IN THE MATTER
of the Resource Management Act 1991
AND
IN THE MATTER
of a Board of Inquiry appointed under s149J of the Resource
Management Act 1991 to consider Notice of Requirements
and applications for Resource Consent made by the New
Zealand Transport Agency in relation to the East West Link
roading proposal in Auckland.
STATEMENT OF EVIDENCE OF ALASTAIR ROBERT JAMIESON ON BEHALF OF
AUCKLAND COUNCIL
OUTSTANDING NATURAL FEATURES
CONTENTS
CLAUSE
1.
2.
3.
4.
5.
6.
PAGE
INTRODUCTION and experience .................................................................................... 1
CODE OF CONDUCT ..................................................................................................... 2
DESCRIPTION OF PROPOSAL ..................................................................................... 2
PARTS OF THE PROPOSAL ADDRESSED IN MY EVIDENCE ..................................... 2
METHODOLOGY OF ASSESSMENT ............................................................................. 2
RELEVANT EFFECTS OF THE PROPOSAL .................................................................. 3
Southdown pahoehoe lava flows including Anns Creek ONF .......................................... 4
Te Hōpua explosion crater and tuff exposure ONF .......................................................... 7
7. MANAGEMENT OF EFFECTS.......................................................................................12
Southdown Pahoehoe lava flows including Ann'screek ONF .........................................12
Hopua explosion crater and tuff exposure ONF ..............................................................12
8. CONCLUSION ...............................................................................................................14
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1.
INTRODUCTION AND EXPERIENCE
1.1
My name is Alastair Robert Jamieson. I am a Biodiversity Team Manager
(Regional) employed by Auckland Council (Council), and am providing expert
evidence in relation to the Outstanding Natural Features (ONF) affected by the
proposed East West Link (Proposal).
1.2
I have a Bachelor of Science degree in Zoology and Geography, and a Master
of Science degree in Physical Geography from the University of Auckland.
1.3
I have held the position of Biodiversity Team Manager (Regional) since
October, 2012. During this time I was the technical expert providing evidence
on Outstanding Natural Features (ONFs) for Council in relation to the
Proposed Auckland Unitary Plan (PAUP) throughout the hearings process of
the Auckland Unitary Plan Independent Hearings Panel.
1.4
Prior to that, I developed draft policies and the schedule and mapping of
Outstanding Natural Features for the PAUP while engaged as a consultant
advisor to Auckland Council in my position of Director, Wild Earth Media Ltd.
Since Auckland Council was established in 2010, I have provided technical
expertise and assessments for resource consents in relation to significant
geological features under the operative Auckland District Plan and ONFs
under the PAUP, initially as a consultant and then in my current staff role.
1.5
In 2008, while engaged as a consultant by Auckland Regional Council, I
provided policy advice in relation to Outstanding Natural Features for Plan
Change 8 of the Auckland Regional Policy Statement. I subsequently provided
further policy advice and developed a draft schedule of ONFs for a later
review of the Auckland Regional Policy Statement.
1.6
My involvement with this Proposal began in late 2016 when I was asked by
Council to provide expert evidence on possible impacts of the Proposal on the
Outstanding Natural Features in the vicinity.
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2.
CODE OF CONDUCT
2.1
I confirm that I have read the Expert Witness Code of Conduct set out in the
Environment Court's Practice Note 2014. I have complied with the Code of
Conduct in preparing this evidence. Except where I state that I am relying on
the evidence of another person, this evidence is within my area of expertise. I
have not omitted to consider material facts known to me that might alter or
detract from the opinions expressed in this evidence.
3.
DESCRIPTION OF PROPOSAL
3.1
The Proposal involves the construction, operation and maintenance of a new
four lane arterial road from State Highway 20 (SH20) at Neilson Street
Interchange in Onehunga, connecting to State Highway 1 (SH1) at Mount
Wellington, as well as an upgrade to SH1 between the Mount Wellington
Interchange and the Princes Street Interchange at Otahuhu. New local road
connections are proposed at Galway Street, Captain Springs Road, the Ports
Link Road, Hugo Johnston Drive and Great South Road. Cycle and pedestrian
facilities are proposed along the route. Grade separation of the through eastwest movements at the Great South Road intersection is included.
4.
PARTS OF THE PROPOSAL ADDRESSED IN MY EVIDENCE
4.1
My evidence addresses the following aspects of the Proposal, that are within
my area of expertise:
(a)
The effects of the Proposal on the Outstanding Natural Features at
Southdown/ Anns Creek and Te Hōpua.
(b)
Managing the effects of the Proposal.
(c)
Conclusions.
5.
METHODOLOGY OF ASSESSMENT
5.1
I have assessed the Proposal and its possible effects on the Southdown/ Anns
Creek and Te Hōpua ONFs against my own knowledge of these features,
gained over more than twenty years of familiarity with the sites. Since 1994 I
have made several site visits to Te Hōpua explosion crater, Anns Creek, and
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the northern coastline of Mangere Inlet to carry out surveys for various
purposes, including examination of the lava flows and other geological
features of the area.
5.2
Most recently I made site visits to Anns Creek and Te Hōpua in April 2017,
including one visit with Dr. Ian Smith (NZTA geological expert) and other
members of the NZTA and Council project teams. On those occasions I have
made a careful comparison plans showing the proposed location of structures
and works with the actual geological features on the ground.
5.3
I have reviewed relevant literature relating to Auckland’s volcanic features
(e.g.; Kermode, 19921; Kenny and Hayward, 19962; Hayward, B., Murdoch, G.,
Maitland, G. 20113) relating to the values of the ONFs. I have read the
relevant documents describing the proposal, including the technical reports
relating to my area of expertise:

