Statement of Evidence of Shane Moore 019 Outstanding Natural Features CIT Holdings Ltd Primary evidence Submitter number 6240 IN THE MATTER OF The Resource Management Act 1991 (the Act) and the Local Government (Auckland Transitional Provisions) Act 2010 AND IN THE MATTER OF The Proposed Auckland Unitary Plan Topic 019 Outstanding Natural Feature overlay STATEMENT OF EVIDENCE OF SHANE MOORE ON BEHALF OF CIT HOLDINGS LIMITED IN RELATION TO TOPIC 019 OUTSTANDING NATURAL FEATURE OVERLAY 4 AUGUST 2015 Statement of Evidence of Shane Moore 019 Outstanding Natural Features CIT Holdings Ltd Primary evidence Submitter number 6240 CONTENTS EXECUTIVE SUMMARY .......................................................................................... 1 1. QUALIFICATIONS AND EXPERIENCE ............................................................ 2 2. SCOPE OF EVIDENCE ..................................................................................... 3 3. BACKGROUND ................................................................................................. 3 4. REVIEW PROCESS .......................................................................................... 5 5. FINDINGS OF REVIEW ..................................................................................... 6 6. CRITERIA FOR SCHEDULING OF ONFS ...................................................... 16 7. CONCLUSIONS ............................................................................................... 18 Statement of Evidence of Shane Moore 019 Outstanding Natural Features CIT Holdings Ltd Primary evidence Submitter number 6240 EXECUTIVE SUMMARY A. This statement is presented on behalf of CIT Holdings Limited (“CIT”). B. In principle I support the protection and enhancement of the volcanic centres that contribute to Auckland’s volcanic character and heritage. Unfortunately, a number of Auckland’s volcanic centres have been modified by previous development to the extent that they now provide limited heritage value. I consider that parts of the St Heliers Volcano falls into this category. C. In contrast to Council’s assessment I consider that the St Heliers Volcano can be separated into 2 main landform types that warrant 2 differing levels of protection, as follows: a. The explosion crater and remnants of the inner walls of the tuff ring, which remain highly discernible and include unique features that warrant special protection. These features are already vested in public ownership. This may in fact be what the Outstanding Natural Feature (“ONF”) overlay was intended to achieve given it is titled the “St Heliers explosion crater ONF”? and b. The outer tuff ring, which almost entirely comprises privately owned residential lands that have been built over, and is now barely discernible from the ridges of East Coast Bays Formation rocks that border it. I do not consider that this area warrants special protection. D. I consider that adequate protection of the general topographic form of the outer tuff ring remnants is already provided by the other rules of the PAUP that control the residential development which dominates the extent of this volcanic centre (earthworks, ground stability, height controls etc.). E. I therefore consider that the proposed ONF overlay as it applies to CIT’s properties at 14-22 and 28-30 Waimarie Street, St Heliers is not appropriate and should be removed or, if removal is not supported, amended as clarified in this evidence. 1 Statement of Evidence of Shane Moore 019 Outstanding Natural Features CIT Holdings Ltd Primary evidence Submitter number 6240 1. QUALIFICATIONS AND EXPERIENCE 1.1 My full name is Shane Robert Moore. I am a Principal Environmental Scientist of Tonkin & Taylor (T&T), specialist environmental and engineering consultants. I hold the Degrees of a Bachelor and Master of Science, majoring in Geology, from the University of Auckland. 1.2 I have some 20 years’ experience undertaking geological assessments, principally with respect to the assessment and management of contaminated land. My experience has largely been based in New Zealand, particularly in the Auckland region. 1.3 For my Masters thesis I undertook detailed geophysical and hydrogeological studies of the Mt Richmond and McLennan Hills volcanic centres in Otahuhu. Mt Richmond in particular shares a number of features in common with the St Heliers Volcano, which is the subject of my evidence. Since my thesis I have worked regularly across a variety of the volcanic centres, and their associated deposits, within the Auckland region. 1.4 I appear on behalf of CIT Holdings Ltd (“CIT”) to address the submission and further submissions made on the Proposed Auckland Unitary Plan (“PAUP”) in respect of the Outstanding Natural Feature (“ONF”) overlay, particularly as it affects CIT’s properties at 14-22 and 28-30 Waimarie Street, St Heliers. 