THAMES-COROMANDEL DISTRICT COUNCIL

PROPOSED THAMES-COROMANDEL DISTRICT PLAN

Variation 2 ' Airfield'

Section 42A Hearing Report

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INTRODUCTION

Purpose of the Report

1. This report is a staff analysis of submissions and further submissions received on Variation 2 to the Proposed Thames-Coromandel District Plan. The purpose of this report is to assist the Hearings Panel in their consideration of the merits of submissions on the variation. The recommendations contained in this report do not have any statutory weight.

2. In preparing this report I have considered all submission points and further submissions relating to Variation 2 (Section 28 Airfield Height and Noise Overlay and Planning Map 17D). Recommendations are made to every submission point and further submission in the summary tables for each submission topic. Appendix 1 of this report contains a track changed version of Table 1 of Section 28.1.1 and Table 1 of Section 28.3 showing the effect of the recommendations in this report. In considering the submissions I have given regard to the provisions of the Proposed District Plan and the Section 32 analysis as notified, the Council's statutory obligations, Civil Aviation Authority rules and expert advice.

Staff and experts

3. This report has been prepared by Elisabeth Maria Resl, Senior Consultant Planner. I hold a Master of Arts and a Master of Applied Science. I have been practising as a planner for more than 20 years and have been working for the Council since April 2011, as Senior Policy Planner and subsequently as a Consultant Planner. I have been directly involved in the development of the draft District Plan and I have drafted the Section 32 analysis for the notified Proposed District Plan.

At the time of drafting Variation 2 Dave Park, a specialist engineer at Astral Ltd, was engaged to provide an assessment of all relevant CAA requirements as they relate to the airfield’s current and foreseeable use. Dave Park was retained by the Council to provide expert advice on matters raised by submitters that were beyond the scope of planning expertise.

Abbreviations

AIP Aeronautical Information Publication CAA Civil Aviation Authority of New Zealand Council Thames-Coromandel District Council The Plan Proposed Thames-Coromandel District Plan MBAC Aero Club Incorporated MAUW Maximum All Up Weight MCTOW The aircraft maximum certified take-off weight WWL Whitianga Waterways Limited Airey Design the OLS design Airey Consultants Ltd produced on WWL’s survey map Airey Map the Map that Airey Consultants Ltd produced for WWL in March 2017 to support a 1:20 OLS as opposed to a 1:40 OLS (8737/06 SK01 & 02 Rev B Mar 17

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If a section and/or provision reference does not have a document name before it, the reference is from the Plan.

BACKGROUND

4. Variation 2 seeks to amend two separate tables in Section 28 ‘Airfield Height and Noise’ and subsequent changes to Planning Map 17D Airfield Height Restriction Overlay ‘Whitianga Airfield’ (with consequential amendment to overlay maps 17A and 17B) as follows:

 Amending the Main Transitional Surface, also called an Obstacle Limitation Surface (OLS) from a 1:7 gradient to a 1:5 gradient; and  Showing the main runway strip in its actual location; and  Amending the main runway strip length to 1265m (04-22); and  Extending the runway strip width to 80m.

5. Variation 2 was prepared following consultation with the Mercury Bay Aero Club (MBAC), representatives for Whitianga Waterways Ltd, who own and develop land adjacent to the airfield. Dave Park a consulting aviation expert for the Council and an aviation expert for Hopper Development Ltd, Murray Smith, from Airey Consultants Ltd, an aviation expert acting for WWL were part of the consultative discussions.

6. The issues regarding Whitianga Airfield include:  Since the maps in the Plan were based on the inaccurate maps contained in the Operative Plan the Plan’s map needed to be updated to reflect the actual on the ground layout of the airfield runway. WWL offered to undertake an on the ground re- survey of the airfield runway and Airey Consultants Ltd undertook to produce an OLS design (the Airey design) to be used for Variation 2.  The 1:7 OLS is an unnecessary constraint for development around the airfield since it is unrealistic that the foreseeable use of the airfield will ever necessitate this level of protection.  Recognition of the airfield as an important existing and future air transport facility, while noting the current economic constraints that limit any substantial investments into upgrading the facility.  The Club want to attract quality air transport services, charter and scheduled, based on small commuter type aircraft (typically less than 20 seats).

7. Variation 2 was drafted in cognisance of the issues raised during the discussion with relevant parties, recommendations made by Dave Park in his draft report and a physical survey (undertaken by WWL) on the actual location of both runways for Code 2 Day operations. The following specifications were used to manage OLS requirements for Variation 2:

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Table 1: Runway dimensions consistent with Airey Consultant’s design - main runway 1351m x 80m; subsidiary runway 34/16 640m x 60m

Specification Code 2 non-instrument air transport day/night

Approach and take-off

Inner edge length 80m

Distance from threshold 30m

Divergence 1:10

Length 3000m

Upslope 1:40

Transitional (side surface)

Upslope 1:5

Inner Horizontal

Height 45m

Locus from strip edge 2500m

Conical

Slope 1:20

Height above aerodrome 150m

The management and operation of the airfield – Background

8. Submitters and further submitters stated that the MBAC is better qualified to manage and dictate the future direction and operation of the airfield. This is why Variation 2 was drafted based on consultation with the MBAC. I note in this context that OLS specifications used for District Plans serve the sole purpose of protecting airfield operations from potentially encroaching development and reverse sensitivity.

9. The District Plan OLS determines the degree and location of height controls in the vicinity of the airfield, it cannot and should not determine how the airfield is actually operated. This is a matter that is managed between the CAA, the airfield owner and operator and the aircraft operators.

