City Rail Link - Summary of Submissions
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City Rail Link - Summary of Submissions Sub Sub Submitter Organisation Name Topic Description Summary No. Matter Name I am writing to add my voice of support for the CRL project. As a daily user of commuter trains in Wellington I strongly believe that the link will make Glenn Auckland a more vibrant city, which is easier to travel around. It will also make Auckland a more attractive holiday destination - especially to those 1 1/1 1.1 Support - NOR All Chadwick who don't drive - or won't drive in a city that they are unfamiliar with. I feel it is important to register my support - despite not living in Auckland, because it should be on record that this project has support from people outside Auckland. 2 2/1 Erin E Wi 1.1 Support - NOR All 5 The submitter seeks that: (a) The NOR for the CRL proposal be cancelled and withdrawn. (b) That any designation of other approval of the CRL proposal includes and is subject to LIFE's property and facilities first being relocated and re-established on an alternative site with the same CLC Trust attn Malcolm 1.23 Oppose / withdraw - 3 3/1 attributes as the LIFE Central site and facilities and within a specified timeframe not exceeding 2 years from the designation approval date; (c) That Board McLean NOR All the lapsing period of any designation or approval be limited to 5 years; and (d) Any further, additional or consequential relief that is necessary or appropriate in respect of the matters referred to in this submission. (d) The AEE makes no reference to the LIFE Central Site and facilities in respect of the "existing environment" and the AEE Table 7.3 ("Summary of Assessment of Effects on the Environment" makes no reference to LIFE Central or the proposal's serious adverse effects on it, including disruption, noise and vibration with particular reference to LIFE's auditorium and facilities (including electronic, audio and visual equipment). (e) The only apparent AEE reference to LIFE Central is in respect of "intangible effects" under the heading "Concern Around Loss of Community and Cultural Facilities". This is an insufficient recognition of the CRL proposal's effects on LIFE; and even then the AEE in addressing them only acknowledges CLC Trust attn Malcolm that such effects are not able to be "completely avoided", with the only suggested "methods to mitigate" being "...communications and liaison with 3 3/2 5.26 Social impact Board McLean those affected...". Significantly, the AEE acknowledges in respect of the CRL proposal that "...the effects of construction will be significant". However, in addressing such effects, the AEE simply and somewhat generally asserts that, "methods and practices are available (and have successfully been used on other projects) and will be implemented where practicable via conditions on the designation to avoid, remedy or mitigate these adverse effects". (g) There is apparently no detail on how such avoidance, remediation or mitigation of adverse effects would occur other than the generalised approach of a proposed "Environmental Management Framework", under which there would be (one or more) "environmental management plans" (including a construction environmental management plan). (h) Significantly, however, the "identified management plans under the EMF would not be developed or provided to the Auckland Council until the Outline Plan procedure stage under section 176A of the RMA; meaning that the substantive assessment of the CRL's adverse environmental effects CLC Trust attn Malcolm 3 3/3 4.2 RMA policy framework (and any particular measures to address them) would not be done until after the public (including affected property owners) have lost the opportunity Board McLean for statutory input - in what effectively amounts to a deferral of the adverse effects assessment beyond the Requirement evaluation and determination. (i) In respect of the "main construction site area" (of which LIFE's site is part) the AEE asserts "there is also the potential of this land being 'blighted' pre-construction...". This assertion is incorrect as it is already the actual and continuing adverse effect of the requirement (and the designation if the requirement is confirmed) that the LIFE site and its development plans are stymied. Prior to the CRL being proposed LIFE had pre-application meetings with the Auckland Council in respect of its already-developed plans for the expansion of its facilities on the site including the auditorium, to accommodate the rapidly-growing LIFE community and the public notification of the CRL requirement has already stymied those proposals, as the NOR demonstrates. (j) The proposed 20 year lapse period is opposed and the paragraph 2.2.7 reasons are insufficient and apparently incomplete. CLC Trust attn Malcolm 3 3/4 5.23 Property rights The asserted "certainty to affected land owners" amounts to the "certainty" of a 20 year blighting period (if approved) for affected