TRANSCRIPT OF PROCEEDINGS BOARD OF INQUIRY … · 16.11.2012 · MacKays to Peka Peka Expressway Proposal HEARING at KAPITI COAST on 16 NOVEMBER 2012 BOARD OF INQUIRY: Retired High

TRANSCRIPT OF PROCEEDINGS

BOARD OF INQUIRY

MacKays to Peka Peka Expressway Proposal

HEARING at KAPITI COAST on 16 NOVEMBER 2012

BOARD OF INQUIRY:

Retired High Court Judge Sir John Hansen (Chairperson)

Environment Commissioner David Bunting (Board Member)

Ms Glenice Paine (Board Member)

Mr Mark Apeldoorn (Board Member)

Page 300

Kapiti Coast 16.11.12

LIST OF WITNESSES

<ANDREW MURRAY, resworn [9.34 am] ................................................ 303

<CROSS-EXAMINATION BY MS SIMONS [9.34 am] .................. 303 5

<CROSS-EXAMINATION BY MR FOWLER [9.44 am] ................. 308

<RE-EXAMINATION BY MR APPLEDOORN [10.04 am] ............ 318

<THE WITNESS WITHDREW [10.05 am] ....................................... 319

<STEPHEN DESMOND HEWETT, sworn [10.05 am] ............................ 319 10

<EXAMINATION BY MS GREGORY [10.05 am] .......................... 319

<CROSS-EXAMINATION BY MR CONWAY [10.12 am] ............. 322

<CROSS-EXAMINATION BY MR BENNION [10.34 am] ............. 330

<CROSS-EXAMINATION BY MR FOWLER [10.59 am]............... 340

<RE-EXAMINATION BY MS GREGORY [11.01 am] .................... 341 15

<THE WITNESS WITHDREW [11.22 am] ....................................... 348

<TIMOTHY MARTIN KELLY, sworn [11.36 am] ................................... 348

<EXAMINATION BY MS SIMONS [11.37 am] .............................. 348

<THE WITNESS WITHDREW [11.43 am] ....................................... 351 20

<DONALD RICHARD WIGNALL, sworn [11.43 am] ............................. 351

<EXAMINATION BY MR CONWAY [11.43 am] ........................... 351

<CROSS-EXAMINATION BY MR FOWLER [11.47 am]............... 353

<CROSS-EXAMINATION BY MS GREGORY [12.02 pm] ............ 359 25

<RE-EXAMINATION BY MR CONWAY [12.16 pm] .................... 364

<THE WITNESS WITHDREW [12.22 pm] ....................................... 366

<TIMOTHY MARTIN KELLY, resworn [12.23 pm] ............................... 366

<EXAMINATION BY MS WHITE [12.23 pm] ................................ 366 30

<THE WITNESS WITHDREW [12.24 pm] ....................................... 368

<DR WAYNE JOHN HASTIE, sworn [1.30 pm] ....................................... 368

<EXAMINATION BY MS WHITE [1.30 pm] .................................. 368

<CROSS-EXAMINATION BY MR FOWLER [1.31 pm] ................ 369 35

<CROSS-EXAMINATION BY MS GENTER [1.37 pm] ................. 372

<THE WITNESS WITHDREW [1.42 pm] ......................................... 375

<JULIE ANN GENTER, affirmed [1.43 pm] ............................................. 375

<CROSS-EXAMINATION BY MR JOHN HASSAN [1.57 pm]..... 380 40

<THE WITNESS WITHDREW [2.03 pm] ......................................... 383

Page 301


[9.30 am]

CHAIRPERSON: Mr Hassan, just before we start, we had a fairly extensive

yesterday and I think it‟s likely there will be certain areas that we will

revisit at some stage. 5

MR HASSAN: Yes, sir.

CHAIRPERSON: There seem to be indications that there‟s been some

amendments to the designation, for example, we took it at the 10

Takamore area the Maketu (ph 1.02) tree is now within the

designation, is that correct?

MR HASSAN: The answer to that, sir, is the macatu tree and the land across

to the west is part of what we have proposed to the Board be considered 15

for protection through the designation, not to allow works.

CHAIRPERSON: Right. And there was also, it‟s in the rebuttal evidence I

know, a shifting of cycleways and things like that. What I just wanted

to do, seeing we are not sitting till Tuesday - - - 20


CHAIRPERSON: - - - to just ascertain with the EPA staff that we are in

possession of the completely updated plans and such. 25

MR HASSAN: Yes, sir. Sir, now attached to the opening legal submissions in

the annexured set, the plan that‟s attached at the back. This plan here,

Commissioners, your Honour, the macatu tree is shown, maybe you

could get the location, but I think nevertheless in that green area there. 30

CHAIRPERSON: Yes.

MR HASSAN: And the green area over here being the other side of that

protection quadrant. This one here being, one will recognise that with 35

reference to the restoring the Māori proposal which sits alongside the

conditions, in terms of the arrangements proposed.

CHAIRPERSON: And that also shows the realignment of the cycleway past

that wetland there? 40

MR HASSAN: No, it doesn‟t, sir, and we need to get that – we can clarify

that if need be.

CHAIRPERSON: Well I thought it was closer to the Deardon‟s place than 45

that in the original plans.

Page 302



CHAIRPERSON: Anyway, look, all we‟re asking is there is a double check

just to make sure that we‟ve got everything on file that we should have. 5

MR HASSAN: Yes, sir. We will confer with Ms Morgan on anything that the

Board requires. Thank you, sir.

CHAIRPERSON: Now, seeing we had a day off yesterday, would you mind 10

re-swearing, Mr Murray, please?

MR HASSAN: Sir, may I take a - - -

CHAIRPERSON: Yes. 15

MR HASSAN: - - - two housekeeping matters first. Jut to introduce

Ms Gregory alongside me who will take part of the responsibilities

today. She will lead Mr Hewitt and also cross-examine, sir. And Mr

Nicholson from the Transport Agency alongside. 20

And I need to correct the record on something – in my opening

submissions, in speaking to the Board I mentioned the Otaihanga

roundabout, and I looked at the transcript again and I was working

from my understanding at the time, but my understanding wasn‟t 25

correct, and I said that the issue of doing the roundabout work would be

covered by conditions. I made the comment that it is outside this

project and it is undertaken under the separate designation for

proceedings, which is correct.

30

But I made this further point that there‟s a condition in the proposed

set. Now in fact the position is that there isn‟t, and I just wanted to

correct the record on that, sir.

CHAIRPERSON: All right. 35

MR HASSAN: One other matter, sir, briefly. I understand the planners are

still hard at work on the conditions, they want to get them right and so

they got a bit slow on their timetable - - -

40

CHAIRPERSON: Well we were working on today, but I would sooner, and

the Board have discussed this – we would sooner give them extra time

to get it right - - -

MR HASSAN: Yes, sir. 45

Page 303


CHAIRPERSON: - - - than put them under any pressure. I mean we‟ve got

more pressing things at the moment, as a Board, than those.

MR HASSAN: Thank you, sir.

5

CHAIRPERSON: All right. Now, Mr Murray, if you just be re-sworn please.

<ANDREW MURRAY, resworn [9.34 am]

CHAIRPERSON: Ms Simons? 10

<CROSS-EXAMINATION BY MS SIMONS [9.34 am]

MS SIMONS: Thank you. Good morning.

15

MR MURRAY: Good morning.

MS SIMONS: Firstly, it is pleasing that the transportation witnesses have been

able to reach agreement on all matters except for one or two

outstanding issues and, as you know, the Kapiti Coast Airport is very 20

supportive of the expressway, but there are just one or two points of

clarification that I need to follow up with you and I shouldn‟t take very

long.

[9.35 am]

25

Just starting out, the expressway is a road of national significance, it is

a large scale piece of infrastructure, isn‟t it?

MR MURRAY: Yes.

30

MS SIMONS: Sir, this is a large catchment or it has the potential to service a

large catchment?

MR MURRAY: Yes.

35

MS SIMONS: And it provides the opportunity for growth and development for

economic benefit in accordance with all of the government policy

statements and the essential government imperatives?

MR MURRAY: Yes. 40

MS SIMONS: And when we look at the flyover we can see that the benefits

to the communities along the route are by virtue of their ability to

access either to or from the expressway into the receiving community?

45

MR MURRAY: No, I wouldn‟t agree with that completely, no.

Page 304


MS SIMONS: You‟re saying that it‟s not a benefit or you‟re saying that it‟s

not the only benefit?

MR MURRAY: I believe that the community get a lot of benefits, not just 5

from having direct access. There would be a lot of benefits, for

example removing traffic from some roads for people don‟t even need

to use the expressway, so they will get significant benefits.

MS SIMONS: So allowing access from the local network onto the expressway 10

is a benefit?

MR MURRAY: Generally speaking, for those people, yes.

MS SIMONS: And if you look at the flyover, those communities that may not 15

have access, those communities alongside the expressway that do not

have access, they don‟t get the same degree of benefit, do they, as those

that do have access through on and off ramps? To some degree at least.

MR MURRAY: To some degree. I think it very different – it‟s very site 20

specific.

MS SIMONS: Yes.

MR MURRAY: And which particular movement you‟re referring to. 25

MS SIMONS: All right. The capacity for growth and the capacity for the

expressway to facilitate growth, are to some degree, therefore,

interrelated?

30

MR MURRAY: Sorry, can you repeat that – the capacity for growth and the

capacity for the expressway to accommodate that growth?

MS SIMONS: Yes.

35

MR MURRAY: Yes, they are related.

MS SIMONS: Now are you aware of plan change 73 to the Kapiti Coast

District Plan?

40

MR MURRAY: That‟s the airport precinct one?

MS SIMONS: I‟m not expecting you to understand it, but you are aware of its

existence?

45

Page 305


MR MURRAY: If that‟s the airport one, I can‟t remember the number but I

think that‟s the airport precinct one.

MS SIMONS: That‟s correct. This airport zone.

5

MR MURRAY: Yes, I‟m aware of that.

MS SIMONS: And are you aware that it was a privately promoted plan

change?

10

MR MURRAY: Yes.

MS SIMONS: Yes. So the owners of the airport would have, you would have

expected, undertaken quite a significant degree of diligent scrutiny of

the proposal that they were promoting for the airport? 15

MR MURRAY: I would expect so.

MS SIMONS: And it‟s now operative, isn‟t it, plan change 73? It‟s part of the

Kapiti Coast District Plan? 20

MR MURRAY: I believe so.

MS SIMONS: And that plan provides for approximately, just short of, 340,000

square metres of gross floor area of development in and around the 25

airport zone?

MR MURRAY: That‟s what I understand, yes.

MS SIMONS: And this will provide employment, economic benefit, one 30

would hope?

MR MURRAY: I would – I‟m not an expert in economic benefit, but yes, it

allows for growth.

35

MS SIMONS: Well, that‟s part of the – that‟s part of the objective.

MR MURRAY: Yes.

MS SIMONS: Have you seen around the airport recently, the degree of 40

development work that‟s going on?

MR MURRAY: I have observed it very recently. I guess my observations

would be more along the lines of the lack of development rather than

development, but yes, I have observed the general area. 45

Page 306


MS SIMONS: Development has commenced as a result of plan change 73?

MR MURRAY: I believe there is some, yes.

MS SIMONS: And this is planned growth, rather than aspirational growth, 5

isn‟t it, because it‟s provided for in the district plan?

MR MURRAY: The district plan has some process that needs to be gone

through. It‟s not just everything up to your 340,000 that can be done.

There are thresholds and caps and require further analysis at certain 10

points.

MS SIMONS: That‟s right, and I‟m glad you raised that because I will come

back to that, but in order for plan change 73 to become operative it

would have had to go through a rigorous section 32 analysis under the 15

Resource Management Act? It would have had to look at costs and

benefits. It would have had to look at the risk of acting or not acting.

It would have to evaluate alternatives, under section 32?

MR MURRAY: I‟m not an expert on the Resource Management Act but I 20

understand that, yes, it goes through a consenting process. Yes.

[9.40 am]

MS SIMONS: Right. So this is a rigorous process and it would have involved 25

the owners of the airport?

MR MURRAY: I would understand so, yes.

MS SIMONS: Yes. Have you spoken to the owners of the airport at all about 30

their plans for growth around the airport or within the airport zone?

MR MURRAY: No, I haven‟t.

MS SIMONS: Now, in order for this proposed growth, there needs to be 35

adequate infrastructure. You would have to agree with that?

MR MURRAY: Yes.

MS SIMONS: And you have read Sir Noel Robinson‟s evidence? 40

MR MURRAY: Yes.

MS SIMONS: And he explains in his evidence, doesn‟t he, his experience at

Highbrook where the provision of infrastructure informed the growth – 45

it provided, it enabled growth at Highbrook?

Page 307


MR MURRAY: Yes.

MS SIMONS: So it‟s fair to say that if the infrastructure is inadequate it has

the potential to in fact throttle development, doesn‟t it? 5

MR MURRAY: I believe it could have that effect, yes.

MS SIMONS: Now you mentioned the provisions within the plan change 73

which relate to thresholds, and that is in relation to growth and that 10

provides that if growth reaches a certain level then there‟s a

requirement for the applicant to seek a restricted discretionary activity

to enable that development to occur. Would that be fair?

MR MURRAY: That‟s my understanding. 15

MS SIMONS: Yes. And it‟s a restricted development, a restricted discretionary

activity, which means, doesn‟t it, that there are restrictions on where

the consent authority can exercise its discretion?

20

MR MURRAY: I believe so, yes.

MS SIMONS: And in the case of the airport zone, it is specifically and

exclusively restricted to the expected traffic generation from the airport

zone and the effects on the local road network and State Highway 1 25

within the district, and the timing of any improvement works on the

local road network and State Highway 1. That‟s the only thing that the

council has to exercise its discretion on. Correct?

MR MURRAY: I am aware of those transport related issues there. I didn‟t 30

really look whether there were any other ones.

MS SIMONS: Well, do you accept that if I‟m reading from the provisions of

the airport zone rules and standards, that they confirm that the

discretion is restricted to matters relating to those I have just described? 35

MR MURRAY: I would accept that, if that‟s what you‟re reading from.

MS SIMONS: Thank you. So the point, therefore, for you and indeed the

Board, is to be satisfied that where there is planned growth the 40

expressway can provide for that planned growth around the airport.

Are you satisfied that in fact the designation and the design of the

expressway can provide for all of the planned growth for the airport

zone?

45

Page 308


MR MURRAY: We have assessed the design of the interchange at Kapiti

Road under a scenario which has full development in the airport, and

we believe the operation of the interchange is satisfactory.

MS SIMONS: Right. No more questions, thank you. 5

MR MURRAY: Thank you.

CHAIRPERSON: Mr Fowler?

10

MR FOWLER: Yes, thank you, sir.

<CROSS-EXAMINATION BY RICHARD FOWLER [9.44 am]

MR FOWLER: Mr Murray, in your transport modelling that you carried out, 15

the Western Link Road, plus an expressway, performed best in

transport terms, didn‟t it?

MR MURRAY: In the modelling that the Alliance that I‟ve been involved in,

have been done, we haven‟t compared Western – we haven‟t run a 20

Western Link Road option.

MR FOWLER: In your own modelling that you refer to in paragraph 207.3 of

your evidence - - -

25

MR MURRAY: Well I‟ll just need a moment to look at that. Evidence-in-

chief or rebuttal?

MR FOWLER: Yes, 207.3. Same answer to my question?

30

MR MURRAY: No, that does not relate to the work that the Alliance had

done, that was previous work done by others.

[9.45 am]

35

MR FOWLER: Yes, I wasn‟t asking you about the Alliance work, I‟m going

to come to that. In that modelling work that you‟re referring to there - -

-

MR MURRAY: I did not do this work. 40

MR FOWLER: Just listen to my question. The WLR and an expressway

performed best in transport terms, didn‟t it?

MR MURRAY: That‟s what that piece of work suggested, yes. 45

Page 309


MR FOWLER: Yes. And you have reviewed that modelling – I‟m not asking

you whether you agreed with it, I‟m just asking whether you reviewed

that modelling?

MR MURRAY: I have not reviewed that modelling in detail. 5

MR FOWLER: All right.

MR MURRAY: I have read the report.

10

MR FOWLER: You‟ve read the report on which - - - -

MR MURRAY: On that modelling.

MR FOWLER: Thank you. 15

MR MURRAY: That describes these outcomes, yes.

MR FOWLER: Now moving forward to the Alliance team, I think you may

have already answered this, but can you confirm that that particular 20

option wasn‟t subsequently tested by the Alliance team, was it?

MR MURRAY: No. The option that was referred to in that previous work, no,

the Alliance has not done that same test, no.

25

MR FOWLER: And can you confirm that in August 2009 State Highway 1

upgrade plus Western Link Road was recommended by the Kapiti State

Highway 1 Strategy Study, wasn‟t it? You‟re aware of that?

MR MURRAY: I don‟t recall that specific recommendation. 30

MR FOWLER: So you‟re not aware of what was recommended by the Kapiti

State Highway 1 Strategy Study in August 2009? You‟re not aware of

that outcome?

35

MR MURRAY: I don‟t recall that specific recommendation. I have been

through that strategy report.

MR FOWLER: You have been through it?

40

MR MURRAY: Yes.

MR FOWLER: Right. Were you responsible for the – at least in overview

terms – the compilation of the Assessment of effects chapter that dealt

with alternatives, lodged with the application? 45

Page 310


MR MURRAY: No.

MR FOWLER: So that‟s not your work?

MR MURRAY: That‟s not my work. 5

MR FOWLER: Okay. Did you review it?

MR MURRAY: No.

10

MR FOWLER: Are you familiar with it?

MR MURRAY: I have read that part of the AEE. In my evidence I describe

my role, which specifically says I was not directly involved in that

option analysis process. 15

MR FOWLER: Who do you say, in the Alliance team, was?

MR MURRAY: My understanding was there was a wide range of people

doing that option analysis – people from a wide range of skills across 20

the whole, you know, all the different aspects, you know, noise,

emissions, transport, costs, engineering – I can‟t name all of them.

