Cit Holdings Limited in Relation to Topic 019 Outstanding Natural Feature Overlay

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.

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

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.

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.

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;

(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 to reviewing the above information, I undertook a site walkover inspection of CIT’s properties and the wider footprint of the St Heliers Volcano on 15 April 2015 to assess the nature of the geologic landforms.

1 Evidence-in-chief by Mr Alistair Jamieson on behalf of Auckland Council, Attachment B, page 18. 2 Kermode, L. O. 1992. Geology of the Auckland urban area. Scale 1:50 000. Institute of Geological and Nuclear Sciences geological map 2. 1 sheet + 63 p. Institute of Geological and Nuclear Sciences Ltd., Lower Hutt, New Zealand. 3 Hayward, B. W., Murdoch, G., Maitland, G. 2011. Volcanoes of Auckland, The Essential Guide. Auckland University Press, University of Auckland, New Zealand.

Statement of Evidence of Shane Moore 019 Outstanding Natural Features CIT Holdings Ltd Primary evidence Submitter number 6240

Figure 2: Investigations (red squares) undertaken by T&T near the St Heliers Volcano (yellow outline)

5. FINDINGS OF REVIEW

5.1 Figure 3 shows the extent of the St Heliers Volcano as mapped by Kermode2. The extent of the tuff deposits (purple shading) is marked by a dashed line that indicates that the boundary is “gradational”. This is consistent with the mechanism of formation of the volcano where rising magna violently exploded to the surface following contact with shallow groundwater. The exploded materials (volcanic ash and fragmented country rock) then fell back to ground mantling the surrounds of the explosion crater and hardening to form tuff. Depending on the violence of the eruptions and number of eruptive cycles a raised tuff ring may form. As shown in Figure 4 the greatest thickness of tuff develops closest to crater with deposits thinning with distance away from the eruption centre and grading onto the surrounding topography.

Statement of Evidence of Shane Moore 019 Outstanding Natural Features CIT Holdings Ltd Primary evidence Submitter number 6240

Figure 3: Mapped extent of St Heliers tuff ring (from Kermode 19922)

Figure 4: Stylised cross-section of an explosion crater and tuff ring

5.2 I agree with the evidence provided on behalf of Council by Ms Absolum and Mr Jamieson that inspection of the St Heliers Volcano reveals the explosion crater, which is now occupied by Glover Park, and the remnants of the inner walls of the tuff ring remain highly discernible from within the crater.

5.3 However, I disagree with the statements made by Mr Jamieson (in the analysis provided as Attachment B to his evidence) that “…outer flanks of the volcanic landform are important, integral and highly visible parts of the feature…” and by Ms Absolum (in paragraph 6.50) that “…the feature remains clearly legible and is identifiable from a wide area. The feature is also clearly visible to the numerous people visiting the reserve and surrounding area and can also be seen from within the harbour.”

5.4 In contrast, in my opinion there is a clear difference between the outer flanks of the St Heliers Volcano tuff ring and the interior of the tuff

Statement of Evidence of Shane Moore 019 Outstanding Natural Features CIT Holdings Ltd Primary evidence Submitter number 6240

ring/crater and the levels of protection that should be afforded to these areas. My evidence in support of this position follows.

5.5 As shown in Figure 5, with the exception of the crater floor of the eruption centre, which is occupied by Glover Park, the landside extent of the St Heliers explosion crater has been intensely developed and urbanised. The flanks, ridgeline and much of the interior of the tuff ring/crater is covered by medium to high-density residential lots and supporting infrastructure.

Figure 5: 2008 aerial photograph showing intensity of development in the St Heliers area

5.6 Because of its urbanisation the presence of the wider tuff ring is almost entirely obscured. There are no longer outcrops or exposures of the volcanic deposits, that are visible to the public, and may therefore warrant specific protection. The only outcrop of the remnant volcanic features are along the coastal cliffs, and blocks on tuff falling onto the intertidal platform below, which are already public lands. The presence of the tuff ring is now only discernible across much of it footprint through intrusive investigations such as those that T&T has undertaken (refer to Figure 2).

