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Tonkin & Taylor Aquatic Centre Report

Council discussed on Tuesday the purchase of land south of the Thames Airfield for the purpose of siting the Regional Aquatic Centre that was included in the Ten Year Plan.

I have no idea at this stage as to the outcome of that process – everyone is very ‘tight-lipped.’ But I can say that Denis Tegg for one was not impressed, and obtained the relative documents under the OIA prior to the meeting. He made a submission in Public Forum that did noy go down well. The Council had earlier dealt with the Tonkin & Taylor Report on the suitability of the land in question in a workshop.

Denis’s valid concerns, and request for a full legal report on the likely jeopardy of pursuing this proposal in its present form, are summarised below, but first I have posted the Executive Summary of the Tonkin & Taylor Report so that readers can fully understand the relaxed approach adopted by this consultancy in arriving at its conclusion that “There are no fatal flaws” in the proposed development.

You may come to a different conclusion.

Here is the Executive Summary of the Tonkin & Taylor Report on the Thames Aerodrome Pre-Feasibility Site Study for a Regional Aquatic Centre,

Executive summary

Tonkin & Taylor Ltd (T+T) has undertaken a Pre-Feasibility Study for Thames Coromandel District Council (TCDC), assessing the proposed regional swimming pool complex development of Site 1: Aerodrome South.

The assessment of this site was part of a wider study for TCDC to assess envisaged future developments at three sites located in or near the Thames Aerodrome, immediately south of Thames. The assessment for Site 1: Aerodrome South covered the following pre-feasibility engineering considerations:

  • ·         Geotechnical;
  • ·         Flooding and coastal inundation; and
  • ·         Contaminated land

T+T has assessed that, based on the engineering aspects considered, there are no 'fatal flaws' to developing the southern area of the Aerodrome for a regional swimming complex. Projected sea level rise results in 100 Year ARI storm tide levels of 4.14 m for the 2120 projection. To continue to defend the area against this projected sea level rise, the stopbank design crest level would need to be raised by 1.14 m (and up to 1.6 m at existing low points in the stopbank).  (my bold)

As we have not undertaken any flood modelling, TCDC may wish to undertake further flood modelling in conjunction with WRC. This would incorporate updated sea level rise projections and model the effects of stopbank raising on the river systems, in particular the Kauaeranga River spillway across SH25.

The potential required increase in stopbank height is considered feasible in geotechnical terms. We expect that the potential geotechnical design constraints identified in this report could be addressed by appropriate design.

The key geotechnical considerations that will need to be addressed during detailed design are: seismic liquefaction potential; earthworks considerations; consolidation settlement (arising from surcharging from building loads or increasing site levels); foundation options; and stopbank stability. These considerations are addressed in this report, however we consider these can likely be addressed by appropriate design.

Results of soil sampling show that there are elevated concentrations of metals within the near surface soils (fill and topsoil), however the measured concentrations do not present a risk to human health or the environment, based on the current and proposed future land use. There is no evidence to suggest that ground contamination issues would constrain the proposed development of the site although they may add cost to development.

Due to previous hazardous activities and industries that have occurred on site, a resource consent is likely to be required as part of the requirements under the National Environmental Standards for Assessing and Managing Contaminants in Soil to Protect Human Health. The current soil testing results indicate that change in use or subdivision of the site can be undertaken as a permitted activity. We expect that this report could be used to form part of the resource consent application (if required).

We advise that Council take into consideration these findings when deciding on the next stages of the proposed development

This a a precis of the comments by Denis Tegg on the Tonkin & Taylor Study prepared and presented at the Public Forum on 18 November.

Firstly, let me make it clear that I am not opposed to a new swimming pool in or near Thames.  But it is my belief that the proposed airfield site is inappropriate and risky, and that we need a better site. I consider that the Tonkin & Taylor report has certain deficiencies, but more important, that a prefeasibility legal assessment is just as important.

I set out here the reasons I believe this to be the case.

