Before the Environment Court at Wellington
In the Matter of
And
In the Matter of
Lane Neave PO Box 25626 Wellington 6146 Solicitor Acting : Amanda Dewar
section 87G of the Resource Management Act 1991
the direct referral of the Application for resource consents associated with an extension to the runway by Wellington International Airport Limited
(ENV-2016-WLG-00058)
Affidavit of John Clifford Kyle
Email : [email protected] Phone: 03 379 3720 Lane neave.
I, John Clifford Kyle, Director, of Dunedin swear:
Introduction
1. My full name is John Kyle. I am a director of Mitchell Daysh Limited and have
provided resource management advice to Wellington International Airport Limited
(WIAl) in relation to its runway extension project, the subject of these
proceedings. I am authorised to make this Affidavit.
2. I have personal knowledge of the matter set out in this Affidavit and its contents
are true to the best of my knowledge and belief.
3. In April 2018 my firm prepared a report outlining the status of the various
technical reports provided as part of the resource consent application for WIAL's
runway extension project (April Report). I attach a copy of the April Report as
Exhibit A.
4. I have been asked to review the April Report in response to the two strike out
applications. I have reviewed the strike out applications and the accompanying
affidavits.
5. The April Report concluded:
"We are of the opinion that the technical reports that accompanied the
assessment of environmental effects for the Project can continue to be
relied upon, with any new information or updates being presented in
evidence if considered necessary. "
6. I consider the April Report remains valid for the following reasons :
(a) the biophysical effects of the runway extension (such as ecology, coastal
processes) have been assessed and the likelihood that time has
changed the findings of these assessments is very low; and
(b) some assessments such as the economic assessment, and the
forecasting will need to be updated before a hearing is held. Again this
should occur in preparing the evidence.
SWORN at Hamilton
)
this I! day of a{'I?IYJbr 2u!81 2018 befor me: )
J ! hn Clifford Kyle
Kuru ICltu Solicitor Hamilton
)
M I TC HE L L ,L
DAYSH
Exhibit Note
This is the annexure marked "A" referred to in the annexed affidavit of John Clifford
Kyle sworn al HamillO his /I ~ ay of December 2018 before me:
Signature .
A Solicitor of t (Solicitor to gn in part on Exhibit)
Kuru Ketu solicitor
Hamilton
WELLINGTON INTERNATIONAL AIRPORT LIMITED
PROPOSED RUNWAY EXTENSION - STATUS OF TECHNICAL REPORTS
April 2018
REPORT INFORMATION
Report Status Final
Our Reference 6900
File Location Dunedin
Author John Kyle I Claire Hunter
Review By John Kyle
© Mitchell Daysh Limited (2018).
This document and its contents are the property of Mitchell Daysh Limited .
Any unauthorised employment or reproduction, in full or in part. is forbidden.
Status of WIAL Runway Extension Technical Reports L ,
1. INTRODUCTION
As part of preparing resource consent application for the proposed runway extension
project (the Project) at Wellington International Airport (the Airport) a number of technical
assessment reports were prepared. These reports were prepared by independent experts
in order to inform a comprehensive assessment of the environmental effects associated
with the Project. These experts were also engaged to provide recommendations regarding
appropriate mitigation measures and environmental monitoring to be undertaken by WIAL
to manage any actual or potential adverse environmental effects arising as a result of the
Project's construction or operation.
The application for resource consent to enable the proposed runway extension has been
directly referred to the Environment Court. Following a Court of Appeal challenge by
NZALPA regarding the suitable runway end safety area (RESA) length, Wellington
International Airport Limited (WIAL) sought leave from the Environment Court to adjourn
the hearing. Upon receiving the subsequent Supreme Court Appeal decision, WIAL has
now requested a further Environ ment Court adjournment. This will aHow time for WIAL to
seek further consideration by the Director General of Civil Aviation of the acceptable RESA
length at Wellington Airport as part of the Project. The Director has indicated he will take
approximately six months to consider WIAL's request. As such, WIAL wishes to keep the
current application for resource consent "alive" in case the Director determines there are
potential RESA options which would enable the Project to remain in or very near its current
form such that it remains within the scope of the current application.
