5. sylvia allan - overview.pdf - environmental protection

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

BEFORE A BOARD OF INQUIRY PEKA PEKA TO NORTH ŌTAKI EXPRESSWAY PROJECT

In the matter of the Resource Management Act 1991

And

In the matter of a notice of requirement and resource consent

applications by the NZ Transport Agency for the

Peka Peka to North Ōtaki Expressway Project

And

In the matter of a notice of requirement by New Zealand

Railways Corporation / KiwiRail Holdings Limited

(trading as KiwiRail) for the realignment of a

section of the North Island Main Trunk railway

line through Ōtaki

STATEMENT OF EVIDENCE OF SYLVIA JEAN ALLAN (ALTERNATIVE ROUTE ASSESSMENTS) ON BEHALF OF THE APPLICANTS

12 July 2013

TABLE OF CONTENTS

QUALIFICATIONS AND EXPERIENCE.................................................................... 2

BACKGROUND AND ROLE ..................................................................................... 3

SCOPE OF EVIDENCE ............................................................................................ 4

EXECUTIVE SUMMARY .......................................................................................... 5

INTRODUCTION ...................................................................................................... 6

REVIEW METHODOLOGY ...................................................................................... 6

OPTION AND EVALUATION PROCESS .................................................................. 8

ASSESSMENT OF ALTERNATIVE ROUTE OPTIONS ............................................ 9

RESPONSE TO KĀPITI COAST DISTRICT COUNCIL SECTION 149G(3) REPORT

............................................................................................................................... 16

RESPONSE TO SUBMISSIONS ............................................................................ 17

CONCLUSION........................................................................................................ 18

WGTN_DOCS\1155376\v1 Page 2

QUALIFICATIONS AND EXPERIENCE

1. My name is Sylvia Jean Allan.

2. I am an independent planning consultant with my own firm, Allan Planning and

Research Ltd.

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

(a) I have a Bachelor of Science (Honours) Degree in Physical Geography and

Geology from Canterbury University and a Postgraduate Diploma in Town

Planning from Auckland University;

(b) I am a Fellow of the New Zealand Planning Institute ("NZPI") and a former

President of that professional body;

(c) I have over 40 years’ experience as a planner, both in New Zealand and in the

United Kingdom;

(d) I was awarded both the first Nancy Northcroft Planning Practice award by the

NZPI and a Distinguished Service Award, and am experienced in most aspects

of environmental planning;

(e) I was the National Planning Team Leader for MWH NZ Ltd (an international

environmental, engineering, planning, and resource management company) for

12 years until 2009; and

(f) during my career I have worked on a wide range of projects throughout New

Zealand, including major infrastructure projects. My clients have included

central government, district and regional councils, energy and communication

companies, industrial and commercial organisations, community groups, and

individuals.

4. Throughout my planning career I have been involved in formal evaluations of options

for planning projects, including infrastructure. In the early days this involved

application of methodologies such as the "goals achievement matrix" or the "planning

balance sheet".1 More recently the typical methodology for comparing options has

involved some type of systematic multi-criteria analysis.2

5. I applied this type of methodology in route and substation site identification for the

North Island Grid Upgrade Project. This now-completed project has been New

Zealand's largest infrastructure project in recent years, comprising some 200

kilometres of overhead 400kV power line, 20 kilometres of underground cable, one

entirely new substation and major modifications to three existing substations. The

suitability of the methods used in analysing options, and the identified routes and

sites, were confirmed through a Board of Inquiry process.

1 Both described in J Brian McLoughlin, "Urban and Regional Planning – A Systems Approach", Faber, 1970.

2 For example, as recommended in the New Zealand National Asset Managers Steering Group (NAMS) 2004

publication "Optimised Decision Making Guidelines – A sustainable approach to infrastructure", which is widely used, and commonly referred to as the "NAMS Handbook".

6. I was also asked to review the methodology and route choice for the power line

designations in the Board of Inquiry process in Contact's Hauāuru mā raki Wind Farm;

and for hearings relating to several power lines in the Coromandel. I also identified

and undertook an evaluation of optional routes for a South Island 400kV power line

route of similar scale to the NIGUP project (this last project did not proceed).