MR FOWLER: Are you able to assist us today in terms of indicating who

would be able to answer questions on behalf of the application 25

regarding chapter 9, Assessment of Alternative Routes?

MR MURRAY: Specifically I don‟t know the exactly correct people, but I

understand, possibly Mr Baily was involved and the planners would

have been involved as well. 30

MR FOWLER: You have, however, at least read it, haven‟t you?

MR MURRAY: The AEE? That chapter?

35

MR FOWLER: Chapter 9.

MR MURRAY: Yes.

MR FOWLER: Yes. And you can confirm, can‟t you, that in terms of the 40

overview in chapter 9, that particular option, that is State Highway 1

upgrade plus WLR, wasn‟t included as one of the seven overview

options in that chapter?

MR MURRAY: I don‟t recall specifically all the options that we looked at, but 45

if that was not in there then I‟ll take your word on that.

Page 311


MR FOWLER: All right. If I ask you the same question regarding the

principal route options, the four principal route options that were

identified, would you give the Board the same answer?

5

MR MURRAY: About who was involved or?

MR FOWLER: No, about whether or not the upgraded State Highway 1 plus

WLR option was one of them.

10

MR MURRAY: I agree, I don‟t think that was one of them.

MR FOWLER: Are you the most senior employee, principal or representative

from Beca‟s that is giving evidence at this hearing?

15

MR MURRAY: I wouldn‟t suggest that. There‟s a range of people at very

similar levels.

MR FOWLER: What is your position at Beca precisely at the moment?

20

MR MURRAY: My job description is as a technical director of transport. But

it is one of a number of people with that role.

[9.50 am]

25

MR FOWLER: In that role, can we take it that you would be reviewing reports

and materials that are fed from Beca about this project to NZTA?

MR MURRAY: Some of them, not all of them.

30

MR FOWLER: Are Graham Bell and John Rowe Beca employees who have

been working on this project?

MR MURRAY: Yes.

35

MR FOWLER: And do they have expertise in matters relating to economic

assessments and evaluations?

MR MURRAY: Yes. They‟re not economists, but they have expertise in

applying the NZTA‟s economic evaluation manual to the model. 40

MR FOWLER: Are you aware of a draft report on the cost benefit ratios in

respect of this project prepared in December of 2011, that was recently

leaked to the media?

45

MR MURRAY: I am aware of that draft report, yes.

Page 312


MR FOWLER: Have you had an opportunity to read it?

MR MURRAY: Yes.

5

MR FOWLER: It was one of a bundle of five papers, wasn‟t it, prepared in

respect of this project?

MR MURRAY: I really don‟t know. It was an internal, incomplete draft report

within Beca, and that‟s as far as it‟s ever gone. So a package, I‟m not 10

sure what you are referring to.

MR FOWLER: So you don‟t know whether it formed part of a package of five

papers that were being prepared?

15

MR MURRAY: No, I don‟t.

MR FOWLER: So if I were to ask you what happens to the other four papers,

you wouldn‟t know?

20

MR MURRAY: I‟m not aware of a package or other papers.

MR FOWLER: Is there any other witness coming along to this hearing from

Beca or from NZTA that you know of who could answer that question?

25

MR MURRAY: Well I don‟t know what those other papers are, so I couldn‟t

know who might be able to tell you what they are.

MR FOWLER: Would you even know whether transport modelling would

have been one of the topics in those other papers? 30

CHAIRPERSON: Well we haven‟t established the other papers yet, have we?

MR FOWLER: No, sir.

35

CHAIRPERSON: So are you calling evidence to establish these other papers

or what?

MR FOWLER: That may well be the case. I‟m not sure of that at the present

- - - 40

CHAIRPERSON: Well the time to ask the questions is after you‟ve

established the papers.

MR FOWLER: All right. Well I will take a different line in that case, your 45

Honour.

Page 313


You are not aware of any transport modelling work done at about that

time, is that what you‟re saying to the Board?

MR MURRAY: In December 2011? 5

MR FOWLER: Yes, in December 2011.

MR MURRAY: There would have been a range of transport modelling being

undertaken. 10

MR FOWLER: I will ask the question more directly. Are you aware of any

transport modelling that was being done in December 2011 in respect

of this project?

15

MR MURRAY: Yes, there would have been modelling done for various

reasons – informing the overall process, the AEE, and as well as that,

that draft incomplete report that you referred to earlier.

MR FOWLER: All right. No, that‟s fine. Okay. That takes us forward. Can 20

I ask you, perhaps, a question that might well be self-evident – that

draft report does not appear anywhere in the application papers, does

it?

MR MURRAY: It was never finished. It was still draft, it was still within 25

Beca.

MR FOWLER: That report, and the substance of it, doesn‟t appear anywhere

in the application papers, does it?

30

MR MURRAY: Not to my knowledge, no.

MR FOWLER: Do you know anything about the reasons why it wasn‟t

included?

35

MR MURRAY: No, because it was never finished, so it was obviously not

required.

MR FOWLER: Okay. Well you‟ve just given me an answer that it wasn‟t

included because it wasn‟t finished. My question was, do you know 40

the reasons why the draft was not included in the papers that came as

part of the application?

MR MURRAY: I don‟t know what papers you are referring to, sorry.

45

MR FOWLER: All right. Part of the application.

Page 314


MR MURRAY: Sorry, what was the question?

MR FOWLER: You don‟t know why the substance of that report is not part of

the application? 5

MR MURRAY: I don‟t know why it would or would not be part of the

application. We were asked to do a piece of work which was never

finished, never completed, it has still got draft internal use only, why

would it be part of the AEE – it wasn‟t my call whether they even 10

needed that kind of work.

[9.55 am]

MR FOWLER: All right. Now you said before that you have read it, can you 15

confirm that the BCR figure that it calculated was 0.23 for the project?

MR MURRAY: That‟s what that internal draft suggests, yes.

MR FOWLER: And self-evidently that is very different from 0.93, isn‟t it? 20

MR MURRAY: Yes.

MR FOWLER: Are you able to assist the Board with the reasons for that

difference, or is that beyond your expertise? 25

MR MURRAY: I have perused that report and I did at the time, and there were

a number of issues that I raised with it that I was uncomfortable with,

that I believed it was missing a number of elements.

30

MR FOWLER: That wasn‟t quite my question, Mr Murray. Let me ask it

again this way. Was one of the reasons articulated in that draft for that

change that costs had gone up?

MR MURRAY: They had gone up prior to a previous one. Yes. 35

MR FOWLER: And was another reason, and a significant reason, articulated

in that report, that the benefits had slumped?

MR MURRAY: The benefits were less than in the previous calculations, yes. 40

MR FOWLER: And do you recall whether that slump was of the order of from

$429 million down to $118 million, articulated in that draft?

MR MURRAY: That sounds about right, yes. 45

Page 315


MR FOWLER: Different topic, Mr Murray. Would you agree that in terms of

the future growth in the district, most planning is on the basis that

there‟s going to be high or medium growth in Waikanae? Is that a

proposition you would agree with?

5

MR MURRAY: I don‟t understand the context. Whose definition of high low

or medium? I‟m not sure what you‟re referring to.

MR FOWLER: All right. Well, let‟s be a bit more specific. In terms of the

district plan, and I apprehend from your answer to Ms Simons you have 10

some familiarity with that, is that right?

MR MURRAY: Specifically around the airport precinct, I looked into that,

yes.

15

MR FOWLER: Well, are you also familiar with what has been rezoned for

new residential areas in the Waikanae vicinity? That must have been a

factor in your planning, surely, Mr Murray?

MR MURRAY: Yes, the modelling included assumptions about future growth 20

around the Ngrara area specifically.

MR FOWLER: Right. And with Ngrara, that‟s by far the largest of those

changes, isn‟t it?

25

MR MURRAY: I believe so.

MR FOWLER: Would you accept that development there is also likely to

stimulate some commercially zoned land in that vicinity?

30

MR MURRAY: I am not familiar with the specific zoning in that, but as you

just described, I understand it is mostly residential.

MR FOWLER: Yes. Well, have you factored that at all into any of your

amylases, that a growth in Ngrara in the residential area, will have 35

some flow-on effects in terms of the commercially zoned land?

MR MURRAY: I‟m not sure what commercially zoned land you are referring

to.

40

MR FOWLER: Okay.

MR MURRAY: What we‟ve used is estimated traffic generation for that

development.

45

Page 316


MR FOWLER: In terms of that traffic generation, that is relatively close to the

proposed Waikanae grade separated intersection that is proposed, isn‟t

it?

MR MURRAY: One of the connection points is indicated to be in that area, 5

yes.

MR FOWLER: And in your analyses, wouldn‟t you be expecting that the

growth of traffic generated by those new areas is going to be locally

focused using the expressway between Paraparam, Paraparaumu and 10

Waikanae?

MR MURRAY: Between Ngrara and Waikanae?

MR FOWLER: Yes. And Paraparaumu. 15

MR MURRAY: I wouldn‟t expect them to be using the expressway between

Ngrara and Waikanae. They are basically in Waikanae.

MR FOWLER: But you‟re not planning for any growth in terms of traffic on 20

the expressway itself between say Paraparaumu and Waikanae

attributable - - -

MR MURRAY: Yes. Those movements, yes.

25

[10.00 am]

MR FOWLER: Thank you. Yes. And would you agree with me that ordinarily

that would be the function of a local road, but for the presence of the

expressway? 30

MR MURRAY: A local road could form that function, yes.

MR FOWLER: Just a couple of other queries to wind up, Mr Murray. You‟ve

referred to, I think early in your evidence at paragraph 9, 35

“comprehensive modelling of pedestrians and cyclists”.

MR MURRAY: No, that‟s not what it says. It says a “comprehensive

assessment of the transport effects including assessment on cyclists,

pedestrians” - - - 40

MR FOWLER: Yes, no, this is - - -

MR MURRAY: This has “included detailed modelling of the future

conditions”, so we haven‟t done comprehensive modelling of 45

pedestrians and cyclists.

Page 317


MR FOWLER: That‟s exactly the question I was – you‟ve anticipated exactly

the question I wanted to ask next, Mr Murray. So thank you, I‟ll move

straight on. In terms of the Western Link Road, you made, I

understand an observation yesterday in cross-examination that the 5

Western Link Road - - -

CHAIRPERSON: Wednesday.

MR FOWLER: It would have been indeed, thank you, sir. Yes. The Western 10

Link road doesn‟t take off nearly as much traffic as the expressway –

do you recalling making that observation?

MR MURRAY: I don‟t recall specifically making that observation, but I

understand that that is in my evidence on State Highway 1. 15

MR FOWLER: That‟s a proposition you agree with?

MR MURRAY: On State Highway 1, the existing State Highway 1, yes, the

analysis that was done previously by others, but that you referred to, 20

showed a smaller reduction on State Highway 1 due to the Western

Link Road than this expressway project does.

MR FOWLER: And the same question that you anticipated a moment ago I

want to ask you, in respect of that, have you done any analysis or 25

studies on which that observation is premised?

MR MURRAY: I have read that strategy study in which that had that predicted

analysis from the Western Link Road and I‟ve also been involved in

these reports which showed an expected reduction due to the project. 30

MR FOWLER: So the precise analysis that you‟re relying on is the strategy

study and what was the other part of your answer?

MR MURRAY: Well the strategy study looked at the Western Link Road, and 35

that‟s where the predicted reduction from that has come from. They

also looked at a version, a slightly different version to this expressway,

and with regard to this project, all our technical reports and my

evidence is what the expected reduction of State Highway 1, around

50-odd percent, has come from. 40

MR FOWLER: So in respect of the second half of that answer, you‟re relying

on the studies that have been done by whom?

MR MURRAY: The strategy study was done previously. 45

Page 318


MR FOWLER: Yes.

MR MURRAY: I believe it was done by Opus Consultants.

MR FOWLER: Yes, and then your answer went on to deal with studies in 5

respect of what I took to be the assessment of effects or this

application. Can you just be a bit more precise about what you were

relying on when you gave that answer?

MR MURRAY: The assessment of effects on transport that we‟ve done, and 10

all the technical reports which are part of the application are where I

get the predicted reduction on State Highway 1 from the project from.

MR FOWLER: Right. And by “we”, do you mean Beca?

15

MR MURRAY: Sorry?

MR FOWLER: By “we” do you mean Beca?

MR MURRAY: Sorry, you‟ll have to remind me where I said “we”. 20

MR FOWLER: A moment ago you said “we” – studies “we” have done.

MR MURRAY: Through the Alliance, through Beca and through which are

part of the Alliance, yes. 25

MR FOWLER: Right. Thank you, sir, I have no further questions.

CHAIRPERSON: Thank you. Re-examination?

30

MR HASSAN: I don‟t have any.

<RE-EXAMINATION BY MR APPLEDOORN [10.04 am]

MR APPLEDOORN: In relation to the potential for development At the 35

airport, are there GFA thresholds at the restricted discretionary level in

the district plan?

MR MURRAY: There‟s a range of them. Some of them are – my

understanding is the restricted discretionary comes in at roughly 100-40

102,000 square metres. There are other requirements for infrastructure

at lower levels than that when they‟re not restricted discretionary.

MR APPLEDOORN: Thank you, John.

45

Page 319


CHAIRPERSON: Anything arising from that? Thank you. You may stand

down and you are released, Mr Murray.

MR MURRAY: Thank you.

5

<THE WITNESS WITHDREW [10.05 am]

MS GREGORY: Mr Stephen Hewitt.

CHAIRPERSON: Thank you. 10

<STEPHEN DESMOND HEWETT, sworn [10.05 am]

<EXAMINATION BY MS GREGORY [10.05 am]

15

MS GREGORY: Good morning, Mr Hewett. Can you please confirm that

your full name is Stephen Desmond Hewett?

MR HEWETT: It is.

20

MS GREGORY: And you‟ve prepared a statement of evidence-in-chief dated

4 September and a rebuttal statement dated 25 October?

MR HEWETT: Yes, I did.

25

MS GREGORY: And you have the qualifications and experience set out at

paragraphs 2 and 3 of your evidence-in-chief?

MR HEWETT: I do.

30

MS GREGORY: Do you have any corrections to that evidence?

MR HEWETT: No corrections.

MS GREGORY: And can you confirm that you participated in expert 35

conferencing and you are a signatory to the Expert Witness Joint

Statement to the Board of Inquiry on Traffic and Transportation dated

5 November?

MR HEWETT: I was. 40

MS GREGORY: And as a result of that statement you‟ve provided additional

information set out in the addendum dated the 14th, of which you are

also a signatory?

45

MR HEWETT: I did.

Page 320


MS GREGORY: And can you confirm that the evidence in those statements

are true and correct?

MR HEWETT: They are. 5

MS GREGORY: Thank you. I‟ve got a couple of supplementary questions

for Mr Hewett.

Mr Hewett, you‟ve had an opportunity to read the transcript from 10

Wednesday when Mr Goldie was giving his evidence?

MR HEWETT: I have.

MS GREGORY: When Mr Goldie was questioned by Mr Bennion he talked 15

about the possibility of an alternative route or Hall Road within the

designation but beside Poplar Ave, and Mr Goldie answered that that

was an option to reduce traffic between the site on Poplar Ave used for

the plant storage and the construction zone of the expressway. From a

traffic engineering perspective do you have any comments to make on 20

that option?

MR HEWETT: From my understanding the designation includes the whole of

Gold Rock site, and that‟s been now – a proportion of that‟s been

handed back and so the actual proportion of that section between the 25

designation that only has the road on it, the expressway, and that

section of road is now – site is quite small. Effectively it is really just

the actual plant site, or the site yard. My understanding is that it is only

going to be used for storage of vehicles overnight or for a period of

time, barriers, those type of things that would be used for the 30

construction, and that there would be a relatively small number of

heavy vehicles or construction type vehicles, that would be utes and

those kind of things, that would access that site.

And from that point of view, my point of view, is that it would be to 35

create a hall road between those two, that yard and the actual road

designation would cause more problems than it would actually solve in

terms of having to deal with the dust, those number of – that site

already has an access onto Poplar Road, it‟s not sealed, but it is known

as a clean access, and that it doesn‟t affect the residents at all. And in 40

my opinion it would be easier for those vehicles to access Poplar Road

and travel down it than to actually drive down a Hall Road which

would cause dust problems and those types of things.

45

Page 321


MS GREGORY: Thank you, Mr Hewett. There was also some discussion on

Wednesday about Mazengarb Road and the need to close that road and

provide a detour during the bridge beam placement. Mr Goldie said

that you may be able to talk to this point. Could you explain to the

Board your understanding of the Mazengarb Road bridge beam 5

placement works?

MR HEWETT: So part of one of the submissions from MetLife was that they

wanted the possibility of not having the bridge beams installed at night.

I undertook an exercise to investigate what the actual effects would be 10

if we closed off during the – effect of the inter peak – effectively

between the school, while the school is in place. And in my opinion,

that could be done quite simply and the effect would be relatively

small.

15

[10.10 pm]

You have Guildford and Realm Road that would provide natural

alternative routings for that traffic, and on the section where we

actually cross is the lowest traffic generation or the lowest component 20

of traffic that‟s actually on Mazengarb. So the effect on the community

would be quite small but still allow for school children to actually

travel to and from school, so not affecting the school travel time, which

is the majority of traffic that would be travelling on that section of road.

25

MS GREGORY: And just finally, Mr Hewett, Mr Wignall raised some

concerns in the Traffic Joint Statement about pedestrian access on

Raumati Road and Kapiti Road. In the addendum to the Transport

Conferencing Statement you have provided some additional

information on the duration and timing of construction and the 30

maintenance of those facilities, just explain the outcome of that

additional work for those two roads.

MR HEWETT: So I‟ve looked at all the roads and effectively what we were

asked to do was to identify what the duration was of the terms of – and 35

I have to relate to, sorry – I think Mr Goldie‟s related to these plans that

actually in the report 4, Technical Report 4, and he was ready to

identify what those effects – in terms of Raumati, we have said that we

will provide the footpaths on both sides of the road at all times. In

terms, I think you said, Kapiti? 40

MS GREGORY: Yes.

