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 (https://guardiansofthebays.org.nz/) 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?

News from Guardians of the Bays

Wellington International Airport’s decision to withdraw its Environment Court application should mark the end of a protracted and costly process for ratepayers, according to community organisations and concerned Wellingtonians opposed to the project.

The Airport first lodged its application for resource consent with the Environment Court in April 2016. That application was put on hold in April 2018 to allow time for serious safety concerns raised by the New Zealand Pilots Association (NZALPA) to be resolved. Those concerns have still not been resolved satisfactorily which is why the airport had to withdraw its consent application.

Co-Chair of Guardians of the Bays Richard Randerson, representing more than 600 concerned individuals as well as other community and ratepayer organisations, said that Wellington Airport had run a protracted and flawed process since they first made the extension proposal.

“There has neither been the demand nor the support for the Airport’s proposal. Wellington Airport has drawn down significant amounts of ratepayer funding for an Environment Court application that has tripped over itself at every turn.

“The Airport is saying it is simply going to redo its proposal and resubmit. Given the many millions of dollars that ratepayers have already paid to the Airport, the Wellington City Council should not commit to any further ratepayer funding for this project.

“The Airport Company’s blind determination to proceed made a mockery of the hundreds of people who submitted against the proposal and of the very real safety concerns about the safety margins that any international airport should meet. The submissions from business, community groups and individuals show up many unanswered questions,” Mr Randerson said.

Co-Chair Dr Sea Rotmann called on the Wellington City Council, representing ratepayers’ shareholding in the Airport company, to call time on any political and financial support for the proposal and put the “White Elephant” proposal to bed, once and for all.

“In this local body election year, it would be an opportune time for all candidates, including the Mayor, to stop this farce once and for all and move on with better projects for our city, like social housing, traffic congestion, infrastructure and earthquake and climate change resilience,” she said.

“The Council’s Low Carbon Capital Plan is also utterly incompatible with support for an extended runway, as aviation emissions are already almost 25 percent of our City’s emissions profile.

“The airport has never had a convincing business case and there is no evidence that airlines will actually use the runway to bring long-haul flights into Wellington. The much-touted ‘Capital Express’ route to Canberra has been canned, after publicly available loading data clearly showed the route was achieving less than a 50 percent passenger loading. And that is despite a $9 million ratepayer subsidy to promote the route.

“We call on Mayor Justin Lester to make good on his promise, made shortly after he was elected last year, that his support was dependent on demand for the route. It has been proven that the demand is not there and yet the Mayor continues to support it.

“The airport extension was going to cost up to $500m according to one expert – much more than the $300 million originally suggested when this process started, four years ago.

“Combined with all the other projects that Wellington City Councillors are also signing up to, ratepayers will be straining under increasing rates and a massive increase in the City Council’s total borrowings, projected to grow from $404.1 million to $806.5 million.

“Wellington ratepayers should not be faced with the financial risk of the extension. The Airport company’s 66 per cent shareholder Infratil have publicly said they are only willing to cover about 17 per cent of the cost.

“What has happened to the many millions of ratepayer dollars of financial support towards the technical reports which are now moot and towards fancy marketing to sell this ill-fated project? It’s time to admit that this has been a costly mistake and to focus on more important infrastructure resilience projects for our city.”

 

 

 

 

Thank goodness for the Air Line Pilots Association (ALPA). The Court of Appeal has just ringingly found in favour of the pilots’ union over the safety issues raised by the Wellington runway extension.

Not only has the previous High Court ruling been overturned. The Director of Civil Aviation (CAA) has also been ordered told back to the drawing board to properly do the job of evaluating the size of the safety areas required for the extension, in full accord with New Zealand’s international obligations. The pilots union were also compensated by the Court of Appeal judges for their costs in bringing the court action.

Interestingly, the reasoning in the Court of Appeal decision almost exactly mirrored the detailed critique of the original High Court decision made in this Werewolf article last October.

All along, the pilots’ safety-related legal challenge had revolved around the size of the 90 metre long Runway End Safety Area (RESA) being proposed for the runway extension. Basically, the RESA is the safety zone required if and when planes ‘run off’ the runway proper and need to decelerate safely, in the event of an emergency, or because of a runway undershoot or overshoot. A 90 metre RESA at each end is the minimum requirement under the international aviation standards, but is less than the 240 metre zone distance recommended – whenever this is ‘practicable’ – under the rules set by the International Civil Aviation Organisation (ICAO).

As Werewolf pointed out in October, the High Court ruling by Justice Karen Clark had supported a chain of dubious reasoning, based on the CAA Director’s acceptance that a 90 metre sized RESA met the ICAO minimum requirements – and that anything further than this could be validly assessed as to whether the additional costs would be “practicable”. In effect, it meant that beyond the 90 metre length RESA minimum, safety issues would be rendered liable to a cost benefit analysis by airport management, and with this dubious process receiving a CAA stamp of approval, and validation by the High Court. Not any more.

The issue hinges – as Werewolf argued and the Court of Appeal has also followed – on the wording of the relevant Part 139 of the Civil Aviation Act and on Annex 14 of the ICAO regulations: “A RESA must extend to a distance of at least 90 metres and, if practicable to a distance of at least 240 metres from the end of the runway strip.” In the High Court, a lot of freight got heaped onto that key word “practicable.”

By way of a possible compromise, the pilots’ union had all along proposed to accept a RESA distance shorter than 240 metres if an artificial buffer zone called an EMAS (for Engineered Materials Arrestor System) was installed in Wellington, of sufficient quality as to create, in effect, a 240 metre RESA safety zone. Basically, an EMAS is made of crushable materials into which the plane wheels can sink, thereby bringing an overshooting (or undershooting) aircraft safely to a halt. One telling sign of the difference between a 90 metre RESA and a 240 metre RESA in safety terms? Reportedly, a 90 metre RESA will capture only around 60% of overruns. By comparison, a 240 metre one will capture over 90%.

The legal battle – in both the High Court and the Court of Appeal – was waged over the tension between what the relevant aviation rules require, and what they recommend, given that the ICAO rules and New Zealand regulations allow for an unspecified degree of discretion, which was duly exercised by the CAA Director in greenlighting the 90 metre RESA minimum length – even though the ICAO advocated far longer where “practicable.” Many of the legal arguments turned on how far the notion of what is “practicable” should have been pursued by the CAA, and to what degree safety recommendations should be weighed against the cost of compliance, given what’s known of the risks involved.

Is it desirable for best safety practices to be traded off against what is “practicably” affordable – in a context where many bigger, heavier and faster landing aircraft on long haul flights (ie laden with jet fuel) will be flying into the notoriously weather-challenged Wellington International Airport in future? After Pike River, many New Zealanders would probably have expected the authorities to err on the side of caution, on matters of health and safety.

Not this time – or not initially, anyway. Arguably, the airport management/CAA/High Court line had defended the minimum safety regulations as good enough – and with anything costing more as being either not “practicable” or at the very least, facing an uphill battle to justify its existence. This, as the Court of Appeal has now found, is not what “practicable” means in the context of New Zealand’s airline safety obligations.

The indefensibility of the CAA/High Court position (as Werewolf showed last October) was most readily demonstrated with respect to the pilots’ suggested EMAS arrestor system compromise. Werewolf’s inquiries with the main international supplier of EMAS systems revealed an installation cost of circa $NZ14 million, which would add only an extra 4.66% to the mooted $300 million cost of the entire runway extension. This would seem entirely “practicable” on cost grounds, one would have thought.

Yet bizarrely, the High Court defended the CAA Director’s refusal to even consider an EMAS, because – Justice Clark reasoned last July – the legislation doesn’t expressly require him to carry out such an evaluation! Here’s how Justice Clark justified the sidelining of an available, relatively affordable safety option:

[125] For this argument to succeed NZALPA must identify the source of the obligation on the Director to consider the engineering techniques and construction options realistically available to the airport operator, including the potential for using EMAS, when assessing the practicability of a runway end safety area longer than 90 metres. Mr Rennie’s argument [for NZALPA] relied on “practicable” bearing the ordinary meaning of “actually able to be constructed”. Accordingly, the Director was bound to consider what is actually able to be constructed.

[126] In undertaking his comprehensive analysis of the proposal put to him the Director was not required to turn his mind to alternatives. Part 139 is silent as to EMAS technology. There is no requirement for EMAS to be installed and no assumption that it will be. Part 139 is dissimilar from Annex 14 which permits shortened runway end safety areas where an arresting system is installed. The focus of Part 139 is on length rather than arresting systems.