1.5 In terms of my involvement to date, I reviewed the Proposed Auckland Unitary Plan and my client’s submission. I have also read the evidence of Ms Melean Absolum and Mr Alastair Jamieson on behalf of Council. Therefore, I am familiar with the issues to be addressed at this hearing. 1.6 I confirm that I have read the Expert Witness Code of Conduct set out in the Environment Court's Practice Note 2014. I have complied with the Code of Conduct in preparing this evidence and I agree to comply with it while giving oral evidence before the Hearings Panel. Except where I state that I am relying on the evidence of another person, this written evidence is within my area of expertise. I have not omitted to 2 Statement of Evidence of Shane Moore 019 Outstanding Natural Features CIT Holdings Ltd Primary evidence Submitter number 6240 consider material facts known to me that might alter or detract from the opinions expressed in this evidence. 2. SCOPE OF EVIDENCE 2.1 My evidence is written to complement the planning evidence of Ms Kay Panther Knight in relation to the ONF provisions of the PAUP. 2.2 My evidence will address the following: (a) It provides a description of the process I have undertaken to review the ONF overlay relating to CIT’s properties; (b) The findings of my review of the ONF overlay; and (c) An assessment of the “outstandingness” of the ONF against the relevant criteria at Appendix 3.1 to the PAUP; My assessment of the Council’s evidence and specifically, the Council’s response to CIT’s submission is included in the above. 3. BACKGROUND 3.1 CIT owns the properties located at 14-22 and 28-30 Waimarie Street, St Heliers. The properties have been owned by CIT and related entities since 2010. A number of consents have been granted in respect of the properties. Most recently in October 2011, consent was granted for the construction of a four-level apartment development at 14-16 Waimarie Street. Further, CIT has been working on a proposal for terraced housing on the land located at 28-30 Waimarie Street as well as a substantial new dwelling on the land located at 22 Waimarie Street. 3.2 As notified, CIT’s properties are subject to the ONF Overlay (ID 194) associated with the St Helier’s explosion crater, as illustrated in the image below. 3 Statement of Evidence of Shane Moore 019 Outstanding Natural Features CIT Holdings Ltd Primary evidence Submitter number 6240 Figure 1: CIT Properties and Extent of ONF overlay (green dots) 3.3 CIT’s submission sought deletion of the overlay from its properties for the following reasons: (a) The majority of the land in the block between Glover Road and Waimarie Street has already been extensively developed; (b) The land has been heavily modified in the past and, for all intents and purposes, the natural feature of the tuff ring has been completely “built out”; and (c) The overlay appears to follow cadastral boundaries, particularly in the vicinity of the subject site, which would suggest inaccuracies in the mapping of the physical extent itself, which would be unlikely to mirror site boundaries. 3.4 Further, as requested by the Panel, CIT provided additional evidence (Attachment A) summarising its position in respect of the submission and the overlay amendment. I prepared this summary following a site walkover and visual analysis of the surrounding environment. I concluded that the outer tuff ring is now barely discernible from the ridges of East Coast Bays Formation rocks, and therefore the area does not warrant special protection. 4 Statement of Evidence of Shane Moore 019 Outstanding Natural Features CIT Holdings Ltd Primary evidence Submitter number 6240 4. REVIEW PROCESS 4.1 The process I followed in reviewing and assessing CIT’s properties and the wider St Heliers volcanic centre was similar to that described in the evidence of Mr Jamieson1. In summary I reviewed the following information as part of my assessment: (a) Readily available published geological information for the area (for example Kermode 19922), and summary information (for example Hayward et al. 20113); (b) Historic aerial photographs, both vertical and oblique, available from online sources (for example Auckland Council’s GIS Viewer and the National Library) and a physical library of historic aerial photographs of the region for which T&T manages the Crown copyright; (c) Topographic information both from site inspection (refer below) and information published by Auckland Council; (d) ONF overlays proposed for similar features; and (e) Geological data obtained from a number of intrusive geotechnical investigations undertaken by T&T within and across the footprint of the St Heliers Volcano (refer to Figure 2). In addition