Submission to MartinJenkins

WLW seeks NO expansion of the Air Noise Boundaries at Queenstown Airport

We Love Wakatipu Incorporated Society “feedback” for MartinJenkins airport growth economic and social impact assessments.

Prior to making specific comments on impacts of QAC’s airport growth proposal, We Love Wakatipu must outline some of our serious concerns about the process being used to assess and direct QAC’s growth aspirations:

  1. We Love Wakatipu Inc’s significant concerns about the transparency, objectivity and validity of this MartinJenkins community feedback process (formerly described as “consultation”) remain extant. These have previously been identified to MartinJenkins, but not rectified. Please include our emails identifying these concerns (alongside those of WSG) in your analysis.
  2. This submission concentrates on QAC’s plans to expand Queenstown Airport’s air noise boundary (ANB).  That is because we find the “hypothetical scenarios” of MartinJenkins, prepared we are told after discussions with QLDC and QAC, as distractions to the main menu.  It is telling that neither of the two “scenarios” that have so far found some favour with communities on either side of the Crown Range – no expansion of the ZQN’s ANB and no jets in Wanaka, and relocation of ZQN to free up the land for urban development – are included in these scenarios.
  3. If the Mayor and councillors agree to QAC’s ANB expansion proposal in its statement of intent, that consent would need to be fought at resource consent stage.  The costs (both time and resources) on the community of fighting a resolute QAC would be enormous. Even worse, we ratepayers would be paying for all three sides of the argument – paying for QAC lawyers from our council-controlled trading organisation’s budget, funding Council’s defence of their decision to support QAC against its community’s well-being and democratic feedback, and the community ourselves fighting both of them.  The RMA is stacked against community participation in this way, because of the huge cost of litigation for the community and lack of accountability for or control of QLDC and QAC for their spend of ratepayer funds on legal costs.
  4. Once enacted through a district plan variation thus effectively sponsored by QLDC ratepayers, ANB expansion could not be retracted. This decision would be irreversible and impact not only on our community and environment now, but for ever.
  5. There is currently inadequate information and detail about both costs and benefits of QAC’s plans to allow either QAC as manager or QLDC in their governance role to make the best long-term decisions for our community’s economic, environmental, social and cultural well-being as required by the Local Government Act.
  6. Furthermore, QAC’s plans do not acknowledge or take adequate cognizance of capacity and noise reduction technology improvements that already exist – 25% and up to 75% respectively. 75% quieter means four planes for the “noise cost” of one. Combining this with 25% more capacity in each flight means we get five times as many seats, for no extra noise. This would mean QAC could more than reach their desired 5.1 million PAX/year without expanding their ZQN’sair noise boundary or needing jets into Wanaka.  And there is more improvement on both fronts in the development pipeline.
  7. But QAC cannot base their plans on airlines using best technology unless they explicitly require its use, through robust and deliberate noise reduction incentives, Heathrow style. Instead, QAC is merely “encouraging” airlines to do so. And meanwhile, this lack of transparency effectively creates further, uncontrollable and unacknowledged potential growth within both existing and expanded ANBs.
  8. As shown by the response to QAC’s 2018 consultation – 92.5% of some 1500 submissions in opposition, just 3.4% in support – the community strongly feels that QAC’s proposed ANB expansion would have excessive, unacceptable and unwarranted impacts on our community. And further, it Is not the appropriate mechanism through which to determine our community’s growth strategy.
  9. The airport is the only growth lever that the community and council have control over.  This discussion – what level and rate of growth is acceptable and sustainable for our community – still needs to be had. A consultant’s social and economic impact assessments, especially as fundamentally flawed as these are, are no substitute for this. Imposing air noise boundary expansion on a community that has so clearly said no is not democratic and it is not promoting the well-being of that community. These are the two functions of local government.
  10. It is for our community and our council – not international airline demand, not QAC and not big business – to discuss and determine how growth should be managed.

Social/Community impacts of ANB expansion at Queenstown Airport

If councillors agree to QAC’s air noise boundary expansion plans at Queenstown Airport, we would all be affected. Everyone who lives in and loves Queenstown. And not only us, because decisions made now would have huge impacts on the young people in our lives and future generations. Expansion of the ANB would have significant and irreversible outcomes.

