hole is

replaced with a reinforced concrete column (the ‘pile’) at varying

longitudinal spacing depending upon the ground stiffness. Gaps

between piles (if any) may be filled with shotcrete as the excavation

progresses.

75. Inside the soldier pile walls the permanent rail ‘box’ structure will be

constructed (as described above) which will comprise a waterproofing

membrane, followed by a cast-in situ reinforced concrete structure

which will house the rail envelope. The rail envelope comprises the

area required for the new trains currently being built for the Auckland

rail network and associated space proofing for Over Head Line

Equipment (OHLE) rail services and emergency and maintenance

access provisions.

76. Once the excavation and propping of the trench is complete (prop

spacing and the walls themselves will be designed to suit excavation

plant) the waterproofing and cast-in situ structures may be placed.

This structure may then be backfilled up to the previous street level.

77. Works within Albert Street will be inside a construction hoarding in the

middle of the street. Staging of the works may require secondary

construction access points but it is envisaged that access to the

worksite will primarily be from the North across the Customs Street

intersection. Construction laydown would be possible within the

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hoarding itself and also within the demolished Downtown site and / or

the Lower Albert Street area within the designation footprint.

78. This section of CRL construction is expected to take approximately

24 months including reinstatement to current ground levels.

Aotea Station

79. In terms of the form of Aotea station a series of guiding principles were

developed and these are described in section 3.4 of the CDR. Mr John

Fellows provides further detail in his evidence. Below I describe the

principal constraints around Aotea Station which are a mixture of

subsurface constraints and existing surface ground use constraints.

80. The design constraints include;

(a) The Orakei Main Sewer in Victoria Street which constrains the rail

alignment vertically from the south;

(b) The presence of significant number of utilities running East West

in the pavements of Wellesley and Victoria Street and also North

South under the pavements in Albert Street. It is to be

determined whether the disruption associated with utilities could

be undertaken as enabling works, but the indicative programme

assumes that they are undertaken as part of the main CRL

works;

(c) The stormwater line that impacts the running tunnels in Albert

Street described above;

(d) The Lower Albert Street retaining wall which constrains the

station walls to the East due to the presence of underpinning

piles that were used to strengthen the wall (with an additional

concrete skin) in the 1980s;

(e) A number of buildings (identified by Auckland Transport’s Built

Heritage Expert Bruce Petry) as being of heritage or character

status;

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(f) The ground conditions;

(g) Access to properties on the East of Albert Street via Lower Albert

Street and at surface level;

(h) Access to the properties on the West side of Albert Street; and

(i) Traffic and pedestrian movements across Wellesley and Victoria

Streets.

81. Previously the NoR had assumed that utilities would be diverted prior to

CRL allowing a quadrant methodology at the road intersections. A

changed construction methodology from that originally described in the

ITA has been developed allowing concurrent utility diversions would

require the closure of the major intersections of Wellesley and Victoria

Streets. This facilitates a much less encumbered worksite and

programme benefits for CRL. It is also preferable from a risk

perspective in that the Aotea station top slab can be constructed

monolithically7 across the principal East West span providing structural

durability.

82. The Station requires cut and cover construction largely because of its

shallow depth, the adverse ground conditions and the width of the

station box itself (as described by John Fellows).

83. It is assumed that ‘top-down’ construction method may be used

(although bottom up construction using propping and temporary traffic

decks are considered feasible). The ‘top-down’ method is a variation of

cut and cover tunnelling, again using propped diaphragm walls or

secant/soldier pile walls through soft ground to penetrate the bedrock

below. It is used where wall deflections are particularly critical or where

the surface must be returned to its former use as soon as possible (e.g.

the busy road intersection).

84. Once the walls have been installed, construction of the station ‘roof’

can commence. The installation of the roof top slab effectively stiffens

the wall and minimises deflections. Upon completion of the roof,

7 A single concrete pour.

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subsequent excavation activities can be undertaken beneath the roof

slab from pre-designated access points through the roof slab.

85. These will include construction of the concourse and base slabs and

the excavation of the intervening material. It is expected that this can

be achieved with excavators in the softer soils and possibly

roadheaders in the ECBF rock.

86. In terms of a construction sequence this is envisaged to comprise the

following stages.

87. The main construction site for the Aotea Station will be established

adjacent to the entrance at Wellesley Street. The buildings at this

location will be demolished using large hydraulic excavators, say a CAT

336E or similar (200kW motor). This activity would be expected to

take around 6-12 weeks.

(a) This area will be the main worksite for Aotea station and will

remain active throughout construction of CRL. This will serve to

remove excavation spoil from the site, receive and stockpile

construction materials and provide construction facilities for

construction staff. The Worksites are envisaged to be operating

up to 24 hours a day 7 days a week depending upon the shift

pattern adopted. It is assumed for the indicative programme that

the bulk of production occurs during a six day working week;

(b) Elements stored on site and features of the site are anticipated to

include:

(i) General storage of construction materials;

(ii) Fuel storage;

(iii) Reinforcing steel storage, bending and fixing;

(iv) Bentonite and cement for grout and piled wall construction;

(v) Pile casings;

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(vi) Spoil stockpiling from the excavation. However spoil will be

taken for off-site consented disposal on a daily basis;

(vii) Construction plant e.g., piling rigs, mobile cranes,

shotcreting plant, compressors etc.;

(viii) Station fitout materials and major plant;

(ix) Maintenance facilities and stores;

(x) Water treatment plant; and

(xi) Site offices and workers’ facilities.

88. The construction sequence for Aotea Station is staged around access

to the Crowne Plaza Hotel and its car park (i.e., around the existing

entrance way circled above). Wellesley St will be closed for a period of

around 12 months to enable the utility diversion, and piling activities

and construction of the roof of the station box. Whilst it is closed

access to the hotel at surface and Lower Albert St level will be from the

North.

89. The station box walls will be on the West side of the underpinned

Lower Albert St wall. This will require removal of the wall down to the

level of the existing Lower Albert St road level prior to piling. Any

existing decking planks on the Crowne Plaza side would be removed.

The ground on the West side of the wall would be removed and the wall

demolished progressively using a combination of mechanical

excavators and hydro-demolition to reduce noise to expose the existing

1200 diameter piles under the wall.

90. A steel piling deck and frame connected to the existing piles may then

be installed to enable the new 1050 diameter piles for Aotea Station

box to be installed.

91. Contiguous piled walls through the soft material at surface into bedrock

will be made. The piles are assumed to be between 15-20m long and

900-1050 thick, installed using a 65T or 90T piling rig (400-500kW

motors). Smaller diameter soldier piles maybe required for utility

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services that remain in place during construction. The piling duration is

expected to be of the order of 12-16 weeks

92. Once the piles are installed installation of the roof slab can commence.

Once the station roof slab is in place this will largely separate

construction noise below from surface activities. Based on the

evidence of Mr Clark it is acceptable that Wellesley Street intersection

may be completely closed and used as a worksite for an estimated

period of approximately 12 months. Access to and from Crowne Plaza

at surface level and from the lower Albert Street service level can be

provided from Victoria Street during this period. In a similar way the

vehicle access to Skycity (car-parking and services access) from Albert

Street can be maintained.

