REPORT. Erosion Protection Works - Wainui Beach. Resource Consent Applications and Assessment of Environmental Effects.

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1 1 REPORT Erosion Protection Works - Wainui Beach Resource Consent Applications and Assessment of Environmental Prepared for Prepared by Date Job Number

2 Distribution: (consent authority) (FILE) 1 copy 1 copy + digital 1 copy

3 Table of contents 1 Introduction Overview and background of proposed works Applicant and property details Overview of resource consent requirements Proposed Regional Coastal Environment Plan Combined Regional Land and District Plan Consent duration Wainui Beach Erosion Management Strategy 4 2 Environmental setting Site location Site description Land use activities and values Geology Ecology Coastal processes Erosion processes Coastal erosion hazard 12 3 Description of proposed works Proposed works Rock revetment - Tuahine Crescent Sand push ups Gabion basket 21 Wairere Road Consideration of alternatives Rock revetment Tuahine Crescent Gabion basket 21 Wairere Road 17 4 Resource consent requirements Proposed Regional Coastal Environment Plan Management areas Combined Regional Land and District Plan Zoning Resource consent requirements 23 5 Assessment of effects on the environment Introduction Positive effects Rock revetment Sand push ups Gabion basket Landscape and natural character effects Rock revetment Sand push ups Gabion basket Amenity effects Coastal processes effects Rock revetment Sand push ups Gabion basket Ecology effects Rock revetment 29

4 5.6.2 Sand push ups Public access and safety Rock revetment Construction works Water quality effects Construction/ removal of erosion protection structures Sand push ups Cultural and archaeological effects Rock revetment Sand push ups Gabion basket Summary of cultural and archaeological effects 34 6 Statutory assessment RMA assessment Section 104D RMA Part 2 of the RMA National Environmental Standards Policy framework analysis New Zealand Coastal Policy Statement Gisborne Regional Policy Statement Proposed Regional Coastal Environment Plan District Plan assessment Policy framework analysis conclusion Notification 56 7 Consultation 57 8 Conclusion 58 9 Applicability 60 Appendix A: Appendix B: Appendix C: Appendix D: Appendix E: Consent application forms Certificate of title Drawings Design report Tangata Whenua correspondence

5 Schedule 4 requirements Schedule 4 of the RMA sets out the information required in an application for a resource consent. All relevant matters required to be included have been addressed in the assessments and descriptions in this AEE. The following table provides a summary of the information required in Schedule 4 and a quick reference to its location in this report. Schedule 4 Item Location within report (section) A description of the activity 3 A description of the site at which the activity is to occur 2 The full name and address of each owner or occupier of the site 1.2 A description of any other activities that are part of the proposal to which the application relates A description of any other resource consents required for the proposal to which the application relates An assessment of the activity against the matters set out in Part An assessment of the activity against any relevant provisions of a document referred to in section 104(1)(b). This must include: Any relevant objectives, policies, or rules in a document Any relevant requirements, conditions, or permissions in any rules in a document Any other relevant requirements in a document (for example, in a national environmental standard or other regulations) An assessment of the activity s effects on the environment that includes the following information: If it is likely that the activity will result in any significant adverse effect on the environment, a description of any possible alternative locations or methods for undertaking the activity. An assessment of the actual or potential effect on the environment of the activity. If the activity includes the use of hazardous substances and installations, an assessment of any risks to the environment that are likely to arise from such use. If the activity includes the discharge of any contaminant, a description of - The nature of the discharge and the sensitivity of the receiving environment to adverse effects; and - Any possible alternative methods of discharge, including discharge into any other receiving environment. A description of the mitigation measures (including safeguards and contingency plans where relevant) to be undertaken to help prevent or reduce the actual or potential effect. Identification of the persons affected by the activity, any consultation undertaken, and any response to the views of any person consulted. If the scale and significance of the activity's effects are such that monitoring is required, a description of how and by whom the effects will be monitored if the activity is approved. Not applicable Not applicable

6 Schedule 4 Item If the activity will, or is likely to, have adverse effects that are more than minor on the exercise of a protected customary right, a description of possible alternative locations or methods for the exercise of the activity (unless written approval for the activity is given by the protected customary rights group). An assessment of the activity s effects on the environment that addresses the following matters: Any effect on those in the neighbourhood and, where relevant, the wider community, including any social, economic, or cultural effects. Any physical effect on the locality, including any landscape and visual effects. Any effect on ecosystems, including effects on plants or animals and any physical disturbance of habitats in the vicinity. Any effect on natural and physical resources having aesthetic, recreational, scientific, historical, spiritual, or cultural value, or other special value, for present or future generations. Any discharge of contaminants into the environment, including any unreasonable emission of noise, and options for the treatment and disposal of contaminants. Any risk to the neighbourhood, the wider community, or the environment through natural hazards or the use of hazardous substances or hazardous installations. For applications involving permitted activities If any permitted activity is part of the proposal to which the application relates, a description of the permitted activity that demonstrates that it complies with the requirements, conditions, and permissions for the permitted activity (so that a resource consent is not required for that activity under section 87A(1)). Location within report (section) Not applicable Not applicable 4

7 1 1 Introduction 1.1 Overview and background of proposed works (GDC) have developed and adopted the Wainui Beach Erosion Management Strategy (WBEMS) for managing coastal erosion along Wainui Beach. This strategy, developed with assistance from coastal experts and key stakeholders, considered the risk that coastal erosion posed along Wainui Beach and identified options to manage the risk, while also achieving the wider values and goals of the community. These values and goals include retaining beach access, protecting property, and conserving and enhancing the natural environment 1. Within the strategy, short, medium and long-term options were developed for eight key areas between Tuaheni Point and Makorori Point. In the short term, obtaining resource consents for sand push ups along Wainui Beach and replacement of the existing rail iron log and rock wall (between the concrete groyne near the southern end of the beach to the vicinity of the Tuahine Crescent beach access way) with a more robust structure were identified as key action areas for GDC to implement. To implement the recommendations in the WBEMS, GDC is applying for resource consent to replace the rock and rail wall and undertake sand push ups along the entire length of Wainui Beach (from Tuahine Crescent in the south to the point at which SH 35 goes inland in the north). These erosion management works are necessary to protect private and public properties along Wainui Beach. In particular, the area of backshore from the concrete groyne to the Tuahine Crescent beach access comprises steep eroding soft cliffs. The main concern in this area is the potential damage to and loss of dwellings, particularly the dwelling to the north of the concrete groyne (6 Tuahine Crescent), which is located further seaward than the dwellings to the north and is within the extreme risk erosion zone. In addition, coastal protection works were undertaken on the GDC owned Esplanade Reserve seaward of 21 Wairere Road under the emergency works provisions of the Resource Management Act 1991 (RMA) in August This followed a storm event which caused damage to a part of 21 Wairere Road. The protection works comprised the construction of gabion baskets with rock above the baskets on top of the eroded dune face. As part of this application retrospective resource consent is sought for the construction and occupation of the gabion basket in the CMA to provide protection of the dwelling at 21 Wairere Road. Land use consent is also sought for the removal of the rock above the gabion basket. This report has been prepared in fulfilment of section 88 of the Resource Management Act 1991 (RMA), and in accordance with our letter of engagement dated 5 October Applicant and property details Table 1.1: Applicant and property details Applicant Owner of application site Rock revetment Coastal Marine Area: No ownership. Private Land: 8 Tuahine Crescent: Rosemary Reynolds 6 Tuahine Crescent: Caroline and Simon Cave. 1 (2014) Wainui Beach Erosion Management Strategy