A number of section 274 parties to the Environment Court proceedings, have expressed
concerns with regard to this request. Concern has been raised that since WIAL's
application was prepared and filed, significant time has passed, and this may have
implications on the relevance and currency of the accompanying technical assessments.
There is criticism that due to the delay the technical assessments may be outdated and
not reflective of the actual or potential effects of the Project.
The purpose of this report is to consider whether these technical reports would remain
valid in the circumstances where the application is reactivated in its current form (or near
to it) .
2. CONSTRUCTION METHODOLOGY AND APPROACH TO THE
MANAGEMENT OF EFFECTS
The environmental effects associated with the proposed construction activities were
based on a construction methodology developed by the Project engineers AECOM. It was
noted in the relevant technical assessments that subsequent detailed design and contract
innovation may result in alterations to the final construction methodology. However, the
various technical assessments were based on the best estimate of construction which
Status of WIAL Runway Extension Technical Reports L ,
derived from AECOM's worldwide experience with similar projects. Flexibility in the final
design and construction methodologies was and is anticipated as part of the applications.
This is not uncommon in large scale infrastructure projects, because the process of
appointing contractors will almost always yield a degree of innovation in the way the
Project is ultimately delivered. Thus, consent terms and conditions should be designed to
provide sufficient flexibility to enable the benefits of such innovation to be realised, where
this remains consistent with achieving sustainable management of natural and physical
resources.
Based on the anticipated construction methodology and the subsequent operation of the
Project, the findings of the technical assessments (refer Chapter 7 of the AEE) have
concluded that in some cases the actual or potential effects of the proposed runway
extension are such that mitigation, remediation and/or monitoring measures are
necessary. It is proposed that the suite of mitigation and management measures is
formalised through the imposition of conditions on the resource consents that are being
sought by WIAL. Proposed conditions were attached to the application (refer section 8.5 of
Chapter 8 of the AEE), however it was always expected that the conditions would be
subjected to further amendments and refinements as the consenting process progressed
and further consultation with submitters occurred.
2 ,1 PROPOSED CONDITIONS
In summary, the conditions set out the following obligations:
) General construction matters including requirements to adopt best practice methods;
) Management and mitigation of potential construction effects. requirements for
community liaison and the preparation and implementation of an overarching
Construction Management Plan;
) Management and mitigation of ecological effects during construction and
requirements for post construction remediation;
) Management and mitigation of potential amenity and nuisance effects that are likely
to arise during construction e.g. construction traffic, noise, dust;
) Management and mitigation of potential effects on coastal processes including
mitigation to offset the effects on surfing amenity within Lyall Bay;
) Management and mitigation of potential effects on natural character, and landscape
values; and
) A requirement for urban amenity matters to be addressed including requirements for
enhancements to (in particular) the coastal margin.
Status of WIAL Runway Extension Technical Reports L
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In a number of areas, it is more appropriate to impose conditions which set in place
environmental process standards rather than requiring strict adherence to performance
standards that may not. in the long term. be the best way to mitigate effects.
With respect to the Project this is to be achieved utilising management plans.
2.2 PROPOSED USE OF MANAGEMENT PLANS
The proposed management plans vary in their function. At the most fundamental level
management plans detail the steps that need to be taken to achieve a specified outcome
or bottom line. These management plans have application where there is reasonable
certainty about the steps necessary to complete that process. The role of the
management plan in this context is to provide detail as to how a particular parameter is to
be met. The conditions of consent establish the relevant parameters.
