IN THE MATTER of the Resource Management Act 1991 (RMA

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IN THE MATTER
of the Resource Management Act 1991 (RMA)
AND
IN THE MATTER
of a joint application by Kokiri Lime Company
Limited for resource consents to establish and
operate an open pit alluvial gold mine under s 88
of the RMA (RC150362 and RM15.361)
BETWEEN
KOKIRI LIME COMPANY LIMITED
Applicant
AND
OTAGO REGIONAL COUNCIL
Consent Authority
AND
CENTRAL OTAGO DISTRICT COUNCIL
Consent Authority
PRIMARY STATEMENT OF EVIDENCE OF
JASON ALEXANDER BARTLETT FOR KOKIRI LIME COMPANY
LIMITED
31 May 2016
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SUMMARY OF EVIDENCE
1.
My name is Jason Alexander Bartlett and I am a traffic engineer. I summarise
my evidence, according to the key headings in this statement, as follows:
Traffic Assessment
(a)
I prepared the Traffic Assessment for the proposed alluvial gold mine.
This assessment forms part of the Resource Consent Application, and
is included under Appendix C.
Submissions and correspondence with submitters
(b)
Kokiri Lime Company Limited have consulted with major submitters,
being the New Zealand Transport Agency (NZTA) and the Ministry of
Education (MoE). Through this consultation conditions of consent
have been agreed which are appropriate and will manage or mitigate
any potential transport effects.
Central Otago District Council’s recommendations
(c)
The Central Otago District Council’s section 42A report, in relation to
traffic considerations, considers the consultation undertaken, as well
as the specific conditions of consent, will manage or mitigate any
effects on the users of the adjacent state highway and the unformed
legal roads which pass through the mine site.
Conclusion
(d)
I consider that the proposed conditions of consent, subject to the
proposed additional amendments in response to issues raised by
submitters, are appropriate to manage or mitigate any potential
transport effects.
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INTRODUCTION
Qualifications and experience
2.
My name is Jason Alexander Bartlett.
3.
I am an experienced traffic and transportation engineer. My academic and
professional qualifications are:
(a)
New Zealand Certificate in Engineering, Civil Option obtained in 1993;
(b)
Bachelor of Engineering (BE) from the University of Canterbury
awarded in 1996;
(c)
Graduate Member of the Institution of Professional Engineers of New
Zealand (G.IPENZ), since 1995; and
(d)
Chartered Engineer and Member of the Institution of Civil Engineers
(CEng MICE), since 2007.
4.
I have over twenty years’ experience in road design, network management,
traffic and transportation engineering including nine years in the UK. During
my time in the UK I became a Chartered Engineer and a Member of the
Institution of Civil Engineers.
5.
Since April 2008 I have been working as a traffic and transportation engineer
in Queenstown. The first four of these years was for GHD Limited. I now
operate my own traffic engineering consultancy, Bartlett Consulting, which
was established in July 2012.
Background to evidence preparation
6.
I have been retained by Kokiri Lime Company Limited (Kokiri) to prepare a
statement of evidence on the traffic and transportation effects of the proposed
gold mine.
7.
I have visited the site in July and August 2015 to review the adjacent highway
environment and possible mine access locations. I am generally familiar with
land development matters in Roxburgh and Central Otago through other
consulting briefs and previous work in the District.
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8.
I prepared the Traffic Assessment for Kokiri, dated November 2015, which
forms part of the Resource Consent Application and is included under
Appendix C.
9.
In preparing this evidence I have read the following documents:
(a)
“Kokiri Lime Company Limited – Alluvial Gold Mine – Resource
Consent Application and Assessment of Effects on the Environment”
(Resource Consent Application), prepared by Golder and dated
December 2015.
