WELLINGTON REGISTRY I MUA I TE KŌTI TAIAO O AOTEAROA TE ... · Project’s earthworks on existing wind turbine foundations (within the Te Āpiti Wind Farm) that are located in the

Barristers and Solicitors Wellington Solicitors Acting: David Randal / Thaddeus Ryan / Frances Wedde Email: [email protected] Tel 64-4-499 4242 Fax 64-4-499 4141 PO Box 2694 DX SP20201 Wellington 6140

IN THE ENVIRONMENT COURT OF NEW ZEALAND WELLINGTON REGISTRY I MUA I TE KŌTI TAIAO O AOTEAROA TE WHANGANUI-Ā-TARA ROHE

ENV-2020-WLG-00014 UNDER the Resource Management Act 1991 IN THE MATTER OF a notice of motion under section 87G of the Act

seeking the grant of resource consents to Waka Kotahi NZ Transport Agency for Te Ahu a Turanga: Manawatū-Tararua Highway

STATEMENT OF EVIDENCE OF TIMOTHY JOHN WATTERSON ON BEHALF OF WAKA KOTAHI NZ TRANSPORT AGENCY

PROJECT DESIGN

12 June 2020

BUDDLE FINDLAY .

TABLE OF CONTENTS INTRODUCTION .................................................................................................... 3 PROJECT OVERVIEW ........................................................................................... 5 PHYSICAL AND PROGRAMME CONSTRAINTS ................................................... 9 DESIGN DEVELOPMENT APPROACH ............................................................... 11 COMMENTS ON SUBMISSIONS ......................................................................... 18 COMMENTS ON SECTION 87F REPORT ........................................................... 33 ATTACHMENT TW.1 – UPDATED CONSENTING DRAWINGS .......................... 36

INTRODUCTION

1. My name is Timothy John Watterson.

2. I am the Design Director for Te Ahu a Turanga Alliance, the alliance which

has been engaged by Waka Kotahi NZ Transport Agency ("Transport Agency") to design and deliver Te Ahu a Turanga: Manawatū-Tararua Highway Project ("Alliance" and "Project" respectively).

Qualifications and experience

3. I have the following qualifications relevant to the evidence I shall give:

(a) Masters in Civil Engineering with Honours (UK);

(b) Chartered Civil Engineer (Engineering Council, UK);

(c) Professional Member of Engineering New Zealand;

(d) Professional Member of The Institution of Civil Engineers (UK); and

(e) Professional Member of The Chartered Institution of Highways and

Transportation (UK).

4. In my 25 years of experience, I have led the design of large-scale roading

and other infrastructure projects including:

(a) Design Director for this Project (2019 - present);

(b) Design Director for the North Canterbury Transport Infrastructure

Recovery (NCTIR) Alliance that was responsible for designing and

constructing all road and rail repair works after the 2016 Kaikoura

earthquake and implementing new safety and resilience improvements

(2017-18);

(c) Design Manager for the Christchurch Northern Corridor Alliance (2015-

2017);

(d) Project Director/Design Manager for various large infrastructure

projects in Melbourne, Australia (2013-2015);

(e) Design Manager for SH16 Causeway Upgrade project in Auckland

(2012-2013);

(f) Design Manager for the East Taupo Arterial project (2008-2010); and

(g) Design Manager for the SH20 Manukau Extension, Auckland (2005-

2010).

Code of conduct

5. I confirm that I have read the Code of Conduct for expert witnesses

contained in the Environment Court Practice Note 2014. This evidence has

been prepared in compliance with that Code. In particular, unless I state

otherwise, this evidence is within my area of expertise and I have not omitted

to consider material facts known to me that might alter or detract from the

opinions I express.

6. I also note that my employer, Aurecon NZ Ltd, is a Non-Owner Participant in

the Alliance. I have explained to Aurecon NZ Ltd and the Alliance my

obligations under the Code in giving this evidence, including the overriding

duty to assist the Court impartially on matters within my area of expertise.

Background and role

7. I have been working on the Project since February 2019. My role has been

to:

(a) lead and manage the overall design development for the Project during

the ‘RFP Tender Phase’ (February 2019 to May 2019), and ‘IPAA

Phase’ (July 2019 to current); and

(b) form part of the Alliance Management Team (July 2019 to current).

8. I contributed to and reviewed the Design and Construction Report ("DCR") included as Volume II of the application for resource consents (the "Application") lodged with Manawatū-Whanganui Regional Council ("Horizons") on 11 March 2020 in respect of the Project.

9. In preparing my evidence I have:

(a) undertaken site visits and have a detailed understanding of the Project

area;

(b) been involved in numerous specialist workshops and expert meetings;

(c) reviewed the sections of the Application, drawing set and technical

reports relevant to my assessment and the draft statements of

evidence of the applicant’s witnesses;

(d) reviewed the designations in place for the Project and the designation

conditions; and

(e) attended a number of public information sessions and meetings of the

Community Liaison Group ("CLG") initiated by the Transport Agency for the Project pursuant to the designation conditions.

Purpose and scope of the evidence

10. My evidence addresses the following matters:

(a) an overview of the Project;

(b) the Project's physical and programme constraints;

(c) the approach to developing the Project's design;

(d) design-related matters raised in submissions; and

(e) the Section 87F Report.

11. Mr Tony Adams provides evidence on the construction methodology for the Project.

PROJECT OVERVIEW

12. The Project is described in Section 1 of the DCR, which for ease of reference

is repeated below.

13. The Project is for the construction, operation, use and maintenance of

approximately 11.5 km of rural state highway connecting Ashhurst and

Woodville via a route over the Ruahine Range. The purpose of the Project is

to replace the indefinitely closed existing State Highway 3 ("SH3") through the Manawatū Gorge with a new stretch of rural state highway. The location

and extent of this new state highway in relation to the former route is shown

in Figure 1-1 of the DCR.

14. The Project provides for the following key elements, which are shown on the

General Arrangement Drawings contained in Volume III of the Application:

(a) approximately 11.5 km of two-lane, median divided, access controlled

rural state highway, with crawler lanes over the majority of the length in

each direction, connecting SH3 at Ashhurst with SH3 at Woodville via a

route over the Ruahine Range to the north of the Manawatū Gorge;

(b) connection to the existing state highway network, by way of:

(i) a single lane roundabout, which will provide a new intersection of

SH3 and State Highway 57 ("SH57") and be located at approximately CH 2900, to the immediate east of the current

SH57 / Fitzherbert East Road / SH3 intersection (referred to as

the "Western Roundabout"); and

(ii) a single lane roundabout providing a new intersection of SH3 with

local roads to the west of Woodville located at approximately CH

13790 (referred to as the "Eastern Roundabout" and discussed further below).

(c) a four-lane bridge across the Manawatū River (BR02) and the adjacent

Palmerston North – Gisborne rail line at the western end of the

Manawatū Gorge at approximately CH 3600 to CH 3900;

(d) a four-lane ‘Eco Bridge’ (BR03) spanning the ecologically sensitive

area located on northern side of the Manawatū River, 100m north of the

river bank at approximately CH 4000 to CH 4300;

(e) a four-lane Mangamanaia Stream Bridge (BR07) located at

approximately CH 12900 (with two farm tracks passing underneath

which are located above the Q10 flood level1);

(f) underpasses to allow access across (i.e. beneath) the new alignment to

or within private property at:

(i) approximately CH 3270 – providing access to Nutcracker Farm

(which is located to the south of the proposed state highway);

(ii) approximately CH 8240 – connecting the northern and southern

sections of Te Āpiti Wind Farm, which is owned and operated by

Meridian Energy Limited ("Meridian"); and

(iii) approximately CH 10210 – connecting the northern and southern

sections of the Ballantrae Hill Country Research Station

("Ballantrae Farm") which is owned and operated by AgResearch Limited;

(g) a controlled access to Te Āpiti Wind Farm for over-dimension vehicles

at approximately CH 8000;

(h) realignment of access tracks within Te Āpiti Wind Farm to maintain the

network of accesses between the wind turbines for ongoing farm

operations;

(i) a restricted (left in/out) access point to the adjacent farm/lot at

approximately CH 10900;

(j) a restricted (left in/out) access point to future stockyards at


(k) a replacement grassed airstrip and associated access track located

approximately 100m to the south of its current location (within the

1 Q10 represents a 10-year flood event.

Andrew Bolton property), adjacent to the Project alignment at


(l) creation of a Western Gateway Park at the western end of the

Manawatū Gorge Scenic Reserve, to facilitate access to existing

walking tracks in the Reserve and new recreational facilities provided

by the Project, consisting of a parking area (comprising 80 car parks, a

bus drop-off bay and parking space for up to three buses, landscaped

open spaces connected by pathways, and relocation of existing toilet

facilities);

(m) a shared use path ("SUP") for pedestrians and cyclists commencing at the existing SH3 Ashhurst Bridge and terminating at the Vogel Street /

Hampson Street intersection, Woodville; the width of the SUP is

generally 3m but narrows where it traverses certain constraint points;

(n) safe stopping areas ("SSAs") accessed from the main alignment leading to viewing platforms / rest areas accessed via a footpath as

follows:

(i) an SSA off the eastbound carriageway at approximately CH 5200

leading to a viewing platform / rest area via a 2m wide and

approximately 500m long footpath;

(ii) an SSA off the westbound carriageway at approximately CH 8150

leading to a viewing platform / rest area via a 2m wide and

approximately 200m long footpath; and

(iii) an SSA at approximately CH 11650 leading to a viewing platform

/ rest area via a 2m wide and approximately 200m long footpath;2

(o) a 2-3m wide walking/cycling track linking the SSA at CH 5200 (which

accesses a proposed lookout over Ashhurst) and the new eco-

experience area between approximately CH 4200 and CH 4800 to the

north of the Manawatū River and west of the Project alignment (this will

be a repurposed construction access track);

(p) new walking tracks and boardwalks within the eco-experience area

between approximately CH 4000 and CH 4250 (on the western side of

the Project alignment);

2 This SSA was proposed to be accessed from the westbound carriageway, but will now be accessed from the eastbound carriageway. This new location allows direct access to the SSA from the proposed SUP, which is on the north side of the new alignment at this location, and provides for improved viewing of the Tararua Plains. This change was requested by Tararua District Council and members of the CLG.

