Planning: Anita Copplestone and Phillip Percy
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Report pursuant to s42A Resource Management Act 1991 In the matter of: A Notice of Requirement to construct and operate a new intermodal rail and freight hub on land between Palmerston North and Bunnythorpe And: A hearing by Palmerston North City Council pursuant to s100A Requiring Authority: KiwiRail Holdings Ltd Hearing date: 9 August 2021 S42A Technical Evidence: Planning By: Anita Copplestone and Phillip Percy, Consultant Planners 1 Executive Summary 1.1 Purpose of this report 1. KiwiRail Holdings Limited has lodged a Notice of Requirement for a Regional Freight Hub with Palmerston North City Council. The NOR is for a designation for the construction and operation of an intermodal rail and freight facility. 2. An Independent Hearing Panel (“the Panel”) has been appointed by the Council to make a recommendation on the NOR to the Requiring Authority (KiwiRail). We have prepared this planning report on behalf of the Council to assist the Panel to make a recommendation on the NOR. The report has been prepared in accordance with s 42A of the RMA. 3. The purpose of this report is to identify and crystallise the principal issues, environmental effects and policy that will be considered through the hearing process. In providing this planning advice, we draw on and cross reference the independent advice provided by other experts in the s 42A team. 4. The expert scientific or engineering advice that we have relied on is set out in the following supporting Technical Evidence s 42A reports: a. Technical Report on Traffic and Transport effects – by Harriet Fraser; b. Technical Report on Noise and Vibration effects - by Nigel Lloyd; c. Technical Report on Landscape and visual effects – by Chantal Whitby; d. Technical Report on ecological effects - by Justine Quinn; e. Technical Report on Stormwater and Flooding – by David Arseneau and Reiko Baugham; f. Technical Report on Lighting effects – by Glen Wright; g. Technical Report on Air quality effects – by Deborah Ryan; h. Technical Report on Social effects – by Amelia Linzey; i. Technical Report on Economic effects – by Shane Vuletich; Page 2 of 260 j. Technical Report on Palmerston North City Council Assets and Infrastructure – by Robert van Bentum; k. Technical Report on Railway track design, construction and operation – by Michael Than. 1.2 Submissions received 5. Ninety-eight submissions were received, covering a broad range of issues, both in support and opposition to the Freight Hub. We have categorised those submission points into issues and have addressed them in detail in our report. Our analysis of submissions has been supported by material provided by KiwiRail and the advice of the Council’s technical experts. 1.3 Relevant provisions of policy documents 6. The relevant statutory provisions for the consideration of the NOR are set out in a standalone document that accompanies this report.1 We evaluate the relevant statutory provisions as we go through the topics in this report. 7. Generally, the proposal is consistent with relevant planning provisions that focus on enabling infrastructure, including the infrastructure objectives and policies in the Horizons One Plan (“One Plan”) and the Palmerston North District Plan (“District Plan”). However, on the information available for assessment at the time of this report, the proposal is inconsistent with some relevant provisions, including: a. District Plan provisions that seek to maintain the character and amenity of rural and residential environments; b. District Plan provisions directed at ensuring a safe and efficient land transport network for all road users; c. provisions in the One Plan and the National Policy Statement for Freshwater Management 2020 (“NPS FM”) that seek to prioritise the health and wellbeing of waterbodies and freshwater ecosystems; 1 Relevant Planning Instruments: KiwiRail Freight Hub Notice of Requirement Page 3 of 260 8. In our opinion, the following matters require additional controls to achieve alignment with the relevant provisions (in no particular order): a. Resolve safety and efficiency issues on the road network; b. Provide safe and efficient active transport routes; c. Identify more comprehensive mitigation, and offsetting and compensation, to address the loss of freshwater bodies and their values (including natural character and Te Mana o te Wai); d. Establish noise limits, and provide off-site mitigation where needed; e. Develop bespoke design principles and outcomes to inform the detailed design and effects mitigation. 1.4 Consideration of alternative sites, routes and methods 9. In our opinion, KiwiRail has undertaken adequate consideration of alternative sites or locations for the Freight Hub through its multi-criterion assessment of the suitability of the site. 10. KiwiRail has, however, identified several alternative project design methods for addressing significant adverse effects which were not assessed in formulating the NOR. Those alternative methods include: a. Extending the designation boundary to include properties that are expected to be significantly affected by noise; b. Methods for mitigating conflicts in the roading network created by the Freight Hub; c. Methods for efficient connection between businesses in the NEIZ and the Freight Hub; d. Grade separation at the Kairanga-Bunnythorpe Road intersection with the level crossing in Bunnythorpe to alleviate safety and efficiency effects. 