before a board of inquiry basin bridge proposal · the bridge is being progressed to assist in...

BROOKFIELDS / KENSINGTON SWAN Level 9

79 Boulcott Street PO Box 25-306 Featherston Street Wellington Ph +64 4 499 9824 Fax +64 4 499 9822

Solicitors acting: A F D Cameron / A M B Green / F R Wedde Contact: F R Wedde DDI: +64 4 498 0847 Email: [email protected]

Before a Board of Inquiry

Basin Bridge Proposal

Under the Resource Management Act 1991 (the Act)

In the matter of a Board of Inquiry appointed under section 149J of the Act

to consider the New Zealand Transport Agency's notice of

requirement and five resource consent applications for the

Basin Bridge Proposal.

Statement of Rebuttal Evidence of Duncan Brutton Kenderdine for the New Zealand Transport Agency (Construction Management)

Dated 21 January 2014

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STATEMENT OF REBUTTAL EVIDENCE OF DUNCAN BRUTTON

KENDERDINE FOR THE NEW ZEALAND TRANSPORT AGENCY

Contents

1 Introduction 2

2 Scope of Evidence 2

3 Construction Staging and Programme 3

4 Pedestrian and Cyclist Management 5

5 Implementation of the Urban & Landscape Design Framework 6

6 Joint Witness Statement regarding Groundwater 7

7 Evidence on behalf of Submitters 8

8 Conclusion 12 Annexures Annexure A - Revised staging Drawings Annexure B - Revised programme Annexure C – Draft Minutes Construction Traffic Planning and Public Transport Annexure D - Revised Pedestrian and Cycle Routes Annexure E - Preliminary Baseline noise monitoring results

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1 Introduction

1.1 My full name is Duncan Brutton Kenderdine.

1.2 My rebuttal evidence is given on behalf of the New Zealand Transport Agency

(Transport Agency) in support of the Notice of Requirement (NoR) and the

five associated applications for resource consent lodged with the

Environmental Protection Authority on 17 June 2013 in relation to the

construction, operation and maintenance of the Basin Bridge Project

(Project).

1.3 I have the qualifications and experience set out at paragraph 1.3-1.5 of my

statement of evidence in chief, dated 25 October 2013 (EIC).

1.4 I repeat the confirmation given in my EIC that I have read the ‘Code of

Conduct’ for expert witnesses contained in the Environment Court Practice

Note 2011 and that my evidence has been prepared in compliance with that

Code.

1.5 I attended expert witness conferencing held on 28 November 2013 in relation

to Vibration, Construction Noise and Operational Noise, and also over the

period leading up to 10 December 2013 in relation to Erosion and Sediment

Control. I am a party to the outcomes of those conferences recorded in the

joint witness statement dated 15 December and 10 December 2013

respectively.

2 Scope of Evidence

2.1 In this statement of rebuttal evidence I will:

a provide an update on construction staging;

b provide comment on pedestrian and cyclist management change;

c provide information on how the Urban & Landscape Design Framework

(ULDF) will be implemented in the detail design process;

d respond to the joint witness statement on groundwater, and

e respond to the evidence of Mr Michael Faherty and Mr Con Wassilief on

behalf of the Roman Catholic Archbishop of the Archdiocese of

Wellington (St Joseph’s Church), Mr Warren Ulusele on behalf of

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Wellington City Council; and Messers Alastair Morris and Darrell

Stratham on behalf of Regional Wines and Spirits.

2.2 The fact that this rebuttal statement does not respond to every matter raised in

the evidence of submitter witnesses within my area of expertise should not be

taken as acceptance of the matters raised. Rather, I rely on my EIC, and this

rebuttal statement to set out my opinion on what I consider to be the key

construction management matters for this hearing.

3 Construction Staging and Programme

3.1 Volume 4 of the application for the Proposal contains a proposed Construction

Environmental Management Plan (CEMP). Appendix A of the CEMP is a draft

Construction Methodology and Programme. As noted in my EIC the design of

the Bridge is being progressed to assist in refining a construction price so that

the Transport Agency can enter into an agreement to build the Bridge, should

the Proposal be approved by the Board. As part of this process further

investigations of ground conditions have been completed and more

consideration has been given to the construction phasing.