(b)
The NZTA Access standards and guidelines 1 which outline the
minimum requirements for an access onto a state highway;
(c)
The submissions which raise safety concerns, being the submissions
of NZTA, MoE and Leonie Patrick;
(d)
Central Otago District Council’s (CODC) section 42A report (CODC
Staff Report), filed on 5 May 2016, and prepared by Mr Dave Whitney,
CODC’s Planning Consultant.
(e)
The correspondence between major submitters (NZTA and MoE) with
Kokiri and to agree conditions of consent to manage or mitigate the
concerns raised in their submissions;
Outline of evidence
10.
In this brief of evidence, I will discuss:
(a)
Traffic assessment carried out;
(b)
The submissions relating to traffic and transport matters and
subsequent discussions between NZTA, MoE and Kokiri;
(c)
The recommendations, in relation to traffic and transport matters, in
CODC’s Staff Report; and
(d)
1
Proposed consent conditions.
From Transit (now NZTA) Planning Policy Manual (August 2007), Appendix 5B
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CODE OF CONDUCT
11.
I have been provided with a copy of the Code of Conduct for Expert Witnesses
contained in the Environment Court’s Consolidated Practice Note dated 1
December 2014. I have read and agree to comply with that Code.
12.
I confirm that the topics and opinions addressed in this statement are within
my area of expertise except where I state that I have relied on the evidence
of other persons. I have not omitted to consider materials or facts known to
me that might alter or detract from the opinions I have expressed.
TRAFFIC ASSESSMENT
13.
Kokiri propose to establish an alluvial gold mine north of Roxburgh. This mine
is generally on land to the west of State Highway 8 (SH8) although it also
includes land within the SH8 road reserve and to the east of SH8.
14.
The mine will be accessed from SH8. The mine is mobile and will move
through the area over a 15 year (cumulative) time period. During this time a
number of accesses will be formed.
15.
In this location SH8 is generally flat and straight with a number of existing
property access. The road is a Limited Access Road (LAR) meaning that it is
difficult to form new accesses from SH8.
16.
To limit the effect of the mining operation on the safety and operational
efficiency of SH8, my Traffic Assessment recommended:
(a)
That access to the mine should utilise existing crossing places which
comply with the minimum standards set out be NZTA;
(b)
That the mine shall operate no more than two crossing places at any
one time. One of these must be able to accommodate heavy vehicles;
(c)
That appropriate permissions be sought and approved should it
become viable to mine the area of the mine within the road reserve for
SH8; and
(d)
That appropriate visual barriers or screens are placed between SH8
and the operational area of the mine to minimise driver distraction.
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17.
To manage these effects to a degree I consider to be less than minor, I
recommended a number of conditions of consent, and these conditions were
incorporated into the Resource Consent Application.
18.
It is also noted that no formed local roads pass through the mine area, though
there are a number of unformed legal roads which do. One of which provides
access to a local walking track, Bullock Track Walkway.
SUBMISSIONS AND CORRESPONDENCE WITH SUBMITTERS
Introduction
19.
Three of the submissions identify transport concerns.
Submission of NZTA
20.
NZTA submitted in opposition to the application. The submission raises a
number of concerns relating to effects on the continued effective operation of
SH8 and the sustainability effects of the application and mining activity on the
state highway resource.
21.
After the receipt of NZTA’s submission, Kokiri met with NZTA.
I have
reviewed the correspondence that was subsequently exchanged between
Kokiri and NZTA regarding conditions of consent which would be acceptable
to NZTA. I consider that the proposed conditions of consent 2, which will be
presented by Ms Carmen Taylor in her evidence, are appropriate to mitigate
or manage the potential adverse effects on SH8 identified by NZTA. I
understand that these conditions are acceptable to NZTA.
Submission of MoE
22.
The MoE submission raised concerns regarding the movement of the school
bus and the safety of school bus users in the vicinity of the mine access. The
MoE provided provisions to be included within the conditions of consent
should consent be granted.