(q) a repurposed existing access track (the "Western Access Track") to provide walking and cycling facilities alongside the Pohangina River

(over a distance of approximately 3km) from the Project through to

Saddle Road;

(r) stormwater treatment wetlands (at approximately CH 3000 to the north

of the alignment, CH 3400 north, CH 3950 north, CH 4650 south, CH

5700 north, CH 8300 south, CH 10900, CH 12400 south and CH 12800

north);

(s) stormwater swales, roadside drainage channels, sediment basins (at

various locations, see Drawings TAT-3-DG-H-1401 to 1421 in Volume

III of the application documents);

(t) culverts to reconnect streams crossed by the proposed works;

(u) stream diversions to recreate and reconnect streams; and

(v) spoil disposal sites (at various locations, see Drawing TAT-3-DG-C-

3600).

15. Key temporary construction-related elements of the Project are discussed in

the evidence of Mr Adams. In short, they include:

(a) construction staging to facilitate the development of the Manawatū

River Bridge (BR02) and the Eco Bridge (BR03);

(b) construction yards providing for car parking, office space, staff rest and

wellbeing facilities, stores, minor vehicle and machinery repairs, and

fuel storage (at various locations, see Accommodation Works Drawings

TAT-3-DG-C-3601 to 3616);

(c) laydown areas (at various locations, see Accommodation Works

Drawings TAT-3-DG-C-3601 to 3616);

(d) stockpile areas (at various locations, see Accommodation Works

Drawings TAT-3-DG-C-3601 to 3616);

(e) construction access tracks; and

(f) a temporary western car park providing car parking and toilet facilities

for users of the Manawatū Gorge Scenic Reserve during the

construction phase. This facility will be relocated several times during

the construction period to allow for the safe management of the

construction activities.

PHYSICAL AND PROGRAMME CONSTRAINTS

16. The Project design has been directed by the notices of requirement given by

the Transport Agency for the Project ("NoRs"), and now confirmed by the Environment Court, together with the designation conditions which have also

now been confirmed by the Court.

17. One substantial improvement made to the design since the NoRs were first

issued, which is a change that has now been confirmed by the Environment

Court, has been to modify the requirement within the Tararua District to

provide for a more northerly alignment of the Project ("Northern Alignment"). This modification results in less adverse effects on ecologically sensitive areas and is described further below.

18. The Project's design and construction approaches have been influenced by

both physical and programme constraints, which are described in Section 2

of the DCR and summarised further below.

Physical constraints

19. The physical constraints that have influenced the design are summarised at a

high level in Table 2-1 of the DCR and include the Project corridor's

topographic and geological setting, cultural areas, sensitive ecological areas

(including protected areas), the need to maintain and allow for existing land

uses (predominantly farming and agribusiness as well as Te Āpiti Wind

Farm) and the engineering challenges associated with this.

20. Particularly important to the matters I address in my evidence are the

geotechnical elements, including the need for the Project to be resilient

against potential land instability and earthquakes. The geomorphology of this

area is strongly controlled by the tectonic setting of the lower North Island. At

the western extent, three faults (the Parahaki, Raukawa, and Centre faults)

run approximately in a northeast direction crossing the Manawatū River. At

the eastern extent of the Project site, the faults of note include the Totara,

Ruahine, and Mohaka faults.

21. The Geotechnical Design Technical Memorandum attached as Appendix A of

the DCR includes a summary of the geology within the Project area and

interpretative data to be used in the design of geotechnical-related elements

(e.g. cuttings, fill embankments and spoil sites). As the memorandum states,

due to the highly complex geological and seismological setting of the area,

the Project has been designed to improve the resilience of the transport

network in the event of a significant earthquake and/or slip, road accidents,

or other disruption, by providing a new, more resilient route, built to modern

standards, and a new high-quality bridge crossing of the Manawatū River.

22. All geotechnical design is being carried out in accordance with the Transport

Agency Bridge Manual 3rd Ed Amendment 3 (2018) and the Transport

Agency Project Minimum Requirements ("MRs"), specifically A5 (Geotechnical Engineering), A6 (Bridges and Retaining Walls) and A7

(Pavements and Surfacing), which establish the Transport Agency’s quality

standards for resilient infrastructure.

23. In addition, since the Application was lodged, further ground investigations

have been undertaken and reported in the Te Ahu a Turanga: Manawatū

Tararua Highway – Detailed Design Report - Geotechnical Interpretive

Report ("GIR") dated 29 April 2020 (Revision B). It is standard practice for large infrastructure projects that undertake significant programmes of ground

investigation works to update progressively documents such as the GIR.

Programme constraints

24. There are also a range of programme or time constraints that influence the

timing of design and construction activities. These are noted in Section 2.3

of the DCR and include:

(a) property acquisition;

(b) consenting timeframes (including lodgement and decisions);

(c) seasonal requirements and duration of ecological surveys and other

pre-construction environmental compliance requirements as

necessitated by the designation conditions or resource consent

conditions;

(d) detailed design duration (including start and end dates);

(e) the ability for the main contractor to begin the construction

activity/works;

(f) the duration of the construction activity/works; and

(g) working hours, weather, and available seasons (e.g. for earthworks and

pavements).

25. These constraints are addressed further in the evidence of Mr Adams.

DESIGN DEVELOPMENT APPROACH

26. The approach to developing the design of the Project is described in Section

3 of the DCR and summarised below.

Design development process

27. The Project's design has developed over time, taking into account

increasingly detailed information regarding environmental and other

constraints, and then responding to those constraints with a focus on

minimising the Project’s adverse effects on the environment.

28. The design has been informed by numerous processes undertaken prior to

and since the slips that closed the section of SH3 through the Manawatū

Gorge in April 2017. Relevant studies undertaken by the Transport Agency

since 2010 that have influenced the Project’s design are listed in Table 3-1 of

the DCR. These studies demonstrate the design development progression

from high-level network optioneering exercises through to development of a

high-level design concept in the Manawatū Gorge Alternatives Detailed

Business Case ("DBC") stage. During this stage, 18 options were considered, and the preferred route was identified.

29. Following the DBC stage, an indicative alignment design was developed to

support the NoRs for the Project and a Request for Proposal ("RFP") tender phase in early 2019. This enabled the extent of the Project designation to be

determined in response to potential effects on the environment. In particular,

a realignment was introduced at the eastern end of the Project to reduce

potential effects on a stream and on property. In addition, during the hearing

on the NoRs, the Transport Agency agreed to add the SUP and other

refinements to the overall Project design.

30. During the RFP tender phase, the ‘ADVANCE’ team (which later formed the

Alliance) developed a Preliminary Concept Design ("PCD") for consideration by the Transport Agency. While ADVANCE’s PCD mostly kept within the

designation corridor set by the NoRs, it also included a deviation of the

indicative highway alignment over a 1.5 km length between the Eco Bridge

(BR03) and CH 5100 (within the original designation area), and then between

CH 5500 to CH 7100 (partially outside the original designation area). As

noted above, this resulted in the Transport Agency seeking a modification of

the NoR within the Tararua District to provide for the Northern Alignment,

which has now been confirmed by the Environment Court. The PCD resulted

in a number of benefits, including:

(a) reduced impact and footprint on two areas subject to Queen Elizabeth

II Open Space Covenants (the "Western QEII" and "Eastern QEII");

(b) significant reductions in effects on two streams which traverse the

Western QEII and Eastern QEII (streams 6 and 7), albeit with an

increased length of stream affected on a different water course (stream

5);

(c) reduced impacts on old growth treelands, areas of secondary

broadleaved forests and scrublands as well as areas of advanced

secondary broadleaved forest and mānuka/kānuka scrublands;

(d) avoidance of 0.05 ha of nationally significant swamp maire and old

growth forest, achieved by extending the length of the Eco Bridge

(BR03) from 155 m to 305 m. This extension to BR03 also removed

large embankment fills and removed up to 308 m length of potential

culverts through the lower section of the Western QEII gully;

(e) reduced effects on Te Āpiti Wind Farm; the indicative design shown in

the original NoRs required the removal of one, possibly two, wind

turbines whereas the Northern Alignment does not require the removal

of any turbines, reduces the number of turbine foundation zones

impacted to six (i.e. turbines where nearby earthworks require specific

consideration to ensure that the stability of turbines is not

compromised, as discussed below), and also enables uninterrupted

access to the wind farm during construction;

(f) reduced effects on the research facility located on a part of the

Ballantrae Farm by way of an amended alignment and steepened cut

slopes stabilised using geogrid to minimise the footprint and land

requirement (the revised alignment also reduces the extent of direct

impact on the research farmlets contained within Ballantrae Farm);

(g) optimised earthworks volume and material re-use strategies to provide

construction programme efficiencies, enabling the potential completion

of the earthworks in 3 to 3.5 earthworks seasons; and

(h) a number of site-specific geotechnical construction solutions, such as

benched cut slopes optimised for stability, resilience and a minimised

risk of erosion; improved seismic resilience through the provision of

geogrid and geotextile reinforced rafts in areas where the alignment

crosses fault lines; and low maintenance cut bench drainage solutions

including concrete canvas liners to reduce long-term erosion risk to

drainage channels.