10. The Council needs to protect regional transport assets in a way that is consistent with Objective 5 in Section 18 Transport (‘Subdivision, use and development adjacent to the District’s airfields, wharves and Marine Service Zones do not significantly adversely affect the 4

operation, future development and expansion of those airfields, wharves and Marine Service Zones’). Protecting the airfield from potential obstacles and reverse sensitivity is the Council’s task under the Resource Management Act. Operating the airfield within the requirements of the CAA is the MBAC’s obligation.

11. Submitters and further submitters acknowledged the achievements and on-going positive contribution that the MBAC makes to the local community, including the business community, which is recognised.

ANALYSIS AND RECOMMENDATIONS

Show the main runway strip in its actual location on the planning maps

12. All submitters and further submitters support the correct representation of the runway strip on the planning maps.

13. Submitter 25 (Whitianga Waterways Ltd) requests the runway to be shown according to Airey Map (dated March 2017).

14. Submitter 23 (Keith Vernon) additionally seeks extension of the main runway transitional side upslope to a height of 45m. The next part of this report (which deals with the OLS) will concern itself with this matter.

Recommendation and reasons

15. R 1.1: Runway to be shown in its correct location according to a Council created Map 17D showing the correct OLS.

16. Reasons for Recommendations

a) Both the Operative Plan and the Plan showed the runway incorrectly located on the planning maps. b) The Airey Map does not show the correct OLS.

Point # Submitter Accept/ Recomm FS Point Submission topic Reason Further submitter Reject endation # David Cranna 1.1 Main runway strip shown in correct Accept R 1.1 a) location Whitianga Waterways Ltd – FS 25 But according to the Airey Consultants Reject R 1.1 a)b) support Ltd Plan

Keith Vernon-Support FS 23 BUT KV seeks extension of OLS to inner Accept R 1.1 a)b) horizontal edge at a height of 45m - Grant Biel 6.1 Main runway strip shown in correct Accept R 1.1 a)

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location Keith Vernon - partly oppose and FS 23 with amendments as per KV partly support Mercury Bay Aero Club -support 9.1 Main runway strip shown in correct Accept R 1.1 a) John Hart - support FS 2 location Accept Kevin Paulsen - support FS 3 Accept Philip Hart - support FS 4 Accept Peter Armstrong - support FS 5 Accept Leanne Butler - support FS 7 Accept Kevin Rintoul - support FS 8 Accept Peter D Scandrett - support FS 10 Accept Wallace Pendray - support FS 13 Accept Richard Hood - support FS 15 Accept Anthea H Austin - support FS 17 Accept Peter L Austin - support FS 18 Accept Douglas A St George - support FS 19 Accept Harold Abrahamson - support FS 20 Accept Steve Brown Douglas - support FS 21 Accept Brian H Wigley - support FS 22 Accept Keith Vernon - partly oppose and FS 23 Accept partly support Accept Stephen J Chilcott - support FS 24 Accept Rachel Ervine - support FS 27 Accept Stephan Bosman - support FS 29 Accept Christine Rabarts - support FS 30 Accept Geoff Cooper (Fly DC3 NZ Inc.) - FS 31 Accept support Accept Gavin Magill – support FS 32 Accept Keith Vernon-support FS 23 Accept John Stephenson -support 16.1 Main runway strip shown in correct Accept R 1.1 a)b)c) location Keith Vernon – support FS 23 Accept R 1.1 a)b)c) Whitianga Waterways Ltd - support FS 25 Needs to be shown according to Airey Reject R 1.1 in part Consultants Ltd plan (dated March 2017) Ross L Walker - support FS 26 Accept R 1.1 a)b)c) Whitianga Waterways Ltd 25.1 Main runway strip shown in correct Reject R 1.1 a)b) location Keith Vernon - support FS 23 Subject to other KV points Support R 1.1 a)b) with suggested changes

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Amend main runway transitional surfaces (OSL) from 1:7 to 1:5

17. Most submitters and further submitters support the change of the OLS from 1:7 to 1:5. Submitter 23, Keith Vernon, seeks an extension of the 1:5 OLS upslope to 45 m in accordance with AC139-6. The Council expert confirmed that Submitter 23 is correct in pointing out that the Map 17D needs to show the 1:5 OLS upslope to 45m.

18. Submitter Alan Hopping (for ‘The Lost Spring’) opposes all changes to the Operative District Plan including the change from 1:7 to 1:5. In the same vein Mr Hopping supports all points made by the MBAC. A fair assumption can be made that Mr Hopping’s opposition to the 1:5 OLS might be due to a mistake when filling in the submission form. In any case the retention of a 1:7 OLS is not supported for the reasons provided in paragraph 6 of this report with further detail available in the Council Report Variation 2. Mr Hopping wishes to be heard and will be able to clarify his position at the hearing. For the purposes of this report it is assumed that Mr Hopping supports the change from 1:7 to 1:5.

Recommendations and Reasons

19. R 1.2: OLS to be shown as 1:5 for main runway strip with the transitional upslope extending to a height of 45m.

20. Reasons for Recommendations: a) The 1:7 OLS would unnecessarily restrict development on sites adjacent to the airfield. b) Existing dwellings would not be able to comply with the 1:7 OLS. c) Given the surrounding topography there is no realistic prospect of the airfield ever expanding its scope of operation to justify a 1:7 OLS. d) Showing the transitional upslope extending to a height of 45 m is the correct CAA standard for Code 2 non-instrument operation as specified in AC139-6. (Please refer to Appendix 1 Section 4).