8 2 Site address / map reference (NZTM) Legal description District Council / Plans 4 Tuahine Crescent: Adrian and Katherine Cave. 2 Tuahine Crescent: Margo and Richard Calcott. Esplanade reserve:. Sand push ups Coastal Marine Area: No ownership. Esplanade reserves:. Private Land: There are multiple properties which cadastrally extend into the CMA along Murphy Road and Pare Street. Gabion basket and removal of rock Coastal Marine Area: No ownership. Private Land: 21 Wairere Road: Anne Milton, James Milton and Michael Torie. Esplanade Reserve:. Rock revetment works 8 Tuahine Crescent (concrete groyne) to 2 Tuahine Crescent (structure proper ends at Tuahine Crescent beach accessway, and curves in at 2 Tuahine Crescent): E N to E N. Sand push ups Wainui Beach (from Tuahine Crescent in the south to the point at which SH 35 goes inland in the north): E N to E N (approximate). Gabion basket and removal of rock GDC Esplanade reserve seaward of 21 Wairere Road: E N. Rock revetment works 8 Tuahine Crescent: Lot 7 DP 3216 (CT 2A/1310). 6 Tuahine Crescent: Lot 6 DP 3216 (CT 2C/253). 4 Tuahine Crescent: Lot 5 DP 3216 (CT 2C/278). 2 Tuahine Crescent: Lot 4 DP 3216 (CT 3C/1449). Accessway Reserve: Lot 16 DP 3216 (CT 4C/1048). Esplanade Reserve: Lot 14 DP 3216 (CT GS3C/1305). Esplanade Reserve adjacent to 2 Tuahine Crescent: Lot 3 DP 4655 (CT GS3C/1303). Gabion basket and removal of rock 21 Wairere Road: Pt Lot 6 DP 1307 (CT 1C/436). Esplanade reserve: Beach Reserve Deposited Plan 1307 (CT ). Sand push ups There are multiple private properties which cadastrally extend into the CMA along Murphy Road and Pare Street. There are also multiple reserves which cadastrally extend into the CMA. Combined Regional Land and District Plan.

9 3 Regional Council / Plans Address for service during consent processing Address for service during consent implementation and invoicing Proposed Regional Coastal Environment Plan. Hayley Jones PO Box 317 Tauranga HJones@tonkintaylor.co.nz Neil Daykin PO Box 747 Gisborne Neil.Daykin@gdc.govt.nz We attach copies of the application forms in Appendix A, and copy of the relevant Certificate of Titles in Appendix B. 1.3 Overview of resource consent requirements Proposed Regional Coastal Environment Plan Resource Consent is sought from GDC under the following provisions of the Proposed Regional Coastal Environment Plan: Rule 4.5.6J Discretionary Erection or placement of structures (rock revetment and gabion basket) in the general management area of the CMA for avoiding, remedying or mitigating the effects of natural processes. Rule 4.3.6J Discretionary Erection or placement of structures (rock revetment and gabion basket) in the protection management area of the CMA for avoiding, remedying or mitigating the effects of natural processes. Rule 4.5.8E Discretionary Occupation of space of rock revetment and gabion basket within General Management Area of CMA. Rule 4.3.8E Discretionary Occupation of space of rock revetment and gabion basket within Protection Management Area of CMA. Rule 4.5.9G Discretionary Movement of sand from one section of the Wainui Beach foreshore to another within General Management Area Combined Regional Land and District Plan Resource Consent is sought from GDC under the following provisions of the Combined Regional Land and District Plan: Rule Non-complying Erosion protection works (rock revetment, gabion basket) in the amenity reserve zone, and earthworks (sand push ups) in the amenity reserve zone. Rule Non-complying Erosion protection works (rock revetment, gabion basket) and earthworks (sand push ups) in the residential zone. Rule Discretionary Land disturbance and structures within 200 m of MHWS.

10 4 Rule Restricted Discretionary Land disturbance (rock revetment construction) which disturbs more than 10m³ of earth in any 3 month period within outstanding landscape overlay. Rule Discretionary Installation or alteration of works designed to mitigate the effects of coastal hazards. Rule Discretionary Alteration of natural dune landform including earthworks in the extreme coastal hazard risk area. Rule Restricted Discretionary Land disturbance of more than 10m³ of soil in any 3 month period in the Land Overlay 3 area for construction of rock revetment and gabion basket. Overall consent is sought from GDC for a non-complying activity. 1.4 Consent duration The applicant seeks a 25 year term for the construction, occupation and maintenance of the rock revetment structure for the regional resource consent and land use consent. Having a 25 year term for the regional consent will ensure that the proposed structure matches the expiry date of the recently consented rock revetment to the south of the groyne (2042) as recommended in the WBEMS (2014). At the expiry of the consents consideration of the most appropriate coastal management option will be undertaken based on the nature, scale, and understanding of the coastal hazards at that time. Any future management option will be based on the Wainui Beach Community s perspective at that time (including the landowners adjacent to the rock revetment). A 25 year consent term for sand push ups along Wainui Beach is sought for the regional consent, and an indefinite term for the land use consent. A 5 year consent term is sought for the regional resource consent for the gabion baskets on the GDC owned Esplanade Reserve seaward of 21 Wairere Road, and an indefinite term for the land use consent. 1.5 Wainui Beach Erosion Management Strategy The WBEMS was developed through a stakeholder engagement process and supported by a forum of key stakeholders, formed by council, to bring together multiple stakeholder perspectives and work through issues. It is also informed by the advice of Tonkin and Taylor, Eco Nomos and eco-i. Tonkin and Taylor and Eco Nomos were commissioned to provide detailed advice on erosion management options. For the medium term (20-30 years) to longer term (next 100 years) the strategy identifies further actions that may be required in response to aggravated erosion due to projected sea level rise and other climate change factors. The WBEMS recommends that GDC obtain resource consent for sand push ups from Tuahine Beach accessway to Hamanatua Stream (i.e. areas 3 to 6 in the management plan). This will allow Council to respond in the event of severe erosion that threatens dwellings (scarp lies within 8 m of the dwelling). The WBEMS also recommends replacement of the existing rail and log wall north of the groyne ending in the vicinity of the Tuahine Crescent beach access way with a more robust structure. The WBEMS specifies that this replacement structure should, as far as practicable, be constructed with a similar footprint to the rail iron log and rock wall to minimise adverse effects on beach values. The WBEMS states that the term of the consent for this replacement structure should match the expiry date for the recently constructed revetment to the south of the concrete groyne.

11 5 As outlined in the WBEMS the RMA and policies and plans written under the Act (particularly the NZCPS) were critical to the development of the strategy. Therefore, management approaches such as locating development away from harm and avoiding hard structures were carefully considered in the development of the WBEMS. However in the instance of Wainui Beach, development is existing, including both residential development along the backshore area of Wainui Beach and the development of hard protection structures along the beach. The development of the strategy was also guided by the objectives and policies of the NZCPS including those related to natural character of the coastal environment, Maori cultural values and participation of Maori in decision making, and surf breaks of national significance. The WBEMS was developed over many years and considered different actions for different parts of the beach with an overall view of providing a sustainable approach to erosion management along Wainui Beach. As discussed above, what is being proposed under this resource consent application has been developed by stakeholders with input from the community, and has been prepared by and endorsed by many parties interested in the issues.

12 6 2 Environmental setting 2.1 Site location Wainui Beach is located approximately 6 km to the east of Gisborne. The beach is approximately 6 km long and runs adjacent to the Wainui Beach settlement. Wainui Beach is a popular sandy beach, which is widely used for a range of recreational purposes. Historically, the beach has suffered from coastal erosion which threatens the adjacent properties, dwellings, Wainui Beach Surf Club, and recreation and esplanade reserves. Gabion baskets Wainui Beach (sand push ups extent) Replacement of existing rail iron wall with rock revetment Figure 2.1 Location Plan Copyright Google Maps 2017 The existing rail iron log and rock wall to be replaced with rock revetment is located at the southern end of Wainui Beach and is approximately 40 m long (with an additional return length of approximately 7 m at the northern terminus of the structure to transition into existing bank and tie into existing rail iron structure), extending from the southern concrete groyne to the northern extent of the Tuahine Crescent beach access way (Figure 2.2).