3.2 The initial construction phasing identified the opening of the eastbound link

road in the early phases of the Project. This option is no longer feasible as it

has been identified that the ground improvements required at the abutments

and pier foundations are more extensive at the eastern end of the Project.

3.3 To reflect this change and the desire for improved pedestrian and cycling

temporary pathways as discussed in section 4 the updated construction

sequence drawings are now proposed. The updated drawings are attached in

Annexure A. The drawing changes are listed in Table 1 below.

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Table 1: Updating of staging drawings

Original Figure reference Replacement Figure reference

Comment

BRB 14 017 Rev A New Drawing showing enabling works

Figure 2 Pre-work intersection improvements and BRB 04 9000 Rev E

BRB 14 018 Rev A No change

Figure 3 Stage 1 and BRB 04 9001 Rev E

BRB 14 019 Rev A Brings forward the removal of the Ellice St building and reconfiguration of St Joseph’s car park. Piles 1, 2, 3, 7 and 8 constructed.

Figure 4 Stage 2 and BRB 04 9002 Rev D

BRB 14 020 Rev A Work on spans 1-2 and 7-8 commence. Piles 4, 5 and 6 completed. Pavilion construction started. Work on East bound link road is not commenced.


BRB 14 021 Rev A Spans 2-3 and 6-7 complete.


BRB 14 022 Rev A Bridge structure completed. Pavilion completed. East bound link road is not completed.


BRB 14 023 Rev A East bound link road constructed and opened


BRB 14 024 Rev A Landscaping commences


BRB 14 025 Rev A Tie ins to bridge completed


BRB 14 026 Rev A No change

3.4 The indicative programme for the Bridge’s construction at Figure 1, Appendix

A of the proposed CEMP has been updated to reflect the changes in

construction staging. The amended programme is attached in Annexure B.

3.5 I, along with Mr David Dunlop, attended a meeting with WCC, GWRC,

Wellington Cable Car Company and Go Bus representatives to review the

construction impacts of the Project on the wider transport network. The

revised construction staging layouts were presented and discussed. There

was general agreement with the proposed layout. Mr Dunlop notes in his

rebuttal statement his assessment that these changes will have minor impacts

on the traffic flow through and around the Basin.

3.6 I have attached the draft minutes of that meeting as Annexure C. I note there

were a number of items raised in detail that will be part of the detailed

communication and planning for the Construction Transport Management Plan

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(CTMP) and Appendix A of the CEMP. For instance, I understand the trolley

bus wires can be de-energised over a weekend, with no impact on bus service

due to reduced demand (as bus use is dominated by work commuters and

schools which are week day functions), which will allow the erection of the

temporary Bridge beams over the top of the wires without risk from live wires.

4 Pedestrian and Cyclist Management

4.1 A number of submissions have identified concerns about pedestrian and

cycling access around the Basin Reserve area during the construction phase.

Further it is listed as one of the three key adverse construction effects in the

joint witness statement of planning witness dated 20 December 2013 (page

14). In my opinion, the construction activities will have a minor impact on

current pedestrian routes. A drawing BRB 14-027 Rev A has been prepared to

show the pedestrian and cycling routes during construction. This drawing is

attached as Annexure D.

4.2 Only one major section of footpath is unavailable during the construction

period for public use. This is the section of approximately 150m around the

north eastern corner of the Basin Reserve. The footpaths marked in green on

the drawing will be untouched. The footpaths marked in red may be subject to

some minor disruption such as the erection of adjoining security fences or

pedestrians having to wait for vehicles entering or exiting construction areas.

The footpaths marked in yellow are defined as temporary. These footpaths are

identified as temporary as the location of the footpath will change during the

construction period. In identifying the pedestrian routes considerable care has

been taken to minimise any disturbance to the existing pedestrian routes and

their utilisation.

4.3 It is my observation from the adjoining National War Memorial Park project

that alternative or temporary pedestrian and cyclist routes are easier to use or

seen as ‘better’ by the users if they can be in place longer and are prepared in

a semi-formal manner.

4.4 Proposed condition DC 23 requires the CTMP to go through an independent

Crime Prevention Through Environmental Design (CPTED) review. As part of

the construction planning work undertaken to date, discussions have been

held with a CPTED expert. As a result appropriate provision for CPTED

measures have been made in the Project’s budgets and methodologies.

