Guardians of the Bays are pleased to report that a change has finally been enacted to reduce the recreational air traffic noise that residents living in Miramar North are exposed to.

When the weather is good, planes from the Wellington Aero Club have been circling the Miramar Peninsula along what is known as the “circuit”. In doing so, they inflict the noise of their engines on thousands of residents. At times, circles exceed 50 occurrences in a day, hijacking the soundscape at the same time that residents want to enjoy being outside.

For years, the Guardians have been trying to find solutions to minimise the nuisance, meeting with the Aero Club, the Airport and WCC on several occasions. The last meeting, in April 2021, was sadly fruitless, but things are about to change.

From mid-December, a new Memorandum of Understanding between Airways and the Wellington Aero Club will be signed. This new agreement states that when recreational aircraft are departing towards the north (or on that circuit around the peninsula), their normal procedure will now be that on their Eastern turn, their right wing tip will need to be to the North of the prison (rather than at the Maupuia water towers (red circle on map below) which was their previous reference point for this purpose). If there are safety reasons where they need to turn earlier, the air control tower can require them to, however this will not be the norm.

The green marker is the new turning point for recreational aircraft

This will take recreational air traffic further away from homes, resulting in a direct reduction in exposure to noise. While this is undeniably an improvement, Guardians of the Bays will continue to advocate for the circuit to be pushed even further north (around the inhabited north of the peninsula), a change that would completely shield residents from noise.

This win, while initiated by the Guardians, is the result of a closed discussion between Wellington Airport, Airways (the organisation in charge or managing air traffic) and the Aero Club. It is a disappointment the community was not included in the last leg of the discussion. However, we acknowledge this is a step in the right direction.

In this festive season, we would like to celebrate this welcome change, and thank all parties involved in making it happen.

This guide is prepared by Guardians of the Bays. We’re a community group set up to oppose Wellington Airport’s expansion plans. But all over the country, communities are facing more noise and more disruption from airports’ aggressive expansion plans – which are also making the climate emergency worse.

The Government’s new Civil Aviation Bill could do a lot to reign in airport noise, aviation emissions, and airports’ powers to ride roughshod over local communities. But it doesn’t. We have till Thursday to submit to make it stronger. The Guardians are going to submit, and we hope you will too!


The Civil Aviation Bill 2021 is open for submissions. Submissions close at 11.59 pm on Thursday, 02 December 2021

You can submit here: 

This guide explains why submitting on the Bill is important – please use the proposed submission points below, add your own points, and make a submission!

According to Minister of Transport Michael Wood: “This bill repeals and replaces the Civil Aviation Act 1990 and the Airport Authorities Act 1966 with a single, modern statute that will provide a platform for safety, security, and economic regulation of civil aviation now and well into the future.

But there’s a gaping hole in the Civil Aviation Bill: it does almost nothing to address aviation’s contribution to the climate emergency.

The relentless drive by Wellington Airport and other New Zealand airports to expand their flight and passenger numbers represents a threat both to climate and to local communities.

Even during the COVD-19 pandemic, airport companies have pressed ahead with plans to expand existing airports and create new ones as this helps them grow their asset base and increase their profits – which has led to the absurd possibility that three international airports will be inflicted on Central Otago (in Queenstown, Wanaka and Tarras).

There are some very modest climate-related measures proposed in the Bill, related to monitoring aviation emissions. That’s important and worth supporting, but it’s a pinprick compared to the scale of the problem.

What needs to change in the Bill?

The Bill is large and complex. It has implications for civil liberties, the return of land and the COVID-19 response, among many other aspects.

The proposed submission points below are specifically designed to impose much stronger climate change requirements on airports and restrict their ability to operate with impunity. However, we encourage you to look at all the other aspects of the Bill.

Proposed submission points

Making reducing greenhouse gas emissions a key purpose of the Bill

The purpose of the suggested amendments below is to ensure that specific, measurable, and urgent greenhouse gas emissions reductions are a central objective of the operation of New Zealand airports:

Amend Clause 3, Main purpose

Change Clause 3, Main purpose, from “The main purpose of this Act is a safe and secure civil aviation system.” to ““The main purpose of this Act is a safe and secure civil aviation system that contributes to specific, measurable, and urgent greenhouse gas emissions reductions.”