These include (but are not limited to) the following impacts:

  • Excessive aircraft noise
    Excessive, ongoing aircraft noise impacting on our everyday life in so many ways. Those living under the flight path cannot continue with backyard conversations. Podcasts and music are interrupted because they can’t be heard whenever planes take off.  Windows rattle each time a jet goes overhead. Café chats, yoga under the crosswind runway, Sunday sleep ins, sleep at all for those on night shifts – all would fall victim to increased airport noise.  The opportunity to enjoy not only our beautiful visual but also our aural landscape, one of the treasures of which is silence, also lost.
  • Outdoors is our focus
    Most residents and visitors come to the Queenstown Lakes because of the outdoors.  If they wanted to sit in a soundproof box, they’d go to a city where they could enjoy some culture while in it.
  • Three minutes for living
    QAC plans mean 16 flights every hour during peak times. That means there would be less than four minutes between each plane arriving or leaving. So for at least one minute out of every four, people in the almost 4000 properties under the expanded ANB would lose the ability to hear anything but planes. Currently, these peak hours are Saturdays and Sundays 2.30-4 PM, just when our kids are playing sport and many people have a chance to be outside enjoying themselves. These peak time windows would no doubt be extended.
  • Recreation amenity loss
    Many of our most significant public recreational areas would become much noisier, for much longer and more intensely. Frankton Arm, Frankton Beach, Kelvin Grove, Queenstown Event Centre fields and courts, Frankton Recreational Reserve, Frankton tennis/hockey courts and golf course, 80% of Queenstown tracks and trails – all are within the expanded air noise boundary.
  • Zero mitigation possible outdoors
    And you cannot mitigate the impact of increased aircraft noise in our beautiful outdoors. From gardeners to mountain bikers, landscape artists to kayakers, walkers to readers – we would all lose the silence that is an inherent and important part of our natural environment.
  • Crosswind runway loss would aggravate
    Noise impacts would be further aggravated if the crosswind runway closes, and General Aviation (sightseeing planes, helicopters and private planes) are forced to use the main, West – East runway. Alternatively, GA could be forced out of Queenstown Airport as Wakatipu Aero Club was some years ago.  QAC has told WLW that the fate of the crosswind runway would be decided during the next masterplan iteration and acknowledges its operational viability is at risk under expansion plans.
  • 4,000 properties directly compromised
    Five times as many properties – almost 4000 – would suffer the seriously interrupted conversations, annoyance and stress that come with being inside QAC’s air noise boundary. This includes most of the Frankton Flats, large chunks of Kelvin Peninsula and Frankton Road home-owners.  And those on the margins of the expanded ANB would also experience more interruptions, more often, more seriously because aircraft noise doesn’t magically stop at the ANB (ask the high school students about that).
  • Private development rights compromised
    And with this, the loss of their development rights. QAC would require, through district plan rules, that any renovations or new builds within the extended ANB include mechanical ventilation so that those living inside could hear each other and get to sleep within their hermetically sealed homes (40 DB within all noise sensitive environments). Locals could forget the indoor/outdoor flow they had planned. And it is they who would have to pay the considerable costs of this sound insulation, because QAC won’t be. Please note that this is both a social and economic impact.
  • Lost residential amenity
    As a result of the above, there would be considerable loss of residential amenity as our lives are interrupted more often by aircraft noise and its many downstream effects and we are forced to escape inside to avoid it – a move against the DNA of most locals.
  • Increased traffic congestion
    More traffic congestion on our roads as more tourists rent more cars, then have their first NZ driving experience in bottlenecked downtown Queenstown or on the Crown Range, Kawarau Gorge or Devil’s Staircase roads. Please note that this so for expansion at both Wanaka and Queenstown – regardless of where they land, many visitors would want to visit both towns. None of these driving options are good introductions to New Zealand driving. This already causes immense frustration among locals, leading to road rage and at times inappropriate racist responses to tourist drivers. Other impacts of this include loss of productive time, increased danger to all road users and more air pollution as cars idle in line.
  • Contradictory and obfuscating information
    We note that QAC CEO Colin Keel told the Kelvin Peninsula Community Association’s emergency meeting on August 15, 2018, that 50% of visitors now arrive through our airport. Interestingly, QAC and QLDC both are still using the old figure of 30%, thus minimising the impact on tourism growth expanding the ANB would have. QAC staff at this meeting also told KPCA that approximately one third of those arriving at the airport then hired a car. Interestingly again, both QAC and DQ in the past month told WLW that they could not tell us the figure for car rentals by airport arrivals. It is very difficult for the community to truly assess impacts if QAC and QLDC do not share information or if the information that they do share is contradictory.
  • Bogus zero sum analysis