93. Again based on the analysis undertaken by Mr Clark the Victoria Street

intersection may also be completely closed (though this cannot be done

unless the Wellesley Street intersection is functioning), and used as a

worksite. Access to Crowne Plaza Hotel and Sky City at surface level

would be from Wellesley Street. The Lower Albert Street service level

can be accessed from Wellesley Street. The period of closure of

Victoria Street intersection is expected to be longer at approximately

16-18 months given a greater extent of construction undertaken during

that phase.

94. Excavations and installation of concourse and base slabs would occur

largely beneath the station upper slab serviced from the main worksite.

The estimated duration of the civil works at Aotea Station is around four

years with a further year for fitting out of mechanical and electrical

systems and architectural finishings and system commissioning. Test

running and trial running of the new CRL link may take a further ten

months prior to opening of CRL.

95. The impacts upon the local road network have been assessed by Ian

Clark and are addressed in his evidence. It is assumed that ready

mixed concrete and shotcrete will be supplied to site. Based on the

indicative programme it is expected that vehicle movements will be a

maximum of around 150 truck movements to site per day (with

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corresponding numbers returning from site) comprising of spoil

removal, material delivery peaking during major concrete pours.

TBM Running Tunnels

96. From Aotea Station through to Newton Station, via Karangahape

Station, running tunnels are envisaged to be constructed using an

earth pressure balance TBM (I describe this later in my evidence). The

length of this section is approximately 2.1km with a minimum depth to

track of 15m and a maximum depth to track of 40m.

97. There is an overall rise of approximately 45m between Aotea and the

NAL. Key considerations which have influenced the design and

alignment of the tunnels that connect the stations and the depth of the

stations are the maximum gradients for operations and the need to

provide appropriate clearance beneath the Central Motorway Junction

structure.

98. The indicative tunnel design is detailed at section 3.3 of the CDR. The

concept design for the two tunnels has been developed to meet the key

technical parameters introduced earlier in my evidence (at paragraph

34) along with the list introduced at section 2.1 of the CDR.

99. An appropriate tunnel cross section provides for the kinematic

envelope8 of the new trains currently being built for the Auckland rail

network and associated space proofing for Over Head Line Equipment

(OHLE). A non-ballasted concrete track slab is proposed largely to

reduce track maintenance requirements. In the vicinity of some

sensitive vibration sensitive receivers track isolation measures may be

necessary as described in Mr James Whitlock’s evidence.

100. Egress and emergency access is provided for on the insides of the rail

tunnels. The minimum width of the egress walkway is proposed to be

850mm and this is subject to confirmation with the New Zealand Fire

Services. Cross passages between the running tunnels are proposed

at spacings to be confirmed with the New Zealand Fire Services.

8 A kinematic envelope is the design space occupied by a rail vehicle when in motion. It is

developed from considerations of speed, rail curvature and rail cant (superelevation).

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101. As stated in paragraph 88 of my evidence, the running tunnels

connecting Newton Station to Aotea Station are assumed to be

constructed with an ‘earth pressure balance’ tunnel boring machine

(TBM) with an outer diameter of around 7m. The TBM can be

described as a tunnelling ‘factory’. The key components are the

cutterhead, the working chamber (plenum chamber, a pressure

chamber also used for ‘mixing’ and conditioning the spoil as required),

the screw conveyor and the steel shield which contains the TBM

hydraulic plant, precast concrete lining erection equipment, and

construction personnel. Thrust rams bearing on pre-cast concrete

lining rings (each ring comprising several segments) force the rotating

cutter head and the associated cutting tools into the ground.

102. The characteristics of the spoil reflect both the in-situ properties of the

ground, the mechanical excavation process (including any spoil

conditioning, refer below) and the presence of groundwater. I note that

groundwater extraction will be the subject of a subsequent resource

consent process.

103. It is anticipated that the substantial majority of spoil arising from the

driven tunnels will be East Coast Bays Formation sandstone and

siltstone. I note that spoil disposal sites selection may be the subject of

a subsequent resource consent process.

104. The pre-cast segmental lining will be made of high quality durable

reinforced concrete. Joints between the pre-cast elements

incorporating durable compression gaskets would provide the tunnel

lining with a suitable level of watertightness.

105. The pre-cast segmental lining would be erected within the tail shield of

the TBM and connected with temporary bolts during construction. The

cutter head excavates at a diameter greater than that necessary for

passage of the shield and erection of the permanent works lining. The

resulting annulus between the outside of the segments and the

excavation is filled with a cementitious grout.

106. Construction of cross passages will require that the pre-cast lining is

‘broken-out’ and additional mining operations undertaken to form the

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space required. The mining will likely be undertaken with track-

mounted roadheaders or hydraulic hammers for excavation. The

current indicative construction methodology therefore assumes that

cross passage openings in the segmental lining would be constructed

using steel segments which would be a similar thickness to the

concrete segments in order to fit the TBM. Also the tunnel bores are

separated a minimum of 0.5 diameters (3.5m) to maintain them within

the Vincent Street road corridor. This tunnel separation is maintained

within the road reserve adjacent Federal Street and along Vincent

Street before the tunnel separation is increased in the approaches to

Karangahape Road station. (Beyond Karangahape Road Station the

tunnels are brought closer together beneath Ian McKinnon drive before

splaying once more in the approaches to Newton Station.)

107. Experience from Project Rosedale and Project Hobson has

demonstrated the suitability of Earth Pressure Balance TBM (EPBM)

tunnelling techniques in Auckland geology with minimal environmental

effects, e.g., vibration and settlement. A larger EPBM will soon

commence tunnelling for the Waterview Connection project.

108. TBM construction sequence peak vibration and potential re-radiated

noise occurs during the excavation of the ground. The duration of this

peak vibration and noise is dependent upon the length of each pre-cast

concrete segment which is installed progressively as the tunnel is

constructed to form ‘rings’. Assuming a 1.5m long segment length,

excavation would typically take about 40 minutes per ‘shove’ but may

be up to an hour.

109. The actual tunnel production rate is a complex mix of existing physical

conditions, design and engineering constraints and human factors.

For the purposes of developing a reasonably conservative programme

it is assumed that the duration to tunnel 100m with the TBM may take

up to 2 weeks.

110. The TBM running tunnels will be accessed from the worksite at the NAL

connection (southern end of the CRL). This area will also house the

spoil handling facilities with tunnel spoil being removed using road

trucks. It is recognised that truck removal is the most likely and

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practicable means of spoil removal. It will also generate the most

adverse effects and therefore has been adopted for the assessment of

the NoR.

111. The indicative site layout shows a configuration using conveyors (also

adopted for Waterview Connection). Rail locomotives could also be

used, particularly as the mined platform tunnels (refer below) provide

the opportunity for sidings to allow multiple locomotives to be used.

Some of the curve radii behind the TBM may also favour the adoption

of rail locomotives but this choice is really up to the constructor.

112. Segments for the permanent tunnel lining and the grout used to fill the

gap between the lining and the ground would also be supplied from the

NAL connection worksite (refer paragraph 133).

113. Materials and labour would be supplied to the TBM using either tracked

vehicles (with temporary invert slabs) or rail locomotives.

114. The concrete segments of the lining would be ‘pre-cast’ in a specialist

facility off-site with the segments brought to the site and stored.

115. The worksite has been configured notionally to contain suitable areas

to stockpile all of the materials necessary to support the tunnel

production with daily deliveries expected. The majority of vehicle

movements to and from the site would be expected to be associated

with off-site spoil disposal (as discussed below).