Amend Clause 4, Additional purposes

At present Clause 4, Additional purposes: reads “This Act has the following additional purposes: … (e) to take into account the adverse effects of civil aviation on the interests of people, property, and the environment.”

We propose the following changes:

  1. In subclause 4(e), add “with particular regard to the adverse effects of greenhouse gas emissions resulting from civil aviation”, so that it reads “to take into account the adverse effects of civil aviation on the interests of people, property, and the environment, with particular regard to the adverse effects of greenhouse gas emissions resulting from civil aviation”.
  2. add new subclauses 4(f), 4(g) and 4(h):
    1. 4(f) To ensure that bringing about specific, measurable and urgent greenhouse gas emissions from aviation operations, including flights, is a primary consideration in all decisions regarding airport licensing and operations, including but not limited to proposals to build new airports, expand existing airports, extend airport runways or build new runways.
    2. 4(g) To implement a cap on gross domestic and international aviation emissions at 2021 levels, and to reduce this cap annually to ensure sharp reductions in gross aviation emissions during the first three budget periods of the Government’s Emissions Reduction Plan.
    3. 4(h) To ensure the monitoring and minimisation of high aviation flight paths, especially of international flights, to reduce particulates of carbon dioxide, nitrogen oxides, sulphates, soot and water vapour in aircraft contrails which have the greatest climate-changing impact.

We further propose that additional clauses should be added to the Bill to give effect to the amended Clauses 3 and 4(e), and new clauses 4(f), 4(g) and 4(h).


Clause 58 Rules for noise abatement purposes

This reads: “The Minister may make rules under section 52 prescribing flight rules, flight paths, altitude restrictions, and operating procedures for the purposes of noise abatement in the vicinity of aerodromes.”We support this clause and request that the Minister exercise this power to make rules that prescribe flight rules, flight paths, altitude restrictions, and operating procedures to abate noise in the vicinity of airports.

In particular, we request that noise levels in the environs of each airport be capped at or below current noise levels, thus ensuring that additional airport operations will not create any additional noise exposure for nearby residents.

We further request that particular attention be given to significantly reducing recreational aviation operations in urban areas, as the noise adversely affects large groups of residents for the benefit of a small number of recreational flyers.

Other matters

Other matters you might like to comment on include:

Clause 226 Aerodrome to be operated commercially

This clause provides that an aerodrome operated by an airport operator must be operated as a commercial undertaking unless it’s council-controlled

We propose that this clause be changed so that airports should not be operated as commercial undertakings.

Explanatory note: In our view, the profit motive leads directly to airports wanting to grow their asset base, which in turn leads to many of the airport expansion and new airport proposals we’re currently facing.

Clause 232 Airport operators must consult concerning capital expenditure plans

This clause requires the airport operator only to consult with ‘substantial customers’.We propose that this be changed to “substantial customers and the community that surrounds the airport.”

Make your submission here:

Support us: Donate

Guardians of the Bays has lodged an appeal with the Environment Court against Wellington International Airport Limited’s aggressive and unsustainable expansion plan.

The Airport’s plan Notice of Requirement for the East Side Area removes the buffer area that exists between the airport and the community of Strathmore Park to the east; putting much larger jet aircraft on the edge of one of Wellington’s poorest communities,.

Guardians of the Bays Co-Chair Yvonne Weeber

Under the plan, Wellington Airport says passengers will double to 12 million by 2040 while at the same time claiming airport ‘operational’ emissions will fall by 30% by 2030.

“This is laughable: You can’t ‘airport’ your way out of a climate crisis”, Weeber said.

The environmental, health, and social costs of Wellington Airport’s plans fall well beyond just the neighbouring communities of Strathmore and Kilbirnie, says Weeber.

The community get vastly increased levels of noise, air and light pollution, and traffic congestion; New Zealand as a whole gets significantly increased greenhouse gas emissions as well; and the Airport gets to make more money off the back of those two things.

Weeber says the Airport could hardly have picked a poorer neighbourhood to bear the brunt of its proposed expansion.

This reads like a real-life retelling of The Castle: Strathmore Park is one of the most socio-economically deprived areas in Wellington, and the majority of the worst-affected locals are Kāinga Ora tenants without a voice and without the means to fight. We’ve got to help them and future generations to tell the Airport ‘they’re dreamin’.

