31654827:637695

BEFORE THE ENVIRONMENT COURT I MUA I TE KOOTI TAIAO O AOTEAROA

IN THE MATTER of the Resource Management Act 1991 (RMA) AND IN THE MATTER of a direct referral application under section 87G

of the RMA for resource consents for the necessary infrastructure and related activities associated with holding the America’s Cup in Auckland

BETWEEN PANUKU DEVELOPMENT AUCKLAND

LIMITED

(ENV-2018-AKL-000078) Applicant AND AUCKLAND COUNCIL Regulatory Authority

STATEMENT OF EVIDENCE OF MITCHELL TSE ON BEHALF OF THE AUCKLAND COUNCIL

(AUCKLAND TRANSPORT)

Dated 21 August 2018

BROOKFIELDS LAWYERS M C Allan Telephone No. 09 979 2128 Fax No. 09 379 3224 P O Box 240 DX CP24134 AUCKLAND

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1. INTRODUCTION

1.1 My full name is Mitchell Bruce Tse.

1.2 My evidence is given on behalf of the Auckland Council (the Council) in its

regulatory capacity in relation to the direct referral application filed by Panuku

Development Auckland Limited (Applicant) seeking resource consents for the

construction, occupation, use and maintenance of permanent and temporary

infrastructure and undertaking of activities within the coastal marine area and on

land, associated with the America’s Cup (the Application).

1.3 My evidence should be read in conjunction with the traffic and transport evidence of

Ms Bronwyn Coomer-Smit prepared on behalf of the Council. I have relied on the

professional opinions of Ms Coomer-Smit for assessment of traffic and transport-

related effects. My evidence relates to Auckland Transport’s role and processes in

managing the construction and events traffic and transport aspects of the

Application. The precise scope of my evidence is explained below in section 5 of

my evidence.

2. QUALIFICATIONS AND EXPERIENCE

2.1 My role at Auckland Transport (AT) is the City Centre Network Operations (CCNO)

Technical Lead, reporting to the Technical Services Manager at Auckland Transport

Operations Centre (ATOC) Smales. This team is part of AT’s Transport Operation

Division and works closely with key stakeholders such as the New Zealand

Transport Agency in managing the northern portion of the North Island transport

network including the state highway, arterial and local roads between Taupo to Cape

Reinga.

2.2 I have held this role since February 2016. I was appointed to this position due to my

extensive knowledge of transport network management across Auckland.

2.3 I hold a New Zealand Certificate in Engineering (Civil) and a Diploma in Traffic

Engineering from Wellington Polytechnic, New Zealand and a Post Graduate

Certificate in Transport Planning Management and Control from the University of

New South Wales, Australia.

2.4 I am a Registered Engineering Associate and a member of the Transportation Group

New Zealand (formally known as the IPENZ Transportation Group), Signals New

Zealand User Group (SNUG) and SCATS Members User Group (SMUG).

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2.5 I have over 25 years of network operations experience with 18 years specifically in

the Auckland Region. I have provided intersection designs, transport impact

assessments, network planning, road safety audits across Auckland. My experience

included managing network impacts during the construction of the Newmarket

Viaduct, Victoria Park Tunnel, Waterview Tunnel and the management of Auckland

road network during the 2011 Rugby World Cup, 2015 Cricket World Cup and

numerous special events such as the annual Farmers Santa Parade, Christmas in

the Park, Bledisloe Cup Matches, and the British and Irish Lion’s 2017 Tour.

2.6 I have been managing the transport network for Auckland City Centre since 2016. I

work as part of the ATOC team, which is mandated to keep Auckland’s road network

moving as efficiently as possible for all transports modes. These include

pedestrians and people on cycles and vehicles travelling on roads on a day-to-day

basis. Some of the key functions that ATOC carries out are listed below:

a. monitor and manage traffic signals to manage all road corridors;

b. monitor traffic activities including accidents on the network and provide

response to these activities;

c. manage and co-ordinate public and private projects within the road corridors;

d. traffic control and management around events; and

e. integrate public transport with events.