Thankfully, the Court of Appeal has now quietly shot this rationale down in flames:

[73] The other error identified by Mr Rennie was the Director’s failure to consider whether an arresting system might provide the necessary degree of additional safety otherwise available from a 240 metre RESA. He simply discounted this consideration on the ground that the viability of an arresting system had not formed part of [Wellington International Airport Limited] WIAL’s plan or decision.

Clark J justified this omission because Appendix A.1(a)

is silent on arresting system technology the focus on length limits the Director’s function to ensuring the physical characteristics of the RESA are acceptable. However, her observation reinforces the importance of correctly applying Appendix A.1(a)’s emphasis on the safety available from a 240 metre RESA.

[74] We are satisfied that the Director in exercising his statutory power was bound to consider carefully whether an alternative means of ensuring safety was available without a 240 metre RESA irrespective of whether or not that alternative was referred to in the rule or in WIAL’s plan. In assessing practicability in light of the statutory purposes of aviation safety and New Zealand international obligations, the availability of an arresting system (as an alternative measure referred to in Annex 14 to the Convention) must be a relevant consideration in assessing the acceptability of the RESA length.

In sum, this has been a victory for common sense – and for safety – over cost-cutting expedience. It is now back to the drawing board for the CAA Director, who may well struggle to explain how a RESA beyond 90 metres in length is not ‘practicable.’ There are several options for him to consider. These are (a) whether some length somewhere between the 90 metre minimum and the 240 metres advocated by the ICAO can be found (b) whether some trade-off can be found between the proposed length of the runway and the length of the RESA and (c) whether an EMAS can be installed that either in itself or in combination with a RESA, will be equivalent to a 240 metre RESA.

In itself, this Court of Appeal decision may not be enough to derail the runway extension. Yet given that (a) the project funding (b) its economic viability and (c) the environmental impact of the extension are all looking like uphill battles…it could well be time to finally pull the plug. In the meantime, the Court of Appeal decision will have some obvious downstream implications for the mooted Queenstown airport runway extension as well. Thanks to the pilots union and to the Court of Appeal, the regulation of airline safety has now become something more than a rubber stamp process in this country. In future, it will be harder for passenger safety to be prematurely traded off against cost savings and profit maximisation.

PSA40951
Singapore Airlines launched Singapore-Canberra-Wellington flights in September. (Paul Sadler)

Singapore Airlines’s new service to Canberra and Wellington has featured plenty of empty seats during its first months of operations, new figures suggest.

According to the Bureau of Infrastructure, Transport and Regional Economics (BITRE) monthly report on international airline passenger and freight numbers, SIA’s flights between Singapore and Canberra were roughly half full in October, the first full month the route has been in service since it launched on September 20.

However, the Canberra-Wellington leg has not been as well patronised, with only a quarter of the seats filled.

The BITRE data indicated SIA carried 2,599 inbound passengers from Singapore to Canberra in the month of October, when it operated 18 flights.

Given flight SQ291 is operated by Boeing 777-200s configured with 38 angled life-flat business class and 228 economy class seats for a total seat count of 266, the BITRE data suggested SIA’s average load factor on Singapore-Canberra was 54.3 per cent.

Meanwhile, the reciprocal SQ292 carried 2,011 passengers from Canberra to Singapore in October, which represented an average load factor of 44.5 per cent.

The Singapore-Canberra-Wellington rotation, which the Star Alliance member dubs the “Capital Express”, operates four times a week.

It is the first scheduled international passenger service to Canberra more than a decade after the short-lived Air Pacific (now Fiji Airways) flights to Nadi ended in 2004.

The flight also links the capitals of New Zealand and Australia for the first time. However, passenger numbers of the Canberra-Wellington leg were lower than that of Canberra-Singapore.

The BITRE data showed SIA carried 1,163 passengers from Canberra to Wellington in October, which represented an average of 65 passengers per flight for an average load factor of 24.3 per cent.

The return Wellington-Canberra service averaged 68 passengers per flight, which represented a load factor of 25.5 per cent.

It is worth noting a December 2016 report in The Canberra Times indicated the BITRE figures do not include passengers travelling from Wellington to Singapore and beyond via Canberra, or travellers headed to Wellington from Singapore via Canberra.

Indeed, the report quoted Singapore Airlines ACT manager Tan Chin Yu saying: “We have been encouraged by the support from the local community since we went on sale in January and remain pleased with the number of customers choosing to travel on the new service, both to Singapore and beyond with direct connections to UK/Europe.

“There has been a good mix of business and leisure travellers in both the business and economy class cabins,” he told the newspaper.

Canberra is SIA’s sixth destination in Australia alongside Adelaide, Brisbane, Melbourne, Perth and Sydney. The airline group’s regional wing Silkair also serves Cairns and Darwin with narrowbody equipment.

The Virgin Australia shareholder and alliance partner is adding more flights to Brisbane, Melbourne and Sydney in 2017.

SIA has also boosted its premium passenger offering with a new SilverKris lounge at Brisbane Airport.

Overall, the BITRE figures showed SIA had an average load factor of 89 per cent for its flights to Australia and 77.9 per cent for its flights out of Australia in October.

The BITRE data for the first full month of SIA’s Canberra operation suggests the passenger numbers will take some time to build up, given Singapore and Wellington are new nonstop markets for the city and that the route was first launched in January, meaning the figures represented the efforts of about seven months of marketing and promoting the new route.

However, there will be more international seats to fill out of Canberra from as early as the second half of calendar 2017, with Qatar Airways planning to launch service to the Australian capital.

In November, Qatar named Canberra as one of eight new destinations being added to its fast-growing network.

The oneworld alliance member indicated flights to Canberra would begin some time in the 2017/18 timeframe, without providing any further details, such as frequencies and operating aircraft type.

The Australian capital would be Qatar’s fifth destination in this country. It currently serves Adelaide, Perth, Melbourne and Sydney nonstop from its Doha hub.

Canberra Airport managing director Stephen Byron said discussions were ongoing with a number of other Australian and overseas airlines about international flights, which could lead to a new service starting before Qatar begins its operations to Canberra.

“We always thought there would be a race to be first to be second if you like,” Byron told reporters at Canberra Airport on November 29.

“We’ve been talking to the other Middle Eastern hub carriers, to the other Asian hub carriers and also to the Chinese airlines about direct flights.

“It is possible that an airline could announce a service to a different route that might commence before that time.”

The BITRE report showed SIA carried 74.4 tonnes of freight into Canberra in October, with 34.7 tonnes of cargo taken to Singapore. There was negligible freight between Canberra and Wellington.

By Michael Reddell, October 17, 2016. Link here.

Fairfax’s Hamish Rutherford had a substantial piece in Saturday’s Dominion-Post on the proposed Wellington airport runway extension, under the heading If we build it, will they come? (a rather similar title to my own first post on the airport last year).  It seemed like a fairly balanced article, covering many (but not all) of the key uncertainties about the project.   Most of them wouldn’t be a matter for public concern if this was to be a privately-funded project, but it isn’t –  and everyone agrees on that.

There was an interesting quote to that effect at the start of the article from airport company chair Tim Brown.

As Tim Brown tells it, the first time he discussed a “back of the envelope”-type analysis of the cost to extend Wellington runway with the airport’s chief executive, Steve Sanderson, the conversation was “completely negative”.

…..Brown had just been presented an outline of a $300 million project, aiming to enable non-stop long-haul flights to the capital.

However, the  potential gains to the airport (two-thirds owned by Infratil, the rest by Wellington City Council) were likely to see a boost in profits that would only justify it investing around $100m.

Whatever the final costs of the project might be (and the estimates are unmoved in the years since), Brown was clear about the chances.

“Literally within 10 seconds I said: ‘So what? What do I care? We’re not going to do that, are we?’,” Brown recalled this week.

This isn’t a project that might need the last 10 or 20 per cent of the cost picked up by the taxpayer/ratepayer to make it viable.  Instead it only works –  even on their own numbers –  if the Crown/WCC picks up two-thirds of the capital cost (and ratepayers have already paid millions of dollars to get the proposal this far).  This is a politically-driven project at least as much (and probably more) than it is a WIAL/Infratil one.

The whole process is getting underway again now, both because the airport company (WIAL) has restarted its resource consent application, and because now that the election is past the ability of citizens and ratepayers to hold in check the big spending “boosterish” tendencies of the mayor and councillors is diminished considerably.  It is difficult to tell quite what the balance of the council now is, but the new mayor has been at the forefront of the various “booster” projects the Council is spending money on, and one councillor who was vocally opposed to the extension in the previous term is no longer on the council.  WCC’s track record –  of wanting to “do something”, spend money on big ticket initiatives, often with little or no public scrutiny (sometimes not even with scrutiny from councilors) – is pretty disquieting.

