UNDER the Resource Management Act IN THE MATTER

Transcription

1 BOARD OF INQUIRY BASIN BRIDGE PROPOSAL UNDER the Resource Management Act IN THE MATTER of a Board of Inquiry appointed under s149j of the Resource Management Act 1991 to consider applications for a notice of requirement and resource consents made by the New Zealand Transport Agency in relation to the Basin Bridge. 22 MAY

2 Contents 1. Introduction 3 2. How A Basin Reserve Flyover Would Affect Me 3 3. Cricket Matters 4 4. Why The Basin Bridge Proposal Should Not Proceed 7 5. Conclusion 9 2

3 1. Introduction 1.1 My name is Timothy Jones. I am a resident of Mt Victoria. I am making this submission in my capacity as an individual submitter. I am opposed to the project. 1.2 This representation covers my personal reasons for opposing the proposal, the threat the project poses to the future of Test and domestic cricket at the Basin Reserve, and explains why I believe the project should not proceed. 2. How a Basin Reserve Flyover Would Affect Me 2.1 I am a resident of Ellice St, Mt Victoria. I have lived in Ellice St since 1993 with my wife Kay Jones and, from 1996, our son. The Basin Reserve and the Town Belt, one below us and one above us, are two iconic features of the neighbourhood in which we take pleasure. 2.2 The proposed flyover would be directly visible from Ellice St and from the front of our property. It would significantly lower the amenity and aesthetic value of Ellice St and the Basin Reserve precinct as a whole, by placing a dominant and inappropriate structure front and centre in the view from Ellice St, and the wider view of the Basin Reserve from the Town Belt. 2.3 No matter how many concept images filled with pictures of attractive young people lounging under the flyover on a warm summer s day NZTA chooses to commission, real-world experience demonstrates that motorway flyovers are massive, ugly magnets for crime, graffiti and people living rough and seeking shelter. Placing a flyover in the middle of this important area for pedestrains and cyclists will lower both the real and the perceived safety of the neighbourhood, espcially at night. 2.4 I am a keen pedestrian who often walks through the Basin Reserve precinct, principally during the day but sometimes at night. Family members also walk through this precinct, and my son was up until this year one of the thousands of school students who attend schools in the vicinity of the Basin Reserve and/or pass through the precinct on their way to and from school. I do not want to walk, and I would prefer that family members not walk, eitther under 3

4 the flyover, or on the sub-standard, narrow, exposed and potentially dangerous shared pedestrian/cycleway that is proposed. 2.5 I have been awoken at night several times recently by the noise and vibration of construction at Memorial Park. The lengthy construction period of the proposed flyover would lead to much greater disruption by noise and vibration, with adverse consequence for the health of myself and my family. 2.6 I have been following cricket for forty years, played lower-grade club cricket in Dunedin and Wellington, and watched my first Basin Reserve Test in I have attended many Basin Reserve Tests held since then, witnessing memorable New Zealand victories and individual performances. I have also attended men s and women s one-day internationals held at the Basin Reserve, and domestic provincial and club cricket matches held there. Anything which lowers the amenity and cricket values of the Basin Reserve, or threatens the future of the Basin Reserve as a Test cricket ground in particular, is of great concern to me. It is clear from cricket evidence that there are risks to the future of the Basin Reserve from the project in terms of spectator reaction, player reaction, and possible action by the game s authorities. 4