3. MY ROLE

3.1 I did not provide a technical report for the Application as part of the Council’s section

87F reporting. AT’s Development Consenting Team assessed the traffic and

transport impacts of the Application together with Ms Coomer-Smit1. I am satisfied

that the transport and traffic effects from the Application have been adequately

assessed and addressed in the evidence of Ms Coomer-Smit.

3.2 For a normal resource consent application process, AT’s operations team does not

get involved until the construction traffic management plan (CTMP) is submitted,

which is a requirement of the conditions of consent or the Applicant commences a

Corridor Access Request (CAR) process. Due to the timeframe of this Application,

the Applicant has requested that the relevant management plans be reviewed as

part of the assessment. It is at this stage when I became involved with the

1 Ms Coomer-Smit’s and Ms Crafer’s report is at CB148, page 3811 onwards.

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Application. I have attended meetings with the Applicant and discussed the

requirements of these management plans. I have reviewed the draft CTMP, the

draft construction staff management plan (CSTP) and draft events traffic

management plan (ETMP) that formed part of Joseph Phillip’s evidence2.

3.3 Representatives from AT’s Development Consenting Team participated at the

Environment Court mediations for traffic and transport-related matters and reviewed

the proposed conditions of consent. I have also reviewed the relevant conditions of

consent for the CTMP, CSTP and the ETMP.

3.4 I participated in the Court-assisted expert witness conference relating to traffic and

transport on 26 July 2018 and was a signatory to the Joint Witness Statement (JWS)

of the same date3.

4. CODE OF CONDUCT

4.1 While aspects of my evidence might be characterised as more in the nature of

‘corporate’ evidence, I was involved in expert witness conferencing. In addition,

aspects of my evidence relate to the draft conditions and management plans.

Accordingly, I consider it appropriate to confirm the following matters:

(a) I have read the Code of Conduct for Expert Witnesses (Code) outlined in the

Environment Court's Consolidated Practice Note 2014 and have complied

with it in preparing this evidence;

(b) I agree to follow the Code when presenting evidence to the Court;

(c) I confirm that the issues addressed in this brief of evidence are within my

area of expertise, except where I state that I rely upon the evidence of other

expert witnesses; and

(d) I also confirm that I have not omitted to consider material facts known to me

that might alter or detract from my opinions.

5. SCOPE OF EVIDENCE

5.1 This statement of evidence covers the following:

2 Evidence of Joseph Phillips, E10, page 0537 onwards. 3 JWS, E23, page 1294 onwards.

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(a) A summary of my evidence;

(b) AT’s role when assessing this Application;

(c) AT’s role in managing construction traffic and transport impacts on the road

network during construction and providing details of the Corridor Access

Request (CAR) process;

(d) AT’s role in the planning and management of events; and

(e) Conclusions.

5.2 I do not provide an assessment of traffic effects in my evidence, and I rely on the

assessment provided in the evidence of Bronwyn Coomer-Smit in that regard.

6. EXECUTIVE SUMMARY

6.1 AT is responsible for managing the road corridors and the transport network. Any

construction activities requiring works or closure of the road corridors will require a

CAR permit from AT. The Applicant and the Event host will be working with Council,

Auckland Tourism, Events and Economic Development (ATEED) and AT to plan

and manage the events. An additional event permit will be required from the Council,

and AT will be part of that planning process to ensure impacts on its transport

network including its public transport network are minimised and managed. AT’s

ATOC will work closely with the Event’s MEOC during the event operation to

implement additional mitigations to manage any escalation of the events.

7. AT’S STATUTORY FUNCTIONS AND RESPONSIBILITIES AND ITS ROLE IN

ASSESSING THE APPLICATION

7.1 AT is a council-controlled organisation (CCO) established on 1 November 2010

under section 38 of the Local Government (Auckland Council) Act 2009 (LG(AC)A).

Its statutory purpose, as set out in section 39 of LG(AC)A, is “to contribute to an

effective, efficient and safe Auckland land transport system in the public interest”.

AT is also a requiring authority and road controlling authority for the region.