Presumably under some pressure during the election campaign, the new mayor Justin Lester modified his stance somewhat in responding to pre-election candidate surveys.

I have committed to seeking the resource consent for the airport extension project. It’s too early to say whether the project will proceed because the following three caveats will need to be satisfied before it proceeds:

1. Resource consent approval

2. Financial support from Central Government

3. Commitment from airlines to fly direct routes to Asia.

This is a 50 year project and needs careful consideration before any decision is made.

On the face of it, that looks like a fairly insurmountable set of hurdles.  It is very unlikely that any airline is going to give a commitment to fly direct long-haul routes between Asia and Wellington in advance of (multi-year) construction even starting –  they couldn’t know what would happen to fuel prices, the world/regional economy or the like in the intervening period.    That is especially so given the expressed lack of interest in flying long-haul from Wellington from the one airline that always will be flying New Zealand routes, Air New Zealand.

And, to date, central government seems to have been commendably non-encouraging about any suggestion of central government financial support.

So what –  beyond the track record of poor quality secretive spending – makes me uneasy about the Lester-led Council?  First, Lester knows very well that he won’t get commitments from airlines before the Council has to make decisions on whether to fund the runway extension –  but he might get non-binding expression of interests, which could be politically spun to sound a bit like commitments.  Second, the government has a  track record of ending up funding uneconomic infrastructure projects, including ones it initially poured cold water over.  One could think of Transmission Gully, or KiwiRail, or Northland (by-election) bridges or –  perhaps most concerningly – the City Rail Link in Auckland.   With a modest budget surplus to be subject to an electoral auction next year, is it so inconceivable that the government could change tack (government built houses and immigration last week) and throw $100 million in the direction of the runway extension?  Compared to the spending on Transmission Gully, it would be chicken feed.

And while Lester is quoted extensively in the Fairfax article, neither of the conditions in the pre-election quote above (airline commitments, central government funding) is repeated.  [UPDATE: I gather they are still part of his set of pre-conditions]

So ratepayers beware.  Citizens beware.

In the Fairfax article, Lester tries to blunt possible ratepayer concerns by suggesting the bulk of any Council funding should be raised from business rates rather than from residential ratepayers, because “the majority of the benefit would go to the business sector”.  That might sound superficially plausible (if there were material benefits at all) but the mayor seems unaware of the notion of tax incidence: that the party who writes the cheque to pay a tax or rates bill isn’t typically the party that bears the economic cost.   Much of any company tax is actually borne, over time, by workers –  because less investment occurs than otherwise, and wages are lower as a result.  Just as renters bear some/much of the incidence of rates bills paid by landlords, we should expect that the wider pool of Wellington citizens would bear much of the economic cost of higher business rates to fund an airport extension, even if no non-business ratepayer ever has to increase their direct rates bill.  This is an issue that should bother all citizens, not just business ratepayers.

A lot of the decision-making should turn on a robust cost-benefit analysis of the proposal.  WIAL and the Council have commissioned their own analysis, which suggests large positive national benefits.  Not many people who have looked carefully at the numbers have found their numbers persuasive.  Justin Lester seems to suggest this is all about self-interest

“I’m not going to have people telling me and telling Wellington and telling our council what we should be doing because of their own interests.”

If one wanted to descend to a similar level, one could ask about the incentives on and interests of councillors –  spending other people’s money on big ticket projects.  But, perhaps more importantly, advocates like Lester would do better to front up and explain why they disagree with specific points raised by critics –  whether those critics are representatives of the airline industry, or other commentators and economists.

In the last few weeks, questions have begun to surface about the estimated cost of the runway extension itself.  In a private sector project, citizens wouldn’t need to worry too much.  After all, if the company proposing the development gets it wrong, its own shareholders will be the ones who lose money.  But this is a project where large amounts of ratepayers/taxpayers money will be at stake, and where it isn’t clear how well aligned incentives really are.  The construction estimates are being done for WIAL, which has already concluded that it would only be worth them putting in around $100 million.  If the project is to proceed central or local government will be on the hook for the rest.  Mightn’t the incentives at present be to keep the construction estimates to the low end of a possible range?  Doing so might (a) increase the chances of getting a resource consent (since, sadly, the Environment Court needs to do an economic appraisal) and (b) increase the chances of getting central and local government approval to proceed, with political commitment to the project, with any later cost-overruns perhaps largely falling on those parties.

My own unease has been around three main points; developed in earlier posts:

(a) the large assumed increase in long-haul visitors to New Zealand, simply because of an option to fly long-haul into Wellington (rather than Auckland or Christchurch.

(b) the very large assumed “wider economic benefits” assumed to flow from such increases in visitor numbers, even if the passenger projections were accurate, and

(c) the discount rate being used to evaluate such gains (many of them decades into the future).

I dealt with the visitor number points in this post late last year.   The WIAL cost-benefit analysis uses passenger projections which assume an increase of 200000 visitors to New Zealand (building up over time) simply because it becomes physically possible to fly long haul into Wellington.   That seems implausible.  In his own look at the passenger projections, Ian Harrison of Tailrisk Economics, noted that the numbers assumed that within 20 years 30000 more Americans a year will come to New Zealand simply because they can fly directly into Wellington.   One can imagine a few more might want to arrive via Wellington, but is it really credible that so many more will come to New Zealand as a whole?  Perhaps more startling were the assumptions for “other Asia” (ie other than China and Japan).  At present, only around 30000 people come from those countries to Wellington in a year.  The projections assume that putting in a runway allowing long-haul flights will provide a boost of an additional 105000 visitors annually within 20 years.  Were Wellington Florence, perhaps it would be a credible story.  As it is –  and even with some more marketing spending and a heavily subsidized new film museum – it just doesn’t ring true.  Long-haul passengers don’t come to New Zealand for its cities –  the cities are mostly gateways, and in the case of the lower North Island, Wellington isn’t the gateway to much.  (And yes, I can see the South Island as I type, so perhaps there is a small “gateway to the South, by slow ferry” market).

I touched on the “wider economic benefits” and the discount rates in this post. Here are some extracts from that post:

But much the biggest issues relate to the possibility of benefits to New Zealand from additional foreign tourists buying real goods and services in New Zealand.  Sapere appear to have estimated a total for the likely increase in tourist spending in New Zealand and then subtracted an estimate for the cost of providing those services.  For that they have assumed that 45.5 per cent of the expenditure is domestic value-added (ie returns to labour and capital).  That approach doesn’t seem right and generates highly implausible estimates.

The producer surplus is the gain to the provider of a good or service over and above what he or she would have been willing to provide that service at.   The cost of providing the service includes the cost of intermediate inputs (materials etc) but also the cost of the labour and the cost of capital (a normal rate of return).  If the producer sells product at that cost, there is no producer surplus. In this context, there is no net economic benefits –  economic costs have just been covered.

Over the long haul, in reasonably competitive markets, producer surpluses should be very small (in the limit zero).  For a hotel that budgeted on 80 per cent occupancy, a surprise influx of visitors for the weekend will generate a producer surplus –  the windfall arrivals add much more to revenue than they do to costs of supplying the service.  But over the long haul –  and the airport project is evaluated over the period out to 2060 –  it is fairly implausible that there will be any material producer surplus resulting from well-foreshadowed increases in visitor numbers.  Most of what tourists spend money on in New Zealand are items such as accommodation, domestic travel, and food and beverage.  In all those sectors, capacity is scalable.  One would expect new entrants just to the point where only normal costs of capital were covered.  In the long run, supply curves for most of these sorts of services/products should almost flat.

My proposition is that there are few or no producer surpluses likely to arise from a trend increase in foreign tourism as a result of extending Wellington airport.  But even if there were, any such gains would have to be offset against the loss of producer surplus for New Zealand producer (to foreign producers instead) from New Zealanders taking more holidays abroad.  It makes little difference to the hoteliers if I take my holiday in London instead of Queenstown, while at the some time someone in Manchester takes his in Queenstown instead of taking it in London.

Even if the consultants are right that there would be more additional inward visitors than outward, any producer surpluses from either set of numbers should be small.  And the net of two small offsetting numbers is even smaller.

The safest assumption, in evaluating the WIAL proposal, is to assume that the economic benefits of the proposal all accrue to users, and that there are no material net economic benefits (or costs) to the rest of the community.  Perhaps there is a small amount in the net GST flow, but it is hardly worth focusing on given the scale of the other uncertainties.