Point # Submitter Accept/ Recomm FS Point Reason Further submitter Submission topic Reject endation # David Cranna 1.2 Change 1:7 to 1:5 Accept R 1.2 a)b)c) Whitianga Waterways Ltd – FS 25 support Keith Vernon - Support FS 23 a)b)c)d)

Grant Biel 6.2 Change 1:7 to 1:5 Accept R 1.2 a)b)c) Whitianga Waterways Ltd – FS 25 support Keith Vernon -support FS 23 +1:5 supported subject to OLS R 1.2.1 a)b)c)d)d) extending to inner horizontal edge at 45m.

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Ken Heslin 11.2 Change 1:7 to 1:5 Accept R 1.2 a)b)c)

Keith Vernon – support FS 23 a)b)c)d) John Stephenson 16.2 Change 1:7 to 1:5 Accept R 1.2 a)b)c) Whitianga Waterways Ltd - support FS 25 Ross L Walker – support FS 26 Keith Vernon - support FS 23 + inner horizontal at height 45m R 1.2 a)b)c)d) Keith Vernon 23.1 Show main runway OLS 1:5 extending Accept R 1.2 d) Whitianga Waterways Ltd - oppose1 FS 25 to inner horizontal height of 45 m in Reject R 1.2 d) accordance with AC 139-6 (22m from outer edge of runway width of 80m). Whitianga Waterways Ltd 25.2 Change 1:7 to 1:5 Accept R 1.2 a)b)c)d) The transitional surface of 1:5 to a height of 45 m above airfield height datum

Keith Vernon - support FS 23 Subject to inner horizontal edge at a Accept R 1.2 a)b)c)d) height of 45 m

Restriction on aircraft greater than 5700 kg using the airfield

21. All submitters and further submitters (except Submitter 23, Keith Vernon) oppose a weight restriction. The Council expert is not concerned about lifting the weight limit in particular since this would allow the DC3 at a weight of 14,100kg. The DC3 is a Code 3 aircraft however the Council expert believes that it is for the operator of the aircraft to address any operational issues arising. The Council expert further notes that the AIP already contains a MAUW restriction of less than 5700 kg (based on single wheel load of 1270 kg) specified by the airfield operator.

22. Further submitter 23 (Keith Vernon) supports that weight restrictions remain in Table 1 and argues that MCTOW is a critical design/operational parameter.

23. Submitter 16 (John Henry Stephenson) says in his submission opposing the weight restriction that Whitianga is a strategically large airfield on the eastern seaboard of the peninsula and that it would play a key role in any potential Civil Defence emergency. To place a weight restriction on the airfield would seriously limit its usefulness. I concur with Mr Stephenson’s view. I would like to add that Mr Stephenson’s position is of overall importance when considering whether to restrict the airfield’s operational scope. The potential use of the airfield as an alternative transport asset in emergencies needs to be considered for all design parameters including the 1:40 upslope.

1 It is noted that it seems that in this instance Mr Vernon and WWL are seeking the same relief though.

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24. MBAC and a number of further submitters argue that the Whitianga airfield has become a popular destination for the DC3 for Charters and weekend visits and is a valuable source of income for the Club and the local community. Paragraph 21 of this report presents the Council expert’s comment on relaxing the weight restrictions in Table 1 to allow for the DC3 to use the airfield. I concur with these comments and do not recommend provisions that would restrict the use of the DC3 on the Whitianga airfield and that go beyond what the Council’s role is in this process. Paragraph 37 explains how the 1:40 upslope surface on both ends of the main runway is vital to enable the DC3 to use the Whitianga airfield.

25. Further submitter 30 (Christine Rabarts, owner of the Bread&Butter Gallery Whitianga), supports all MBAC submission points and states that the DC3 flights are a key means of transportation for her clients, making Whitianga accessible as a day event outing for groups of people. The submitter adds that the DC3 is operated voluntarily by pilots and crew which comes to huge yearly costs. The regular ‘bread&butter flights’ help making DC3 maintenance and operation financially viable and available for the whole of New Zealand to enjoy. These are valid arguments in support of retaining the airfield’s accessibility for a variety of aircraft which is consistent with Objective 5 in Section 18 of the Plan.

Recommendations and Reasons

26. R 1.4 Lift restrictions on maximum landing weight in Table 1, Section 28 1.1. 27. Reasons for Recommendations: a) Restrictions on landing weight are an operational issue to be addressed by the airfield owner and the operator of an aircraft. b) Allow for the continued operation of the DC3 on the Whitianga airfield. c) Allow for potential emergency operations on the airfield without weight restrictions.