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5 Implementation of the Urban & Landscape Design Framework

5.1 As noted above the detail design for the Bridge is being progressed. This

detailed design work has to date focussed on the engineering aspects of the

design, particularly the structural, utilities and services aspects. Consistent

with DC.1, this design work is being carried out in general accordance with the

lodged drawings and the ULDF. Architectural and landscape design expertise

is an important component of the design team and the work to date has been

informed by Mr John Hardwick-Smith, Ms Megan Wraight and senior

members of their combined firm Wraight Athfield Landscape Architecture.

5.2 Further design work is required to prepare construction drawings. This next

phase of design will commence with a series of inception workshops following

the Board’s decision on the Proposal. The key stakeholders as listed in DC.31

will be invited to these workshops. The inception workshops will confirm the

design objectives, requirements and standards, ensuring always compliance

with the relevant conditions as confirmed by the Board.

5.3 Following the inception workshops, the 30% design process will commence.

The outcome of the 30% design process will be the preparation of the draft

Urban and Landscape Design Plan (ULDP) as contemplated by the draft

conditions. The ULDP will be provided in draft to selected stakeholders for

comment. The ULDP will also be subject to a review that considers the

constructability of the design in terms of costs, practicality of construction and

potential construction effects. Following this review the construction drawings

and specifications will be prepared.

5.4 The ULDP will determine exact details and finishes, based on the ULDF and

lodged drawings. This is important because the lodged drawings and ULDF do

not define all outcomes precisely, and inevitably there will be some design

conflicts. Interpretation is required to resolve site and construction constraints

whilst achieving the intended design outcomes.

5.5 An example of this is follows. The ULDF for Zone 3 (Kent Tce/ Ellice St)

requires the design to ‘integrate stormwater management into rain garden at

the street edge’, which in this location refers to an approximately 1 metre wide

strip of landscaping between the footpath and the road edge.

5.6 The construction of a rain garden at this location is problematic for the

following reasons:

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a the construction of a rain garden would require a traffic lane to be closed

for several months during construction which would add significantly to

journey times; and

b the construction of a rain garden would require extensive relocation of

services.

5.7 The design process has identified the following solution at this location, being:

a the use of a proprietary filter system such as Stormwater 360 to ensure

the stormwater treatment is equivalent to that achieved by a rain garden

or better. These systems have been used on other Transport Agency

projects such as the Victoria Park Tunnel. The treatment system will

produce a discharge that complies with the Transport Agency’s

‘Stormwater Treatment Standard for State Highway Infrastructure’ (May

2010); and

b the same garden area as envisaged for the rain garden will be created at

Bogart’s corner. The species selection will ensure that the garden has

similar aesthetic qualities as rain garden plantings elsewhere to ensure

visual continuity.

5.8 I note that the ULDP is subject to certification by WCC and that any such

changes will therefore be subject to review by WCC before construction can

begin. I see the ULDP development and certification process as outlined in the

proposed conditions by Mr Daysh as being an appropriate mechanism to

confirm and make decisions on these types of detailed design issues.

6 Joint Witness Statement regarding Groundwater

6.1 The joint witness statement on groundwater dated 12 December 2013

proposes that condition WP 3 be amended to require groundwater monitoring

at the boreholes known as BHTT15 and BH603. In keeping with this proposal

monitoring of the groundwater at these locations has commenced.

6.2 To assist in confirming the knowledge already gained on site geology and

groundwater, and to assist the design process, a series of additional

investigation boreholes and pits will be undertaken on land owned by the

Transport Agency.

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7 Evidence on behalf of Submitters

Roman Catholic Archbishop of the Archdiocese of Wellington (St Joseph’s

Church) (Mr Michael Faherty and Mr Con Wassilief)

7.1 Mr Faherty identifies three matters in respect of construction effects: the loss

of parking during construction; noise; and lay down areas.