Perhaps this point will seem counterintuitive to lay readers and city councillors.  Surely “Wellington” or “New Zealand” is better off from having more foreign visitors (assuming the numbers outweigh the increased outflow of New Zealanders)?  And if so, shouldn’t we –  Councils, government –  be willing to spend money to get those benefits?   The short answer is no.    Good and services cost real resources to provide, and in a competitive market simply providing more goods and services won’t make the city or country better off –  you need to be able to sell stuff that generates more of a return than it costs to provide (including the cost of capital).  Vanilla products and services typically don’t do that.  After all, labour that is used to provide services to tourists is labour that can’t be used for something other activity.  And over a horizon of 45 years we can’t just assume there are spare resources sitting round unused.  Spending public money to generate this economic activity will come at a cost of some other economic activity being displaced (as well as the deadweight costs of taxation, which are allowed for in the cost-benefit analysis).

If, to a first approximation, there are no “net incremental economic benefits” for the “rest of the community” then even if the WIAL/Sapere passenger number estimates are totally robust, the net benefits of the project drop from $2090 million to $954 million.

It is not as if the new visitors – even if they eventuate –  are likely to be top-end exclusive customers.  Business and government travel –  a significant part of the Wellington market –  is unlikely to be much affected, and any boost to overall visitor numbers seems likely to be mostly tourists, consuming fairly vanilla, easily replicable, goods and services.

And what of the discount rate?

It is very unlikely that any private company (or shareholder) would evaluate such a risky project using anything as low as a 7 per cent real cost of capital.  On the WIAL/Sapere numbers, even raising the discount rate to 10 per cent –  a fairly typical cost of capital for Australian companies according to a relatively recent survey by the RBA –  roughly halves the value of any net benefits from the project (even if all the other assumptions about passengers numbers, and “wider economic benefits” are in fact well-founded).  But this runway extension seems much riskier than the typical investment project –  it is location-specific, not usable for anything else, and relies on assumptions that involve transforming the nature of the business (ie there is no long haul capacity at present, and no one can know with any confidence how much demand there might be for the service).  It would be enlightening if Infratil/WIAL told us what cost of capital/discount rate assumptions they would use in evaluating such a project if all the risk were on them?  I’m sure, for such a hard-nosed bunch of operators, if would prudently be more than 10 per cent real.

The Fairfax article picks up a number of other points, including some comments from me. In some of those comments, I probably wasn’t as clear as I might have been.

A few weeks ago, Singapore Airlines –  assisted by a non-transparent Wellington City Council subsidy –  began flying several times a week between Singapore and Wellington, with a stopover in (of all places) Canberra.  No one know whether those flights will succeed (SIA reportedly wants to move to daily), and become viable without ongoing Council subsidies.  That uncertainty is reflected in the article.  Tim Brown from WIAL seems to believe that if the route succeeds, and attracts a larger proportion of foreign passengers, it would tend to support the case for the runway extension.  Justin Lester seems a bit nervous

Like the airport company, Lester also appears to concede that if the Singapore Airlines flights do not show the demand its supporters hope, it would be bad news for the runway extension.

“People are getting on and off these planes four times a week and if the demand doesn’t go up to seven times a week, you know, we won’t need to do it,” he said, quickly adding that this would be a “strong indicator” rather than proof the runway extension was not worthwhile.

I was quoted along similar lines

Would strong success of Singapore Airlines’ new route, with a high proportion of visitors, help prove the case of the missing passengers?

For a man who freely admits he is naturally sceptical about most public infrastructure projects, Reddell is surprisingly open to the idea.

“If they can make that route viable without larger public subsidies than they’ve got then I think that would be interesting”, especially given that passengers face being “stuck in Canberra for a couple of hours”.

But with several caveats.  First, even if the Wellington-Canberra-Singapore route proves viable, it only offers any insight on the long-haul issue if a material proportion of the passengers in and out of Wellington are not just Wellington-Canberra passengers (although it seems unlikely that a daily 777 flight just Wellington/Canberra would be economic).

Second, if such flights prove viable with the current runway, that is great. All involved are likely to gain.  But that is different proposition than spending  (an irreversible) $300 million on a new runway.  As I noted

However, Reddell adds, this may only prove Brown is right about the problem being a lack of marketing, without proving the airport extension itself was needed.

“I would open up the argument, [of] let’s subsidise some more flights, and if they don’t work we can shut them down, whereas with the $300m runway extension, it’s a sunk cost,” Reddell said.

“The great thing about marketing is you can shut it off. You can’t do much with a runway extension” that doesn’t work out.

In the cost-benefit analysis, one of the options they looked at was a big increase in marketing expenditure.  It produced net benefits not that much smaller than those purportedly on offer from the runway extension, and could be re-evaluated constantly, rather than being irreversible.

If central and local government do go ahead and fund the extension, it wouldn’t surprise me if 10 years hence there were a few long haul flights in and out of Wellington.  But, of itself, that would prove nothing about the economics of the project.  The financial contribution of central or local government would, no doubt, be treated as a bygone –  with no direct financial returns, and arguable and uncertain indirect ones –  and with a runway in place, and only its own capital contribution to cover, perhaps WIAL could attract a few flights.  That might leave today’s councilors feeling better, as they show the extension to their grandchildren, but is no reason to think that Wellington citizens and ratepayers will have been made better off as a result.

I’ve not touched at all on issues like the possibility that future carbon charges make long haul travel less attractive than it is today, or that rising sea levels might raise questions about Wellington airport more generally.  But they all should bring us back to Justin Lester’s point

This is a 50 year project

and

His “gut instinct” was that the case would eventually be proven, but it could be soon, or it could be decades away.

The costs of waiting simply aren’t that large.  If the proponents are right, the case will look that much more compelling  –  and less risky –  10 years from now.  If they are wrong, (lots of) real resources will have been irreversibly wasted –  and that burden will be felt not just by Wellington businesses, but by all citizens and ratepayers of Wellington.   I’d urge the incoming Council to reflect on that choice, and to take seriously what decisionmaking under uncertainty should mean.

by Lindsay Shelton, October 11, 2016. Link here.

A report from the Wellington City Council identifies a “worst case scenario” if only trucks are used to carry the rocks needed to build a longer runway at Wellington Airport.

The report, prepared by the council for the airport’s resource consent application, says that 252 people sent submissions that were concerned about traffic during the four year construction period, and 202 people were concerned about noise.

The council report states:

The Project has the potential to generate adverse noise effects given the scale of works proposed, the duration of the construction project, and the proposed night-time construction works. In addition, the Project proposes road haulage of fill during off-peak periods (9.30am-2.30pm, and 10pm-6.00am) during weekdays, which will generate traffic noise effects on properties along the haulage route.

The applicant has provided a Construction Noise Assessment … which assesses the noise effects associated with constructing the runway extension, and the land-based transportation of construction materials (including fill) to the site. The report also identifies measures to mitigate such noise.

A noise expert has reviewed the airport’s proposal and has found that

The Project includes a construction duration of 48 months (or greater), and due to airport operations, construction will be focused at night when construction activity is usually avoided near residential activities.

The nearby residential properties on Moa Point Road will be significantly affected by the proposed night time construction noise (with noise levels of up to 14dB over the night limit of 45dBLAEQ), and some properties on Kekerenga and Ahuriri Streets to a lesser extent will also besignificantly affected (ie, up to 8dB over the night limit of 45dBLAEQ). The noise effects will have the potential to result in sleep disturbance and associated health issues for the residents of the Moa Point Road properties,and sleep impairment for the residents of some properties on Kekerenga and Ahuriri Streets.

There are limited opportunities for mitigation at source, namely onsite construction noise mitigation measures, or mitigation measures on public land.

The applicant has assessed the night truck movements in terms of traffic noise, and has established a programme of reduced truck numbers to keep the increase in noise emissions at an acceptable level. This approach is supported and would ensure truck noise does not become significant for neighbouring residents to the haul route.

The applicants’ noise assessment does not address the effects of the outbound day haulage route along Lyall Parade and Onepu Road. This is less likely to have significant effects given it’s during the day, but this assessment should still be undertaken to provide a clear understanding of the overall traffic noise

[A consultant] has identified that mitigation measures targeted at a set number of properties (on Moa Point Road, Kekerenga and Ahuriri Streets) are essential, and without this, the noise effects on occupants of these properties will be potentially significant. [He] further recommends that these mitigation measures be included as consent conditions. These proposed mitigation measures, such as relocation and acoustic insulation of properties, rely on the co-operation and permission of the property owners or occupiers.

…While these mitigation measures may significantly improve the impact of construction noise on these parties, there is no obligation for the owners or occupiers to accept alterations to their houses or to temporary relocation during the construction period. In the event that such measures are not accepted by them, there will remain a significant noise effect on these parties.

… it ultimately will depend on whether the applicant can manage to obtain agreement from these people for either mitigation option. If this cannot be
obtained, then there remains a significant construction noise effect, which will be unacceptable.