Point # Submitter Accept/ Recomm FS Point Submission topic Reason Further submitter Reject endation # David Cranna – oppose 1.4 Restriction of MCTOW Accept R 1.4 a)b)c) Whitianga Waterways Ltd - FS 25 Accept support Keith Vernon oppose FS 23 Reject

Grant Biel support 6.4 Lift Restriction of MCTOW Accept R 1.4 a)b)c) Whitianga Waterways Ltd – FS 25 Accept support Keith Vernon oppose FS 23 Reject R 1.4 Mercury Bay Aero Club 9.4 Lift Restriction of MCTOW Accept R 1.4 a)b)c) John Hart - support FS 2 Accept Kevin Paulsen - support FS 3 Accept Philip Hart - support FS 4 Accept Peter Armstrong - support FS 5 Accept Leanne Butler - support FS 7 Accept 9

Kevin Rintoul - support FS 8 Accept Peter D Scandrett - support FS 10 Accept Wallace Pendray - support FS 13 Accept Richard Hood - support FS 15 Accept Anthea H Austin - support FS 17 Accept Peter L Austin - support FS 18 Accept Douglas A St George - support FS 19 Accept Harold Abrahamson - support FS 20 Accept Steve Brown Douglas - support FS 21 Accept Brian H Wigley - support FS 22 Accept Stephen J Chilcott - support FS 24 Accept Whitianga Waterways Ltd - support FS 25 Accept Rachel Ervine - support FS 27 Accept Stephan Bosman - support FS 29 Accept Christine Rabarts - support FS 30 Accept The Lost Spring - oppose FS 28 Accept Geoff Cooper (Fly DC3 NZ Inc.) - FS 31 Accept support Gavin Magill – support FS 32 Accept Keith Vernon-opposed FS 23 Limit should be around 4000kg max Reject Ken Heslin 11.5 Lift Restriction of MCTOW Accept R 1.4 a)b)c) Keith Vernon – oppose FS 23 Reject Whitianga Waterways Ltd - support FS 25 Accept Jan Kenny - oppose 12.2 Restrictions of MCTOW Accept R 1.4 a)b)c) Whitianga Waterways Ltd - support FS 25 Supports change to Table 1 Accept in part Keith Vernon - support FS23 Reject John Stephenson -support 16.6 Lift Restrictions of MCTOW Accept R 1.4 a)b)c) Ross L Walker – support FS 26 Accept Keith Vernon -oppose FS 23 Reject Whitianga Waterways Ltd 25.4 Lift Restrictions of MCTOW Support T 1.4 a)b)c) Keith Vernon -oppose FS 23 Reject

Reduction in main runway length

28. Variation 2 Attachment 3 Map 17D depicts the main runway at 1265x80m catering for Code 1 and Code 2 aircraft. Code 2 covers most (but not all) 19 seat air transport aircraft including the Beech 1900D (Air NZ), the Jetstream 31 and the Bombardier (now Viking) Twin Otter (both operated previously in New Zealand). It also covers the modern generation of single engine pressurised air transport aircraft such as the Pilatus PC12 operated by Sounds Air. Code 2 also includes some versions of the De Havilland Dash 8-100 and -300 (up to 50 seats), also previously operated by several NZ airlines, and the 50 seat ATR42 (a smaller version of the ATR72 operated by Air New Zealand). It does not cover the ATR72 (68 seats) as this is Code 3. The main runway 04-22 is technically a Code 3 runway as it is > 1200m long. Code 1 is up to 800m, Code 2 is 800-1200m, Code 3 1200-1800m. However the runway is currently unsealed

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with no lighting or fixed wing aircraft instrument approach procedures which limits the types of aircraft and operations possible.

29. All submitters (except Submitter 23, Keith Vernon) and further submitters oppose a reduction of the runway length and support the Map Airey Consultants drafted (the Airey Map) in support of submission 25 (Whitianga Waterways Ltd) and submission 9 (MBAC). The key reason provided by submitters for opposing a reduced runway length is their desire to allow for an optimal flexibility of the airfield’s use. Another important concern that submitters and further submitters bring forward is the continued ability of the DC3 to land in Whitianga.

30. Submitter 23, Keith Vernon, seeks the main runway length of 1427m to be shown with 1:40 upslope and clearance from the State Highway at the 04 end. The Council’s expert commented as follows: “There is no intention to reduce the maximum runway length available below that applicable to a 1:20 take-off and approach OLS and the airfield can be configured in this way if the airfield operator wishes and the CAA agree. However small twin engined commuter aircraft, and the DC3, cannot realistically comply with a 1:20 climb-out gradient in the event of engine failure on take-off, therefore distances for 1:40 gradient (which can more easily be complied with) should be provided in the AIP by the airfield operator and the flight path past the road at each end of the runway should be protected in the Plan to 1:40 gradient to better ensure those aircraft can operate now and in the future.” In response to Mr Vernon’s relief point to keep the runway at a length of 1427m, the Council expert explains that a slight reduction is necessary to achieve adequate vehicle clearance of the highway at the SW runway end (Please also refer to Appendix, Section 4).

31. Submitter 16 (John Henry Stephenson) points out in his submission, which opposes a reduction of the operational runway length, that although Code 2 only requires a minimum of 1200m runway, additional length is better because it provides a ‘starter extension’ and a runway over-run area. These are very tangible safety features particularly in bad weather. The Council’s expert concurs with this view and there is no intention to reduce the operational length of the runway. The actual reduction of the runway’s operational length is triggered by a conceptual road on private land adjacent to the airfield as represented on the Airey Map and by providing the correct clearance over the road at the SW end.

32. While the Council supports the retention of the Whitianga airfield as a key strategic transport asset, it is noted that the Airey Map shows that the runway – represented at 1526m on the official CAA aerodrome chart – is reduced to 1351m at 1:20 due to a conceptual road for a future subdivision on adjacent land. This has the effect of pushing the fan origin further south west along the runway. According to the Council expert’s advice the runway length with the 1:40 upslope (as per recommendations in Appendix 2) allows for a greater variability of aircraft including the DC3 than the option presented by the Airey Map with the 1:20 upslope. Securing additional runway length is supported, if this is achievable within MBAC owned land.

Recommendations and Reasons

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33. R 1.5: Change Map 17D as per the Council expert’s recommendations with a 1:40 upslope (Appendices 1 and 2).