2
Refer Evidence of Ms Carmen Taylor, Annexure B, Kokiri’s Proposed Amendments to CODC’s Land Use
Consent Conditions, Conditions 17 (including Advice Notes 1 and 2), 18, 19 (including Advice Note) and
19A.
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23.
I have reviewed subsequent correspondence between Kokiri and MoE
regarding conditions of consent which would manage or mitigate the concerns
that they raised in the MoE submission. The proposed conditions of consent
will include conditions to stop heavy vehicle access to the mine during the
hours of the school bus activity on the adjacent SH8 3 . I consider these
conditions are appropriate to mitigate or manage the potential adverse effects
on SH8 identified by MoE I understand that these conditions are acceptable
to the MoE.
Submission of Ms Leonie Patrick
24.
A submission in opposition by Ms Leonie Patrick also raised concerns relating
to interruption of traffic flow along SH8. I have no further details regarding the
basis of this concern and therefore cannot make any further specific comment.
However, I reiterate the conclusions of my assessment. That is, potential
traffic effects will, in my opinion, be less than minor provided the effects are
managed in accordance with the proposed consent conditions.
Summary
25.
I note that the concerns raised, by NZTA and MoE, are primarily focused on
the effects experienced by road users. I therefore consider that the proposed
conditions of consent are appropriate to manage or mitigate any potential
transport effects on the adjacent road network.
RESPONSE TO DISTRICT COUNCIL RECOMMENDATIONS
26.
The CODC Staff Report provides a good summary of the traffic effects of the
proposed mine. Generally, this report promotes the conditions of consent
agreed between the Kokiri and NZTA, and MoE.
27.
I note the report also proposes conditions of consent regarding the use,
diversion and rehabilitation of the pedestrian and cycle paths adjacent to SH8
and unformed legal roads that pass through the site, which includes access
3
Refer Evidence of Ms Carmen Taylor, Annexure B, Kokiri’s Proposed Amendments to CODC’s Land Use
Consent Conditions, Conditions 17A.
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to the Bullock Creek Walkway 4. I consider that the proposed conditions of
consent regarding these unformed legal roads are appropriate to manage or
mitigate any potential transport effects.
PROPOSED CONDITIONS OF CONSENT
28.
I have reviewed the proposed traffic conditions which will be presented by Ms
Carmen Taylor in her evidence. These conditions are a result of consultation
with NZTA and MoE, together with the conditions suggested by CODC. I
consider that the proposed conditions of consent are appropriate to manage
or mitigate any potential transport effects of the proposed mine.
CONCLUSION
29.
In summary, I conclude that:
(a)
Kokiri propose to establish an alluvial gold mine north of Roxburgh
which is generally on land to the west of SH8. The mine area will also
include land within the SH8 road reserve and to the east of SH8.
(b)
The mine will be accessed from SH8. It is proposed that a maximum
of two mine accesses would be used at any one time. These accesses
would be constructed to meet the minimum standards of NZTA.
(c)
Consultation with NZTA has resulted in a number of proposed
conditions of consent which will manage or mitigate the potential
adverse effects of the mine on the adjacent SH8.
(d)
Consultation with MoE has resulted in proposed conditions of consent
which will mitigate heavy vehicle movements around the school bus
and maintain the safety of school bus users.
4
Refer Evidence of Ms Carmen Taylor, Annexure B, Kokiri’s Proposed Amendments to CODC’s Land Use
Consent Conditions, Conditions 19A.
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(e)
The CODC Staff Report considers the consultation undertaken with
NZTA and MoE, and also recommends specific conditions of consent
to manage or mitigate any effects on the users of unformed legal road
which pass through the mine site including access to the Bullock Creek
Walkway.
30.
I consider that the proposed conditions of consent are appropriate to manage
or mitigate any potential transport effects. With these conditions of consent
in place I consider that the effects of the proposed alluvial gold mine will be
less than minor.
Dated this 31st day of May 2016
________________________
Jason Bartlett
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