Evidence of Lesley Hopkins – Planning Effects and conditions

Evidence of Andrea Rickard – Statutory Planning

Evidence of Dr. Ian Smith – Geological Heritage Assessment

Evidence of Gavin Lister - Landscape

Evidence of Shona Myers – Terrestrial Ecology

Evidence of N. Nancekivell – Annexure F, Plan Set 3 (v2)
6.
RELEVANT EFFECTS OF THE PROPOSAL
6.1
My assessment has identified the following key relevant effects arising from
the Proposal:
(a)
The effects of the Proposal on lava flows within the Southdown
pahoehoe lava flows including Anns Creek ONF; And
(b)
The effects of the Proposal on the landform and geological exposure
at Hōpua explosion crater and tuff exposure ONF.
1
Kermode, L (1992), Geology of the Auckland urban area.
2
Kenny J.A. and B.W. Hayward (1996): The inventory and maps of important geological sites and landforms in the
Auckland Region and Kermadec Islands (First Edition). Geological Society of New Zealand Miscellaneous Publication
84.
3
Hayward, B.W., Murdoch, G., Maitland, G. (2011) Volcanoes of Auckland. Auckland University Press.
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Effects and their magnitude
Southdown pahoehoe lava flows including Anns Creek ONF
6.2
The Southdown pahoehoe lava flows including Anns Creek ONF (ONF ID192)
contains some of the best examples of basalt lava flows with examples of
pahoehoe surfaces in the Auckland volcanic field. Pahoehoe is a Hawai`ian
term used to describe basaltic lava surfaces with smooth undulating or ropey
textures. The extent of these flows has been much reduced from their former
extent in the Auckland volcanic field due to coastal development and
reclamation. Prior to reclamation, the foreshore between Southdown and
Onehunga historically contained extensive lava flow exposures extending from
Anns Creek to Onehunga Mall.
6.3
The ONF Overlay Schedule (Schedule 6) of the AUP (OP) identifies the
following factors as being relevant to the identification of the Southdown
pahoehoe lava flows including Anns Creek as an ONF:
(a) The extent to which the landform, feature or geological site
contributes to the understanding of the geology or evolution of the
biota in the region, New Zealand or the earth, including type localities
of rock formations, minerals and fossils;
(c) The extent to which the feature is an outstanding representative
example of the diversity of Auckland's natural landforms and
geological features;
(d) The extent to which the landform, geological feature or site is part
of a recognisable group of features;
(g) The potential value of the feature or site for public education;
(i) The state of preservation of the feature or site.
6.4
The ONF containing these features can be divided into three parts, as broadly
indicated in Annexure D of Dr. Smith’s evidence:
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
Anns Creek Estuary (i.e. the Mangere Inlet foreshore at Southdown).