Detail/Appeal grounds

Guardians of the Bays will ask the Environment Court to overturn the Notice of Requirement for the East Side Area expansion on a number of grounds, including –

  • The removal of the existing buffer from the District Plan that separates the community of Strathmore Park from the Airport’s operational activities;
  • The devastating effects on surrounding neighbourhoods of increased noise, reduced amenity, increased dust, visual disturbance, light pollution;
  • Vastly increased traffic congestion that the Airport have no concrete plans to manage;
  • The lack of information on how environmental impacts of stormwater, earthworks, sediment and dust are to be managed;
  • The lack of consideration or information on air discharge from airport operations right next to neighbouring Strathmore Park Residents pollution – including largely Kianga Ora owned social housing;
  • No means of residents complaining about excessive noise and environmental issues if this expansion goes ahead;
  • No agreement to maintain the long standing and hard contested public connection of vehicles, cycles and pedestrians between Broadway and Moa Point on the East Side of Wellington Airport; and
  • No commitment to support New Zealand’s commitment to reduce carbon emissions and be carbon neutrality by 2050 by Wellington Airport or airlines using their facilities.


Guardians of the Bays (GotB) is an incorporated society set up to reduce the adverse effects that arise from Wellington International Airport Limited (WIAL).

Wellington International Airport Limited (WIAL) applied for two a Notices of Requirement (NOR) of the Main Site (existing airport) and the East Side Area (ESA) to Wellington City Council (WCC) for to designate both areas for airport purposes on 25 February 2020.

GotB submitted on both the NOR Main Site and the NOR SEA.

The NOR ESA is on half the southern end of Miramar Golf Course and WIAL sought to use this recreational buffer area as tarmac for plane taxiways, movements and parking next to an extended terminal building.
This land has historically provided a buffer between the Airport and the community to the east, and the need for such a buffer has long been considered a necessity by policy makers at the Wellington City Council, as evidenced under the current District Plan:

  • Rule of the WCC District Plan sets out that the Council will “Provide for the ongoing use of the Golf Course and recreation activities within the buffer of land to the east of the Airport area” and recognises that “The existing Golf Course provides a buffer between the Residential Areas and the Airport operations”.
  • Rule advises that the Council will “Ensure a reasonable protection of residential and school uses from Airport activities by providing controls on bulk and location, ensuring sufficient space is available for landscape design and screening, and by retaining a buffer of land of a recreational nature to the east of the Airport.”

The NOR ESA seeks to do away with this land buffer, as if they were never really any need for it in the first place, or as if it were simply a ‘nice to have’. In this regard, the NOR ESA is completely at odds with the intent of the existing WCC District Plan that set a clear expectation that a buffer was a ‘must have’.

GotB was a submitter to both NORs and opposed the East Side Area on a number of areas including climate change, noise, sustainability, environmental, health and welfare of the surrounding community.
WCC’s experts initial finding was that the NOR ESA should be withdrawn unless appropriate noise and climate change conditions were developed and accepted under section 171(2)(c) of the Resource Management Act 1991.

However, the Independent Panel recommendations to WIAL after, submissions, three days of hearing and additional expert conferencing were for the approval of the NOR ESA and the NOR Main site with minor adjustments

WIAL has since approved the NOR ESA and NOR Main Site.

It is WIAL’s decision to approve the NOR ESA that GotB is appealing to the Environment Court.

Guardians of the Bays are considering their options after hearing that Wellington International Airport (WIAL) have today accepted the Notice of Requirement (NOR) and airport expansion on the Eastern Side of the Airport into the Miramar Golf Course.

The hearing of WIALs NOR expansion plans faced a large number of objections and criticism from the community and environmental groups due to the lack of consideration of climate change, community amenity (especially noise) and long term economic resilience.

The expansion is based on bogus forecasts of passenger numbers doubling by 2040, and lack of climate change modelling that doesn’t take into account significant climate change policy changes and air travel reductions through out the world.

Guardians of the Bays Co-Chair Yvonne Weeber wonders “What planet are they on?”. The expansion should be considered a pipe dream of days long past. “It’s going to cost hundreds of millions, with ratepayers possibly underwriting a significant amount of this expansion. People are reducing their air travel and it’s going to become the dictionary definition of a stranded asset. WIAL should be working with the community to increase amenity rather than reducing it with this Eastern Side Airport expansion”.

