Submissions are being called for WIAL’s proposed airport extension, and must be sent in by 4:30 pm Friday the 12th of August. the proposed extension application will seriously impact on the Corner, and all surf breaks of Lyall Bay.

A summary of points to add to your submission can be found near the end of this article, if you have already made a submission you can add further documents to your submission up until the due date.

Associated information on the proposed extension project can be found at our partners website www.guardiansofthebays.org.nz

Online submissions can be filled in via:  www.actionstation.org.nz/wellington_airport_extension .

There is no doubt that the Airport extension and sub standard mitigation offered by WIAL ( the untested technology of a Submerged Swell Focus Reef ) will impact negatively on the bays surf breaks collectively, especially since WIAL are proposing limited baseline modelling for the Bay and Corner surf break.

SPS is disappointed  that WIAL are seeking the deletion of the Corner as a protected and recognised  regional surf break in the Wellington regional Council’s Proposed Natural Resources Plan, while at the same time proposing a new widened promenade of at least 3 meters  along Moa Point Road beside the Corner surf break.

Wellington City Council historically, have not heard our complaints regarding the dumping of rock and concrete fill down the length of Moa Point Road and its negative impacts on the Corner surf break. WCC are in breach of the NZCPS each time they do this. It can be viewed as increasing the coastal margin incrementally. WCC is a minority shareholder in WIAL.

The Wellington Boardriders Club and  SPS have insisted all along , that adverse effects on the Corner surf break must be avoided or remedied. Shaping the wall to maintain a breaking wave with a quality equal to or greater than what is already there, is one example of potential remedy.

The NZCPS gives three levels of response to adverse effects from a consent or activity- Avoid,  Remedy, or Mitigate.  WIAL have elected to only mitigate for the loss of Lyall Bays surfing wave quality.

Mitigate is the lowest level of response for adverse effects. that is why you must write a submission opposing the airport extension and SWFS proposal (SPS and the Guardians of the Bay can assist you with that).

What is meant by avoid, remedy, or mitigate?

Each is a different way of addressing an adverse effect so it is acceptable. For example, a quarry has an adverse visual effect. You would ‘avoid’ the effect if you did not quarry or if the quarry was located where it couldn’t be seen. You would ‘remedy’ the effect if you filled the hole in. You would ‘mitigate’ the effect if you planted trees around the hole. All three actions may address the adverse effects, but in the long term only one or two are likely to be acceptable to the community.

SPS continue to protest at the low level of monitoring offered by WIAL for their Submerged Wave Focus Structure (SWFS) as proposed mitigation for the significant impacts the extension will have on all of Lyall Bay’s surf breaks, including the Corner. the two peer reviews of the DHI reports back this up.  Fundamentally flawed, is how the peer review sums up the DHI shoreline impact assessment report.

SPS note that that WIAL’s statutory context report does not recognise any obligation to regionally significant surf breaks listed in the GWRC PNRP.  The Statutory Context report nor any other of WIAL’s reports, gives reference to Policy 13. 2 c of the NZCPS, which forms the base for recognition of surf breaks in a regionally significant context.

WIAL have elected to build a promenade the length of Moa Point Road to satisfy walkers and Cyclists at the expense of the Corner surf break, as part of the mitigation for its obligations to overall impacts on Natural Character that the extension will impose on the landscape.

How can WAIL Construct this promenade without modifying the Moa Point rock wall, and avoid impacting on the Corner surf break wave quality?

There would be no obligation to repair the Corner, if the Corner is not recognised in regional planing documents.

The GWRC PNRP is a separate Environment court appeal  next year, but there is the potential for WIAL to contest the proposition of regionally signifcant surf breaks in its extension application.

If you are prepared to accept this scenario as a surfer, then you are preparing to have yourself shafted. Alternatively you can make a submission opposing the Extension and SWFS. You can withdraw your opposition at any time you decide the concerns raised in your submission are met,or you can join with other parties opposed.

Fig 1-5  of Mitchell Partners Assessment of Environmental Effects   clearly shows development into the Coastal Marine Area (CMA) along Moa Point Road, as blue lines protuding into the surf zone.

Where are the rocks on top of the western side of Moa Point Road going to go, once the construction of the  Promenade begins?
If past history is to be acknowledged, then the line up for the Corner is a safe bet. There are no detailed working papers for the promenade to draw any conclusions from.

It is important that you  make a submission opposed to the extension project outright, that way you can insist that the Moa Point Sea wall is not modified further without due consideration of its impacts on the Corner surf break.

 

Policy 13 of the NZCPS facilitates the recognition of regionally significant surf breaks  by way of identifying them as regionally significant natural features. WIAL have ignored policy 13. 2 (c)

Throughout all of WIAL’s application documents they have failed to mention NZCPS  policy 13.2(c)

(2) Recognise that natural character is not the same as natural features and landscape or amenity values and may include matters such as:

(c) natural landforms such as headlands, peninsulas, cliffs, dunes, wetlands, reefs,freshwater springs and surf breaks;

The collective Wial reports only discuss Policy 13.2(b) biophysical, ecological, geological and geomorphological aspects;

WIAL’s recreational and landscape plans  do give any reference to policy 13.2 c, or  any special value to surf break policies in the PNRP  as they are seeking to delete them, and rate it along with any other recreational amenity value like walking your dog or riding a bike.