    A senior council representative arguing for airport growth claimed that not allowing ANB expansion would mean more tourists would arrive by road, thus claiming that it would worsen traffic congestion. However, it is unlikely that the hordes of Australians who currently arrive for long weekends skiing, biking, partying et cetera would find it so easy to drive here. Nor the many who take advantage of ridiculously cheap package deals and plane seats when airline and tourism operators try to fill spare capacity.
  • Ratepayers bear the externality costs
    More infrastructural failures, bottlenecks and costs as our strained infrastructure creaks under more poos, more wastewater, more vehicles, more waste and the need for more drinking water. We currently get $5-6 million a year in dividends from QAC – this doesn’t come near the costs of providing for that many more tourists. (More on this under economic impacts).
  • Cultural investment suffers
    Recommended average rates increases in the 2020 – 2021 annual plan range from 3.91% to 6.76%, with dwellings taking most of the hit.  This does not include any of the infrastructural requirements of the airport. Nor does it include any real investment in our cultural resource, which is always the first to suffer the sword when the civic accounts get tight.  So any developments from the Three Lakes Cultural Trust’s recently released strategy would be entirely reliant on philanthropic funding to enrich our community’s arts and cultural sector. It is this sector that provides vibrancy, identity and cohesion for our community – not the incessant arrival of jet planes bearing yet more tourists.
  • Education negatively impacted
    Effects on our children’s education. Even if the soundwaves do magically stop at the high school boundary, as QAC’s air noise boundary plan creatively suggests, their outside spaces can’t be soundproofed. Our primary school and preschool children would have their classes and play interrupted. Already we hear from parents whose children “switch off” from lessons for five minutes or so after their concentration’s been interrupted by the roar of a jet plane. Who came to Queenstown to have their kids educated in a soundproof box?  All schools within range of the airport’s ANB (see October 2018 QSG letter signatories) opposed expansion. It also would put greater cost on the Ministry of Education as it would have to build to stringent noise insulation requirements imposed through QAC input into the district plan review (as referred to elsewhere). This cost would then likely spillover onto the community, through the need to fund raise because of restricted ministry capex budgets or missing out on school resources if funds could not be raised for them.
  • Health eroded
    Negative effects on health and our hospital would increase because of more widespread exposure to both aircraft noise and pollution. These are elaborated on further below.
  • Over-touristed community
    Council’s 2018 Quality of Life Survey revealed 63% of respondents were uncomfortable with visitor number growth in the district, indicative of a community struggling with incipient over-tourism.
  • All community associations against
    All Wakatipu Basin community associations signed the Queenstown Stakeholders Group October 2018 letter to Council expressing unanimous opposition to ANB expansion on behalf of their communities. Both Kelvin Peninsula Community Association and Frankton Community Association made significant submissions to the QAC feedback process, which MartinJenkins has committed to including in this analysis so we need not repeat their concerns. We do, however, reiterate them.
  • Lost social licence
    The resultant loss of social licence for tourism, the economic backbone of our district, as resentment against the “tourist takeover” grows. Angry communities do not make good hosts. This is obviously also an economic impact – but the inherent pressure of this loss of social licence would be felt throughout the community. Business owners would suffer backlash. Community cohesion and identity would suffer under the welter of too many tourists.
  • International communities push back
    Communities overwhelmed by tourist pressure around the world have started fighting back.  We have the chance to hold back that tide, to stop our community, our environment and our infrastructure from being overwhelmed, exhausted and overrun.
  • Economic anxiety
    This sense of loss of control and agency would be exacerbated by the economic pressures identified below.  As rate demands go up to pay for infrastructural costs externalised by QAC on to our community, many more of our residents would feel economic pressure. Especially those on low or fixed incomes, such as long-term elderly locals whose primary wealth is locked up in their overpriced properties or those trying to enter the property ladder.
  • Loss of ownership control
    And this loss of personal agency would be reflected and exacerbated by the potential loss of any community and council control over QAC should their debt servicing prove untenable, in the face of another GFC or pandemic.  On top of the likely loss of community dividend (elaborated under economic impacts below), QLDC could easily lose its controlling shareholder status if QAC seeks external funding by selling more shares.  As they did to Auckland International Airport in 2010, without consent of Council, as cited in this Office of the Auditor General report as a case study of how not to run a council-controlled organisation. Or perhaps this loss of control might be the long-term cost of funding from Bank of China, one of QAC’s three debt facility providers. This is a fundamental and serious potential impact, both economic and social/political. QAC’s noise boundary expansion proposal is based on strategic issues that Queenstown Lakes District Council and our community should decide, not QAC’s mainly Auckland-based directors or the Bank of China, behind closed doors.