34. Reasons for recommendations: a) The decision on how the MBAC chooses to use the actual operational length of the runway should be left with MBAC without any Council imposed restrictions. b) Map 17D shows the runway at 1265m with a 1:40 upslope. These dimensions are based on the latest on the ground survey (done by WWL) and the outcomes of consultation with the MBAC and Whitianga Waterways Ltd. It needs to be amended at the SW end because the 1:40 upslope origin point does not allow the required clearance over the highway at that end, and at the NE end to remove the restriction imposed by the future road sought by WWL. c) It allows for a variety of passenger planes to safely use the airfield including safe operation of the DC3. d) Map 17D (Variation 2) does not curtail the operational length of the airfield as it can still be operated as a 1:20 should MBAC wish. However providing for the 1:40 OLS in the Plan ensures protection of the take-off and approach paths for small commuter aircraft and DC3 operations. A conceptual road on neighbouring property to the North East of the end of runway would reduce the runway length by up to 90m at 1:20 and up to 200m at 1:40.

Point # Accept/ Recomm Submitter FS Point Submission topic Reason Reject endation Further submitter # David Cranna – oppose 1.5 Reduction of runway length Accept R 1.5 a)b)c) Whitianga Waterways Ltd support FS 25 Reject d) in part Keith Vernon support FS 23 Specifics from KV as per other Accept a)b)c) submission points Grant Biel oppose 6.5 No Reduction of runway length Accept R 1.5 a)b)c) Whitianga Waterways Ltd - support FS 25 Runway to be shown as 1265 m inner Reject d) in part edge to inner edge

Keith Vernon -support FS 23 Specifics from KV as per other Accept a)b)c) submission points Mercury Bay Aero Club 9.6 No Reduction of Runway Length Accept R 1.5 a)b)c) John Hart - support FS 2 Kevin Paulsen - support FS 3 Philip Hart - support FS 4 Peter Armstrong - support FS 5 Leanne Butler - support FS 7 Kevin Rintoul - support FS 8 Peter D Scandrett - support FS 10 Wallace Pendray - support FS 13 Richard Hood - support FS 15 12

Anthea H Austin - support FS 17 Peter L Austin - support FS 18 Douglas A St George - support FS 19 Harold Abrahamson - support FS 20 Steve Brown Douglas - support FS 21 Brian H Wigley - support FS 22 Stephen J Chilcott - support FS 24 Whitianga Waterways Ltd - oppose FS 25 in part Rachel Ervine - support FS 27 Stephan Bosman - support FS 29 Christine Rabarts - support FS 30 The Lost Spring - oppose FS 28 Geoff Cooper (Fly DC3 NZ Inc.) - FS 31 support Gavin Magill - support FS 32 Keith Vernon - support FS 23 With further amendments to Map 17D Ken Heslin – support 11.5 No Reduction of Runway Length Accept R 1.5 a)b)c) Keith Vernon – support FS 23 With further amendments to Map 17D John Stephenson 16.5 No Reduction of Runway Length Accept R 1.5 a)b)c) Ross L Walker - support FS 26 Whitianga Waterways Ltd - oppose FS 25 Main runway to be shown as 1265m Reject d) in part from inner edge to inner edge Keith Vernon -support FS 23 Accept a)b)c) Keith Vernon 23.2 Show main runway length as 1427m Accept R 1.5 a)b)c) and positioned to ensure 1:40 upslope at the 04 end clear the road adequately. Whitianga Waterways Ltd -oppose FS 25 Reject d)

Fan at both ends of main runway are shown as 1:40 surface gradient on planning map

35. All submitters and further submitters oppose the change of the surface gradient from 1:30 (as per the Operative District Plan) to 1:40 and support a 1:20 surface gradient (as per the Airey Map) on both ends of the runway.

36. Submission 23 (Keith Vernon) seeks the main runway to be shown at a length of 1427m with 1:40 upslope gradients, the upslope gradient at the 04 end being of particular importance to allow for clearance over the highway.

37. The Council expert’s advice is that the 1:20 is a minimum standard and a number of aircraft cannot achieve that climb gradient in the engine inoperative situation on take-off, in particular the DC3 (which is actually a Code 3 aircraft) is unable to do this. This is a requirement under their operating rules and applies day or night. Therefore with a 1:20 gradient OLS these

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aircraft could be substantially penalised on take-off weight or not be able to operate at all. This would be contrary to Objective 5 of Section 18.3 Transport.

38. The Council’s expert further notes that there is no objection to the airfield being laid out as a 1:20 on the ground. The Council expert notes that this is a CAA issue for the operator to address. I concur with this view and recommend to leave it to the airfield operator to layout its runway length as it chooses.

39. What the expert is more concerned about is protecting the flight paths away from the airfield, specifically across and beyond the roads at each end so the 1:40 is not encroached for the future. This is not an operational but a planning issue under the Resource Management Act 1991. Whitianga aerodrome is the only facility on the east Coromandel Coast north of that can accommodate larger air transport aircraft. It cannot be replaced as a piece of the Region's air transport infrastructure.

40. The MBAC is relying on Plan provisions to enforce height controls hence the Council needs to have a say on what the level of control should be, especially as MBAC are asking the Council to relax the existing 1:30 (planning) control in the Operative District Plan. Height controls do not result in any financial obligations for the MBAC and do not interfere with the current goals the MBAC has set itself in terms of how it wants to operate the airfield. While acknowledging that the airfield is in private ownership and has been successfully operated privately for the last 50 years, the Council has an obligation to secure a realistic level of protection on surrounding land to safeguard the airfield’s continued successful operation under changing circumstances.