7.2 The Auckland Council Resource Consent Department is responsible for assessing

resource consent applications for development within the region. AT is involved in

moderately scaled land use and subdivision applications providing comments on

traffic and transport assessments as they relate to AT functions and operations, as

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well as advice on road assets to be provided and vested with AT. When assessing

resource consent applications, AT ensures its functions and responsibilities are met

by providing comments and guidance on the following:

a. operation of the local road network;

b. ensuring the safety of all modes of transport are considered and provided

for; and

c. developing and enhancing the local road, public transport, and walking

and cycling networks.

7.3 AT has not made an independent submission on this Application and has provided

input to the Council’s traffic and transport assessment prepared by Ms Coomer-Smit

in assessing the traffic and transport effects of the Application. AT has not engaged

an independent traffic consultant to advise on the Application. AT staff have been

working closely with Ms Coomer-Smit and relied on her traffic and transport

assessment.

8. AT’S ROLE IN MANAGING CONSTRUCTION TRAFFIC AND TRANSPORT

IMPACTS ON THE ROAD NETWORK

8.1 I understand that some section 274 parties may be concerned in relation to how

construction traffic will be managed, especially for the Wynyard Quarter area, given:

there are a number of projects currently under construction; the constraints of the

road network; and the tight timeframe for the delivery of the AC36 infrastructure and

bases. I provide the following to assist the Court and section 274 parties to

understand AT’s role in managing the transport network during the construction

phase of the Application.

8.2 I preface my comments below by noting that, at expert witness conferencing, the

traffic experts agreed that the draft CTMP and CSTP, and the related objectives, will

enable construction transport effects to be satisfactorily managed and mitigated4. I

have carried out a general review of the draft CTMP and CSTP prepared by the

Applicant. Subject to Ms Coomer-Smit’s further recommendations on these draft

management plans and relevant conditions of consent5, I have no significant

concerns with what has been proposed to manage construction traffic relating to the

4 Traffic JWS, E23, page 1296, para 3.2. The JWS records that Mr Parlane raised an issue about the

loss of off-street car parking – I rely on Ms Coomer-Smit’s evidence concerning that matter. 5 Evidence of B Coomer-Smit, paragraph 9.8.

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Application within Wynyard Quarter, the Viaduct Basin and the Hobson Wharf / Quay

Street vicinities.

8.3 In particular, I support the proposed conditions of consent (refer to condition 22C)

requiring consultation with the Community Liaison Group (which will include

representatives of AT) in the development and content of plans such as the CTMP

and ETMP. This will ensure AT is involved for the preparation of traffic related

management plans e.g. CTMP for the syndicate bases and the event traffic

management plans for subsequent Events following AC36, should further events be

held in Auckland.

8.4 I am generally satisfied with the proposed traffic management measures outlined in

the draft CTMP attached to Mr Phillip’s evidence. I note it is a proposed requirement

of the resource consent for AC36 (refer to condition 103) to provide a CTMP (or

potentially several CTMPs, e.g. for syndicate base construction works). The CTMP

is generally reviewed and certified in conjunction with Council’s development

engineering team as part of the engineering approval process. AT manages the

road corridor and approval must therefore be obtained from AT for any works within

the road corridor.

8.5 For works to occur within the road, a CAR application must be made to AT’s Road

Corridor Access (RCA) team who manages works within the road. The Applicant

must upload their application detailing their proposed works in the road via an online

system called MyWorkSites. This portal allows the RCA team to review temporary

traffic management plans and see potential clashes of existing or proposed works

within the same road corridor. Depending on the complexity of the work on the road

and the proposed temporary traffic management the RCA team then involves other

experts from other AT departments to assist and evaluate the situation. An online

portal ensures that all applications can be reviewed together and integrated where

necessary to minimise impacts on the transport network.

8.6 A traffic management plan (TMP) is required for each CAR application to undertake

works within the road corridors. TMPs are site-specific plans that cover the design,

implementation, maintenance and removal of temporary traffic management (TTM)

measures while work or activity is carried out in the road corridor (road, footpath or

berm). These are uploaded on the online portal and are much more detailed than

the draft CTMP already submitted. As part of the RCA approval, the contractor is

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required to write to the residents and businesses in the affected area and emergency

services are advised of the proposed traffic management and affected timeframe.