Health Impacts – erosion of community social wellbeing

Environmental noise is an increasing global issue related to population growth, urbanisation and expanding transportation infrastructure – including airports. Research from around the world shows environmental noise degrades residential, social and learning outcomes.  Increased and ongoing exposure to aircraft noise would increase impacts, including:

  • Heart and blood
    Cardiovascular impacts through general stress, sleep disturbance and annoyance. Increased risk factors include raised blood pressure, elevated blood glucose and blood fat levels. These may lead to hypertension, hardening of the arteries and an increased risk of heart attacks.
  • Lungs – micro particulates
    Impacts of aircraft emissions, primarily Particulate Matter 2.5, tiny particles inhaled into the lungs that could then cross into the bloodstream. This means they circulate around the body and could affect different body systems. There is evidence these PM 2.5 particles could move into tissue and cause inflammation. Black carbon is another problem emission.
  • Pollution concentrated on population centres
    Our topography means pollutants would become concentrated over inhabited areas. There are already times that there is a clear smell of aviation gas in the air at Wakatipu High School. Aviation gas releases carbon dioxide, nitrogen oxide, sulphur oxide, lead and hydrocarbons into the air. As planes do not have catalysers to reduce emissions, landings and takeoffs above the lake and nearby residential areas mean that fine particle pollution would end up afflicting these places. The effect of increased numbers of planes waiting to land or taxiing to take off or park would see a particular increase in air pollution around Frankton.
  • Stress outcomes
    Annoyance is the most prevalent community response. It results in negative reactions such as disturbance, irritation, dissatisfaction and nuisance. These may cause people to experience stress related symptoms.
  • Disturbed sleep
    Aircraft noise both disturbs sleep and impairs sleep recuperation. Physiological reactions to noise include changes in breathing, body movements and heart rate, which do not adapt over time. Those considered more at risk include the elderly, shift workers, children and those with poor health. For many of these groups, sleeping patterns may differ from the general curfew hours at airports – especially for children and shift workers.
  • Impaired reading and memory development
    Exposure to aircraft noise at home and at school has been shown to impair reading and memory skills. Poorer performance on standardised achievement tests has been observed, reversible if noise is reduced.
  • Soil and water contamination
    Soil and water contamination from aircraft and runway operations, a particular issue should aircraft need to jettison fuel into the shallow and slow-moving Frankton Arm (thus making dilution of pollution far more difficult).
  • Overtaxed volunteer emergency systems
    Further costs – stress, money, personal resources and time – on our safety and emergency community response teams, especially as housing and other community infrastructure is close to the airport and our public health service is already stretched thin. Under the current Civil Defence and Emergency Management planning system, much of this relies on a small and shrinking volunteer base. We could not expect our community associations and their supporters to continue subsidising this effort and cost under the proposed ANB expansion. It is not sustainable.
  • Overtaxed public amenities
    Other public health issues impacted on include provision of public toilets, freedom camping, water supply and wastewater capacity, traffic congestion, parking provision, public amenity and waste minimisation.  All of which impact on the community either socially (through loss of level of service) or economically (through increase in rates perspectives.
  • WHO expresses concerns
    The World Health Organisation describes noise as “an underestimated threat” that could cause short and long-term health problems, including the above plus hearing impairment and poorer work performance.
  • International studies raise concerns
    Several major studies in Europe have analysed the significant impacts of noise created by jet airports.  These include this statistical analysis of more than 1 million residents near the Cologne airport, which concluded aircraft noise has significant impacts on health from an average sound level of just 40 dB: another European Commission study that showed the well-being of people living with daytime aircraft noise (55 dB and above) suffered, as did their property values: and this study published in medical journal The Lancet showed chronic environmental stress such as aircraft noise could impair cognitive development in children, especially reading comprehension. As it said “schools exposed to high levels of aircraft noise are not healthy educational environments.”
  • ICAO seeks to reduce adverse noise effects
    The International Civil Aviation Organisation, a specialised agency of the United Nations, has as one of its “main priorities and…key environmental goals” limiting or reducing the number of people affected by significant aircraft noise.  As it says “aircraft noise is the most significant cause of adverse community reaction related to the operation and expansion of airports. This is expected to remain the case in most regions of the world for the foreseeable future.”
  • Insufficient hospital capacity
    Continuing the current “regional hub” status and incessant growth of Queenstown Airport would put an unacceptable level of stress and risk on our medical system, hospital, residents and visitors. In the Otago Daily Times of March 5, 2020, SDHB chief medical officer Nigel Millar acknowledged the board’s hospitals would have “a limited capacity to deal with severe Covid-19 cases” should a pandemic eventuate. Queenstown Lakes is obviously more vulnerable than many places because of the high rate of international tourists, and therefore increased likely vectors. Also, the lack of family/community support to facilitate self-isolation or recovery for tourists. Across the Southern Health District, there are 22 negative pressure isolation rooms available: 13 in Dunedin, eight in Southland and only one at Lakes District Hospital. There is also only one single room with a bathroom that could be used in an outbreak at LDH (versus 73 and Dunedin and 39 in Southland).
  • Insufficient emergency capacity
    The same stress and risk on our medical system, hospital, residents and visitors would occur should there be a serious plane accident.  We are over two hours to the nearest base hospital.  This is one of the many good reasons that international airports almost everywhere else in the world are located near cities with base hospitals.