Anns Creek West

Anns Creek East
Page 4
6.5
At Anns Creek Estuary, the alignment of the Proposal avoids physical damage
to the coastal exposures of basalt lava along the foreshore; with the piles
situated well clear of the lava flows. From examining the plans while on site, it
appears that the viaduct will largely pass between two outcrops of lava on the
coast here, and directly above a very small part of one of them.
6.6
At Anns Creek west, where a section of the ONF lies immediately south of the
Southdown Power Station site, the proposed alignment passes to the north of
the ONF and avoids it completely.
6.7
At Anns Creek East, the proposed alignment passes directly over a portion of
the ONF. The lava flows in this area also support ecologically significant lava
shrubland. The effects of the Proposal on the associated ecological values of
this area are addressed in the evidence of Mr. Bishop.
6.8
A Construction and Pier Exclusion Area Map provided in Annexure 4 of Shona
Myers’ evidence on terrestrial ecology identifies the areas where no temporary
or permanent piers or other intrusive earthworks are to be constructed. This is
intended to minimise impacts on the sensitive ecological and geological values
of the area. Proposed ecological management condition of consent EM.1A is
provided in the evidence of Lesley Hopkins and details the requirements of the
Construction Restriction Area.
6.9
The exclusion area covers most of the lava flows at Anns Creek East;
however it is unclear whether damage to these flows will be able to be avoided
entirely. I consider that the Construction Restriction Area would probably
minimise the physical effects of the Proposal on the significant geological
features within Anns Creek East, if its requirements can be implemented
rigorously.
6.10
In my opinion, the substantial viaduct that will result from the Proposal would
become a dominating physical feature in the immediate vicinity of the ONF
where it crosses the lava flows at Anns Creek East and along the Anns Creek
Estuary foreshore. At Anns Creek East, the viaduct will cover part of the
feature, and dominate the immediate environment in this section of the ONF.
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6.11
Landscape effects are addressed in the evidence of Mr. Brown, who considers
that the effects of the proposal – and in particular, its viaduct – are acceptable
from a natural character and landscape standpoint. I consider the viaduct will
have a limited effect on the specific geological values for which these features
are identified as ONF, particularly in the context of the highly modified
industrial environment surrounding the lava flows which has effectively
severed them from any other related geological landforms or features.
6.12
The provision of a shared path for cycle and pedestrian access as part of the
viaduct may provide the public with views of the Anns Creek East area, which
could be consistent with reasons (g) for it being identified as an ONF; i.e. the
potential value of the feature or site for public education. However, I note that
the adverse effects of the viaduct required to accommodate this may outweigh
the potential benefit, for the ecological reasons covered in the evidence of Mr.
Bishop.
6.13
More subtle long term effects on the ONF potentially include modification of
the ongoing physical processes that occur within the ONF, including rainfall,
weathering, coastal processes, and in particular, biological associations and
processes. These effects are minor in relation to the specific factors for which
the ONF is identified in the AUP (OP); however some of them would be of
considerable importance in relation to the ecological features of the area,
which are covered in detail in the evidence of Mr. Bishop.
6.14
I recommend that these effects be avoided by moving the alignment of the
viaduct further north, to avoid the Anns Creek East ONF entirely. If the
structure cannot be moved northward due to other constraints, I recommend
the effects be minimised by refining the design of the structure to reduce both
its width and the number of piles required.
6.15
In his evidence, Dr. Smith recommends that interpretive signage be
established in the vicinity of the lava flows to provide educational material
about the area's geological history and scientific values. I am supportive of
this, as it is has the potential to enhance the value of the feature for public
education.
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6.16
The ecological mitigation for the Proposal includes restoration of lava
shrubland ecosystems, and weed control in Anns Creek East and Anns Creek
Estuary, as described in the evidence of Ms Hopkins and Ms Myers. The
visibility of most of the lava flows in these areas is currently being reduced and
prevented by the thick growth of exotic grasses, gorse and other weed
species.
6.17
In general, I support the ecological mitigation involving restoration of lava
shrubland ecosystems proposed in the Ecological Management Plan
(ECOMP) under resource consent condition EM.1. I consider that if
implemented appropriately, weed clearance, ongoing weed control and
removal of accumulated plant material to reveal lava surfaces could provide
some mitigation for any adverse effects of the Proposal on lava flows.
6.18
Ecological restoration can be conducted in ways that are consistent with
protecting the ONF values of the lava flows. To ensure this, the ECOMP
should state that the geological values of lava flows will be maintained and
enhanced. Specifically, the addition of soil or other materials (such as
weedmat) that might obscure bare lava surfaces must be avoided.
6.19