11. There is no information in the NOR to explain why these alternative methods were not followed through or considered for the NOR, which we consider to be a deficiency in the assessment of alternatives. In particular, we consider Page 4 of 260 that extending the boundaries of the NOR to allow for the management of significant noise effects should have been given specific consideration. 1.5 Whether the designation is reasonably necessary for achieving the objectives 12. We consider that the Freight Hub is reasonably necessary to achieve KiwiRail’s objectives. However, we consider the objectives could be better achieved through refinement and improvement to the design to better integrate the Freight Hub with other infrastructure and economic activities. 1.6 Any other matters 13. The Freight Hub proposal is well aligned with national, regional and city strategic planning documents that seek to facilitate the growth of the freight and logistics sector and to improve the capacity and efficiency of the rail freight network. The proposal fits well with the Council’s land use strategy for the north-eastern part of the city. However, there is uncertainty regarding the degree of alignment with strategic transport documents, including those that seek to achieve: a. Integration of transport and land use to support well connected communities; b. Reliable multi-modal transport system with less modal conflict, including an integrated walking and cycling network; c. A transport system where no-one is killed or seriously injured with a target for reduction of 40% in the next decade; d. Efficient, reliable access and movement by road, rail and public transport, including for freight. 14. The Freight Hub and the Palmerston North Integrated Transport Initiative (“PNITI”) programme of works are two major land transport infrastructure projects that will need to be developed in an integrated manner. Heavy reliance is placed on the proposed Road Network Integration Plan (“RNIP”) to achieve effective integration. While this may be the appropriate mechanism, we consider further refinement is appropriate to provide certainty of process and outcomes and to optimise the Freight Hub’s integration with these Page 5 of 260 programmes. We consider that the positive effects of the Freight Hub will be increased by better integrating with the programmes above and nearby industrial activities. 1.7 Effects on the Environment 15. We have prepared a Summary of Effects and Recommendations Table to accompany our report and to provide an accessible summary of our opinions and recommendations regarding the effects of the NOR. This table provides a summary of: a. effects that have been identified by submitters, KiwiRail and the Council’s s 42A reporting team; b. our recommendations to address these effects; c. recommended requirements for conditions; and d. references to where these effects and recommendations are fully addressed in our report. 1.8 Positive effects on the environment 16. The Freight Hub will have significant positive effects on the environment. The most significant positive effects will be economic. In particular, the Freight Hub will enable growth of the freight and logistics sector, provide employment opportunities, and increase the capacity and efficiency of the rail freight transport network. 17. Achievement of these positive effects is heavily reliant on the Freight Hub being well connected and integrated with the wider transport network and with the other economic activities in the northeast of the city (e.g. the North East Industrial Zone (“NEIZ”) and Palmerston North Airport). More work is needed to demonstrate how and when these integrations will be achieved, however, the development of the Freight Hub in its proposed location is well aligned with local and regional strategic planning to develop an integrated, well-connected multi-modal freight and logistics centre in the north-east of the city. Page 6 of 260 1.9 Adverse effects on the environment 18. We have also identified potentially significant adverse effects of allowing the NOR. We have identified these as significant due to: a. the large scale of the effects and the fundamental changes to the characteristics of the environment; b. the nature and potential intensity of the effects; and c. the uncertain timing and long duration of the effects. 19. We consider the most potentially significant adverse effects are: a. effects of noise and vibration on sensitive receivers during construction and operation; b. social effects arising from disruption to communities, displacement of people and loss of amenity; c. effects on the safe and efficient functioning of the road network; d. loss of waterbodies (streams and wetlands) and their actual and potential values, including in relation to Te Mana o te Wai and natural character; e.