7.2 He identifies the loss of access to the St Joseph’s car park for a two month

period (while the building at 28 Ellice Street is removed and their car park

reconfigured) as having the potential to significantly impact on the operation of

the Church. We have examined the construction methodology to identify

opportunities to minimise the impact on car parking. By staging the house

removal and car park formation works we can ensure a minimum of 15 parks

will be available in the car park area throughout this two month period. The

number of parks may be more than 15 but this is dependent upon the

construction activity being undertaken at a particular time.

7.3 We are continuing to consider the following options to mitigate the temporary

loss of parking:

a making additional car parks available in the car park area on Sundays

(subject to the construction activity being undertaken);

b providing alternative car parking within 200m of the Church;

c provision of taxi cabs/vans to take parishioners to and from their homes ;

d provision of taxi chits;

e providing a valet service to take parishioners’ vehicles to off-site parking;

and

f providing an off-site car parking area and a shuttle to take parishioners to

the Church.

7.4 As part of the ongoing detail design process we would investigate if there are

opportunities to reduce the construction period for the house removal and car

park construction. I believe a combination of the measures outlined above will

significantly reduce the impact on parishioners and the Church.

7.5 Mr Faherty also identifies a concern about large mobile plant being parked in

the immediate vicinity of the Church when not in use. He also identifies

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concerns about the appearance of the work area so that ‘land doesn’t look like

a refuse tip’ (paragraph 59). I also note Mr Faherty’s acknowledgement about

the practicalities of using the area. We have looked at the construction

methodology and believe it will be possible to park large mobile plant at least

20m away from the Church during weekends or periods where construction

equipment is not being used for more than 12 hours. Large mobile plant would

include cranes and drill rigs. I recommend that a condition is included to cover

this requirement.

7.6 I note Mr Faherty’s concerns about the tidiness of the site. Given the very

limited space available for storage and working the site will be carefully

managed. There will be no space available for storage of materials that are

not required.

7.7 Mr Faherty identifies noise as another concern particularly during Church

events such as funerals and christenings. As noted in my EIC (paragraph

11.20) the Alliance already has experience of working immediately adjacent to

the Carillon and responding to ceremonies there which require due respect.

7.8 It would be the Alliance's objective in regard to St Joseph’s to be a good

neighbour and minimise any adverse effects from construction activities. The

Church has identified critical periods and events (for example, weddings and

funerals). We would develop with the Church an action plan and a protocol for

working together. As identified above, the staging programme shows that

works within the immediate vicinity of St Joseph’s are not continuous. The

action plan would be developed to reflect the different stages of the

construction cycle.

7.9 Mr Wassilief suggests the construction of a noise wall in front of the Church1. I

note and defer to the rebuttal evidence of Mr Dravitzki on this issue. Further it

is my opinion that the potential for the construction of a noise wall should be

allowed for in the Construction Noise and Vibration Management Plan.

However the wall should only be constructed if noise limits are being

exceeded. I also observe that a noise wall of this height would significantly

reduce the views from the Church’s reception/meeting areas. To assist in

managing future noise effects, we commenced undertaking background noise

measurements in areas such as the Church chapel. The results of this

monitoring are attached as Annexure E.

Wellington City Council (Mr Warren Ulusele)

1 Evidence of Mr Wassilieff (Archdiocese of Wellington (St Josephs Church)) section 54-60.

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7.10 Paragraph 102.2 of Mr Ulusele’s evidence seeks a condition that a condition

survey of the Pavilion (Museum Stand) be undertaken before and after

construction. I am of the opinion that this condition is unnecessary as the

stand is over 90m away from the nearest construction activity. The monitoring

experience from the construction activities at the Buckle Street underpass

supports my observation.

7.11 In paragraph 102.1.3 Mr Ulusele seeks the addition of a condition to address

the effects of vibration, dust, water and possible physical damage to heritage

structures. In my opinion Mr Ulusele’s concern is already adequately covered

by the proposed conditions that require the preparation of management plans,

including the CEMP, the Construction Noise and Vibration Management Plan

and the Construction Air Quality Management Plan.