7. Roading projects where I have examined route options either as part of an

investigatory team, or as an independent reviewer, have included:

(a) the Ruby Bay Bypass (1995);

(b) a study of Nelson Arterial Route options (2009-2011);

(c) the Woodend Bypass study (ongoing); and

(d) the Ōtaki to Levin Road of National Significance project (ongoing).

8. I have presented papers on methodologies for evaluating alternatives at a Water New

Zealand Conference and a New Zealand Planning Institute Conference.3

9. I confirm that I have read the 'Code of Conduct' for expert witnesses contained in the

Environment Court Practice Note 2011. My evidence has been prepared in

compliance with that Code. In particular, unless I state otherwise, this evidence is

within my sphere of expertise and I have not omitted to consider material facts known

to me that might alter or detract from the opinions I express.

BACKGROUND AND ROLE

10. Section 171(1)(b) of the Resource Management Act 1991 ("RMA") requires particular

regard to be had to whether adequate consideration has been given to alternative

sites, routes, and methods of undertaking the work (where a requiring authority does

not have an interest in the land sufficient for undertaking the work, or it is likely that

work will have a significant adverse effect on the environment).

11. I prepared Technical Report 3: Route Options Review ("Route Options Review")

dated September 2011, which is in volume 3 of the Assessment of Environmental

Effects Report ("AEE") lodged in support of the Project applications. The Route

Options Review describes the assessment of potential alternative routes for the Peka

Peka to North Ōtaki Expressway (the "Expressway"), which was carried out in order

to inform the NZ Transport Agency's ("NZTA") final decision as to the route of the

Expressway.

12. In preparing the Route Options Review, I discussed the issues about options which

had been identified with the Project's planning and legal advisors; reviewed material

provided by the planners (including Mr Peter Coop) and familiarised myself with the

current state of the Project; developed a strategic approach and necessary steps to

3 1. Allan, S and Oldfield, S, “Identifying the Preferred Option – Complex Decision-making for Large Projects”,

paper presented at the New Zealand Planning Institute Conference, May 2009, Rotorua. 2. Allan, S and Shaw, T, “Use of Multi-Criteria Analysis to Identify a Preferred Dam Site”, paper presented at Water New Zealand’s Annual Conference, September 2009, Rotorua.

undertake a formal review of options; and discussed the state of development of the

route which has subsequently been refined and is the subject of the current Board of

Inquiry process, with a range of Project advisers. I also undertook a site visit of the

wider area.

13. I was particularly concerned to make sure that sufficient expertise, involving people

who had appropriate qualifications and who had also had the opportunity to undertake

investigations of the alternative routes under consideration, would be brought to bear

on the investigations I was to lead. This was organised with the assistance of the

NZTA and Opus International Consultants ("Opus"). I also sought to involve a

process peer reviewer with specific expertise in decision theory and multi-criteria

analysis,4 and this was duly incorporated into the process.

14. The roles of those who assisted in the analytical process which I led is fully explained

in the Route Options Review report.

15. As an observer, I also attended workshops run by Ms Kerry Griffiths of URS, who was

responsible for the decision processes and methodologies relating to determining

preferred options for interchange locations and layouts and cross-corridor

connections. While Ms Griffiths' methodology differed slightly from my own, I consider

the differences appropriate to the different scale of analysis necessary for decisions in

the different parts of the Project.

SCOPE OF EVIDENCE

16. My evidence is given in relation to the notices of requirement and resource consent

applications lodged by the NZTA and KiwiRail for the Expressway and North Island

Main Trunk ("NIMT") Railway realignment (together, the "Project").

17. My evidence addresses the following matters in relation to the Route Options Review:

(a) my methodology for analysing different route options for the Expressway;

(b) the option and evaluation process, including:

(i) an initial screening of options already considered;

(ii) a review to identify any options not adequately considered; and

(iii) the route options identified for further assessment; and

(c) the assessment of alternative route options, including:

(i) the technical feasibility of options;

(ii) specialist assessments;

(iii) multi-criteria analysis; and

4 This was Dr Steve Oldfield, MWH Senior Risk Manager, who I had worked with on previous projects.

(iv) subsequent analysis and the overall outcome.

