BEFORE THE AUCKLAND UNITARY PLAN INDEPENDENT HEARING PANEL IN THE MATTER of the Resource Management Act 1991 and the Local Government (Auckland Transitional Provision) Act 2010 AND IN THE MATTER of Topic 016 RUB North/West AND IN THE MATTER of Wilks Road South Land Owners Group (WRSLOG) Submissions: 2431 2981 3004 3071 3196 3212 2692 2982 3007 3073 3198 3213 2972 2983 3009 3075 3200 3215 2973 2984 3032 3078 3201 3216 2974 2985 3037 3102 3203 3218 2975 2986 3040 3105 3205 3219 2977 2989 3041 3109 3207 3231 2978 2994 3044 3113 3208 3237 2979 2998 3054 3118 3209 3709 2980 3003 3058 3128 3211 STATEMENT OF REBUTTAL EVIDENCE OF JOHN SCOTT ON BEHALF OF THE WILKS ROAD SOUTH LAND OWNERS GROUP (WRSLOG) 17 DECEMBER 2015 Rev.17.12.15 TABLE OF CONTENTS 1 Summary……………………………………………………………………………… 2 2 Introduction……………………………………………………………………………. 3 3 Scope and Reasons for Rebuttal…………….………………………………..…… 4 4 Refuting the Airfield Development Potential……… …………………………….. 5 5 Refuting the removal of areas of Dairy Flat from within the RUB………. 9 6 Conclusion……………………………………………………………………………... 14 Attachment A Different versions of NSAC Rural Urban Boundaries Attachment B NSCA (David Park) Aviation Evidence, dated 27 November 2015 Attachment C CAA Guidance material for land use at or near aerodromes, 2008. Attachment D List of Aerodromes with Part 139 Certification 1 1. SUMMARY 1.1 My name is John Scott and I am providing this rebuttal in relation to evidence submitted by the North Shore Aero Club (NSAC) on the northern Rural Urban Boundary (RUB) part of Topic 016 RUB North/West (Topic 016). This relates to the Dairy Flat RUB and specifically to the area owned by the Wilks Road South Land Owners Group (WRSLOG), identified in the Auckland Council’s evidence as the Postman Road area. 1.2 WRSLOG made submissions on the notified Proposed Auckland Unitary Plan (PAUP), because the Postman Road (WRSLOG area) is excluded from within the RUB. We wish it included as our properties are surrounded on three sides by the Future Urban Zone (FUZ), depreciating the rural nature of our properties, whilst denying us future development opportunities. 1.3 However, in the Council’s Evidence submitted on the 14 October 2015, they supported the inclusion of the Postman Road (WRSLOG area) within the RUB, thereby alleviating these concerns and providing Auckland with much needed land for urban development. 1.4 In the WRSLOG Statement of Primary Evidence dated 16 November 2015, we fully concur and endorse the Council’s decisions to include the Postman Road (WRSLOG area) within the RUB and the FUZ. 1.5 In both our Submissions and Statement of Evidence, the WRSLOG fully support the objectives and policies that ensure the existing aerodrome activities are not compromised by reverse sensitivity issues and these should be resolved through future structure planning. 1.6 However, WRSLOG have been compelled to make this rebuttal because of the evidence presented by NSAC. 1.7 NSAC propose a significant buffer zone around the aerodrome that prohibits future urban development. They also expound on the growing importance of the airfield as a Satellite Auckland Airport and the possibilities to expand, by extending the main runway across Postman Road. 1.8 This rebuttal is based on belief that the NSAC Statements of Evidence are unreasonable, unrealistic and not in the best interest of the Dairy Flat Community. 1.9 There are ample Civil Aviation Authority of New Zealand (CAA) regulations and Council objectives, policies and rules for noise management and land use around airfields that can be implemented when developing the structure plan for Dairy Flat, so that the airfield’s existing activities are not compromised by reverse sensitivity or safety issues. 2 2. INTRODUCTION 2.1 My name is John Scott, I am a registered Chartered Engineer (Engineering Council UK), hold a NZ Private Pilot Licence and a member of NSAC. I am a retired Project Manager and a resident of Dairy Flat within the WRSLOG area. 2.2 This area is owned mainly by the WRSLOG members and is identified in the Auckland Council’s Statements of Evidence as the Postman Road area, as shown in Figure 1. 2.3 This is lay material that we wish to present to the Independent Hearing Panel (IHP) as a rebuttal of evidence submitted by the NSAC. Figure 1 Dairy Flat Area, Highlighting the Postman Road (WRSLOG area) 2.4 WRSLOG fully support the objectives and policies that ensure the existing aerodrome activities are not compromised by reverse sensitivity issues and these should be resolved through future structure planning. However, NSAC wish to exclude most of Dairy Flat from the FUZ and develop a Satellite Auckland Airport. 