At the Anns Creek Estuary foreshore, the proposed alignment minimises the
physical effects of the structure in this location, as any movement northwards
or southwards would result in a larger area of ONF being affected. For this
reason, I support the proposed location of the alignment in this area.
Te Hōpua explosion crater and tuff exposure ONF
6.20
Hōpua explosion crater and tuff exposure ONF (ONF ID46) consists of two
geologically related but distinct parts; the landform of a volcanic explosion
crater and an exposure of volcanic tuff in the Manukau Harbour foreshore.
6.21
The main part of the feature is small explosion crater with a low tuff ring about
500m in diameter, resulting from a volcanic eruption sequence at least 29,000
years ago. The original crater was breached naturally by the sea and filled
with marine sediments around 8000 years ago. The original tidal basin has
subsequently been artificially reclaimed and the site compromised by
motorway construction. However, the tuff ring landform remains clearly
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discernible as one of Auckland’s smallest explosion craters both in aerial
photographs and from various viewpoints around the site on the ground.
6.22
An intertidal exposure in the Manukau Harbour foreshore on the western side
of Te Hōpua provides a readily accessible cross section through the tuff
deposits of the volcano. Particular features of interest in this exposure are the
relatively large blocks of basalt rock that were blasted from a lava flow
(thought to be from One Tree Hill) that was in place prior to the eruption of Te
Hōpua. This exposure is the remnant of a much larger area of exposed
intertidal tuff that has largely been covered by reclamation and road
construction.
6.23
The Outstanding Natural Features Overlay Schedule (Schedule 6) of the AUP
(OP) lists the following factors as being relevant to the identification of Hōpua
explosion crater and tuff exposure as an ONF:
(a) The extent to which the landform, feature or geological site
contributes to the understanding of the geology or evolution of the
biota in the region, New Zealand or the earth, including type localities
of rock formations, minerals and fossils;
(d) The extent to which the landform, geological feature or site is part
of a recognisable group of features;
(e) The extent to which the landform, geological feature or site
contributes to the value of the wider landscape;
(g) The potential value of the feature or site for public education;
(h) The potential value of the feature or site to provide additional
understanding of the geological or biotic history.
6.24
The Proposal will involve physical modification within Te Hōpua explosion
crater ONF in two key areas:
(a) Construction of the off ramp from State Highway 20 to EWL will
involve earthworks on Te Hōpua crater floor that diverge from the
present Onehunga Harbour Road off ramp alignment, and increase
the width of earthworks.
(b) Construction of the ramp on the southern side of Te Hōpua to the
proposed Neilson St interchange overbridge will involve substantial
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earthworks and the construction of retaining walls up to 8m high. The
overbridge and the ramps on the northern side are outside the ONF.
6.25
These works will have a limited physical effect on the values for which the
ONF is scheduled, as much of the proposed works area is already modified by
historic fill and other alterations. However, it appears likely that excavations for
the Proposal will cut into the volcanic tuff ring in the southwestern part of the
ONF in the vicinity of Onehunga Harbour Road, although the extent and
effects of this are unclear.
6.26
In addition, the Proposal will involve substantial trenching along the southern
edge of Te Hōpua tuff ring, in an area that was excluded from the identified
ONF due to the substantial existing modifications from previous development.
The trench will encounter artificial landfill, tuff deposits from Te Hōpua volcano
and the sediments that lie beneath. While this part of the Proposal avoids the
ONF, it provides a potential opportunity for scientific investigation to reveal
new information about the development of the volcano and the geological
history of the wider area.
6.27
Proposed resource consent condition HH.8 provides for a suitably qualified
person to record the geology of the proposed cut into Te Hōpua tuff ring that
will be undertaken to form the trench on Onehunga Harbour Road. I support
this condition in part. The condition should be amended to provide for
sampling of materials of geological interest, suitable scientific analyses and
reporting on findings, in addition to simply recording the site. This would
maximise the scientific benefit of this unique opportunity to study the
temporary exposure of geological material in the trench.
6.28
The alignment of the Proposal entirely avoids the intertidal exposure of Te
Hōpua tuff in the Manukau Harbour foreshore within the ONF. This area is
currently affected by scattered debris such as concrete and rubbish, and loose
slabs of concrete demolition material that form the road embankment on the
northern side the Aotea Sea Scout Hall. Old broken sewer pipes leading from
the Sea Scout hall cut across the tuff exposure. To the south of the hall there
is a large stormwater outfall, which discharges water across the feature
causing erosion in the tuff surface.
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6.29
Activities to improve the condition of intertidal exposure of Te Hōpua tuff could
provide mitigation for some effects of the Proposal on other parts of Te Hōpua
ONF. These could include:

removal of rubbish, concrete debris and old broken sewer pipes
from the foreshore;

potential reconstruction of the embankment north of the Aotea
Sea Scout Hall to pull the base back off the tuff exposure and
improve the aesthetics the structure; And

potential relocation of the stormwater outfall south of the Aotea
Sea Scout Hall to avoid further erosion of the tuff by stormwater
flows. However, it will need to be determined if this can occur
without adversely affecting the hydrology of the wetland within the
crater, which I understand is connected to the harbour via this
pipe.
6.30
The visual effects of the Neilson St interchange overbridge and associated
ramp and retaining walls on the southern side of Te Hōpua are addressed in
the evidence of Mr. Brown. He considers that these changes would compound
the enclosure and fragmentation of the ONF by transport links and
infrastructure.
6.31
I consider that the ramp with retaining walls up to 8m high will impede views
across the ONF from points where it is presently possible to appreciate the
circular form of the crater; including the entrance to Gloucester Paik North at
Onehunga Mall, as well as Onehunga Harbour Road and Orpheus Drive on
the western side of the ONF. The structure will also cut off views in either
direction between the volcanic explosion crater and the Manukau Harbour,
thus making it more difficult to view and understand the geological setting of
the feature in relationship to the harbour.
6.32
I consider that this will detract from the values of the ONF, and contribute to
the cumulative effects of ongoing degradation of the feature by roading and
development. These effects are unable to be reduced without avoiding
construction of the proposed road interconnections.
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6.33
Council‘s submission seeks that removal of power pylons and undergrounding
(or removal) of the power transmission lines that traverse Te Hōpua should be
explored as a means of mitigating effects of the Proposal. Mr. Brown
considers that removal of the transmission towers and lines would offer
significant ‘compensation’ and remediation for aesthetic and ‘landscape’
effects in the area.
6.34
In addition, I consider that removal of this infrastructure would also provide
some mitigation for the physical effects of the Proposal in relation to Te Hōpua
ONF. If the power lines were placed underground in alignment beneath road
formations, this would have no additional adverse effect on the ONF in my
opinion.
6.35
In his evidence, Dr. Smith recommends that the park within Te Hōpua crater
be enhanced by including interpretive signs that explain its geological history
and scientific values. Dr. Smith also recommends that improvement of the link
between Gloucester Park and the proposed pathway that runs along Mangere
Inlet to the east to improve the connection between Te Hōpua and Anns
Creek. Although I am supportive of these possibilities, I do not consider that
they provide substantive mitigation for the adverse effects of the Proposal.
6.36
Proposed resource consent condition LV.5A (a) provides for an artwork of
unspecified dimensions to encircle Te Hōpua for the purpose of highlighting its
presence and circular form. Few details are provided about what this would
entail, however in his evidence, Mr. Lister considers that an artwork would
outweigh what would otherwise be adverse effects of the Project on Te
Hōpua.
6.37
While I am not opposed to an artwork in principal, I consider that structures for
an artwork may result in adverse physical and visual effects on the ONF,
depending on the scale and location of any structure(s) and the potential
ground disturbance involved. I concur with Mr. Brown’s landscape evidence
that such an artwork would hardly alter or reduce the combined impact of both
the EWL and SH20 on Te Hopua Tuff Crater.
6.38
In any case structures for an artwork would likely require additional resource
consent(s) under the AUP (OP) overlay and land disturbance rules that apply
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to activities within an ONF. In my opinion, proposed resource consent
condition LV.5A (a) condition should be amended to ensure that it does not
lead to further adverse effects on the ONF; otherwise it should be deleted.
7.
MANAGEMENT OF EFFECTS
7.1
In my opinion amendments to the Proposal and/or the NoR/ resource consent
conditions are required to ensure effects are appropriately managed as
follows:
7.2
Southdown pahoehoe lava flows including Anns Creek ONF
(a)
A resource consent condition should require that detailed design for