13 7 Tuahine Crescent beach access way Rock revetment to replace rail iron log and rock wall Southern concrete groyne Existing rock revetment Figure 2.2 Rock revetment to replace existing rail iron log and rock wall Copyright GDC Tairawhiti Maps 2017 The gabion basket and rock structure is located on the esplanade reserve in front of 21 Wairere Road, and is approximately 15 m in length. Gabion basket and rock Figure 2.3 Existing gabion basket and rock Copyright GDC Tairawhiti Maps 2017

14 8 2.2 Site description Wainui Beach consists of a predominantly sandy shoreline which extends approximately 6 km from Tuaheni Point in the south to Makorori Point to the north. The beach is backed by rocky steep cliffs at the southern headland of the beach which extends from Tuaheni Point to the Tuahine Crescent beach access way. Further north (i.e. from the Tuahine Crescent beach access way to the intersection of Murphy and Cleary Roads) the bluff is lower and less erodible and is generally composed of old estuarine sediments. The balance of the sandy beach is backed by dunes. For a detailed description of the wider beach refer to the WBEMS Land use activities and values Tuahine Crescent As shown in Figure 2.4 below there is an existing rail iron log and rock wall at the site which is located on average 8 m seaward from the cliff toe and runs from the southern concrete groyne approximately 160 m north to 52 Murphy Road. At the northern end of the structure the rail iron has been partially covered in sand and the logs are no longer present. The area surrounding the existing rail iron log and rock wall to be replaced with rock revetment is characterised by the following activities and features: North: Coastal margin/esplanade reserve with rail iron log and rock wall extending northwards; East: Esplanade reserve/intertidal area of Wainui Beach; South: Coastal margin/esplanade reserve with concrete groyne, and rock revetment extending southwards; and West: Private property and dwellings. Figure 2.4 Existing rail iron log and rock wall (shown with red arrow) Source T+T, 2016

15 Wairere Road The shoreline at Wairere Road is characterised by a sandy beach backed by a high dune. Various erosion protection structures have been placed close to the base of the high frontal dune, with these structures being largely buried during periods of accretion. In the 1970 s gabion baskets filled with cobbles held by timber posts, were placed along the length of the beach from Lloyd George Road to the Hamanatua Stream. The gabion baskets were later reinforced with vertically piled rail irons (Smith and Strongman, 2013). Following this, many private and public erosion protection works were undertaken along the entirety of Wainui Beach (Smith and Strongman, 2013). We understand from advice from GDC that there was a historic seawall structure in front of 21 Wairere Road that partially failed at some stage following a storm event in August 2016, and which was replaced by the gabion basket and rock structure as emergency works. Figure 2.5 Partially failed seawall structure Source GDC, 2016 The area surrounding the gabion basket and rock structure is characterised by the following activities and features: North: Coastal margin/esplanade reserve with gabion basket extending northwards; East: Intertidal area of Wainui Beach; South: Coastal margin/esplanade reserve with grouted rock seawall extending southwards. Gabion basket structures are located further south of the seawall; and West: Private property and dwelling Geology Wainui Beach lies within the active Hikurangi Deformation Front (Beanland & Haines 1998), which is associated with uplift and intense deformation. The rock formations are largely silty sandstones and muddy siltstones on a bed of marls and bentonitic rocks (Stoneley 1962; Kingma 1965; Ridd 1970). The headlands (Tuaheni Point and Makorori Point) are composed of these soft sedimentary rocks, making them prone to coastal erosion, and a seaward dip of the strata triggers frequent landslide events. Geotechnical investigation have been carried out to assist in understanding the geology of the backshore of Tuahine Crescent. The results showed a complex sequence of dense sands banded by

16 10 softer clays, the bluff material comprised softer fine grained silts and sands, suggesting an erodible bluff. Historically, slump failure has been evident at the northern end of the Tuaheni Point bluff (where both the rock revetment south of the concrete groyne and the rail iron log and rock wall is now present), with slump failure in the 1950 s posing a risk to the houses in the area at that time (Figure 2.6) (GDC, 2014). Figure 2.6: View of cliff line adjacent to Tuahine Crescent in December 1955 showing the natural character and erosion/landslide mechanisms in this area prior to the placement of erosion protection works. Source: GDC Ecology The duneland flora at Wainui Beach comprises a range of exotic and indigenous plants typical of suburban coastal settlements. Fauna is comprised of mostly introduced species, with small numbers of indigenous species (blue penguin, oystercatchers, skinks and others) due to predation (Trafford, 2008 & GDC, 2009). Field studies undertaken in 1993, 1995 and 1997 along Wainui Beach have recorded a total of 29 species of macrofauna along three separate transects extending from the base of the foredune to below low water along Wainui Beach. Thirteen of these species were found to be marine forms which occur on the intertidal beach and 16 are terrestrial and inhabit the backshore (Stephenson, 1998). Wainui Beach south of Hamanatua Stream has a low species diversity and relatively low abundance of macroinfauna which is confined to the uppermost intertidal drift line and supralittoral zone (Stephenson, 1993) Coastal processes A description of the coastal processes at the site has been included in the Design Report annexed to this report as Appendix D.

17 Erosion processes Erosion processes at Wainui Beach are complex, and appear to be dominated by short term erosion processes e.g. storms and rip currents. The WBEMS discussion document provides a detailed summary of the existing information available regarding erosion processes occurring at Wainui Beach, and has been used to inform the discussion below Short term erosion Rapid erosion events are generally caused by storms, however the beach is continually changing with periods of accretion generally occurring following storm events. From sedimentary and geomorphic evidence, Gibb (2001) suggests Wainui Beach experiences an oscillatory drift of sand along its length. In north-easterly conditions the northern end of the beach experiences losses in its width while the southern end gains in width and, conversely, in southeasterly sea conditions a narrowing of the beach at its southern end occurs while its northern end widens. The wider a beach system, the more wave energy it can absorb and, thus, the more protected from erosion its dunes or cliffs/bluffs are. Conversely, narrower beach systems leave dunes and cliffs more exposed to erosion processes. Therefore, the southern end of Wainui Beach is at its most vulnerable when it is narrowed during prolonged south-easterly wave storms (Gibb 2001). The whole beach system is subject to erosion, and episodic events in the vicinity of Tuahine Crescent have been recorded as far back as 1912 (Dunn and Lange, 2003) Long term trends Over a 57-year survey period ( ), 90% of the 31 beach profiles studied between Tuaheni Point and Makorori Point presented a long-term trend of retreat as a result of erosion (Gibb, 2007). These rates of erosion ranged from 0.02 to 0.51 m/year and averaged 0.18 m/year. Only 3 profiles showed a trend of accretion with accretion rates ranging from 0.09 to 0.30 m/year and averaging m/year. This accretion was assessed as being the result of the installation of a training groyne at the southern side of the Hamanatua Stream outlet which prevents the stream mouth from migrating to the south and eroding the dune and upper beach face. Prior to the groyne s placement in 1982, there was a trend of erosion ranging from to m/year. These trends are summarised in Figure 2.8. Figure 2.8 Net rates of coastal erosion per year (m/yr) and accretion for 31 sites between Tuaheni Point and Makorori Point from 1942 to 1999 Source: Gibb, 2007