The second type of management plan is more sophisticated and better suited to those
situations where a degree of flexibility is required in order to respond appropriately to
what is learned from "doing" including from monitoring results. This approach generally
revolves around the use of management plans to guide the way that a development or
resource use occurs at the outset, which is coupled with comprehensive monitoring
requirements and subsequent and ongoing adaptation of management responses to
better achieve predicted or desired outcomes. This approach is referred to as "adaptive
management".
Both forms of management plans are proposed to be utilised to mitigate and manage the
effects of the Project. As indicated earlier our experience with consenting large-scale
projects confirms that this practice is common and considered to be best practice,
including by the Court.
There are a number of elements of the Project which give rise to effects on environmental
values and where the outcome cannot be predicted at the outset (or at any stage) with
absolute certainty due to the dynamic and complex nature of the receiving environment
involved. Where such circumstances exist, an adaptive management approach is a useful
method in ensuring the desired results are attained. The following areas of management
associated with the Project can be the subject of such an approach:
> Effects on the aquatic ecology within the coastal environment affected by the
reclamation; and
> Effects on coastal processes including surfing amenity and seabed and foreshore
morphology.
The approach allows matters of management response to be left until after the consent
approval process. Conditions promoting such as approach are generally coupled with
obligations to collaborate with key interest groups and/or the consent authority to settle
upon the appropriate response given what has been learned. Again, this is not uncommon
Status of WIAL Runway Extension Technical Reports L.
3 ,
with large scale infrastructure projects, and is a particularly good management tool where
a longer lapse date for the consents is also being sought (e.g. 10 - 15 years).
2.3 SPECIFIC MANAGEMENT PLANS
The following management plans were identified as being required to ensure any actual or
potential adverse effects arising from the Project were suitably managed:
) Construction Management Plan (CMP).
) Stakeholder and Communications Management Plan (SCMP).
) Construction Air Quality Management Plan (CAQMP);
) Noise and Vibration Management Plan (NVMP);
) Construction Traffic Management Plan (CTMP);
) Erosion and Sediment Control Plan (ESCP);
) Environmental Mitigation and Management Plan (EMMP);
) Surf Mitigation Adaptive Management Plan (SMAMP);
) Landscape and Urban Design Management Plan (LUDMP); and
) Network Utility Management Plan (NUMP).
The proposed conditions of consent require each management plan identified above to be
finalised prior to construction commencing. In some instances, for example the Surf
Mitigation Adaptive Management Plan, additional baseline monitoring is proposed to be
obtained to further confirm the existing state of the environment The management plan
obligations also require extensive consultation with key stakeholders or the immediately
affected community and will be constructed to adapt to address current concerns and
issues.
It is our view that the requirements of the conditions coupled with the assessments and
future work that is required to prepare the management plans need to be considered in
assessing the currency and ongoing validity of the technical assessments. In short, the
adaptive approach is responsive to change and uncertainty, and it should be. Thus, it is
fundamentally wrong to assume that all of the technical assessments should present the
"final word" as to how the various effects arising from the Project should be managed. We
return to these matters as we discuss each relevant report below.
