Before a Board of Inquiry East West Link Project In
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BEFORE A BOARD OF INQUIRY EAST WEST LINK PROJECT IN THE MATTER of the Resource Management Act 1991 (“the RMA”) AND IN THE MATTER of a submission by AUCKLAND HELIPORT LIMITED PARTNERSHIP (#126324) under section 149E of the RMA in respect of applications for resource consent and notices of requirement by the NEW ZEALAND TRANSPORT AGENCY in relation to the EAST WEST LINK PROJECT in Auckland STATEMENT OF EVIDENCE OF KEITH CHARLES STEPHENS FOR AUCKLAND HELIPORT LIMITED PARTNERSHIP AHLP Corporate Dated: 22 May 2017 BERRY SIMONS S J Berry Telephone: (09) 969 2300 Facsimile: (09) 969 2304 Email: [email protected] Postal: PO Box 3144 Shortland Street AUCKLAND 1140 1. INTRODUCTION ................................................................................................................................. 3 2. SUMMARY OF EVIDENCE ................................................................................................................... 5 3. AHLP AND THE EXISTING HELIPORT OPERATIONS ............................................................................ 10 4. BACKGROUND TO THE DEVELOPMENT OF THE PIKES POINT SITE .................................................... 14 5. CONSTRAINTS ON THE LOCATION OF HELIPORTS AND ABSENCE OF ALTERNATIVE SITES ................. 21 6. HOW THE PROJECT WOULD AFFECT AHLP’S OPERATIONS ............................................................... 28 7. AHLP’S ENGAGEMENT WITH NZTA AND REQUESTED SOLUTION ...................................................... 31 8. RESPONSE TO NZTA EVIDENCE ......................................................................................................... 36 9. CONCLUDING COMMENT ................................................................................................................. 38 Page 2 1. INTRODUCTION Qualifications and experience 1.1 My name is Keith Charles Stephens. I am: (a) The sole director and shareholder of Hangar One Limited, which is the sole General Partner in Auckland Heliport Limited Partnership (”AHLP”); and (b) The Managing Director and Chief Pilot at Advanced Flight Limited (“Advanced Flight”), the helicopter management and charter company which currently operates out of the Heliport at 59 Miami Parade, Onehunga. 1.2 I have 27 years’ experience flying helicopters and am one of a very small number of pilots in New Zealand to hold a Category A Instructor Rating (with Flight Examiner privileges and including multi-engine and instrument ratings), from the Civil Aviation Authority (“CAA”). I have over 7,000 hours of flying experience. 1.3 I established Advanced Flight in 1998 and have been responsible for managing and developing the company since that time. This has included establishing the existing Heliport (a project that commenced in 2006) and subsequently AHLP. I have overall responsibility for and am familiar with all aspects of Advanced Flight, AHLP and the Heliport’s operations. Purpose and scope of evidence 1.4 The purpose of my evidence is to outline relevant background; the impact that the East West Link Project (“EWL” or “the project”) would have on AHLP and the Heliport if the project is implemented in the proposed alignment; and the solution that AHLP requests. 1.5 In doing so, my evidence: (a) Introduces AHLP and its existing Heliport facility (Section 3); Page 3 (b) Outlines the background to development of the Heliport on its existing Pikes Point site (Section 4); (c) Outlines the constraints that apply to selecting sites for commercial heliports and helicopter landing areas and the absence of suitable sites for the Heliport to relocate to (Section 5); (d) Outlines why, if established in its current alignment, the EWL would mean the end of AHLP’s commercial helicopter charter business and usefulness as a Civil Defence and community asset (Section 6); (e) Briefly summarises the extensive engagement that AHLP has had with NZTA regarding the EWL and the solution AHLP requests for mitigating the project’s effects on the Heliport (Section 7); (f) Responds to the only evidence presented by NZTA regarding the Heliport, which is from Messrs Harrington and Nancekivell (Section 8); and (g) Sets out some brief concluding comments (Section 9). 1.6 A summary of my evidence is set out in Section 2 below. 1.7 I am authorised to give this evidence on behalf of AHLP. Expert Witness Code of Conduct 1.8 I am presenting my evidence as director and shareholder of Hangar One Limited and Managing Director and Chief Pilot at Advanced Flight, rather than as an expert witness. However, some of the technical matters that I address in my evidence are within my area of expertise, i.e., helicopter-related aeronautics and relevant Civil Aviation requirements. To the extent that the Board wishes to rely on that evidence, I confirm that I have read the Code of Conduct for Expert Witnesses contained in the Environment Court Practice Note 2014 and that I agree to comply with it. I confirm that I have considered all material facts that I am aware of that might alter or detract from the Page 4 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. 