18 Coastal erosion hazard In 2001 Gibb assessed the coastal erosion hazard zone (CEHZ) which analysed 14 profiles along Wainui Beach, and subdivided the coastal erosion hazard zone into extreme, high, and moderate risk erosion zones and a safety buffer zone. These results were incorporated into the Proposed Regional Coastal Environment Plan and combined Regional Land and District Plan, and are used in the WBEMS. The extreme risk, high risk and moderate erosion zones were defined in Gibb (2001) 2 as the following; The extreme risk erosion zone (EREZ) lies immediately adjacent to the coast along the 4.2km long Wainui Beach and encompasses the area that is or is likely to be subject to adverse effects from short- term duneline fluctuations and storm cuts. The EREZ encompasses most of the foredune complex and has a high probability of being adversely affected at any point in time but more particularly during a 20 to 30 year long negative IPO phase (Interdecadal Pacific Oscillation). The EREZ ranges in width from about 20 m to 45m. The high risk erosion zone (HREZ) lies adjacent to and landward of the EREZ and encompasses the area that is likely to be subject to a net shoreline retreat from the combination of a midrange most-likely SLR of 0.16 m above 1990 levels by 2050, and any historical long-term retreat. The HREZ encompasses the period from and has a high probability of being adversely affected at any time over this time frame. The HREZ ranges in width from 0 to 25 m along Wainui Beach being widest where there is a relatively higher historical long-term erosion rate coupled with forecast erosion from sea level rise. The moderate risk erosion zone (MREZ) lies adjacent and landward of the HREZ and encompasses the area that is likely to be subject to a net shoreline retreat from a predicted mid-range most likely SLR of 0.40m above 1990 levels by 2100 and any historical long-term retreat. The MREZ encompasses the period from 2050 to 2100, and ranges in width from 0 to 30 m along Wainui Beach being widest in the area of the greatest historic erosion coupled with forecast erosion from sea-level rise. The long term shoreline trends for Tuaheni Point showed the headline had retreated at to 0.42 m/year, averaging m/year from 1942 to As shown in Figures 2.9 and 2.10 below there are dwellings at the top edge of the eroding cliffs adjacent to Tuahine Crescent, a significant portion of which lie within the extreme and high risk erosion zones as assessed by Gibb (2001) and presently contained in the Combined Regional Land and District Plan and online GIS maps (see Figures 2.9 and 2.10). The extreme risk erosion zone is shown as dark orange, the high risk erosion zone is shown as lighter orange, the moderate risk erosion zone is shown as yellow, and the safety buffer zone is shown as blue in the Combined Regional Land and District Plan and online GIS maps. 2 Gibb, J. (2001) Review of the 1995 Wainui Beach Coastal Hazard Zone.

19 13 Extreme risk erosion zone High risk erosion zone Moderate risk erosion zone Safety buffer zone Figure 2.9 Identification of properties surrounding the site with dwellings in the existing Extreme Risk Erosion Zone shown as dark orange Source: GDC, 2014 Figure 2.10 Identification of properties surrounding the site with dwellings in the High Risk Erosion Zone shown as light orange Source: GDC, 2014 The dwelling at 21 Wairere Road is partly located within the moderate risk erosion zone as shown in Figure 2.11 below.

20 14 Figure 2.11 Dwelling at 21 Wairere Road within Moderate Risk Erosion Zone Source: GDC, 2014 In summary, the dwellings at Tuahine Crescent are located in the extreme and high risk erosion zone, and the dwelling at Wairere Road is located in the moderate risk erosion zone based on the coastal hazard erosion zones as defined by Gibb and shown in the Combined Regional Land and District Plan.

21 15 3 Description of proposed works 3.1 Proposed works Rock revetment - Tuahine Crescent The rock revetment is approximately 40 m in length and extends from the southern concrete groyne to the northern extent of the Tuahine Crescent beach accessway, and will replace the existing rail iron log and rock wall. As shown on the drawings attached at Appendix C, the proposed rock revetment has a slope of 1.5:1 (H:V), a crest elevation of approximately 4.85m RL, and a crest width of approximately 3 m, and extends approximately 11 m seaward from the base of the cliff, approximately 3.5 m further seaward than the existing rail iron log and rock wall. While the crest elevation of the proposed rock revetment will be built at 4.85 m RL initially, provision for GDC to upgrade the crest elevation of the rock revetment to 5.60 m RL in the future is proposed. The 5.60 m RL crest elevation provides for a 50 year design life accounting for a sea level rise of 0.45 m. The rock revetment has been designed to limit its occupation, with a design slope as steep as possible (1.5:1, H:V), while maintaining its suitability for the mitigation of coastal erosion. At its northern terminus the structure will transition into the existing bank and tie into the existing rail iron log and rock wall located to the north of the beach accessway. This transition area will have a longshore length of approximately 7 m and have a 1.5:1 (H:V) slope both seaward and to the north. The existing timber stair access at Tuahine Crescent will also be required to be altered. The timber platform and stepped access is to be repositioned to allow public access over the proposed revetment face. The details for the structure are to be confirmed during the detailed design. As above, the works involve the construction of a rock revetment at the toe of the escarpment, in the location of the existing rail iron log and rock wall. The following works will be undertaken: The existing rock will be uplifted and graded, and rail-iron and logs removed. The rail-iron and logs will be disposed of at an appropriate facility, and any rock deemed to be suitable by the engineer will be reused in the construction of the rock revetment; The foreshore will be excavated with an excavator to create an appropriate grade for the structure; Geotextile will be placed over the graded area; and The underlayer and armour rock will then be placed on top of the geotextile to the required profile. Vehicle access for construction machinery to the Coastal Marine Area (CMA) is available from the southern end of Pare Street. Construction works will be undertaken when the foreshore is not inundated with tidal water. It is expected that this requirement will be imposed as a condition of consent. The construction works are expected to take approximately 20 weeks and this timeframe estimate will be confirmed once the contractor has been appointed for the physical works. It is expected that maintenance of the structure will be required over the duration of its consent term Sand push ups It is proposed to remove sand from between the mean high water and mean low water spring locations to widen the upper profile of the beach. The following works will be undertaken: Using mechanical plant (e.g. a small motor scraper or hydraulic excavator), obtain sand from the foreshore by scraping thin layers between the MLWS and MHWS shorelines. Care must be

22 16 taken to scrape no lower than 0.5 m below the existing foreshore profile nor lower than the minimum profile elevation surveyed in that area. Using mechanical plant (e.g. a small tracked bobcat or bull dozer), form the dunes by placing and shaping the sand within the area bounded by private property boundaries (or the edge of vegetation) and the MHWS spring shoreline. The dunes should be built up against the existing beach profile. This will take the form of a dune berm with a 5 m wide crest (at an elevation of 5.0 m RL) and a maximum seaward slope of 2:1 (H:V). Sand will only be moved when the upper beach is depleted and when there is sufficient sand in the lower profile to widen the upper beach following erosive episodes. As discussed in the design report while sand should be placed above the scraped location as far as possible, it is acknowledged that often locations where scraping is possible (i.e. where an excess of more sand is located between MHWS and MLWS) will differ from locations where upper beach scarps are present and sand is required. It is therefore recommended that sand is transported no more than 200m along the beach to keep sand in the same immediate littoral system as far as possible. Vehicle access to the CMA is available from the southern end of Pare Street, and from Moana Road at the Surf Club. Vehicle access also appears to be available from the carpark at the northernmost end of the beach from Whangara Road Gabion basket 21 Wairere Road The gabion basket and rock constructed under the emergency works provisions of the RMA is approximately 15 m in length and extends along the esplanade reserve in front of 21 Wairere Road. Rock has been placed above the baskets on top of the eroded dune face. Retrospective resource consent is sought for the erection and occupation of the gabion basket in the CMA. It is proposed to remove the rock above the gabion baskets. This will be undertaken with an excavator. Any rock deemed to be suitable by the engineer will be reused in the construction of the rock revetment at the southern end of the beach. Planting of the exposed dune face is recommended using salt tolerant vegetation following removal of the rocks to stabilise the sand against wave runup and overtopping of the gabion baskets. As above, vehicle access to the CMA is available from the southern end of Pare Street. 3.2 Consideration of alternatives The replacement of the existing railway iron and log wall with a more robust structure and sand push ups along Wainui Beach are recommended in the WBEMS. This consent application seeks to implement these recommendations to mitigate the effects of erosion, and reduce coastal erosion at Tuahine Crescent where the dwellings are currently closest to the cliff edge and where coastal erosion poses the highest risk. It is assumed that all options, benefits and costs have been considered and assessed by GDC, the community and technical advisors through the development of the WBEMS. Therefore the options assessment provided below refers to the option of upgrading the existing wall (leave rail iron in and building over it) or replacing the existing structure with new rock revetment only. Refer to the WBEMS for a consideration of alternatives and reasoning for recommending the existing rail iron log and rock wall be replaced with a more robust structure.

