BEFORE THE UNITARY PLAN INDEPENDENT HEARINGS PANEL

IN THE MATTER of the Resource Management Act 1991 and the Local Government (Auckland Transitional Provisions) Act 2010

AND

IN THE MATTER of the Proposed Auckland Unitary Plan (PAUP), Topic 019 – Outstanding Natural Features

AND

IN THE MATTER of the submissions and further submissions set out in the Parties and Issues Report

STATEMENT OF PRIMARY EVIDENCE OF ALASTAIR ROBERT JAMIESON ON BEHALF OF AUCKLAND COUNCIL TOPIC 019 - OUTSTANDING NATURAL FEATURES 22 JULY 2015

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Index

1 Summary 2

2 Introduction 3

3 Code of Conduct 3

4 Scope 4

5 Explanation of Outstanding Natural Features 4

6 Expert Evaluation / Assessment - Proposed Amendments 8

7 Expert Evaluation / Assessment - Proposed Provisions 10

8 Conclusion 11

1. SUMMARY

1.1 My full name is Alastair Robert Jamieson. I am giving evidence on behalf of Auckland Council addressing submissions filed in respect of the PAUP’s identification of Natural Features.

1.2 With minor exceptions, I support the overlay provisions relating to ONFs as were notified in the PAUP. Some amendment and simplification to the provisions is now proposed. I am comfortable with the plan provisions proposed in the planning evidence of Peter Reaburn. I consider they clarify and simplify the notified provisions whilst retaining the ability to ensure appropriate management of adverse effects on ONFs.

1.3 I have reviewed the submissions that seek amendments to the mapping of ONFs, and the ONF Schedule in Appendix 3.1. My review has been supported by a separate review undertaken by Melean Absolum in respect of those ONFs that have landscape significance. As a result of these reviews I propose a number of amendments to the mapping and schedule. These amendments are detailed in Attachment B to my evidence, with proposed map changes illustrated in Attachment C.

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2. INTRODUCTION

2.1 My full name is Alastair Robert Jamieson. I am a Biodiversity Team Manager (Regional) at Auckland Council, a position I have held since October, 2012. Prior to that date, I was a consultant advisor to Auckland Council on natural features matters within the Proposed Auckland Unitary Plan (PAUP) in my position of Director, Wild Earth Media Ltd.

2.2 I have a Bachelor of Science degree in Zoology and Geography, and a Master of Science degree in Physical Geography from the University of Auckland.

2.3 While engaged as a consultant by Auckland Regional Council in 2008, I provided policy advice in relation to Outstanding Natural Features (ONFs) for Plan Change 8 of the Auckland Regional Policy Statement. I subsequently provided further policy advice and developed a draft schedule of Outstanding Natural Features for a later review of the Auckland Regional Policy Statement.

2.4 While engaged as a consultant by Auckland Council, I developed draft policies and the schedule of Outstanding Natural Features for the PAUP. Since Auckland Council was established in 2010, I have provided technical expertise and assessments for resource consents in relation to significant geological features under the operative Auckland District Plan and ONFs under the PAUP, initially as a consultant and later in my current role.

2.5 I provided evidence to the Panel in relation to the RPS provisions relating to ONFs, as part of Topic 010.

3. CODE OF CONDUCT

3.1 I confirm that I have read the Code of Conduct for Expert Witness contained in the Environment Court Practice Note and that I agree to comply with it. I confirm that I have considered all the material facts that I am aware of that might alter or detract from the opinions that I express, and that this evidence is within my area of expertise, except where I state that I am relying on the evidence of another person.

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4. SCOPE

4.1 I have been asked to provide evidence in relation to the submissions made on the ONF overlay, which is part of PAUP Topic 019. My evidence focusses on amendments sought to the ONF mapping and the ONF schedule in Appendix 3.1 to the PAUP. I also provide brief comment on some of the plan provisions, which are more fully canvassed in Peter Reaburn’s evidence.

4.2 I have been a member of Council’s case team that has assessed issues raised in submissions relating to Natural Features. I also have considerable experience in administering provisions relating to natural features, including earthworks provisions, in legacy plans. My opinions are based on my qualifications and direct experience.

4.3 I attended mediation on the ONF provisions and mapping on 22 June 2015. I have also attended a number of direct discussion meetings.