3. STATUS OF TECHNICAL REPORTS
As mentioned above, a number of technical reports were prepared to accompany the
resource consent applications prepared by WIAL for the Project. These reports consisted
of:
Status of WIAL Runway Extension Technical Reports L
4 ,
> Astral Aviation Consultants - Review of Runway Length
> InterVISTAs - Route Development Assessment
> InterVISTAs - Route Forecasts
> Sapere Research Group - Cost Benefit Analysis
> Raukura Consultants - Cultural Values Report
> TRC- Assessment of Effects on Recreation
> AECOM - Concept Feasibility and Design Report
) Astral Aviation Consultants - Construction Aeronautical Study
> Traffic Design Group - Traffic Assessment
> AECOM - Construction Noise Assessment
> DHI Water and Environment limited (OHI) - Surf Break Impact Assessment
> AirBIZ - Alternatives Airport Sites Investigation
> Raukura Consultants - Cultural Impact Assessment
> DHI - Preliminary Shoreline Assessment
> National Institute of Water & Atmospheric Research Ltd (NIWA) - Coastal Processes
Assessment
> NIWA - Marine Sediments and Contaminants (Lyall Bay)
> NIWA - Technical Report on Coastal Hydrodynamics and Sediment Processes in Lyall
Bay
> NIWA - Ecological Character Report
> Aquatic Environmental Sciences (AES) - Assessment of Ecological Effects
> NIWA - Assessment of Ecological Effects arising from the Proposed Submerged Wave
Focussing Structure
> AECOM - Construction Air Quality Assessment
> Kevin Jones - Archaeological Assessment
> Boffa Miskell limited - Urban Design Assessment
> Boffa Miskell limited - Landscape and Visual Assessment
> Frank Boffa - Natural Character Assessment
> Marshall Day Acoustics - Operational Noise Assessment
An assessment of whether these reports have, and will continue to endure the test of time
to accommodate the requested additional time is set out below:
Status of WIAL Runway Extension Technical Reports L
5 .,
3.1 RUNWAY DESIGN AND LOCATION
Relevant Reports
) Astral Aviation Consultants - Review of Runway Length
> Astral Aviation Consultants - Construction Aeronautical Study
) AirBIZ - Alternatives Airport Sites Investigation
The reports prepared by Astral Aviation Consultants assess the runway extension length
options to determine which configuration would allow viable operations of long haul flights
from Wellington to east Asian and western North American destinations. These reports
also establish appropriate construction parameters associated with working within an
operational airfield. It is not anticipated that technology regarding the type of aircraft, or
construction techniques will significantly change within the timeframes that are being
sought by WIAL with the Court and therefore the findings of these reports will remain valid
to the consideration of the runway extension project.
The AirBIZ report builds on an earlier study an earlier study undertaken by Works
Consultancy Services in 1992. This original study encompassed the establishment of
selection criteria for feasible airport sites, a search for such sites within the Wellington
region, and a high level economic evaluation of candidate locations. Seven sites were
identified following review of the region's topography to find the preferred location. The
conclusions of the 1992 study supported retention of Wellington Airport at its current
location. The work undertaken by AIRBIZ in 2013 further confirmed that the current
location of the Airport remains the most appropriate, due to its close links to the
Wellington CBD, and the existing investment and infrastructure already established at the
site. The conclusions of this report are unlikely to change.
3.2 FORECASTING
Relevant Reports
) InterVISTAs - Route Development Assessment
) InterVISTAs - Route Forecasts
The reports prepared by InterVISTAs provide an assessment of the potential demand from
the airline's perspective for a longer runway at Wellington Airport. These assessments use
relatively up to date passenger and aircraft data. so it would be appropriate that the
conclusions reached in these reports are revisited. These assessments however
contribute to the rationale ed for the Project, and any changes to the conclusions found in
Status of WIAL Runway Extension Technical Reports
L 6 .,
these reports can likely be adequately addressed in evidence. rather than the preparation
and circulation of a new report.
3 .3 ECONOMIC ANALYSIS
Relevant Reports
> Sapere Research Group - Cost Benefit Analysis
Sapere Research Group prepared the cost benefit analysis for the Project. This
assessment and report was based on up to date market data and forecasts at the time the
application was filed and would be expected to be updated regardless of the length of the
adjournment. As a result, it is appropriate that the analysis is revisited prior to the hearing
proceeding and can likely be presented in evidence. rather than the preparation and
circulation of a new report.
As a result. it is appropriate that the conclusions reached in th is assessment are revisited
prior to the hearing proceeding. Such findings can likely be presented in evidence, rather
than the preparation and circulation of a new report.
3 .4 CONSTRUCTION METHODOLOGY AND EFFECTS
Releva nt Reports
> AECOM - Concept Feasibility and Design Report
> AECOM - Construction Noise Assessment
> AECOM - Construction Air Quality Assessment
As mentioned earlier in this report. the construction methodology has been developed
based on AECOM's experience with other similar reclamation projects around the world .