The council report also assesses the effect of construction traffic:

The worst case scenario is assessed from a traffic perspective, that being that all fill will be sourced from Kiwi Point and Horokiwi Quarries and transported to the site via road haulage. Therefore, the Council’s construction traffic assessment has been 2709846_2 based on road transport of all fill within the parameters (i.e. truck numbers, haulage routes, operating times, etc) proposed by the applicant.

The haulage traffic is likely to have the most discernible level of traffic effects given the overall volume of heavy trucks on the roading network where land based transportation of fill material is adopted (up to 620 daily truck movements/60 trucks per hour). The applicant has acknowledged these effects, and has proposed haulage routes and variable truck movements (i.e. differing truck numbers at different times of the day and week) to address them.

The proposed haulage traffic travel times avoid commuter and school traffic peaks, and weekends, which is appropriate.
The route selection, being predominately the state highway network with day time use of Lyall Parade and Onepu Road, is appropriate.
 The use of high performance motor vehicles (HPMVs) is an appropriate choice of haulage vehicle i.e.it will minimise the total number of truck movements

Haulage via road is, from a traffic perspective, the worst case scenario. While the applicant has requested the worst case scenario be assessed as part of this application, this should be avoided if at all possible and should only be used if all other non-road based options are exhausted.

The report also states:

As already noted however in terms of noise, the proposed mitigation measures in the form of purchasing the affected properties, providing temporary re-housing during construction works, or providing acoustic insulation and mechanical ventilation rely on property owners or other occupants accepting these options.

Where this does not occur, the residents are exposed to some significant noise effects.

With respect to visual amenity, as outlined previously, the residents of Moa Point Road will experience the greatest level of visual amenity effects, which are unable to be mitigated. For the Moa Point residents it is unlikely that these objectives and policies will be met.

Read also:
Regional Council report identifies issues during runway construction

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Wellington Airport’s runway extension faces another legal challenge, on safety grounds
by Gordon Campbell, October 19, 2016. Link here.

If the $300 million runway addition planned for Wellington Airport proceeds, it will have a major impact on the marine environment at both ends of the 355 metre extension, and particularly so at the Cook Strait end. Besides the permanent effect on tidal patterns along the south coast, people living adjacent to the airport will be affected by the noise, dust and truck movements during the construction phase of the project. A few weeks ago, these and other aspects of the runway extension were canvassed within Wellington Regional Council reports that were released right on the eve of the recent local body elections.

The suggested steps to mitigate the effects – around Moa Point for instance – will inevitably add to the cost of the runway extension, although by how much will depend on what mitigation steps are eventually deemed to be essential by the Environment Court, which will rule on the environmental consent application in early 2017.

Wellington Airport is two thirds owned by the NZX listed company Infratil, and the remaining third is owned by Wellington City Council. Infratil is proposing to meet one third (ie, $100 million) of the runway extension costs, with central government picking up another third, and Wellington City Council the remaining third. In Infratil’s opinion, the bulk of the runway extension costs should come from taxpayers and ratepayers because, in its view, most of the benefits will accrue to the country and to local region rather than to the airport owners – who would otherwise be unable to justify the runway expansion costs on commercial grounds.

Obviously, the $300 million estimate is a pre-mitigation figure. In September when Scoop queried Infratil CEO Tim Brown about the accuracy of the $300 million estimate, Brown stuck by that amount, but only conditionally :

‘A lot of research has gone into that figure. We believe its going to be quite accurate…but what will happen at the end of this, of course, is that if we get the [environmental] consents, we’ll get the consents with who knows what conditions. So those conditions could add additional costs. [For now] its an accurate cost of what the extension will cost before any embellishments.’

Some of the environmental impacts will be only transitional during the construction phase, yet others will permanently affect the wave patterns and marine eco-system. In addition, the runway extension project has been controversial on at least two other fronts :

(a) the safety of the extension design, which will be tested in the Court of Appeal in a few days time and

(b) the net benefits likely to accrue from the injection of ratepayer and taxpayer funds.

This year, runway advocates and their critics have sharply disagreed over the credible increase in passenger traffic (inwards and outwards) that the extension would be likely to generate, and the net flow-on value to the Wellington region, and national economy. Scoop will analyse these financial arguments in a separate article. This article will address only the safety issues, which will be argued before the Court of Appeal on Thursday, October 20.

Safety First

The safety-related legal challenge revolves around the size of the 90 metre long Runway End Safety Area (RESA) being proposed for the runway extension. Basically, the RESA is the safety zone required if and when planes ‘run off’ the runway proper and need to decelerate safely, in the event of an emergency, or because of a runway undershoot or overshoot. A 90 metre RESA at each end is the minimum requirement under the international aviation standards, but is less than the 240 metre zone distance recommended – whenever this is ‘practicable’ – under the rules set by the International Civil Aviation Organisation (ICAO). In July, the High Court rejected a challenge mounted by the Airline Pilots Association (ALPA) against the decision by the Director of the Civil Aviation Authority (CAA) to allow only a 90 metre RESA for the runway extension.

That CAA approval of a 90 metre RESA for Wellington is important in itself. It will also create a precedent for Queenstown airport as well. Or for any other New Zealand destination seeking an increase in long haul international aircraft, in a context where the geographical terrain makes it costly for the ‘best practice’ safety standards to be met.

As will be explained below, the pilots’ union challenge rejected by the High Court in July had two main elements., Firstly, ALPA contended that the CAA should have required the longer RESA recommended by the ICAO, rather than the 90 metre one endorsed by the CAA Director. The wording of the relevant Part 139 of the Civil Aviation regulations states: “A RESA must extend to a distance of at least 90 metres and, if practicable to a distance of at least 240 metres from the end of the runway strip.” In the High Court, a lot of freight got heaped onto that key word “practicable.”

Secondly, and by way of a possible compromise, the pilots union proposed to accept a shorter RESA distance if an artificial buffer zone called an EMAS (for Engineered Materials Arrestor System) was installed in Wellington, of sufficient quality as to create, in effect, a 240 metre RESA safety zone. Basically, an EMAS is made of crushable materials into which the plane wheels can sink, thereby bringing an overshooting (or undershooting) aircraft safely to a halt. One telling sign of the difference between a 90 metre RESA and a 240 metre RESA in safety terms? Reportedly, a 90 metre RESA will capture only around 60% of overruns. By comparison, a 240 metre one will capture over 90%.

The legal battle is over the tension between what the relevant aviation rules require, and what they recommend, given that the ICAO rules and New Zealand regulations allow for an unspecified degree of discretion, which was duly exercised by the CAA Director in greenlighting the 90 metre RESA length. As mentioned, many of the legal arguments turned on how far the notion of what is “practicable” should have been pursued by the CAA, and to what degree safety recommendations should be weighed against the cost of compliance, given what is known of the risks involved. Is it desirable for best safety practices to be traded off against what is “practicably” affordable – in a context where many bigger, heavier and faster landing aircraft on long haul flights (ie laden with jet fuel) will be flying into the notoriously weather-challenged Wellington International Airport in future? After Pike River, many New Zealanders would probably have expected the authorities to err on the side of caution, on matters of health and safety. Not this time, not so far.

So far, surprisingly little consideration appears to have been given – in the High Court or media coverage – to the cost of the EMAS compromise proposal that ALPA have put on the table. This does seem odd, given that concept what is, or isn’t practicable/affordable has played such a prominent role in the legal wrangling to date. In the US, the Federal Aviation Administration (FAA) is the counterpart of our own Civil Aviation Authority. To comply with FAA regulations issued in accordance with a ten year phase-in plan contained in a 2005 Congressional vote, hundreds of US airports have been required to create either a 240 to 300 metre RESA, or to install an equivalent EMAS arrestor system, by December 31, 2015. Here’s a February 2016 FAA fact sheet advocating the practical utility of EMAS.

And here’s a 2015 update on the RESA and EMAS upgrades being pursued by the ICAO and FAA.

Evidently, the FAA regards an EMAS as providing a particularly suitable solution for locations (such as Wellington) where the available land is scarce, and very costly:

The EMAS technology improves safety benefits in cases where land is not available, or not possible to have the standard 1,000-foot overrun. A standard EMAS installation can stop an aircraft from overrunning the runway at approximately 80 miles per hour. An EMAS arrestor bed can be installed to help slow or stop an aircraft that overruns the runway, even if less than a standard RESA length is available.

For this article, Scoop has tried to establish what it would cost to install an EMAS in Wellington. First, I accessed the contract document for the recent EMAS project at San Francisco International Airport, available here.