Karangahape and Newton Stations

116. My colleague Mr John Fellows will describes the station designs in

more detail in his evidence. However, I provide below a brief summary

to provide some context. The form of Karangahape Road and Newton

Station has been influenced by the surface constraints, the depth of the

alignment and the ground conditions, in particular the characteristics of

the weak rock within which the majority of CRL will be constructed.

117. At both Newton and Karangahape Road there are a number of Heritage

Buildings surrounding the stations. These buildings will experience

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ground movement (settlement) as a result of CRL and the effects upon

the buildings are discussed in the evidence of Mr Craig Stevenson.

118. At Karangahape Road the platform level is around 32m from surface

and the station is designed around a vertical transportation concept

using escalators. The platform tunnels are accessed from tunnels

emanating from a central concourse which in turn is accessed from

inclined escalator shafts which connect to surface. There is a main

entrance in Beresford Square and a secondary entrance in Mercury

Lane.

119. During construction the Beresford Square entrance will support piling

and excavation operations and the shaft may also be used to access

the platform tunnels. Once the tunnelling is complete this shaft may be

used to effect the fitout of the station.

120. Building demolition is required for the Supper Club using large

hydraulic excavators, for example a CAT 336E as part of the

excavation works within the piled walls required for the entrance.

121. Contiguous piled walls are assumed through the soft material at

surface into bedrock. The piles are assumed to be around 18m long

and 900 thick installed using a 65T piling rig (400kW motor). The

duration of piling would be expected to last for around 8-12 weeks

depending upon the final depth and extent of the entrance shaft along

Beresford St. Peak noise and vibration would be expected to be

greatest whilst the piling rig is in front of the property which would

progress at an average rate of 5 linear metres per day.

122. Shaft excavation would be assumed to use a similar excavator as was

used to clear the site.

123. Depending upon the final design of the entrance a primary lining of

shotcrete and rock nails may be placed as the excavation proceeds

beneath the piles.

124. The permanent lining could be cast in lifts from the base of the shaft.

This would be supplied by ready mix concrete trucks.

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125. During construction the Mercury Lane entrance in addition to

construction of the shaft would be used to remove the majority of the

platform tunnel spoil (handled at the adjacent construction site).

During construction the shaft may be used to access the platform

tunnels.

126. Building demolition is required for several buildings in the area using

large hydraulic excavators, for example a CAT 336E.

127. Contiguous piled walls are assumed through the soft material at

surface into bedrock. The piles are assumed to be around 18m long

and 900 thick installed using a 65T piling rig (400kW motor). The

duration of piling would be expected to last for around 12-16 weeks.

128. Shaft excavation would be assumed to use a similar excavator as was

used to clear the site. It would be expected given the depth of the shaft

a gantry crane would be used to hoist a skip from the shaft. The skip

would discharge onto a loading platform where a front end loader would

(say CAT 938K, 130kW) be used to load haulage trucks for off-site

disposal.

129. Depending upon the final design of the entrance a primary lining of

shotcrete and rock nails may be placed as the excavation proceeds

beneath the piles.

130. The permanent lining could be cast in lifts from the base of the shaft.

This would be supplied by ready mix concrete trucks.

131. At Newton Station the platform depth is about 40m from surface. Given

the transit times to surface, and also the increased spatial requirements

arising from escalator concepts, the design has assumed that lifts will

be used instead of escalators. From the central lift concourse the

platform tunnels are accessed from connecting tunnels.

132. The location of Newton Station has been designed to avoid the

Watercare reservoir located to the east of Symonds Street, and the

alignment was moved as far to the west as other geometric constraints

would allow and still achieve the Mt Eden connections described below.

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133. The platform tunnels for both stations are around 12m in diameter

which is spatially adequate for the trackway (the trains’ kinematic

envelope) all services (overhead and to the sides) and the required

platform width.

134. There is not a lot of experience in large diameter tunnel excavations in

Auckland’s geology, and the largest constructed to date is around 8m.

There are of course larger tunnels within New Zealand, such as the

Mt Victoria Tunnel, the Kaimai Tunnel, and the Terrace Tunnels and

more recently the Johnstones Hill Tunnels - all in different geology.

135. The ECBF forms the bedrock of Auckland which is an intrinsically

complex sedimentary rock. The intrinsic complexity arises from the

depositional environment of the rock, which was often chaotic. When

excavated the rock separates along bedding planes but also along

joints shears and faults which are present to a greater or lesser degree.

136. It is a weak rock meaning that it has a compressive strength typically

an order of magnitude (ten times less than) typical concrete. However,

given the bedding plane discontinuities and other potential separation

planes from faults and joints etc., it has all the complexities of stronger

rocks, i.e., that blocks can fall out under gravity which presents health

and safety risks to miners.

137. From my experience overseas with caverns (up to 25m in diameter) I

have experienced the difficulties of constructing larger diameter tunnels

when the ground strength is low, as is the case here. Smaller diameter

tunnels are simpler to construct in terms of staging, and are less risky

because the demands placed upon the ground are reduced.

Minimising risk is a key driver behind the reduced size of the platform

tunnels of the Concept Design as compared to the APB&B Concept

Design.

138. The ECBF characteristics also influence the separation distance

between tunnels, known as the pillar width, i.e. the pillar of ground

remaining between tunnels.

139. In programme terms, the platform tunnels are scheduled to be

completed (in terms of temporary lining at least) prior to the TBM

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arrival. This avoids the risks inherent in breaking out temporary linings

and enlarging the tunnels from the smaller TBM diameter circa 7m to

the platform tunnel size circa 12m. Again I have experience of both

methods and confirm that the adopted methodology is superior from a

safety in design perspective.

140. There are two shafts for each station at Karangahape Road and

Newton station, comprising the main entrance shaft and a secondary

egress shaft. The secondary shaft is provided for fire life safety

purposes but also to discharge vitiated air from the station. (Air quality

effects are discussed in the evidence of Camilla Borger). Where

practicable, underground stations have ventilation plants that discharge

at surface at both ends. (These design aspects are described by John

Fellows in his evidence).

141. Labour, material and spoil will be required to be supplied and removed

from each shaft location.

142. The Dundonald St shaft when operational will be a secondary egress

shaft and plant room area for the station. During construction the shaft

may be used to access the platform tunnels but these may also be

accessed from the Mt Eden side which may be preferable given the

larger scale of the worksite and its ability to manage greater traffic

movements associated with spoil.

143. Excavation plant and shaft excavation concepts are similar to that

described for Karangahape Station above.

144. It is expected that ready batched concrete and shotcrete will be brought

to site.

145. It has been assumed in the indicative methodology for Karangahape

Road Station that construction access to the platform tunnels will be

from the secondary shaft in Mercury Lane, which will be configured to

handle the majority of the tunnel spoil. (Refer Drawing 152 in

Appendix A). This enables earlier access to the UP main platform

tunnel and therefore is likely to provide more construction programme

flexibility. It is noted that even with reduced widths the platform tunnel

excavations are significant undertakings requiring careful construction

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management. An indicative worksite layout is attached in Appendix A.

The site is configured around a gantry crane and skip hoist supplying a

spoil handling yard which in turn supplies dump trucks that remove

spoil from site.

146. At Newton Station the Dundonald Street shaft (refer Drawing 201 in

Appendix A) is constrained in terms of road access. The main shaft

excavation will benefit from the carpark (which I understand is

controlled by Auckland Transport) adjacent to the Watercare reservoirs

in terms of extended construction laydown and spoil handling areas.