Yvonne Weeber
Co-Chair Guardians of the Bays
Phone 0272225390

Jeff Weir
Executive Member Guardians of the Bays and Strathmore Park Resident
Phone 021 0252 3031

Kia ora koutou,

Guardians of the Bays is disappointed by the Independent Commissioner’s recommendation to approve Wellington International Airport Limited (WIAL)’s project to expand the East Side Area and over half of Miramar golf course.

We are disappointed by this recommendation as it has failed to take into proper consideration the significant adverse effects on the immediate neighbours, Wellingtonian’s wellbeing overall, and generations of today and tomorrow. We are also disappointed in the adverse effect on ratepayers who will be asked to fund the construction of a future giant white elephant. 

We firmly believe Wellington Airport should not be allowed to expand into the East Side Area  in a climate change crisis as the airport  is already responsible for 20% of Wellington’s green-house gas emissions. The East Side Area expansion will substantially increase Wellington Airports and related activities green-house emissions.

Guardians of the Bays is now considering its options. We will engage with members of the community, the iwi, community groups and Wellington City Council as we prepare for WIAL’s decision on this recommendation.

We are happy to be approached for comment.

Ngā mihi

Below are the panel’s final recommendation reports:

Kia ora!

On the 7th of July 2021, our exec committee gathered with the public to hold our annual AGM. We had several speakers and discussed exciting initiatives which we will be working on over the next half of 2021. We remain committed more than ever to ensure the community comes first in the Eastern Suburbs, and the airport second.

We look forward to meeting with the community on these very important topics in the next few months.

Here is the minute of our hui: Guardians of the Bays AGM 2021 minute.

Wednesday 7th of July
St Aidan’s Church centre, 89 Miramar Ave
6.45pm come for a cup of coffee/tea and food .
7pm AGM will start.

Welcome to our Annual General Meeting, edition 2021. This hui is open to the public and will cover general business but also discuss the airport expansion. Below is the agenda of the meeting:

  1. Welcome and Introductions (Yvonne to Chair, Richard minutes, timekeeper);
  2. Those present;
  3. Apologises;
  4. Minutes of the last AGM to be confirmed;
  5. Reports:
    1. Annual Report;
    2. Financial Report;
  6. Speakers Local residents of Strathmore Park and submitters at the recent WIAL hearing (Jeffery Weir and others if present) (10 minutes each);
  7. Presentation of the new mission statement (15 minutes):
    • Finance implications of the new mission statement;
    • Vote on the updated constitution.
  8. Election of the executive of Officers (two co-chairs and four executive members) (15 Minutes)
    • Call for nominations;
    • Nominees invited to speak;
    • Vote.
  9. Update on airport expansion plan (5-10 minutes)
    • Where is started: the Airport masterplan;
    • Purchase of the golf course;
    • Notice of Requirement – the two airport designation;
    • Written submissions;
    • Expert evidence from the Wellington City Council and Wellington International Airport Ltd;
    • Hearing;
    • What is happening now?
  10. GotB strategy to maintain public engagement (5-10 minutes):
    • maintain a connection with the community through website, social media, public meeting and comm campaign;
    • with WCC: we need an open, unequivocal position on the expansion; who’s appointed at the board;
    • with GWRC;
    • with the government.
  11. Open the floor to discussion/questions.

Here are some relevant documents:

  1. Guardians of the Bays 2021 annual report;
  2. Guardians of the Bays 2021 financial report;
  3. Guardians of the Bays 2020 AGM meeting minute;
  4. Notice of constitutional change.

A before and after view of the expansion project. Credit: the Airport NOR.

For many years, Wellington Airport has been making plans for expansion. In its 2040 master plan, it talks about the runway extension though this has faced fierce and, to some extent, successful opposition. The airport is also looking at expanding towards the East, over the golf course. It managed to buy half of it and is now preparing the legal framework to convert it to airport operations land. The first step consists of a change of land designation, and the consultation for that change started in November. One would wonder why there is even a consultation since, in legal terms, the airport is a Requiring Authority, and it can decide for itself what it does with the land. That goes as far as overwriting the District Plan rules. Welcome to the airport wonderland!