23 Rock revetment Tuahine Crescent Upgrade existing rail iron log and rock wall Upgrading the existing wall would encompass rocks being placed both landward and seaward of the rail iron log and rock wall. This was not considered a practical option to mitigate the effects of coastal erosion as the existing rail iron is deteriorating and unlikely to last for the intended consent term without replacement. With the deterioration of the rail iron, the logs may also fall out. It is noted that at the northern end of the structure the rail irons are partially covered in sand and rusting, and no logs are observable. There also may be health and safety issues relating to the exposed and rusted railway irons. It is noted that the existing structure is unlikely to be effective in mitigating coastal erosion in the medium-term (>15 years) due to its design (low crest and lack of geotextile) and current condition. Given the above, and the engineering limitations of the existing rail iron rock wall (it is relatively low crested and there is wave washed wooden debris at the top of the structure indicating periodic overtopping), the upgrade of the structure is not recommended, and replacement with a more robust structure is required Remove existing structure and replace with rock revetment Removing the existing structure and replacing it with a new rock revetment is the preferred option as it aligns with the recommendation under the WBEMS, and will help to mitigate the effects of coastal erosion on the existing dwellings and inhabitants of Wainui Beach which are located in an extreme risk erosion zone or high risk erosion zone. It is proposed that the term for this structure matches the expiry date for the recently constructed revetment to the south of the concrete groyne. Once the consent expires consideration of the most appropriate coastal management option will be re-evaluated based on the nature, scale, and understanding of the coastal hazards at that time, and also land-owner and community preference Gabion basket 21 Wairere Road As discussed above, the gabion basket and installation of rocks on the esplanade reserve in front of 21 Wairere Road were undertaken as emergency works. It is proposed to remove the rock above the gabion basket, and obtain retrospective consent for the gabion basket for the following reasons: The gabion basket at the site is consistent with other existing structures along Wainui Beach, to the north and south of the structure; The gabion basket will continue to provide short term erosion protection to the adjacent property and dwelling; and The rock placed above the gabion baskets does not appear to be a conventional revetment design, with geotextile overlaid by underlayer rock and armour rock, but rather widely graded riprap. There appears to be some larger rocks, which may be appropriate for the wave climate at the site, but also a high proportion of small rock (size unknown) which is likely to be displaced onto the beach during storm events. The extent of any geotextile beneath the rock is uncertain. Without full length geotextile in place, fine materials in the backslope foundation (comprising the dune slope) can migrate through the larger rocks causing erosion and oversteepening of the slope even with the rock in place. Overall, the emergency works have fulfilled their intended purpose, however the rock above the gabion is not considered an appropriate on-going coastal erosion protection option. The gabion

24 18 basket is considered to be in keeping with the adjacent erosion protection structures, and will continue to provide short-term erosion protection of the adjacent property and dwelling. Planting of the exposed dune face is recommended using salt tolerant vegetation to stabilise the sand against wave runup and overtopping of the gabion baskets.

25 19 4 Resource consent requirements The requirements for resource consents are determined by the rules in the Proposed Regional Coastal Plan, and the Combined Regional Land and District Plan. The rules which apply are determined by the zoning of the site, any identified limitations in the plan, and the nature of the activities proposed. Activities associated with the erosion management proposed within this application will occur both above and below mean high water springs (MHWS). Therefore the sand movement, and construction of the rock revetment, will involve a combination of foreshore disturbance and earthworks as defined in the regional and district plans respectively. Due to the nature of the activities and the dynamic nature of the beach, the location of MHWS is likely to change and therefore accurately quantifying the proportion of works above and below MHWS is not practicable. 4.1 Proposed Regional Coastal Environment Plan The Proposed Regional Coastal Environment Plan acknowledges that there are areas within the Coastal Environment where particular resources and therefore certain types of activity occur. In turn there are different types and levels of effect and amenity within a particular area, depending largely on what sort of activities are being undertaken there Management areas There are three management areas that are identified under the plan, the General Management Area, Protection Management Area, and Port Management Area. The Port Management Area includes highly modified environments where human structures dominate and natural landscape values are largely altered, the Protection Management Area includes terrestrial areas of significant conservation value, marine areas of significant conservation value, culturally sensitive sites and outstanding landscapes, and the General Management Area makes up the balance of the Coastal Environment. As identified under Map 2A22 the following activities are likely to at least partially be within the following protection management areas under the Proposed Regional Coastal Environment Plan: Gabion basket and removal of rock Wainui Beach Esplanade reserve (TP); Rock revetment Tuaheni Point Outstanding Landscape (Unit 15). The Protection Management Area Wainui Beach Esplanade reserve (TP) is a protected natural area (scenic reserve) and includes the section of esplanade reserve from Wairere Road to Hamanatua Stream. This area comprises steep foredune face fronted by incipient dune and beach foredune. The replacement of the rail iron log and rock wall with rock revetment appears to be within the outstanding landscape overlay under the Proposed Regional Coastal Environment Plan which comprises Tuaheni Point (Unit 15) (Figure 4.1). Unit 15 comprises a long sweeping sandy bay, terminated by Tuaheni Point, an isolated and rocky finger of sand stone projecting out from the coast..

26 20 Figure 4.1 Map 2A22 of Proposed Regional Coastal Environment Plan showing Landscape Unit 15 (Outstanding Landscape) hatched area. Source:, Although the replacement rock revetment appears to be within the outstanding landscape area in the Proposed Regional Coastal Environment Plan, the boundaries are not well defined and it is considered that the intent of the landscape assessment undertaken by Boffa Miskell (1995) was for the area of the replacement rock revetment to be excluded from the outstanding landscape area as discussed in more detail below. The Boffa Miskell landscape assessment (1995) was commissioned by GDC to assist the council in implementing and administering the Regional Coastal Environment Plan and Combined Regional and Land Plan, and to identify outstanding and natural landscape areas/ features (outstanding natural features and landscapes were not differentiated within the report) of the coastal environment in the Gisborne region. Tuaheni Point was identified as an outstanding landscape and feature in the Boffa Miskell assessment, the extent of which was described as delineating by the edge of the built development (NZMS 260 Y18 GR ). These coordinates extend from approximately 14 Tuahine Crescent on the eastern peninsula to 313 Sec 2E Kaiti on the western peninsula. The extent of the outstanding landscape and feature as assessed by Boffa Miskell is shown in Figure 4.2 below, and depicted in Figure 4.3 which shows the northern delineation of the area along the eastern peninsula as determined by the Boffa Miskell coordinates. This is located approximately 80 m south of the rock revetment. Figure 4.2 Outstanding natural feature and landscape Tuaheni Point (red highlight shows delineation of feature). Source: Boffa Miskell, 1995.