18. My evidence also responds to issues raised by a small number of submitters in

relation to the assessment of alternative routes for the Expressway.

19. As noted above, the Route Options Review informed the NZTA's ultimate decision on

the route of the Expressway, as discussed in the evidence of Mr Rod James of the

NZTA.

20. My evidence does not address the processes and decisions around potential

alternative locations for and designs of the interchanges between the Expressway and

the local road network, specific alignments of the Expressway along the chosen route,

or cross-corridor connections. These are discussed in the evidence of Mr Tony

Coulman. Nor do I address the assessment of alternative routes or sites for the NIMT

Railway realignment, which is discussed in the evidence of Ms Pam Butler. The

statutory tests in relation to the consideration of alternatives are discussed further in

the evidence of Mr Coop.

EXECUTIVE SUMMARY

21. My evidence sets out the basis, process, and findings of a review of potential

alternative routes for the Expressway.

22. The process included a review of past investigations, and development and evaluation

of four route options, one of which was the route option preferred by the NZTA Board

in December 2009, subject to further assessments being carried out (the "Board-

Preferred Option"). Two of the assessed options, to the east of State Highway 1, had

not been previously evaluated by the NZTA or its predecessor organisation.

23. The evaluations involved preliminary development of reasonable alternative routes to

assess technical feasibility, followed by specialist investigations of the effects of the

route options. The initial analyses by the specialists were brought together through a

process involving multi-criteria analysis, which in turn involved best-practice

techniques such as decision conferencing through a facilitated workshop, at which

information about the options was shared and tested. The outcome of the workshop

was analysed on the basis of a range of weighting systems, and was also subject to

further sensitivity analysis.

24. The overall finding was that, while the western route option assessed was clearly not

preferred, the other three route options – the Board-Preferred Option and two route

options to the east – were closely matched in terms of the appropriate considerations

to take into account when choosing a preferred Expressway route. In particular, there

was no clear preference between the Board-Preferred Option and the Eastern Plains

option on the basis of this multi-criteria analysis.

25. This finding was not able to be clarified through closer analysis of the multi-criteria

scoring or the potential effects of the routes (about which some further information had

been obtained). This further emphasised the closeness of the options.

26. As a result of the Route Options Review, and past studies of potential routes for the

Expressway, in my view an appropriate range of feasible route options was robustly

considered before the NZTA Board made its final decision on the route of the

Expressway.

INTRODUCTION

27. As discussed in the evidence of Mr James, potential routes for an expressway from

Peka Peka to North Ōtaki have been the subject of numerous investigations and

studies over many years, as well as several public consultation exercises. In

December 2009, the NZTA Board adopted the Board-Preferred Option, subject,

among other things, to further review and investigation of the alignment against

current planning requirements prior to preparation of the notice of requirement. This

option was substantially the same as an earlier (2003) alignment approved by the

Transit New Zealand Board, following consideration of a range of options.

28. As possible route alternatives had been considered over a long period, the NZTA

decided (as discussed in Mr James' evidence) that it was appropriate to commission

a review of the historical work, update it as necessary, and bring the findings together

in a comprehensive report.

29. The purpose of the Route Options Review was:

(a) to ensure that the NZTA and the wider community could be confident that past

and present studies and investigations had led to a situation where all parties

could be clear that a range of feasible route options had been considered prior

to the NZTA Board making a final decision on route selection;

(b) to ensure that there had been adequate consideration of, and appropriate

documentation of the aspects involved in the identification and rejection of,

alternative route options in terms of section 171(1)(b) of the RMA; and

(c) to consider and evaluate alternative route options which had arisen in

consultative processes since December 2009.