5. EXPLANATION OF ONFS

5.1 As notified, Policy 1 in RPS Chapter B4.3.2 identifies the “Unitary Plan criteria” for ONFs as follows:-

Identify geological sites and landforms that are ONFs using the following criteria:

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, including type localities of rock formations, minerals and fossils b. the rarity or unusual nature of the site or feature c. the extent to which it is an outstanding representative example of the diversity of Auckland's natural landforms and geological features d. the extent to which the landform, geological feature or site is a component of a recognisable group of geologically associated features e. the extent to which the landform, geological feature or site contributes to the aesthetic value or visual legibility of the wider natural landscape (this criterion was changed in evidence given at the Topic 010 RPS hearing). 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 Page 5

h. the potential value of the feature or site to provide additional understanding of the geological or biotic history 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 the contribution of the feature to the more publicly valued groups of landforms and geological sites associated with Auckland's volcanoes, coastlines, Hauraki Gulf islands, and the Waitākere Ranges

5.2 These criteria arose from an analysis I undertook for Auckland Council in 2011, resulting in a report prepared by me entitled “Advice on Criteria for the Identification of Significant Geological Features in Auckland (July 2011)”. This was fully explained in my Topic 010 evidence.

5.3 The identification of ONFs was carried out utilising a number of sub-categories of “Site type”. These are:

A1 Large landforms in working rural environments A Large landforms V Large volcanic landforms V1 and V2 B Smaller more fragile landforms C Dynamic landforms and features D Exposures of geological material E Fragile exposures of geological material F1 and F2 Caves

5.4 The site types are distinguished from one another by a combination of scale and other characteristics that influence their sensitivity to adverse effects. They range in size from hundreds of hectares (e.g. ‘Large’ landforms such as Tapora and Whatipu) to tens or a few hectares (e.g. ‘Volcanic’ features such as Mt Eden and , or ‘Smaller and more fragile’ landforms such as the Patauoa Creek interglacial terrace and Reef fossil forest), to tens or just a few square metres (e.g. ‘Fragile exposures of geological material’ including Arataki volcanic breccia and Liverpool Street tuff exposure, and ‘Caves’ such as the lava caves at Ambury Road and Kitenui Ave). In addition, the characteristics of some of the features are distinguished Page 6

because they have a particular influence on their management requirements: ‘Dynamic’ landforms are sites such as dunes, and wetlands or lakes and other hydrological features where the continuance of process is an important consideration (e.g. Pakiri Beach, Lake Pokorua, and Te Henga/ Bethells swamp). Exposures and fragile exposures of geological material are steep to vertical exposures formed naturally in cliff faces (e.g. coastal cliffs at Tamaki Drive and Takapuna) or artificially in road cuttings or quarries (e.g. Northwest Motorway lava flow, Pukapuka Quarry unconformity).

5.5 On behalf of Auckland Council I have had primary responsibility for the identification of ONFs in Auckland utilising the above criteria and site types. This process built upon work I had previously carried out to develop a draft schedule of ONFs for a review of the Auckland Regional Policy Statement for Auckland Regional Council during 2009. The reviewed RPS was not notified, but instead was used by AC as a starting point in preparing the PAUP for a number of topics, including ONFs. I carried out the work for Auckland Council to identify ONFs for the PAUP during 2011 and 2012.

5.6 The principal sources of information about potential ONF sites that I considered were the existing schedules of significant geological sites contained in various sections of the operative Auckland Council District Plan. In particular, the Operative North Shore, Isthmus, Manukau and Hauraki Gulf Islands sections of the plan contain relatively comprehensive schedules of significant geological sites, while the Waitakere section contains a schedule of Outstanding Natural Features (Appendix H). I also referred to the Regionally Significant Volcanic Features identified in the Auckland Council Regional Policy Statement, and considered Coastal Protection Areas identified with geological values in the Auckland Council Regional Plan: Coastal.

5.7 Another key source of potential sites for consideration was the Inventory and Maps of Important Geological Sites and Landforms in the Auckland Region and Kermadec Islands (Kenny and Hayward, 19961) This document is part of the New Zealand Geopreservation Inventory, which is a series of publications that aims to list the best examples of the wide diversity of natural physical features and processes that characterise each part of New Zealand. The Geoscience Society of New Zealand

1 Kenny J.A. and B.W. Hayward (1996): The inventory and maps of important geological sites and landforms in the Auckland Region and Kermadec Islands (First Edition). Geological Society of New Zealand Miscellaneous Publication 84.