However, it was recognised in the application documentation that subsequent
investigations, detailed design and contractor innovation may result in alterations to the
construction methodology. The CMP will confirm construction methodologies. plant and
equipment to be utilised and construction timeframes, as well specific measures to be
employed to avoid, remedy or mitigate adverse effects.
It should also be noted that the environmental assessments (e.g. construction noise and
traffic assessments) that have relied on this construction methodology have been
assessed on the worst-case basis (e.g. all fill material will be land based and transported
on the road network. rather than being marine based and barged to the site. and the
Status of WIAL Runway Extension Technical Reports ...
7 "I
requirement for stone columns to stabi lise the reclamation) and are therefore considered
to be conservative. As such, in our assessment the AECOM work can be relied upon even
if the Court hearing is further delayed.
3.5 CULTURAL AND ARCHAEOLOGICAL ASSESSMENTS
Relevant Reports
) Raukura Consultants - Cultural Values Report
) Raukura Consultants - Cultural Impact Assessment
) Kevin Jones - Archaeological Assessment
A Cultural Values Report and Impact Assessment accompanied the application to extend
the Airport's runway. The values report identified historical and current uses of the
immediate and surrounding area and identified the cultural significance of the site. The
historical facts presented in this report will not alter, nor will the cultural significance of the
immediate or surrounding site. Current uses are largely associated with gathering kai
moana, and although there may be fluctuations in the abundance and availability of such
resources, the effects of the proposed runway extension in this regard (Le. loss of an area
of habitat. restriction of the coastal marine area during construction etc) are well known
and understood. Such effects are not expected to differ if there is a further delay in the
hearing proceedings.
The archaeological assessment is also based largely on historical facts, and any findings in
this regard are unlikely to change necessitating a revisit of this assessment.
3.6 RECREATIONAL ASSESSMENT
Relevant Reports
) TRC4 Assessment of Effects on Recreation
The Recreational Assessment identified that Lyall Bay is popular for a number of
recreational activities including walking, running, surfing, kite surfing, surf lifesaving,
swimming, fishing, drives, picnics, visiting cafes and aeroplane watching. The CMA around
Moa Point is also used for diving, snorkel ling, fishing and gathering of seafood. The report
also identified various activities resulting from the construction and/or operation of the
runway extension that could adversely affect these pursuits. While the popularity of the
identified activities may alter (due to weather patterns, new retall or cate activities in the
area), the nature of the activities undertaken in the area will remain relatively constant and
Status of WIAL Runway Extension Technical Reports l
S .,
as such the assessment of actual or potential adverse effects on such activities will remain
valid.
Due to the original author of the recreational report relocating overseas, WIAL
commissioned another recreational expert to peer review this work and provide evidence
at the hearing. While this may result in slightly differing conclusions being reached as to
the extent and/or severity of effects, the type of recreational activities that occur in the
area and the nature of the effects arising from the construction and operation of the
runway extension are not anticipated to alter to any significant extent.
Furthermore, WIAL has and is continuing to discuss the impacts of the proposal with key
recreational groups and stakeholders such as the Wellington Boardriders Club. Such
parties represent a wide range of individuals, and although there may be new members or
surfers to the area since the applications were first lodged who may not have made an
individual submission or joined as a section 274 party, it is considered that their interests
are likely to be sufficiently covered via the submissions of such stakeholders and the
ongoing consultation with representatives.
Key management plans, for example the CMP, SCMP, CTMP, and the SMAMP, establish
measures to mitigate potential adverse effects on recreational activities (Le. timing of
heavy traffic to avoid congestion and safety issues with pedestrians and cyclists) and also
require that WIAL consult with key stakeholders and communicate with the affected
community and recreational groups prior to and throughout the construction of the Project.
