We Love Wakatipu Inc submission to the draft Queenstown Lakes Spatial Plan

April 2021

Dear hearing panel,

Thank you for the opportunity to submit on this vital document. This is a submission on behalf of We Love Wakatipu Incorporated Society (WLW), which was set up to fight Queenstown Airport Corporation’s plan to expand ZQN’s air noise boundary (ANB), on behalf of our community. 

We agree with the necessity of having a long-term spatial plan and with many of the contents of this draft. However, we believe it is based on a fundamentally flawed basic assumption and a concept of “Grow Well/Whaiora” that reflects the perspective of tourism business rather than repeated and strong community feedback on the inherent contradiction between continued airport growth and the well-being of our community.

Because this feedback – the community has been saying a very loud and clear “no” to expanding the ANB since first asked by QAC in 2018 – has been ignored to date, many we have spoken to will not submit on the Spatial Plan.  Between cynicism and Covid, they have run out of energy to respond on issues that they feel will be seen only through the current council’s ‘more bums on seats’ tourism business lens.

As hearing panel member Cr Glyn Lewers will remember, he and I presented a 1500-strong petition plus substantial submissions from Frankton Community Association (he was then chair) and Kelvin Peninsula Community Association (which I was representing) to QAC back in mid-2018, expressing both communities’ united opposition to ANB expansion and all its downstream ramifications. Cr Lewers’ voting pattern and statements indicate his position has changed since leaving the FCA role. At the KPCA meeting that fed into our submission, and every meeting since, this opposition has remained unanimous.  Overall, over 92% of around 1500 submissions opposed QAC’s expansion plans. This strong community opposition was again reflected in the council commissioned MartinJenkins report on socio-economic impacts of different airport scenarios.  This report was commissioned at the behest of Mayor Jim Boult when the issue became the unwanted central election issue, purportedly to guide future council airport growth scenario decisions.

However, MartinJenkins and council staff running the process refused specific requests from local group FlightPlan2050 to offer a scenario for discussion in which Queenstown Airport was removed, opening up the land for other uses long-term.

Furthermore, it was made clear at the start of each workshop that discussion of this alternative was off the table.  MartinJenkins’ scenario of a third international airport did not pair such development with closure of ZQN and the potential upsides of this.  And despite this, it received strong support from the community.

The MartinJenkins report was further flawed by concentrating on the narrow lens of GDP and modelled economic impact. The “socio” part of the socio-economic report was largely ignored. As was the promise that it would include environmental impacts.

However, as councillors have still not specifically workshopped this report and its findings, the flaws have probably had little impact and this discussion is included just to illustrate the paucity of meaningful community consultation on airport growth to date.

The same prohibition on discussing the future of the ZQN-shaped doughnut that is currently Frankton’s land resource was imposed when the Frankton community came together to feed into QLDC’s Frankton master plan.

All of which contrasts significantly with the Spatial Plan’s claim that a key part of engaging with the community was to test future growth scenarios and have robust discussions on possible outcomes. Neither alternative scenarios nor robust discussion was allowed at any of these community engagements.

And so it probably comes as no surprise to anyone that one of the two fundamental assumptions on which the Spatial Plan has been based is continued growth of Queenstown and Wanaka airports in our midst, to meet demand.

When asked in the past, QAC has said this “demand” is based on predictions by experts of likely airline demand.

It is certainly not the “demand” of our communities.  As the clear feedback mentioned above, the Mood of the Nation and QLDC Quality of Life surveys have shown, pre-Covid growth was far above the “well-being” threshold of our communities. It is the four well-beings that QLDC is charged with responsibility for – economic, social, community and environmental – not meeting international airline demand.

The second assumption on which the Spatial Plan is based is that growth will soon return to pre-Covid levels and then continue, so that our population and visitor numbers double by 2050.

WLW accepts that the government requirement for the Spatial Plan is predicated on Queenstown Lakes being a high growth district.  However, the loss of social licence for tourism and serious angst against excessive growth expressed in many forums suggest a council focused on its community’s wellbeing would aim to minimise rather than maximise the developer-driven freight train of growth we have experienced in recent years.

The Spatial Plan states its purpose is to “ensure we are delivering the best possible future for our community and the generations that will follow us.”  Which sounds great. As does its label – Grow Well/Whaiora. 

But the problem is one of who/what is the driver of those definitions of “better future” and “Grow Well/Whaiora”?

Certainly not all the feedback showing both Queenstown and Wanaka communities vehemently oppose QAC/QLDC’s airport expansion plans, nor our clear pre-Covid exhaustion with over-tourism and unmitigated growth. 

Not the imperative of climate change mitigation nor the distinct possibility that a better regulated, safer, more climate-friendly international airport at Tarras would be a commercial reality that even QAC and QLDC couldn’t ignore long-term.