5.7 Both Mr Jamieson and Ms Absolum make comment as to the legibility of the landform associated with the St Heliers Volcano. As stated in paragraph 5.2, I agree that some of the landforms are highly legible and

Statement of Evidence of Shane Moore 019 Outstanding Natural Features CIT Holdings Ltd Primary evidence Submitter number 6240

identifiable from within the crater (Glover Park and surrounds). However, I do not consider that the landforms are highly legible or identifiable when viewed from outside the crater.

5.8 Figure 6 shows the topography near St Heliers Volcano. It can be seen that the topography developed on the surrounding sedimentary rocks of the East Coast Bays Formation (ECBF) is similar in elevation and gradients to that developed across the St Heliers Volcano.

Figure 6: Topography near St Heliers - volcanic within brown circle, ECBF within red circles

5.9 Figures 7 and 8, which are photographs I took from CIT’s properties during a recent site visit, and Figure 9 (taken by Ms Panther Knight) demonstrate the similarity in elevation and form between the volcanic and non-volcanic (ECBF) landforms in the area.

Figure 7: Panorama from highpoint of CIT properties showing the similarity to the ECBF topography to the west

Statement of Evidence of Shane Moore 019 Outstanding Natural Features CIT Holdings Ltd Primary evidence Submitter number 6240

Figure 8: Close-up of part of Figure 7

Figure 9: View to east from part way up ECBF ridge at Gifford Street

5.10 The overall subdued nature of the outer portions of the St Heliers Volcano tuff ring are further demonstrated in Figures 10 and 11, which show the volcano and surrounds in 1956. In contrast to Ms Absolum’s opinion that “…the feature… can also be seen from within the harbour.”, I contend that the coastal cliffs, which are principally formed by ECBF rocks, are the dominant feature of the area when viewed from the harbour. The volcanic landforms of the St Heliers Volcano are obscured in these views by the intensity of development, similarity to the surrounds, and predominance of the coastal cliffs.

5.11 Review of the topography versus the proposed ONF overlay (refer to Figure 1) also shows that the overlay clearly follows cadastral boundaries rather than actual geologic features, such as the rim of the tuff ring.

Statement of Evidence of Shane Moore 019 Outstanding Natural Features CIT Holdings Ltd Primary evidence Submitter number 6240

5.12 In conclusion, I consider that only the general topographic form of the outer flanks of the tuff ring remains, and even that is now much modified and barely discernible when viewing the feature from any vantage other than from within the crater.

Figure 10: Oblique aerial photograph looking to south-east across St Heliers in 19564

Figure 11: Oblique aerial photograph looking to south across St Heliers in 19565

4 Achilles Point with Cliff Road and Glover Park, Saint Helliers coastal settlement with Bucklands Beach beyond, Auckland City. Whites Aviation Ltd :Photographs. Ref: WA-41107-F. Alexander Turnbull Library, Wellington, New Zealand. http://natlib.govt.nz/records/30116979

Statement of Evidence of Shane Moore 019 Outstanding Natural Features CIT Holdings Ltd Primary evidence Submitter number 6240

5.13 Even considering the topographic form from within the crater, reviewing existing earthworks on CIT’s properties (refer to Figures 12 through 14) shows that significant modifications would be required to alter the landform to the extent that it is no longer recognisable as part of the tuff ring. The existing earthworks are barely discernible from across the crater and would be further obscured once new structures are developed or vegetation is re-established over these areas.

Figure 12: Example of existing earthworks on ridgeline of CIT’s properties

Approximate extent of CIT’s properties

Area of earthworks

Figure 13: View of existing earthworks from northern rim of tuff ring

5 Looking to Glendowie with Glover Park, Maskell Street and St Heliers Bay foreground, with Panmure Basin and Tamaki River beyond, Auckland City. Whites Aviation Ltd :Photographs. Ref: WA-40752-F. Alexander Turnbull Library, Wellington, New Zealand. http://natlib.govt.nz/records/30113503

Statement of Evidence of Shane Moore 019 Outstanding Natural Features CIT Holdings Ltd Primary evidence Submitter number 6240

Area of earthworks

Figure 14: View of existing earthworks compared to wider extent of tuff ring

5.14 Such modifications would compromise the views from properties along the rim of the tuff ring, and I suggest for this reason alone are unlikely to be undertaken. Regardless, adequate protection of the general topographic form of the tuff ring remnants is already provided by the other rules of the PAUP that control such development (such as earthworks, ground stability, height controls etc.).