31. The ADVANCE team was successful with its tender and was engaged by the

Transport Agency to design the Project (including for consenting purposes,

and then the detailed design) and construct it. The Alliance has since been

formed and has carried out further design work on the Project, which is

reflected in the current concept design as detailed in the DCR and on which

the resource consent application is based.

32. This further process has involved design refinement as a result of working

with iwi partners and stakeholder engagement, a thorough review of the PCD

design, investigating new value-add ideas, reviewing scope adjustments, and

workshopping of relevant experts, iwi and stakeholders. This process has

led to some further design refinements which were detailed in the DCR.

33. Also, during this phase, the general location and extent of a SUP was

developed. The SUP is proposed to be generally along the length of the new

state highway starting at the eastern end of the Ashhurst Bridge and ending

at Hampson Street in Woodville.

34. Refinements of the design of the Project are continually being made, in the

usual way, as the Project proceeds through detailed design and then

construction phases. These refinements relate to matters such as the precise

location and configuration of SSAs and property access underpasses and will

be the subject of outline plans lodged with the territorial authorities. These

refinements are focussed on providing additional improvements to the Project

and are being designed to fall within the envelope of effects presented and

assessed as part of the lodged application.

Eastern Roundabout

35. For the purposes of this evidence and the application for regional consents,

the material refinement relates to the Eastern Roundabout, which is in the

vicinity of infrastructure owned by a submitter, Transpower New Zealand

Limited ("Transpower") and the property of another submitter, Mr Shoebridge.

36. In particular, the Eastern Roundabout is now proposed to have a four-arm

(rather than a five-arm) single lane configuration. This new layout is shown

in detail in one of the General Arrangement drawings (TAT-3-DG-R-0116 – D

– Sheet 16) and one Plan and Long Section drawings (TAT-3-DG-R-0509 –

D - Sheet 9). These two drawings are updates to drawings that sit within the

Geometrics suite of the Consenting Drawings (Volume III of the Application);

the updated drawings are annexed to my evidence as Attachment TW.1.

37. This new roundabout configuration provides a simpler road layout by

providing a new intersection of SH3 with Napier Road / Vogel Street /

Woodlands Road and is located at approximately CH 13790, to the

immediate west of the current intersection of these roads. Troup Road will

join Vogel Street via an at-grade T-intersection, rather than directly onto the

roundabout circulatory carriageway (as was shown in the lodged design).

38. The primary reasons for this modification include:

(a) reducing the overall footprint for the roundabout, which in turn reduces

earthworks and pavement areas (and cost);

(b) improving road user safety (for drivers, pedestrians, and cyclists)

through improved ‘readability’ and navigation through the roundabout,

in response to a concern raised during the independent road safety

audit of the Concept Design; and

(c) minimising impact on the infrastructure owned by Transpower in the

vicinity of the roundabout.

39. The modified four-arm roundabout arrangement provides the same access to

adjacent local roads as the five-arm roundabout, and increases the

separation distance of the roundabout from the property of a submitter, Mr

Shoebridge (discussed below).

40. I note that the Eastern Roundabout arrangement has led to refinements to

the stormwater drainage design, which are described in detail in Mr David Hughes' evidence and are shown in detail in the updated Stormwater Drainage Drawings (specifically TAT-3-DG-H-1416) and are annexed to my

evidence as Attachment TW.1.

Stream diversions and spoil sites

41. Also, since lodgement, proposed spoil site 15 has been removed due to

design refinement, associated grade and finished levels of stormwater

infrastructure and a desire to protect the existing stream and wetland habitat.

This is indicated on an updated drawing set attached to my evidence

(specifically TAT-3-DG-E-3644). As a result, the stream diversion on spoil

site 15 is also no longer proposed.

42. As a result of negotiations with Meridian, seven constructed stream channels

and associated riparian margins are proposed to be replaced with cut off --

drains at spoil sites 16, 25, and 28. Riparian planting margins have also been

reduced to 10 m either side on four stream diversions as result of discussions

with Meridian.

43. These changes are discussed further in the evidence of Mr Damien McGahan, Ms Justine Quinn and Mr Hughes, and are shown in detail in the Ecology Offset and Compensation Drawings (specifically TAT-3-DG-C-

4153 and TAT-3-DG-C-4154) and the Stormwater Drainage Layout Plans

(specifically TAT-3-DG-H-1406, TAT-3-DG-H-1407, TAT-3-DG-H-1409, TAT-

3-DG-H-1410). These drawings are updates to drawings that sit within the

Ecology and Stormwater suite of the Consenting Drawings (Volume III of the

Application); the updated drawings are annexed to my evidence as

Attachment TW.1.

44. In addition to the drawings identified showing the three material changes,

(four-arm configuration of the Eastern Roundabout, removal of Spoil Site 15

and change from stream diversions to cut off drains), there are consequential

updates to approximately 30 other drawings within the drawing set lodged

with the application.

45. A schedule of the Consent Drawings which have been amended, and the

changes to them are included in the first page of Attachment TW.1. Updated revisions of these drawings are also annexed to my evidence as

Attachment TW.1. These drawings supersede and replace the equivalent drawings lodged with the Transport Agency’s application for consents

(Consenting Drawings - Volume III of the Application).

Cultural values and design principles

46. The Project’s design has been developed together with the Project’s iwi

partners, being Rangitāne o Manawatū, Rangitāne o Tamaki nui-ā-Rua,

Ngāti Kahungunu ki Tāmaki nui-a-Rua and Ngāti Raukawa, in particular

through regular design workshops that commenced in mid-2019. These

workshops have also included input from representatives of Te Āpiti Ahu

Whenua Trust, particularly in regard to proposed Project works near Parahaki

Island. Input from iwi has been integrated throughout the Project’s design,

especially for those areas of particular interest including ecology, stormwater

management, earthworks, structures and cultural expression.

47. The Project’s Alliance Charter sets out a number of cultural values

underpinning the partnership with iwi in respect of the Project. These values

are detailed in the DCR.

48. In addition, the designation conditions provide for the Project to be designed

and constructed in accordance with the Cultural and Environmental Design

Framework ("CEDF"), which itself is a document developed collaboratively with the Project's iwi partners.

49. The intention behind all of the above measures is to embed cultural values

and principles in the design process. The DCR gives some examples of how

this has occurred, including (but not limited to) the following:

(a) the location of and selection of spoil sites for excess cut material, which

has been decided following focussed engagement with the iwi partners;

(b) the preferred SUP route option has been based on an understanding

and an appreciation of the wider cultural landscape and the

identification of areas where public access is not appropriate;

(c) cultural expression opportunities across the Project, including tracks

and trails, structures, and gateway treatments at each end of the

Project;

(d) the preferred stormwater treatment methodology has been agreed in

discussions with the iwi partners; and

(e) the form and location of proposed ecological offset/compensation and

landscape planting has been decided in discussion with the iwi

partners.

Landscape values and design principles

50. The DCR also explains the approach to landscape values and design. In

particular, it explains that a whole-of-landscape and integrated catchment

approach has been adopted and that there is an emerging framework

requiring a design response that "works with the grain" of the land;

recognises the surrounding landscape including the rural and natural

character attributes; and fosters the experience of traveling to and through

the landscape.

51. The principle of ‘gateways’ as part of the overall user experience and wider

open space and urban integration of the Project is a key component of this

landscape design response, with three landscape areas across the Project

alignment complementing the whole-of-landscape and integrated catchment

management approach, as follows:

(a) A ‘Western Landmark Gateway’ that recognises the unique landscapes

of the traditional western gateway to the Manawatū Gorge, the

Manawatū River crossing and traversing the ecologically sensitive

areas subject to QEII covenants.

(b) An ‘Upland Experience’ that highlights the driver experience of

travelling through the Te Āpiti Wind Farm and the surrounding rolling

upland landscape.

(c) An ‘Eastern Rural Gateway’ that recognises and enhances rural

character and the arrival to and departure from the Tararua Plains,

while maintaining a connection to the “old gorge”.

52. In summary, the landscape values and design principles for the Project have

guided the engineering design in the following ways:

(a) minimisation of effects on:

(i) threatened ecosystems; and

(ii) streams, wetlands, indigenous vegetation and QEII covenanted

forests;

(b) integration of cuts and fills into the landscape;

(c) provision of public access which is mindful of cultural and ecological

sensitivities;

(d) maintenance of natural character and landscape values of the

Manawatū Gorge;

(e) provision of opportunities to/for:

(i) bridges that are a means of re-connection and celebration of the

adjacent area;

(ii) a feature bridge over the Manawatū River but which does not

significantly detract from the natural character and amenity of the

Manawatū River;

(iii) improved access to Manawatū River beaches;

(iv) enhancing connections to alluvial forest remnants and offsetting

adverse effects on them;

(v) views to, across, and down:

(1) the Manawatū and Pohangina River valleys;

(2) Te Āpiti Wind Farm, rural landscape and indigenous forest;

and

(3) the Tararua plains;

(vi) stopping/viewing/experiencing Te Āpiti Wind Farm and providing

improved access to the Manawatū Gorge Scenic Reserve; and

(f) provision of gateways and access to Ashhurst, Manawatū Gorge and

Woodville.