8.7 To provide a current example, the City Rail Link project requires works within Albert

Street resulting in the partial stopping and temporary diversion of traffic. This project

is required to submit a CAR application. At this point, the RCA team will collaborate

and manage other projects e.g. Commercial Bay Development on Lower Albert

Street where they may have requested works within the road corridor. These

requests are managed by the RCA team in consultation with ATOC team and other

teams at AT to ensure the transport network is not adversely impacted. For example,

it is necessary to ensure the Northern Express Buses have continued access via

this part of the City to ensure public transport services are not disrupted. While at

the same time ensuring all projects requiring works within the vicinity can continue

with their construction programme in a timely manner.

8.8 In relation to the management of the Application’s construction traffic, this will be

managed in the same or similar manner to all construction works within the City. I

have discussed the requirements for the CAR application for the Application’s

construction works with Richard Galloway, the Construction Traffic Manager for

Wynyard Edge Alliance. This included specific discussion in relation to the

management of construction works within Wynyard Quarter, the Viaduct and

Downtown.

8.9 It is important to ensure the safety of all transport modes including pedestrians and

people on cycles are provided while managing the construction effects within the

area. The specifics of the CTMP as outlined in proposed conditions 104 and 105

will also guide the processing of the CAR process. The proposed conditions of

consent (see proposed condition 104(e)) also do not allow the Applicant to seek a

full road closure of any road to facilitate construction activities. Only managed and

partial road closures are provided for and therefore can be applied for via the CAR

process. The definitions for full, managed and partial road closures are included in

the conditions of consent. I agree with these definitions.

8.10 A number of submissions also raised concerns regarding the number of construction

projects that are taking place or going to take place within similar area and timeframe

as the Application. Apart from reviewing the CTMP, AT’s RCA team also manages

any CAR applications via the online portal to minimise the impacts on the road

networks from construction projects happening within similar timeframe in the same

area. These processes have been used for large construction projects which I have

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managed in the past. Refer to paragraph 2.5 of my evidence. I am satisfied that

AT’s CAR process can manage other construction projects that may be occurring

contemporaneously in the area during the America’s Cup construction programme.

This will also assist the Applicant to satisfy condition 105(i) requiring co-ordination

with AT regarding other construction sites and streetworks in the vicinity of the

Wynyard Precinct and the Viaduct Precinct, including works on Quay Street.

8.11 Apart from the CAR process as described above, the CCNO team hold weekly

meetings with contractors and internal stakeholders (Traffic Operations, Road

Safety, Travel Demand, Parking, Special Events, AT Metro and NZTA) regarding all

works taking place in the City Centre including Wynyard Quarter. These meetings

provide updates on existing works/projects and also upcoming works/proposed

works where opportunities are seen to work collaboratively with less disruption to

the network, reduce clashes and also manage work sites. Site meetings with

contractors and traffic management companies also take place. The CCNO also

undertakes weekly site audits across all the projects currently active to ensure

temporary traffic management setups are appropriate and compliant. Furthermore,

a monthly internal stakeholder meeting is held to ensure our traffic operations, road

safety and travel demand teams are kept informed of the impacts and performance

of the network as these projects are delivered. The CCNO also provides weekly and

monthly reports to ensure AT’s Senior Management Team is kept informed on the

management and operation constraints of the network.

9. AT’S ROLE IN MANAGING TRANSPORT AND TRAFFIC MATTERS DURING

EVENTS

9.1 I now turn to AT’s role in the management of transport and traffic during events. I

have read Grant Calder’s evidence regarding the America’s Cup events

management6. Section 7 of this evidence provides an outline of the event permit

process which is a separate permit from the Council and additional to the resource

consent process. Mr Calder confirms that the application for hosting an event will

require consultation with AT and ATEED, which is also a CCO. I confirm that I have

attended a meeting with the Applicant and ATEED to discuss the traffic and transport

management during the AC36 events. I attended this meeting with representatives

from AT’s Special Events team and AT Metro.