3.7 TRAFFIC AND TRANSPORTATION ASSESSMENT
Relevant Reports
> Traffic Design Group - Traffic Assessment
The key matter arising with regard to effects on the transportation network from the
Project is the haulage of fill material through the state highway and local road network to
the Project site. As set out in the application the method for the transportation of fill
material to the site will not be finalised until a construction contract is awarded and the
details around the source of construction material is confirmed. If dredged material is
utilised, then this wou ld likely result in a significant reduction of fill material transported via
the road network. The traffic assessment assumed a 'worst case scenario' whereby all fill
material would be transported to the construction site by road.
Key matters that informed the preparation of the traffic assessment included road capacity
and road safety. While baseline traffic results are not anticipated to alter significantly within
the timeframes being proposed by WIAL, WIAL has used the delay in the current
proceedings to work closely with the NZTA to develop and try to agree conditions relating
Status of WIAL Runway Extension Technical Reports L.
9 "I
to the haulage of material to the site. As part of this ongoing consultation, the NZTA
identified that because WIAL is seeking a 10 - 15 year lapse date, conceivably the Project
construction may be some time away and therefore additional modelling of the anticipated
future road capacity (e.g. the road network in 2016 vs 2026) was required. Such modelling
is underway, and this will assist in informing the impacts of haulage traffic on general road
capacity. intersection delays and speed impacts in this future environment. Such data and
conclusions relating to effects on this future environment can be presented at the hearing
via evidence.
In addition to this work that is underway, the proposed CTMP will detail controls for
construction traffic , including provisions for temporary traffic management, driver protocols
and monitoring. This Plan will appropriately account for where fill material is being
sourced, and accurately detail and manage the expected construction vehicle movements
and resulting effects on the surrounding environment.
This area of assessment is necessarily dynamic in nature due to the fact that road user
characteristics continually evolve. This is an iterative process that builds upon the original
assessment and is necessarily collaborative, particularly with the NZTA and with the
Council as road controlling authorities.
3.8 SURF AND SHORELINE ASSESSMENTS
Relevant Reports
) DHI Water and Environment Limited (OHI) - Surf Break Impact Assessment
) DHI - Preliminary Shoreline Assessment
Utilising data obtained by NIWA, DHI undertook numerical modelling to assess the impact
of the proposed runway extension on the wave climate, swimmer safety and surf quality of
the surf breaks at Lyall Bay. This modelling was based on robust physics and an
understanding of the local surf environment, and although the data was obtained some
time ago (e.g. 2014) changes to the surf environment within Lyall Bay are not anticipated to
occur rapidly to the extent that the conclusions reached by DHI with regard to the
potential effects on the surfing amenity within Lyall Bay will be significantly altered.
Furthermore, the findings of this report are that Airport Rights surf break will be losl, and
there will be a decrease in wave peakiness due to reduced refraction to the east
elsewhere in the Bay. This ultimately results in an adverse effect on the surfing quality
with in Lyall Bay. Those most directly affected by this, in particular organisations which
represented the views of a number of individuals and community members such as the
Wellington Boardriders Club and the Lyall Bay Surf Lifesaving Club were closely involved
Status of WIAL Runway Extension Technical Reports I-
10 .,
in consultation with WIAL at the outset of the Project and the sharing of information with
regard to the DHI reporting.
To mitigate or offset these effects a submerged wave focusing structure is proposed. WIAL
is still committed to this mitigation, and via ongoing consultation with key stakeholders
such as the Wellington Boardriders Club, has developed detailed conditions requiring the
preparation of a SMAMP. As detailed design of the proposed structure has not yet been
undertaken, in preparing the SMAMP WIAL is required to undertake further, more detailed
baseline monitoring. It has been generally agreed that the conditions and subsequent
preparation of the SMAMP, which also requires extensive stakeholder input and review,
are an appropriate mechanism for addressing the key concerns of the local surfing
community affected by the proposal. Again, an adaptive management response is
proposed. and responses necessarily evolve as more is learned. This approach has been
endorsed in the submission by the Wellington Boardriders Club.