41. The Council expert’s view is that: “The 1:20 OLS would adversely affect the ability for twin engine commuter type aircraft to operate at the airfield. This is because these aircraft are not capable of safely operating at 1:20 on approach or take-off.”

42. The Council expert believes it would be possible to set up thresholds based on the 1:40 upslope which would be 70m further out than the Airey 1:20 thresholds at the north east (22) end (after removal of the future road constraint) and 125m at the south west (04) end. These reduced thresholds he believes would still give 1170m for landing. (Please refer to Appendix 1, Section 2)

Recommendations and Reasons

42. R 1.3: Retain the transitional surface gradient of 1:40 on both ends of the runway on Planning Map 17D.

43. Reasons for recommendations: a) The 1:20 is a minimum standard for Code 2 aircraft and a number of aircraft cannot achieve that climb gradient in the engine inoperative situation on take-off, in particular the DC3 (which is actually a Code 3 aircraft) is unable to do this.

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b) The change from 1:30 (as per Operative District Plan) to 1:20 has been justified by MBAC and Whitianga Waterways Ltd as a consequence of restricting the airfield operation to daylight/non-instrument only. It has not been considered that a number of planes would be penalised by this lack of protection and might not be able to use the airfield in the future. c) Whitianga aerodrome is the only facility on the east Coromandel Coast north of Tauranga that can accommodate larger air transport aircraft. It cannot be replaced as a piece of the Region's air transport infrastructure. d) While acknowledging that the airfield is in private ownership and has been successfully operated privately for the last 50 years, the Council has an obligation to secure a realistic level of protection on surrounding land for the airfield’s continued successful operation under changing circumstances. e) The airfield can be operated at a 1:20 upslope gradient, the 1:40 protection is a purely planning related concern to protect the airfield from height encroachment on neighbouring properties.

Point # Submitter Accept/ Recomm FS Point Submission topic Reason Further submitter Reject endation # David Cranna-oppose 1.3 1:40 upslope Reject R 1.3 a)b)c)d)e) Whitianga Waterways Ltd - FS 25 However Runway shown as 1265m support in part inner edge to inner edge. Keith Vernon support If daylight operations only Grant Biel - support 6.3 Change 1:40 gradient to 1:20 Reject R 1.3 a)b)c)d)e) Whitianga Waterways Ltd – FS 25 support Keith Vernon support FS 23 1:5 (KV suggests 45m extension to inner horizontal edge) Mercury Bay Aero Club 9.2 Change 1:40 gradient to 1:20 Reject R 1.3 a)b)c)d)e) John Hart - support FS 2 Kevin Paulsen - support FS 3 Philip Hart - support FS 4 Peter Armstrong - support FS 5 Leanne Butler - support FS 7 Kevin Rintoul - support FS 8 Peter D Scandrett - support FS 10 Wallace Pendray - support FS 13 Richard Hood - support FS 15 Anthea H Austin - support FS 17 Peter L Austin - support FS 18 Douglas A St George - support FS 19 Harold Abrahamson - support FS 20 Steve Brown Douglas - support FS 21 Brian H Wigley - support FS 22 Stephen J Chilcott - support FS 24 Whitianga Waterways Ltd - support FS 25 Rachel Ervine - support FS 27 15

Stephan Bosman - support FS 29 Christine Rabarts - support FS 30 The Lost Spring - oppose FS 28 Geoff Cooper (Fly DC3 NZ Inc.) - FS 31 support Gavin Magill – support FS 32 Keith Vernon-support FS 23 Subject to extending inner horizontal at a height of 45 m Ken Heslin 11.3 Change 1:40 to 1:20 Reject R 1.3 a)b)c)d)e) Keith Vernon -support FS 23 If only for daylight operations John Stephenson -support 16.3 Change 1:40 to 1:20 Reject R 1.3 a)b)c)d)e) Whitianga Waterways Ltd - support FS 25 Ross L Walker – support FS 26 Keith Vernon - support FS 23 Whitianga Waterways Ltd 25.3 Change 1:40 to 2:20 Reject R 1.3 a)b)c)d)e) Keith Vernon -- support FS 23 For daylight only

Restrictions on Night/Instrument Flying

44. The MBAC opposes future-proofing the airfield for Code 2 night operations on the grounds of:  High Terrain adjacent to and surrounding the airfield  The slim likelihood of any practical demand for night operations during winter  The cost of installing and maintaining runway and ‘lead-in ‘ lighting  The cost of installing and maintaining an instrument approach system  Opposition by the community to noise arising from night operations

45. MBAC supports maintaining the airfield for day only VFR which in their view would reduce restrictions on the airfield infrastructure and assist in relaxing conditions on surrounding land development. MBAC’s reasoning for opposing future-proofing of the airfield for night operations is conclusive and should be accommodated for by changing Table 4 to exclude night operations. It is noted here that it is the Council expert’s view that fore-closure of instrument/night operations is a short-sighted decision within the context of the sparsity of flat land available on the eastern seaboard. It is however important in this context to understand that the 1:40 upslope OLS is not only important for potential night operations, it is essential for operating small twin-engined commuter aircraft.

46. Submitter 16 (John Henry Stephenson) argues against night-time commercial operations on the grounds of community noise considerations. Further submitter 26 (Rachel Ervine) supports all points made in submission 16. Mr Stephenson’s argument is aligned with what our expert’s view is. My recommendations on this issue are mainly based on the fact that the airfield is privately operated and if the Aero Club does not receive substantial financial support, they will be unable to upgrade the airfield.