5 3. Cricket Matters 3.1 As noted in 2.6 above, I am a keen cricket follower and watch cricket, especially Test cricket, at the Basin Reserve whenever other commitments permit. I greatly value the ambience of the Basin Reserve, which stands in such marked constrast to the concrete bowl of Wellington Stadium an excellent venue for the various football codes, but a poor venue for cricket, in particular long-form cricket. 3.2 It is widely acknowledged, and has been stated by cricket expert witnesses at this hearing, that the Basin Reserve is New Zealand s premier Test ground. However, the Basin Reserve faces threats to that status both from the development of other boutique Test grounds in New Zealand, and from the recent seizure of power in the International Cricket Council by the big three of India, England and Australia three countries which have previously shown disregard for the welfare of Test cricket in New Zealand, and which have little incentive to want to tour here. India, the most lucrative of the visiting countries for New Zealand cricket due to the television rights income their tours generate, has been especially reluctant to tour, or to play three-test series. In this context, placing the Basin Reserve s future as a Test cricket ground, both in the formal sense of its ICC accreditation and the informal sense of players and spectators opinion on the ground, seems both unwise and unjustified. 3.3 All six cricket expert witnesses who provided evidence to the Board of Inquiry have expressed concerns about the effects of the proposal on the ground. The range of concerns has included such matters as the effect on the ambience of the ground and on spectator enjoyment; visual distraction of players, match officials and spectators; and the risk the project poses to the Basin Reserve s ICC accreditation as Test ground, either directly as a consequence of an ICC review of the project s status, or indirectly as a result of player reaction. 3.4 Under cross-examination, cricket witness Mr Snedden said that an unmitigated flyover would be hideous and imposing [1] and an unmitigated flyover is what spectators and players approaching the northern entrance to the ground would see. 5

6 3.5 In his evidence, Mr Neely noted, and provided examples to demonstrate, that if a flyover was built, the Basin Reserve would become the only Test ground wholly or partly surrounded by an elevated roadway (see Neely, EIC, 1.13 and Appendices). 3.6 Again under cross-examination, Ms Wraight, appearing for the applicant, agreed that the proposed mitigation measures provided only partial screening of the proposed flyover [2], and that even this partial screening would not be fully in place for 5-10 years after the completion of the project. 3.7 A number of cricket witnesses emphasised that the spectator appeal of the Basin Reserve depended in large part on its character as a green, tree-lined space. The proposed Northern Gateway Building, which experts in urban design, landscape and visual matters agreed should not be built at the proposed location if the project did not go ahead, would lessen this character of the ground. The sight of moving traffic on the flyover from spectator areas would further lessen it. As noted by Mr Clinton (1.43), this may cause spectators to decide not to attend games and other events at the Basin, with consequential effects on the financial viability of the ground. 3.8 The NZ Transport Agency has characterised the view of traffic through the current and proposed additional trees to the east of the proposed Northern Gateway Building as glimpses through the trees (Lister, EIC, 5.8, p. 19). However, such glimpses would in fact provide exactly the sort of intermittent sudden visual distraction highlighted by Mr Snedden in his evidence (Snedden, EIC, 1.23c, pp 6-7). It is yet to be demonstrated that temporary visual mitigation could adequately solve this problem, especially in high wind conditions. 3.9 Perhaps the most significant risk to the future of the ground is one that derives from the construction of the project itself, including the proposed mitigation at the ground. This is the risk that the project, and/or the proposed mitigation, will trigger an assessment by the ICC of the Basin Reserve s status as an international cricket ground. The Basin Reserve has not previously had to undergo such an assessment because it was grandparented into Test status, and as Mr Clinton notes in his evidence (Clinton, EIC, 1.41, p. 10), it is not clear that Basin would pass such an assessment. As Sir John Anderson explained in his evidence, the project and asociated mitigation work may 6