Coincidentally  Mitchell Partners,  who are running the WIAL’s appeal to the Proposed Natural Resources Plan, have also written  WIAL’s Assessment of Environmental Effects  (AEE)

Out of all the WIAL reports, the AEE is the only one where WIAL makes a single  mention The GWRC Proposed Natural Resources Plan policy P51, but it does not expand on WIAL’s obligation to that policy, just that WIAL intend to only mitigate, rather avoid or remedy.

Lyall Bay as a cultrally significant area.

In all of WIAL’s reports, the airport company  have neglected to refer to the cultural significance of Lyall Bay, as a meeting place for Maori and Hawaiian,  Duke Kahanamoku and Paramount Maori Chief   Tureiti Te Heuheu Tukino V , met after the Duke came in from his surfing demonstration at the Lyall Bay carnival. Lyall Bay is a culturally significant Polynesian site.

Points For Your Submission

Lyall Bay has cultural significance as a heritage site for surfing nationally and internationally. The father of modern surfing, Hawaiian Olympic swimming champion Duke Kahanamoku demonstrated his surfing skills to an audience of thousands at Lyall bay in 1915. The significance of this visit to Lyall Bay by Duke kahanmoku has been recognised by Wellington City Council, who are preparing a monument to this historical visit. Lyall Bay is culturally, and historically, a significant Polynesian site.

To quote from http://www.nzjh.auckland.ac.nz/docs/2010/NZJH_44_1_02.pdf :

A widely reported reception accorded to Kahanamoku by the Maori chief Tureiti Te Heuheu Tukino V reinforced Pakeha associations of Kahanamoku with Maori. Te Heuheu was a prominent identity, politician and paramount chief of Ngati Tuwharetoa, whose home at Lyall Bay was a major centre for Maori visiting the capital for political business. He sought Kahanamoku out at his Wellington carnival and reportedly asked, ‘Where is this Honolulu Maori you call a Hawaiian?’ He also organized a powhiri and dinner on 7 March 1915 when Kahanamoku visited the Lyall Bay Surf Club to demonstrate surfing. The all-day event included a haka, hongi, traditional Maori dinner, toasts, Maori and Hawaiian songs, and presentation of a Maori cloak [Figure 3].61 In its commentary on the fête, the Dominion speculated on cultural bonds between Maori and Hawaiians, noting for example that Kahanamoku’s middle name, Paoa, also featured in Maori legend.

The numbers of New Zealanders that surf, rivals the numbers of NZers who play rugby (Sport and Recreation New Zealand, 2008). Surfing has been accepted as an Olympic sport for the Tokyo Olympics in 2020. As an urban sports ground Lyall Bay is of the highest amenity and heritage value, and adverse effects must be avoided with any construction, such as the proposed airport extension project.

Lyall Bay in context with the RMA and NZCPS

WIAL’ proposed Airport extension and SWFS conflict with both the RMA and NZCPS and the protection of surf breaks. The maintenance and protection of surf breaks is relevant to several aspects of the RMA, particularly the purpose and principles of the RMA (sections 5, 6, 7) and the purpose of Regional Policy Statements‟ (RPS) (section 59).

Wellington International Airport Limited’s (WIAL) Proposed extension and Submerged Wave Focus Structure conflict with the principles of the RMA as well as  the New Zealand Coastal Policy Statement(NZCPS).

WIAL have neglected to consider the relevance of polices 3, 4, 5, 10, 13, 14, 15, 18, 22, 23, of the New Zealand Coastal Policy Statement (NZCPS) in the context of protection for, use and enjoyment of Lyall Bay’s surf breaks.

WIAL have neglected to consider policy 13 2. c of the NZCPS in its Statutory Context report or Assessment of Environmental Effects (AEE) reports;

NZCPS Policy 13 Preservation of natural character
2. Recognise that natural character is not the same as natural features and landscapes or amenity values and may include matters such as:

c) natural landforms such as headlands, peninsulas, cliffs, dunes, wetlands, reefs, freshwater springs and surf breaks;

WIAL’s statutory context Report does not acknowledge surf break policies in the GWRC PNRP. WIAL’s  AEE reports does not acknowledge surf break policy within the  Greater Wellington Regional Council’s Proposed Natural Resources Plan beyond simply listing policy p51. Lyall Bay’s surf breaks are protected under policy P51 of the GWRC PNRP and its schedule K significant surf breaks, which lists the Corner surf break and that of Lyall Bay’s surf breaks collectively, as regionally significant;

Policy P51: Significant surf breaks
Use and development in and adjacent to the significant surf breaks identified in Schedule K (surf breaks) shall be managed by minimising the adverse effects on:

(a) natural processes, currents, seabed morphology and swell corridors that contribute to significant surf breaks, and

(b) access to significant surf breaks within the coastal marine area, on a permanent or ongoing basis.