REVIEW METHODOLOGY

30. The methodology for undertaking the Route Options Review required a systematic

approach which I set out in the brief, which was developed in association with other

Project advisors, as a number of stages. These were:

(a) Stage 1: initial screening of options already considered and review of basis for

decisions to retain or reject;

(b) Stage 2: review of a range of material to identify any options not adequately

considered;

(c) Stage 3: decision on options which required further consideration and

evaluation;

(d) Stage 4: scoping and technical review of feasibility of options;

(e) Stage 5: scoping of aspects for investigations by expert advisors, which would

later form the basis for a multi-criteria evaluation of options;

(f) Stage 6: review and preliminary evaluation of options by specialist experts;

(g) Stage 7: multi-criteria analysis of route options;

(h) Stage 8: subsequent analysis, including sensitivity analysis and application of

different weighting systems; and

(i) Stage 9: preparation of review report.

31. The multi-criteria analysis methodology used in stage 7 was a key element in the

overall analysis. Multi-criteria analysis is a useful aid to decision-making, and is

particularly applicable when there are several options to choose between and where

there are numerous complex considerations involved, beyond those which are readily

characterised through, for example, cost benefit methodology. Multi-criteria analysis

is thus commonly used in assessments of options for major infrastructure.5

32. As an adaptable methodology, it is also a tool with relevance for evaluations, including

those under the RMA and Local Government Act 2002, to compare and assess

alternative proposals where there are multiple objectives, and where there are a range

of diverse potential adverse and beneficial effects affecting different areas and

communities. The range of attributes that are relevant to a decision between options

can be numerous and varied, and it is necessary in such circumstances to bring

together the information in a reliable, credible and transparent way.

33. Figure 3 on page 16 of the Route Options Review shows how multi-criteria analysis is

applied. Key aspects to be taken into account in the decision are identified, defined,

and scored on a consistent basis. Once scored, they can then be weighted as

appropriate and combined into a single option score. In multi-criteria analysis

processes, the scores can be seen as surrogates for measures of value for an aspect

(allowing for the effects of diverse criteria, with different units, to be combined). The

weights represent beliefs or assumptions about what is important in a particular

situation or to a particular group of decision-makers.

34. In the context of my involvement in the Project, there were several steps needed

before such multi-criteria analysis could be applied. The first three stages set out

above included a screening of options already identified and a determination of

options that required further consideration. Had I determined that the process to that

stage had been robust and a reasonable range of options considered, the review

would have been completed at Stage 2, with a corresponding report. Similarly, the

5 See footnote 2. The methodology is the methodology suggested by the New Zealand Asset Managers Steering

Group (under the auspices of Ingenium) for determining the optimal solution for “projects which have to be assessed on the basis of cultural, social, economic and environmental considerations” (see section 4.5, the NAMS Handbook).

process could have stopped at Stage 4 had the additional options proved to contain

fatal flaws.

35. As it transpired, all of Stages 1 to 9 were carried out, each stage building on decisions

and information from the prior stage of investigation. Throughout, there was a high

level of collaboration between myself and other Project advisors. For example, the

Stage 3 and Stage 4 steps involved the Project's planning and engineering advisors

as well as myself, and drew on consultation which had been undertaken. Stages 5 to

7 involved the wider project team, including investigations and preliminary evaluations

by a range of technical expects, and a multi-criteria analysis process through decision

conferencing techniques. The final two stages were undertaken by me with some

assistance from Dr Oldfield.

36. This structured and transparent process, including appropriate and relevant

information at each stage, is in my opinion, in accordance with best practice in

assisting with decisions on major infrastructure, such as the appropriate route choice.

The preferred route is then subject to considerable refinement, through more detailed

consultation and technical investigations, as was undertaken for the Expressway

beyond the scope of my involvement.

OPTION AND EVALUATION PROCESS

Initial screening of options already considered

37. Prior to my involvement, a review of previous route options had been undertaken by

Mr Coop. That documentation is provided as Appendix 3.A to the Route Options

Review. My independent review agreed with Mr Coop’s findings.