147. Mr Clark has assessed the traffic effects of this for each shaft location

in his evidence but initial estimates are that both station locations may

at peak experience truck movements of around 100 trucks per day.

148. The Worksites are envisaged to be operating up to 24 hours a day 7

days a week. It is assumed for the indicative programme that the bulk

of production occurs during a six day working week.

149. Elements stored on site and features of the site are anticipated to

include:

(a) General storage of construction materials;

(b) Fuel storage;

(c) Reinforcing steel storage, bending and fixing;

(d) Bentonite and cement for grout and piled wall construction;

(e) Pile casings;

(f) Station fitout materials and major plant;

(g) Spoil stockpiling from the excavation. However spoil will be taken

for off-site consented disposal on a daily basis;

(h) Construction plant e.g., piling rigs, mobile cranes, shotcreting

plant, compressors etc.;

(i) Water treatment plant;

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(j) Maintenance facilities and stores; and

(k) Site offices and workers’ facilities.

150. The shaft walls will be supported in a similar manner to the cut and

cover tunnels excavations described above, i.e., using piles or

diaphragm wall panels. The walls may either be for the full depth of the

shaft or sufficiently deep into rock to enable a safe working

environment during excavation. Previous projects in Auckland (Hobson

and Rosedale) for example have a collar of piles through the soft

overlying sediments with the rock walls supported with rockbolts and

mesh down to the required level. These shafts have extended to

similar depths. Ultimately shaft walls will be made sufficiently

watertight by placing internal reinforced concrete structures with

external waterproofing membranes to minimise impacts upon

maintenance during operation.

151. The platform tunnels may be excavated using hydraulic excavation

plant and the ground stabilised as the excavation proceeds using

rockbolts and or shotcrete installed close to the shaft or tunnel face.

The 12m diameter tunnels may require top headings and benching as

opposed to a full face excavation. This is to suit the reach of

excavation plant and also as the heading operation is the most

important phase of tunnel construction, i.e., when the tunnel heading is

stable, the bench can be removed relatively easily and quickly.

152. Permanent support for the platform tunnels may comprise a cast in-situ

reinforced concrete lining with a waterproofing membrane erected

before concrete placement that would enable the structures to be

designed to resist water ingress.

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Southern Tunnel Portals and NAL Connection

153. From Newton Station the CRL rail geometry is particularly constrained

with tight horizontal curves and steep vertical gradients and little

flexibility given the need to connect to the existing NAL infrastructure.

The existing NAL rail infrastructure needs modification in terms of re-

grading (raising and lowering) of rail track and grade separation of two

local roads Normanby Road and Porters Avenue.

154. The two lines (the UP and DOWN CRL mainlines, or ‘mains’, the

railtracks) need to split to provide east and west facing links. This

requires ‘turnouts’ trackwork which widen the rail envelope (refer

above) and an underground ‘flat’ crossover junction.

155. The existing NAL tracks will be repositioned to allow the CRL tracks to

rise up between the NAL tracks. There will be temporary track

alignments (and some temporary closures) to allow for operation of the

NAL during construction of the permanent structures.

156. The topography is at its highest point around Newton Station and drops

off sharply to the South in the vicinity of the NAL where the topography

is gentler. The landforms are of course heavily influenced by the

underlying geology described later.

157. A combination of mined tunnels, shafts, cut and cover tunnels and

trenches are required here. There are also extensive surface works

required particularly at the Southern extent of the scheme including

excavations and retaining walls, service diversions, local roadworks

and road bridge modifications (Mt Eden) and road bridge installation for

road rail grade separation (Normanby Road and Porters Avenue) and

footbridge installation (Ngahura Street)

158. In 2008 Project Clearwater installed a large diameter (circa 2m

diameter) stormwater main connecting to a shaft in Flower Street and

running down Nikau Street to Ruru Street. The alignment of this

stormwater utility (installed using pipejacking equipment) clashes at rail

level across both CRL mainlines requiring diversion. The presence of

the shaft in Flower Street also complicates tunnelling for the UP main in

this area.

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159. At this location rockhead drops away sharply to the south (mirroring the

topography) and weathered rocks and alluvium come closer to the top

of the CRL tunnels which increases the need for tunnel temporary

supports and the overall risks of tunnelling.

160. By the junction with Nikau Street and Flower Street the CRL UP main

tunnel would need to be around 14m diameter. This is a relatively large

diameter for a weak rock such as the East Coast Bay Formation

requiring careful design and construction monitoring. As the tracks

diverge to the South the tunnel diameters would increase accordingly

and the combination of lack of ground cover and weakening ground

above makes mined tunnelling much more difficult.

161. These adverse geological conditions are risk factors to the CRL project

and in combination with the large tunnel diameters required has

influenced the preferred choice for the NoR of cut and cover methods in

this area.

162. The complexity and extent of the rail geometry required and the shallow

and variable ground cover has driven the Concept Design towards cut

and cover tunnels and therefore the need to acquire the properties at

this location. The final position of the mined tunnel cut and cover

portals (i.e., where the tunnel headwall sits in the temporary

construction state) is a matter of further ground investigation, more

detailed design, cost and risk analysis.

163. The UP main West link and the DOWN main East link cross each other

in the centre of the block of properties bounded by Ruru, Nikau,

Shaddock Street and Flower Street. This flat junction would require its

own shaft around 15m deep, linked either side with cut and cover

tunnels sized for individual rail tunnels.

164. Around Shaddock and Ruru Street the geology at surface becomes

basalt from Mt Eden’s volcano. Aurecon’s ground investigation team,

have interpreted, based on ground investigations undertaken to date for

CRL and elsewhere in Auckland, that basalt flows have infilled old

valleys and so may extend beneath the excavations required for CRL in

this area. (Refer Figure 2 below)

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165. Basalt is a hard rock and can be broken mechanically. However, in my

experience of blasting operations overseas it is a much more effective

method in terms of time of excavation than say hydraulic breakers.

Figure 2 Interpreted extent of basalt around Mt Eden Station

166. Trench excavation in basalt at the NAL may be up to 100m long, 10-

12m deep and 7m wide at the base. Blasting would involve the

operation of drilling rigs to drill blast holes. Decked charges with

instantaneous charge weight of between 1-3kg of bulk emulsion

explosive may be trialed to develop site specific attenuation constants.

One of the reasons to adopt blasting in my opinion is that effective

blasting may reduce the period of disturbance (in comparison with

multiple rockbreakers) with very limited risks.

167. Blasting may take advantage of the strength of the basalt to blast in

vertical panels. Fragmentation, i.e., the size of the rock fragments

resulting from the blast may be a secondary consideration to creating

the trench excavations through the basalt flows. In any event it is

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anticipated that post blasting, large hydraulic breakers and mechanical

excavators will be required to remove the broken basalt. This will be up

to 100T with 400kW motors.

168. I will describe the surface works and staging for CRL connection to the

NAL in two halves, East and West. However, it is worth noting that by

the time CRL will be constructed the NAL will be an electrified railway.

Therefore, not only does construction have to consider the safety risks

associated with physical clashes with running trains but also the need

to avoid electrical overhead lines and the risks of construction plant

striking those overhead lines.