MR HEWETT: There is a process of constructing firstly to the south first in

terms of Kapiti Road, where we would retain the footpaths on the 45

northern side, the concrete paved one, and we would retain or

Page 322


reconstruct the footpaths onto the south. And that‟s in place for

effectively nine months, and then to build the southern abutment. And

then when we move it over and effectively do the works to the north, to

build the northern abutment, what I have said and talked with the

construct, Andrew Goldie, that we would provide it on the southern 5

side. There is an issue about providing on the northern side because it

actually isn‟t next to the construction site. In my view we would

investigate the possibility of retaining that at the time we did the Site

Specific Traffic Management Plan. But at this time, for kind of health

and safety reasons, we have said that may not be installed. 10

MS GREGORY: Thank you, Mr Hewett. Can you please now answer any

questions?

CHAIRPERSON: Mr Conway? 15

MR CONWAY: Thank you, sir.

<CROSS-EXAMINATION BY MR CONWAY [10.12 am]

20

MR CONWAY: Good morning, Mr Hewett. Now this morning I will be

referring you to obviously your own evidence, but also Mr Wignall‟s

evidence and one of the particular plans which I won‟t get to

immediately but which is CVCM314.

25

MR HEWETT: The Otaihanga Road Crossing?

MR CONWAY: Yes, that‟s correct. Now starting on the topic of access to

Otaihanga construction yard for other site users, in paragraph 41 of

your rebuttal evidence you refer to Ms Thompson‟s suggested new 30

designation condition of – I‟ll wait till you turn to that - - -

MR HEWETT: 39?

MR CONWAY: Sorry, paragraph 41. 35

MR HEWETT: Yes, sorry.

MR CONWAY: And that‟s the condition relating to allowing other users of

the Otaihanga construction yard to continue their access efficiently. 40

MR HEWETT: Yes.

MR CONWAY: Now in your view, will the measures that have been proposed

for that area, in effect, mean that the intent of that condition will be 45

met?

Page 323


MR HEWETT: In my opinion, in terms of providing – because I‟m looking at

construction effects on the road – that any new access or existing

access be retained and that the existing users would be able to access

off and on to Otaihanga Road. In terms of on site, that is, I understand 5

that Mr Goldie has answered that question and said that they would

provide for access to all existing users.

[10.15 am]

10

MR CONWAY: So you would concur with his view?

MR HEWETT: Yes.

MR CONWAY: So in your view that condition, the intent would be met? 15

MR HEWETT: Yes.

MR CONWAY: So I presume you wouldn‟t have any issue then if that was

included, because you would be able to comply with that? 20

MR HEWETT: I would have no issue with it.

MR CONWAY: Turning now to the plan that‟s up on the screen, and in

conjunction with that your evidence-in-chief at paragraph 73, now can 25

you confirm that what we‟re seeing on this plan is the Otaihanga Road

– perhaps if we look at the right hand side of it first, which provides the

bigger picture view – we are seeing Otaihanga Road looking from the

State Highway 1 end towards the coast and there are accesses to the left

and to the right into construction areas. Is that a fair summary? 30

MR HEWETT: That‟s correct. Yes.

MR CONWAY: And in paragraph 73 of your evidence-in-chief, second

sentence, you say “where the existing pavement cross-section fronting 35

a site access point does not allow for construction vehicles to pull off

the through lane before turning into the site” – I‟m presuming you are

meaning before turning right into the site?

MR HEWETT: Yes. 40

MR CONWAY: “Additional pavement will be constructed to allow this

manoeuvre”. Now essentially there, if I‟m reading it right, you‟re

saying that a vehicle moving away from us on that diagram, a truck

turning right into a construction area will remain on the central main 45

carriageway and any other vehicles such as local traffic that are

Page 324


wanting to carry on through will pass it on the left and carry on through

– is that correct on that area of land that‟s marked “E”?

MR HEWETT: So in terms of the drawing that‟s on the right, that is a concept

that‟s been put forward, so it‟s not actually what would be – has not 5

been designed, not detail designed, so it‟s just a concept. But in terms

of your analogy, yes, the truck would, in my view, sit next to the

centreline to turn right, like a normal right-turn lane, and that traffic

would then underpass that vehicle on the left hand side and therefore

we would provide additional widening to effectively provide a right 10

turning bay. So an alternative to that could be it‟s just a widening for

traffic to underpass like you find on the State Highway. Or that we

would, you know, actually mark it as a right turning bay so that people

would know that‟s where the truck sits on the road.

15

In similar terms, I‟ll add to that – similar to any type – so in my opinion

all access will be treated as like any other development access, and so

they would be designed in a way, in accordance with the council‟s

requirements for that access and for that purpose, and therefore the use

and generation of traffic that would use it. And that would all be 20

covered under the Site Specific Traffic Management Plan that is

prepared for each site like this.

MR CONWAY: And so presumably in that process you would look at things

like sight lines, blind spots - - - 25

MR HEWETT: Additional signage.

MR CONWAY: - -- whether it‟s safe for someone to come past?

30

MR HEWETT: Yes. So additional signage would cover from pedestrians,

vulnerable users, cyclists, sight distance, signage, all those things are

required. Therefore, if sight distances is affected therefore you would

look at the speed reduction and those types of things to address those

things. And additional signage to warn motorists and road users of 35

what‟s going on.

MR CONWAY: In terms of speed limits, I think it‟s – you can‟t see it quite

on that big version, the version on the screen, but there‟s a note I think

that says there would be a 50 kilometre an hour speed limit. 40

MR HEWETT: 50K.

MR CONWAY: Do you think that‟s appropriate for an underpassing

manoeuvre in that location? 45

Page 325


MR HEWETT: Yes.

MR CONWAY: Are you aware of Mr Wignall‟s views on that point?

MR HEWETT: I am. And we discussed this in our conferencing and I am of 5

the opinion that we would certainly investigate it in part of the detail

design, but in terms of providing the additional width through there to

allow the vehicles underpass, is an appropriate measure.

[10.20 am] 10

I do understand he is saying that – from our conferencing – that he

would like the vehicle that is coming behind, say, a truck, to actually

stop behind the truck while it does the manoeuvre. I am of the opinion

that that could be what the council approves, but in my opinion, 15

recommendation that the widening should be provided.

MR CONWAY: Out of those two options you‟ve just described, which one

would you say is safer?

20

MR HEWETT: Providing for the underpass. So providing the extra width.

So they‟re not impeding the traffic that‟s coming through.

MR CONWAY: And presumably you‟re saying the detail of that would be

worked through with the council and the council would have the ability 25

to have input into that process and suggest a different way of doing

things?

MR HEWETT: Yes. Just like they would have that same approach and

process for any development which was proposing an access onto their 30

local road.

MR CONWAY: Would you propose to have any sort of safety audit carried

out of these sort of manoeuvres and designs before they‟re finalised?

35

MR HEWETT: If that is within the process the council requires for a site

access, then yes, that would occur.

MR CONWAY: So that is “if” the council sought it you would provide for it?

40

MR HEWETT: If it is required under their requirements for a site access then

yes.

MR CONWAY: If I was to say to you that the council‟s view was that it

would be required, would you have any difficulty with that at this 45

point?

Page 326


MR HEWETT: I would have no problem with having a safety audit of

following that process.

MR CONWAY: Would you have any difficulty with that being expressly 5

referred to in the conditions?

MR HEWETT: I don‟t think that‟s required under conditions because quite

often in terms of site specific traffic management plans there is an

auditing process that goes through that. 10

MR CONWAY: You say “quite often”, is that - - -

MR HEWETT: Well because if you are doing something that actually is a

major construction change then you would undertake, and it is there for 15

a long period of time, you would most probably go through the safety

audit process because it is effectively a new access.

MR CONWAY: And would you do that here?

20

MR HEWETT: If that is what the council requires then yes, we would follow

that process. And that would be set out in terms of the Construction

Management Plan. So there would be a level of – in terms of access

requirements or construction that would set off a requirement and

therefore the council would have the ability within the agreement of 25

that Construction Management Plan, to put that threshold, which may

be at this location. So I would have no problem with following the

safety audit. But I do not believe, in my opinion, that it is required to

be a condition.

30

MR CONWAY: And what is the specific reason for that? It‟s because, you

say, is it, it would already happen anyway?

MR HEWETT: Yes.

35

MR CONWAY: So then again, a condition is not going to change what you

would be doing? It would happen regardless in your view?

MR HEWETT: No, because you‟re effectively then requiring, in my opinion,

that every site access would require a safety audit, and not all site 40

access would require a safety audit, just like you putting an access into

a (INDISTINCT 3.28), not all accesses require a safety audit. Some

locations, they would require a safety audit because of the complexity,

and that would be covered firstly in the Construction Management

Plan, and secondly, it would be covered in the Site Specific traffic 45

Management Plan process.

Page 327


MR CONWAY: Okay. Thank you. Moving on to a new topic – access for

emergency vehicles. Now I would just like to take you quickly to

paragraph 20 of your rebuttal statement, and you say there “I note that

Mr Wignall has not suggested any amendments to the proposed 5

designation conditions or the draft construction traffic management

plan”.

MR HEWETT: Yes.

10

MR CONWAY: And you‟ve referred, I think, later on there, paragraph 25 to

paragraph 8.18 of Mr Wignall‟s evidence where he says “the

Construction Traffic Management Plan needs to be amended to provide

for certain matters including, c) 24 hour access for all emergency

services through construction work areas”. 15

MR HEWETT: So you‟re talking paragraph 25 of my evidence, rebuttal?

MR CONWAY: Yes, you refer to that then. So he has suggested some

amendments. Do you accept that? 20

[10.25 am]

MR HEWETT: Yes, I do.

25

MR CONWAY: Now, in paragraph 26 and 27 of your rebuttal, if I can

paraphrase it, and you‟re welcome to correct me, you are essentially

saying there that the Construction Traffic Management Plan will cover

it? IS that a fair summary? You‟re saying you don‟t need those details

now because it will be in the CTMP? 30

MR HEWETT: That‟s what I‟m saying. I‟m saying it‟s all covered in the

Construction Traffic Management Plan in terms of setting that

requirement. So what he‟s talking about is 24 hour access for

emergency vehicles. That would be outlined as a requirement and is 35

normally outline – well, not normally, it is always outlined as a

requirement, in my opinion, in all the projects I have worked on in

terms of providing for emergency access.

MR CONWAY: So the Construction Traffic Management Plan will say that 40

there will need to be 24 access for all emergency vehicles?

MR HEWETT: Yes, because the council will be reviewing that and that is

what they will be requiring, and I think that is appropriate.

45

Page 328


MR CONWAY: Okay. So if the conditions, again, were to say that that was a

requirement, that wouldn‟t be a problem for you, would it?

MR HEWETT: I don‟t think there should be a condition, because the outline

is that in terms of when we are putting in the beams for the bridges, the 5

road will be closed, so therefore there would be a detour in place and so

as part of doing that Site Specific Traffic Management Plan for that

activity the emergency, police, you know, fire, ambulance, would be

contacted to make them aware of it and so they would know the

alternative route if they required to actually access a property. And so 10

having a condition that says you have to have 24 hour means that while

putting the beams in would mean we would have to have an access for

emergency vehicles.

MR CONWAY: So aside from that? 15

MR HEWETT: And that may not be, you know, able to be provided.

MR CONWAY: Aside from that location though you are saying it would be

provided? 20

MR HEWETT: All other times it would be provided, but to have a condition

that says you must provide it would mean that you couldn‟t provide it

because it would be put in there, bridge beams in for example it would

require you couldn‟t have emergency access. But a detour would be 25

provided.

MR CONWAY: Okay. In terms of the overall approach, your evidence takes

the view that in terms of the matters raised by the council‟s submission,

essentially any requests for further detail should just be dealt with 30

through the CTMP processes, is that right?

MR HEWETT: Through the, yes, the Construction Traffic Management Plan,

process plan, and then down into the Site Specific traffic Management

Plans. 35

MR CONWAY: So you‟re saying where the council has asked for more detail

now, that will be dealt with when it gets sent the CTMP, the

certification, 15 working days before construction starts?

40

MR HEWETT: In all the projects I have been involved in you have a process

in terms – and that will be set out in the process in terms of the

Construction Management Plan But when you‟re dealing with complex

traffic management processes the Construction Management Plan sits

in between, it takes construction activities, traffic management and 45

communication. It is the document that gives the traffic management

Page 329


team the teeth to be able to control and deliver an outcome that

minimizes and mitigates effects on the community in terms of

construction activities. And effectively it is what has been provided at

the moment as a – what I would a layman‟s terms view so everyone can

understand it. 5

When we re-write that Construction Management Plan for the project it

will outline whose responsibility, what their roles are, what the

thresholds, what the objectives are, how you are going to undertake the

activities. So it is quite clear and quite – and then to have the ability 10

for the council to have a participation in it. In all of the ones that I have

produced the council has an activity in being involved and making sure

that their needs are met. Because at the end of the day we‟ve got to do

a Site Specific Traffic Management Plan – we don‟t want that to be

held up. 15

[10.25 am]

So most times when they‟re complex we are talking to the council and

the independent reviewers well before that 15 days because we want it 20

to be a smooth process to go through. The construction guys don‟t

want to be held up because they need to meet a programme with

delivery. So it‟s never been an issue, in my opinion, before. The

council issues have always been addressed through that process and it

is therefore not a requirement to have a condition that makes 25

mandatory requirements for the contractor.

MR CONWAY: In terms of managing your timeframes, presumably you‟re in

quite a good position here in that instead of waiting till that 15 working

day period kicks off or any pre-consultation you have with the council 30

to find out what the council thinks, you‟ve got some pretty clear ideas

here about what the council will likely be requiring in that process,

haven‟t you?

MR HEWETT: I think the council has put some ideas up. In terms of 35

construction there have been concepts been put forward that I have, you

know, been asked to look at and provide evidence associated with, but

that doesn‟t mean that is the exact way they‟re going to construct. At

the time when they look at, you know, the whole process, the full

balances, the construction process, the alternatives in terms of like how 40

they can construct, there will be modifications that need to be

undertaken. And if you provide that, you know, detail now in terms of,

you know, I will call it “hemming them in”, then you won‟t be able to

provide the flexibility later on which is what you want to get a better

outcome. 45

Page 330


And that is what I‟ve seen with, you know, design and construct

contracts where they haven‟t quite prescribed – you must meet this

level – and therefore the innovation, the benefits that you could provide

by coming up with alternatives. And just to reiterate, the Construction

Management Plan process gives teeth to the Temporary Traffic 5

Management Team to be able to manage the construction crews to

deliver a better outcome and mitigation for traffic effects related to

construction. And then to communicate those early to the community-

so the school and to pupils – in terms of getting information out the

community in terms of signs, so that people are aware of what 10

alternatives they can do.

MR CONWAY: The application documents contained a draft CTMP, didn‟t

they?

15

MR HEWETT: They did.

MR CONWAY: And I suppose the point that I‟m wanting to explore with you

is that you‟ve got comments from the council about what it thinks

about that draft and you‟ve got a choice between reflecting those 20

comments in the document and conditions now and therefore being

ahead of the game, or waiting until that later process and then

potentially having the council turn around and say “actually no, we‟re

not satisfied with what you‟ve got here, and by the way we have been

telling you the whole way through”, and what I‟m hearing from you is 25

you are saying you would still prefer to have the flexibility of not

updating it now and instead make those changes later. Is that a

summary of what you are saying?

MR HEWETT: I‟m saying that the process is appropriate, that they shouldn‟t 30

be prescribed conditions in terms of temporary traffic management and

that the process that should be followed is providing a management

plan that allows those flexibilities and that the protection that you are

talking about is provided through that process, both from the council,

the community and also the contractor. 35

MR CONWAY: Thank you, sir. No further questions.

CHAIRPERSON: Mr Bennion?

40

<CROSS-EXAMINATION BY MR BENNION [10.34 am]

MR BENNION: Mr Hewett, you have responded in your rebuttal, I think, to

some statements by the Raumati South residents, so I‟ll focusing on

them, they‟re my clients. 45

Page 331


Have you got, just for reference as we go, it would be useful if you‟ve

got a map of the Poplar Ave area in front of you, and I‟m thinking of –

if you‟ve got the statement of rebuttal of Andrew Goldie, he‟s got a

couple of maps at the back of that.

5

MR HEWETT: Sorry, it‟s small, but are you talking about that?

MR BENNION: Yes, that will do.

MR HEWETT: That map which is in his rebuttal evidence - - - 10

MR BENNION: Yes.

MR HEWETT: - - - CVSP105.

15

[10.35 am]

MR BENNION: All right. The first questions are about a response you made

to my friend about the suggestion of a hall route beside Poplar Ave on

the southern side between the Popular Ave interchange construction 20

site and the Goodman‟s cleanfill operation.

MR HEWETT: Mm‟hm.

MR BENNION: Yes? 25

MR HEWETT: Yes.

MR BENNION: Yes. And you thought the site is only going to be used for

storage of vehicles. I understood Mr Goldie to say that the site might 30

also be used for the temporary storage of fill, but do I understand that

you are now saying that‟s not going to be its use?

MR HEWETT: No, from what I saw in the transcript in terms of the area that

potentially is going to be given back to the Kapiti Pony Club, that it is 35

actually small. There would be some room to put fill in the area that‟s

been identified that would remain, I would say that‟s a relatively small

area in terms of fill that could be provided for.

MR BENNION: We might be at cross purposes here. During the work on the 40

interchange, would this area on the southern side of Poplar Ave be used

for transporting and moving fill backwards and forwards above the –

different from the current Goodman operation, but actually

requirements of the interchange?