2. SUMMARY OF EVIDENCE AHLP and the existing Heliport 2.1 AHLP operates a highly successful helicopter charter business which services the premium end tourism market, from a modern, purpose- built Heliport adjacent to the Mangere Inlet at 59 Miami Parade, Onehunga. This business is the realisation of my long-held vision to establish an Auckland-based helicopter management and charter company. 2.2 The operation began using a single helicopter from rented premises at Ardmore Airport. Today, AHLP is one of New Zealand’s largest helicopter charter service providers, employing 14 full-time and 2 part- time staff and with an annual turnover of $6,370,000. 2.3 The Heliport has approximately 2,700 aircraft movements a year and would transport on average 7,200 passengers through the facility on an annual basis. As outlined by Dr Wheeler, our charter business generates significant economic benefits for the wider Auckland region, with assets of over $50million USD, net economic effects of between $30million to $35million per year, and estimated employment effects of approximately 244 full-time jobs. 2.4 The Heliport is now home to a fleet of seven single-engine and four twin-engine helicopters. The bulk of our charter business (and therefore the economic benefits that the Heliport generates) relies on our single-engine helicopters, which undertake 90% of our commercial flights. 2.5 The Heliport is also a significant community asset and an important part of Auckland’s transport infrastructure, in particular because it can be used as a back-up facility for helicopters operated by our emergency services. The Heliport therefore represents a significant Page 5 transport / tourism and community asset and an important part of Auckland’s transport infrastructure. 2.6 It has been a long hard road setting up this business and I funded the entire investigation, design and initial construction of the Heliport personally, at significant risk. I did so because the Pikes Point site presented a “once in a lifetime” opportunity to make the Heliport a reality which I could not let pass by. It was and remains an ideal site for our Heliport, given the range of factors that constrain where such facilities can locate. I am very proud of what I have worked very hard to achieve. 2.7 The EWL proposal does not just limit our operations; it threatens our very existence. We cannot operate if they put the road in front – it would be all over. Constraints on heliport location and rationale for existing Heliport site 2.8 A range of regulatory and practical constraints apply to decisions about the siting of helicopter landing areas, heliports and helicopter operations. These primarily comprise the Civil Aviation Rules (“CARs”) relating to heliports and helicopter movements; the need to be able to comply with relevant noise abatement protocols; and district plan restrictions. 2.9 I undertook a detailed two year process (2005-2006) of site identification and evaluation before selecting the Miami Parade site for AHLP’s Heliport. Through this process, I was not able to identify any other site in sufficient proximity to the Auckland CBD and Auckland Airport that could safely and practicably be established as a new heliport for commercial helicopter charters. I remain satisfied that Miami Parade represents an ideal site for our operations having regard to the statutory and other constraints that apply and has a number of significant benefits. 2.10 Should the Heliport be required to close, relocating our fleet back to Ardmore Airport would not be possible for the same reasons we initially Page 6 moved away. In addition, this is no longer an option due to the Mechanics Bay Heliport being at maximum capacity and therefore not able to accommodate the number of movements AHLP would currently require for passenger drop-offs and pick-ups. 2.11 Relocating to either Auckland or Whenuapai Airports is also not feasible as both are too far away from the Auckland CBD (and Whenuapai is also too far from Auckland Airport). There is also already an existing heliport operator at Auckland Airport. As a result, it is not feasible for the Heliport to relocate other than within its present site. Adverse effects of EWL on the Heliport 2.12 EWL’s impact on the Heliport arises primarily as a result of the operation of CAR Part 91.127(d)(3). This imposes restrictions on the flight operations of single-engine aircraft such that we are unable to have approach and take-off paths over any third party or public area where a safe engine-off (auto rotation) landing cannot be assured. 2.13 If, as proposed, the EWL was placed between the Heliport and Mangere Inlet, the alignment would prevent AHLP’s seven single-engine helicopters from complying with this requirement. As Advanced Flight’s director and holder of the General Aviation Air Operator Certificate (“Certificate”) for the Heliport issued by CAA (attached as Appendix 1), I am required by the Civil Aviation Act 1990 (“the Act”) to ensure compliance with Act and all rules made under that Act.