Engineering design principles

53. The design has also been guided by a number of engineering design

principles, which are explained in the DCR and which include:

(a) ‘safety in design’;

(b) ‘maintenance in design’;

(c) road safety audits;

(d) road geometry and signage;

(e) bridges and structures;

(f) earthworks design;

(g) geology;

(h) stormwater and hydrology; and

(i) lighting.

COMMENTS ON SUBMISSIONS

Introduction

54. I comment below on the submissions raising matters relevant to the design of

the Project, namely those of:

(a) Mr Lou Klinkhamer;

(b) Mr Nick Shoebridge;

(c) Transpower;

(d) Meridian Energy Limited ("Meridian"); and

(e) Mr John Bent.

Lou Klinkhamer

55. A video was received from Mr Klinkhamer which seeks an alternative Bridge

option and Project route through the Manawatū Gorge to be considered (in

lieu of the proposed route shown in the lodged design) and uses Karakoram

Highway in Pakistan as an example.

56. As an initial comment, in devising the Project the Transport Agency assessed

a number of options for a new road, as noted in the DCR (section 3). I was

not directly involved in this earlier work but am aware of it through the

subsequent RFP process; it included a strategic study in 2010, an alternative

route assessment in 2012; a further strategic study in 2016, and a Detailed

Business Case in May 2018, involving detailed consideration of a long list

(18) and short list (4) of options. These assessments concluded that that due

to the increasing scale and frequency of land instability events through

Gorge, it is prohibitively expensive and too unsafe to maintain the existing

SH3 route through the Gorge.

57. Specific to Mr Klinkhamer’s submission, the long list assessment presented

in the Detailed Business Case considered an option of constructing a viaduct

through the Gorge (which had its genesis in the 2012 study by MWH). It

concluded that the option was fatally flawed in terms of effects on Māori

cultural and heritage values, and in a broader environmental sense.

58. Constructing a new elevated structure through the Gorge (similar to the

Karakoram Highway bridge in Pakistan, seen in the video included in the

submission) would require a bridge of approximately 5.5-6km in length. This

was estimated to cost $1.1 to $1.4 billion in the DBC. This is significantly

more than the estimated cost of the Project, and would likely be prohibitive.

59. As found in the Detailed Business Case, a new elevated structure through

the Gorge would also give rise to significant adverse environmental effects,

including negative effects on natural character and the river eco-system. A

long, elevated structure with multiple piers in the river would likewise

adversely affect the mauri of the river and would likely be unacceptable to the

Transport Agency’s iwi partners.

60. From a design perspective, I would also have efficiency and safety concerns

regarding such an option – tighter geometric parameters would be required

for the option to traverse the Gorge, which would lower the design speed,

increase the risk of crashes, and make for a less efficient (albeit more flat)

route than that proposed.

61. Resilience issues would also be associated with such an option; structural

foundations and piers for an elevated structure would be subject to the

ongoing risk of significant landslips, safety issues during construction from

significant works required in the river, and significant extra maintenance

compared to the proposed route.

Nick Shoebridge

62. Mr Shoebridge’s submission raises a design-related question, namely

"exactly how many metres the edge of the roundabout is to the closest corner

of our home" and a related concern over noise effects from vehicles

braking/accelerating at the roundabout.

63. The roundabout referred to by Mr Shoebridge is the Eastern Roundabout (at

the eastern end of the Project) discussed above. I was not directly involved

with the NoR process but I understand that Mr Shoebridge (and his mother

Ms Cooke) submitted on the NoRs with similar concerns to those raised

above.

64. Mr Shoebridge’s property is at 49846 Napier Road (SH3), near to Woodville.

65. As I understand was explained by the Transport Agency during the NoR

process, the Eastern Roundabout is a necessary element of the Project,

because it provides a safe intersection catering for all traffic movements and

a safe transition for road users from the modern standard of highway

(provided by the Project) to existing SH3. It was incorporated into the Project

design following recommendations made in an early Road Safety Audit.

66. In terms of noise effects from braking, I am not a noise and vibration

specialist but understand that those effects were considered by experts in the

NoR process and am aware that various designation conditions resulted.

67. One such condition is Designation Condition 39, which provides as follows:

“Noise bunds:

(a) Prior to undertaking construction works activities in the vicinity of

(…) 49846 State Highway 3 (subject to reasonable property

access and land availability):

(i) (…)

(ii) An earth bund must be designed and constructed along the

roadside boundary of the designation with 49846 State

Highway 3, Woodville, for the purpose of operational noise

mitigation and visual screening. The design must be

undertaken in consultation with the owners/occupiers of the

property.

(b) An independent, suitably qualified and experienced person must

design the bunds provided for at (…) 49846 State Highway 3

required by i) and ii)”.

68. Other confirmed designation conditions to mitigate noise effects require:

(a) a low-noise road surface to be laid, prior to the road opening, on Vogel

Street in Woodville and from the Eastern Roundabout extending at

least 2km to the west of the roundabout (Designation Condition 40);

and

(b) a separation distance of 100m between the traffic lanes of roundabouts

and existing dwellings (Designation Condition 41).

69. In terms of the distance of Mr Shoebridge’s dwelling from the proposed

roundabout, it is relevant to note that Mr. Shoebridge’s dwelling is currently

approximately 23m from the edge of the existing SH3 Napier Road

carriageway. The closest edge of the new Eastern Roundabout circulatory

carriageway will be considerably further away than this, at approximately

149m from the dwelling. The separation provided is comfortably greater than

the 100m minimum distance required by Designation Condition 41.

70. The nearest part of the main Project alignment (i.e. as it exits the Eastern

Roundabout heading north-west) will be approximately 170m from Mr

Shoebridge’s property. As such, the new highway will be significantly further

away from the Shoebridge dwelling than the existing SH3 Napier Road, and

vehicles using the new highway (and Eastern Roundabout) will not be

braking/accelerating directly in front of Mr Shoebridge’s property.

71. As required by Designation Condition 40, the roundabout carriageway and

the stretch of road to the west will be surfaced with Stone Mastic Asphalt,

which is a quieter running surface than the chip seal-type surfacing that is on

the existing SH3 Napier Road.

72. Lastly, the four-arm Eastern Roundabout is further away from the Shoebridge

dwelling than the indicative roundabout location assessed during the NoR

process. The existing Troup Road/Woodlands Road intersection with SH3

will be modified and will also be further away from Mr Shoebridge’s property

within the new roundabout/T-intersection arrangement. The roundabout and

main alignment will also be visually screened through the use of appropriate

mitigation planting and landscaping works.

73. I understand that the Transport Agency has been in discussion with Mr

Shoebridge. Works to upgrade the noise bund at his property, the location of

the new bund, and other mitigation measures are still under discussion.

74. In summary, the design of the new Eastern Roundabout has considered the

matters raised by Mr Shoebridge in his current submission and mitigates

adverse effects on his property, in line with the designation conditions. Key

design mitigation considerations include:

(a) That the proposed design will comply with Designation Condition 39,

including modifications to the existing noise bund at Mr Shoebridge’s

property;

(b) Use of asphaltic surfacing on the roundabout and eastern slope of the

main alignment (as required by Designation Condition 40);

(c) Appropriate use of landscaping and planting to clearly signal the

presence and change in speed environment on the approaches to the

Woodville, and visually screen the Project from adjacent properties;

(d) Maintenance of a separation comfortably greater than 100m between

the proposed roundabout and 49846 Napier Road property (as required

by Designation Condition 41); and

(e) Use of appropriate geometric alignments to moderate vehicle speeds

and driver behaviour on the approach to and navigation through the

proposed Eastern Roundabout.

75. Construction related matters associated with the noise bund and road

surfacing are contained in Mr Adams’ evidence.

76. Stormwater management related matters are contained in Mr Hughes’ and Dr Jack McConchie’s evidence.

Transpower New Zealand Ltd

77. In the submission made on behalf of Transpower, paragraphs 1.5 and 1.6

seek clarity on the intended design and construction of the Eastern

Roundabout.

78. As discussed above, the configuration of the proposed Eastern Roundabout

has been modified so that it has four arms (of single lanes). This new

configuration provides a simpler and safer road layout and less works around

existing Transpower assets by providing a new intersection of SH3 with

Napier Road / Vogel Street / Woodlands Road and is located at

approximately CH 13790, to the immediate west of the current intersection of

these roads. Troup Road will join Vogel Street via an at-grade T-intersection,

rather than directly onto the roundabout circulatory carriageway (as was

shown in the lodged design).

79. With respect to the design coordination of the modified four-arm roundabout

with existing Transpower assets in this area, I attended a meeting with

Transpower via video call on Tuesday, 12 May 2020, during which the

Alliance representatives discussed the modified four-arm roundabout design,

including where it interfaces with Transpower assets. The Alliance

representatives confirmed at this meeting that the New Zealand Electrical

Code of Practice for Electrical Safe Distance (NZECP 34:2001) guidelines

have been used to confirm all clearance requirements are met in relation to

works around Transpower assets. There have also been two further

meetings held with Transpower to discuss these matters on 9 and 10 June

2020.

80. At the meeting on 12 May 2020 the Alliance representatives also explained

the design requirement that the final design will maintain all safe distance

requirements and access to Transpower assets, which includes giving due

consideration to the level of the proposed roundabout and the location and

height of the roadside features (e.g. road traffic signage and lighting poles).

The roadside features were discussed in detail at the meeting, and in

subsequent email communications with Transpower.