45

Page 332


MR HEWETT: I think that would be a question you need to put to Andrew

Goldie, but my understanding is that the number of vehicles that would

be accessing that potential yard and that site is quite small. So when

we – in terms of the construction process – are looking at the number of

vehicles that would access the whole of the Poplar interchange site in 5

terms of preload, in terms of construction, we effectively identified a

maximum of 17 vehicle movements – so that‟s in and out – to the area.

So of that you‟re talking a very small proportion that would actually

then travel up to that yard.

10

And so I was of the opinion, when I was asked to look at it, would a

Hall Road be – I know it‟s been identified in the designation, is that

appropriate? I was of the opinion that you‟d have more issues

associated with dust and those type of things than with being able to

use the current access as it stands at the moment, which is, from my site 15

visit, has been used by trucks and is a relatively clean and has no real

issue associated with debris being pulled onto the Poplar Road and

looks very clean.

MR BENNION: Yes, so I think I would agree with you if you were just 20

identifying 17 movements. So what are the 17 movements between

where are where?

MR HEWETT: So in terms of those 17, they are effectively to the north. So

that is backwards and forwards from the quarry or from the site. 25

MR BENNION: And so – sorry?

MR HEWETT: So they‟re travelling effectively right in, left out, if you‟re

talking about the State Highway/Poplar Ave intersection. 30

MR BENNION: And that‟s 17 extra movement per day?

MR HEWETT: No, that‟s in an hour.

35

MR BENNION: In an hour. Okay.

MR HEWETT: So that is a peak. So we‟ve identified what‟s the maximum

number you could possibly get, and we‟ve used that in our analysis all

the way through. 40

MR BENNION: Right. And so you think that‟s all the movements – but

you‟re not sure whether that might include some movements of using

the site for temporary fill, for storage of fill on a temporary basis?

45

Page 333


MR HEWETT: There could be. But no, that hasn‟t – no, that‟s more of a site

Specific Traffic Management Plan when you‟re looking at what‟s

actually the construction activities are going on and then looking at the

actual impacts on that in terms of the access arrangements.

5

MR BENNION: All right.

MR HEWETT: From my discussions with Andy Goldie is that my

understanding – and that even looking at the area that‟s available, that

there would be only a small number of construction vehicles using that 10

access.

MR BENNION: Okay. Can I come to another topic then which is the

restrictions on construction traffic during the peak morning and

evening peaks, and have you seen the opening submissions for the 15

Raumati South Residents?

MR HEWETT: Yes.

MR BENNION: And our suggestion that – well, it seems to us that you‟ve 20

assumed a morning peak of 8.00-9.00 am – am I correct that that‟s

what you‟ve assumed in your modelling, in your assessments?

[10.40 am]

25

MR HEWETT: So for all the modelling work the peak for the whole area is

8.00-9.00 and that that peak has been taken in the analysis in terms of

determining what the (INDISTINCT 0.13) any issues, and what we‟ve

identified is that there is a potential, because vehicles are coming from

Wellington and from the south travelling up, vehicles having to exit 30

Poplar or enter Poplar, have to cross that higher flow. In the morning

the majority of flow is going south – there‟s still a relatively high flow

going north, but it‟s not of the same order, and therefore it is easier for

those vehicles to travel out, and that our construction vehicles are only

turning right in and turning left out in that morning. 35

They are not doing the trip – they are not doing the movement to the

south, they are not doing the right turn. So we didn‟t, when we did the

analysis it wasn‟t flagged as an issue and in my review of it, I don‟t

believe there is an issue. 40

But in saying that, as part of the Site Specific Traffic Management plan

that would be produced for that site, we would survey that flow at the

time of the construction period, and if it is determined that the level of

construction – there is an impact that is association with the am peak, 45

then the plan would actually identify that and restrict the hours.

Page 334


But in my opinion, I don‟t think that restriction is required. But to give

you – if you were talking for what the process does, the process does

allow to identify issues that we don‟t know about now. And it just to

say that, the period might be a couple of years on – I don‟t know when 5

it‟s going to start. The traffic can change and therefore the change in

traffic would be reflected in terms of what the impacts are.

MR BENNION: But just going back – currently you‟ve modelled a morning

peak of 8.00-9.00 am? 10

MR HEWETT: Yes.

MR BENNION: And the residents tell me that‟s not when the peak is, or it

extends – it‟s certainly starts at around 7.30. So your current 15

modelling, where it talks about a peak, is inaccurate according to the

residents, would you accept that, in terms of the numbers that is it

using?

MR HEWETT: I can‟t say “yes”, or ”no”. I don‟t know. 20

MR BENNION: All right.

MR HEWETT: What I can say is that when the Site Specific traffic

Management Plan is done, that they would determine when the actual 25

peak is and the full effects, and that they would know the full effect in

terms of construction activity rate from, you know, the 7 o‟clock right

through. That hasn‟t been outlined, but it would be outlined through

that process.

30

MR BENNION: In that later process, will you be undertaking modelling of a

7.30-9.00 peak?

MR HEWETT: I would say, I can pretty well 100 percent guarantee that that

would occur. 35

MR BENNION: Well why don‟t we get it done now, to be accurate?

MR HEWETT: I don‟t believe that – the process that has been outlined that

would cover that issue, and if it was identified as an issue it would 40

come up with appropriate mitigation.

MR BENNION: But you think the modelling will be 99 to 100 percent certain

to happen – that looks like a pretty good reason to do it.

45

Page 335


MR HEWETT: Well no. For all activities that we would do, for all the things

that we have done now, we would redo it. So for all site accesses, for

all mitigation that we have identified as part of the construction

management process, we would redo the modelling. So this is no

different – this site is no different from Mazengarb, Kapiti, Te anga, Te 5

Moana.

MR BENNION: All right. Let me – just finally on that topic, does your

modelling – your modelling currently also doesn‟t look at any possible

peaks surrounding school closure times, at about 3 o‟clock, like the 10

Waldorf School or the Raumati South School?

MR HEWETT: No, it doesn‟t. But that would be – so that would be

investigated, as I‟ve outlined before, in terms of looking at it. But I

don‟t believe that is a big issue. I know it has been raised, but I don‟t 15

believe it is a big issue.

[10.45 am]

MR BENNION: All right, now can I just move onto another topic which is, 20

just this question of the expectation that the local road network might

have to take up some of the slack during the construction period and I

think in opening we said some Leinster Ave, and this is quoting from

traffic report 33 “some Leinster Ave and Poplar traffic will use the

KCDC road network rather than the existing State Highway One and 25

there will be observation and management of that. Now let me just

understand the process, the site specific traffic management plans

manage the issues at particular sites, there is a potential is there for

work on two sites, for example Poplar Ave interchange and the work on

the bridge on Raumati Road to, the site specific management plans 30

might, will be dealing with impacts there, how do they manage if the

two sites start to throw up complications elsewhere in the local road

network?

MR HEWETT: They might be site specific but they do relate in terms of the 35

construction programme if they are going on at the same time so they

are effectively a factor (INDISTINCT 1.50) in time, if there is an

overlap and the effects were taken into account to overlap and so we

cannot control the local traffic, the local traffic would use local roads if

it sees it is easier to do that so I think you identified in technical report 40

33, we just identified and that is we as Becca and in terms of my review

agree with it that some local traffic would use, because you can travel

on the local road without using the state highway between Poplar and

Raumati and that may occur.

45

Page 336


MR BENNION: All right, so I just want to understand the process here. I

suspect that the problems would show up then in the queue lengths

etcetera at the site specific sites and then you have an adaptive

management approach that would look at that?

5

MR HEWETT: Yes.

MR BENNION: And could think about relationships between two sites and

what was occurring?

10

MR HEWETT: Yes, and as part of the construction just to add for the Board

in terms of the construction management plan it would identify

monitoring, it would identify that Poplar was not identified as a

monitoring site that in my opinion it should be, it would be.

15

MR BENNION: Now can I come to another topic which is the Leinster Ave

entry on State Highway One I think is shown in Mr Goldie‟s map, in his

rebuttal, his first map. He talks about a possible access point from the

Poplar Ave interchange construction area directly onto Leinster Ave

and from his point of view that was preferable rather than trucks 20

entering onto Poplar Ave and then coming onto State Highway One,

you were here for his evidence or you have seen his transcript?

MR HEWETT: I have seen his transcript and I understand the issue so what is

the question. 25

MR BENNION: So he expressed a preference for construction vehicles to use

the entry from Leinster Ave directly onto State Highway One rather

than going out onto Poplar Ave and then turning onto State Highway

One, in the construction terms that was his preference. In traffic terms 30

that is something that can be provided, that is a possibility is it not?

MR HEWETT: That is a possibility.

MR BENNION: If that was an expressed preference in terms of perhaps 35

impacts on traffic on Poplar Ave so there was a preference to try and

get trucks to get using that Leinster Ave turning point, that is something

that would be quite possible within the traffic management plans?

MR HEWETT: Yes, so in terms of for example if you raised the site specific 40

traffic management plan and we have identified that construction

activity during the pm peak that was an issue and that may be part of

that pm peak. to address that pm peak.

Page 337


[10.50 am]

In terms of say shortening up the construction you could use both

accesses so it could effectively be in and out to use the phrase quickly

for the pre-load and so the impact on the community is, in terms of 5

construction traffic is reduced. Just to add to that it would all be

covered under the site specific traffic management plan.

MR BENNION: Can I then come to, well let‟s, while we are at that moment,

can we just come to some proposals or outcomes that were noted in the 10

opening submissions for Raumati South, we have said that Raumati

South residents should have input into the SSTMP for Poplar Avenue

interchange so that what we are envisaging there is that the residents

would get to some sort of, when the Kapiti Council is looking at the

drafts for that the residents at that stage would be able to have some 15

sort of comment to the council and that could be part of their

consideration of the SSTMP, there is no problem with that sort of

approach?

MR HEWETT: In my opinion that would be no problem, they are just a 20

stakeholder so effectively under the construction management plan we

would identify stakeholders effectively like emergency services, there

would be a series of agreed stakeholders who have an interest in certain

areas and that would be appropriate that they understand what is going

on. As I outlined before as part of the communication you want to 25

understand who you are dealing with so therefore no surprises to

anyone or good ideas, the understanding of when things go on, the

community knows about it.

MR BENNION: All right, and the other thing that was noted in the 30

submissions that your construction environment management plan

appendix O, has a section 3.3.2 State Highway One Travel Times, this

is in, have you got our opening submissions or appendix O in front of

you?

35

MR HEWETT: Whereabouts in your opening submission?

MR BENNION: Just at paragraph 41.

MR HEWETT: Yes. 40

MR BENNION: So you have got that paragraph in front, paragraph 41 in

front of you?

MR HEWETT: Yes. 45

Page 338


MR BENNION: Yes, now that is the construction environment management

plan is the sort of overarching framework document and the lower level

plans come under that, but this is the overarching framework for it yes?

MR HEWETT: Yes. 5

MR BENNION: This talks about State Highway One travel times and

efficiency and safety of the road network during road construction,

there is a comment in the plan at third paragraph “journey times will

also be monitored on Raumati Road, Kapiti Road, Mazengarb Road, 10

and Te Moana Road”. It seems to me from the evidence that that should

also include Poplar Ave should it not?

MR HEWETT: I agree.

15

MR BENNION: A key site yes?

MR HEWETT: I agree as I said previously.

MR BENNION: All right, and it goes on to talk about base journey times and 20

some allowance being made, I am looking at I think the third sentence

in that third paragraph “the KPI is proposed to be based around the

base journey time plus some reasonable delay expected for construction

works”, what is meant by “reasonable delay” there, is there some range

or relatively objective measure we can refer to there? 25

MR HEWETT: Copton (ph 4.14.9) says that the maximum is five minutes,

but that to me is not for a long term construction activity. The whole

purpose of monitoring is to identify when you have got a problem and

it is just not two months, you are trying to report a trend and effectively 30

I assume the Alliance would in terms of its monitoring requirements

would look at technology and try and think what is the best way of

providing that monitoring. There is no set guideline, the guideline is

five minutes but that is not in my opinion for long term impacts. That

is not acceptable I do not think in my opinion for a community to be 35

suddenly “I am going to be increased by five minutes”. What you are

looking for in terms of that monitoring process is reliability so people

know, “okay I might be delayed an extra couple of minutes, but I know

when it is, what my alternative to do that” so if you are in an

emergency or you need to get somewhere you can understand what is 40

going on.

[10.55 am]

MR BENNION: If five minutes is not acceptable what is acceptable in your 45

experience?

Page 339


MR HEWETT: It is hard to say, each community is different and you cannot

put a number on it. What we would be doing is identifying what delays

there is and what the mitigating, so we are causing it from a

construction point of view, we would then come in place and say “that 5

is not acceptable” because there is a feedback process in terms of the

community so if we are putting undue delays on a network at certain

times of the day, then that would be fed back through the consultation

process through to the temporary construction management team would

then put in place alternatives. It can vary so what tolerable to me may 10

be not tolerable to someone else and so it is looking at is it a one off

event, is it something that is there all the time. I am not, I cannot give

you what is actually a number because everyone has a different view on

what is acceptable.

15

MR BENNION: Are you saying, in your answer there I think you are saying

that what is acceptable in some way is based on what the community‟s

current expectations might be and how they live their lives and use

cars, is that the way you put it?

20

MR HEWETT: Yes, and so there will be delays. I do not know, there will be

delays. We are trying to minimise those delays as much as possible

and then come up with a mitigation to actually address them.

MR BENNION: All right, just a last thing then the informal walkways issue 25

that Ms Campbell-Cree raises in her evidence and you mentioned it in

your rebuttal I think paragraph 14. I just want to be sure we are talking

about the same thing, you said a second map that Mr Goldie has in his

rebuttal and this is the one that shows us the change to the designation

but it also takes in the area that I am interested in. I think it is annexure 30

C to his rebuttal, yes.

MR HEWETT: Yes.

MR BENNION: Now I think most of the walkways that Ms Campbell-Cree is 35

talking about are from Leinster Ave, you said Leinster Ave is obviously

the community to the east here, the bottom of the picture and heading

west over to Matai Road and there is the Raumati South primary school

on Matai Road. Are you proposing closing off those informal

walkways across that area? 40

MR HEWETT: No, they are not part of the construction.

MR BENNION: Yes that is what I was thinking about.

45

Page 340


MR HEWETT: So I was a little bit confused with why it had been raised. I

thought she was talking about some other walkways that came off there

that were going to be closed by the construction works, they may circle

around through there and therefore my view would be that they use the

local network or as you say, the local walkway that goes through the 5

little park that is on Leinster and then crosses through to the school.

MR BENNION: You are talking about small areas, a few hundred yards and

not this space?

10

MR HEWETT: No, they are still, the informal walkway across to the school,

effectively through the park, the little park there, that would be retained

in my opinion. That is not affected by the work so I cannot see why we

would even be there to make any alterations to that.

15

MR BENNION: All right, thank you sir.

CHAIRPERSON: Thank you Mr Bennion, now - - -

MR FOWLER: I should be less than five minutes sir. 20

CHAIRPERSON: Thank you.

<CROSS-EXAMINATION BY MR FOWLER [10.59 am]

25

MR FOWLER: Mr Hewett, with regard to the one percent increase in State

Highway 1/Kapiti Road intersection due to construction traffic, can I

ask you is there any analysis that has been done in terms of how much

of that is heavy traffic and how much otherwise?

30

MR HEWETT: There would be some you know what the proportion is but in

terms of the numbers that have been provided in the report we are

talking in the order of 150 construction vehicles a day associated with

using Kapiti Road, effectively the State Highway.

35

MR FOWLER: So of that one percent injection those 150 vehicles per day

would represent roughly what?

[11.00 am]

MR HEWETT: In the order of say 100 heavy vehicles I would have thought. 40

MR FOWLER: So it is obvious from that is it not that the majority of that one

percent would be heavy vehicles?

MR HEWETT: Two- thirds yes. 45

Page 341


MR FOWLER: Two-thirds, yes. And in traffic engineering terms when you

are looking at the impact of the heavy vehicle, the standard compilation

if you like that equates to 2.5 to 3 percent of passenger car units when

you are assessing congestion or impact is it not?

5

MR HEWETT: Yes, in PCU‟s yes.

MR FOWLER: There has not been any quantitative analysis in respect of that

intersection as to whether that injection or increment would render the

intersection to any degree dysfunctional has there? 10

MR HEWETT: No, and in my opinion is not required. We are talking in the

order of 15 vehicles using it in the peak hour, that is less than the

fluctuation that would occur on a daily basis in the peak hour.

15

MR FOWLER: I have no further questions.

CHAIRPERSON: Re-examination?

<RE-EXAMINATION BY MS GREGORY [11.01 am] 20

MS GREGORY: Just one question, your Honour. Mr Conway asked you

about the site specific management plans being provided to the council

15 days before they may need to be certified, is it your understanding

of the conditions that the council would be involved in the preparation 25

of those plans as a key stakeholder?

MR HEWETT: Yes.

MS GREGORY: Thank you, that is all. 30

COMMISSION BUNTING: Now I have got a bit of a philosophical question

on this question of management plans if I may. Would you agree that

construction traffic is significant in terms of this overall project, in

terms of what needs to be considered which is controlled and managed, 35

it is a significant effect of the project?

MR HEWETT: Localised, yes. There is effect, but I do not believe it is

anything greater than what would be going on normally down the

network that most people would go on their daily business other than 40

they pass past the bridges that were being built, that is when they would

actually notice the effect. Yes, we are effectively cutting through all the

roads as you go through, but a day to day impact would be less than

minor in my opinion, in terms of, we are retaining the capacity, these

roads are not motorway or high speed state highway where therefore 45

you would get the reduction in capacity because you are slowing the

Page 342


traffic down. We are talking about maintaining the 50k speed

environment or to certain roads we are reducing it down from open

grade, but they are already travelling at slower speed because of the

actual alignment, and in that the impacts in my opinion would not be

felt by the community. They just get on with their day to day lives and 5

have very little impact on the construction activity other than they see it

when they drive past or they are building a beam, there is a crane there.