169. For the East facing links (EFL) the NAL is assumed to be staged in

three phases. However, before construction begins site enabling works

will be required. These include:

(a) Erection of construction site fences along the rail corridor;

(b) Service protection or diversion works at Mount Eden Road,

Normanby Road and along Boston Road; and

(c) Clearance and levelling of the site along the north side of the rail

corridor.

170. Phase 1 NAL slewed to North to enable installation of retaining walls

and track lowering to the South. Normanby Road would be closed for a

period of around 6 months during this phase as it is not possible to

maintain a level crossing given that the NAL must be lowered around

2m. Construction of the road over rail bridge (grade separation)

benefits from the lowering of the NAL and the necessary modifications

to the local road connections required to raise the road level of the

order of 2m are reduced.

171. Mt Eden Road would not be modified by CRL construction works during

the period that Normanby Road is closed. The traffic effects of this

have been addressed by Mr Clark in his evidence.

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172. It is worth noting that Normanby Road level crossing has a high priority

for grade separation on safety grounds irrespective of CRL based on

assessments by Auckland Transport and KiwiRail.

173. Phase 2 NAL moved back to the South to the newly re-graded

alignment to enable excavations and retaining structures for CRL East

facing links. The NAL DOWN main has a temporary alignment at this

stage. The benefit of this staging step is that the constructor has a

worksite discrete from the electrified rail corridor adjacent to the South

and may construct the walls and excavations necessary for CRL to the

North.

174. During this phase modifications to the northern abutment of Mt Eden

Bridge can be made which will involve piling adjacent to the bridge to

replace existing ground anchors, the staged removal of the ground

anchors and the installation of the CRL cut and cover tunnels.

175. Phase 3 The NAL Down main is moved onto to its permanent

alignment above the CRL tracks. Excavation over a 100m stretch of

track will be required requiring the temporary closure of the NAL at the

eastern extent of the project for the section of line that merges the NAL

and CRL to tie-in with existing grades. It would be expected that this

would be undertaken during a Christmas ‘block of line’ over a period of

a few weeks.

176. For the West Facing Links the grade separation of Porters Avenue

requires the lowering of the both NAL mainlines and the raising of

Porters avenue. In the indicative methodology this requires two

temporary alignments for the NAL DOWN main and one temporary

alignment for the CRL UP main and the closure of Porters Avenue for

between 2 and 3 years. Before the main construction begins site

enabling works will be required. These include:

(a) Erection of construction site fences along the rail corridor;

(b) Service protection or diversion works at Porters Avenue, Fenton

Street and Haultain Street;

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(c) Clearance and levelling of the site along both sides of the rail

corridor; and

(d) Development of temporary property accesses along Fenton

Street, Haultain Street and Porters Avenue.

177. Phase 1 In the first stage the balconies on the South side of 3 Ngahura

Street would need to be removed to construct the outer southern

retained walls required to lower the NAL. The outer walls that enable

NAL lowering and the Northern inner wall and the bridging structures

which enable the NAL DOWN main to pass over the CRL west facing

links and the inner southern walls for the CRL can be constructed.

Porters Avenue is closed to traffic. A series of weekend block of line

closures are likely to be required as the piles for the inner wall gets

closer to the NAL alignment.

178. Phase 2 In the second stage the tracks are slewed to the North and

South. The northern inner walls can be constructed and excavation

required for CRL within the rail corridor can be undertaken with access

from the CRL cut and cover tunnels.

179. Phase 3 The NAL up main is placed on its permanent alignment within

the inner and outer retaining walls.

180. Phase 4. In the fourth and final stage excavation to enable the NAL

DOWN mains to be placed on the lowered permanent alignment a

Christmas period block of line will be necessary to minimise disruption.

The reinstatement of Fenton and Haultain Streets can occur and the

road over railbridge at Porters Avenue can also be re-instated.

181. The temporary construction site at the NAL connection between Ruru

Street and Ngahura Street will likely be the main work site for the TBM

assembly and launch and also serve to provide the stockpiling for rail

fitout. (Refer Drawing 220 in Appendix A).

182. It will house the main site offices (likely to be a number of offices) and

associated vehicle parking. It may also be used to store large pre-cast

or fabricated elements which may not be able to be stored at the

individual site storage areas due to size restraints.

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183. The number of truck movements at the worksite are likely to be

dominated by the excavations for the cut and cover tunnels. Including

the TBM spoil activities (refer below) and assuming that these coincide

with the cut and cover activities this may be up to 400 truck movements

exiting the site per day. It is noted that this estimate has several

variables, i.e., the excavation production rate, the number of active

excavation fronts, the bulking factor (i.e., how much greater in volume

the excavated spoil is after excavation) and the capacity of the trucks

used to remove the spoil.

184. It is anticipated that TBM-excavated material will be disposed off site

and allowing for the bulking which happens when ground is excavated

(a bulking factor of 1.8) the TBM tunnels may generate up to

210,000m3 of spoil.

185. For the purposes of illustrating the sensitivity of programme

assumptions in relation to truck movements If the TBM achieves a peak

advance rate of 10 rings per shift, 30m per day for a week, (180m a

week) this would result in the need to remove around 11,500m3 per

week if all spoil were removed from site. In practise it is common to

stockpile spoil on site unless continuous truck access can be provided.

However, assuming spoil trucks operate for 12 hours per day and truck

and trailer units can carry up to 15m3 of spoil per load, this would

require around 10-12 truck trips per hour in each direction.

186. All trucks would enter and leave the worksite via dedicated and secure

access points. From the worksite, the route to the disposal site will

depend on the most appropriate location to receive this material at the

time when construction commences. Mr Clark discusses this in his

evidence.

187. The Worksite is envisaged to be operable up to 24 hours a day 7 days

a week (although tunnelling production is assumed to be over 11 shifts

and 6 days a week) and up to 20 hours per day. A 20 hour per day

TBM operation accounts for two 10 hour work shifts and allows for

maintenance to be carried out in the remaining 4 hours if required.

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188. The segments would be constructed off-site in an existing pre-cast

concrete facility and then transported to site to be stockpiled.

189. Elements stored on site and features of the site are anticipated to

include:

(a) General storage of construction materials;

(b) Fuel storage;

(c) Reinforcing steel storage, bending and fixing;

(d) Bentonite and cement for grout and piled wall construction;

(e) Pile casings;

(f) Spoil stockpiling from the excavation. However spoil will be taken

for off-site consented disposal on a daily basis;

(g) Construction plant e.g., piling rigs, mobile cranes, shotcreting

plant, compressors etc.;

(h) Precast concrete TBM lining segments;

(i) Rail fitout materials;

(j) Maintenance facilities and stores; and

(k) Site offices and workers’ facilities.

The Indicative Construction Programme

190. As for any construction programme it is important to understand that

not all construction activities can overlap, i.e., the commencement of

some activities in a construction programme may depend upon the

completion of others and delays in one activity may therefore introduce

start-up delays in subsequent activities.

191. In general, the underground civil construction precedes mechanical and

electrical systems installation which precedes commissioning and

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testing of the rail safety systems which then enable the railway to

commence operation.