As this contract document indicates, it cost San Francisco $US40 million for a four runway EMAS, or circa $10 million for each runway. To check this figure, Scoop also contacted Zodiac Aerospace in France, who are the main supplier of EMAS systems globally, and to almost all US airports – and asked them this question :

I’m looking for an approximate cost to buy, install and maintain (annually) an EMAS for an international airport scheduled to have regular services for all current regular long haul aircraft EXCEPT the Airbus A-380. The EMAS in question will be overlaid on part of a 90 metre RESA, and be of sufficient quality as to be an effective substitute for a 240-metre RESA. 

Todd Gressick, regional director of Zodiac Aerospace for the Asia Pacific and Latin America, replied:

‘I am going to assume you’re talking about Wellington or Queenstown. If so the prices we have provided in the past are about $7,000,000 – $9,000,000USD for the system, not including any site prep that would then make the 90m RESA equal to a 240m RESA.  Annual cost to maintain the system is man hours 1-2 hours per month for inspections from the airport operations and/or maintenance departments. Annual cost for materials is around $1,000USD (seam seal, tape, adhesive, etc.) ‘ 

So yes, it does seem that $US10 million (ie, NZ $14.11 million) is an accurate enough ballpark estimate. Given the minimum $300 million cost of the Wellington runway extension (prior to the mitigation costs related to the environmental consent) this means that the cost of an EMAS that would render Wellington airport fully compliant with the emerging safety standards in US ( and global) aviation markets would add merely an extra 4.66% to the existing project cost estimate, with this proportion declining further, once any mitigation costs are factored in. That degree of added cost would seem very “practicable.”

Overshoots and undershoots occur in international aviation on a regular basis. Besides the hundreds of lives that could be saved, the cost of a $10 million EMAS in Wellington ( and eventually, Queenstown) would be more than outweighed by the massive direct and reputational costs of a serious accident, and the impact on our tourism industry – which, with justification, would be deemed to have cut corners on safety. To most observers, an EMAS installation seems entirely “practicable” in the context of Part 139 of the Civil Aviation Act and Annex 14 of the ICAO regulations. Yet in July in the High Court, Judge Karen Clark [pictured left] barely considered the EMAS option as relevant to the matters before the court. In fact, she appeared unwilling to entertain why the CAA Director should even be expected to consider whether an EMAS was a ‘practicable’ (ie, affordable) solution to the safety concerns on the table. At paras 125 and 126, the Clark judgement, in effect, asked what is arguably the wrong question : where does it say that the Director needs to consider an EMAS ?

[125] For this argument to succeed NZALPA must identify the source of the obligation on the Director to consider the engineering techniques and construction options realistically available to the airport operator, including the potential for using EMAS, when assessing the practicability of a runway end safety area longer than 90 metres. Mr Rennie’s argument [for NZALPA] relied on “practicable” bearing the ordinary meaning of “actually able to be constructed”. Accordingly, the Director was bound to consider what is actually able to be constructed.

[126] In undertaking his comprehensive analysis of the proposal put to him the Director was not required to turn his mind to alternatives. Part 139 is silent as to EMAS technology. There is no requirement for EMAS to be installed and no assumption that it will be. Part 139 is dissimilar from Annex 14 which permits shortened runway end safety areas where an arresting system is installed. The focus of Part 139 is on length rather than arresting systems.

With respect, that reasoning seems odd. Apparently, because the Part 139 regulations do not specify an absolute need to consider EMAS technology (despite the mandate this technology has received from the FAA, its growing use in US airports large and small, and the need that Part 139 imposes to entertain what is “practicable” to achieve in the pursuit of safety) the High Court decided otherwise. Our CAA Director was not required to include an available, affordable and safety enhancing EMAS technology as part of his decision nexus – before he gave his blessing to a lower safety standard than what the ICAO recommends. Moreover, this example of regulatory undershooting was condoned by the High Court for a runway extension whose economic gains are being weighed out until 2060.

To repeat : if it is not “practicable” on cost grounds for Wellington International Airport Ltd to comply with the 240 metre RESA that’s increasingly the safety norm in developed countries, why is the CAA also declining to even consider the case for substituting a practical, affordable aircraft arrestor system that would, in practice, make the likes of Wellington and Queenstown compliant with the current FAA/ICAO safety recommendations ?

True, some countries with strong tourism sectors have managed to do even worse, and do operate below the minimum safety standards that govern international aviation. Thailand for instance, Thailand was downgraded last December by the ICAO and FAA on safety grounds. However, the safety ‘red flag’ raised over Thailand has reportedly led directly to safety improvements.

Given the emphasis that New Zealand is placing on tourism – the tourism industry is currently poised to supplant dairy as this country’s main export earner – one would have thought this country would be keen to demonstrate its compliance with aviation industry ‘best practice’ standards on safety matters, rather than trying to skate by with the minimum standards. In the July judgement on the Wellington runway extension, the High Court ruling danced around this trade-off between safety and costs. No, the Court reasoned, ALPA were quite wrong to argue that safety was being traded away for cost savings.

NZALPA criticises the cost-benefit analysis as subordinating the objective of safety to the issue of cost. The criticism is unfounded.

The High Court then proceeded to explain what it thought was really happening. Spot the difference, if you can :

The Director’s use of a cost-benefit analysis was not a subordination of safety to cost, but a process by which safety benefits could be rendered in economic terms to be understood properly alongside costs….

Oh, right. Obviously different. And in any case…regardless of what the IACO/FAA might say or recommend, the High Court felt confident that the safety concerns were being fully satisfied, merely by reaching the minimum standard :

The safety objective is integrated into the requirement for a 90 metre runway end safety area, the minimum length established by the Chicago Convention standard.

So that’s alright then. After all, if it wasn’t good enough, it wouldn’t be called the minimum, right?

As Tim Brown of Infratil pointed out to Scoop, larger planes already use Wellington International Airport occasionally – when there’s a weather diversion, or when a regal dignitary flies into the Capital in their customised jet – without incident. As Scoop asked ALPA president Tim Robinson [pictured left], doesn’t that practice erode ALPA’s argument?

Not really. “The big difference there,” Robinson replied, “is that the airport is being used as an emergency alternate. It is used for diversions, but they’re quite a rarity. [Wellington International Airport Ltd] are talking about a regular commercial operation, involving a larger airbus A340 and Boeings which the airport do not have operating to it on a regular basis right now, but which will be part of the regular services they’re hoping to attract.”

Moreover, Robinson adds, even the new Singapore Airlines link from Singapore to Canberra to Wellington is a short hop service, using relatively small aircraft. Not long haul. “On Wellington/Canberra the fuel requirements are not as great as on a long haul direct to China or Los Angeles. If aircraft are going to be departing Wellington for those ports they are clearly going to be fully laden with passengers, and fuel. They’re going to be right at the limits of the performance capability, using the Wellington runway. Because even at its runway extension length [of 2,400 metres] that’s still relatively short for an international airport.”

Arguably, the climatic conditions (erratic wind gusting etc) that are regularly experienced at Wellington Airport are all the more reason why the emergency runoff area for the new extension should be consistent with international best practice, and not set at the bare minimum required to operate legally. If (a) the extension gets the go ahead from the Environment Court, (b) sufficient financing from central and local government is found, and (a) Wellington eventually attracts the long haul airline traffic claimed by its advocates, this will mean that many more pilots will be landing at Wellington Airport without prior experience of the unusual challenges that this airport regularly poses. That’s another reason why erring on the side of safety would seem like a sensible path to follow.

The alternative route – of a cost cutting aimed at getting the runway deal on the table with a price tag that central government might feel more inclined to support – not only involves playing dice with the lives of passengers and crew, but could also, in the long run, be false economics. The cost of one avoidable crash, like this overrun that occurred in Toronto on Pearson Airport’s new runway in 2005, would totally eclipse any interim savings:

An investigation into that accident found….”the overrun area left no additional margin for error and contributed to a high casualty rate.”

Air France says Transport Canada was “negligent” by not implementing the recommendations of a coroner’s inquest [into a prior] 1978 crash that urged the creation of a 300-metre safety area to give aircraft more room to stop after landing. It also charges that the airport failed to install an apron of special concrete [an EMAS] designed to quickly slow aircraft unable to stop on the runway…

Wellington may have to relearn that lesson. Make sure your seat is upright, folks, and ensure your tray table has been folded away. This landing could be rough.

Footnote : Wellington International Airport’s readiness to pursue a path of minimum safety requirements on runway length should not be seen as typical of the aviation industry in this country. The pilots and the airlines have been very safety conscious. Air New Zealand for instance, has fitted ROPS (Runway Over-Run Protection Systems) technology to its Airbus fleet, and this year, this installation has enabled night flights into Queenstown airport.