COMMISSION BUNTING: Do you know if that is a view shared by your

colleagues, other witnesses? 10

MR HEWETT: I do not know, but that is my opinion from being involved in

a large number of construction projects where I have been involved in

providing the traffic management or coming in and dealing with

complex issues, that when we have distilled it and gone back and 15

reviewed it, the impact has always significantly less than what we

expected at the start.

COMMISSION BUNTING: And the question of management plans I think

you know Mr Conway was asking you questions about whether there 20

should be conditions around various things over the top of the

management plan, do you have a view on where you think this Board

should sit in terms of its responsibilities for consideration of

construction traffic effects because construction management plans are

not something we would then get involved with. They would be sorted 25

out by somebody else so what do you think our responsibility should

be?

MR HEWETT: I think in terms of helping the Board, I think your

responsibility is that the process of having a construction management 30

plan and then what the requirements in and Copton to produce those

site specific traffic management plans is an appropriate process, that it

has in my opinion on the projects I am involved in, both on rural,

motorway, local road has worked very well in terms of the outcomes

that we have, it is the way that we are doing construction projects now. 35

It is better than being involved where you have got a prescribed

process. You must meet that and that is all the contractor will then

provide, he will not go any further because it costs me money whereas

a plan he can go through and as I kind of outlined before, that plans

gives the traffic peace and that is what you want, you want them to be 40

able to actually control the activities on the road which would actually

effect the local residents and therefore the communication people.

They work closely together through that plan and through the day to

day process.

45

[11.05 am]

Page 343


COMMISSION BUNTING: So by and large you think we should leave all

those matters to those plans to be sorted out later?

MR HEWETT: In my opinion, yes. 5

COMMISSION BUNTING: Just two other points of detail, in answer to a

question from Mr Conway and I am not sure if I picked it up correctly,

if you use the term “independent review of management plan” can you

just explain that a bit further? 10

MR HEWETT: It is a, sorry, to just look at the process there is a team that

know the contractor have a person effectively is not simplified would

use temporary traffic management plans for an activity. It is then

reviewed independently to against Copton and all the issues to make 15

sure they have done the analysis correctly and then they would go

through approve it and then it would go through the process of the

RCA signing off it.

COMMISSION BUNTING: So it is a question of who is this independent 20

reviewer, someone within the Alliance team or is it someone

completely independent?

MR HEWETT: It has been done many different ways. From my personal

opinion or experience I should say not opinion that we do, so my team 25

does quite a lot of independent review for other projects, Becca might

be involved in it as a part of the team but then they would to come to a

separate team that sits outside that Alliance, that would do the

independent review. The processes are there in terms of doing that and

it works very well. That does not have to be a separate organisation 30

doing that role in terms of independence so the word “independent”

does not mean it has to be of a separate company, it means independent

from the team. Even being independent from the team in that process

Alliance works very well. It has not been decided what that person

would be but the construction management plan would identify who 35

that independent person should be or - - -

COMMISSION BUNTING: Identified at that time rather than now?

MR HEWETT: It is normally identified in the construction management plan 40

in terms of discussion with the RCA‟s, what they are requiring.

COMMISSION BUNTING: So the way that things are drafted at the moment

there is no identification that there would be an independent reviewer

and who that person might be? 45

Page 344


MR HEWETT: It is identified that there will be an independent reviewer. It

has not been identified who that independent reviewer would be. The

production of the construction management plan would then go through

the process of identifying everyone so all the roles because at that time

you are identifying the role within the approving organisations, the role 5

who is actually doing the work, the internal auditing process that goes

within the contractor, the independent person who is responsible for it

so on and so forth.

COMMISSION BUNTING: Okay. 10

MR HEWETT: And then the council and both RCA‟s have input into that in

agreeing that process and those roles.

COMMISSION BUNTING: Just one last question, in terms of where you have 15

got in your conferencing I think the first fifth of November one, there

was still some unresolved matters, you have had another round if you

like. In your view are there any unresolved matters to do with

construction traffic management among you experts?

20

MR HEWETT: In terms of construction traffic no, I think we have covered

off the area. No, I do not think there is. I think in terms of there were

some disagreements between, or difference of opinion between myself

and Don Wignall, but in cross-examination I think those have been

addressed? 25

COMMISSION BUNTING: So there were some?

MR HEWETT: There were some, yes.

30

COMMISSION BUNTING: Well that is all I had, thank you, sir.

MR APELDOORN: Is there a possibility and you mentioned the five minute

delay thing I guess as an example that the application of the code of

practice for temporary traffic management could produce some 35

outcomes that are not acceptable to the community?

[11.10 am]

MR HEWETT: In terms of that they are not acceptable in terms of the delay 40

that has been applied by the effect of the traffic management?

MR APELDOORN: that is one example and I think you were indicating that

five minutes might not be an acceptable delay over a longer period of

time but that perhaps just direct application of that code might enable a 45

Page 345


contractor to demonstrate compliance with that code just through its

application.

MR HEWETT: Yes, there may be situations that he has put it, but the process

of going through that communication provides feedback on that and in 5

my opinion that is normally addressed. There will be delays but it is

more about communicating out those potential delays and what they are

to the community.

MR APELDOORN: So how does a community have confidence that through 10

that consultation process its views would be heard?

MR HEWETT: So in terms of the analysis that we have done we have not

identified any areas that have significant delay. We are not reducing

the capacity through the link roads so Kapiti, Te Moana, Mazengarb 15

Road we are providing existing capacity so in terms of that there is

going to be to my opinion very little delay, other than delay that may

occur from someone driving past having a “ooh there is a crane I want

to slow down and look at the crane” but they are already travelling at a

slow speed. Even when you are looking at Kapiti Road when you have 20

got the peak hour it is relatively slow through where it crosses the

corridor. In terms of trying to determine what the delay is we have

determined that is minimal. It does not mean that we are going to do,

where I talk about delays, it might be more than those five minutes,

they are more around when we are putting bridge beams in or we are 25

doing a detour and they are late at night, which we are doing any

normal activity, no different from works that would be done on the

roads within Kapiti in terms of pavement maintenance, intersection

improvements, those type of things where they have to put a detour in

place and therefore communicated out to the public and therefore the 30

road users.

MR APELDOORN: I suppose I heard you say that traffic volumes and things

can change on road networks and it could be quite some period

between sort of now and the commencement of construction. In a 35

community I suppose is looking for some confidence that I guess

around that sort of advice, do you see some particular way that you can

give them level of confidence that effects will be managed to that very

low level?

40

MR HEWETT: I think through the process of monitoring and sorry answering

your question from the start, firstly yes we will go and do surveys at the

time of construction so for example that is effecting through the

summer months. We are not going to take a council winter and apply

that, we are going to look at what the actual traffic flows are during that 45

month and also compare it back to previous years so to look at any

Page 346


changes. If we did a survey and it is not comparable to the year before,

we would ask the question why. That is effectively from my role of

being independent where you asked that question, why is it different?

Then that would be used to determine what the effects would be and

that process would then fall through in terms of we did identify effect 5

which I think in my opinion is minimal for the majority of the long

term construction activities.

MR APELDOORN: If the effects are going to be very small would there be

any concern about providing some confidence to the community in a 10

form of a condition?

[11.15 am]

MR HEWETT: In terms of what type of condition? 15

MR APELDOORN: Well there have been some examples given in terms of

emergency vehicle access for example which is not one of the visions

that is listed currently in the draft conditions.

20

MR HEWETT: In my opinion that emergency vehicles they are top on the list

in terms of stakeholders. They are always provided for and they are

one of the important stakeholders to communicate with. Any activity

that the contractor would undertake, the temporary traffic management

team through the communications team would communicate with those 25

stakeholders. If there was any activity that would identify that would

create significant delay that we would identify greater than normal than

that would be communicated to the construction team to come up with

an alternative, i.e. to do it at night or some other things like that, that

would occur. There is no activity other than in my view putting the 30

bridge beams in that is actually going to cause any undue delay to the

residents or the road users. Effectively, these are sites accesses that are

very similar to a development where you are pulling in and out of.

They do have heavy vehicles, but we are not talking a large number of

heavy vehicles. Otaihanga is the only one and that will be designed to 35

actually minimise that impact and that has been raised by council.

MR APELDOORN: Just my final question, the traffic management plan

approval process, can you just tell us what the process is in terms of

council‟s involvement? I am particularly interested to just understand 40

whether if council is of a view that some effect is of an unacceptable

level, but yet what might have been submitted is in compliance with the

code, what is the process around that for I guess council not certifying a

plan and therefore work is not being able to commence?

45

Page 347


MR HEWETT: I think it is the same for council and same for NZTA they

would be working the impacts on the state highway, they would be

looking at the contractors, very similar to the council. The process that

the TMP has prepared and it is reviewed independently to determine

what the effects are then goes to the RCA for approval. From my 5

opinion even when from other projects where it might comply with the

Copton, they might turn around and say “actually we are not accepting

the outcomes from it, we want something better, what are the

alternatives that we can have”. Those would be pursued and where it

has happened previously whether complex traffic management and the 10

traffic management associated with this construction is not complex, it

is relatively simple.

Yes, it does affect the community but it is not complex, but where it is

complex and the outcome is that we work within Copton like the 15

council has seen to be that we are affecting pedestrians too much or

something like that, then we would look at an alternative so they have

that process to feedback into it and it is a normal process to occur

because of the going rates through the process for the Alliance, they

need to look after the community. There are requirements for the 20

consultation to do it so it comes back into the temporary traffic

management team to come up with an improvement.

It is also part of the monitoring process so they put in a temporary

traffic management solution Net Copton but they had a lot of I say for 25

example, backlash from the community because something was done

that caused an issue then that would be fed back into “hey look guys we

need to change our construction process because we are affecting this

part of the community” and I think that is a normal process. It happens

there is no requirement to have a condition for that to occur, that is the 30

process that works. On other projects it has worked very well having

that flexibility to look after the community.

[11.20 am]

35

CHAIRPERSON: My question which I hope you can answer slightly more

succinctly but it goes a little bit broader than just construction traffic,

but goes to management plans, now I am conscious of the advantages

of the Alliance approach to projects, but it seems to me particularly

when the local authority is part of that Alliance, when it comes to the 40

plans, the enforcement of those management plans and the independent

review as you described it previously, there is a great deal more scope

for conflict of interest. How would you propose to deal with that

conflict of interest?

45

Page 348


MR HEWETT: In my experience that conflict of interest has never come up.

CHAIRPERSON: So there is never any pressure from the cost side, the

construction side on a management plan?

5

MR HEWETT: No.

CHAIRPERSON: Well assume it does, how would you deal with it in an

Alliancing setting when the local authority is part of the Alliance?

10

MR HEWETT: I do not thing I am the, I certainly do not have the experience

to answer that question.

CHAIRPERSON: Right, well we will find someone else who may be able to

answer it. 15

MR HEWETT: Mr Conway anything from the Board‟s questions?

MR CONWAY: Sir, just one quick point of clarification about an answer the

witness gave to a question by Commissioner Bunting, I just wanted to 20

check that I heard you correctly Mr Hewett when you said that in your

view the independent reviewer could be someone from within the same

firm that prepared the management plan in the first place?

CHAIRPERSON: That was the answer. 25

MR HEWETT: That was the answer.

CHAIRPERSON: Mr Bennion?

30

MR BENNION: No sir.


CHAIRPERSON: Thank you, we will take a 15 minute adjournment. 35

ADOURNED [11.22 am]

RESUMED [11.36 am]

40

<TIMOTHY MARTIN KELLY, sworn [11.36 am]

<EXAMINATION BY MS SIMONS [11.37 am]

MS SIMONS: Your name is Timothy Martin Kelly and you are a 45

transportation planner holding the qualifications and the experience

Page 349


outlined on page one and it is a statement of evidence dated the 15 of

October, is that correct?

MR KELLY: That is correct.

5

MS SIMONS: You are also signatory to a joint witness statement dated the 5

of November which had a subsequent amendment dated 14 November?


10

MS SIMONS: Now do you confirm that the evidence that you have given is

true and correct?

MR KELLY: I do.

15

MS SIMONS: I have one question for this witness sir.

CHAIRPERSON: Yes, thank you.

MS SIMONS: Mr Kelly are you satisfied that if full development of the 20

airport area took place and that the expressway was in place that the

local roading network could cope?

MR KELLY: My view on that is the full growth scenario that we will run by

the Alliance team did identify a number of specific locations in the 25

network where it was evidence there were some capacity problems and

potentially significant delays, but having said that I acknowledged

firstly that that full growth analysis is not only full growth of the

airport, but also (INDISTINCT 4.20.3) centre so I would regard it as a

very much a worst case scenario if you like. 30

Secondly, I would acknowledge that the areas road capacity are

probably fixable given the example about the results which were

provided by Mr Murray presented in the addendum to the second joint

statement rather wrongly I think by the potential delay of over 30 35

minutes to the airport on Kapiti Road (INDISTINCT 4.55.1). In my

view things like that are probably fixable to be honest, it is a matter of

adding a lane or changing the intersection or whatever so from that

point of view I am reasonably satisfied.

40

[11.40 am]

I guess just as background for the Board my initial concern with the

application material was that the NZTA appeared to be taking a rather

narrow if you like view of its responsibilities literally in terms of the 45

immediate corridor and not looking to much at the effects a little bit

Page 350


beyond that corridor to either side. Perhaps in terms of its

responsibilities to assess effects and mitigate, seek to mitigate those

that has some validity, but in my view I believe there is also a wider

responsibility to ensure that the wider road network operates

satisfactorily. 5

I got really quite frustrate at one point to hear arguments really going

on between the NZTA or the Alliance on the one hand and KCDC on

the other about where responsibility lay for upgrading short sections of

Kapiti Road when from my perspective and that of the airport and 10

probably the public in Kapiti in general it just makes sense to

consistently upgrade a whole section, rather than trying to divvy up

short sections and split responsibility.

Having said all that these issues have been worked through through the 15

conferencing and I believe we have gone as far as we realistically can

in terms on ensuring the consistent upgrade of Kapiti Road and also

that provision is made for flexibility in terms of future upgrading of the

network and by that I am referring specifically to not precluding an

eventual provision of ramps at Ohakea Street which is something which 20

I have been pursuing.

So to answer your question more directly, I do have a cautious belief

that full growth can be accommodated but subject to the agreed

upgrade of Kapiti Road and subject to an allowance for providing those 25

ramps at Ohakea Street in the future.

MS SIMONS: Thank you, please answer any questions Mr Kelly.

CHAIRPERSON: Mr Hassan? 30

MR HASSAN: Your honour, in view of (INDISTINCT 2.09) joint

conferencing what I announced to the Board yesterday in terms of an

understanding between KCDC and NZTA which has just been

mentioned by this witness and this witness‟ last answers to those 35

questions, I do not need to cross-examine to assist the Board any

further sir.


40

COMMISSIONER BUNTING: Can I just ask one question, so has agreement

been reached about these provisions for these ramps at Ohakea

(INDISTINCT 2.35) Street?

45

Page 351


MR KELLY: Yes, the point we got to in the joint statement was an agreement

that the designation and the design of the project should seek to not

preclude the provision of those ramps at some point in the future. We

are not suggesting they be built now as part of the project, it is really

just seeking to future proof the network if you like and ensure that 5

more capacity could be provided if needed.

COMMSIONER BUNTING: Okay, thank you sir.

CHAIRPERSON: Thank you, you may stand down. I think you have to stay 10

because you are coming back with another hat on shortly.

MR KELLY: A bit later on.

CHAIRPERSON: A bit later on. You may be released. Now we come to Mr 15

Wignall.


<DONALD RICHARD WIGNALL, sworn [11.43 am] 20

<EXAMINATION BY MR CONWAY [11.43 am]

MR CONWAY: Your full name is Donald Richard Wignall?

25

MR WIGNALL: Yes.

MR CONWAY: You have prepared a statement of evidence dated 05 October

2012 and your qualifications and experience are set out in that

statement? 30

MR WIGNALL: Yes.

MR CONWAY: Before we move to conferencing statements have you got

any corrections to make to your statement of evidence? 35

MR WIGNALL: I do. A couple of brief ones at paragraph 5.19, the reference

should be TR34, that is 5.19 and the same in the following paragraph

5.20 it should be TR34 and I think at paragraph 8.7 the last line “ahead

of the 12 months in brackets” I would like to just, I should have added 40

the words “some being”.

Page 352


[11.45 am]

CHAIRPERSON: Sorry?

MR WIGNALL: Sorry, “some being” two words. Yes, and that is it. 5

MR CONWAY: And is there any explanation you would like to give about

that particular change?

MR WIGNALL: The latter one, it inadvertently gave the impression that 10

anything less than 12 months was not a significant problem.

MR CONWAY: And you have been involved in conferencing and there are

two statements, the first dated 5 November 2012 and then an addendum

dated 14 November 2012, is that correct? 15

MR WIGNALL: That is correct, yes.

MR CONWAY: And subject to the changes you have mentioned, do you

confirm that your evidence is true and correct? 20

MR WIGNALL: I do.

MR CONWAY: Sir, I just have one question I thought I would ask and it

relates to a question that Commissioner Bunting asked of Mr Hewett 25

this morning around the overall construction traffic impacts and the use

of management plans. Mr Wignall, were you here when that question

was asked and answered?

MR WIGNALL: Yes, I was. 30

MR CONWAY: For the benefit of the Board would you like to give a brief

view of your thoughts on that question?

MR WIGNALL: Well, as to whether the construction effects could be 35

significant I am of the view that, yes, they could be significant. I

hesitate to suggest what the Board‟s role is in determining these plans

but the content and the way they are implemented could lead to greater

or lesser effects. So I think that the way the current Construction

Traffic Management Plan is laid out and what its content is would 40

seem, to me, to be relevant to the scale of effects likely to be

experienced.

MR CONWAY: Thank you, would you please answer any questions?

45

MR WIGNALL: Yes.

Page 353


<CROSS-EXAMINATION BY MR FOWLER [11.47 am]

MR FOWLER: Mr Wignall, have you been involved in transport modelling

for similar projects overseas? 5

MR WIGNALL: I have, yes.