6 Evidence of Grant Calder, E4, page 0057 onwards.

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9.2 Planning for the AC36 events is no different to planning other events that occur

within the City. In paragraph 7.3 of Mr Calder’s evidence, he provided examples of

other successful events that have occurred within the same location as the

Application. These include the Volvo Ocean Race and the Auckland Boat Show. In

most cases AT’s Special Event team have been involved in the planning process of

these events from initial concept to event delivery. I agree that there is a well-

established process that has worked well with events such as the Volvo Ocean

Race. Equally, I agree with Mr Calder’s observation that, as the America’s Cup

event will occur over a longer period, additional measures such as earlier

consultation with a broader group of stakeholders within Wynyard and Viaduct

Harbour Precincts as well as Princes Wharf residents will be required as part of the

event permit application.

9.3 An ETMP is required by the proposed conditions of consent (refer to condition 183

onwards). I have reviewed the draft ETMP attached to Mr Phillip’s evidence. I

generally agree with the proposed measures, but these will be subject to further

refinement as the details of the event develop. Measures will be provided to ensure

residents and businesses are consulted and provided for during events. Council’s

event permit application is additional to the requirements of the RMA.

9.4 AT’s Special Events team manages and co-ordinates impacts due to events

operation on the Auckland Transport network. This team processes and approves

every event in Auckland from sold out stadium concerts to community groups

meeting in regional parks. Their mission is to provide a co-ordinated and integrated

traffic and transport operation for events. We achieve this through:

(a) Reviewing and approving Traffic Management Plans (TMP) for events;

(b) Creating parking resolutions to restrict parking around event venues;

(c) Helping control the flow of traffic and create a safe environment for

pedestrians/crowds in the area;

(d) Operate Special Event Bus and Rail Services for the public heading to major

events in Auckland;

(e) Working with normal route buses that work within an event area to divert

them to a suitable location;

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(f) Creating a safe environment for crowd queuing and controlling and creating

a high demand for Public Transport options heading to and from events;

(g) Creating comprehensive marketing, media and communications plans

around each event using various channels such as social media, print, radio,

customer service centre and AT website. This is actively managed by the

team pre, during and post event

(h) Engaging with event stakeholders and Council organisations to bring events

to Auckland from the bidding process to the end of event; and

(i) Being onsite in the control room or in ATOC monitoring and controlling all

outside venue operations.

9.5 I understand that the Applicant together with the event host – America’s Cup Events

Limited – will engage with Auckland Transport (and other stakeholders) at an early

stage regarding the planning and management of the event. AT’s Special Events

Team will be (and has already been) involved with the event permit process to

ensure that the impact of the event on the network and public transport services is

balanced and co-ordinated with any other activities, as well as day to day

management and monitoring during the event itself as per the points above.

9.6 Apart from the Special Event Team, an AT Metro representative has also liaised with

the Applicant in relation to the management of the bus network during the different

event scenarios as described in Mr Phillip’s evidence. Bus services can be diverted

to cater for the scale of the event as stated in Mr Phillips’s evidence. Any temporary

diversion and special provisions of bus, ferry and rail services can be arranged with

prior consultation with AT. Once these plans are finalised, the details of any special

arrangement or diversion will be communicated to the public via all media platforms.

9.7 During the event itself, AT Special Events is expecting to operate an ATOC event

model with a direct link to the event Major Event Operation Centre (MEOC). From

here, there will be real time monitoring across all modes of transport and the ability

to respond to incidents or large scale crowd movements at short notice. Functions

housed within the ATOC model will include CCTV monitoring, rail and bus network

operations, traffic signals and temporary traffic management. The MEOC will

monitor the scale of the activities occurring within the event area and where

necessary additional measures will be undertaken to ensure the impacts to the

transport network are minimised as much as possible.

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10 CONCLUSIONS

10.1 My evidence provides an overview of the additional processes that AT carries out to

manage the road corridors due to construction activities from projects and events.

These processes are additional to the mitigation measures required as part of the

resource consent to manage adverse traffic and transport effects. Existing AT

processes are in place to collaborate and manage contemporaneous construction

works within road corridors. These have been used to manage large construction

projects such as City Rail Link and Commercial Bay Development within the

Downtown area. AT’s processes for special events in conjunction with Council’s

requirements for an event permit will ensure the impacts on businesses and

residents in relation to traffic and transportation matters can be minimised where

possible. AT’s ATOC team will work closely with the MEOC which will be set up to

manage operating issues during the events.

Mitchell Tse

21 August 2018

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