3 3. SCOPE AND REASON FOR REBUTTAL 3.1 This rebuttal relates to the following Statements of Evidence: ñ NSCA (David Park) Aviation Evidence, dated 27 November 2015 ñ NSAC (Joe Smith) – History and Economics Evidence, dated 16 November 2015 ñ NSAC (Kaaren Rosser) – Planning Evidence, dated 16 November 2015 ñ NSAC (Daryl Gillett) – Flight Training and Safety Evidence, 13 November 2015 ñ NSAC (Carlton Campbell) – Submitters Evidence, dated November 2015 3.2 It should be noted that there is some confusion in the actual RUB being proposed by NSAC as there are the following versions (see Attachment A for RUB versions): ñ As presented in Figure 4 of NSAC Unitary Plan Submission 4931. ñ As described in the NSAC Planning Evidence. This also has a precinct option for the entire area. ñ As detailed in NSAC Aviation Evidence, which has most of Dairy Flat removed from the RUB with a second option for limiting the RUB boundary to the 55dB zone surrounding the aerodrome. 3.3 As the Aviation Evidence (see Attachment B), which was submitted after the submission deadline, is the latest version, this rebuttal will focus on this proposal with the intent of addressing the other versions at the same time. 3.4 This rebuttal is based on belief that the NSAC Statements of Evidence are both unreasonable in proposing that such a significant area is excluded from within the RUB and unrealistic in the proposed expansion of the airfield. 4 4. REFUTING THE AIRFIELD DEVELOPMENT POTENTIAL 4.1 THE NSAC state in their Planning Evidence, paragraph 3.1 “the Council have not duly considered the importance of regional infrastructure, including the airport, when determining the proposed RUB area.” They appear to be using the development potential as justification for this position. 4.2 In the NSAC Unitary Plan Submission 4931 page 2, it states one of the club’s aspirations is to “Widen and lengthen the all weather landing strip. Any extension of the landing strip would need to be to the SW of the current main runway, extending across Postman Road for operational and safety reasons” 4.3 Under the heading of “The Airport’s expansion potential” the Aviation Evidence provides much more detail on this proposal. In paragraph 46 it states: “Ideally the sealed runway would be able to be extended to 1100m long and widened to 30m and sit within a 1220m by 150m strip with 90m long runway end safety areas beyond each end. This sealed runway length would be adequate for the operation of larger aircraft such as the 50 seat Bombardier Q300”. 4.4 Figure 2 details how WRSLOG perceive these proposed changes, as well as the Runway Protection Zone (RPZ) mentioned in paragraph 36 of the Aviation Evidence. 4.5 Figure 3 highlights how WRSLOG understand the surrounding facilities and properties will be impacted from this proposed expansion. 4.6 As can be seen from Figure 3 the proposed runway extension would require the following: ñ The purchase of land and removal of some Aero Park buildings. ñ Relocation of most of the aerodrome hangars. ñ Relocation of the Club House and offices. ñ Purchase of properties SW of Postman Road and the demolition of houses. ñ Postman Road rerouted or made a no through road. 4.7 The above does not include other requirements such as the need for adequate parking and other infrastructure necessary for a large commercial operation. 4.8 In addition, should the aerodrome wish to operate 50 seat aircraft, it will require Part 139 Certification, as the CAA state in their “Guidance material for land use at or near aerodromes”, page 1 (see Attachment C) The Part 139 certificate is required for aerodromes where aircraft with more than 30 passenger seats operate regular air transport operations. Aerodromes that do not meet the more than 30 passenger seat criteria may also hold a Part 139 certificate. 4.9 The requirements of Part 139 are extensive and likely to have significant impact on both the aerodrome and the surrounding area. 5 Figure 2 Detailing the Main Runway Extension as Proposed in the Aviation Evidence 6 Figure 3 Highlighting the Impact on Surrounding Facilities and Properties of the Proposed Main Runway Extension 7 4.10 NSAC state in paragraph 4 of their Planning Evidence “Considering that Whenuapai Airbase is to remain a Ministry of Defence base for the foreseeable future, and existing community opposition would never contemplate a fully commercial operation at that location, it is imperative that economic and land use tools align to allow for the required growth of North Shore Airport.” 4.11 Considering Whenuapai residents have been used to large multi-engine aircraft for years, including jets, why do NSAC consider Dairy Flat community will accept this proposal? 4.12 The social and environmental impact as well as the cost for this expansion will be significant and unlikely to be justifiable. 4.13 WRSLOG do not consider this enlargement a realistic proposition and believe NSAC are overemphasising the regional importance of the aerodrome in overstating the possibility of extending the main runway.