land owners - Board McLean assuming even that period is not extended. It is understood that neither Auckland Transport nor the Auckland Council currently has the necessary funding to construct the proposed CRL, in respect of which the statutory "financial responsibility" is a necessary precursor to the legitimacy of the NOR. Given the severity of the proposal's adverse effects on LIFE (and other property owners and members of the community) the lapsing period (if the designation is approved) should be the statutory 5 year period, for which Auckland Transport may obtain, on its merits, an extension under section 184 of the RMA if warranted. The statutory lapse period would remove the uncertainty and lack of accountability that would accompany a 20 year lapse period. (j) The proposed 20 year lapse period is opposed and the paragraph 2.2.7 reasons are insufficient and apparently incomplete. The asserted "certainty to affected land owners" amounts to the "certainty" of a 20 year blighting period (if approved) for affected land owners - assuming even that period is not extended. It is understood that neither Auckland Transport nor the Auckland Council currently has the necessary funding to construct CLC Trust attn Malcolm 3 3/5 5.22 Legal the proposed CRL, in respect of which the statutory "financial responsibility" is a necessary precursor to the legitimacy of the NOR. Given the Board McLean severity of the proposal's adverse effects on LIFE (and other property owners and members of the community) the lapsing period (if the designation is approved) should be the statutory 5 year period, for which Auckland Transport may obtain, on its merits, an extension under section 184 of the RMA if warranted. The statutory lapse period would remove the uncertainty and lack of accountability that would accompany a 20 year lapse period. City Rail Link Notices of Requirement Summary of Submissions Page 1 of 110 City Rail Link - Summary of Submissions Sub Sub Submitter Organisation Name Topic Description Summary No. Matter Name (j) The proposed 20 year lapse period is opposed and the paragraph 2.2.7 reasons are insufficient and apparently incomplete. The asserted "certainty to affected land owners" amounts to the "certainty" of a 20 year blighting period (if approved) for affected land owners - assuming even that period is not extended. It is understood that neither Auckland Transport nor the Auckland Council currently has the necessary funding to construct CLC Trust attn Malcolm 5.24 Designation lapse 3 3/6 the proposed CRL, in respect of which the statutory "financial responsibility" is a necessary precursor to the legitimacy of the NOR. Given the Board McLean period severity of the proposal's adverse effects on LIFE (and other property owners and members of the community) the lapsing period (if the designation is approved) should be the statutory 5 year period, for which Auckland Transport may obtain, on its merits, an extension under section 184 of the RMA if warranted. The statutory lapse period would remove the uncertainty and lack of accountability that would accompany a 20 year lapse period. 3.4 Whether the designations CLC Trust attn Malcolm are reasonably necessary / (k) In its present form (including the proposed lapse period) the CRL proposals fail to achieve the stated "Project Objectives" and is accordingly not 3 3/7 Board McLean NOR is an unreasonable reasonably necessary to achieve the Project Objectives (or "AT's wider objectives). burden CLC Trust attn Malcolm (L) In summary, the CRL proposal does not achieve the sustainable management of natural and physical resources under Part 2 of the RMA and 3 3/8 4.1 Part 2 RMA Board McLean does not satisfy the section 171 RMA criteria. The submitter seeks that: (b) That any designation of other approval of the CRL proposal includes and is subject to LIFE's property and facilities first CLC Trust attn Malcolm 5.31 Mitigation - relocation / being relocated and re-established on an alternative site with the same attributes as the LIFE Central site and facilities and within a specified 3 3/9 Board McLean re-establishment timeframe not exceeding 2 years from the designation approval date; (d) Any further, additional or consequential relief that is necessary or appropriate in respect of the matters referred to in this submission. CLC Trust attn Malcolm 3.3 Alternative locations, 3 3/10 The submitter seeks that: (c) That the lapsing period of any designation or approval be limited to 5 years; and Board McLean sites or methods sought (a) The NOR for the CRL proposal be cancelled and withdrawn. (b) That any designation of other approval of the CRL proposal includes and is CLC Trust attn Malcolm 5.30 Mitigation - preventative 3 3/11 subject to LIFE's property and facilities first being relocated and re-established on an alternative site with the same attributes as the LIFE Central site Board McLean / conditions and facilities and within a specified timeframe not exceeding 2 years from the designation approval date.