81. The Alliance has assessed that the minimum clearances will be achieved and

have confirmed this to Transpower. Discussions with Transpower remain

ongoing. These communications related to the following infrastructure:

(a) Location and levels of the proposed SUP;

(b) Construction activities associated with the roundabout construction

(addressed in further detail in Mr Adams’ evidence, in terms of the construction methodology and temporary access proposed for

roundabout construction adjacent to the existing Transpower assets);

(c) Location, levels and depth of proposed road drainage assets including

culverts, wetland swales, stream diversions and network drainage

systems;

(d) Location and levels of the proposed road lighting poles;

(e) Location and levels of the proposed road traffic signage;

(f) Location and levels of the proposed roadside safety barriers;

(g) Type, height and location of proposed landscaping works; and

(h) Existing and proposed underground utilities (e.g. telecommunications,

water and electrical high-voltage and low-voltage services).

82. As such, the Project’s design and construction will address all of the matters

raised in Transpower’s submission.

83. Further, this information is required to be collated in a National Grid

Management Plan, which is a stipulation of Designation Condition T2. Under

that condition, the Transport Agency is required to demonstrate compliance

with NZECP 34:2001 and address the other matters raised in Transpower’s

current submission.

84. The Alliance will continue to liaise with Transpower, and I note that following

a meeting with Transpower on the 9 June 2020, additional resource consent

conditions have been proposed to address Transpower's concerns. These

include the requirement for compliance with the NZECP, and for a National

Grid Management Plan if construction works are being undertaken in the

vicinity of the 110kV National Grid transmission line. These are discussed in

detail in the evidence of Ms McLeod.

Meridian Energy Limited

Geotechnical / stability matters

85. In the submission made on behalf of Meridian the following geotechnical or

earthworks-related matters were raised:

(a) There is very little geotechnical information to support design

assumptions. This is an ongoing concern for Meridian with

respect to the potential effects of the earthworks on wind farm

infrastructure;

(b) Draw down effects of ground water on turbine foundations (either

via dewatering or earthworks);

(c) Contingency plans in relation to some of the details i.e.

monitoring resulting from earthworks, creep or settlement; and

(d) Impacts of large disposal sites on land adjacent to turbines i.e.

settlement.

86. Meridian also raised the following design-related matters relating to

temporary works and spoil sites:

(a) Geotechnical analysis on the impacts of disposal sites particularly

where they are in close proximity to turbines (…) possible

settlement of the ground causing differential settlement at

turbines. At present there is insufficient detail or analysis provided

i.e. depth of disposal, subsurface soils and draw down effects on

adjacent land or effects of pore water pressures, and;

(b) It is also unclear where temporary topsoil stockpiles will be

located and how these will be managed in relation to proximity to

Meridian’s infrastructure.

87. Meridian has previously received a copy of the Te Ahu a Turanga: Manawatū

Tararua Highway – Detailed Design Report – Geotechnical Interpretive

Report ("GIR") dated 20 March 2020 (Revision A). This document included a summary of geology within the Project area and interpretation to be used in

the design of geotechnical-related elements (e.g. cuttings, fill embankments

and spoil sites) on existing wind turbines (in the vicinity of the Project).

88. It is normal practice for large infrastructure projects that undertake significant

programmes of ground investigation works to update documents such as the

GIR progressively. This is necessary in order to capture ongoing data from

the field (and interpretation thereof) from the staged investigations. The GIR

document for the Project was updated on 29 April 2020 (Revision B). The

updated version (Revision B) was provided to Meridian for information on 28

May 2020.

89. In response to the above matters raised by Meridian, detailed geotechnical

analysis has been undertaken by Chartered Professional Geotechnical

Engineers (working in the Alliance team) to assess potential impacts of the

Project’s earthworks on existing wind turbine foundations (within the Te Āpiti

Wind Farm) that are located in the vicinity of the Project.

90. These works are required by Designation Condition T1, under which the

Transport Agency must prepare a Te Āpiti Wind Farm Management Plan.

91. Among various other things, that Plan must "include technical, engineering

and geotechnical advice from suitably qualified and experienced person(s) in

relation to the impact of the enabling or construction works activities on the

safe and efficient operation of a turbine where (…) enabling or construction

works activities (other than for the relocation of underground infrastructure

and wind farm accesses) are within 160 metres of a turbine location shown

on the plan marked “Drawing No. 1 (Rev 3) General Site Plan With Topo

Information” (referenced in the resource consent granted on 3 September

2003) except that in the case of turbines A11, A12 and A13 (now known as

TAP01, TAP02, and TAP03) this distance is limited to 60m when closer to

Ashhurst".

92. To help inform the detailed geotechnical assessments and to supplement

historical geotechnical information that was available from the construction of

the windfarm, an extensive programme of ground investigation works is being

undertaken throughout the Project extents, including the Te Āpiti Wind Farm.

The physical investigations to recover samples of the existing ground (and

assist the interpretation of geology) includes boreholes, trial pits and hand

augers. Extensive interpretation of the samples is undertaken, which includes

material logging, ground mapping, and defining the different material types

and characteristics (lithology) by professional geologists. Laboratory testing

of recovered ground samples is also being undertaken and includes shear

box tests, compaction testing, hydrometer analysis, compressive testing, and

triaxial undrained shear strength tests.

93. An extensive factual three-dimensional geological ground model for the

Project has been established by professional geologists and geotechnical

engineers, utilising data from historic records, ground observations and on-

site mapping, and the physical ground investigation works.

94. A summary of the geological model is contained in the GIR which was

provided to Meridian.

95. Detailed geotechnical assessments have been undertaken for the potential

effects of the earthworks design and construction (i.e. cuttings, fill

embankments and spoil areas) that are required for the Project in the vicinity

of existing wind turbines. As noted above, the detailed geotechnical analysis

work undertaken to date was provided to Meridian on 29 May 2020.

96. The types of potential effect that have been considered and reported on are:

(a) Settlement due to groundwater drawdown from cuttings/fill

embankments;

(b) Creep settlement from relaxation of the cut ground;

(c) Long-term consolidation settlements;

(d) Slope instability and bearing reduction; and

(e) Seismically induced settlements and stability of the cuttings.

97. In summary, as explained further below, the Project will not adversely affect

the stability of Meridian’s existing assets, such that specific design or

engineering treatments would have been required to address those effects.

The Project earthworks may have an impact on the consent zones for future

turbines in that there may be constraints as to where new wind turbines can

be located in the future (e.g. in connection with Meridian’s potential future

repowering works). Any such constraints are being discussed with Meridian

as part of the compensation agreements.

98. It is normal to expect that there may be some very small ground movements

in the vicinity of large-scale cuttings and fill embankments. However, as the

detailed analysis has demonstrated, any such movements are expected to be

negligible and will not adversely impact wind turbine stability or operations.

The ongoing ground investigation works are part of the standard process that

provides a detailed understanding of the ground composition and how it will

behave, so that knowledge can be incorporated into the design and prior to

construction.

99. That is, if investigations highlighted potential risks to nearby infrastructure or

other property, appropriate design responses would be employed to ensure

appropriate minimisation of those risks.

100. The design is independently peer reviewed by competent professional

engineers as part of the quality assurance process. This is also completed

before construction commences.

101. In addition to this, it is also standard practice, and a requirement of the

Project MRs (Appendix A5 Geotechnical Engineering, Section A5.13), to

implement a programme of instrumentation and monitoring during

construction. This is to further demonstrate compliance with the performance

criteria specified in the design. Regular geotechnical monitoring interpretation

and reporting by the Project’s Geotechnical Engineers will be completed by

the Alliance during construction. This will include detailed monitoring data on

ground movements, groundwater and porewater pressures and variations in

the characteristics, including strength gain, of underlying materials. The

reports will provide a comparison of monitored results against the baseline

design predictions.

102. In assessing the potential impacts on existing wind turbine foundations,

conservative assumptions were adopted for the ground model including

lithology, strength, stiffness and groundwater profile. Finite element analysis

was undertaken using the Plaxis software, which is widely used by industry.

103. Conservative assumptions were adopted for the proposed ground profiles

adjacent to wind turbine foundations (i.e. for cuttings and fill embankments).

This methodology was adopted to give high levels of confidence in the

assessment outcomes. The worst-case maximum cutting depth of 60m (at

CH 6340) and the maximum 30m fill embankment height (at CH 6800) were

used for the analysis. These assumptions were used to develop generic

geotechnical exclusion zones (40m or 60m from the edge of proposed

earthworks). Where wind turbine foundations fall within an exclusion zone,

more location specific earthworks profiles and geology were used to assess

potential impacts on wind turbine foundations. An example is TAP09, where

the actual localised earthworks geometry of the cut profile was used for the

analysis (i.e. 16m deep cut).

104. A summary of this geotechnical analysis is shown below.

Ground movements at turbine locations from open cuts

105. Ground surface movements of less than 5mm are predicted at the selected

wind turbine locations due to the proposed main open cut earthworks (refer

to the summary Table below). This includes both excavation-induced

movements due to stress release and consolidation settlements due to

groundwater drawdown. Such movements are considered relatively low and

are typically less than the movements occurring currently, which are

associated with seasonal ground movement fluctuations.

106. Critical slip scenarios associated with the cut slopes have been assessed

and do not present any risk to wind turbine foundations.

107. Creep movements are anticipated to be a shallow phenomenon restricted to

the top few metres of ground and are primarily controlled by slope gradient

and near surface ground conditions. By inspection of the topographical

contours, the ground surfaces between the relevant cut crests and nearby

wind turbines are relatively flat and as such creep effects generated by the

open cuts are anticipated to be very small. In respect of wind turbine TAP063

the ground is steeper; however, this wind turbine is located on the other side

of a ridge so any creep associated with the open cut will not transfer to the

wind turbine.