27 21 Rock revetment to replace rail iron wall. Approximate northern delineation of ONF on western peninsula. Figure 4.3 Approximate northern extent of outstanding natural landscape Tuaheni Point on eastern peninsula (red dot shows delineation of feature). Source: GDC, 2017 Therefore, it is clear that the Boffa Miskell assessment did not intend for the outstanding landscape feature unit to include the area of the replacement rock revetment. Table 4.1 outlines the resource consents required within the Proposed Regional Coastal Environment Plan. The activities within the General Management Area are governed by the rules under section 4.5, whereas the activities within the Protection Management Area are governed by the rules under Section 4.3. As the boundaries of the protection management areas are not well defined under Planning Map 2A22 we have assumed that the activities subject to this proposal are likely to fall both within the Protection Management Areas and General Management Areas in a technical sense. However, as discussed above, from a logical perspective the replacement rock revetment should not fall within the outstanding natural feature (unit 15), as it was not defined as being within the outstanding natural feature in the Boffa Miskell assessment, and is within a highly modified environment. Table 4.1: Resource consents required Proposed activity Rule reference / description Activity status Erection of rock revetment and gabion basket within general management area. Erection of rock revetment and gabion basket within protection management area. Rule 4.5.6J (General Management Area) Erection or placement of any structure in the Coastal Marine Area which has a predominant purpose of avoiding, remedying or mitigating the effects of natural processes on human property or life. Rule 4.3.6J (Protection Management Area) Erection or placement of any structure in the Coastal Marine Area which has a predominant purpose of avoiding, remedying or mitigating the effects of natural processes on human property or life. Discretionary Activity. Discretionary Activity.

28 22 Proposed activity Rule reference / description Activity status Occupation of rock revetment and gabion basket within general management area. Occupation of gabion basket and rock revetment within protection management area. Sand push ups within general management area. Rule 4.5.8E (General Management Area) Occupation of space involving crown land within the CMA which is not provided for by other rules of Chapter 4.5. It is noted that Rule 4.5.8A- occupation of space for permitted or controlled activities does not apply as the activity is a discretionary activity under Rule 4.5.6J of the plan. Rule 4.3.8E (Protection Management Area) Occupation of space involving crown land within the CMA which is not provided for by other rules of Chapter 4.3. It is noted that Rule 4.3.8A- occupation of space for permitted or controlled activities does not apply as the activity is a discretionary activity under Rule 4.3.6J of the plan. Rule 4.5.9G (General Management Area) The movement of sand from one section of the Wainui Beach foreshore to another. Discretionary Activity. Discretionary Activity. Discretionary Activity. The removal of the rock above the gabion basket, and removal of the rail iron log and rock wall is a permitted activity under Rules 4.3.6H and Rule 4.5.6H. Overall resource consent is sought for a Discretionary Activity under the Proposed Regional Coastal Environment Plan. 4.2 Combined Regional Land and District Plan The rules which apply are determined by the zoning of the site, any identified limitations in the plan and the nature of the activities proposed Zoning Table 4.2: Combined Regional Land and District Plan zoning and planning limitations Zoning / planning limitation Combined Regional Land and District Plan Comment Zoning General Residential Applies to the land/properties to the west of the esplanade reserves. The rock revetment, gabion basket/rocks, and sand push ups are partially within the general residential zone. Maps u75a & u74a. Amenity Reserve Overlays Land Overlay 3 (Regional Rules) Applies to the esplanade reserves along the entirety of Wainui Beach. The rock revetment, gabion basket, and sand push ups are partially within the amenity reserve zone. Maps u66a, u70a, u71a, u74a, u75a & u76a. The land overlays are developed from the land use capability (LUC) assessment of the New Zealand Land Resource Inventory (NZLRI) Gisborne East Coast Region, Second Edition, June The Land Overlay 3 area comprises Classes VII & VIII LUC units. The Land Overlay 3 area applies to the land to the west of, and in close proximity to the CMA at Wainui Beach. The

29 23 Zoning / planning limitation Coastal environment Extreme coastal hazard risk area Outstanding landscape area Comment rock revetment and gabion basket/rock structure are likely to partially be within this zone. Maps u75b & u74b. This applies to land in close proximity to the CMA. The rock revetment, gabion basket, and sand push ups are within the coastal environment. Maps u66b, u70b, u71b, u74b, u75b & u76b. The extreme coastal hazard risk area is defined in the Combined Regional Land and District Plan as the area which lies adjacent to the coast and encompasses the area subject to high impact short-term shoreline fluctuations (as identified in the Wainui 2001 report). There is a significant possibility of values being damaged or destroyed in any one year. Erosion could occur to the full width of this area in a single storm. The rock revetment, gabion basket/rocks, and sand push ups are likely to be within the extreme coastal hazard risk zone. Maps u66c, u70c, u71c, u74c, u75c & u76c. Tuahine Point. The rock revetment appears to be located within the outstanding natural landscape area under Map u75b, however as discussed above, the intent of the Boffa Miskell assessment was to delineate the outstanding landscape area at the edge of the built development. Therefore the replacement of the rail iron log and rock wall with rock revetment should not be located within the outstanding landscape area Resource consent requirements Table 4.3 outlines the resource consents required within the Combined Regional Land and District Plan. Table 4.3: Resource consents required Proposed activity Rule reference / description Activity status Construction and occupation of rock revetment and gabion basket, removal of rocks, and earthworks including sand push ups in the amenity reserve zone. Construction and occupation of rock revetment and gabion basket, removal of rocks, and earthworks including sand push ups in the residential zone. Installation of rock revetment and gabion basket erosion Rule As provision is not made for erosion protection works or earthworks in the amenity reserve zone, the works are a noncomplying activity in accordance with Rule Rule As provision is not made for erosion protection works or earthworks in the residential zone, the works are a noncomplying activity in accordance with Rule Rule Land disturbance and structures within 200 m of MHWS. Non-complying Activity. Non-complying Activity. Discretionary Activity.

30 24 Proposed activity Rule reference / description Activity status protection structures, and earthworks including sand push ups within 200 m of MHWS. Land disturbance associated with construction of rock revetment within an outstanding landscape overlay. Installation or alteration of works designed to mitigate the effects of coastal hazards. Alteration of natural dune landform including earthworks. Land disturbance of more than 10 m³ of soil in any 3 month period in the Land Overlay 3 area for construction of rock revetment and gabion basket. Rule Land disturbance which disturbs more than 10m³ of earth in any 3 month period within outstanding landscape overlay. Rule The works involve the installation of rock revetment, and gabion basket to mitigate the effects of coastal hazards. Rule Any activity, including earthworks that will alter natural dune landform. However it is noted that the beach push up activities are not likely to alter the dunes, rather the upper beach face where the beach face adjoins the dune. Rule The disturbance of more than 10m³ of soil in any 3 month period in the Land Overlay 3 area is a restricted discretionary activity. Earthworks are included under the definition of land disturbance. Restricted Discretionary Activity. Discretionary Activity. Discretionary Activity. Restricted Discretionary Activity. Overall resource consent is sought for a non-complying activity under the Combined Regional Land and District Plan.