192. Briefly, the indicative construction methodology anticipates a 5 to 6

year construction timeframe and I consider this to be a reasonable and

feasible programme for the works anticipated. I consider the key

features and interdependencies of the programme to include:

(a) Preparation of the Construction Environmental Management Plan

(CEMP);

(b) Utility replacements where necessary and diversions as enabling

works (This may precede the main construction works for CRL

so as to remove programme risks);

(c) Mobilisation of construction staff and plant;

(d) Preparation of worksites including property demolition particularly

at Mt Eden where the logistics to support the linear TBM

tunnelling operation are to be established;

(e) Shaft excavation and support rates for mining platform tunnels at

Newton and Karangahape Road stations;

(f) Sequencing of Mt Eden cut and cover construction, i.e., wall

installation sequence and excavation rates in basalt;

(g) Tunnelling production rates (sequential excavation and support)

mined stations. It is important that the ‘up-main’ platform tunnel

in Newton Station be completed prior to arrival of the TBM;

(h) TBM delivery and commissioning (around 18 months) during

which time the NAL worksite will be focussed on preparing the

logistical support for the TBM and construction of the UP MAIN

platform tunnel in Newton Station. The TBM tunnelling when in

production is in relatively short lengths of less than 1km between

stations and around 3.2km in total;

(i) Sequencing of Albert Street intersections and construction of

Aotea Station, i.e., wall installation sequence and excavation

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rates. Key considerations have included the diversion of utilities

and management of traffic impacts during construction on the

local road network, maintaining appropriate public transport

service levels, providing vehicular and pedestrian access to

buildings in the CBD (refer to the evidence of Mr Ian Clark for a

full understanding of the impacts of construction on transport);

(j) Station and rail systems fit out and commissioning of mechanical

and electrical systems; and

(k) Systems integration and rail test running.

193. The concept design anticipates that the longest duration civil

construction activity is Aotea Station. In simple terms this means that it

is expected that the overall programme for opening CRL would depend

upon completion of the civil works within Aotea Station.

194. The main points affecting the indicative construction methodology in

relation to the Albert Street and Aotea Station area (refer diagram) are:

(a) The complete closure of Wellesley Street (11-12 months)

undertaken first and reinstated;

(b) The complete closure of Victoria Street (16-18 months)

undertaken second and re-instated;

(c) A full or partial closure of Customs Street for a period of

approximately 6-9 months (undertaken last); and

(d) The remaining section of running tunnel within Albert Street is

undertaken concurrently with the Wellesley and Victoria Street

Intersection works (24 months).

195. Overall, I consider the concept design and the indicative construction

methodology are reasonably and appropriately conservative.

Response to submissions

196. I have reviewed all submissions that relate to the CRL Concept Design,

in particular those matters that relate to the design and construction of

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the CRL. I have grouped these submissions according to the concerns

raised, and address each concern in the sub-headings below. Under

each sub-heading I also indicate which submitters raised that concern.

197. In response to submissions, there are some minor design clarifications

and methodology modifications to those indicated by the CDR that are

feasible within the NoR ‘envelope’ of land requirement and effects as

described below.

198. The majority of concerns arise from property access and proximity

effects from construction. There are sixteen submissions that I have

specifically addressed9.

Disruption Around Britomart Station

199. I have met representatives of the Tenham Body Corporate (116)who

were concerned about the construction impacts and in particular as it

pertains to my evidence the duration of closure of Tyler St and access

generally to their property. The indicative impacts are outlined in

paragraph 46 above whilst pedestrian access will be possible at all

times vehicle access will be disrupted temporarily.

Cut and cover construction within Albert Street

200. Foodstuffs (118) is concerned about the potential disruption to its store

in Queen Street which is serviced from Albert Street. It is also

concerned about the East/West movement of pedestrians at Swanson

Street. The Albert Street methodology was developed specifically to

maintain serviceable access to all the properties adjoining Albert Street.

A specific consideration was the separation of the majority construction

traffic movements from the general traffic in the service lanes within

Albert Street. I describe this in paragraph 63 above. Mr Clark in his

evidence describes how traffic flows will be affected by the indicative

construction methodology. As for East/West pedestrian movements 9 Submissions: PAL Properties (28) Tenham Body Corporate (116) Foodstuffs (118) Ministry

of Justice (122) Stamford Plaza (71) Chapman Tripp (96) Quay West Suites (95) MediaWorks

(79) Department of Corrections (98) Stamford Residences (70) Precinct Properties NZ Ltd (81)

Auckland Methodist Church (219) Sky City Entertainment Group (88) East Family Trust (249)

James KirkPatrick Ltd (236) New Zealand Heritage Places Trust (72) Samson (89).

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across Albert Street this may be provided using pedestrian walkways

across the cut and cover trench with due consideration for security and

safety measures to protect the general public from the worksite and

vice versa.

201. In addition to the concerns expressed by Foodstuffs above (118) the

Ministry of Justice (MoJ) (122) is concerned about potential disruption

to services supply to the building. I describe an indicative methodology

in paragraph 58 that will generally enable continuity of supply.

However, I note there are risks associated with this which are

inevitable, but are similar to any utility works which may occur in a CBD

location at any time. I expect that most of the utility diversions will be

undertaken prior to the main civil works mobilising but some service

diversions, particularly where only minor diversions are practicable,

may need to be concurrent. Throughout all works in and around live

services industry standard risk management methods would be

developed and applied involving the utility providers i.e., service

identification and carefully controlled safe methods of work as

described in the CEMP.

202. I met Ministry of Justice representatives with other CRL colleagues and

their main concerns expressed were associated with potential access

disruptions but also noise and vibration effects upon Court activities.

Mr Whitlock and Mr Fitizgarld address these effects in their evidence.

203. Stamford Plaza and Residences (70 and 71) have similar concerns as

Foodstuffs but wish to put restrictions upon construction traffic

movements. As described in the response to Foodstuffs it is envisaged

that the majority of construction traffic movements (those for the bulk of

the earthworks removal and backfilling) will occur within the trench and

separated from the general traffic within Albert Street services lanes,

i.e., from Lower Albert Street, or from the Downtown shopping centre

site.

204. Quay West (95) and Chapman Tripp (96) are also concerned about

access restrictions for vehicles and pedestrians. The indicative

methodology described between paragraphs 50 to 64 above provides

for access to Mills Lane from the southbound service lane adjacent to

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the CRL works. Traffic from Mills lane may join Albert Street from

Swanson Street but may for a time as discussed in paragraphs 68 -74

above need to be diverted into Queen Street via Wyndham Street when

North-South traffic flows are prevented by the closure of Victoria Street.

East West pedestrian movements at Swanson Street can be

accommodated by providing a pedestrian walkway as described in

paragraph 143 a) i) above.

205. Quay West is concerned regarding construction site provisions. The

intentions for construction sites have been clarified in paragraph 63

above.

206. Chapman Tripp seeks restrictions on construction traffic on Swanson

Street, Federal Street and Wolfe Street. The outline methodology

above has been discussed with Chapman Tripp in terms of worksites at

either end of Albert Street with concentrations of construction traffic at

these ends. Traffic matters are addressed in Mr Clark’s evidence.

207. I have met representatives of James Kirkpatrick Ltd (236) and

discussed their submission with them. Their property is close to the

Victoria Street intersection. There are several options to provide

continuous access to their site during construction. Another item of

their submission discussed was the potential for loss of support, i.e.,

adverse effects upon their building from adjacent CRL construction.

The CRL works in Albert Street (and elsewhere), in my opinion are no

different to any CBD development where deep basement excavations

are required. The existing building owner is entitled to a right of

support and the designer and constructor are liable for repairs for any

damage should that be observed to occur. This highlights the need for

pre-construction building condition assessments and design and

construction monitoring that is sensitive to the building condition.