108. As described above, the Alliance will undertake instrumentation and

monitoring during construction to verify that any ground movements due to

3 TAP06 is shown on sheet 6 of the General Arrangement Plans in the plan set; drawing TAT 3 DG R 0106 – Rev C.

the earthworks do not affect any wind turbine’s stability or operations. In the

unlikely event that the monitoring data indicates ground movements larger

than expected during construction, in the vicinity of the wind turbines, advice

will be provided by the Project’s Geotechnical Engineers on any mitigations

in collaboration with the construction team and Meridian.

Ground movements induced from embankment loading

109. From inspection of the plan layout, wind turbine locations are at least 25m

from any proposed embankments of significant height. Ground settlements

generated from embankments are therefore predicted to be less than 5mm.

Ground movements induced from seismic loading

110. Very small ground surface movements induced by seismic loading4 for the

existing ground profile (i.e. with no proposed earthworks), have been

predicted at wind turbine TAP09. This is the closest wind turbine to the

mainline open cut. Additional ground surface movement, due to potential

seismic loading, with the presence of the proposed cutting is predicted to be

negligible in magnitude (

114. An extensive programme of instrumentation and monitoring will be

implemented to monitor any ground movements during and after

construction.

115. A summary of the findings is also tabulated below. The results show that the

effects of the Project’s earthworks on existing wind turbine foundations are

negligible and well within any minor movements of the ground that may be

experienced by the turbine foundations due to normal seasonal fluctuations.

Cuttings

Wind Turbine

Chainage (m)

Offset in Plan (m) from main earthworks

Main earthworks approximate cut depth

Predicted movement at wind turbine locations

TAP03 5950 95m south 30m cut

TAP46 9100 28 50

Landscaping

118. Meridian also raised a query regarding the landscaping on the wind farm and

states that its preference is that there is no landscape planting on earthworks

associated with the Te Āpiti works. Meridian accepts, however, that it is

possible to grass earthworks and stream channels to protect the channels

from erosion and ensure habitat for fish.

119. To address these concerns, I highlight that designation condition 17

(Landscape Management Plan) requires the planting proposed to have

regard to the outcomes of consultation with Meridian (designation condition

17(b)(ii). In addition, designation condition 19 (Planting Establishment

Management Plan) stipulates that landscape planting can only be undertaken

if it is within the designation boundary and less than 1.5 metres in height,

unless it is for the purpose of the restoration of QEII covenants or Meridian

provides the Transport Agency with its written consent to such planting.

120. The detailed design and implementation of any landscape planting will be

carried out in accordance with those conditions.

121. Dr Baber and Ms Quinn address in their evidence Meridian’s submission as it relates to wetland and riparian planting in the vicinity of the Te Āpiti Wind

Farm.

John Bent

122. Paragraph 8 of Mr Bent’s submission (submission number 18 and a section

274 party to proceedings) raises one matter regarding the design and

construction of structures. The submission seeks that:

"structures proposed for the construction phase be designed and

constructed to provide long term environmental benefit without further

modification or additions”.

123. In response to the above point, I can confirm that all bridge structures across

the Project will be designed in accordance with industry best practice,

including the Transport Agency’s Bridge Manual. All bridges will have a

design life of 100 years, and all bridge structures along the main Project

alignment will be designed to accommodate a width suitable for four traffic

lanes (so will not need to be modified in the future). Bridge structures,

notably BR02 (the Manawatū River Bridge) and BR03 (the Eco Bridge

immediately to the north of BR02), have been designed using a ‘tread lightly’

approach regarding the environment. This has been achieved through

optimising the overall lengths of these structures (including span lengths and

pier locations) to avoid areas of high ecological value and cultural

significance.

124. Stormwater management related matters are discussed in Mr Hughes’ evidence.

COMMENTS ON SECTION 87F REPORT

125. The section 87F report does not discuss design matters at length. However,

in paragraph 73, Mr St Clair addresses Meridian’s submission points

regarding the geotechnical matters raised in relation to the route and the

proposed works through the Te Āpiti Wind Farm.

126. These matters in Meridian’s submission have been covered earlier in my

evidence. However, I note that Mr St Clair has recommended a new

condition of consent (LD4a) to address geotechnical matters, and to require

the provision of reports and information to Horizons. The condition proposed

by Mr St Clair states:

(a) All cut and fill sites including the “Spoil Sites” identified on Drawings

TAT-3-DG-R-0100-C to TAT-3-DG-R-540-B (inclusive) and Drawings

TAT-3-DG-G-1251-C to TAT-3-DG-G-1257-C (inclusive) and Drawings

TAT-3-DG-C-3640-A to TAT-3-DG-G-3650-A (inclusive) within Volume

III of the Assessment of Environmental Effects for Te Ahu a Turanga -

Manawatū Tararua Highway, and any other approved fill disposal areas

within the project site must be designed to normally accepted

engineering requirements including normally recognised factors of

safety for stability. All such fill disposal sites must be designed so that

there are no adverse effects on land beyond the Designation Boundary

or the boundary of the Spoil Sites Drawings TAT-3-DG-C-3640-A to

TAT-3-DG-G-3650-A (inclusive).

(b) At least forty (40) working days prior to the commencement of

construction activities for the Project, the consent holder must submit to

the Manawatū-Whanganui Regional Council a schedule of cut and fill

sites to which condition LD4a a) must apply. These sites must be those

more significant cuts and fills that could pose a hazard or environment

risk from instability if not appropriately constructed. The sites must

include the main spoil disposal sites.

(c) At least twenty (20) working days prior to the commencement of works

within each cut and fill identified in the schedule provided under

condition LD4a b), the consent holder must submit to the Manawatū-

Whanganui Regional Council a geotechnical design assessment,

prepared by a suitably qualified and experienced geotechnical

engineer, to confirm that the cut and fill activities will include

appropriate drainage and will not result in instability at those sites either

during or after Project construction.

(d) Within forty (40) working days of completion of each cut and fill

identified in the schedule provided under condition LD4a b), the

consent holder must submit to the Manawatū-Whanganui Regional

Council a geotechnical report, prepared by a suitably qualified and

experienced geotechnical engineer, to confirm that the cut and fill

activities have been constructed in accordance with the detailed design

reported on through condition LD4a c).

127. In my view a further condition of consent is not required for geotechnical

matters. The stability of the works and quality of the Project are matters that

are critical to its delivery and accordingly are governed by Transport Agency

specifications for such infrastructure. In particular, the design must be

completed in accordance with the Transport Agency Bridge Manual and the

MRs.

128. A brief summary of the design and verification process (which is described in

Schedule 5 to the MRs) is included below:

(a) The geotechnical design is undertaken by a team of Professional

Geotechnical Engineers and Geologists. They are part of the Alliance

design team and supported by the construction team, other engineering

disciplines, and the Transport Agency’s relevant subject matter experts.

(b) Design preparation goes through a number of ‘design gates’ to ensure

it is reviewed at critical stages prior to completion. This includes

reviews by the construction team and senior geotechnical professionals

(but who are outside the day-to-day design team), and Transport

Agency experts.

(c) The design is also peer reviewed by independent professional

engineers, who are not from the Alliance Participant Organisations.

(d) Design (PS1) and Design Review (PS2) Producer Statements are

provided by the Alliance’s Designer and Independent Peer Reviewer

respectively to confirm that the above process has been undertaken

satisfactorily.

(e) Temporary Works Producer Statements are required for the design of

any temporary works, including support to excavations over 1.5m deep.

The temporary works design and design check must be carried out by

suitably qualified persons, with appropriate skill and experience. The

design check must be undertaken by someone independent of the

Alliance.

(f) Issue for Construction ("IFC") documentation (e.g. drawings and specifications) are released when the PS1 and PS2 Producer

Statements have been completed. Acceptance from the relevant

Transport Agency expert is also required prior to the IFC stage.

(g) As noted above and required by the Project MRs, during construction

the Alliance will provide regular monitoring reports to the Transport

Agency for the geotechnical elements of the works.

(h) The Alliance will also provide Construction Producer Statements (PS3),

signed by the Constructor, on completion of each element of the works.

(i) The Alliance will also provide Construction Review Producer

Statements (PS4), signed by the Alliance Project Manager and

Designer’s Representative. The PS4 confirms that the construction has

been undertaken in accordance with the approved design.

129. As such, there are robust processes to ensure that the Project will be well

constructed and resilient to risks of slope instability.

Timothy John Watterson

12 June 2020

ATTACHMENT TW.1 – UPDATED CONSENTING DRAWINGS

An inventory of amendments to the consenting drawings is provided overleaf. The

updated consenting drawings are provided separately.

Drawing Changes Inventory

Drawing Number Drawing Name Key Changes

General

TAT-3-DG-R-0001 – D Cover Sheet and Locality Plan Updated to show overall changes on the Locality Plan

TAT-3-DG-R-0002 – D Drawing Index Drawings which are subject to change have been clouded.

TAT-3-DG-R-0010 – B Enabling Works – Overview Plan Eastern Roundabout

Removal of Spoil site 15

Geometrics

TAT-3-DG-R-0100 – D General Arrangement – Key Plan Eastern Roundabout


TAT-3-DG-R-0110 – D General Arrangement – Sheet 10 Removal of Spoil site 15

TAT-3-DG-R-0116 – D General Arrangement – Sheet 16 Eastern Roundabout showing four leg design

TAT-3-DG-R-0506 – D Plan and Long Section – State Highway (MC00) – Sheet 6 Removal of Spoil site 15

TAT-3-DG-R-0509 – D Plan and Long Section – State Highway 3 (MC00) – Sheet 9

Eastern Roundabout showing four leg design

Stormwater

TAT-3-DG-H-1406 – D Stormwater Drainage Layout Plan – Sheet 6 Stream diversions are now cut off drains in Spoil Site 25

TAT-3-DG-H-1407 – D Stormwater Drainage Layout Plan – Sheet 7 Stream diversions are now cut off drains in Spoil Site 25, between AC-04 and CU-06, and north of CU-07.