3,9 COASTAL PROCESSES AND COASTAL ECOLOGY
Relevant Reports
> National Institute of Water & Atmospheric Research Ltd (NIWA) - Coastal
Processes Assessment
> NIWA - Marine Sediments and Contaminants (Lyall Bay)
) NIWA - Technical Report on Coastal Hydrodynamics and Sediment Processes in
Lyall Bay
) NIWA - Ecological Character Report
> Aquatic Environmental Sciences (AES) - Assessment of Ecological Effects
> NIWA - Assessment of Ecological Effects arising from the Proposed Submerged
Wave Focussing Structure
NIWA was commissioned to undertake various assessments into the coastal processes,
marine environment and aquatic habitat that would be directly affected by the proposed
runway extension. Although the investigations that underpin these assessments were
undertaken some time ago (N2014 - 2016) changes to coastal processes and habitat are
generally slow moving unless there is sudden anthropological interference. Temporal
changes are not expected to be more than gradual, even evolutionary. The area
immediately adjacent to the existing runway comprises rocky reef habitat and as such
does not experience any significant aggregation or degradation of material depOSition,
and the species composition in this immediate area due to this habitat is also likely to
remain relatively consistent within this timeframe. Given this, the findings of these
assessments are likely to remain valid.
Status of WIAL Runway Extension Technical Reports L
11 .,
It is acknowledged however that there could be land use changes or other natural
phenomenon that result in reasonably instantaneous responses from the coastal
environment (e.g. discharges of material which could alter the current species composition
or habitat; or an earthquake resulting in a new reef formation). If this was to occur, then it
would be reasonable for WIAL to undertake further assessment of the impacted coastal
marine area. These are likely to result in reasonably obvious responses in the receiving
environment; and no such changes are currently known to have occurred since the
applications were filed.
3.10 LANDSCAPE AND NATURAL CHARACTER
Releva nt Reports
> Boffa MiskellUmited - Urban Design Assessment
> Boffa Miskell Limited - Landscape and Visual Assessment
) Frank Boffa - Natural Character Assessment
Construction of the Project will extend the existing runway further out into the CMA. The
landscape and natural character assessments concluded that this will change perspectives
of the area from certain viewpoints and in particular. from residential properties which
currently overlook the area from both the east (Moa Point, Strathmore Park) and west (Lyall
Bay. Houghton Bay) of the Airport. The visual and landscape assessment includes a
detailed visual assessment, taken from a broad range of identified key viewpoints.
The most pronounced visual effects will arise from those living closest and with direct
views to the Project site and those using public spaces near it, to the east of the site. Moa
Point residents will be most affected by the visual effects of the reclamation. If the footprint
of the proposal remains the same or similar then these findings are unlikely to change.
The only thing that could change is the receivers themselves. We understand that the
possibility of recent and ownership cha nges might be able to be addressed through
succession or waiving time limits so that any new owners are not denied an opportunity to
participate in the hearing, should they wish to do so. Having said that we are not aware of
Moa Point residential property ownership changes, aside from the fact that WIAL is actively
continuing to acquire these properties.
As would be expected the assessment of the effects of the Project on natural character
focusses on changes that will result to natural processes and natural forms. There have
been no significant changes occur to baseline conditions in this regard and one can
reliably expect that the assessment report would remain current and fit for purpose,
despite the delay in proceedings, due to the fact that it largely deals with changes to the
bio-physical receiving environment.