7 trigger such an assessment, the outcome of which is unknown, and has subjective elements (Anderson, EIC, 1.34, p. 9). If the level of mitigation achieved is deemed inadequate, or if other issues at the ground cause it to fail to pass the assessment, the ground could lose its Test status in the short or even long term Against the background of developments in international cricket politics which further marginalise New Zealand and other comparatively small Testplaying countries, and which have seen countries who are reluctant to tour here (or play full three-test series when they do) amass greater power within the ICC, I consider it foolhardy to go ahead with a project which could put the future of the ground at risk especially when making changes at grade would not trigger such an assessment, would not require extensive mitigation which has various advverse effects, and would not put the future of the ground at risk. 4. Why The Basin Bridge Proposal Should Not Proceed 4.1 In my view, the Basin Bridge proposal is irremediably flawed in a number of respects. The first and most fundamental of these flaws is that it is neither appropriate nor necessary to build a motorway flyover at the Basin Reserve. A flyover would despoil an iconic part of Wellington that is important to New Zealand at a local, national and international level The Basin Reserve precinct is one of Wellington s crown jewels, with the Kent/Cambridge promenade, the Basin Reserve itself, Government House and grands and the new National War Memorial Park in close proximity The area is of importance to New Zealand both because Government House and the processional route to Government House are copntained within it, and because the Basin Reserve is New Zealand s premier Test cricket ground. Also, Wellington as both a city and a national capital needs to present a good impression to international visitors. Showing that the nation s concept of transport planning has not advanced beyond building flyovers is the antithesis of this. 7

8 4.1.3 Internationally, the Basin Reserve is regarded as one of the world s leading cricket grounds, and thus its future is of concern to cricket fans worldwide, as evinced by the coverage the leading cricket website Cricinfo has given to the Basin Reseve flyover issue. 4.2 A contributing factor is the NZTA s flawed approach to transport planning, which fails to take into account strong international and New Zealand signals that we live in a world in which the future of mobility and access is diverging radically from the assumptions on which NZTA s planning has been based There is evidence from all around the world that young people in particular are turning away from driving and from private motor vehicle ownership. This phenomenon is evident in New Zealand both in traffic statistics, and the steep decline in the uptake of driver licences by young people. While part of this can be accounted for by changes in driver licensing rules, it is copnsistent with the worldwide trend NZTA appears either to be unaware of this trend, or to have failed to apply it to their transport modelling. Their planning appears to operate on a business as usual basis which assumes that the answer to more people is more cars, and the answer to more cars is more roads. NZTA gives lip service to the notion of a multi-modal transport system, and the desirability of a transition away from a heavy reliance of private motor vehicles and towards public transport and active modes, but this is not well reflected in their approach to transport projects in Wellington In the case of this project, the bias towards provision for private motor vehicles is shown not only in the existence of the proposal, but in the sub-standard, too narrow, exposed and at times dangeorus shared pedestrian/cycleway that has been included in the proposal. 4.3 In my view, the assessment process carried out by NZTA could be summed up as we want to build a flyover if anyone suggests an alternative, let s find a reason to dismiss it and build a flyover instead. This attitude was never more dramatically demonstrated than the so-called consultation process of 2011 in 8

9 which the community was presented with two flyover options and invited to suggest which was the least bad. This mockery of a genuine consultation process exemplified the Agency s disregard for community concerns or for any view other than its own. 4.4 This attitude has been reflected in the poor quality of the current proposal. As I am confident will emerge in closing submissions, the Agency has put forward a flawed proposal which raises issues in many areas, such as the separation of the proposal from its wider roading and transport context, the wide disparity between benefits originally claimed from the project and those that can legitimately be claimed from it, the pick a number approach to presenting the project s Benefit Cost Ratio, and the failure to appreciate the values of the receiving environment. 4.5 Most fundamentally, not only is it strongly undesirable to build a flyover at the Basin Reserve, it is unnecessary. It is unnecessary because the roads around the Basin Reserve are not the source of transport congestion in the area.. It is unncessary because significant transport improvements can be made at-grade at a fraction of the cost and with far less disruption. It is unnecessary because the present of transport in New Zealand is diverging from the past, and it is likely the future will diverge further too. It s time for transport planning in New Zealand to join the 21 st century, to join a world in which flyovers are being demolished, not constructed. 5. Conclusion 5.1 In my view, the applicant has failed to provide adequate justification for the project, has failed to adequately consider alternatives, and has failed to demonstrate that it can avoid, remedy or mitigate the many adverse effects of the project on the environment. Therefore, I request that the Board decline the application. 9

10 Timothy Jones References [1] Hearing Day Fifty-Two Transcript, p. 6043, line 5 [2] Hearing Day Thirty-One Transcript, pp