TAT-3-DG-H-1409 – D Stormwater Drainage Layout Plan – Sheet 9 Stream diversions are now cut off drains in Spoil Site 28

TAT-3-DG-H-1410 – D Stormwater Drainage Layout Plan – Sheet 10 Removal of Spoil Site 15

Stream diversions are now cut off drains in Spoil Site 28 and 16

TAT-3-DG-H-1416 – C Stormwater Drainage Layout Plan – Sheet 16 Eastern Roundabout showing four leg design, including change to the design of CU-18 and CU-18A and CU018B removed.

Removal of WS06, and WS10, change in location of WS09.

Removal of TS07

Removal of SD-MC20-01, SD-MC18A-01 and SD-MC18B-01, and inclusion of stream diversion SD-28

TAT-3-GD-H-1434 – B Stormwater Management Devices – Catchment Plan – Sheet 1

Updates to the wetland summary table to reflect stormwater management device changes over the 4-leg Eastern Roundabout design.

TAT-3-GD-H-1437 – B Stormwater Management Devices – Catchment Plan – Sheet 4


TAT-3-DG-H-1439 – B Stormwater Management Devices – Catchment Plan – Sheet 6;

Stormwater designs changes due to Eastern Roundabout four leg design

TAT-3-DG-H-1440 – D Cross Culverts – Catchment Overview Plan Removed CU-18A and CU-18B from schedule

TAT-3-DG-H-1441 – D Cross Culvert Schedule Removed CU-18A and CU-18B from schedule

Change in fish passage requirements for CU-10 and CU-13.

Structures

TAT-3-DG-S-2100 – D Bridge Location Plan Eastern Roundabout f


Temporary Works

TAT-3-DG-C-3610 – D Accommodation Works – Sheet 10 Spoil site 15 removed

TAT-3-DG-C-3616 – D Accommodation Works – Sheet 16 Eastern Roundabout showing four leg design

Spoil Sites

TAT-3-DG-C-3640 – A Spoil Sites – Key Plan Eastern Roundabout


TAT-3-DG-C-3644 – B Spoil Sites – Sheet 4 Removal of Spoil site 15

Erosion and Sediment Control

TAT-3-DG-E-3810 – B Concept Erosion and Sediment Control Bulk Earthworks (Main Alignment) Sheet 10


TAT-3-DG-E-3816 – B Concept Erosion and Sediment Control – Bulk Earthworks (Main Alignment) – Sheet 16

Eastern Roundabout showing four leg design

Ecology

TAT-3-DG-E-4100 – B Waterways and Catchments – Overview Plan Eastern Roundabout and Spoil Site 15

TAT-3-DG-E-4134 – B Terrestrial Ecosystems Plan – Sheet 4 Removal of Spoil site 15

TAT-3-DG-E-4136 – B Terrestrial Ecosystems Plan – Sheet 6 Eastern Roundabout showing four leg design

TAT-3-DG-E-4143 – B Freshwater Ecosystems Plan – Sheet 3 Planted stream diversions removed in Spoil Site 25

Planted stream diversions removed between AC-04 and CU-06, and north of CU-07

TAT-3-DG-E-4144 – B Freshwater Ecosystems Plan – Sheet 4 Removal of Spoil site 15

Planted stream diversions removed in Spoil site 28 and 16

TAT-3-DG-E-4146 – B Freshwater Ecosystems Plan – Sheet 6 Eastern Roundabout now four leg design

TAT-3-DG-E-4150 – B Proposed Ecological Offset/Compensation – Overview Plan

Eastern Roundabout four leg design


TAT-3-DG-E-4153 – B Proposed Ecological Offset/Compensation Plan – Sheet 3 Removal of stream diversions planting at Spoil Site 25, replaced with landscape planting

Streams diversion riparian planting reduced to 10m replaced with landscape planting

TAT-3-DG-E-4154 – B Proposed Ecological Offset/Compensation Plan – Sheet 4 Streams diversion planting on Spoil site 28 and 16, replaced with landscape planting.

Spoil site 15 and stream diversion removed

Streams diversion riparian planting reduced to 10m, landscape planting instead.

TAT-3-DG-E-4156 – A Proposed Ecological Offset/Compensation Plan – Sheet 6 Eastern Roundabout showing four leg design

Woodville

Ashhurst

Filen

ame:

Plot

Date:

Offic

e:\\1

0.209

.203.3

1\FAS

TDAT

A\NZ

CITR

US\C

IFSM

GMT0

1-A.

HEBC

ON.N

Z\AL

LIANC

ES$\M

ANAW

ATU

TARA

RUA

HIGH

WAY

\IPAA

PHA

SE\05

TEC

HNIC

AL –

DESI

GN W

ORKI

NG A

REA\

DRAF

TING

\DEL

IVER

DES

IGN\

2 DRA

WIN

G\_D

RAW

INGS

\3_CO

NCEP

T AN

D CO

NSEN

TING

\TAT

-3-D

G-R-

0001

.DW

GDC

APA

2020

-06-

05 12

:24:56

LOCALITY PLAN

DRAWING No.DATESIZE

A1PROJECT No. TYPE REVAREA DISC NUMBER

Te Ahu a TurangaManawatū Tararua Highway

CONSENTNOT FOR CONSTRUCTION

TAT 3 DG R 0001 D12/06/2020

PROJECT LOCATION

WAKA l

DATE TITLE

REVISION DETAILSDATEREV APPROVED

REVIEWED

APPROVED

PROJECT

DRAWN

DESIGNED

PROJECT No. TYPE REVPHASE DISC NUMBER DRAWING No.

SCALE SIZEA1

.

CLIENT TE AHU A TURANGA: MANAWATŪ TARARUA HIGHWAY

TAT 3

DRAWING INDEX

TAT 3 DG R 0002 D

NOT TO SCALECONSENT

NOT FOR CONSTRUCTION

C. LANE

-

D. MACKINTOSH

D 12/06/2020 ISSUED FOR REGIONAL CONSENT D. McGAHANC 24/02/2020 ISSUED FOR REGIONAL CONSENT D. McGAHANB 19/11/2019 ISSUED FOR CONCEPT DESIGN D. MACKINTOSHA 18/10/2019 CONCEPT DESIGN - DRAFT REVIEW D. MACKINTOSH

Filen

ame:

Plot

Date:

Offic

e:Z:

\MAN

AWAT

U TA

RARU

A HI

GHW

AY\IP

AA P

HASE

\05 T

ECHN

ICAL

– DE

SIGN

WOR

KING

ARE

A\DR

AFTI

NG\D

ELIV

ER D

ESIG

N\2 D

RAW

ING\

_DRA

WIN

GS\3_

CONC

EPT

AND

CONS

ENTI

NG\T

AT-3

-DG-

R-00

02.D

WG

NZAK

L20

20-0

6-10

11:32

:13

DRAWING INDEXDRG No. TITLEREVGENERALTAT-3-DG-R-0001 D COVER SHEET & LOCALITY PLANTAT-3-DG-R-0002 D DRAWING INDEX

TAT-3-DG-R-0010 B ENABLING WORKS - OVERVIEW PLAN

GEOMETRICSTAT-3-DG-R-0100 D GENERAL ARRANGEMENT - KEY PLAN

TAT-3-DG-R-0101 C GENERAL ARRANGEMENT PLAN - SHEET 1TAT-3-DG-R-0102 C GENERAL ARRANGEMENT PLAN - SHEET 2TAT-3-DG-R-0103 C GENERAL ARRANGEMENT PLAN - SHEET 3

TAT-3-DG-R-0104 C GENERAL ARRANGEMENT PLAN - SHEET 4TAT-3-DG-R-0105 C GENERAL ARRANGEMENT PLAN - SHEET 5


TAT-3-DG-R-0109 C GENERAL ARRANGEMENT PLAN - SHEET 9TAT-3-DG-R-0110 D GENERAL ARRANGEMENT PLAN - SHEET 10


TAT-3-DG-R-0114 C GENERAL ARRANGEMENT PLAN - SHEET 14TAT-3-DG-R-0115 C GENERAL ARRANGEMENT PLAN - SHEET 15

TAT-3-DG-R-0116 D GENERAL ARRANGEMENT PLAN - SHEET 16TAT-3-DG-R-0117 C GENERAL ARRANGEMENT PLAN - SHEET 17TAT-3-DG-R-0121 C GENERAL ARRANGEMENT PLAN - SHEET 21

TAT-3-DG-R-0201 C TYPICAL CROSS SECTIONS - SHEET 1

TAT-3-DG-R-0202 C TYPICAL CROSS SECTIONS - SHEET 2TAT-3-DG-R-0203 C TYPICAL CROSS SECTIONS - SHEET 3

TAT-3-DG-R-0204 C TYPICAL CROSS SECTIONS - SHEET 4TAT-3-DG-R-0205 C TYPICAL CROSS SECTIONS - SHEET 5TAT-3-DG-R-0206 C TYPICAL CROSS SECTIONS - SHEET 6