Economic impacts

Economic impacts of QAC’s preferred dual airport strategy are totally unknown – both on our community and on QAC as an entity.  Councillors have confirmed they have seen no business plan or budget outlining QAC’s internal costs and benefits or the infrastructural costs QAC would externalise on to QLDC. Further, QLDC’s CFO Stewart Burns told WLW that the costs of infrastructural requirements imposed on our community by QAC’s plans could not be determined.

  • Infrastructure cost not in QLDC’s 10-Year Plan
    The council’s current $980million 10-Year Plan does not include any allowance for the growth in visitor numbers through expansion of the ANB. Instead, almost 14% ($71 million) of this 10 Year Plan’s budget is contingent on continued dividend flow from QAC, which would likely be wiped out by the debt servicing load of their $500 million-plus development plans.  So how would QLDC fund the resultant infrastructural needs externalised by QAC on to our community? NZTA hasn’t yet bent to Council’s plea to fund 81% of its roading plans for just current needs.  Its recent halving of subsidy for our Special Purpose Roads (Glenorchy and Crown Range) might suggest this is unlikely. The $373 million over 10 years that QLDC is expecting from the visitor levy is also far from guaranteed.  Council had already signalled likely high rate increases to meet its “no ANB expansion” 10 Year plan. The externalised costs of QAC expansion would put an unacceptable load on ratepayers on top of these as-yet unfunded costs of base level growth.
  • Business analysis inadequate
    To suggest that a literature review and community/business sector feedback to MartinJenkins economic impact assessment would have any value at all in terms of giving councillors adequate information for wise governance decisions – when no such analysis has been done by the two agencies in charge –  is risible.
  • Jeopardises Council control
    The airport is the one lever of growth that council and community could control. It is vital that our council holds on to it.  Yet there is no detail, anywhere, of how QAC would fund its $500 million plus development costs over the next 20 years.  QLDC needs to lose just 0.01% of its current 75.01% shareholding to lose controlling shareholder status. With that, we lose all political agency.  If the world gets hit by a pandemic or another GFC, or if New Zealand just loses popularity for some reason, how does QAC service this debt? By selling equity to existing minority shareholder Auckland International Airport, the Bank of China as one of QAC’s three debt funders or any other potential equity partner? QAC’s current debt level is $69.5 million.  There has been no QAC or QLDC cost-benefit or risk analysis of this issue and again, this impact assessment process is not the appropriate mechanism to derive this analysis from.  No responsible councillor would make such vital decisions without proper analysis of this critical issue of potential loss of political control.  It must be remembered that the relationship between QAC and QLDC is cited in the 2015 Office of Auditor General report on CCOs as a textbook case of how not to govern a council -controlled organisation.
  • Business sector opposes
    It is noted that Queenstown Stakeholders Group – which represents the Chamber of Commerce, Destination Queenstown, Downtown Queenstown, more than 20 major local businesses and all Wakatipu Basin community associations – is “fundamentally opposed” to QAC’s ANB expansion plans.  That the primary business sector groups came out unanimously against expansion of the ANB is instructive. They have not resiled from this stance since writing their letter to Council in early October, 2018. The key issue it noted was the complete lack of community infrastructure planning and the subsequent very high risk of the loss of amenity values that bring people here, both as visitors and residents. Their submission added that the social and environmental impacts of QAC’s proposal were not confined to air noise and air noise boundary expansion. “There are greater detrimental effects on the community and visitor experience that would arise for increasing the capacity of the airport. Approximately 3000 homes, almost 12,000 people, 80% of Queenstown tracks and trails, schools, preschools and the hospital would be significantly impacted by the adverse effects of increased noise levels and frequency of aircraft movements.” (NB – QSG underestimates the number of homes that would come within the expanded noise boundary. QAC documentation says it is closer to 4000).
  • False economic picture given
    We Love Wakatipu has already raised with MartinJenkins the skewed picture their use of mean household versus mean individual earnings has had on the economic context presented to focus groups and survey takers. For fullness, our commentary on this is included as an appendix at the end of this submission. The 30% above New Zealand average household income statistics cited is not the reality most Queenstowners experience.