Continuing to grow an excessively noisy international airport in the middle of an increasingly dense urban centre doesn’t enhance any of the four well-beings the council is mandated to provide for, nor meet any reasonable definition of growing well/whaiora.

Especially when QAC, council and our community all know that one day, ZQN will hit its ultimate outer growth limit. It is New Zealand’s most dangerous airport, physically constrained by the river at one end of the runway and the lake at the other, in the midst of a community largely hostile to its presence. 

Hence the dual airport strategy, which QAC started promulgating more seriously in the wake of the 2018 Queenstown response to its ANB expansion plans, with the intention of flicking flights over to the Upper Clutha once ZQN was maxed out.

Although this submission focuses on Queenstown Airport, we must raise the question of whether growing two international airports in the middle of largely hostile host communities is the best use of high value land in two of New Zealand’s most valuable tourist resorts, for the next 30 years or longer term?

Looking at airport infrastructure from regional and national perspectives, is $800 million spent on building/rebuilding two international airports in Queenstown Lakes District sensible expenditure?  Especially when they seriously diminish social licence for tourism in the district that acts as New Zealand’s primary tourism magnet? 

As stated above, We Love Wakatipu Inc’s goal is to stop expansion of ZQN’s air noise boundaries and all its downstream ramifications.  So, our particular concerns in the plan are as follows:

• That the basic assumption of continued growth of Queenstown Airport should be removed.  The community has been resolutely clear in its rejection of ANB expansion – even the Chamber of Commerce and many of Queenstown’s biggest tourism businesses submitted in opposition, in the pre-Covid reality of Queenstown’s community buckling under over-tourism. (Again, Cr Lewers will be able to give you more detail as he was the front person for this group.) This assumption closes off so many other potential opportunities for land-use.  Not just of the ZQN land itself, as the map in the Spatial Plan wrongly suggests, but also all the adjacent land under the expanded ANB.  To have as a basic assumption a principle that contradicts community so strongly, and so limits the potential uses of so much of our best land resource, makes a mockery of the fundamental purpose of the Spatial Plan.
  
• That the Spatial Plan recognises the strong community feedback on QAC’s ANB expansion plan and specifically excludes capacity to do this. ZQN already severely restricts activities on adjacent land and within the ANB. Unfortunately, most owners of these properties have non-complaint covenants that mean you won’t hear from them. Some of the many reasons our community is so strongly against expansion of the ANBs are excessive noise, traffic congestion, impacts on our use of outdoor space, air pollution, loss of social licence for tourism, health effects and loss of community through over-tourism (please see our WLW website and Protect Queenstown Facebook for more details).  Expansion of the ANB as planned by QAC would mean 4000 more properties would be restricted in their use, with no ASANs (activities sensitive to air noise) allowed and design constrained by the need to meet 40Db limits in all bedrooms and living areas. This is a severe restriction on private property rights, which would not be compensated for in any way. People do not live in or visit Queenstown to sit inside an air-conditioned box.
  
• That the inclusion of the Frankton masterplan, which was based on inadequate reflection of community feedback, be caveated. The ‘wordles’ created from public feedback to Shaping Our Future’s Frankton Future Forum (please see page 8) clearly show major contradictions between locals’ aspirations and the presence of a growing international airport in their midst.
  

• That greater consideration be given to climate change mitigation and the likely impacts of this on global long-haul tourism and thus, ZQN use.
  
• That (page 34/35) greater realism be given to the impacts of current ANB impacts. Currently described as “restricts some development outcomes in parts of Frankton,” and showing only the airport land itself, these impacts spread over a far larger area. For instance, council suggestions that Frankton Motor Camp (owned by Council) could be used for affordable housing/worker accommodation were nixed by QAC counsel during proposed district plan hearings, as they were considered an ASAN, and therefore forbidden. The ANB is the greatest constraint on broader Frankton and West-East Corridor spatial use – in terms of height, activities and so on. Witness also the constraints on Queenstown Events Centre land-use.  Plus the impact on people wanting to build their homes and having to meet QAC- imposed internal noise limits.
  
• That if ANB expansion is not ruled out in this Spatial Plan, that the depth and breadth of these impacts are clarified in the narrative and the map, to better inform the 2024 review. Currently the plan is silent on this, part of a pattern of the Spatial Plan narrative minimising problems and land use limitations created by the airport.
  
• Under transport options, mention is made of Queenstown’s role as a domestic and international tourism gateway compounding issues of congestion, emissions and safety. There is an apparent assumption that this gateway/regional hub role should continue. Why should it? It could easily be changed by QLDC giving QAC such instruction through its letter of expectations for the Statement of Corporate Intent.
  
• The map on page 52 has somehow forgotten the huge hole in the middle of the major metropolitan of Frankton created by the airport.  This bifurcates Frankton residential and commercial areas, restricts potential for connections and severely curtails much land use. How can and why would the draft Spatial Plan ignore such a huge impingement on our most usable space?
  