(Building vulnerability is covered in more detail by Mr Stevenson.)

208. I have met representatives of SkyCity (88) and discussed their

submission with them. They are generally supportive of CRL but are

concerned with disruption to their business.

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209. As described in paragraph 68-74 above and in the evidence of Mr

Clark, access to their staff car park and service entrance on Albert

Street. can be provided during construction. Their further input to the

process will occur via the CEMP and communications plan process.

210. They also raised concerns about construction noise and vibration which

is addressed by the evidence of Messrs. Whitlock and Fitzgerald.

211. Skycity in discussing their submission mentioned a desire to link their

operation with CRL for events that occur particularly at weekends given

limited mode choice for patrons (limited PT links, taxis and of course

cars). Connections to the concourse level in Albert Street are possible

(with due regard for operational security) given the flexibility of the cut

and cover method of construction.

212. The aspects of the Precinct (81) submission that are covered by my

evidence include construction staging, construction methods and

proximity to construction sites.

213. Precinct is concerned about the negative effects within the CBD of

using the Downtown site as a worksite for the 5-6 years period of CRL

construction. This site and its criticality to CRL construction has been

recognised since 2008 when a collaborative alignment was developed

between Kiwirail/ARTA and the previous owners of the site (Westfield).

I have already stated above that CRL will need to demolish the

Downtown shopping centre. However, the intentions and timing of the

oversite redevelopment (which itself may take several years to

construct) remain unclear.

214. Precinct is also concerned about the effects of construction in Albert

Street, and specifically asks that TBMs in Albert Street be considered

as an alternative for the Albert Street cut and cover methodology. The

construction programme described above anticipates the use of an

EPBM to excavate the ECBF rock serviced from a construction

worksite at Mt Eden. This type of tunnelling machine would not be

suitable to remove the Albert Street stormwater line, as demolition of

the line would likely repeatedly tear the belt conveyors used to

transport spoil behind the TBM cutterhead stopping the TBM advance.

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215. Alternative TBM alignments that avoid the stormwater line are feasible

but have inferior geometry and would be extremely close to the existing

line and any new diverted line. In terms of the hierarchy of Design

objectives we have placed a high importance upon rail geometry in

order to realise the benefits over the 100 year Design life and minimise

maintenance impacts.

216. If the Downtown site were unavailable (due to for example the

redevelopment of the Downtown site incorporating elements of CRL,

such alternative alignments would require the use of Lower Albert

Street as a TBM construction site to avoid complicating the critical path

activities of Aotea Station. This would be an extremely constrained

site.

217. It is far from clear at this time that such alternatives offer significant or

indeed any advantages in terms of construction costs and risks. I note

that any tunnelled alignments will be of limited extent within Albert

Street and the major Albert Street intersections (Customs, Victoria and

Wellesley) would remain as cut and cover construction and therefore it

may be expected that the resulting impacts upon utilities and traffic

would also largely remain. The NoR Process requires a reasonable yet

robust methodology given the inevitable uncertainty which surrounds a

design in its early stages of development. During my career I have

assessed both methods of construction on a number of occasions (cut

and cover and driven tunnels) and have strongly advocated driven

tunnel methods where the advantages have been clear (good

examples being the Waterview Connection and the Auckland Harbour

Crossing). However, given the CBD context and the relatively shallow

depth of the cut and cover tunnels and given the extent of the cut and

cover works in Albert St for Aotea Station, the benefits are highly

doubtful to me. Tunnelling may introduce further and greater risks to

construction which may prove to be unacceptable to Auckland

Transport, the constructor and their insurers given the engineering

certainty provided by the cut and cover method proposed.

218. However, the above assessment is not intended to imply that there is

complete ‘closure’ of the constructability options. It is stressed that the

actual ‘means and methods’ and durations of construction adopted may

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change to suit the developing CRL design and the skills experience and

capability of the constructor and the ability for the construction team

including AT and stakeholders to manage adverse effects.

219. I have met representatives of New Zealand Heritage Places Trust and

discussed their submission with them as it pertains to the Bluestone

Wall in Albert Street. They are generally supportive of CRL but are

concerned about potential effects upon the wall. In outlining the

indicative methodology it was agreed that in order to achieve the best

outcome for the wall a collaborative process to develop common

understanding of the heritage and engineering constraints, issues and

risks arising will be undertaken. This process will examine the benefits

and disbenefits of a range of options that are possible in order to

develop an optimum methodology to ensure the best outcome for the

wall during construction.

220. I have met representatives of Samson (89) and discussed their

submission with them. They are generally supportive of CRL but are

concerned with disruption to their tenants’ businesses around

Karangahape Road and Newton Station. A more detailed appraisal of

the vehicle access measures will need to be developed across the

Beresford Street worksite but it is expected that vehicle access to their

properties may remain.

(a) Samson’s other major concern is the NoR 2 and supporting

information does not provide sufficient certainty as to the

shallowest depth of the NoR 2 substrata designation. Samson

argues will have adverse impacts on the current profitability and

future development potential of its properties. Which, Samson

would like to be financially compensated for by Auckland

Transport. Samson raised concerns over

(b) (3.6a) NoR 4 “ although labelled sub-strata”, will in fact relate to

surface land and sub-strata below the surface land, to the

maximum depth of NoR2

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(c) (3.6b) “there will be no NoR 3 type strata or buffer designation in

relation to land affected by NoR 4 alone or in combination in with

NoR2".

(d) Samson states in (4.12) the CRL NoR is not clear about the

nominated distance; “is it five meters or is another depth, or

varies according to specific circumstances of the land in

question”.

(e) Samson states in (4.14) that five meters is about 1.5 levels of

basement for a commercial building, some buildings have

basements that exceed 20 or more meters in depth eg: Ironbark

Building 150 Karangahape Road.

(f) (4.18) In Part 4 of the NoR, Samson stipulates the “sub strata

layer extends from the surface to at or below the NoR2 sub-strata

layers- in this layer will contan the tunnel and Karangahape

Station”

(g) In (4.19) Samson argues that there appears to be no NoR 3 type

“strata or buffer designation proposed under this private land and

will not have a buffer layer between the surface and the sub

strata layer”. That will impact on i’s future development potential

for the site.

221. I confirm that the 5m depth below natural ground level was defined as

part of the NoR process was established to enable small scale

construction above the CRL subsurface structures. Even so certain

works being undertaken within this 5m zone (i.e. heavy compaction)

may cause an adverse effect further underground and possibly onto

CRL subsurface structures. The nature of the works proposed would

therefore need to be considered by AT on a case by case basis.

222. Beneath this 5m zone incursion from more significant developments

maybe allowable subject to detailed assessment of the proposed

development and consideration of the effects upon the CRL subsurface

structures.

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223. Similar overseas rail tunnel projects establish conservative loading

controls to:

(a) Control investigation and construction activities (loading and

unloading) depending on tunnel depth and tunnel design.

(b) Facilitate negotiation and approval by the tunnel owner, with

developers required to substantiate and gain approval for any

ground loading or unloading proposals.

224. It will be necessary to consider the following scenario’s

(a) construction of the CRL prior to any adjacent development and

what constraints (if any) the presence of CRL structures may

present to adjacent land developers, and

(b) construction of developments prior to construction of the CRL.