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now maintains and updates the inventory in an electronic database, and I had access to this material updated to 2010. I also consulted a range of research papers and technical publications, such as various papers on Auckland geology published in the New Zealand Journal of Geology and Geophysics. Lastly, I identified a few additional sites that in my professional opinion also had potential to be identified as ONFs.

5.8 There is considerable overlap between the sites identified from these different information sources; nevertheless once duplicates were excluded, I compiled a list of over 300 sites for further consideration. To these, I applied the relevant “site type” attributes listed under paragraph 5.3, and sorted them accordingly. In response to advice that the district plan provisions of the PAUP would not apply to the Hauraki Gulf Islands at this stage, I set aside the solely terrestrial sites within the Hauraki Gulf Islands, but continued to consider those that lie partially or entirely in the CMA.

5.9 I assessed all of the remaining sites against the “Unitary Plan criteria” for ONFs in Policy 1 of RPS Chapter B4.3.2 of the PAUP, which are listed at paragraph 5.1 of this evidence. My brief was to assess ‘outstandingness’ in the regional context. In other words, that ONFs should be identified as being outstanding within the range of the kinds and examples of natural features that occur within the Auckland Region.

5.10 In my view, this approach is appropriate for the identification of ONF’s in the PAUP. Consequently, the assessment process led me to set aside a number of potential ONF sites that I considered to be of less than regional importance. I note that no further distinction is made between sites of regional, national or international significance in the schedule for the ONF overlay.

Mapping of ONFs

5.11 Once I had identified ONF sites using the criteria, I carried out detailed mapping of each one for the ONF overlay. For every site, I developed or refined the mapping using a combination of my own observations from site visits, aerial photography (both vertical and oblique), topographic contour information and geological mapping, and existing information, such as cave survey plans.

5.12 For those sites already scheduled as Geological Features in the Operative Auckland Council District Plan, I was strongly guided by the existing plan maps. In these cases, my brief was generally to refine the maps, rather than to start afresh and map what I Page 8

considered to be the full geological extent of each landform or site. Following discussions with Auckland Council staff, I took the approach of only adding what I considered to be unmodified parts of the features to existing mapped areas. This was carried out very conservatively with respect to private land, but where public reserve land was involved, I sought to include a greater extent of the ONF, where appropriate. In the submissions, I note that this approach has drawn opposition both from submitters who seek less coverage, such as those concerning Lake Pupuke as discussed below, and those seeking that the mapping be more extensive (e.g. 4485- 21 -Auckland Volcanic Cones Society, and 3085-16 - Ngati Whatua Orakei Whai Maia Limited).

5.13 I have visited most of the sites that are now included as ONF areas in the overlay. Exceptions include a number of remote and inaccessible coastal sites on islands and cliffs, and some of the lava caves where access is difficult or restricted. To map caves I relied entirely on existing information, particularly the operative district plan maps where applicable. I had photographed many of the sites from the air on previous occasions, so I also referred to these oblique images to supplement the vertical aerial photography on Auckland Council’s GIS system.

5.14 The ONFs are mapped as an overlay on the PAUP maps. They are also individually scheduled in Appendix 3.1 to the PAUP. Appendix 3.1 lists 249 ONFs by way of unique ID, name, location, site type, description and the relevant unitary plan criteria that apply.

6. EXPERT EVALUATION / ASSESSMENT - PROPOSED AMENDMENTS

6.1 Attachment A to my evidence identifies individual submissions that relate to the ONF mapping and Appendix 3.1, and Council’s response to those submissions. Attachment B is an analysis of individual submissions; however I have not included reference to a number of submissions that seek additions to the ONF mapping. The reasons for this are explained in Peter Reaburn’s evidence. While I have not conducted a full analysis of potential additional sites, I consider that a number of them may have merit, and should be assessed for potential scheduling by way of a plan change in the future.