WIAL have given little detail on its proposed promenade construction and modified  Moa Point Rd sea wall. This would have an impact on surfing wave quality at the Corner Surf break and would require a separate surf break impact assessment report for the Corner surf break, and possibly the Bay as a whole.

WIAL have chosen simply to mitigate for the removal of Airport Rights and significant impacts on all of Lyall Bays surf breaks. WIAL  are only acknowledging surfing at Lyall Bay as relevant to amenity values in context with the NZCPS, which are essentially  interchangeable with other amenity activities such as cycling, walking, or visiting cafes. The Proposed Airport Extension requires the destruction of the Airport Rights Surf break. Airport Rights is a reef break located at the southern end of the runway, off Moa Point road and is listed in the GWRC Proposed Natural Resources Plan (PNRP) schedule of regionally significant surf breaks. Airport Rights is a big wave surfing venue, and is important to a surfers’ progression in capability.

I do not believe that you can mitigate the loss of a finite resource such as a surf break in exchange for the opportunity to walk a dog.

A surf break is a rare and finite natural feature that provides a unique amenity value. Lyall Bay’s Surf breaks warrant protection on a level for avoidance and remedy, not mitigation under the NZCPS as WIAL proposes.

The Proposed Airport Extension would have significant adverse effects on all of Lyall Bay’s surf breaks. The DHI Surf Break Impact Assessment Report notes the reduction in wave peakiness caused by the proposed airport runway extension, the reduction in surf rides is expected to be between 14-29% for Middle Beach and 18-27% at West Beach. The report predicts an expected reduction of total number of surf rides of 4 – 8% at the Corner Surf break, Wellington City’s premier surf break which attracts dozens of surfers at a time, when a good swell is generating.

Inadequate assessment of impacts on the Corner surf break. The independent scientist peer reviewing the DHI Surf Break Assessment report has highlighted; “there are significant changes in wave-driven currents (as presented by both NIWA and DHI), mostly inshore of the spur and in the vicinity of the Corner (e.g. Figures 5-14, 5-17 and 5-20 in the DHI report).  These currents will impact on seabed morphology, and consequently on surfing waves as they propagate shoreward – whether negative or positive is currently unknown since this has not yet been investigated adequately.” This calls into question the DHI estimate of only a 4 to 8% reduction in surfable waves at the Corner.

The removal of the Corner with respect to impacts on surfing conditions. It is of concern that WIAL are not prepared to protect the “Corner” surf break, and are seeking it’s deletion from the schedule of regionally significant surf breaks in the Greater Wellington regional Council’s (GWRC) Proposed Natural Resources Plan (PNRP). The Corner surf break is Wellington City’s most popular surf break, and WIAL have not properly assessed the potential effects of wave driven currents on the Corner should the extension and SWFS projects proceed.

GWRC has to a degree meet its obligation to the New Zealand Coastal Policy Statement (NZCPS) with its schedule of regionally significant surf breaks in its PNRP. The NZCPS policies 13 and 15 give direction to territorial authorities to do so. WIAL’s continued objection to the inclusion of the Corner surf break (and surf break policies in the PNRP) is a reflection on WIAL’s failed consultation process. The surfing groups that consulted on the revised draft Surf Mitigation Adaptive  Management Plan (SMAMP) has not resulted in consensus, and falls well short of what the surfers independent scientist recommends.

The massive reduction in stakeholder input into the process. The revised draft Surf Adaptive Mitigation Management Plan (SMAMP) is not acceptable and not at all in the spirit of what has been discussed and agreed to by WIAL in the meetings between WIAL, the Wellington Boardriders Club, SPS and their independent expert.  In association with WIAL’s submission, which is attempting to nullify the value and importance of surfing in Lyall Bay, these modified conditions suggest that WIAL is not taking a robust precautionary approach to the negative impacts that the extension will cause to surfing conditions at Lyall Bay as required in policies 13 and 15 of the NZCPS.

The Submerged Wave Focusing Structure (SWFS). A SWFS has been proposed as mitigation for the loss of surfing wave quality in Lyall Bay, WIAL have not yet provided a final design concept for what is an unproven technology. This calls into question how WIAL can submit a Preliminary Shoreline Impact Assessment for Submerged Wave Focusing Structure report, when they have not yet provided a final SWFS design concept? A final design of the focus structure is required to determine impacts on the shoreline (which will be interactive with the quality/type of waves breaking in this location due to the SWFS).

The DHI Preliminary Shoreline Impact Assessment for Submerged Wave Focusing Structure report is fundamentally flawed,  a peer review of DHI’s preliminary shoreline impact assessment report by eCoast Marine and consulting Ltd found that the report is fundamentally flawed, and the proposed  SMAMP does not provide adequate protection for Lyall Bay’s surf breaks should the airport extension and SWFS proceed. WIAL have not covered due diligence by caucusing adequately with the surfers independent reviewer.

I object to plans for WIAL to use sediment from CentrePort’s proposed dredging of Wellington Harbour’s entrance which will have disastrous consequences for the surf breaks of Eastbourne and Wellington as a whole.