38. In summary, the following conclusions were drawn from my review:

(a) A range of coastal (or 'Sandhills') route options had been sufficiently

investigated and rejected for reasons that were valid in RMA terms, including a

range of matters of national importance under section 6 of the RMA, and it was

likely that if further evaluation were undertaken, the reasons for rejection would

be even more compelling than previously.

(b) A range of central route options had been investigated in detail several times

over the past decade. The NZTA Board's preference for the Board-Preferred

Option was based on a range of RMA and practical considerations, including

limiting adverse effects on people. While the Board-Preferred Option gave rise

to some section 6 considerations, and a range of other adverse effects, there

was ongoing work on avoidance or mitigation of residual effects. On balance,

other options in the central route were likely to have equal or greater adverse

effects.

(c) As an alternative to both coastal and central routes, a number of options

variously described as the 'Te Wāka' routes were adequately investigated in the

mid-1990s.

Review to identify any options not adequately considered

39. Both Mr Coop and I considered that route options to the east of the Board-Preferred

Option had not been evaluated prior to the commencement of the Route Options

Review process. Consultation processes raised the possibility of, and demonstrated a

level of community interest in, routes through rural land east of Te Horo and Ōtaki.

40. Although it was not suggested that previous investigations of routes to the west of

State Highway 1 had not been adequate, it was agreed between Mr Coop and myself

that it would be appropriate to review a western route on a similar basis to eastern

route options applying up-to-date information. A western route had also been raised

in submissions.

41. Opus was therefore requested to refine two conceptual eastern route options as well

as a western option, and to undertake a preliminary review of their technical feasibility.

Route options identified

42. The route options considered appropriate to include in a further review were:

(a) Option A: a route referred to as the 'Eastern Foothills Route';

(b) Option B: an 'Eastern Plains Route';

(c) Option C: a 'Western Alternative (the Te Waka option)'; and

(d) Option D: a Central Route (which was the Board-Preferred Option).

43. The two eastern routes were considered worthy of further evaluation as representative

of options in that general vicinity, and were found by Opus to be technically feasible.

44. The Te Wāka route or 'Western Alternative’ was developed on the basis of known

information and previous investigations. It is considered to reflect the 'best' of the

previously assessed western options.

45. Finally, as a 'base case', the Board-Preferred Option was to be subject to the same

type of analysis as the three alternatives above, to ensure robustness and

comparability in outcomes.

46. These routes are shown in Figure 1 below.

ASSESSMENT OF ALTERNATIVE ROUTE OPTIONS

Technical review of feasibility of options

47. To provide a comparative assessment of technical feasibility and cost, the routes were

developed by Opus from a broader 'corridor' stage to that of an 'alignment'.

Considerations taken into account in determining the alignment for the four options

included ground conditions, gradient, earthworks volumes, river, road and rail

crossings, and property impacts including connectivity. The development of the

corridors to this level of detail enabled the technical engineering and transportation

assessments to be carried out, preliminary cost estimates to be prepared, and an

economic analysis to be undertaken. Importantly, the options were then able to all be

assessed on the same common basis.

Figure 1: Route options for further evaluation

48. The technical studies found that all alternatives were technically feasible, and all were

within a similar cost range. All alternatives were found to be effective in terms of

through-traffic.6 There were no technical, cost, or cost-benefit reasons to reject any of

the alternatives at this stage, so all routes were subject to further investigations.

Specialist assessments

49. The technical review of the route options was followed by investigations of their

potential environmental impacts, through specialist assessments of a range of

6 Although, as noted in the Report, the overall transport benefits of the Board-preferred option exceeded other

options, due to the likelihood that traffic with an origin or destination in Ōtaki would continue to use the current State Highway 1 route, thereby forgoing safety and efficiency benefits of the alternative route.

environmental and social aspects. The specialist assessments were based on a

nominal 200-metre-wide route, based around the centreline of the routes which had

been the subject of technical review. The exception was Option D, the Board-

Preferred Route, where sufficient design work had been undertaken to define the

route and flexibility was not required. The 200-metre-wide corridor within which the

other routes were based enabled flexibility, and allowed for refinement in detail and

opportunity to avoid or mitigate localised constraints and issues. Effects that would

occur beyond the 200m corridor were also taken into consideration. The extent of

property effects (affected land parcels and dwellings) was, however, based on a 100-

metre-wide typical route within the 200-metre-wide corridor.