MR FOWLER: And also in New Zealand?

10

MR WIGNALL: Yes. Yes, indeed.

MR FOWLER: And would it be fair to say your experience is pretty

extensive?

15

MR WIGNALL: Yes, I wouldn‟t describe myself as, if you like, an expert

modeller but, yes, I am used to dealing with this sort of issue.

MR FOWLER: You would have been through it enough times to form a view

of what would be acceptable practice, wouldn‟t you? 20

MR WIGNALL: Yes, I mean practice does vary, that is true and some are

better than others, yes.

MR FOWLER: And in terms of the process that occurred here, did what 25

occurred here match your view of what would be acceptable practice?

MR WIGNALL: In terms of the modelling?

MR FOWLER: Yes. 30

MR WIGNALL: Yes, I mean I think it has been pretty good, an allowance has

been made for induced traffic. That isn‟t always the case in

New Zealand but it has been explicitly allowed for in this project. So,

on balance, in terms of current New Zealand practice I think it probably 35

is pretty good.

MR FOWLER: In terms of the answer that you have just given, do you have

some misgivings in some aspects outside of the modelling with regard

to what occurred? 40

MR WIGNALL: Not particularly, I mean the Alliance model I think is a good

model and I think the Council has been involved in the whole process,

so I think that has been quite a good thing and the amount of

information you get, and the involvement you have as part of that 45

process, is much greater than if it was done in a conventional sort of

Page 354


project delivery and authority being separate. I mean there are things

that have happened that wouldn‟t have been the way I would have done

them but then I haven‟t been driving the project so I wouldn‟t expect

everything to be done perfectly in line with my views.

5

[11.50 am]

MR FOWLER: Can you tell us what those things were?

MR WIGNALL: Well, I would have modelled the Western Link Road. 10

MR FOWLER: Okay.

MR WIGNALL: I put that in my evidence, I thought that was an important

thing to do, and I would have modelled an intermediate growth 15

scenario between the composite scenario and the full growth scenario.

Those are probably the two main things I would have added to the mix.

MR FOWLER: And can I ask you why you would have wanted to model the

Western Link Road particularly? 20

MR WIGNALL: Well, it seems to me that is what would have happened in

the event of the expressway not being developed and that is, again, in

my evidence. And I would have thought it was important to

demonstrate that the expressway would out perform the Western Link 25

Road, that would be my natural sort of method. And as for the growth

scenario Opus, who previous did the growth forecasting for the same

thresholds as Beca, came up with a higher amount of development and

a higher amount of traffic and we tried to get to the bottom of why that

was the case but doing a sensitivity test on that basis seemed, to me, to 30

be important. In fact, in my appendix C to my evidence, I have done

some modelling of that scenario to satisfy myself.

MR FOWLER: Now, this type of modelling involves timeframes, doesn‟t it?

35

MR WIGNALL: Yes.

MR FOWLER: And, in your view, what is the appropriate number, in terms

of the forecast period, that you should be applying to a project like this?

40

MR WIGNALL: Well, the economic evaluation, which tends to drive a lot of

things, is currently 30 years from the time of opening. So that would

take you up to a long time in the future, 2047. But I mean normally

you wouldn‟t have to model the full extent of that period, you would

want to model years that gave you some confidence that any 45

assumptions you made about that economic forecasting were valid. So

Page 355


a lot of it is tied to the years of the regional model. You have to deal

with the years that the regional model has got information and that, I

think, was primarily 2026 at the time of the creation of the current Beca

Kapiti model. So I think that is one of the fixes, that is one of the

reasons that has been focused on so much. 5

MR FOWLER: But can we take it from your answer that 30 years, in your

view, would have been an appropriate period here?

MR WIGNALL: I would have liked to see, say modelling out to, again they 10

tend to coincide with census years, and that has been disrupted

recently, but originally I think there was an intention to go to 2041,

which would seem appropriate to me.

MR FOWLER: You attended the multi-criteria assessment workshops, didn‟t 15

you?

MR WIGNALL: Most of them, yes.

MR FOWLER: Did you receive material before the workshop to review? 20

MR WIGNALL: In some cases, yes, in some cases, no.

MR FOWLER: It would have been usual to have expected to receive material

before each workshop, wouldn‟t it? 25

MR WIGNALL: In an ideal world, yes, unless it was a workshop on a well

known issue that everyone was briefed on.

MR FOWLER: That multi-criteria analysis, once completed, was not revisited, 30

was it?

MR WIGNALL: I think there were some additional multi-criteria analysis

workshops for some issues, you know, particularly difficult issues. So

I think there was some revisitation of the MCA. 35

MR FOWLER: But not a comprehensive one?

MR WIGNALL: I am struggling to recall at the moment but - - -

40

MR FOWLER: Well, if you can‟t recall then I am not going to ask you to if it

is something you don‟t know, Mr Wignall.

Page 356


[11.55 pm]

MR WIGNALL: I think there was one workshop that revisited and sort of

gathered together quite a number of the critical issues and went into the

reasons for and against the criteria that were established but I would 5

need to check my records to answer that, I am sorry.

MR FOWLER: I want to ask you a couple of questions about effect on

pedestrians and cyclists and the local network.

10

MR WIGNALL: Yes.

MR FOWLER: You were here this morning and you heard Mr Murray‟s

answers on the issues of pedestrians and cyclists, didn‟t you?

15

MR WIGNALL: I did.

MR FOWLER: Are you aware of any assessments of the proposal on its

effects on pedestrians?

20

MR WIGNALL: The only thing I am aware of is a statement that Mr Murray

made at the last conference about levels of service for pedestrians at

signalised intersections on Kapiti Road.

MR FOWLER: So you haven‟t seen any such assessments yourself, have 25

you?

MR WIGNALL: I have not seen any, no.

MR FOWLER: And if I ask you the same question in respect of cyclists, what 30

would your answer be?

MR WIGNALL: I have not seen any analysis of impact on cyclists.

MR FOWLER: Have you been involved in any calculation of benefits for 35

pedestrians?

MR WIGNALL: No.

MR FOWLER: And if I asked you the same question in respect of cyclists, 40

would you give the same answer?

MR WIGNALL: I would, yes.

MR FOWLER: You would expect effects on the wider district local road 45

network to be something that would have to be assessed, wouldn‟t you?

Page 357


MR WIGNALL: Yes. Yes, I would.

MR FOWLER: Do you consider that there has been an adequate assessment

in this instance? 5

MR WIGNALL: Well, there has been extensive SATURN modelling, the

district wide model, to look at the changes in flow and the impact on

that percentage change in traffic flow, that sort of thing. So I guess that

they have looked through from a certain point of view in terms of 10

traffic capacity. I think I mention in my evidence, in an appendix, that

the safety analysis is quite narrow. A lot of it is driven by the economic

evaluation manual and the requirements but, in terms of looking at the

overall impact on speeds and safety and that sort of thing, I have not

seen that undertaken, no. 15

MR FOWLER: In your experience you would have expected to see that done

surely for a project of this size?

MR WIGNALL: I wouldn‟t have expected to see it done, I would like to see it 20

done.

MR FOWLER: In terms of what you would regard as best practice you would

have liked to have seen it done, is that your position, Mr Wignall?

25

MR WIGNALL: Yes, that is correct.

MR FOWLER: Now, you gave evidence in the Transmission Gully Board of

Inquiry hearing, didn‟t you?

30

MR WIGNALL: I did.

MR FOWLER: And you addressed in that hearing, I understand, some issues

regarding the changes in safety of the old road, the piece of road that is

left behind? 35

MR WIGNALL: Yes.

MR FOWLER: Do you remember giving evidence about that?

40

MR WIGNALL: I do.

MR FOWLER: Now, under this proposal here, volumes of traffic are going to

be removed from the existing State Highway 1 onto the new

expressway, aren‟t they? 45

Page 358


MR WIGNALL: Yes.

MR FOWLER: But the old route and its configuration presumably remains,

doesn‟t it?

5

MR WIGNALL: Yes.

MR FOWLER: The same bends and so on are still there, aren‟t they?

MR WIGNALL: I expect they will be, yes. 10

MR FOWLER: I am deliberately going to ask this on an open basis,

Mr Wignall, do you have a view regarding the changes in traffic safety

effects that may or may not occur once the proposal is implemented

affecting the old road? 15

MR WIGNALL: I do, and just to be clear, I have expressed that to the, if you

like the project design team and I think, to be fair, they have responded

to that. I know it is not strictly part of this project, it is a separate

process to undertake, but I undertook modelling to look at the changes 20

in speeds on State Highway 1, raised my concerns about the potential

increase in severity of crashes and the need for appropriate measures to

be taken promptly, not years after implementation, but once the

expressway is open. And I think, to be fair, that has been responded to

pretty well. So I haven‟t referred to that in my evidence at all. 25

[12.00 pm]

MR FOWLER: Given your last answer, Mr Wignall, does that mean you have

some concerns about the continuing safety of the old road? 30

MR WIGNALL: I certainly would have if there wasn‟t a separate process that

had led to an agreement on measures to treat the existing state highway.

So that, you know, in that context I would have.

35

MR FOWLER: Is that because the safety of the old road does not necessarily

improve significantly with the removal of the volumes, in your view?

MR WIGNALL: There is a significant risk, that typically the frequency of

crashes reduces with volumes, that is true, but the severity of crashes 40

may also change and if that isn‟t taken into account the change in social

cost can be virtually minimal as it seems to have been on Albert (ph

1.53) B2. So that is a worry if fairly prompt action isn‟t taken on a

relieved road, yes.

45

Page 359


MR FOWLER: And without those actions, Mr Wignall, are you saying the

social impact improvement isn‟t achieved?

MR WIGNALL: I am not trying to be evasive here but there has been an

assessment done of the relative change in safety on State Highway 1. 5

Now, that may come to pass, that may be accurate. I think there is a

significant risk that those benefits won‟t be achieved, if I can put it like

that.

MR FOWLER: Thank you, sir, that is all I have. 10

CHAIRPERSON: Thank you. Mr Hassan?

MR HASSAN: Your Honour, Ms Gregory do this cross-examination.

15

<CROSS-EXAMINATION BY MS GREGORY [12.02 pm]

MS GREGORY: The first set of questions I have for you, Mr Wignall, relate

to the Te Moana roundabout versus signal issue and I am going to

focus these questions on the differences that have come out of the 20

witness conferencing. It would be helpful if you could have the joint

statements with you and do you have Mr Murray‟s rebuttal statement?

MR WIGNALL: Yes, I do.

25

MS GREGORY: And Mr Nancekivell‟s evidence-in-chief?

MR WIGNALL: I don‟t have those.

MS GREGORY: I can read out the paragraph. 30

MR WIGNALL: Okay, yes, please do.

MS GREGORY: So at paragraph 19 of the joint - - -

35

MR WIGNALL: Sorry, what was the date of it, was it the 14th

of November

statement?

MS GREGORY: It is 5th September, the evidence-in-chief of Mr Nancekivell.

40

MR WIGNALL: Okay, yes, sorry.

MS GREGORY: The evidence is actually behind you in the folders there.

MR WIGNALL: Okay, but if you would like to read it, yes. 45

Page 360


MS GREGORY: I can just refer to the paragraph. In the joint conferencing

statement, in relation to Te Moana intersection, you disagreed with

Mr Murray and Mr Hewett and said that the signals should be

confirmed now in this form of intersection rather than go through a

further design process. 5

MR WIGNALL: Yes.

MS GREGORY: If you could turn to Mr Murray‟s rebuttal statement at

paragraph 84. In this paragraph and the subparagraphs above he sets 10

out why there may be some advantages to signals in this location, there

could also be some disadvantages. Do you accept there could be some

disadvantages with signals at this location?

[12.05 pm] 15

MR WIGNALL: Yes, there could be some, yes.

MS GREGORY: Thank you. And I will just turn now to the reference in

Mr Nancekivell‟s evidence-in-chief, the reference is paragraph 77. 20

And in that paragraph Mr Nancekivell also discusses the Te Moana

Road intersection and there he talks about the differences required from

a design perspective between a roundabout and a signal and notes that,

with the signals, you may require up to six lanes compared with two for

the roundabouts and that there could be significant delays for 25

pedestrians seeking to cross. Do you accept that those are correct

issues identified?

MR WIGNALL: Yes, there could be some increased delays if you put signals

in, that is a possibility, yes. 30

MS GREGORY: Thank you. And in your own evidence, do you accept that

you haven‟t really addressed those types of disadvantages in coming to

your conclusion that signals should be provided?

35

MR WIGNALL: I haven‟t explicitly investigated that. I relied on my

experience of similar circumstances comparing roundabouts with

traffic signals and, indeed, the issue has not been addressed in the

applicant‟s evidence, you know, despite me asking for designs and

details of signals, which I believe have been designed, I have not 40

received them.

MS GREGORY: All right, and with that in mind then, would you accept that

there is some merit in going through a further design process for that

intersection to ensure a robust assessment of those advantages and 45

disadvantages?

Page 361


MR WIGNALL: No, I wouldn‟t, I think the case for signals is overwhelming.

I asked Mr Murray at the last conference if he had seen the evidence of

Brent Cherry, which I put as an appendix to my evidence. He is the

school travel planner who is responsible for looking at movement by 5

children in that area to and from school. And the case is absolutely

overwhelming in favour of signals so I don‟t think any marginal change

in delay is going to influence that decision.

MS GREGORY: Thank you. Just turn now to the next issue which relates to 10

the Western Link Road as a reference case or baseline in your

assessment of effects. Do you accept that you haven‟t used that

approach throughout our evidence but only in relation to operational

traffic and not construction traffic?

15

MR WIGNALL: I haven‟t picked that up, no.

MS GREGORY: Do you accept that the effects that would arise from

construction traffic of the Western Link Road would be significantly

greater than the expressway? 20

MR WIGNALL: I would need to - - -

MS GREGORY: In general without having undertaken any detailed analysis.

25

MR WIGNALL: Well, I don‟t necessarily, I mean the Western Link Road

only impacted once on the state highway at stages 1 and 3 that was

proposed to be implemented.

MS GREGORY: For example - - - 30

MR WIGNALL: There would be impacts that is for sure but I mean I wouldn‟t

necessarily expect them to be greater or less at the moment without

really thinking about it in some detail.

35

MS GREGORY: Well, for example with the local roads, the Western Link

Road included a number of at grade intersections and therefore there

would be much more of a higher level of interaction at the construction

level with those local roads?

40

MR WIGNALL: It is possible that is the case but in which case the

Construction Management Plan would have been very, very carefully

designed to include pedestrians, cyclists and public transport.

MS GREGORY: Have you read the planning conferencing statement? 45

Page 362


MR WIGNALL: Yes, I have.

MS GREGORY: And do you accept that the view of all the planners,

including Ms Thomson for the KCDC, is that they have not used the

Western Link Road as part of the permitted baseline? 5

MR WIGNALL: I do, obviously I understand that. I also note that they made

some statement about the Western Link Road suggesting that it was a

valid case to consider.

10

MS GREGORY: Do you accept there should be a consistent approach to the

assessment of effects across all disciplines within this project?

MR WIGNALL: Yes.

15

MS GREGORY: And, if we adopt your approach of using the Western Link

Road as a baseline for assessing effects, we would only be looking at

marginal increases on that corridor for other technical reports such as

noise or air quality?

20

[12.10 pm]

MR WIGNALL: Yes, I accept that that is the downside and, you know, I am

not giving a legal opinion on this. That is why I have concentrated

most of my evidence in responding to the case that has been put 25

forward, the do minimum case as Mr Murray calls it, yes.

MS GREGORY: And would you accept, on that basis, that the NZTA‟s

evidence, as a package, uses the same consistent baseline throughout its

evidence to assess all of the effects robustly? 30

MR WIGNALL: Yes, I accept that they – you need a consistent standard and

they have applied a consistent standard, that is certainly true, it is just

that in some of the locations I have looked at it is not, it is not an ideal

test but anyway, yes. 35

MS GREGORY: Thank you, Mr Wignall. The final area I would like to focus

on is construction traffic.

MR WIGNALL: Yes. 40

MS GREGORY: Have you got Mr Hewett‟s rebuttal statement with you?

MR WIGNALL: Yes, I have.

45

Page 363


MS GREGORY: Page 7 at paragraph 38, Mr Hewett talks about an

amendment to the condition that has been proposed by Ms Thomson in

response to your concerns and that is the addition of some further

wording to that condition so that, “Safe, adequate and convenient

facilities for local movements by all transport modes -, pedestrian, 5

cycle, vehicle - are maintained throughout the construction period”.

Mr Hewett agrees that that is an appropriate addition and my

understanding is you also agree that that is appropriate?

MR WIGNALL: Yes, I do, yes. 10

MS GREGORY: And would you accept that construction management plans

are an appropriate way to manage effects of construction traffic?

MR WIGNALL: Yes, I would. 15

MS GREGORY: And would you agree that there can be a fine line between

providing for some certainty in the conditions and allowing some

flexibility within the management plan to adapt to the environment at

the time? 20

MR WIGNALL: Yes, I certainly do.

MS GREGORY: If I could just get you to turn to Mr Hewett‟s evidence-in-

chief and, in particular, his annexure C. In this annexure it sets out the 25

relevant conditions that apply to the Construction Management Plan.

MR WIGNALL: Yes, I have got it.

MS GREGORY: If I could just go through some of the details there with you. 30

So DC17 relates to the, as I understand it, the Umbrella Construction

Management Plan.

MR WIGNALL: Yes.

35

MS GREGORY: So that will be updated and finalised and submitted to the

Council.

MR WIGNALL: Yes.

40

MS GREGORY: Then we turn to the Site Specific Traffic Management Plans

and would you accept that condition DC18 sets out, with some

certainty, the matters that must be covered in those Site Specific Traffic

Management Plans?

45

Page 364


MR WIGNALL: Well, it covers the sort of headings that you want and expect,

yes.

