Before the Queenstown Lakes District Council In the Matter of the Resource Management Act 1991 And In the Matter of the Queenstown Lakes Proposed District Plan Hearing Stream 18 (Rural Visitor Zone) Legal Submissions for Queenstown Airport Corporation Limited (Further Submitter 31054) Dated: 6 August 2020 Counsel | Rebecca Wolt | Barrister Email |
[email protected] Phone | +64 21 244 2950 1 Introduction 1. These legal submissions are filed on behalf of Queenstown Airport Corporation Limited (QAC) in respect of its further submission on the Queenstown Lakes Proposed District Plan (PDP) addressing an original submission (OS31021) by Corbridge Estates Limited Partnership (Corbridge) to rezone approximately 322 ha of land located at 707 Wanaka-Luggate Highway Limited from Rural Zone to Rural Visitor Zone (RVA). 2. The Corbridge land is proximate to Wanaka Airport (Airport), under the Airport’s main flight path, and partly within the Airport’s Operative Outer Control Boundary (OCB). 3. QAC is responsible for the management and planning of Wanaka Airport pursuant to a long-term lease by Queenstown Lakes District Council (QLDC). 4. QAC opposes the Corbridge submission for reverse sensitivity and amenity reasons and seeks retention of the land’s Rural zoning. Legal Framework 5. Ms Scott for QLDC has addressed the statutory framework within which decisions on submissions and further submissions must be made.1 Ms Scott’s submissions are generally accepted as correct and adopted here. 6. The issue of jurisdictional scope arises for the Corbridge submission, and Ms Scott’s submissions on that2 will be addressed and elaborated upon shortly. QAC 7. QAC was incorporated in 1988 and is responsible for operating Queenstown Airport.