50. Investigations of the following aspects were considered necessary to undertake an

adequate evaluation of alternatives:

(a) ecology (terrestrial and freshwater);

(b) archaeology and historic buildings and places;

(c) cultural values;

(d) landscape and visual;

(e) social impact;

(f) property considerations;

(g) planning and urban growth;

(h) natural hazards;

(i) land quality;

(j) construction; and

(k) lifeline impacts (i.e. relating to essential services in emergencies).

51. Technical experts were engaged and briefed as to the scope and purpose of their

investigations. The experts were asked to identify and advise on the key

considerations in their areas of expertise for the four routes, and to provide a

preliminary assessment of each alternative. These reports are contained in

appendices 3.C – 3.M to the Route Options Review.

52. Had it been apparent that some of the options received considerably poor rankings, of

that there were significant "fatal flaws" under any of the above headings, it may not

have been necessary to investigate the route options further. However, from an initial

review of the various specialist assessments, it became apparent that it would be

necessary to undertake a full multi-criteria analysis of the options. This was because

the differences between the various route options were very close in a number of

areas. Also, where a particular specialist had broken down the assessment into sub-

categories (for example, as occurred with the social and community impacts and

transport effectiveness evaluations), differences in one sub-category were sometimes

off-set in another category.

Multi-criteria analysis

53. Decisions on criteria, scoring and weighting for assessing route options for the

Expressway were made through a workshop process with experts that allowed for

testing through discussion and questions and answers. A multi-criteria analysis

workshop, applying decision conferencing techniques, facilitated by Allan Planning

and Research, was held on 7 June 2011.

54. A description of the attributes or criteria that were developed from a review of the

preliminary expert reports, and agreed through the workshop process, is set out in the

Route Options Review report. These were:

1) landscape/visual;

2) ecology;

3) archaeology/heritage;

4) cultural values;

5) social/community impacts;

6) compatibility with District plan;

7) transport effectiveness/fit to objectives;

8) effects on lifelines;

9) natural hazard effects;

10) productive land uses;

11) specific land ownership effects;

12) constructability; and

13) costs.

55. The scoring system agreed during the workshop process used a five-point numerical

system, as set out in Table 1 overleaf.

Table 1: Basis for scoring in multi-criteria analysis

Score Description

1 The corridor option presents few difficulties on the basis of the

attribute being evaluated, taking into account reasonable mitigation

proposals. There may be significant benefits in terms of the attribute.

2 The corridor option presents only minor areas of difficulties on the

basis of the attribute being evaluated, taking into account reasonable

mitigation proposals. There may be some benefits in terms of the

attribute.

3 The corridor option presents some areas of reasonable difficulty in

terms of the attribute being evaluated. Effects cannot be completely

avoided. Mitigation is not readily achievable at reasonable cost, and

there are few or no apparent benefits.

4 The corridor option includes extensive areas of difficulty in terms of the

attribute being evaluated, which outweigh perceived benefits.

Mitigation is not readily achievable.

5 The corridor option includes extreme difficulties in terms of achieving

the project on the basis of the attribute being evaluated.

56. The workshop proceeded in accordance with the agenda and process in Appendix 3.K

of the Route Options Review, with a key component being the scoring of the options

for each criterion. In all but a few circumstances consensus was reached amongst

those at the workshop. Where it was not, dissenting views were noted for later

consideration through a sensitivity analysis.

57. Table 2 shows the scores awarded at the workshop. This provided the key raw data

for further analysis.

Table 2: Scores for each route from workshop process (numbers in brackets

indicate aspects where consensus was not reached)

58. The workshop process generally confirmed the initial analyses carried out by the

specialists and awarded similar scores. However, a benefit of the decision

conferencing workshop process is robustness of discussion and “testing” of expert

opinion, and some of the initial assessments of the specialists were modified. There

were also several attributes where the description was not developed fully until the

workshop, and/or where a criterion had not been the subject of prior evaluation.