MS GREGORY: And do you accept that in the first sentence there is says that

those plans would be prepared in consultation with the Council? 5

MR WIGNALL: I do.

MS GREGORY: And, if we turn over to DC19, it also says those plans will

be undertaken in consultation with a number of a key stakeholders 10

there including emergency services, schools, public health services and

that not only will they be involved but the Site Specific Traffic

Management Plan also has to indicate how their responses have been

taken into account?

[12.15 pm] 15

MR WIGNALL: Yes. Yes, I think all of that is fine words.

MS GREGORY: And then do you accept at DC21, that those plans will be

reviewed by a suitably qualified independent person? 20

MR WIGNALL: Well, yes, that is what he says.

MS GREGORY: And at DC22 that an independent party will carry out random

auditing? 25

MR WIGNALL: Yes.

MS GREGORY: Would you agree that those conditions are appropriate?

30

MR WIGNALL: Yes, I don‟t have an issue with a lot of the wording of either

the Construction Traffic Management Plan or the condition, they are all

fine. It is getting a degree of confidence that they are going to be

implemented, to be honest.

35

MS GREGORY: Thank you, Mr Wignall, no more questions.

CHAIRPERSON: Re-examination?

<RE-EXAMINATION BY MR CONWAY [12.16 pm] 40

MR CONWAY: Sir, just one point. Mr Wignall, my friend asked you a

question about DC21 and she referred to this “independent person”. I

am just interested to know if you have any comments on what you

understand to be meant by “independent person”? 45

Page 365


MR WIGNALL: It would be, in my view, a suitably qualified person who is

either a safety auditor or whatever, whatever the issue is. Somebody

not associated with the project team, definitely not. Preferably would

be in a different organisation.

5

MR CONWAY: Thank you, sir.

MR APELDOORN: I have just a couple. If we could just have a look at the

Te Moana intersection briefly, could you just describe for us where the

demands are for pedestrian movement and what the flows are for 10

pedestrian movements through the location of the proposed

interchange?

MR WIGNALL: Primarily it is students going from Waikanae Beach to the

schools in Waikanae, I mean that is one of the critical demands but 15

obviously there is more general pedestrian movement than that and

when we are talking about pedestrians we are not necessarily meaning

just, you know, it might be kids who use scooters, for example, or other

uses. Active, different forms of active travel if you like but, yes I would

say that was one of the critical considerations. And in the appendix to 20

my evidence, there is quite a detailed statement by Brent Cherry about

his experience of exactly that issue in Waikanae, his development of

school travel plans, what the impact is likely to be on those school

travel plans and I thought that was quite powerful evidence.

25

MR APELDOORN: Are there some pedestrian crossing provisions currently

in place that cater for those movements?

MR WIGNALL: Well, there don‟t need to be any because there is no junction

there at the moment but, you know, at the moment there is movement 30

on both sides of the road. I know there is only like a made up footpath

on one side but that is often the case. It is the case of Mazengarb Road

and other places where use is made of shoulders on both sides of the

road and they are important local facilities, yes.

35

MR APELDOORN: So does your primary concern then relate to the

pedestrian movements that cross the ramps, the new ramps that will

create those intersections rather than pedestrian demands that might

involve crossing Te Moana Road itself?

40

MR WIGNALL: Principally, yes, but there may be – I mean obviously there

is a couple of unknown factors, I mean one is what is the use going to

be of the three metre walking and cycling path that is put beside the

expressway which crosses there? What is the use going to be of the

expressway ramps by, say, cyclists who want to get between Te Moana 45

Page 366


and over the river? You know, assuming cycling is permitted of course

but the current proposal is that it is.

[12.20 pm]

5

So there are a number of crossing demands that could be related to

movement along the expressway corridor that are quite important as

well, so I can see the need to be a design. I am not arguing against

having a design workshop, I think that is a great idea and I think that is

needed on Kapiti Road as well, but it should be a design workshop 10

around what facilities should be provided at the traffic signals, that is in

my view.

MR APELDOORN: Have you had any previous involvement with the analysis

and assessment done in relation to the Western Link Road option? 15

MR WIGNALL: I had no involvement in the earlier work, if you like,

anything prior to 2010 effectively. Post 2010 I have done some

independent testing of the Western Link Road and I have obtained all

the model files from Opus and so on and so forth, so I became aware of 20

the background after the event.

MR APELDOORN: Can you tell us was there a do minimum option used as a

basis for assessment or comparison in the work that was done in

relation to the Western Link Road? 25

MR WIGNALL: There would have been, yes, and looking at the model

networks there is a do minimum network and then the different

Western Link Road options. Yes, so there was a do minimum but,

again, that was for economic evaluation purposes as far as I am aware 30

and, yes, I am not sure of the - yes.

CHAIRPERSON: Anything arising from that, Mr Conway? Thank you, may

stand down, Mr Wignall, and you may be released.

35

MR WIGNALL: Thank you.

<THE WITNESS WITHDREW [12.22 pm]

CHAIRPERSON: Now, we come back to Mr Kelly, Ms White. 40

<TIMOTHY MARTIN KELLY, resworn [12.23 pm]

<EXAMINATION BY MS WHITE [12.23 pm]

45

MS WHITE: Can you confirm that your full name is Timothy Martin Kelly?

Page 367


MR KELLY: I do.

MS WHITE: And you are a transportation planner?

5


MS WHITE: And you have prepared a brief of evidence on behalf of Greater

Wellington Regional Council dated 5 October?

10


MS WHITE: And you confirm that the statement is true and correct to the

best of your knowledge?

15

MR KELLY: I do.

MS WHITE: And you participated in witness conferencing on 5 November and

you are a signatory to the joint witness statement of traffic experts

dated 5 November? 20


MS WHITE: Following witness conferencing can you please update the

Board on your position in regards to the expressway proposal? 25

MR KELLY: Okay, just very briefly, when we examined the application we

felt there was a bit of an information gap, if you like, in terms of an

assessment against the compliance with the Regional Land Transport

Strategy and that really was the primary purpose of my evidence to 30

cover that off. My evidence also raised a number of what were really

very minor issues relating to provision for cycling and lighting on the

footpath and those issues have been satisfactorily resolved through the

conferencing process.

35

MS WHITE: Thank you, please remain seated for any questioning.

MR KELLY: Thank you.

MR FOWLER: Sir, I have no further questions of this witness in the light of 40

the evidence that has already been given this morning.


MR HASSAN: Yes, the position remains we have no questions for this 45

witness and his role, sir.

Page 368


CHAIRPERSON: Thank you, Mr Kelly, you may stand down and you are

free to go.

MR KELLY: Thank you. 5


CHAIRPERSON: Now, the next witness is Dr Hastie but there has been a late

application by APSOC (ph 5.03) for cross-examination by Ms Genter, 10

who I take it is not going to be available.

[12.25 pm]

MS BEGOVICH: She will be present at 1. 15

CHAIRPERSON: At 1?

MS BEGOVICH: Yes, or quarter past 1 actually.

20

CHAIRPERSON: Well, why don‟t we take the luncheon adjournment now

and we will recommence at 1.30. You are confident around that

timing?

MS BEGOVICH: Confident, yes. 25

CHAIRPERSON: Okay, that is great, thank you. We will adjourn until 1.30.

ADJOURNED [12.25 pm]

30

RESUMED [1.30 pm]

<DR WAYNE JOHN HASTIE, sworn [1.30 pm]

CHAIRPERSON: Please be seated. Yes, Ms White? 35

<EXAMINATION BY MS WHITE [1.30 pm]

MS WHITE: Your full name is Wayne John Hastie?

40

DR HASTIE: That‟s correct.

MS WHITE: And you‟re the general manager of Public Transport at Greater

Wellington Regional Council?

45

DR HASTIE: Yes.

Page 369


MS WHITE: You‟ve prepared a brief of evidence dated 5 October?

DR HASTIE: That‟s correct.

5

MS WHITE: Can you please confirm that this statement is true and correct to

the best of your knowledge?

DR HASTIE: I can.

10

MS WHITE: You participated in witness conferencing on 5 November and are

a signatory to the joint witness statement of traffic experts dated 5

November?

DR HASTIE: I am. 15

MS WHITE: And following the witness conferencing can you please update

the Board on your position in relation to the expressway.

DR HASTIE: If the conditions, as proposed, are granted or are imposed by the 20

Board, my issues are all resolved.

MS WHITE: Thank you, please remain seated for any questioning.

CHAIRPERSON: Mr Fowler. 25

MR FOWLER: Thank you, sir.

<CROSS-EXAMINATION BY MR FOWLER [1.31 pm]

30

MR FOWLER: Dr Hastie, just a couple of questions about the passenger trips

issues with regard to public transport. You‟ve read the evidence of Mr

Murray, in terms of that topic?

DR HASTIE: I have. 35

MR FOWLER: And where the assessment is given that the mode share of

public transport without the project proceeding through to 2026 would

be of the order of six percent, you would agree with that?

40

DR HASTIE: Well it‟s always hard to predict what it is going to be, it‟s been

quite flat in recent times but, you know, one or two percent a year, yes.

MR FOWLER: You wouldn‟t cabell (ph 2.12) with that assessment?

45

DR HASTIE: No.

Page 370


MR FOWLER: And he says, with the project that drops to five percent. Again,

would you cabell (ph 2.22) with that?

DR HASTIE: No. 5

MR FOWLER: Just in terms of taking the microscope a little closer, there

would be big reductions wouldn‟t there in terms of the Waikanae-

Wellington leg? Is that what you would expect?

10

DR HASTIE: I would say there would be some – expect some reduction. I

think you‟d have to define “big”.

MR FOWLER: Yeah. There‟s been a reference, I think, in his evidence to a

drop from 25 percent to 19 percent. Does that sound right to you? 15

DR HASTIE: That‟s what the modelling is – I understand that‟s what the

modelling shows.

MR FOWLER: And similarly, between Waikanae and Paraparaumu, from 18 20

percent to nine percent?

DR HASTIE: That‟s what the evidence says.

MR FOWLER: With reductions of that order would you not expect that there 25

would be self-evidently some reductions in revenue, unless the fares

were significantly increased?

DR HASTIE: Yes.

30

MR FOWLER: And it would be appropriate to expect, would it not, some

impact on the fare box recovery policy laid out by NZTA for greater

Wellington?

DR HASTIE: Maybe, maybe not. We would certainly try and match the 35

capacity with the demand, so that if the demand reduces we might run

shorter trains for, etcetera, which would therefore reduce cost.

MR FOWLER: And the quality of the service?

40

DR HASTIE: Well we would expect the quality of the service to still remain

in terms of the vehicles used, frequency at this point – we would

obviously always review situation to make sure, as we do all the time,

that capacity meets the demand that‟s there.

45

Page 371


MR FOWLER: And you would accept though that an issue potentially arises

in respect of that reduction on those sort of matters that you‟ve been

describing?

DR HASTIE: I would accept that there will be some impact, whether it‟s an 5

issue or not we will manage – we have lots of things that impact on

patronage. If the Capital to Connections stops, for example, there will

be a big change in patronage because half of the people who catch that

service do so south of Waikanae. So we‟d expect a migration onto our

electric service. 10

MR FOWLER: Now you would have also read Mr Murray‟s evidence, this is

paragraph 119, if the Board pleases, that with the proposal there would

be an opportunity for direct local bus services rather than transfers

between bus and rail to occur. Do you recall that part of his evidence? 15

[1.35 pm]

DR HASTIE: I recall the part that talked about from Waikanae to

Paraparaumu, not from the Coast to Wellington. 20

MR FOWLER: But you recognise that passage of his evidence where he refers

to the possibility of direct bus routes?

DR HASTIE: Yes. 25

MR FOWLER: It‟s the case, isn‟t it, that Greater Wellington doesn‟t operate a

competing bus versus rail service along the same route?

DR HASTIE: In general we try not to subsidy two services that would 30

compete with each other.

MR FOWLER: That would make sense wouldn‟t it, in terms of you discussing

it?

35

DR HASTIE: It would but it does happen on the network and there‟s also

services that are operated commercially by bus operators that do

directly compete with our rail network.

MR FOWLER: Generally speaking though it would be fair to say that it‟s a 40

proposition you‟d avoid?

DR HASTIE: Yes, it‟s fair.

MR FOWLER: In February 2009, Greater Wellington stopped direct bus 45

services between local centres up here, didn‟t it?

Page 372


DR HASTIE: It did, but there‟s been a subsequent review and there‟s been

some further changes to those services.

MR FOWLER: Mr Murray, I think in the previous paragraph of his evidence, 5

that‟s 118, referred to the possibility of improving timetable reliability

of the buses. Do you see that piece?

DR HASTIE: Yes.

10

MR FOWLER: You don‟t have any data at Greater Wellington, do you, on

how many Waikanae to Paraparaumu buses arrive late vis à vis their

timetable arrivals, do you?

DR HASTIE: I couldn‟t tell you what it is, I‟m sure we do have information 15

as we‟ve recently rolled out real time information, so - - -

MR FOWLER: Have you been asked to provide that sort of data for NZTA in

this proposal?

20

DR HASTIE: No, I haven‟t.

MR FOWLER: Yes, thank you, sir, I have no further questions.

CHAIRPERSON: Ms Genter? 25

<CROSS-EXAMINATION BY MS GENTER [1.37 pm]

MS GENTER: Thank you, sir. Thank you, Dr Hastie. I just have a few

questions, since you‟ve just answered some of my questions about the 30

impact of the decline in public transport patronage in the area. Is it fair

to say that a reduction in rail patronage will either have consequences

for cost effectiveness or potentially the frequency of the service?

DR HASTIE: I think I just can say what I said before, which is we would look 35

to match the demand. The first call would be are we running too long a

trains, if there was any reduction, and we‟re not talking massive

reduction here.

MS GENTER: Is it really the length of the trains that as sort of the high cost 40

element in providing a service, or is it the labour? I mean are you more

likely to reduce the number of trains if there‟s a falloff in patronage?

DR HASTIE: We would certainly review that, we would do that as we have

been doing recently anyway. 45

Page 373


MS GENTER: Right.

DR HASTIE: Our experience a few years ago in 2008 was with high fuel

prices, we had a huge increase in patronage on our Kapiti line, and we

find that the rail journeys – the journeys that people make longest trips 5

on and they are more susceptible to fuel price changes, hence there was

a massive up swing. So there‟s a lot of external factors that go into the

demand and hence our requirement to put services on.

MS GENTER: Following on from that point, if there is an increase in the fuel 10

price, and an increase demand over and above what‟s been anticipated

for the rail service, would it also follow that there be reduced demand

for the state highway network, and State Highway 1, in particular the

proposed project?

15

DR HASTIE: I guess there‟s the total number of journey and if the mode shift

swings in favour one or the other, there‟ll be a consequence impact on

the other mode.

MS GENTER: So if there was a higher than anticipated demand for the rail 20

network for external factors, such as fuel prices, then that would have

an impact on the forecast demand for the project, as it‟s been

modelled?

DR HASTIE: I‟m not an expert in that area, but that would be an assumption 25

that you could probably make.

MS GENTER: It‟s my understanding, and perhaps this is beyond your

knowledge, that in the Wellington Strategic Transport Model, the most

recent build in 2011 has been revised to accommodate lower than 30

forecast predictions in population growth in Kapiti, and higher than

expected growth in Wellington Central?

DR HASTIE: It‟s not to my knowledge, but I would expect that what‟s been

done is matching the model to the current forecast, which may or may 35

not be different from previous forecasts but we do get up to date

forecasts from the experts in those areas.

[1.40pm]

40

MS GENTER: Okay, and is it fair to say that population is a significant factor

in modelling demand for transport as it‟s been undertaken to support

the case for the project that‟s been proposed?

DR HASTIE: I think it‟s population and where people live. 45

Page 374


MS GENTER: Yeah.

DR HASTIE: And where they work, and where they wish to travel to.

MS GENTER: Are you aware that the transport modelling that was undertaken 5

by Mr Murray for this project, in the due minimum scenario and the

project scenario, included every other element of the proposed RoNS

works, other than – I guess in the due minimum scenario it included

every section of the proposed highway, except the expressway, and in

the project scenario it includes the expressway? 10

DR HASTIE: Look, I‟m not that familiar with that level of detail of the

modelling work.

MS GENTER: Okay. Do you have any view on the consequence of including 15

all the proposed RoNS in the due minimum scenario for the evidence,

or the demand? You have no views on whether or not, - - -

DR HASTIE: I don‟t have a view on that.

20

MS GENTER: - - - including that the modelling would increase the forecast

demand between Wellington and Kapiti?

DR HASTIE: I don‟t have a view on that.

25

MS GENTER: You don‟t have a view on it. And this, you don‟t have – are

you aware of the consequence in Central Wellington of the modelled

project for traffic volumes in Central Wellington?

DR HASTIE: No, that‟s not something that I‟ve looked at. 30

MS GENTER: Okay. To your knowledge would it have a negative or a

positive impact on Central Wellington to have increased traffic

volumes in the central city?

35

DR HASTIE: I don‟t know that I‟m in a place to answer that question. That

depends on impact in what regard.

MS GENTER: If there‟s increased vehicle trips say into Central Wellington,

would that have an implication for the availability and price of parking 40

in Central Wellington, for example?

DR HASTIE: Well that‟s not within my area of expertise to answer that.

MS GENTER: Not within your area. I have no further questions, thank you. 45

Page 375


CHAIRPERSON: Thank you. Any re-examination, Ms White?

MS WHITE: No, thank you.

CHAIRPERSON: Thank you, Dr Hastie you may stand down and you may be 5

released.

DR HASTIE: Thank you.

<THE WITNESS WITHDREW [1.42 pm] 10

CHAIRPERSON: Ms Genter we now come to your evidence, so if you go in

the witness box we‟ll have you sworn or affirmed and I‟ll just take you

through the formal bit to start with and you may then speak to your

evidence, and then we‟ll go to the cross-examination. Okay? 15

MS GENTER: Thank you.