So in November, the public was invited to submit written submissions, the consultation got handed over to independent commissioners, documents were kept on the WCC website, and the process moved to the oral hearing stage. These hearings ran from Wednesday 19th of May until the following Friday and took place at the airport itself. Day one was given to the airport to make its case, day two was for submitters from the community and the last day was for the City Council. I attended the second day.

The room was organised in such a way that at one end, the three commissioners were facing everyone. Then a rectangle of tables occupied half of the room, with one side for four airport representatives, and the other side for WCC and its experts. The rest of the room was for members of the public and submitters. While the hearing started on time, it immediately went off-track: the previous day had run overtime, and submitters were greeted with two hours of airport propaganda. They needed the expansion they said, because, god forbid, air traffic was expected to double by 2040. They had experts on the case, they said, who had assured the board that COVID was immaterial to projected growth. Also, it wasn’t easy to be an airport in Wellington, since they had to work on a constrained land surface. And there were pesky residents living nearby, so annoying.

With such a start, the agenda had quickly left the room and was seen enjoying a cuppa at Mojo in the main terminal. Meanwhile, submitters were trying to get a slot to speak because, unlike the commissioners, unlike the airport, all of them had external commitments, and were not paid to attend the meeting. Just lucky I took a whole day off unpaid because I was invited to speak at 3.30 PM (after an initially scheduled time of 11:10 AM).

Dr Amanda Thomas.

Some submissions had a greater impact than others (I strongly encourage you to read the extracts below). The one from Dr Amanda Thomas from Strathmore argued that the airport business case was very unconvincing, and asking for a lot of sacrifice from the Strathmore Park community:

The broader context is that aviation represents 13% of Aotearoa New Zealand’s carbon dioxide emissions. If global emissions from aviation were a country, they would be one of the world’s top ten emitters. Emerging research indicates that technology is not emerging fast enough and cannot scale up quickly enough for us to keep flying as we do at the moment, and honour our Paris Agreement commitments.

Politically there is a big shift away from increasing tourist volumes (the airport wants to increase passenger numbers by 29%), and there are some indications that there is a decreasing appetite for long haul flying amongst some of our key markets. Even AirNZ is also indicating a waning appetite for a high volume approach to business.

In relation to Strathmore Park: The areas abutting the southern part of the golf course are 10s on the NZ Index of deprivation, based on the 2018 census. Communities that are 10 on this scale are the most deprived. Deprived communities are often subject to the most environmental hazards, and the psychosocial health problems that follow.

People living in economic deprivation are more likely to do shift work (ie at night) which has a huge health toll – less sleep means increased risk of cardiovascular disease and some cancers, as well as mental health problems. So the increase in noise from the airport during the day would have a big impact on these folks trying to get some sleep.

There is also no way to mitigate any increase in noise outside. This means less access to outdoor spaces – whether public or private – for children, particularly children already facing deprivation in the area above the airport. Time outdoors is essential for cognitive development and to grow good citizens. Constant noise pollution may also serve as a regular reminder of a lack of climate action and lead to more eco-anxiety amongst young people.

Dr Amanda Thomas, Senior Lecturer in Environmental Studies, School of Geography, Environment and Earth Sciences, Victoria University of Wellington

Equally powerful was Jeffrey Weir’s submission. Jeff is another Strathmore resident and rebuked the noise expert’s evidence pushed by the airport. It is edifying:

“Laurel Smith from Marshall Day Acoustics (for WIAL) argues that if the 65 dB noise limit set out in the antiquated (1992!) Airport noise management and land use planning standard (NZS 6805:1992) is met, the health of people living near airports will be protected.” Yet Chris Day – the founding partner and principal of that same firm – has previously argued with regards to Christchurch International Airport Limited (CIAL) that there is not a sudden point at which noise effects ‘switch in’ — it is a sliding scale with adverse effects kicking in well below this limit. So Marshall Day’s conclusions then are inconsistent with their conclusions now. That is not really surprising: In the CIAL case, Marshall Day was arguing that houses should be kept distant from an airport; whereas here they are arguing that an airport should be allowed to move closer to houses. WIAL’s noise ‘experts’ are speaking with a forked tongue.