the viaduct at Anns Creek East moves the alignment further north to
avoid the ONF entirely, or if this is not practicable, refines the
structure to reduce both its width and the number of piles.
(b)
The Ecological Management Plan proposed under resource consent
condition EM.1 should specify that lava surfaces at Anns Creek East,
Anns Creek West and Anns Creek Estuary foreshore are enhanced
by the removal of weeds and accumulated exotic plant material, and
that ongoing maintenance is implemented to keep them weed-free.
(c)
The ECOMP should also specify that ecological restoration and weed
control on lava flows incorporates methods to ensure that that lava
surfaces within the ONF are maintained, and that the addition of soil
or other materials that might obscure bare lava surfaces is avoided.
7.3
Hōpua explosion crater and tuff exposure ONF
(a)
At Te Hōpua, the foreshore exposure of tuff should be maintained
and enhanced by:
(i)
removal of rubbish and concrete debris from the foreshore;
(ii)
reconstruction of the embankment north of the Aotea Sea
Scout Hall, to pull the base of this structure back off the tuff
exposure;
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(iii)
relocation of the stormwater outfall south of the Aotea Sea
Scout Hall to avoid further erosion of the tuff, if this can be
accomplished without adversely affecting the wetland within
Te Hōpua crater.
(b)
Proposed resource consent condition HH.8, providing for the
recording of the geology of the proposed trench on Onehunga
Harbour Road, should be amended to specify that sampling of
materials of geological interest, suitable scientific analyses and
reporting on findings are also included.
(c)
The works proposed at Te Hōpua would involve the construction of a
high ramp and overbridge that will limit the ability to view and
comprehend the volcanic landform from the ground. In partial
mitigation for these adverse effects, removal of power pylons and
undergrounding (or removal) of the power transmission lines that
traverse Te Hōpua should continue to be pursued by NZTA.
(d)
Proposed resource consent condition LV.5A (a) providing for an
artwork to encircle Te Hōpua should be deleted or amended to
ensure that it does not lead to further adverse effects on the ONF.
7.4
In my opinion, these amendments are necessary because:
(a)
Section 6(b) of the Resource Management Act (1991) requires the
protection of outstanding natural features (and landscapes) from
inappropriate subdivision, use, and development, as a matter of
national importance.
(b)
Policy 15(a) of the New Zealand Coastal Policy Statement (2010)
requires that effects of activities on outstanding natural features (and
outstanding natural landscapes) in the coastal environment are
avoided.
(c)
Objective B4.2.1 (1) of the AUP (OP) requires that outstanding
natural features (and landscapes) are identified and protected from
inappropriate subdivision, use and development.
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Objective B4.2.1 (3) of the AUP (OP) requires that the visual and
(d)
physical integrity and the historic, archaeological and cultural values
of Auckland's volcanic features that are of local, regional, national
and/or international significance are protected and, where practicable,
enhanced.
8.
CONCLUSION
8.1
Works associated with the Proposal will traverse and modify two Outstanding
Natural Features that are scheduled in the AUP (OP), namely:

The Southdown pahoehoe lava flows including Anns Creek ONF (ONF
ID192), which contains some of the best examples of basalt lava flows
with examples of pahoehoe surfaces in the Auckland volcanic field;
And

The Hōpua explosion crater and tuff exposure ONF (ONF ID46), which
consists of a volcanic explosion crater landform and an associated
exposure of volcanic tuff in the Manukau Harbour foreshore.
8.2
Overall, I consider that the Proposal will result in less than minor adverse
effects on the geological values for which the lava flows ONF is scheduled.
Ecological restoration mitigation for lava shrublands has the potential to be
beneficial for the management of the lava flows within the ONF.
8.3
The volcanic tuff exposure on the foreshore within the Te Hōpua ONF will be
avoided by the Proposal; however it has the potential to result in more than
minor adverse effects on the geological values of the crater landform. I
consider that if the management measures outlined in Section 7 of this
evidence are implemented to avoid, remedy or mitigate these adverse effects,
the overall effect of the proposal on this ONF will be no more than minor.
Alastair Robert Jamieson
10 May 2017
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