225. The following principles arise:

(a) Development that occurs prior to tunnel construction must not

place physical obstacles (such as foundations) in the path of the

future tunnel nor should any subsurface structures constructed

disturb the ground to a degree whereby they introduce

construction risks. (It is assumed that new developments,

because of building code compliance requirements are

reasonably robust with respect to the effects of adjacent

tunnelling).

(b) Development that occurs after the tunnel has been constructed

should not damage the tunnels or reduce their durability, either by

direct contact, or by inducing deformations.

226. For future development more than 5 metres below Natural Ground

Level, the detailed interaction between future buildings or structures

and their potential impact upon CRL would need to be reviewed by AT.

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227. The loading of future buildings or structures imposed on the tunnel will

vary depending on the following:

(a) Building height, size, mass and proximity to the tunnel;

(b) Foundation design of the proposed development;

(c) Geotechnical conditions supporting the building and surrounding

the tunnel; and

(d) Separation between the tunnel and the proposed foundations

228. The objective will be to obtain building foundations, designed to keep

loading and stress changes on the tunnels to a minimum. The selection

of foundation type by a building designer depends on the loads

imposed by the proposed development and subsurface ground

conditions. Generally, the concentration of applied foundation stresses

increases with the following foundation types:

(a) Raft slab foundations – provide optimum distribution of building

loads

(b) Pad or spread footings – offer good control of load distribution

(c) Piled foundations below 5 metres – may yield concentrated

loading that requires special consideration

229. The Department of Corrections (DoC) (98) are very concerned about

secure access to the prison using Lauder Road. The CDR suggested

that a temporary level crossing could be re-instated to the East of the

existing Normanby Road crossing using DoC land. We have met

representatives of DoC and explained that this is not possible given

that the NAL at this location will need to be lowered by around 4m and

it will be necessary to close Normanby Road as described above. The

raising of the road by approximately 2m above the CRL and NAL tracks

will require modifications to access to various adjoining properties

including the Dilworth Trust and the Tram Lease site. It is noted that

the Normanby Road crossing has rated very highly in the list of

priorities (on safety grounds) for road/rail grade separation in recent

work undertaken by Auckland Transport. It is re-iterated that CRL will

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reduce the scale of impacts upon the local road network because of the

track lowering (approximately 4m) required by the CRL geometry.

230. The final configuration of the revised road layout will need to be

developed in conjunction with these landowners and Council. Mr Clark

will address the local road impacts in his evidence.

231. The main concern of PAL properties (28) is that the rail alignment is

directly under Eclipse apartments and not road reserve. PAL

properties suggests that inadequate consideration of alternatives has

occurred. I confirm that it is possible to increase the plan offset

distance to the Eclipse apartments without significantly affecting the

Karangahape Station platform position. The reductions in

environmental effects will be discussed by Craig Stevenson.

232. The principal concern in the Mediaworks (79) submission is

construction and operational vibration which is addressed by the

evidence of Mr Whitlock and Mr Matthew Harrison of SLR. I can

comment on vibrations arising through construction during construction

blasting as I have extensive experience of preparing blast risk

assessments for construction projects in Hong Kong, Dublin and the

United States in sensitive locations proximal to sensitive receivers such

as residences, offices and rail operational control rooms and

associated vibration sensitive equipment and am familiar with the

standards that may be used to both predict vibration and limit the

effects of vibration to reasonable levels. I also have practical

experience of mitigation techniques to limit the adverse effects of

blasting such as vibration and air overpressure and the derivation of

site specific blasting attenuation constants.

233. Since lodgement of the NoR further ground investigations have been

completed by Auckland Transport which have defined extensive basalt

flows at Mt Eden. The best practicable option to remove the basalt

(refer figure 1 above) is blasting.

234. It is customary in Auckland to use the German Standard DIN 4150 for

the assessment of blasting effects on buildings or structures. This is a

very conservative standard in comparison to British Standards, the

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United States Bureau of Mines guidance and the local standards

developed in Hong Kong by the various authorities there, including the

Mass Transit Railway Corporation and the Hong Kong Mines

Department.

235. The basalt excavation at the NAL may be up 100m long, 10-12m deep

and 7m wide at the base and so this is a significant amount of basalt to

excavate using mechanical methods such as hydraulic breakers.

236. Using the blast attenuation constants of Australian Standard AS 2187:2

and assuming that a peak vibration level recorded by Marshall Day

within the TV3 studios of 0.9mm/s is an acceptable limit (as it may

reflect daily ambient conditions in the vicinity of the studio) this should

enable reasonable trials for blasting to be undertaken from the southern

‘dive’ structures required for the West facing links of CRL to the NAL

some 100m from the TV3 building (sensitive receivers all around the

site would of course be considered).

237. It is noted also that turnout tunnels of approximately 15m diameter are

required beneath the TV3 building requiring the use of roadheaders.

The adverse effect of these semi-continuous vibrations is addressed in

the evidence of Mr. Whitlock and Mr Harrison. I note that TV3 allowed

a team of CRL advisors including myself to visit the studio in operation

on the 21st June 2013 to better understand the operations, which was

informative.

Response to Planner’s Report

238. Auckland Council has raised several issues in respect of the

construction assumptions which I have clarified above.

239. Council experts have considered the settlement assessment to be

reasonable if not conservative. In our experience volume loss of 1%

(incorporating all the elements that contribute to volume loss) is a

reasonably conservative starting point and is readily achievable with

good workmanship. We note that London’s Crossrail has adopted

0.5% and 1% within the tunnelling contract specifications without the

need to mandate closed mode operation. Notwithstanding we have

undertaken sensitivity tests at higher assumed volume loss

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percentages (1.5%) and do not consider the issue particularly

significant in terms of impacting the conclusions we have reached or

the Designation footprint.

240. We note that further investigation of building vulnerability and further

analysis of the effects of tunnel construction will be undertaken which

may lead to the specification of sections of the work that may require

‘closed mode’ operation.

Proposed Conditions

241. A suite of conditions is proposed in the evidence of Ms Fiona Blight.

242. The conditions referring to Construction Management Plan (CEMP)

relate to managing the effects of the Project during construction.

The conditions cover the following matters:

(a) The Communications and Consultation Plan(s);

(b) The procedures to be followed to manage the effects during

construction, to be managed under Construction Environmental

Management Plan (CEMP);

I am comfortable with the proposed condition.

CONCLUSIONS

243. Overall, I consider the concept design and the indicative construction

methodology are reasonably and appropriately conservative.

244. In my view the majority of potential adverse effects which arise during

construction will be temporary and can be addressed and managed via

the CEMP process. The CEMP will provide a robust process for

managing adverse effects that may occur during construction.

William (Bill) Russell Newns 2 July 2013

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Appendix A – Drawings

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Page 64: Auckland Council Statement of Evidence of William (Bill ... and Project Rosedale (TBM (EPBM) and access shafts and outfall structures) and the Huntly North Shaft (caisson sinking and

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Page 66: Auckland Council Statement of Evidence of William (Bill ... and Project Rosedale (TBM (EPBM) and access shafts and outfall structures) and the Huntly North Shaft (caisson sinking and

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Page 67: Auckland Council Statement of Evidence of William (Bill ... and Project Rosedale (TBM (EPBM) and access shafts and outfall structures) and the Huntly North Shaft (caisson sinking and

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