Moreover, WIAL state that they don’t wish to change the Air Noise Boundary (ANB) set out in the Standard, which is the boundary at which they must not exceed that 65 dB noise limit. Yet they are seeking an exemption to ignore a portion of the ANB and instead measure their emissions at another point. That’s because without some kind of exemption they cannot taxi their much bigger, noisier jets so close to the borders of the ESA…they would instantly be in breach. That entirely defeats the purpose of the ANB. You can’t say you will both simultaneously respect the ANB while asking permission to ignore a part of it.

The Standard itself says of itself that it is not the be-all and end-all when it comes to noise matters: “A local authority may determine that a higher level of protection is required in a particular locality, either through use of the Airnoise Boundary concept or any other control mechanism.” We, in fact, have such an additional control mechanism as part of the existing regulatory framework: A buffer between the airport and residents to the east; the need for which is specifically called out and provided for in the WCC District Plan. The Airport’s Notice of Requirement (NoR) effectively creates a hole in the District Plan into which most of this buffer disappears, and an important part of the existing noise control framework disappears along with it. Furthermore, not only will 2/3rds of that buffer be lost but noisier Jets that are currently in use will be shifted to those 2/3rds. Meaning the buffer doesn’t just become 2/3rds less effective than it is currently … it likely becomes significantly more than 2/3rds less effective.

WIAL has gone for a ‘dream’ masterplan scenario that puts a new road and bigger-jet-capable taxiway as close to residents as the land and noise limitations will possibly allow them to. There is no counterfactual. There are no half steps. There are no options with different trade-offs between increased operational efficiency and increased negative externalities on other parties. The NOR is silent on what options might exist to use some or all of the east side land for WIAL activities that increase overall operations efficiency without similarly increasing operational noise. In short, the NOR is all or nothing.

The airport also says that the airport plans “have been shared with stakeholders and clearly communicated to the Airport’s neighbouring community” and that documents asking for input into the Masterplan 2040 were ‘hand delivered’. ‘Hand Delivered’ just means ‘mail drop’. Practically no one has seen anyone from the airport first-hand – and certainly no one I have spoken to amongst my neighbours. Raukawa street is generally very poor. If ever there was a community to get creative with regard to engagement, this is it. The end result of WIAL’s “clear communication” is as you would think it would be: Everyone in my neighbourhood that I have spoken to have been largely unaware of the scope and scale of the ESA NOR. WIAL has failed to undertake meaningful consultation with affected parties, and they could hardly have picked a worse neighbourhood to do it in.

Finally, WIAL has been silent about the implications of a combination of Pest-Free Miramar and buffer plantings on airstrike and ground-strike risk. Surely the risk increase as both the number of flights increases and the number of birds thanks to a successful Pest Free Miramar programme. They have said nothing about this safety risk.”

Jeffrey Weir, Strathmore Resident

As for me, my argument focused on climate change. I tried to demonstrate that expansion, drawing more traffic, would inevitably increase emissions. Indeed, the technology to fly sustainably is far from ready and no one can predict when it will be. Even with improved fuel efficiency, the increase in traffic leads to a net increase of GHG (as found in this ICCT study). If the expansion was going ahead, it would further jeopardise Wellington’s efforts to reduce its emissions, efforts already insufficient to reach Te Atakura’s objectives. And that’s despite the fact that 92% of Wellingtonians want action on climate change, no matter what.

So Wellingtonians, let’s make it clear for you: you are against the airport expansion. Sadly, the commissioners made it equally clear climate change wasn’t in the scope of their analysis, deepening, even more, the schism between the airport and the real world.

Lastly, two elected members turned up. Thomas Nash, Green Regional Councillor, came to announce GWRC was working hard to provide the airport with a bus service, a bus service the airport dearly wants back apparently, but not until a satisfactory commercial agreement is found it seems. I still fail to understand how one can link Public Transport to the expansion, the former being required regardless, and the hearing being about the latter. Thomas Nash explained he was making a submission on behalf of the Regional Council.

Sarah Free, Eastern Ward Councillor and Deputy Mayor of Wellington made a submission in her own name, to ask, pretty please, for access between Strathmore and Lyall Bay to be maintained, something the airport can’t promise today. Yes, a Green Councillor, representative of the Eastern community, was not allowed, it seems, to speak on behalf of the community, and chose to use her time to speak about road access if the expansion happens. If you think you are misreading this, sadly you aren’t.