  • Tourism industry has the lowest productivity
    Expanding the preponderance of tourism jobs in our economy is not the way to improve our community’s economic or social well-being.  Tourism jobs earn on average just two thirds of the mean individual income.  Council’s 2018 Quality of Life Survey showed 21% of respondents had no discretionary income and 3% could not cover their costs. QLDC’s 2018 LTP acknowledges Queenstown Lakes workers earn 15% below New Zealand average earnings. Our productivity is low compared to Northland and the West Coast, commonly seen as two of our poorer regions (see appendix). Our council and business sector have to get a whole lot more creative, robust, analytical and proactive to create a broader and deeper economy than just increasing visitor numbers through ANB expansion. This would turbocharge precisely the wrong drivers of economic growth. Stimulating high volume, low value and short stay tourism just perpetuates this low margin business and undermines our community’s economic and social well-being.
  • High flyers
    There has been some commentary from the business sector that greater connectivity is needed to encourage ‘talent’ to move to Queenstown and facilitate remote business. This argument has some merit – but limited. The primary route required, we are told, is Queenstown – Wellington – Queenstown to allow businesspeople to fly up and down in a day to meet with central government politicians.  If there really is that level of demand, one of the airlines would respond to it. If there isn’t, then the community should not be asked to pay for increasing the chance of airlines providing such flights by expanding the air noise boundary to save incoming ‘talent’ the inconvenience of overnighting in the capital.  If convenience is that important, perhaps they should stay there :-). We also note that the active facilitation of such frequent-flying lifestyles runs directly counter to Council’s formal declaration of a Climate Emergency.
  • Traffic congestion inefficiencies
    QAC expansion plans would inevitably lead to further loss of productive time as more people get stuck in traffic congestion while travelling between jobs and to work on our choked roading network.
  • Hospital infrastructure overheads
    There are also the potential costs inflicted on our public health system of either a pandemic or serious plane accident, as highlighted in the health impacts section above. SDHB does not get compensation for the extra costs of tourists on our already strained public health budget. We have to pay for their hospitalisation, air evacuations and ACC ambulance trips from our district’s health budget as they rarely have or use travel medical insurance. Our local public health system, especially the mental health sector, is already under severe strain. This should not be exacerbated by SDHB having to subsidise New Zealand Tourism Inc by expanding ZQN’s air noise boundary so that it could remain a regional hub. The appropriate place for regional hubs is nearby a base hospital. Invercargill, Dunedin and Christchurch all have both available airport capacity and base hospital facilities nearby.
  • Cost of social licence
    The loss of social licence for tourism is another economic cost. We have already seen this in community response to accidents involving tourists, where racism has reared its ugly head. This is a sign of a community under stress, lashing out at a visible example of pressure they are continually feeling. Over-tourism is a negative as much for the visitor and the businesses that service them as it is for the community whose identity, cohesion and very existence is overwhelmed by it. The most recent Mood of the Nation online survey showed 78% of Queenstown respondents felt international tourists were putting too much pressure on New Zealand, nearly double the figure of those surveyed in other towns.  This negativity towards tourists and tourism would only increase with the suggested ANB expansion.
  • Private property rights loss
    The loss of property rights referred to under social impacts for private landowners has already impacted on council development of Frankton Campground, which would be an ideal site for workers’ accommodation (council owned, sunny, central to active and public transport routes, employment and recreation resources). This was nixed by QAC lawyers’ input during Stage I of the district plan review, with a ban on ASANs (activities sensitive to air noise) within the ANB. This is the kind of opportunity cost lost in Frankton Flats – some of our most developable, sunny, flat land in a basin where topography and land costs conspire against affordability. Forbidding ASANs is a way for QAC to prevent infiltration of future potential complainants, but for the community as a whole, it is an unjustifiable development straitjacket that costs both the community and development sector hugely. With no recompense.  Expanding the ANB stretches this straitjacket over even more land.