• The page 88 section on air services is a commercially and politically driven narrative that lacks the objectivity expected of an independent and professional Spatial Plan. Many locals would disagree with the claim that air services connectivity across Queenstown Lakes is “vital to the economic and social well-being of the Queenstown Lakes”. Sure, our community needs connectivity. It need not be to the level wanted by QAC. It need not be provided at ZQN. Also commercially/politically driven is the statement that “it is important that the level of service continues to support growth in demand for commercial air services”. This would appear to be a fundamental Spatial Plan paradigm. But such political pressure cheapens the document and should be removed, in favour of strategic independence that will survive both the current council term and community critique.
  
• This section also describes QAC’s dual airport vision as “at conceptual level”. A pretty well-developed concept, considering we have been told that redevelopment of both airports would cost around $400million each and have submitted on QAC’s alternative ZQN terminal options. It is interesting that the narrative says that further community consultation is required. Better, surely, that QAC and council stop ignoring the consultation already done and agree to operate within the existing ANB.  With already existing noise technology improvements and capacity increases, the current ANB allows several times the number of passengers QAC claims it is targeting through ANB expansion. We have received confirmation through a LGOIMA response from QAC that their ANB and demand modelling to date does not take any account of this. ANB expansion would in fact allow many, many more tourists than the 5.2 million passengers QAC claim to be targeting, with no ability for QLDC/community to control this further growth. Further good reason to ban ANB expansion in the Spatial Plan.

Perhaps the saddest part of this Spatial Plan, however, is the fact that the broader Spatial Plan team has not used this opportunity to trigger/force a broader debate about the best use of the hole in the middle of Frankton doughnut, faced with the current council’s reluctance to do so.

WLW is not pushing for relocation of ZQN – but surely this is a debate worth having now, when the draft Spatial Plan is focused on best use of our constrained and valuable land resource and $800 million has not yet been spent on QAC’s unpopular redevelopment plans. 

This is the time and place for open-minded, blue sky thinking – especially in the face of the competing Tarras International Airport proposal and demands from so many in the community for a reset in the wake of Covid. 

Proposing two international airports within 70km of each other is bad enough – to potentially have three, because of intractable council competition and the current lack of nationwide airport infrastructure coordination capacity, would be an unforgivable waste on many fronts.

QLDC’s and QAC’s response to this Tarras proposal (beyond the Spatial Plan’s one-liner) has been to take the strategic direction of the airport totally behind closed doors, to be developed by QAC with no councillor sign off and zero community input, to ensure that CIAL has no visibility of QAC’s defence and attack strategy.

This makes the Spatial Plan even more critical for our community, as the council has abandoned the “total control” it claimed it had over QAC through its Statement of Corporate Intent during November’s High Court case, any chance of community input and any transparency.

In conclusion, the Spatial Plan is our community’s best opportunity to work out whether a noisy (and getting noisier) international airport is the optimal use of Wakatipu’s biggest chunk of developable, flat, sunny, geotechnically stable land, already blessed with the necessary community, recreational and infrastructural requirements.

Or is there a better alternative for community, economic, environmental and social well-being and climate change mitigation than the continued, dispersed and diluted web of homes, roads and pipes across the Wakatipu?

Remember, these are the four well-beings (‘wellness’ in Spatial Plan-speak) our councillors are obliged under the Local Government Act to base their strategic decisions on. Have councillors remembered the Climate Emergency Declaration they voted for not so long ago?

In 108 pages, the Spatial Plan text is almost silent on ZQN, despite the central and critical assumption of its continued growth in Frankton’s heart. Perhaps because this assumption leaves no room for improved use of this space. Or, being eternal optimists, perhaps there is a realisation, somewhere in the spatial planning universe, that having New Zealand’s most dangerous airport consume this land is a nonsense we have more hope of addressing at the 2024 review, under a new council? And that Kai Tahu and central government members of this Spatial Plan working group would be supportive of this.

Our community should be allowed to have this debate before QAC spends some $800 million on dual airport development and ratepayers have to suck up all the other externalities and costs (think roading, loss of developable land, excessive noise, congestion, over-tourism, compromised property rights of 4000 more property owners…). 

We understand that, under the current timeline, there would not be time for such a debate prior to Council wanting to sign off the draft plan.  Which leaves two alternatives – adjust the timeline or signal in the Spatial Plan that such debate must take place, with meaningful opportunity for community input and influence, prior to the 2024 review  And ban any action being taken in this direction in the interim.

Again, many thanks for your efforts to make this Spatial Plan a better, more visionary, objective document that reflects consistent and strong community feedback about our fundamental opposition to an ever-growing airport in our midst.

And many thanks to those staff who tried their hardest to have vision and incorporate community feedback, where they could.

Kind regards,

We Love Wakatipu Inc Society (chair Cath Gilmour)