Specific comments on scoring are noted in part 4.5 of the Route Options Review.

59. In multi-criteria analysis, it is rare that all attributes are considered to be equally

important, so the scores are often combined in one or more ways to identify the

preferred option from the analysis as a whole. This involves a process of weighting

the criteria relative to each other. The workshop therefore also developed a weighting

system which represents the view of the key technical and specialist advisors team

involved in the Project. This is shown in Table 3 below. This provided one weighting

system, with additional analyses being undertaken as a later exercise, along with

sensitivity analysis.

Table 3: Weighting system derived from workshop process

60. The weighting system from the workshop placed greatest emphasis on cultural values

and the fit to Project objectives, followed by two key RMA section 6 matters (namely

ecological values and archaeological values). Lesser weight was placed on costs,

constructability, and specific ownership effects. By a small margin, the workshop

weighting favoured the Central, Board-preferred, option.

Subsequent analysis and overall outcome

61. To increase the robustness of the analysis the scoring was subjected to a range of

weightings and the outcomes reviewed in terms of their consistency and range of

differences. A total of 8 weighting systems were utilised, including the workshop

weighting. Other than the weighting system developed at the workshop, which gives

an expert view of the importance of the different criteria, these weighting systems

were developed to highlight different aspects which are relevant to RMA and/or local

and central government decision-making. They included a weighting system which

emphasised RMA section 6 matters, and one which balanced RMA Part 2 matters

more evenly. The fourth weighting system endeavoured to apply a community-based

weighting. The other four weighting systems placed emphasis on each of the

"quadruple bottom line" considerations.

62. Once the final weightings had been assigned, an outcome was obtained that ranked

each of the four alternatives considered. The outcome for the alternative routes that

had been assessed is shown in Table 4.

Table 4: Analysis of route options

63. The overall conclusion from the multi-criteria and subsequent analysis was that the

two eastern route options developed for the review were almost equivalent to the

Board-Preferred Option, in terms of the range of matters that contribute to decisions

on route preferences under various legislative requirements. Of the two, the Eastern

Plains option was generally preferred to the Eastern Foothills option. The Western

Route option was not favoured under any of the analyses.

64. A full explanation of the detailed evaluation with the various weightings applied to

each option is contained in the Route Options Review report. As explained in the

conclusion to the Route Options Review report, the general finding was that, while the

Western Route option was clearly not preferred, the other three options were closely

matched when compared on the basis of the types of considerations that are

appropriate to take into account when choosing a preferred route.

65. Further information was sought on noise effects and air quality effects which had not

been incorporated in the multi-criteria analysis. The findings on these aspects did not

assist in identifying a preferred option.

66. I finalised the Route Options Review and submitted it to the NZTA in September 2011.

As discussed in the evidence of Mr James, the NZTA's final decision as to the route

of the Expressway was made in December 2011.

RESPONSE TO KĀPITI COAST DISTRICT COUNCIL SECTION 149G(3) REPORT

67. Page 7 of the Kāpiti Coast District Council's 'Key Issues' report identifies that the issue

of alternative routes for the Expressway is a key matter for consideration by the Board

of Inquiry.

68. I note, however, that the author of the report has categorised the issue as follows:

"Key issues relate to the appropriateness and justification of the proposed

Expressway route and NIMT in comparison with alternative route options"

(emphasis added).

69. From my background in planning and alternatives assessment, I understand that an

inquiry under section 171(1)(b) of the RMA should focus on the adequacy of process

by which alternatives were identified and considered, rather than the appropriateness

and justification of a chosen route as against any alternative possibility.

70. In my view the range of options which have been formally identified and evaluated

through the processes described in the Route Options Review meet good practice

requirements in terms of the RMA. A careful analysis was unable to distinguish

between three options, and on that basis it was acceptable for the Board to choose to

continue with the option which scored "best" in terms of the criterion "Transport

Effectiveness/Fit to Objectives". This decision could be made in the full knowledge

that other attributes of alternative routes were closely balanced, with no clear

preferences.