TAT-3-DG-R-0501 C PLAN AND LONG SECTION - STATE HIGHWAY 3 (MC00) - SHEET 1

TAT-3-DG-R-0502 C PLAN AND LONG SECTION - STATE HIGHWAY 3 (MC00) - SHEET 2TAT-3-DG-R-0503 C PLAN AND LONG SECTION - STATE HIGHWAY 3 (MC00) - SHEET 3

TAT-3-DG-R-0504 C PLAN AND LONG SECTION - STATE HIGHWAY 3 (MC00) - SHEET 4TAT-3-DG-R-0505 C PLAN AND LONG SECTION - STATE HIGHWAY 3 (MC00) - SHEET 5

TAT-3-DG-R-0506 D PLAN AND LONG SECTION - STATE HIGHWAY 3 (MC00) - SHEET 6TAT-3-DG-R-0507 C PLAN AND LONG SECTION - STATE HIGHWAY 3 (MC00) - SHEET 7TAT-3-DG-R-0508 C PLAN AND LONG SECTION - STATE HIGHWAY 3 (MC00) - SHEET 8

TAT-3-DG-R-0509 D PLAN AND LONG SECTION - STATE HIGHWAY 3 (MC00) - SHEET 9

TAT-3-DG-R-0530 C PLAN AND LONG SECTION - MERIDIAN ACCESS (MCW0) - SHEET 1TAT-3-DG-R-0531 C PLAN AND LONG SECTION - MERIDIAN ACCESS (MCW0) - SHEET 2

TAT-3-DG-R-0532 C PLAN AND LONG SECTION - MERIDIAN ACCESS (MCW0) - SHEET 3TAT-3-DG-R-0533 C PLAN AND LONG SECTION - MERIDIAN UNDERPASS (MCX0)TAT-3-DG-R-0534 C PLAN AND LONG SECTION - MERIDIAN ACCESS (MCY0)

TAT-3-DG-R-0535 C PLAN AND LONG SECTION - MERIDIAN ACCESS (MCY1)TAT-3-DG-R-0536 C PLAN AND LONG SECTION - MERIDIAN ACCESS (MCY2)

TAT-3-DG-R-0537 B PLAN AND LONG SECTION - MERIDIAN ACCESS (MCY3)TAT-3-DG-R-0538 B PLAN AND LONG SECTION - MERIDIAN ACCESS (MCW1 & MCW2)TAT-3-DG-R-0539 B PLAN AND LONG SECTION - MERIDIAN ACCESS (MCX1)

TAT-3-DG-R-0540 B PLAN AND LONG SECTION - MERIDIAN ACCESS (MCX2)

GEOTECHNICALTAT-3-DG-G-1251 C EARTHWORKS TYPICAL DETAILS - SHEET 1

TAT-3-DG-G-1252 C EARTHWORKS TYPICAL DETAILS - SHEET 2TAT-3-DG-G-1253 C EARTHWORKS TYPICAL DETAILS - SHEET 3

TAT-3-DG-G-1254 C EARTHWORKS TYPICAL DETAILS - SHEET 4TAT-3-DG-G-1255 C EARTHWORKS TYPICAL DETAILS - SHEET 5TAT-3-DG-G-1256 C EARTHWORKS TYPICAL DETAILS - SHEET 6

TAT-3-DG-G-1257 C EARTHWORKS TYPICAL DETAILS - SHEET 7

STORMWATERTAT-3-DG-H-1401 C STORMWATER DRAINAGE LAYOUT PLAN - SHEET 1TAT-3-DG-H-1402 C STORMWATER DRAINAGE LAYOUT PLAN - SHEET 2

TAT-3-DG-H-1403 C STORMWATER DRAINAGE LAYOUT PLAN - SHEET 3TAT-3-DG-H-1404 C STORMWATER DRAINAGE LAYOUT PLAN - SHEET 4TAT-3-DG-H-1405 C STORMWATER DRAINAGE LAYOUT PLAN - SHEET 5

TAT-3-DG-H-1406 D STORMWATER DRAINAGE LAYOUT PLAN - SHEET 6TAT-3-DG-H-1407 D STORMWATER DRAINAGE LAYOUT PLAN - SHEET 7

TAT-3-DG-H-1408 C STORMWATER DRAINAGE LAYOUT PLAN - SHEET 8TAT-3-DG-H-1409 D STORMWATER DRAINAGE LAYOUT PLAN - SHEET 9TAT-3-DG-H-1410 D STORMWATER DRAINAGE LAYOUT PLAN - SHEET 10

TAT-3-DG-H-1411 C STORMWATER DRAINAGE LAYOUT PLAN - SHEET 11TAT-3-DG-H-1412 C STORMWATER DRAINAGE LAYOUT PLAN - SHEET 12

TAT-3-DG-H-1413 C STORMWATER DRAINAGE LAYOUT PLAN - SHEET 13TAT-3-DG-H-1414 C STORMWATER DRAINAGE LAYOUT PLAN - SHEET 14TAT-3-DG-H-1415 C STORMWATER DRAINAGE LAYOUT PLAN - SHEET 15

TAT-3-DG-H-1416 D STORMWATER DRAINAGE LAYOUT PLAN - SHEET 16TAT-3-DG-H-1417 C STORMWATER DRAINAGE LAYOUT PLAN - SHEET 17

TAT-3-DG-H-1421 C STORMWATER DRAINAGE LAYOUT PLAN - SHEET 21

TAT-3-DG-H-1434 A STORMWATER MANAGEMENT DEVICES - CATCHMENT PLAN - SHEET 1TAT-3-DG-H-1435 A STORMWATER MANAGEMENT DEVICES - CATCHMENT PLAN - SHEET 2

TAT-3-DG-H-1436 A STORMWATER MANAGEMENT DEVICES - CATCHMENT PLAN - SHEET 3TAT-3-DG-H-1437 B STORMWATER MANAGEMENT DEVICES - CATCHMENT PLAN - SHEET 4TAT-3-DG-H-1438 A STORMWATER MANAGEMENT DEVICES - CATCHMENT PLAN - SHEET 5

TAT-3-DG-H-1439 B STORMWATER MANAGEMENT DEVICES - CATCHMENT PLAN - SHEET 6

TAT-3-DG-H-1440 D CROSS CULVERTS - CATCHMENT OVERVIEW PLANTAT-3-DG-H-1441 D CROSS CULVERTS - SCHEDULE

TAT-3-DG-H-1450 C TYPICAL STORMWATER DRAINAGE DETAILS - NETWORK DRAINAGE, CHANNELS ANDBASINS

TAT-3-DG-H-1451 C TYPICAL STORMWATER DRAINAGE DETAILS - STREAM DIVERSIONS AND CUT-OFFDRAINS

TAT-3-DG-H-1452 C TYPICAL STORMWATER DRAINAGE DETAILS - CROSS CULVERTSTAT-3-DG-H-1453 C TYPICAL STORMWATER DRAINAGE DETAILS - WETLAND

STRUCTURESTAT-3-DG-S-2100 D BRIDGE LOCATION PLANTAT-3-DG-S-2101 C UNDERPASS STRUCTURE (BR01, BR05 & BR06) - TYPICAL PLAN & SECTIONS

TAT-3-DG-S-2201 C BR02 - MANAWATŪ RIVER BRIDGE - PLAN & ELEVATION

TAT-3-DG-S-2301 C BR03 - ECO BRIDGE - PLAN & ELEVATION

TAT-3-DG-S-2701 C BR07 - MANGAMANIA STREAM CROSSING BRIDGE - PLANTAT-3-DG-S-2702 C BR07 - MANGAMANIA STREAM CROSSING BRIDGE - ELEVATION & TYPICAL CROSS

SECTION

TEMPORARY WORKSTAT-3-DG-C-3601 B ACCOMMODATION WORKS - SHEET 1TAT-3-DG-C-3602 B ACCOMMODATION WORKS - SHEET 2TAT-3-DG-C-3603 B ACCOMMODATION WORKS - SHEET 3

TAT-3-DG-C-3604 B ACCOMMODATION WORKS - SHEET 4TAT-3-DG-C-3605 B ACCOMMODATION WORKS - SHEET 5

TAT-3-DG-C-3606 B ACCOMMODATION WORKS - SHEET 6TAT-3-DG-C-3607 B ACCOMMODATION WORKS - SHEET 7TAT-3-DG-C-3608 B ACCOMMODATION WORKS - SHEET 8

TAT-3-DG-C-3609 B ACCOMMODATION WORKS - SHEET 9TAT-3-DG-C-3610 D ACCOMMODATION WORKS - SHEET 10

TAT-3-DG-C-3611 B ACCOMMODATION WORKS - SHEET 11TAT-3-DG-C-3612 B ACCOMMODATION WORKS - SHEET 12TAT-3-DG-C-3613 B ACCOMMODATION WORKS - SHEET 13

TAT-3-DG-C-3614 B ACCOMMODATION WORKS - SHEET 14TAT-3-DG-C-3615 B ACCOMMODATION WORKS - SHEET 15

TAT-3-DG-C-3616 D ACCOMMODATION WORKS - SHEET 16

SPOIL SITESTAT-3-DG-C-3640 B SPOIL SITES - KEY PLANTAT-3-DG-C-3641 A SPOIL SITES - SHEET 1

TAT-3-DG-C-3642 A SPOIL SITES - SHEET 2TAT-3-DG-C-3643 A S

Documents

WELLINGTON REGISTRY I MUA I TE KŌTI TAIAO O AOTEAROA TE ... · Project’s earthworks on existing wind turbine foundations (within the Te Āpiti Wind Farm) that are located in the