  • In my opinion the proposed airfield site will not pass the legal tests and comply with the New Zealand Coastal Policy Statement provisions relating to coastal hazards.
  • Our highest court has determined that where Coastal Policy Statement objectives and policies use clear and directive language, local councils have a binding legal obligation to implement those policies.  In other words, There is no wriggle room.
  • Objective 5 is – “To ensure that coastal hazard risks taking account of climate change, are managed by locating new development away from areas prone to such risks; “
  • Policy 25 requires that “in areas potentially affected by coastal hazards over at least the next 100 years:  (a) avoid increasing the risk of social, environmental and economic harm from coastal hazards;”
  • “Avoid” has been defined by the Supreme Court as to mean “not allow” or “prevent occurrence of”. 
  • The Court of Appeal decision has just ruled that these principles also apply to resource consents when the Coastal Policy Statement uses clear prescriptive language like “avoid”. 
  • These directive policies are compulsory “bottom lines”. The Council cannot use an “overall judgement approach” under Part 2 of the RMA, or the District Plan to circumvent these policies. 
  • Council must also consider this proposal beyond “at least 100 years” The DOC guidance says consideration beyond 100 years is required where :-
  1. there is a significant increase in value of assets – ($25 million in this case)
  2. the effects are irreversible (the swimming pool will not be transportable) and
  3. the asset will important for several generation
  • Tonkin and Taylor have only considered sea level rise projections of a minimum 100 years out to 2120 of 1.36 m.  But the Ministry Guidance projects sea level rise out to 2150 of 1.88m. This adds a further half metre to both the depth of flooding, and projections for raising the crest height of the seawall used by Tonkin and Taylor. 
  • This would mean the seawall would have to be raised between 1.7 and 2.1 m higher than its current level.  It also implies that the entire seawall between Kopu and Tararu would also have to be raised by similar amounts to protect existing assets.

Other Matters

  • Land subsidence and Relative Sea Level Rise has not been considered– Land and settlement will substantially add to the inundation risks – both direct and via groundwater
  • Groundwater Intrusion - The report assumes groundwater levels will remain static when assessing liquefaction risk or building stability generally but takes no account of the potential for rising groundwater due to sea level rise.
  • There is no discussion as to how groundwater intrusion can be prevented from seeping under the seawall.  Raising the wall does not stop seepage underneath
  • River flooding models - The river flooding models from WRC are outdated – taking account of just 0.5 m of sea level rise and do not factor in the potential for more intense and long-lasting rain events due to climate change.
  • West Coast Tsunami Study - A report on tsunami risk in the Firth of Thames is due shortly.  An earlier report suggests that the airfield is the highest risk tsunami hazard area.  Local earthquake risk from the Kerepehi Fault is also being reassessed.
  • Shoreline Management Plans -  Coastal Management Strategy - These plans should be fully developed and public engagement undertaken before a decision is taken to proceed with the airfield site.  (Hawkes Bay )
  • Residual Risk - The residual risk from a failure or overtopping of the seawall or river stop banks is not discussed in the report (Edgecumbe situation)
  • Climate Change Projections are Outdated - The sea level rise and other climate change projections based on IPCC 2014 are now out of date.  By the time the project gets to the consent stage it is likely that higher sea level rise projections will apply.
  • Frequency of Extreme Storm Events - There is no discussion of the frequency of current one in 100-year events in the future – as per the Parliamentary Commissioner’s Report and MfE Guidance.


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Reader Comments (3)

So Dennis, feel free to suggest another location if this worries you so much. If you can only come up with barriers you are not helping the community to move forward with this project. Also remember the life expectancy of a public swimming pool before replacement or major refurb is 50 years tops.

September 21, 2018 | Unregistered Commenter.

As the SOLD sign is up, you will have to assume TCDC are the new owners

September 21, 2018 | Unregistered Commenter?

Regardless, and as Denis has pointed out, it is the legal obligations under the Coastal Policy Statement that have now been well established by legal precedent that our Council has to take regard of if it is to avoid legal jeopardy. If you know a way around that, then feel free to explain!

September 21, 2018 | Registered CommenterBill Barclay

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