Regional Wines and Spirits (Mr Alastair Morris and Mr Darrell Stratham)

7.12 The evidence of Mr Morris identifies a number of concerns about the impact of

the construction process on Regional Wines and Spirits (RWS), as follows:

a construction activities will occupy their car park for 2 to 3 months;2

b customers commonly buy in bulk (e.g. cases) and it is not feasible to walk

any distance to their cars;3

c that due to the disruption to the local transport network and temporary

closures customers will find it difficult to access the site;4

d customers will be subject to unpleasant dust, noise and vibration;5

e disruption to footpaths;6 and

f difficulty in heavy vehicles accessing Hania Street and unloading,

particularly when access from Hania Street southwards is restricted7.

7.13 The evidence of Mr Stratham raises concerns about the lack of guaranteed

parking for RWS customers8.

7.14 Further to my EIC we have examined the potential impacts of the construction

process on the RWS business and options to avoid or mitigate these impacts.

2 Alistair Morris, evidence in chief, section 11. 3 Ibid, section 12. 4 Ibid, section 13. 5 Ibid, section 14. 6 Ibid, section 17. 7 Ibid sections 22 to 26 8 Darrell Statham, evidence in chief, sections 12 to 24.

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A major concern of RWS is the ability to guarantee parking to its customers.

Table 2 below identifies the construction phases and the impact on parking

and alternatives.

Table 2: Construction staging and car parking for Regional Wines and Spirits.

Development Stage Current Car park Alternative parking

Stage 0 Unavailable 1 week to install groundwater monitoring bore

Parking area opposite on corner (see Figure 1 blue zone.

Stage 1 Unavailable for 4 weeks while piles C and D installed

Parking area opposite on corner (see Figure 1 blue area).

Stage 2 Available

Stage 3 Unavailable for 4 weeks while pile columns C and D constructed and deck placed

Parking area opposite on corner (see Figure 1 blue area) for pile columns and across the road in the construction area (green area) for deck placement.

Stage 4 Available

Stage 5 Available

Stage 6 Available

Stage 7 Available

Stage 8 Available

Figure 1: Location of alternative parking for Regional Wines and Spirits.

7.15 Table 2 shows that the RWS car park will not be available for a period of

approximately nine weeks. During this time alternative parking will be

available.

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7.16 Table 3 identifies proposed actions that will be undertaken to address the

other concerns raised by RWS. These concerns will be addressed during the

compilation and implementation of the CTMP.

Table 3: Mitigation measures for Regional Wines and Spirits

Concern Response

The inconvenience of carrying heavy loads to alternative car parks.

The Alliance will provide a service to transport purchases from the shop to the customer’s car when alternative car parking is being used.

Potential customers will not be able to easily access RWS.

Signage will be erected to clearly identify the location of RWS and how to access this site. Traffic Management staff will be briefed to ensure they can direct people to RWS

Disturbance to footpaths providing access to RWS

Foot access will be maintained to RWS throughout the entire construction process as shown in drawing BRB-14-027 attached and discussed above in Section 5.

Difficult in accessing RWS to unload deliveries

Alliance traffic management staff will assist in the ensuring that vehicles can safely access and depart the RWS site.

Inability to access RWS with delivery vehicles

In the event that Hania Street is closed and heavy vehicle access is not available. The Alliance will arrange for deliveries for RWS to off loaded at a safe location and transhipped to RWS on a smaller vehicle at the Alliance’s cost.

7.17 The concerns about noise, dust and vibration are in my opinion addressed by

the preparation and implementation of the relevant environmental

management plans.

7.18 In addition, it will be my objective to ensure that the Alliance maintains

effective communication with RWS throughout the construction period.

8 Conclusion

8.1 I have reviewed the evidence of submitters in relation to construction effects

and stand by the conclusion in my EIC that with good communication and the

robust conditions and management plans proposed, the Basin Bridge and

associated works can be built without significant adverse effects.

8.2 Individuals and groups have been met with since I completed my EIC, and

their views and concerns are informing the development and refinement of the

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conditions and management plans, which will ensure an even more robust

outcome in regards to construction effects.

Dated 21 January 2014

Duncan Brutton Kenderdine

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Annexures: Annexure A - Revised staging Drawings Annexure B - Revised programme Annexure C – Draft Minutes Construction Traffic Planning and Public Transport Annexure D - Revised Pedestrian and Cycle Routes Annexure E - Preliminary Baseline noise monitoring results

before a board of inquiry basin bridge proposal · the bridge is being progressed to assist in...

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