RESPONSE TO SUBMISSIONS

Submission of Sharyn Sutton (102855)

71. In paragraph 15 of her submission, Ms Sutton states that “inadequate consideration

has been given to alternative routes ..... between Peka Peka and North Ōtaki that

would have lesser adverse effects”. In particular, Ms Sutton appears to disagree with

a finding early in the Route Options Review report (page 6) that western coastal route

options had already been adequately developed, considered and rejected.

72. The basis for this conclusion is found at the bottom of page 5 of the Route Options

Review report, where reference is made to various studies, including the 2001/2

Scheme Assessment Report, and a 2003 addendum to that Report which arose from

consultation carried out on the Scheme Assessment Report. In both studies, a range

of western route options had been identified, as can be seen in Appendices 2 and 3 of

Appendix 3.A of the Route Options Review report. As described on page 5 of the

Route Options Review report, both studies had undertaken evaluations which had led

to the Board-preferred option being proceeded with. Having reviewed the relevant

reports in Stage 1 of my own studies, I was satisfied that a wide range of western

route options had been considered in depth.

73. However, as noted earlier in this evidence, a decision was made at Stage 3 of my

study that a representative western route option should remain "in the mix" for

evaluation using the same methodology as for the new, eastern, options. Opus

developed the alignment, as explained, to the stage where its technical feasibility was

confirmed. This route is Option C in Figure 1 and Tables 2 and 4 of this evidence. It

was found that this option ranked poorly, compared with the other three, under all

evaluations.

Submission of Chris Christie (102877)

74. Ms Christie states that the planned Expressway is in the wrong place and will be

socially and physically divisive, and that it "impacts too seriously on people's lives,

health, homes and businesses". The submission states that the author would support

an expressway " to the west – as long planned, or ... to the east – nearer the

mountains."

75. While I am not in a position to comment on whether the proposed Expressway's

effects on people are "too serious" for it to be approved, I can comment on the

findings relating to environmental effects as a whole7 on route options evaluated,

which include options to the west and east of the current alignment. As noted earlier

in this evidence, a thorough and structured evaluation has demonstrated that a route

to the west would be likely to have greater impacts, whereas routes to the east would

have approximately equivalent adverse effects, although these effects would relate to

different physical areas and therefore to different people.

Submission of Chris Parkinson (102901)

76. The submission on behalf of the Parkinson family indicates support for the "Sandhills

option" to the west of current State Highway One. My comments in response to this

submission are similar to those in response to submission 102855 above. On the

basis of a range of analyses of options over time, which I reviewed, as well as on the

basis of the inclusion of a representative Western alternative "Te Waka" route option

(Option C) in the recent multi criteria analysis, a western option would not be preferred

over other options.

CONCLUSION

77. The Route Options Review provided an updated and consistent approach to the

evaluation of an appropriate range of alternative routes.

78. As a result of the Route Options Review, two new route options were identified, and

sufficient information was collected on these routes to enable an assessment of them

in terms of relevant considerations for an expressway alongside two previously-

identified options.

79. The work involved in the Route Options Review was rigorous, including:

(a) a review of options previously investigated, and community input;

(b) identification of possible areas for routes which had apparently not been

considered in more than a cursory way;

(c) development of options in these areas and a technical check of practicality;

7 Generally encompassing the meaning of the words “environment” and “effects” as defined in sections 2 and 3 of

the RMA.

(d) investigation of options by specialists within a framework providing adequate

information for a multi-criteria analysis;

(e) a multi-criteria workshop, eliciting scoring and a single weighting system; and

(f) analysis of results on this basis, and subsequent further analysis applying

additional weighting systems and alternative scorings.

80. The Route Options Review and past studies and investigations led to a situation

where a range of feasible route options had been considered prior to the NZTA Board

making a final decision on route selection.

Sylvia Jean Allan

12 July 2013

5. sylvia allan - overview.pdf - environmental protection

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