Safety impacts – economic risk

Existing safety concerns at Queenstown Airport would be exacerbated by tripling the number and intensity of flights, if allowed by expansion of ZQN’s air noise boundary. What would be the impact of even one serious air accident? On the passengers and crew, our community, our environment, our health system, our economy and reputation?

During a 2012 court case, retired Civil Aviation Authority (CAA) inspector and Air New Zealand pilot Colin Glasgow, stated that Queenstown has a “Category X” rating in CAA and airline operator circles – the highest rating according to degrees of difficulty. The main contributors to this Category X rating are:

  • The forced proximity of aircraft because of the narrow flight corridors in this mountainous terrain.
  • The 90m grassed run-off areas at both ends of the runway being at the absolute minimum permissible length (240m is the generally recognised industry standard).
  • The risk of ice build-up on aircraft wings during bad weather, dramatically reducing their aerodynamic performance. This means that for any given airspeed, the aircraft is less able to fly safely.
  • Being situated at the confluence of three mountain valleys, ZQN is subject to strong wind shear. This could subject an aircraft to violent updrafts and downdrafts and also abrupt changes to its horizontal movement.

Being situated at the confluence of three mountain valleys, ZQN is subject to strong wind shear. This could subject an aircraft to violent updrafts and downdrafts and also abrupt changes to its horizontal movement.

How do the Civil Aviation Authority see it?  CAA annual reports over the last nine years show a clear trend of increasing concern regarding safety at Queenstown Airport. Tellingly, these same reports make no mention of airspace risk at any other main airport in NZ.

  • CAA 2011/2012 Annual Report.
    “We have conducted a comprehensive risk review of air transport operations at Queenstown to help guide the Authority’s regulatory approach to operations at this aerodrome.”
  • CAA 2014/2015 Annual Report.
    “The current air surveillance system supporting the air traffic management system is operated by Airways. It consists of primary and secondary radars and a multilateration system based in Queenstown. The current radar system would be at the end of its life by 2021.”
  • CAA 2015/2016 Annual Report.
    “Queenstown airspace has a variety of flying activities, mountainous terrain, changeable weather and a high density of traffic; all of which create a challenging operational environment with an increased potential for an accident to occur.”
  • CAA 2016/2017 Annual Report.
    “Queenstown Operations – We conducted a gap analysis of the effectiveness of current controls, created a stakeholder plan and engaged with stakeholders to precisely define the risks associated with Queenstown operations. Pleasingly, there were no major safety occurrences during the year, and analysis determined that current controls are effective.”
  • CAA 2016/2017 Annual Report.
    “The mountainous terrain, changeable weather and high and constricted density of traffic make Queenstown a challenging area to fly. As such, there is increased potential for accidents to occur.”
  • CAA 2017/2018 Annual Report.
    “Aviation accidents in the Queenstown area have the potential to damage New Zealand’s reputation for safe and secure skies, and as a tourist destination, as well as incurring unnecessary social cost.”
  • CAA 2018/2019 Annual Report.
    “Aviation accidents in the Queenstown area have the potential to damage New Zealand’s reputation for safe and secure skies, and as a tourist destination, as well as incurring unnecessary social cost.”

And the drum roll for most worrying quote goes to this extract from the CAA’s 2014 Queenstown Airspace Classification Review:

“Given that there are now significantly more passengers
in the (Queenstown) airspace at any one time than ever
before and greater numbers of aircraft than before,
the exposure risk of passengers to an airspace safety
occurrence has increased markedly”.

How is it possible that the QLDC executive and councillors could vote on expanding the air noise boundary – tripling flights from mid-2018 – without fully understanding the safety consequences of this decision?

Environmental impacts

Five UK airports – Heathrow, Stansted, Bristol, Southampton and Luton – have had their expansion plans rejected recently, primarily because of climate change ramifications but also because of noise and community impacts.