6.2 I have proposed some amendments to the ONF mapping and Appendix 3.1, as follows:- Page 9

Map changes – addition of extent

• Feature ID 158: Point Chevalier Waitemata Group sedimentary structures • Feature ID 222: Three Kings volcano (Te Tatua A Riukiuta)

Map changes – amendment or reduction of extent

• Feature ID 10: Beachlands fault • Feature ID 42: Helena Rubinstein and Ratcliffe lava caves • Feature ID 48: Hōteo hogback bluffs and unconformity • Feature ID 115: Mt Smart volcano remnant (Rarotonga) • Feature ID 138: One Tree Hill (Maungakiekie) • Feature ID 143: Ōrākei Basin volcano • Feature ID 144: Ōrākei Greensand Miocene fossils, Hobson Bay • Feature ID 162: Ponui Island Pillow Lava • Feature ID 179: Red Hill volcanic centre

Map changes – deletion of entire feature

• Feature ID 80 Lunn Avenue baked sediments, Mt Wellington

Changes to Appendix 3.1

• Feature ID 48: Hōteo hogback bluffs and unconformity • Feature ID 91: Mathesons Bay basal Waitematā Group rocks and fossils unconformity and Miocene reef corals • Feature ID 118: Mt Wellington () • Feature ID 179: Red Hill volcanic centre • Feature ID 202: Tamaki estuary rhyolitic ignimbrite • Feature ID: 236 Pukewairiki tuff ring • Feature ID 240: Waitangi Falls, Glenbrook • Feature ID 253: Wiri lava cave

6.3 In respect of other submissions analysed in Appendix 3.1, I highlight some that I recognise are of major concern to submitters.

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6.4 The site which has received the most attention from submitters is Lake Pupuke volcano ONF (ID 74), largely on account of the fact that the ONF incorporates many private residential properties. From a geological point of view, I consider that the actual extent of the ONF is much larger than the mapped area, and should include full extent of the explosion crater and tuff ring, while submitters seek to have the area reduced. Similar issues are raised in submissions concerning volcano ONF (ID 74) and St Heliers explosion crater ONF (ID 194), two other volcanic landforms where the shape of the geological landform and distribution of residential properties are comparable to Lake Pupuke.

6.5 Another key concern arising at Lake Pupuke is the concurrence of part of the ONF overlay with the Smales 2 Precinct, which provides for future development on the land (including a former quarry site) owned by submitter W. Smale Limited (3249-3). These matters are addressed in detail in my analysis of submissions at Attachment B of this evidence.

7. EXPERT EVALUATION / ASSESSMENT - PROPOSED PROVISIONS

7.1 In his evidence, Peter Reaburn, Council’s Lead Planner for the ONF overlay, provides planning evidence on the provisions for the overlay within Chapter J6.1, and also proposes a new set of district plan objectives and policies for inclusion in Chapter E6. Mr Reaburn’s amendments are proposed to obtain better alignment with the RPS provisions and to respond to issues raised in submissions, however there are no major changes proposed to the provisions as notified. I have read Mr Reaburn’s evidence, which in part relies on this evidence. I support the conclusions Mr Reaburn has reached, and the provisions as redrafted.

7.2 I support the proposed amendments to Chapter J6.1. I consider that the provisions are appropriate to manage the potential adverse effects of activities, and consistent with the sensitivity of the various ONF site types identified and discussed at paragraphs 5.3 and 5.4 of my evidence.

7.3 I consider that the different provisions for grazing of sheep and goats and grazing of other stock is appropriate for ONFs, because heavier large hoofed animals such as cattle stock cause greater damage to geological sites than grazing of sheep and other lighter small hoofed animals.

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7.4 In my experience, cattle grazing and tracking can cause considerable ground damage and also exacerbates erosion. I consider this kind of damage may occur in all seasons, and note that the soils of many ONFs remain vulnerable to disturbance even in the summer months. In my opinion, particular examples of these include ONFs with steep slopes and friable soils such as volcanic cones and explosion craters, and those with sandy soils. For this reason, I do not support Federated Farmers’ submission (6523/123), which is discussed in Mr Reaburn’s evidence (paragraphs 9.5 and 9.7), as it would not provide for the protection of ONFs throughout the year.

8. CONCLUSION

8.1 With minor exceptions, I support the mapping, scheduling and provisions relating to ONFs as were notified in the PAUP. I support the amendments to the provisions now proposed. I have proposed some changes to the mapping and Appendix 3.1 that correct errors and refine the location and / or explanation of the ONFs.

Alastair Jamieson 22 July 2015