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47. Submitter 28 (Stephen John Chilcot) argues that it is short-sighted to limit instrument flights from the airfield since in the future small airlines may choose to operate a scheduled all- weather service. While I concur with Mr Chilcot’s concerns, paragraphs 8 and 9 of this report explain how the Council intends to leave operational decisions to the MBAC and paragraph 45 provides conclusive arguments against the necessity to protect for future instrument operations.

Recommendations and Reasons

48. R 9.5: Allow for daylight only/non instrument flying on the Whitianga airfield by changing Table 1 of Section 28.1.1 to this effect.

49. Reasons for recommendations: a) High Terrain adjacent to and surrounding the airfield b) The slim likelihood of any practical demand for night operations during winter c) The cost of installing and maintaining runway and ‘lead-in‘ lighting d) The cost of in installing and maintaining an Instrument Approach System e) Opposition by the community to noise arising from night operation

Point # Submitter Accept/ Recomm FS Point Submission topic Reason Further submitter Reject endation # Mercury Bay Aero Club 9.5 Delete night and instrument flying Accept R 9.5 a)-e) Whitianga Waterways Ltd - support FS 25 Rachel Ervine - support Stephan Bosman - support FS 27 Christine Rabarts - support FS 28 Geoff Cooper (Fly DC3 NZ Inc.) - FS 30 support FS 31 Gavin Magill – support FS 32 Keith Vernon - support FS 23 Jan Kenny - support 12.4 Daylight only operations Accept R 9.5 a)-e) Whitianga Waterways Ltd – FS 25 support Keith Vernon - support FS 23 John Stephenson -support 16.4 Daylight only operations Accept R 9.5 a)-e) Whitianga Waterways Ltd - FS 25 support Ross L Walker – support FS 26 Keith Vernon -support FS 23 Keith Vernon 23.3 Either include night curfew or Reject R 9.5 a)-e) allow for daylight only and adjust OLS accordingly. Whitianga Waterways Ltd - FS 25 Accept oppose Whitianga Waterways Ltd 25.5 Daylight only operations Accept R 9.5 a)-e) Keith Vernon - support FS 23

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Other Matters

50. Submitter 23 (Keith Vernon) comments that the wording in Table 1 of section 28.3 ‘…until the maximum building height standard of the underlying zone is reached’ is confusing because the slope extends over more than one zone. 51. R 23.1 Change wording in Table 1, Section 28.3 Airfield Height as it refers to the Whitianga main runway to: 1:5 until a height of 45m above the ground level2 of the runway is reached.

2 Ground level will need to be established through survey.

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ATTACHMENT 1

Deletions to notified Variation 2 are marked as strikethrough, recommended changes are marked in bold italics underlined.

Section 28 – Airfield Height and Noise

28.1 Background

28.1.1 Airfield use height overlay

Table 1 –Parameters to Set the Plan Obstacle Limitation Standards

Airfield Runway Night/instrument Aeroplanes > 5700 Passenger air (runway) >800m long flying kg MCTOW* transport

Coromandel No No No No

Pauanui No No No No

Thames (main) Yes Yes No No

Thames No No No No (subsidiary)

Whitianga Yes YesNo No Yes Yes (main)

Whitianga No No No No (subsidiary)

*Maximum Certified Take-Off weight

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Section 28.3 Airfield Height

Rule 1 All Activities

Table 1- Obstacle limitation surface (as shown in the Planning Maps)

Take-off/approach surface Transitional side surface gradient from Airfield runway gradient from the ends of the the sides of the runway strip runway strip

Coromandel 1:20 1:4 until 2 m height is reached

1:5 until the maximum building height 1:20 standard of the underlying zone is reached

1:5 until the maximum building height Thames (main) 1:40 standard of the underlying zone is reached

1:4 until the maximum building height Thames (subsidiary) 1:20 standard of the underlying zone is reached

1:5 until the maximum building height standard of the underlying zone is Whitianga (main) 1:40 reached a height of 45m above the ground level of the runway is reached

Whitianga 1:20 1:4 until 2m height is reached (subsidiary)

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MEMO Astral Limited

TO: ELISABETH RESL

FROM: DAVE PARK

DATE: 14 NOV 2017

RE: WHITIANGA AIRFIELD HEIGHT CONTROLS RUNWAY 04-22

I have reviewed the submissions on Variation 2 and the Variation itself (as attached in Figure 1), which I understand is based on an airfield layout supplied by Whitianga Waterways Ltd (WWL) and designed by Airey Consultants Ltd who are engaged by WWL.

My comments are confined to the obstacle limitation surface (OLS) design for runway 04-22, which is the basis of the height controls for that runway. I have assumed the runway is non-instrument and primarily intended for aircraft up to and including “Code 2” as defined in CAA Advisory Circular AC139-6 on air transport operations.

I have previous passed you my comments on the relevant submissions on Variation 2 (with the exception of WWL’s submission). This memo addresses the Airey Consultant’s design and WWL’s submission which is based on the Airey design. I also comment on further on Mr Vernon’s submission which I believe has suggestions that should be adopted.

My overall approach is to try to ensure the airfield has the best practicable height control protection from encroachment by future off-airfield obstructions, such as buildings and especially in the take- off and approach paths, because these could adversely affect the airfield’s capacity to accommodate future air transport operations by Code 2 aircraft.