Mayor Boult’s decree that the UK Privy Council’s decision to reject Heathrow’s third runway because of the U.K.’s climate change international commitments is not relevant to the Queenstown case (ODT, 5.2.20) displays a cynicism towards QLDC’s June 2019 declaration of climate emergency that we hope is not shared by the rest of his council or council’s senior management team.

It is also cynical that this impact assessment – at one stage being touted as also an environmental impact assessment – puts most of the onus for this on to QAC: “More detailed assessment of environmental sustainability matters related to airport operations would be covered in Queenstown Airport Corporation’s own sustainability framework,” QLDC PR said in January.  But QAC takes no responsibility for the carbon footprint of the planes that arrive and leave from ZQN or Wanaka. Their mandate is only ground operations. While their efforts on that front might be praiseworthy, they come nowhere close to addressing the real elephant in the atmosphere; that international flights’ percentage share of tourism sector climate change gas emissions would increase from 27 to 55% from 2018 to 2050 IF demand-led growth continues unabated.

QLDC’s responsibility to not expand the ANB, with all its environmental and climate change impacts, cannot be so easily eschewed. Among the primary concerns of the 78% of Queenstown respondents who felt international tourism was putting too much pressure on the country in the Mood of the Nation survey were pressure on infrastructure, damage to the environment and overcrowding of national parks and great walks.

MartinJenkins consultant Donella Bellett committed to WLW on March 5, 2020, that MartinJenkins would read and include the report this figure comes from – Parliamentary Commissioner for the Environment Simon Upton’s “Pristine, Popular … Imperilled? An enquiry into the environmental consequences of projected growth in tourist activity” report.  Rather than repeat points made in this, I look forward to MartinJenkins’ analysis and response.

Soil, water and air pollution issues are raised under the health impacts section above.  We reiterate rather than repeat them here.

These would be exacerbated by the results of infrastructural failures such as more instances of sewage in our lakes and rivers, more air pollution from idling vehicles and more rubbish entering our waste stream without adequate diversion channels because of the cost for our small population base.

Alternatives to MartinJenkins for “hypothetical scenarios”

It is clear from the above submission that expansion of Queenstown Airport’s air noise boundary is untenable and unjustified.

By stipulating airlines must use quieter, more capacious aircrafts, QAC could achieve its desired growth within the existing air noise boundary. So far, it has chosen not to do so. Even more puzzling, it has not even acknowledged that it could. Neither expansion of ZQN’s noise boundary nor development of Wanaka airport would be required if they chose smarter growth over the easy option of louder growth.  So the first alternative option is:

  • Smart management to accommodate growth within the existing air noise boundary.

QAC’s legislated purpose is to meet the strategic objectives, both financial and non-financial of its shareholders as outlined in its statement of intent.  As controlling shareholder, QLDC has the legal right to stipulate these. QLDC’s two roles under the Local Government Act are to enable democratic action and decision-making, and promote the social, cultural, economic and environmental well-being is of its communities, both now and in the future. The Queenstown community has made it abundantly clear through every (slightly) democratic process available that its well-being would not be served by expanding the air noise boundary. The above submission supports this case, pointing to clear evidence that increased aircraft noise would not benefit our community.

Two other alternatives – that have received community support elsewhere but were not part of the MartinJenkins feedback process – are:

  1. no expansion of ZQN air noise boundary and introduction of ATRs at Wanaka Airport, if proper consultation shows that this is what Wanaka’s community wants, as proposed by Wanaka Stakeholders Group.
  2. Relocation of Queenstown Airport to an alternative site in the Cromwell – Tarras area, and urban development of the ZQN site, as proposed by FlightPlan2050.

As mentioned elsewhere, Invercargill, Dunedin and Christchurch Airports should be playing the role of regional hubs, not Queenstown. Impacts of this would include better regional dispersal of tourists, less environmental impact, safer driving introduction for tourists, more efficient use of existing infrastructure, lower carbon and noise impacts through use of wide-bodied jets and encouragement of longer stay tourists.  Most other Alpine resorts in the world have airport is at least one hour away – it would not stop people coming here. But perhaps it might make tourists value and treat our district with more respect if it’s not just a cheap flight for a boozy weekend.



PS We Love Wakatipu pointed out the above issues to MartinJenkins at the February 28 focus group we took part in. The focus group leader said they would include this broader (in our eyes, more representative) perspective in their report back to Council. They did not commit to making their context summary more accurate in the interim, so public feedback continues to be misinformed.

We look forward to seeing a better informed, more rigorously analysed economic assessment from MartinJenkins in March and then May.

Submission ends

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