The ROPS technology – which alerts pilots when the runway length could be exceeded while landing – is briefly explained by Airbus here.

ROPS continuously monitors an aircraft’s position and calculates the distance needed to safely stop on the runway in dry and wet conditions. If the determined stopping distance is longer than the available runway length, ROPS triggers visual and oral alerts – either on final approach to landing or during the post-touchdown rollout.  Operational experience has already demonstrated the system’s value on several occasions… a ROPS alert enabled A380 pilots to make a “go-around” during approach after increasing tailwinds created a potential for runway overrun.  In another situation, pilots received a ROPS alert to use maximum braking and thrust reverse for a safe stop on an icy runway because the aircraft had been in a non-standard configuration after landing. In further augmenting ROPS’ capabilities, Airbus will enable pilots to input additional contaminated runway conditions (standing water or compacted snow, as examples). 

For this article, Scoop asked two questions about this evolving technology. Namely, which aircraft in Air New Zealand’s national and international fleet currently utilise ROPS technology – and which aircraft in its domestic and international Boeings fleet use the Honeywell Runway Awareness and Advisory System (RAAS) or any equivalent variant of its Enhanced Ground Proximity Warning System? “All of our domestic and international jets,” Air New Zealand replied, “have either the Honeywell EGPWS system or equivalent.”

That’s re-assuring to know. So even if Wellington does eventually get the legal greenlight for its 90 metre RESA, pilots will not be left entirely bereft of aids to help them prevent overshoots and undershoots. Not that Air New Zealand believes for a moment that Wellington airport will succeed commercially with its runway project, anyway. Out of the blue, Air New Zealand also added this bald footnote to my ROPS/Honeywell inquiry :

Air New Zealand has been very clear that it will not operate long haul direct services to/from Wellington. It’s not the length of the runway that is the problem, it’s the size of the local market.  There’s simply not sufficient traffic to make such services commercially viable.

Link here.

The Regional Council last week released a 165-page staff report analysing Wellington Airport’s application for permission to extend its runway.

The report, on the airport’s resource consent application, confirms that of the 776 submissions received, 527 were against the runway extension, 227 were in support of it (either in full or in part), and there were 18 neutral submissions and four conditional.

The airport is seeking permission for reclamation work to be carried out seven days a week, 24 hours a day. The proposed construction programme indicates that reclamation filling could take between 5 and 18 months depending on the source of material. The entire project will take up to four years.

The report refers to 310 trucks per day taking loads from quarries to the reclamation site:

Traffic emissions during construction will arise from trucks transporting fill material to the construction zones at the airport and construction vehicles at the airport construction site…The applicant considers that it is unlikely that there will be any measurable changes in vehicle related combustion emissions from 310 trucks per day…. [An expert] has advised that the covering of loads is “best practice and will satisfactorily mitigate potential fugitive dust over the haul route.”

Though no final decision seems to have yet been made on the use of barges, the airport is expecting that:

between 15 – 25 barges (i.e. 30 – 50 two way movements) will be required to operate each day (over an 18 hour period) over a 5 – 18 month period.

Barges transporting fill material to the construction site will follow the existing shipping route within Wellington Harbour to a point opposite Pencarrow Head. From there, barges will travel across the harbour entrance and around to the construction zone. It is intended that this route on the east side of the bay entrance will minimise disruption to recreational activities in the bay such as surfing, kiteboarding and stand-up paddle boarding.

Among concerns raised in the staff report is the effect of runway reclamation on the city’s wastewater outfall:

The Moa Point wastewater treatment plant coastal outfall passes through the area of the proposed reclamation. In the early phases of the work it is proposed to construct a protection structure over the outfall pipe to avoid damage due to the placement of the dyke and reclamation fill.

And here are the concerns:

The construction of a protection structure over the MOP has the potential for adverse effects on the environment should the works result in damage to the MOP, specifically the discharge of treated wastewater into the CMA at the works location. Further, the runway extension construction works could impact the interceptor main and sludge pipeline.

The application states that the effects of the reclamation construction on the MOP include loading stress on the pipeline and settlement of sediment/gravels under the pipeline. However, the application does not outline the consequences of damage to the pipeline and potential pollution of Lyall Bay of wastewater should this occur. Nor does the applicant recognise the potential for adverse effects on other infrastructure, specifically the interceptor main nd sludge pipeline.

Concerns from the Wellington City Council are described:

Construction activities … could affect the sludge pipeline (which carries sludge to the Southern Landfill) that generally follows Moa Point Road and the wastewater interceptor main under the southern end of the existing
runway that carries sewage to the WWTP. The sludge pipeline is a high
pressure pipeline and any damage or breach of it will result in significant adverse effects on the environment.

In their submission, WCC seek the protection of the pipeline, inceptor main and sludge pipeline in both their physical extents and their operational and maintenance capabilities. The submitter (WCC) states that any damage to the outfall or restriction in being able to maintain and operate the outfall has the potential to cause significant costs to the community in both monetary and environment…

[The city council is] not convinced that ‘burying’ the MOP under the runway reclamation is an acceptable result. A more detailed outline of the process to agree the mitigation and timing of its implementation is considered to be required in the consent conditions.

The airport’s view:

… the MOP will either be protected in place or realigned so that it will not be impacted by the reclamation. It will be up to the form of contract and the final construction programme whether moving (which will require additional consents) or protecting the outfall takes place prior to or concurrent with marine based reclamation works.

The report uses diplomatic words in its summaries. Here’s one of the summaries.

The proposed runway extension and SWFS will likely result in minor
effects in relation to physical disturbance and loss of habitat;

Construction noise, vibration and light will likely result in minor effects on
mammals and fish;

Sediment discharges during ground improvement work, placement of the
rock dyke, earthworks to remove the hillock and as a result of dewatering will likely result in minor effects;

Adverse effects from the proposal on the Taputeranga Reserve are likely to be less than minor.

Over 200 submissions raised concern about construction and operational noise. The report identifies the effect of the construction work on recreational users in the Lyall Bay area. They

… will be exposed to construction and haul route noise. Recreational users on Moa Point Road and beach and the breakwater will experience the highest level of construction noise (up to 60 dB) and haul route noise (61 dB).

But not to worry.

In summary, provided the applicant complies with the recommended conditions of consent, we consider the effects of construction noise on recreational users of the CMA in Lyall Bay will be less than minor.

However,

Effects on recreational users of the CMA at Moa Point is likely to be more than minor given its close proximity to the construction site. Albeit temporary (up to 48 months) construction noise will likely impact recreational amenity in this area

Other effects are identified, including fishing:

The temporary exclusion zone around the proposed runway extension construction site will restrict access to approximately half of the area used for gathering seafood between Moa Point and Hue-te-taha Peninsula during construction (3-4 years).

and surfing:

Access to the surf break Airport Rights will be lost permanently from commencement of the proposed runway construction.

Expert advice from Dr Michael Steven states:

I consider short term effects on water-based recreational activities, such as surfing and gathering kai moana to be more than minor within the areas of the exclusion zones. For some recreationists, such as surfers, adverse effects from the SWFS exclusion zone may be unacceptably adverse in the short term, and unable to be mitigated.
and:
For expert surfers, the loss of the Airport Rights break may be regarded as an unacceptable outcome, and an outcome that is beyond the potential of the SWFS to mitigate.
In summary, we consider the effects on surfing amenity as a result of the proposed runway extension will be more than minor because the Airport Rights surf break will be completely lost and the three other surf spots in Lyall Bay could have a reduction in characteristic surf rides of between 14-29%.

Dr Steven has also advised:

The proposed runway extension will result in highly adverse effects on the biophysical landscape/seascape in Lyall Bay east/Moa Point embayment (compared to the moderate rating applied by the applicant) given the proposal involves a total loss of 10.8ha of marine environment and its replacement with a terrestrial form.

For residents on Moa Point Road and the beach at Moa Point, I consider the effects on views from this area to be extreme, and unable to be remedied or mitigated. As such, I regard these effects as significant and unacceptably adverse.

Another expert considers the effects of the proposal on coastal bird habitat and says these will be more than minor and the potential effects on regional bird populations as a result of increased birdstrike could be significant.

The report however contains no analysis or criticism of the economic benefits being claimed for the longer runway:

With construction costs excluded, the economic wellbeing of the Wellington region has been assessed to improve by $1billion on the most likely scenario, even if that community were to fund the entire cost of the project through local and central taxes. The applicant acknowledges that how the runway extension would be funded is still to be determined.

The Regional Council’s report, in full, is here.