In a climate emergency, is making room for more planes the right thing to do?

At the time of writing, it is unclear when and how the public will be notified of the decision the panel will come to, despite numerous requests. Even if the panel decided to recommend against the expansion to the East, the airport could still go ahead, as it is a Requiring Authority. It will do so fully aware of the fierce opposition from the surrounding suburbs, and turn a blind eye to its climate responsibility or the known consequences to residents’ health.

I left this hearing with many fundamental questions unanswered:

  1. How can Aotearoa’s legal framework enables an entity to be so detrimental to its neighbourhood?
  2. How can a legal framework be so disconnected from the real world, where climate change is not a consideration?
  3. How is it possible that, in New Zealand, a democracy established in 1893, the first country in the world where women can vote, an elected member is unable to forcefully, loudly speak his or her mind, to defend community’s interests?

So what to do? If you feel outraged as I am, by this project from another age which will have so many adverse effects on immediate communities and future generations, consider supporting Guardians of the Bays ( or subscribe to their website. This community group has pushed back against the runway extension and is now pushing back against the airport expansion.

Talk to your Councillors, the Mayor, your MP, and ask them to intervene to put this project in the freezer until such time flying sustainably has become a reality.

In August last year, the Wellington City Council declared a climate emergency, and released a blueprint outlining intentions and objectives to make the city carbon neutral by 2050. With a 30 year horizon, it was hard to get past the irony of the program name “Te Atakura, First to Zero.” Hopefully, by then, Wellington will not be first to zero, as many cities will have reached that goal much earlier. But it was a start, and intentions were clearly laid out.

There was therefore a lot of anticipation about the implementation plan, meant to articulate how we planned to achieve these targets. But despite the climate emergency, there hasn’t yet been much sign of urgency.

It wasn’t till one year later (on August 6 2020), that the implementation plan was released, without any media announcement. So it was mostly unnoticed, which might have been intentional – the document is 55 pages long and its lack of ambition is shocking when considering what’s at stake. It’s empty of real actions that could change the course of Wellington’s greenhouse gas emissions and ensure the city does its part to mitigate climate change.

What should we have been able to expect from the implementation plan? There should be binding, bold and clearly aligned actions for the council to deliver, with requirements and delivery strongly linked. According to this document, most of the emissions are coming from transport, so this is where the strongest actions should have been found. Alas, the plan is full of “advocating” with plenty of “investigating opportunities”. In other words, the strategy relies on “best efforts” and “best intentions”.

On page 12, it states:

“… Transportation: At 53% of the city’s emissions, we need a rapid reduction in fossil fuel vehicles in favour of public transport, electric vehicles, shared mobility, cycling, walking and remote working. Aviation and marine account for almost 20% of this sector, but have limited immediately available solutions; therefore a move away fossil fuel road vehicles will need to be the biggest challenge of this decade.”

The airport’s emissions, which amount to 20% of Wellington transport emissions (25% of ALL emissions according to other reports) are left unaddressed. For the remaining 80%, the only substantial actions are more cycleways, and rapid transit which as we sadly know won’t see daylight for at least another 10 years and are far from under the Council’s control.

The implementation plan sees great opportunities in switching to electric vehicles which will be achieved by:

“… advocating to central Government for regulatory and policy changes for EVs and renewable electricity generation”

To say this is underwhelming is a euphemism: the Council is not committing to do anything but watch and advocate, debate and identify opportunities. Yet, countless cities have already set a firm timeframe to ban fossil-fuel from CBD streets in 2030, some by 2025.

This implementation plan was the perfect opportunity for Wellington to issue a similar statement, as suggested by Councillor Tamatha Paul:

“… Auckland City have committed to being fossil-fuel free CBD streets by 2030. I want us to declare the same thing.”

The implementation plan was the precise moment to declare exactly that, followed by a by-law to make it certain. Additionally, since EVs are the answer to less emissions, the council could have committed to make the new tunnel dedicated to EVs only, should the tunnel come before rapid transit. This is a missed opportunity.

