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

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

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

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

Contact:
Yvonne Weeber
Co-Chair Guardians of the Bays
Phone 0272225390

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

Kia ora koutou,

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

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

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

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

We are happy to be approached for comment.

Ngā mihi


Below are the panel’s final recommendation reports:

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.