5.15 As part of my review I also compared the way that the ONF overlay is proposed to be applied St Heliers Volcano to the application of ONFs to other similar features, i.e. volcanic explosion craters with tuff rings, across the Auckland Volcanic Field. I note from this high-level review that very few of the tuff rings that have similar expressions to the St Heliers Volcano have ONF designations which extend substantially onto developed private property, for example Taylor Hill (immediately south), Auckland Domain, Orakei Basin, Panmure Basin, Mt Richmond, Mt Robertson, Hopua, Mangere Lagoon, Crater Hill, Pukaki Lagoon, Kohuora, and others.

5.16 In its schedule (Appendix 3.1) Council describes Crater Hill and Pukaki Lagoon as the two best remaining examples of explosion craters and tuff rings in the Auckland Volcanic Field. As shown in Figure 15, in a similar manner to the St Heliers Volcano, along its northern extent the rim of the tuff ring of the Pukaki Lagoon eruption centre extends beneath private residential zoned property and road reserves, particularly along Pukaki Road and Prangley Avenue. However, as shown in Figures 16 and 17, in contrast to St Heliers the Pukaki Lagoon ONF overlay specifically avoids any privately held property under residential zoning. In fact, the overlay specifically extends between adjacent privately held properties to capture a small area of publically held land adjoining Pukaki Road. The Pukaki

Statement of Evidence of Shane Moore 019 Outstanding Natural Features CIT Holdings Ltd Primary evidence Submitter number 6240

Lagoon ONF overlay does include a single landholding under rural production zoning but is otherwise restricted to publically held lands.

5.17 Further, where private properties have been included in respect of other explosion craters and tuff rings it is most common for the overlay to extend across only part of the properties (for example. Lake Pupuke, Tank Farm Volcano etc.). This approach better reflects the actual extent of the features requiring protection rather than following cadastral boundaries as applied to St Heliers.

5.18 In conclusion, it is unclear to me why St Heliers should require specific protection where the same features of Pukaki Lagoon, reportedly one of the best type examples, and other similar eruption centres, do not.

5.19 It is particularly concerning that Ms Absolum concludes that “…the ONF should include the encircling tuff ring.” and Mr Jamieson that “Any evaluation of change should consider extending the feature to include more of the landform to the south of the identified ONF.” The basis for these conclusions are unclear and appear inconsistent with the way in which the ONF overlays are proposed to be applied to similar features.

Approximate area where tuff ring rim underlies residential properties

Figure 15: Topography of Pukaki Lagoon

Statement of Evidence of Shane Moore 019 Outstanding Natural Features CIT Holdings Ltd Primary evidence Submitter number 6240

Figure 16: CIT Properties and extent of St Heliers ONF overlay (green dots) tuff ring (brown line)

Figure 17: Extent of Pukaki ONF overlay (green dots) tuff ring (brown line)

Statement of Evidence of Shane Moore 019 Outstanding Natural Features CIT Holdings Ltd Primary evidence Submitter number 6240

6. CRITERIA FOR SCHEDULING OF ONFS

6.1 The following criteria are used by Council to schedule ONF’s:

(a) “the extent to which the landform feature or geological site contributes to the understanding of the geology or evolution of the biota in the region, New Zealand or the earth (includes type localities of rock formations, minerals and fossils)

(b) the rarity or unusual nature of the site or feature;

(c) the extent to which the feature or site is an outstanding representative example of the diversity of natural landforms and geological features in Auckland;

(d) the extent to which the landform or geological feature or site is a component of a recognisable group of geologically associated features;

(e) the extent to which the landform or geological feature or site contributes to the value of the wider landscape;

(f) the community association with, or public appreciation of the values of the feature or site;

(g) the potential value of the feature or site for public education;

(h) the potential value of the feature or site to provide additional understanding of the geological or biotic history of the region;

(i) the state of preservation of the feature or site;

(j) the extent to which a feature or site is associated with an historically important natural event, geologically related industry, or individual involved in earth science research

(k) the importance of the feature or site to Mana Whenua;

(l) the contribution of the feature to the more publicly valued groups of landforms and geological sites associated with the region’s volcanoes, coastlines, the Hauraki Gulf Islands, and the Waitākere Ranges.”