<JULIE ANN GENTER, affirmed [1.43 pm]

20

CHAIRPERSON: Please be seated. Ms Genter, you have filed a brief of

evidence which I think is dated, but do you confirm that subject to the

corrections you have made that your evidence is true and correct to the

best of your knowledge and ability?

25

MS GENTER: I do.

CHAIRPERSON: And there are various reference annexure to that?

MS GENTER: Yes. 30

CHAIRPERSON: And as I understood you the other day you wish to make

those papers available by way of an Exhibit to the Board?

MS GENTER: I do. 35

CHAIRPERSON: So that will be – what Exhibit number are we up to?

MS DUFFY: They‟ve been numbered, sir, 2, 3 and 4.

40

CHAIRPERSON: Thank you. So that‟s not all of the references, they‟re the

specific papers you wish us to have access to?

MS GENTER: Yes.

45

EXHIBIT 2, 3, 4 – PAPERS

Page 376


CHAIRPERSON: Thank you. Now is there anything you wish to say

speaking to your evidence before we go to cross-examination?

MS GENTER: Yes. I believe I have 15 minutes to speak? 5

CHAIRPERSON: Yes.

MS GENTER: Thank you very much. Thank you for hearing my evidence. As

you will see from my written statement, I do have a professional 10

background in transport planning. I have some experience and

knowledge of traffic modelling, I‟ve worked as a traffic modeller, in

addition to working as a policy analyst. Now my position on the project

is based on my professional experience and knowledge, and that is the

only reason for my position, it has nothing to do with a political or 15

ideological position.

[1.45 pm]

I think that the Board is in somewhat of a difficult position because it 20

turns out that in the field of transport planning there‟s been a great deal

of evidence coming out in the last 10 years that really questions the

traditional approach that traffic engineers took to planning for, and

predicting demand for transportation infrastructure. And it‟s this new

information that leads us to the conclusion that this project is not going 25

to have the positive benefits that are intended. That many of the project

objectives listed by the applicant will not be achieved by the project,

and that there will be harmful negative impacts that have not been

quantified or assessed by the applicant at this point.

30

And it‟s my submission to the Board that it isn‟t good enough for the

applicant to say that they‟re not aware of any methodology for

assessing this. Actually before we make a decision, before we can

make a decision on what the total environmental, social and economic

impacts of the project are going to be, we need to have a better 35

assessment of what those impacts are. And it is possible, I believe to

make that assessment, but it would require doing things in a different

way than what the applicant has typically done.

So specifically I‟ll just refer to Mr Hassan‟s opening statement. “At the 40

core of this enquiry is how best to solve an existing problem impacting

people and communities, in terms of their wellbeing, health and

safety”. And later on he says, “to solve this problem effectively

requires an expressway”, and I don‟t believe that the evidence

submitted by the applicant establishes that an expressway is either 45

Page 377


required, or that it would best address the problem that is faced by

people in communities.

So to just expand upon the specifics that I layout in my statements, I‟d

say that in the traffic modelling no other options are considered, except 5

a four lane highway north of Wellington. And this has a consequence

of making the business case look slightly better. It‟s still not very good,

the conventionally assessed transport benefits are still less than the

cost, but if we were to do a realistic scenario where we modelled true

alternatives to all of the RoNS sections, then I think that you‟d get a 10

better sense of what the total benefits are, and whether there are

alternatives to an expressway that could meet the safety requirements

and the transport requirements of the area.

Specifically I‟d say that with the methodology choosing to do a due 15

minimum scenario, to model a due minimum scenario, including things

like the RoNS projects that are closer to Wellington Central, and to

exclude something like the western link road, I think really puts the

Board in a position where they‟re unable to test whether or not there is

a better alternative to the expressway. And in the rebuttal evidence I 20

believe Mr Murray – sorry I haven‟t noted the paragraph, referred to

the fact that this criticism of the western link route option hadn‟t been

modelled. As well there‟s funding uncertainty and it‟s not clear that the

project would go ahead.

25

But I‟d say that that holds true for the other RoNS as well, many of

them haven‟t been contented. So if we‟re going to pick a scenario to

model I just don‟t think that there‟s the case for modelling the entire

RoNZ and not modelling the western link road.

30

Now I raised a number of quite detailed criticisms about the

methodology and particularly time travel savings. My purpose here

wasn‟t to suggest that – it wasn‟t to suggest that time travel savings

can‟t be used as a proxy for evaluating the relative merit of a project,

but rather it was to suggest that there actually is no evidence for this 35

methodology. There never was any evidence.

The expert witness will say that this is the only methodology they‟re

aware of, and it‟s the one that they‟ve used for several decades, and

that‟s true, but you know, transportation professionals round the world 40

have admitted that this methodology was invented in the „60s and it‟s

unclear that it‟s ever been established that this method of forecasting a

future scenario with and without a project, and subtracting the

difference in travel time, actually accurately captures what happened as

a consequence of those projects. And that‟s a really important point. 45

Page 378


[1.50 pm]

There simply isn‟t external evidence and one of the documents that I

have provided to the Board is a summary of some of the post

implementation reviews that have been undertaken by the NZTA. It‟s 5

not a comprehensive list, I‟m trying to obtain that from the NZTA, but

I‟ve had to make that request on an Official Information Act request,

and so it‟s taken some time. But there‟s a summary of projects

undertaken in Auckland and if you refer to the Greenlane one – sorry,

I‟m not sure which piece of evidence it was, which number – there‟s – 10

it‟s one of the documents that I brought on Wednesday and tabled.

You‟ll see that there‟s some observations by auditors that in almost

every case the forecast benefits were higher than the actual benefits of

major state highway projects in and around Auckland, and in particular 15

in the Greenlane, they say time travel savings have not been – do not

appear to have been achieved. So I think that there‟s – at this point in

time, in 2012, there is a real need before we commit, or before we grant

consent to a project that‟s going to have long term impact on the

community, on the transport network, for the entire region, I think it‟s 20

an appropriate time to say, actually maybe we need to go back and

revisit our assumptions around this an see if it‟s going to have the

impacts that we intend it to, and whether we‟ve adequately

incorporated the full costs.

25

Because the time travel savings – I note that in the economics evidence,

and to a certain extent, yeah I believe it‟s in Mike Copeland‟s

economic evidence, he refers to the fact that there will be impacts, both

positive and negative on property, as a consequence of this project, and

that those consequences are very difficult to model, but because there 30

will be some positive and some negative that we can sort of consider it

as a wash.

But in fact the fact that time travel savings aren‟t – don‟t necessarily

result in actual time travel savings over time, they‟re probably 35

capitalised in property values. So by modelling the benefits of the time

travel savings you‟re getting some sense of what the positive impact is

for properties that are further away from urban areas, and the additional

access that‟s granted by the project results in some uplift in property

values, rather than time travel savings. 40

Page 379


But the negative impacts have not been considered or quantified, and I

think that – I list a number of specific choices in my evidence about the

research around the impact of transport infrastructure on property

values, particularly in paragraphs 33, 34, 35, and I‟m sure the Board

could even just think about their own experience, there simply are no 5

highly desired properties within 500 metres of an expressway. There‟s

direct negative impacts from noise, from the other associated negative

impacts of traffic, which lead to – and I think, and particularly in the

case of the Kapiti Expressway where a number of affected residents

who will now find themselves within 200 or 500 metres of the 10

expressway, didn‟t know that the project was going to happen, it wasn‟t

planned for in the previous 10 years.

And I think that they will be suffering negative impacts that cannot be

mitigated through sound barriers alone, cannot be mitigated and will 15

not be mitigated, or at least they won‟t be bought out by NZTA because

only properties that need to be taken directly will be compensated for.

So I think these complex interactions between transport and land values

are extremely important to get a full picture of what the actual impacts

of the project will be. 20

Further, there will be negative impacts on central Wellington, through

increased traffic – cars coming into central Wellington, so that‟s

another one of the complex inter-relationships. If you make it easier to

drive from further away from central Wellington, then more people will 25

drive into central Wellington, there will be worse traffic, it will take

away from the property values of the land in central Wellington, even

as it‟s adding perhaps some value to places that are further afield.

[1.55 pm] 30

So I suppose in summary I would say that the applicant simply hasn‟t

demonstrated in the transport, traffic and economics evidence that

there is a problem that can only be met by an expressway, and further,

they certainly haven‟t given a full picture of what the negative impacts 35

will be on the community, but also on the wider transportation network.

One of the objectives listed is resilience, I think that‟s an interesting

objective. I think it‟s important to get a clear definition of what they

mean by resilience because the evidence seems to suggest that 40

investment in highways around the world, in North America and New

Zealand, and in Australia, has led to a transport system that‟s highly

reliant on fuel and vehicles. That‟s generally the cost of that are not

taken into account in the wider benefit cost analysis, has an impact on

New Zealand‟s economy and it‟s resilience to high fuel prices, it‟s 45

Page 380


resilience to increased carbon costs and the ability of communities to

get around in the 21st Century.


5

<CROSS-EXAMINATION BY MR JOHN HASSAN [1.57 pm]

MR HASSAN: Thank you, sir. Good afternoon, Ms Genter, I don‟t think I‟ll

be very long in questioning. So just in terms of your observations a

moment ago in terms of your qualifications briefly, you said that you 10

had worked as a modeller. If I take you to the first page of your

evidence, do you refer to that in those paragraphs?

MS GENTER: In paragraph 4, I say, “during my time as transportation

consultant for M R Cagney I undertook work in New Zealand and 15

overseas, including traffic impact assessment, traffic modelling,

including PTV (INDISTINCT 2.05), that‟s micro-simulation

modelling. I also used (INDISTINCT 2.10), that‟s just an analysis of

intersections, public transport network design, strategic parking policy,

and a number of research reports for the New Zealand Transport 20

Agency.

MR HASSAN: Thank you. Now you mentioned, in terms of looking at

alternatives that one of the true alternatives that you see to the project is

the western link road? That‟s correct isn‟t it, that‟s what you said? 25

MS GENTER: It‟s an alternative that hasn‟t been modelled in this assessment.

MR HASSAN: And I understand from looking at your evidence that you see

public transport as also relevant to that? 30

MS GENTER: Yes.

MR HASSAN: And in terms of the problems which you referred to in your

oral statement that Mr Murray addressed, where he said, “the 35

expressway was effectively the only way to solve those problems”, one

of those being congestion, you‟d accept that congestion‟s an issue for

the community?

MS GENTER: It‟s my understanding that congestion isn‟t an issue on the state 40

highway network, but if it were an expressway wouldn‟t solve that

problem.

MR HASSAN: So your perception is that there isn‟t a congestion problem?

45

Page 381


MS GENTER: No, it‟s my understanding based on one of the traffic modelling

reports that I‟ve read, that was read by Mr Murray as well, that it‟s

relatively uncongested part of the network and that‟s part of the reason

why the time travel savings aren‟t – don‟t outweigh the cost of the

project. 5

MR HASSAN: Okay, so with that qualification though, you‟d agree would

you that assuming there is a problem which has been identified you

may not agree with the scale of it, you see public transport as a way of

addressing that issue of congestion? 10

MS GENTER: No, but it is a way of moving more people at peak hour, it‟s a

more cost effective way of moving more people at peak hour.

MR HASSAN: In other words, moving people on the public transport system 15

and not the roads, and therefore relieving congestion?

MS GENTER: Well it‟s a way to move more people at peak hour, and if your

goal is – and generally I think the goal, it‟s accepted of transportation

improvements, is to move people and goods, but the traditional traffic 20

engineering approach including the one taken in the assessment focuses

uniquely on vehicles, vehicles take up much more land than people do,

they use a lot more resources than people do, so if you have – if you

define your problem as how do we move more vehicles through a given

corridor, then you might say you need an expressway. But if you think 25

actually the goal is to move more people at peak hour, then I think

public transport is clearly going to do that.

MR HASSAN: Okay, and if we assume that moving those people on the road

network causes the problem of congestion, leaving aside your opinion 30

on whether or not there is congestion, you rely on some material for

that opinion don‟t you? You referred to an article – I think it was in

annexure, is it Exhibit 2 - - -

MS GENTER: The fundamental law of road congestion. 35

MR HASSAN: Sorry, you didn‟t hear my question.

MS GENTER: Sorry.

40

[2.00pm]

MR HASSAN: Now, just let the question get put. Now, I think it‟s Exhibit 2,

have you got the Duranton and Turner article with you?

45

Page 382


MS GENTER: I‟m familiar with that article.

MR HASSAN: You remember it off by heart because I‟m going to ask you

something and you‟ll be able to confirm? If you don‟t have a copy of it,

that‟s fine, you may not need it. You‟d agree, wouldn‟t you, that that 5

article itself concludes that increased provision of roads or public

transit is unlikely to relieve congestion? So you distance yourself from

that part of that opinion?

MS GENTER: I don‟t distance myself, I would say that you can move more 10

people on public transport at peak hour. The only way to reduce

congestion would be to have direct time based pricing. But if the goal is

to move more people then clearly public transport is going to move

more people. If you are trying to solve the problem of congestion by

providing increased capacity for vehicles, you‟re not going to solve the 15

problem of reducing congestion, you are going to affect land use and

traffic in such a way that people become more reliant on cars, there‟s

higher vehicle kilometres travelled per capita in the area, and there are

significant costs incurred by vehicle kilometres being travelled.

20

MR HASSAN: Thank you, well finally, thank you. Just in terms of your

capacity as a witness, I think fairly I need to ask you this because you

made this statement yesterday when you weren‟t under oath, and I just

want to check that it is your opinion under oath. The transcript records

your response to his Honour yesterday in regard to your role yesterday, 25

you said this, if I could quote please, about the difference between the

advocate and expert witness, “I think that it is probably for the

purposes of this hearing I would be considered an advocate and that my

evidence is presented as an advocate‟s witness. It is just my views that

I‟m putting forward and my evidence are based on my professional 30

expertise in this area”.

Is that a fair statement that you would confirm as a witness?

MS GENTER: I‟m not an expert on the procedures of the Court, so I was 35

somewhat confused as to the distinction between being an advocate and

an expert witness, and all I can say is I believe that it is at the discretion

of the Court whether or not I‟m considered an expert witness or not.

MS HASSAN: Thank you, I don‟t have any further questions. 40

CHAIRPERSON: Ms Genter, you have now the right of re-examination and

it‟s a little hard to re-examine oneself, but the purpose of that is to

allow you to respond to anything that arose out of the cross-

examination. It‟s not a revisiting of everything else earlier, just the 45

Page 383


matters that came out of cross-examination. So I‟ll give you that

opportunity now.

MS GENTER: Is it appropriate to pose a question to the Board?

5

CHAIRPERSON: Well you can certainly pose it, whether it‟s something we

can answer, we‟ll just have to wait and see.

MS GENTER: I‟m wondering if the Board found my explanation, in response

to Mr Hassan‟s question about congestion, and whether or not public 10

transport is a useful means of addressing congestion, if they found that

clear enough or if I should try to explain it a little more clearly?

CHAIRPERSON: Well, for myself I understood it, I‟m sure, because when

you‟re finished now I‟m going to give the Board members the 15

opportunity to ask questions. I‟m sure if it wasn‟t clear they will ask

you.

MS GENTER: Okay.

20

CHAIRPERSON: Is there anything else you wanted to - - -

MS GENTER: No.

MRS PAINE: No, I‟m fine thank you. 25

COMMISSIONER BUNTING: I‟m fine too, thank you.

MR APELDOORN: Thank you.

30

CHAIRPERSON: Thank you, you may stand down. Thank you again for

making time available in your schedule.


35

CHAIRPERSON: Well I think we‟ve now reached the end of the witnesses

for today and we‟re making good progress due to the cooperation of

everybody. We will adjourn until 9.30 am on Monday morning, sorry,

Tuesday morning. I have got meetings all day in Christchurch, I will be

in trouble if I don‟t arrive at those. I take it the updated schedule has 40

been provided? All right thank you. There‟s an updated schedule of

witnesses and arrangements relating to the 26th of November when we

will hear evidence on the Marae, and other matters such as that. So

thank you all and we‟ll have a good weekend and we will reconvene

Tuesday morning at 9.30. 45

Page 384


MR HASSAN: Sir, may I just have one – a couple of very brief things. Mr

Gibson and Mr Bowman, I understand are able to go onto the record

without cross-examination from them too. I understand the Board –

does the Board have any questions of those two witnesses, sir, from the

EPA - possibly not? 5

CHAIRPERSON: Sorry, the two witnesses were?

MR HASSAN: I beg your pardon, sir, Mr Keith Gibson, the lighting expert,

Mr Ian Bowman, the heritage expert – no party wishing to cross-10

examine either witness.

CHAIRPERSON: I think I‟ve already dealt with a memorandum at lunchtime

following that and excusing attendance.

15

MR HASSAN: Yes, sir, I missed that, sir. There is a matter concerning Mr

Fuller that I will write to the Board about on Monday, and I‟ve spoken

to Counsel about that, and thirdly, sir - - -

CHAIRPERSON: We also dealt with the question relating to St Heliers, these 20

people and their witnesses.

MR HASSAN: Thank you, sir.

CHAIRPERSON: So they were dealt with – the Board may have reached 25

agreement and that was signed off at lunchtime.

MR HASSAN: And I just wanted to record, sir, that the – in terms of the

Board‟s enquiries earlier of witnesses, the NZTA has listened to those

comments and it will take them on board, sir, in regard to issues that 30

were raised with witnesses in regarding to conditions, and issues of

conflict or perception of conflict of interest, sir.

CHAIRPERSON: I‟m grateful. I rather thought it would be taken on board.

Thank you. 35

MATTER ADJOURNED AT 2.06 PM UNTIL TUESDAY, 20 NOVEMBER 2012

Documents

TRANSCRIPT OF PROCEEDINGS BOARD OF INQUIRY … · 16.11.2012 · MacKays to Peka Peka Expressway Proposal HEARING at KAPITI COAST on 16 NOVEMBER 2012 BOARD OF INQUIRY: Retired High