How the runway is actually set out on the ground is a matter for the aeroclub to determine in accordance with CAA requirements.

I conclude with recommendations to the Commissioners on changes to Variation 2.

1. Protection of 1:40 upslope (WWL Submission)

I remain of the view that the 1:40 OLS upslope must be protected from off-airfield development that could penetrate it (but not penetrate a 1:20 upslope) it as that would adversely affect the ability for twin engined commuter type aircraft to operate at the airfield. This is because these aircraft are not capable of safely operating at 1:20 on approach or take-off. The requirement, in terms of both certification by the CAA and operation, for these aircraft is generally 1:40.

The impact of laying out the airfield in compliance with 1:40 compared to 1:20 is actually quite small, being minus 20m of 04 take-off distance, minus 125m on 22 take-off distance, minus 125m on 04 landing distance and minus 20m on 22 landing distance.

2. Current potential

I have assessed the airfields current potential to accommodate a 1:40 OLS upslope on both take-off and landing. There are some assumptions on survey levels in this, but I believe the figures are accurate to plus or minus 20m. I have allowed for 4.5m vehicle clearance over the existing highway at each runway end, and for the location of the airfield’s NE boundary. As the runway is currently configured it appears to extend slightly into the adjoining property owned by WWL.

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For runway 04, a take-off-distance at 1:40 of approximately 1420m is currently possible and on runway 22, 1200m. For landing on 04, a distance of approximately 1170m is currently possible at 1:40 and on 22, 1397m.

The disparity between runway directions is largely due to the large amount of “inset” of both take- off and landing points at the south west (SW) runway end to provide 4.5m high vehicle clearance over the highway. This is not adequately accounted for in the current runway set-out.

Code 2 aircraft nominally require 800-1200m long runways which the above figures meet (the 30m shortfall from 1200m on 04 landing not being significant in design terms).

3. Airey Consultant’s Design

There are two features to this design, which are incorporated in the Variation 2 OLS layout, that I am concerned with because they detract from the airfield’s current potential.

a. Proposed road

At the north east (NE) runway end the Airey design provides 4.5m clearance over a proposed future road running along the airfield’s north boundary cutting in towards the runway end on an oblique angle. This is shown in Figure 2 attached. I understand this proposed road is not included in Council planning proposals, therefore I have not included it in my assessment of the 1:40 (or the 1:20) NE OLS origin points.

The proposed road would have a detrimental effect of minus 90m on take-off runway length available on 04 at 1:20, and minus 200m at 1:40. There is no effect on runway 22 take-off.

The effect on landing distance on 22 would be minus 90m (1:20) and minus 200m (1:40). There would be no effect on 04 landing.

b. Use of 1:20 upslope for OLS design

The use of 1:20 upslope for OLS design will allow higher development closer to the runway ends compared to 1:40. While this maximises the potential to develop land around the airfield, it is at a significant cost to the existing and future capability of the airfield to accommodate Code 2 aircraft that cannot operate to 1:20.

Figure 3 illustrates the effect of high buildings that penetrate the 1:40 but not the 1:20. Figure 4 shows where the impact could occur at the NE runway end on land currently not developed.

4. Mr Vernon’s submission

Mr Vernon submitted that the 1:5 transitional surface should extend up to a height of 45m i.e. a lateral extent of 225m compared to 75m specified in Variation 2. Mr Vernon is correct, as this is the CAA standard for Code 2 non-instrument specified in AC139-6.

Mr Vernon also submitted that he opposes reducing the main runway length to 1265m, and that it should be 1427m. Reduction below 1427m is necessary to achieve adequate vehicle clearance of the highway at the SW runway end, however I concur with Mr Vernon’s sentiment that any reduction in runway length should be the minimum possible and for that reason I do not support providing for the proposed future road at the NE end as included in Variation 2.

Including allowance for vehicle clearance on this road (as shown in the Airey design) reduces the take-off and landing distance possible by up to 90m at 1:20, and by up to 200m at 1:40.

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5. Recommendation to Commissioners a. I recommend the Commissioners reject WWL (and other submissions) which seek to increase the OLS upslope to 1:20, on the basis that 1:20 does not provide adequate control of off-airfield obstacles to ensure the take-off and landing distances required by Code 2 commuter aircraft are maximised.

b. I recommend the following changes to Variation 2, based on Mr Vernon’s submission: i. Extend the runway 04-22 transitional surface laterally out to 225m instead of 75m. ii. Move the origin of the NE 1:40 OLS outward (i.e. further in the NE direction) by approximately 70m, the exact figure to be determined by survey to allow 4.5m clearance of the take-off and approach surfaces over the highway.

c. I further recommend a correction of the OLS origin location at the SE runway end, as depicted in the Variation 2 Airfield Height Restriction Overlay to allow for clearance of the take-off and approach surfaces at 1:40 over the highway at that runway end, based on Mr Vernon’s submission. This will require the OLS origin location to move inwards (i.e. to the NE) by approximately 125m, the actual figure again to be confirmed by survey.

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Figure 1: Variation 2 as notified Figure 2: Location of proposed road included in Variation 2

Without future road included OLS origin point (inner edge) can move NE 70m at 1:40

70m Proposed future road

Figure 3: Effect of 1:40 OLS upslope in protecting for off-airfield obstacle encroachment

Figure 4: Effect of high buildings penetrating 1:40 OLS upslope

Buildings in this area 8m high (permitted by 1:20 upslope) would reduce runway 04 1:40 take-off distance by approximately 160m