6.2 Council has assessed that criteria a, c, d, f, g, h, and l apply to the St Heliers explosion crater ONF under the PAUP. I present my assessment against the criteria as follows:

(a) Being one of some 50 volcanoes in the Auckland Volcanic Field the St Heliers Volcano contributes in a general way “to the understanding of the geology in the region”. However, it is not so unique in this capacity that the understanding of the geological history of the region would be significantly impaired in the

Statement of Evidence of Shane Moore 019 Outstanding Natural Features CIT Holdings Ltd Primary evidence Submitter number 6240

absence of this feature. The St Heliers Volcano does include one feature that contributes to a broader understanding in a more unique manner. Erosion by the sea has exposed the tuff ring along the coastal margin of the volcano. Blocks of tuff that lie at the base of the eroding cliffs have been shown to include crustal rocks that were ejected by the volcano. These deposits are unique to the St Heliers and neighbouring Taylors Hill eruption centres and contribute to the understanding of the geological history of the region. However, while these features are unique, the parts of the volcano where they are present, and remain accessible, are already vested in public ownership;

(c) The St Heliers Volcano is one of 19 explosion craters with surrounding tuff rings in the Auckland Volcanic Field (Hayward et al. 2011). It is therefore rare but not unique in the region. It is not an outstanding representative example of its type and as described in my preceding evidence is generally intensely developed and poorly preserved;

(d) As per responses to points (a) and (c);

(f) I am unable to comment conclusively on the community association with, or public appreciation of the values of the feature. However, I suspect to the general public the feature likely has far greater value for its sporting grounds and park facilities than any geological aspects. The unique features described in response to point (a) clearly have a high value to a small special interest group. However, as indicated above these features are already vested in public ownership;

(g) As described in the preceding sections of my evidence the tuff ring of the St Heliers Volcano is almost entirely built over. There are no longer outcrops or exposures of the volcanic deposits that are visible to the public. The developed areas of the tuff ring therefore have very limited educational value. As described in response to point (a) the parts of the volcano that have educational value are already vested in public ownership;

(h) As described in response to the previous points the tuff ring of the St Heliers Volcano almost entirely comprises privately

Statement of Evidence of Shane Moore 019 Outstanding Natural Features CIT Holdings Ltd Primary evidence Submitter number 6240

owned residential lands that have been built over. These lands can therefore not be accessed “to provide additional understanding of the geological… history”. Large areas of the volcano that could provide this opportunity are already vested in public ownership, Glover Park and the road reserves which cross the volcano;

(l) As a result of St Heliers Volcano being intensely developed and having a subdued form I would classify it as being one of Auckland’s lesser known and therefore publicly valued volcanoes.

6.3 In summary, I consider that the above assessment reveals 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 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.

7. CONCLUSIONS

7.1 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 fall into this category.

Statement of Evidence of Shane Moore 019 Outstanding Natural Features CIT Holdings Ltd Primary evidence Submitter number 6240

7.2 In summary, I consider that the St Heliers Volcano can be separated into 2 main landform types that warrant 2 differing levels of protection, as follows:

7.3 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.).

7.4 Additional protection of the crater floor and interior of the tuff ring is already afforded by these areas being vested in Auckland Council, comprising Glover Park and the Waitara and Glover road reserves. Therefore there seems little merit in retaining the Outstanding Natural Feature notation for the tuff ring of the St Heliers explosion crater, and particularly as the notation relates to the land at 14-22 and 28-30 Waimarie Street.

Statement of Evidence of Shane Moore 019 Outstanding Natural Features CIT Holdings Ltd Primary evidence Submitter number 6240

7.5 However, if it is deemed necessary to retain the notation I consider that it would be best to either:

(a) Limit it to the undisturbed areas of the crater and tuff ring that are already vested in Council ownership; or

(b) Define it by the ridgeline of the tuff ring and not the cadastral boundaries by which it is currently defined.

Shane Moore 4 August 2015

Statement of Evidence of Shane Moore 019 Outstanding Natural Features CIT Holdings Ltd Primary evidence Submitter number 6240

ATTACHMENT A ADDITIONAL SUMMARY OF RELIEF SOUGHT