Status of WIAL Runway Extension Technical Reports 12 ,
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3.11 OPERATIONAL NOISE
Relevant Reports
) Marshall Day Acoustics - Operational Noise Assessment
The noise assessment by Marshall Day determines that the proposed runway extension
and Code E aircraft would not cause a significant change to overall noise exposure (Lon) in
the community and noise from aircraft operations would comply with the current Air Noise
Sounda.y (ANS) for a sufficiently long period of time. Unless in the intervening period there
has been significant variance in aircraft type or technology likely to use the runway
extension (and there has not). the findings of this assessment are unlikely to change in the
period of time that has elapsed between the assessment report being completed and the
likely hearing date.
4. SUMMARY
A number of technical reports were prepared by a range of independent experts in order
to inform a comprehensive assessment of the actual or potential effects on the
environment arising from the Project. These assessments were based on the construction
methodology that was provided by the Project engineers AECOM. The AECOM
methodology was based on that firm's extensive global experience with land reclamation
and infrastructure development projects. These assessments have been utilised in the
knowledge that subsequent detailed design and contractor innovation would likely result
in alterations to the final construction methodology. These assessments also assume a
'worst case' construction methodology regarding certain aspects of the Project, for
example that all fill material would be from land-based sources and therefore transported
to the site via the road network. On this basis the reporting for various aspects of the
Project is considered to be conservative.
The expert assessments also recommend various methods to avoid, remedy or mitigate
adverse effects on the environment. In a number of cases, the reporting recommends the
use of an adaptive management approach, whereby further monitoring and investigation,
and the development and refinement of mitigation is identified as the Project development
progresses. It is intended to respond to the state of the environment at the time the
construction of the Project commences. Th is is appropriate and not uncommon with large
scale infrastructure projects. particularly where a longer lapse date (of 10 -15 years) is also
being sought. A number of management plans are proposed in this regard.
Against this background, it is our view that there are very limited circumstances where the
technical reporting related to the Project will become outdated, even in light of the
timeframes proposed. We are of the opinion that the technical reports that accompanied
Status of WIAL Runway Extension Technical Reports
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the assessment of environmental effects for the Project can continue to be relied upon,
with any new information or updates being presented in evidence if considered necessary.
The key reasons for this are as follows:
> Technical matters relating to the construction and management of an operational
airfield are unlikely to alter.
> Ecological and coastal processes - although the investigations that underpin these
assessments were undertaken some time ago (N2014 - 2016) changes to coastal
processes and habitat are generally slow moving unless there is sudden
anthropological influence. Temporal changes are not expected to be more than
gradual.
> Cultural, heritage and archaeological assessment are largely based on historical facts
and events, and therefore the findings of these reports are unlikely to significantly
change.
> The economic environment in which the Project exists may be subject to external and
internal fluctuations, and therefore it would be appropriate to revisit these matters. We
think that this updating can be done in evidence without any prejudice to the parties.
This is a typical situation in our experience.
> With regard to recreational effects, landscape, natural character, visual amenity and
construction related amenity effects. it is accepted that there may be some changes
to the receiving environment (Le. the neighbouring property owners may change),
however the findings with regard to the nature, scale and intensity of such effects are
unlikely to significantly change. It is also noted that WIAL is committed to continually
working with the affected community prior to and during construction in particular to
ensure they remain informed and any commitment with regard to mitigation (i.e. noise
mitigation or property relocation during particularly noisy periods) is successfully
implemented. These measures are to be guided by the management plans proposed .
We also understand that there are legal means to address change in land ownership
and involvement in the proceedings within the affected community.
> During consultation the NZTA has expressed concern that the road network and
traffic environment could alter within the 10 - 15 year lapse date that is being sought
by WIAL with regard to the Project. WIAL is continuing to work with the NZTA and
modelling of the expected future road network is underway. These findings are to be
presented in evidence in due course. Neither the NZTA nor the Councils have raised
any difficulty with this iterative approach. Certain matters, such as the submerged
wave focussing structure were always intended to be subject to further site
investigation, monitoring and consultation with key stakeholders as set out in the
relevant management plan.
L. Status of WIAL Runway Extension Technical Reports
14 ,