Thankfully, the plan outlines one very sensible measure on page 18:

“Incentivising city-wide remote working – has the potential to reduce city-wide emissions …”

Yet this has been contradicted by some councillors who have called for the exact opposite after the lockdown, to “save the CBD” (suburban businesses, you’re on your own!) The Wellington Regional Economic Development Agency is even spending $75,000 to attract people back into the CBD. As does the mayor, who is calling for people to come back into the CBD:

“GREAT to be down to Covid Level One. Now let’s have all our people back in town – our business community and their employees need us all doing that! …”

Of course, the elephants in the room are the big contributors to the GHG emissions: aviation and marine activities. Here, while 92% of the public says emissions must be reduced “no matter what” (page 15), the Council decides … to do nothing, despite the 92 per cent, and despite the very real threat of climate change. This is behaviour commonly known as “procrastination’ that has led to the climate debacle we are in, a crisis so severe that experts estimate its economic cost will be 5 to 6 times the cost of COVID-19.

As suggested several times, the only way forward, if Wellington is serious about reducing its GHG, is to put a sinking cap on emissions from these big polluters. While not stopping people from flying, it would force the industry to adapt to the pollution it is responsible for. The Council should create a framework to contain the emission of its two biggest polluters, located in the middle of the city.

This is a timely reminder that, while the city has been trying to bring down its emissions, the airport’s have gone up by a staggering 45% since 2001, and will increase even more if the expansion plan goes ahead. In a time of climate emergency, the Council could commit to not issuing resource consents for the Airport’s expansion. Upon arrival of clean planes , the growth could resume, with strict conditions that emissions don’t increase.

Even with its core operations (“The Council itself”, page 36), the Council fails to set ambitious actions. It starts with a 2030 goal to convert its transport fleet to electric (page 39):

“Alongside identifying opportunities to reduce the size of the Council’s vehicle fleet, a December 2030 timeframe has been proposed to replace all Council owned fossil fuel driven cars, SUVs, vans and utes with zero emission electric replacements. Electrifying the fleet has the potential to reduce our corporate transport carbon emissions …”

While this is laudable (but note the “identifying opportunities” part), why did it stop there. There should be a change to the procurement process for subcontractors, setting up a minimum share of electrified tools, trucks and machinery to be eligible to work for the Council. A gradual increase over the years (20% minimum by 2025, 40% by 2027, etc) would give a firm indication to the industry it is time to undertake the transition, beyond the narrow perimeter of the Council owned fleet.

Finally, the implementation plan is not supported by reliable numbers. It starts, on page 12, by confusing the efforts that will be required, by which decade:

“… Council has committed to ensuring Wellington is a net zero emission city by 2050, with a commitment to making the most significant cuts (43% [from 2001]) in the next 10 years.”

The problem is that a couple of lines below, a table shows that Wellington has already reduced emissions by 10% in 2020 from 2001. With a reduction target of 43% by 2030 from 2001, the reduction between 2020 and 2030 is of 33 points. In the same table, the reduction target between 2040 and 2050 is of 32 points (from 68% to 100%). So, in this plan, the reduction efforts will be steep (33 points) between now and 2030, then relax a little (25 points), then steep again (32 points)! These numbers contradict the story that the commitment will be more significant in the first 10 years – 32 points (or a 43% reduction compared to 2001) is what’s needed to get to zero in 2050.

On page 18, the plan sums up all the 28 actions it has listed and concludes it has the potential to reduce emissions by … 14%! In other words, the implementation plan, with all its advocating, recognizes it will fail:

“This plan includes 28 committed and recommended actions with associated GHG reductions that can be measured. These actions are estimated to result in an 80,043 tCO2e reduction per annum, or a 14% reduction, in city-wide emissions from 2001 levels at 2030”

So the actions are not only unambitious and weak, but also they are insufficient to reach the targets the 2019 blueprint has set out … How can we, as a city, can be satisfied with that?

Overall, the implementation plan is a missed opportunity. It reiterates some lukewarm targets, set a year ago, and does not contain any new meaningful actions to significantly curb emissions in Wellington. It leaves the market to act on its own, and it hopes that Central Government will do the hard work, which makes the City Council a simple observer, with plenty of advocating to do.

Can Councillors and the Mayor say they are truly satisfied with it? Do they think it really lays mechanisms to curb the city’s emissions “no matter what”? Is there something more coming (another document?) which will gives confidence that climate change will not be left to luck in Wellington? Everyone knows that “economic urgency” is not enough to justify lack of action, so why is this plan so pale?