By Michael Gunson

dude-wheres-my-surfbreak

WIAL’s grand plan for Lyall Bay’s surf breaks:

The Surf break Protection Society (SPS) would like to think that its submission opposing Wellington International Airport Limited (WIAL)’s airport extension and artificial swell focus reef is the cause of the airport company’s decision to suspend and revise its consent application. The reality is probably that the society’s submission is only one of a number of high quality submissions that have led WIAL to suspend the process.

After recent investigations and inquiries by SPS, WIAL have stated that they have no plans to increase the Moa Point Rd seawall, next to the Corner surf break, during the next 12 months.

This has come as a bit of a surprise to Wellington surfers, as it was assumed these works since 2000 had been undertaken by the Wellington City Council, not the largely privatised WIAL. The works on the seawall are undoubtedly having an adverse effect on the Corner surf break, Wellington’s most popular surfing venue. These works coincide with WIAL seeking the deletion of the Corner surf break from the GWRC Natural Resources Plan (PNRP)’s schedule of regionally significant surf breaks.

WIAL have been modifying the Moa Point Rd seawall next to the Corner surf break utilising a permitted rule under the old existing GWRC Regional Coastal Plan (Dude, this means WIAL don’t have to ask anyone to throw rocks over the seawall!).

The existing Regional Coastal Plan is soon to be replaced with the new Proposed Natural Resources Plan (PNRP). The PNRP specifically incorporates surf break protection policies, compliant with the New Zealand Coastal Policy Statement 2010.

The works on the seawall have changed the behaviour of swell approaching the Corner surf break, by changing the slope angle, which now absorbs much of the swell energy traveling along the seawall.

Over the last 6 years or more, the works have continued with an increased frequency/scale, impacting on surfing wave quality at the Corner surf break.

A number of Wellington’s surfers are also confused as to what WIAL is actually offering by way of the airport company only mitigating for the impacts of the proposed airport extension on Lyall Bay’s surf breaks.

WIAL’s Assessment of Environmental Effects (AEE) for the consent application (page 137) states that “Avoiding or reducing the effects of the proposed runway extension on surfing amenity is difficult to achieve without impacting the length of the runway extension.”

So instead of avoiding or remedying effects on the Corner (and acknowledged significant effects on the Bay’s middle and western surf breaks) WIAL’s application to the Environment Court is only in the context of mitigation, the lowest response available under the RMA (aside from doing nothing).

surfing

WIAL’s own desktop modelling indicates an adverse effect on Wellington’s most popular “Corner” surf break, which the airport company contests is only minimal.

The possible reduction of wave rides at “The Corner” is likely to only be noticeable by the most seasoned and experienced surfers who have surfed “The Corner” for many years (WIAL AEE).

The peer review of WIAL’s technical report acknowledges that the effects of wave-driven currents on the Corner are also an unknown factor.

WIAL’s DHI technical report does not take into account the cumulative effects of a replacement sea wall, and CentrePort’s proposed dredge disposal grounds off Fitzroy Bay on the Corner surf break, as these activities are not part of the airport extension consent applications.

WIAL is still unwilling to undertake a degree of baseline monitoring necessary to gauge the overall adverse effects on the Corner surf break. (Note that seeing they have already impacted on the surf quality, even a baseline would show it to be worse than it previously was).

WIAL have given an undertaking that when they provide a final design concept for the artificial swell focus reef (not yet provided in WIAL’s AEE), the focus reef structure itself, will not have an adverse effect on the Corner. This is utterly meaningless unless WIAL understand the baseline conditions, the natural processes that form the surf break, and environmental influences that impact on the break, like modifying the seawall (which they don’t).

Artificial swell focus reefs are an unproven technology, there is not one working example anywhere in the world designed specifically for surfing.

What happens if the artificial surf focus reef fails?

It doesn’t really seem to matter, because WIAL will have their airport extension and any response required will be guided simply by the objectives, rules, and policies in the GWRC Proposed Natural Resources Plan (PNRP) that protect the Corner surf break, and all other surf breaks of Lyall Bay. Unless WIAL’s submission to the PNRP is successful of course…

WIAL have submitted decisively in opposition to these surf break protections in the PNRP, and there is every indication that WIAL will appeal these protections for the Corner surf break through an Environment Court process entirely separate to the airport company’s consent applications.

The hearings for the PNRP are due in March next year, and the suspension for the WIAL airport extension application has lent WIAL a helpful timeframe to test its submission seeking the deletion of the Corner surf break from the PNRP schedule of regionally significant surf breaks, before the airport extension consent applications begin.

WIAL need the Corner deleted to provide a mitigation offset for the airport extension, a promenade with a new rock-armoured seawall down the length of Moa Point Rd with viewing platforms, and a reworked breakwater (WIAL AEE).

In WIAL’s submission to the GWRC PNRP, the company has comprehensively sought the deletion of the Corner surf break from all references in the plan, and there is every possibility that WIAL would be prepared for a trade-off in not pursuing the deletion of surf break policies totally in the PNRP, simply for the removal of the Corner surf break, from the PNRP’s schedule of regionally significant surf breaks.

WIAL are also seeking a new rule in the PNRP under 5.7.6Seawalls. Specifically for the replacement of existing seawalls they are seeking that it be a permitted activity status (that means that the public would not be consulted and no consent or public notification is required).

WIAL are also contesting in part the existing rule 165, specifically that part which lists the schedule of regionally-significant surf breaks as a matter of control – in this case meaning that works must ensure no adverse effects occur on the Corner surf break.

In other words: Dude, WIAL don’t want to look out for the Corner surf break as they keep dumping rocks off the seawall, and are opposing any rules that mean they would have too.

Under the existing regional coastal plan the rules on structures (seawalls) that WIAL have been using come with conditions that: Any maintenance, repair, replacement extension, addition or alteration to or of any existing lawful structure adds no more than 5 metres in horizontal projection and 1 metre in vertical projection measured from the structure existing at 29 June 1994 (the date of public notification of that Plan as a proposed plan).

The New PNRP that replaces the old Regional Coastal Plan resets the clock for the sea wall footprint as of 31 July 2015, meaning that WIAL will be able to extend a further 5 metres into the sea – IF the Corner is not a consideration.

WIAL were reportedly adding to the Moa Point Road seawall footprint right up to that date in 2015, meanwhile, SPS and the Wellington Boardriders club were negotiating in good faith over avoiding adverse effects on the Corner surf break from the extension and swell focus reef.

During these consultations, WIAL’s Communications Manager Greg Thomas continued to deflect questions about the Corner surf break back toward the perceived benefits of the proposed artificial swell focus reef. Mr Thomas knew full well our concerns over impacts of modifications to the seawall on the Corner surf break.

Due to concerns raised by SPS, GWRC are now revising the works undertaken by WIAL along the Moa Point Rd seawall to ensure the airport company has been complying with the rules of the existing coastal plan.

If WIAL gets its way in the PNRP appeals process by eliminating the Corner surf break, the airport company will be able to build its new armoured Moa Point Rd sea wall (page 212, 283, WIAL AEE) without consulting surfers or the general public.

It should be noted that while the promenade and new seawall are in WIAL’s AEE for the airport extension, the consents for the promenade will be a separate consent application to Wellington City Council.

Unless WIAL’s submission is challenged there is the real potential that the new sea wall to provide viewing platforms down to sea level in WIAL’s AEE, being undertaken without any consultation or consideration of the Corner surf break.

This whole scenario provides a level of difficulty for surfers in debating cumulative effects on the Corner surf break through the airport extension environment court process.

WIAL are doing everything they can to walk away from its obligations to the Corner surf break, as perceived by the surfer dudes (including SPS) who were consulting with WIAL in good faith over the promise of an artificial swell focus reef.

WIAL’s desire is to complete these works related to the promenade and seawall prior to the construction of the airport extension being completed (AEE page 264).

Over the next fifteen years WIAL are seeking to progressively develop commercial activities with its sites on the Western apron, in the vicinity of the Corner surf break.

By all appearances it would seem that the existence of the Corner surf break conflicts with WIAL’s vision for this area.

If you have any historical photos of the Moa Point Rd seawall over the last fifteen years or so (with dates), please email them to info@surfbreak.org.nz and we will pass them on to the GWRC investigating officer.

SPS is committed to protecting the Corner and all surf breaks through the PNRP Environment Court appeal process, and the society will challenge this assault on the Corner, Airport Rights, and all of Lyall Bay’s surf breaks.

Dude, WIAL is not acting in good faith, if surfers fall for the carrot of an unproven artificial surf focus reef, and WIAL succeeds in removing the Corner from the schedule of regionally significant surf breaks, then the Airport company can simply walk away from any perceived obligations toward our Corner, and surfers will be asking themselves:

Dude, where’s my surf break?