31 25 5 Assessment of effects on the environment 5.1 Introduction The following assessment identifies and assesses the types of effects that may arise from the proposed works. This assessment also outlines the measures that the applicant proposes to avoid, remedy or mitigate any potential adverse effects on the environment. Actual and potential effects on the environment have been identified as including: Positive effects; Landscape and natural character effects; Amenity effects; Coastal process effects; Ecology effects; Public access and safety effects; Water quality effects; and Heritage effects. 5.2 Positive effects Rock revetment The replacement of the rail iron log and rock wall with rock revetment will provide a degree of protection to private land and a public access structure from coastal erosion. As discussed above, the replacement of the rail iron log and rock wall with a more robust structure was recommended in the WBEMS which was developed through a stakeholder engagement process and through input from the community. The Tuahine Crescent public stair access to the beach will also be reinstated following the works. The bank behind the log rail-iron wall and the rock revetment to the south of the groyne is vegetated, contrasting with the exposed active cliff south of these structures, suggesting the existing erosion protection structures are assisting with mitigating the effects of wave undercutting aggravating existing slope instability. The continued sub-aerial weathering of the cliff and reduction in erosion at the base of the cliff appears to have allowed a stable angle of repose to form and vegetation to establish. However, the existing rail iron log and rock wall is not likely to be effective at mitigating coastal erosion in the medium-term (>15 years) due to its design (low crest and lack of geotextile) and the current condition of Wainui Beach. It is also noted that the rail iron log and rock wall is rusting, which may cause the logs behind the rail iron to fall out. Due to the existing structural integrity of the rail iron log and rock wall, during erosion events rocks may therefore spill out on the foreshore, which is unsightly and can cause issues to pedestrian access. It is noted that at the northern end of the structure the rail irons are partially covered in sand and rusting, and no logs are visible. The exposed rail irons can also pose a health and safety risk to the public. Due to the slope of the proposed replacement rock revetment, it is likely to absorb more wave energy than the existing rail iron log and rock wall. Therefore, the revetment is likely to result in reduced beach lowering during erosive events when compared to the rail iron log and rock wall. Given the coastal erosion hazard risk in the area (particularly given the extreme risk to the dwelling at 6 Tuahine Crescent, and high risk to the dwelling at 4 Tuahine Crescent) it is considered necessary to maintain engineered protection in this area over the same lifetime as the recently constructed

32 26 revetment to the south of the groyne. It is noted that significant slumping of the cliff was evident in the vicinity of the subject site in 1955 (Figure 2.6), and undercutting is present at the base of the cliff to the south of the recently constructed rock revetment (Figure 5.1). As discussed above, the dwelling at 6 Tuahine Crescent within the extreme risk zone are or are likely to be subject to adverse effects from short- term duneline fluctuations and storm cuts, and has a high probability of being adversely affected at any point in time. The dwelling at 4 Tuahine Crescent, which is located in the high risk erosion zone, has a high probability of being adversely affected at any time from the present to 2050, and is likely to be subject to a net shoreline retreat. The rock revetment is the most practicable option to reduce landward retreat and protect the adjacent dwellings which are at extreme or high risk to coastal erosion for a period of time. If the existing structure was removed and/or left to deteriorate further, there may be aggravation of existing erosion in the area, and undercutting and slumping of the cliff may reoccur. Whilst not directly comparable, Figure 5.1 below shows what a protected shoreline in comparison to a nonprotected shoreline could look like. Accordingly, due to the condition of the existing rail iron log and rock wall, and the extreme and high risk coastal erosion poses to the adjacent dwellings, replacing the structure is considered the most effective approach to mitigate the effects of coastal erosion, and protect the adjacent dwellings, private properties and public access structure. Figure 5.1: Photograph showing undercutting to the south of the rock revetment to the south of the concrete groyne. Source: T+T, Sand push ups Sand push ups are proposed along Wainui Beach to mitigate the effects of coastal erosion where required and when the beach profile has excess sand on its lower face. Sand push ups can facilitate dune and upper beach face repair after erosion events by speeding up natural repair processes by moving sand from the lower beach profile to the upper beach profile. Therefore push ups have minimal impacts on the beach system and coastal processes. In addition, sand push ups are an

33 27 aesthetically unobtrusive option to mitigate the effects of erosion when compared to hard protection structures, and can widen the upper beach, improving access and the amenity value of the beach. Overall, push ups are an effective short term erosion mitigation option, which will allow GDC to respond quickly to severe erosion events that may pose a threat to dwellings (e.g. eroded scarp lies within 8 m of the dwelling, which is outlined as a potential trigger under the WBEMS) Gabion basket The existing gabion basket was constructed under the emergency works undertaken in front of 21 Wairere Road in response to a storm event that caused damaged to part of the property. The gabion basket structure will mitigate some of the effects of coastal erosion on the property at 21 Wairere Road which is within a high risk erosion zone, and dwelling which is within a moderate risk erosion zone. It is noted that during accretion periods, sand may partially or fully cover the structure, extending its longevity. It is proposed that the rock above the gabion basket is removed, as the rock may be displaced during storm events. 5.3 Landscape and natural character effects Rock revetment As discussed in Section of this report, it is clear that the Boffa Miskell assessment did not intend for the outstanding landscape unit to include the area of the replacement rock revetment. From a visual and natural character perspective the area has been highly modified with an existing rail iron log and rock wall at the site, a concrete groyne to the south, rock revetment extending south from the groyne, and residential properties along the coastal frontage. As such, the replacement of the existing rail iron log and rock wall with rock revetment is in keeping with the landscape and character values at the site. The rock revetment to replace the rail iron log and rock wall will not extend as far seaward as the rock revetment on the southern side of the groyne as it will be slightly steeper, but in general will mirror the alignment of the adjacent structure. Although the rock revetment will extend approximately 3.5 m further seaward than the existing rail iron log and rock wall which it will replace, the rock revetment will be in keeping with the rock revetment to the south of the groyne and is required to be located within the CMA to provide protection for the properties at extreme and high risk from coastal erosion (the cliffs are of higher elevation and the properties are at heightened risk in this area compared to the properties further north). The larger footprint of the rock revetment, in comparison to the existing rail iron log and rock wall, is due to the slope of the structure, which is flatter and is likely to be more effective in dissipating wave energy than the vertical rail iron log and rock wall. The rock revetment is to be constructed and sited as recommended in the WBEMS i.e. extends to the vicinity of the Tuahine beach access. Overall, as the replacement rock revetment will be similar in appearance to the rock revetment to the south of the groyne, and will replace an existing structure, the rock revetment will be in keeping with the highly modified existing environment and will not materially change the overall visual impression of the existing shoreline Sand push ups The sand push-up part of the application relates to the transfer of sediment from a portion of the profile of Wainui Beach to another. This will be used to reinstate and restore the upper beach face and dunes following erosion events. Therefore there will be no discernible alteration of the beach in terms of landscape and natural character.

34 Gabion basket Any landscape and natural character effects of the gabion basket are likely to relate to the introduction of the gabion baskets at the base of the escarpment. As shown in Figure 5.4 below the gabion basket has a relatively low crest elevation and is a small structure (both in terms of length and height) which is located at the base of the escarpment. Gabion baskets filled with cobbles held with rail irons are also located to the north of the site, and a grouted rock seawall is located to the south. Gabion basket structures are also located further south of the seawall. It is noted that provided the rock above the gabion is removed, the proposed structure will have a similar footprint to the gabion basket structures to the north and further south, and will generally be keeping with the modified existing environment. In addition, during accretion periods the structure is likely to be partially covered in sand. As such, the gabion basket will be in keeping with the structures to the north and further south, and as such will not materially change the overall visual impression of the existing shoreline. Figure 5.4: Gabion basket and rock which was constructed as emergency works. Source: GDC, Amenity effects Any visual effects have been addressed in Section 5.3 above. Other components of amenity effects include noise, dust and vibration which may be associated with the construction of the structures. It is considered that the main receptors of these short term construction based effects will be the users of the beach and the houses in close vicinity of the site. To mitigate potential adverse effects on beach users and nearby properties, the applicant offers that conditions are imposed by GDC that require: Compliance with NZS 6803: 1999 Acoustics - Construction Noise; and Construction work is undertaken between 7am and 7pm Monday to Saturday (excluding public holidays). 5.5 Coastal processes effects Rock revetment As discussed within the design report (attached in Appendix D), the existing rail iron, log and rock wall is located at around the average MHWS position and will therefore be affecting the existing beach by:

35 29 Truncating the beach at the position of the wall face; Preventing landward migration during storm conditions or under long-term erosion; Increasing wave reflection and potential scour in front of the wall; and Locking up sediment behind the wall which is not available for offshore-onshore transport. However, the existing wall is substantially located at the toe of a cliff shoreline (which is less susceptible to erosion than a dune shoreline) and therefore these affects are similar to those that would be occurring naturally without the wall in place (i.e. are occurring south of the revetments at the cliff-beach interface). Any effects of the rock revetment on coastal processes are likely to be similar to those of the existing rail iron log and rock wall, and therefore the replacement of the rail iron log and rock wall with rock revetment is not likely to result in a significant change to the existing coastal environment. Overall, it is considered any adverse coastal process effects associated with the proposed replacement rock revetment are likely to be less than minor when compared to the effects associated with the existing rail iron log and rock wall. Further, any adverse coastal process effects (particularly sediment lock up and beach scour) associated with the proposed replacement rock revetment are likely to be minor when compared to the effects which would result from an unprotected cliff shoreline Sand push ups See design report attached at Appendix D Gabion basket The gabion baskets at the site are consistent with other existing structures along Wainui Beach, although with a slightly lower crest elevation. As the gabion basket structure creates a hard barrier to erosion, and sand locked up behind the structure is not available for onshore/offshore transport, it is likely that some scouring may occur in front of the wall during erosive periods. However, there is also likely to be periods when sand accretes in front of the structure, covering the structure and assisting with extending its longevity. Given the small scale of the structure (only approximately 15 m long, with a low crest height) the amount of sand locked up behind the structure is likely to be minor and its potential for foreshore lowering is minor. In addition, there are gabion baskets located to the north of the structure, and a grouted rock seawall located to the south, and the gabion basket will tie into these adjacent erosion protection structures. As such, any adverse coastal effects of the gabion basket structure are likely to be minor. 5.6 Ecology effects Rock revetment The rock revetment will not be located within a terrestrial area of significant conservation value, or marine area of significant conservation value as listed under Appendix 3 of the Proposed Regional Coastal Environment Plan Occupation effects Benthic and terrestrial macroinfauna Surveys were undertaken at Wainui Beach in 1993, 1995 and Two reports were produced which assessed the impact of existing beach protection structures on benthic and terrestrial macroinfauna at Wainui Beach, and changes associated with beach erosion on the macroinfauna of

36 30 Wainui Beach south of the Hamanatua Stream (DOC, 1993 & 1997 ). The reports concluded that the available biological evidence indicates that the existing protection structures on southern Wainui Beach are influencing the composition of the macroinfauna of the backshore. However, overall this effect was concluded to be small since general environmental conditions on Wainui Beach south of the Hamanatua Stream are such that the natural pattern is for there to be macroinfauna of low species diversity and relatively low abundance. In addition, the rock revetment will be located as far landward as possible, at the base of the cliff and in the upper area of the beach where benthic fauna is generally lower in diversity and numbers. Given the above, and as the surrounding environment has been highly modified by erosion protection structures, and the rock revetment will replace the existing rail iron log and rock wall, any adverse effects of the rock revetment on macroinfauna are likely to be minor on coastal birds The rock revetment is not located within a bird nesting, roosting or feeding zone, or area of significant conservation value as listed in the Proposed Regional Coastal Environment Plan. Given the above, and as the area has already been modified, and will replace an existing structure, any effects on coastal birds are considered to be less than minor Construction effects Any disturbance to the foreshore will be minimised as much as possible during the construction of the rock revetment. Haul routes for construction machinery will be established along the upper beach from Pare Street, and therefore vehicles will not transit across or close to vegetated areas, shell fish beds, bird nesting areas, or any area identified as waahi tapu. Any adverse effects associated with the construction of the rock revetment on coastal ecology are likely to be minor Sand push ups Benthic fauna The lower beach profile, particularly near the toe of the beach (the beach slope/sand-flat interface), is generally where the greatest densities of benthic fauna are found. As discussed above, species assemblages found in the upper areas of beaches tend to have a lower diversity and numbers. Benthic species living in the sand from the toe of the lower beach profile that would be transferred to the upper beach profile will not survive the process, as conditions on the upper beach slope would be too dry. To minimise disturbance to the benthic communities, sand will not be removed from the toe of the beach below MLWS (-0.61 m RL), avoiding affecting the greatest density of benthic fauna. Where practicable, sand from the beach would be excavated to a greater depth from within a smaller area (but no lower than 0.5 m below the existing foreshore profile) rather than a shallow depth over a wider area, to avoid affecting a larger area of shellfish habitat. The main zone occupied by benthic communities, including shellfish, is about the upper 20 cm. Machinery will remain within defined construction zones and avoid areas within the lower beach slope as far as practicable. Species assemblages found on the upper beach profiles of Wainui Beach would be covered by the redistributed sand and it is expected that some of these benthic organisms would not survive the push up process. However, as discussed above, species found in the upper areas of beaches tend to be lower in diversity and abundance.

37 31 While the number of benthic organisms may be reduced by the sand transfer activities previous studies elsewhere in New Zealand (e.g. Gardner & Wear, 2006 in Wellington Harbour, Port of Tauranga, 2009; Lyttleton Port Company, 2013) indicate that communities would become reestablished in 1-3 years post-disturbance. In the case of mobile surface dwelling benthic species (such as snails), the duration will be much shorter than this, i.e. weeks or months. Given communities are expected to recover subsequent to beach push up operations, as only a proportion of the beach would be affected by the sand transfer at one time, and sand will not be removed from the toe of the beach below MLWS, any adverse effects of the sand transfer on benthic communities are expected to be minor on coastal birds As discussed in the W.D. Lynsar and Wainui Beach Reserves Management Plan (2008) there is generally a low number of fauna both in terms of species and abundance at Wainui Beach. A small black-backed gull colony was resident on the Makorori Headland, however their breeding area has been modified by erosion and it is not known whether the colony still resides there, and this does not form part of the site where the beach push ups are to take place. Little blue penguins have been known to come onto the shore. Birds such as black shag roost in the Pine and Macrocarpa trees on the northernmost part of the headland (outside of the reserve and the proposed beach push ups along Wainui Beach). Oystercatchers and kingfisher have also been noted in the reserve. The proposed transfer of sand has the potential to result in some temporary disturbance to coastal birds at Wainui Beach. Some areas of the beach (particularly the lower beach profile) are expected to have some foraging habitat value for coastal birds. However, it is expected that the recovery time for invertebrate and mollusc communities that inhabit the lower beach profile will be relatively short (approximately 1 3 years). Any disturbance to foraging for coastal birds would therefore be localised to the area of the sand push up, and birds are able to use adjacent foraging areas along Wainui Beach, and other nearby beaches, during sand transfer operations and recovery periods of invertebrate and mollusc communities. Any effects of the sand push ups on foraging habitat for coastal birds are considered to be less than minor as during the sand transfer operations, and recovery period of invertebrate and mollusc communities any coastal birds will be able to use adjacent foraging areas along Wainui Beach and other nearby beaches. 5.7 Public access and safety Rock revetment The site comprises a popular recreation beach. As shown in Figure 5.2, the existing iron-rail log wall at times inhibits access along Wainui Beach, particularly during spring tides and periods of erosion.

38 32 Water level reaching rail iron log and rock wall (apex of beach) Figure 5.2: Aerial view of coastline adjacent to Tuahine Crescent in March Source: Google Maps, As shown in the plan attached at Appendix C, and based on the topographic survey undertaken, public access is currently available at the site some of the time depending on the width of the beach. However, in some circumstances (e.g. during periods of erosion, higher than average tides and/or larger waves) access is already restricted due to the existing rail iron log and rock wall at the site, and with predicted sea level rise public access is expected to be further reduced. Replacing the rail iron log and rock wall with the rock revetment will not materially change access along the beach, as tidally restricted access will continue following the replacement of the structure. In addition, the concrete groyne to the south of the rail iron log and rock wall restricts access further south. This is particularly evident in Figure 5.2 above. Therefore, although pedestrian access will be limited during high tides along the small section of beach subject to this application, following replacement of the rail iron log and rock wall with the rock revetment, it will not worsen practical access. During periods of limited tidal access down this end of the beach, people are likely to go up the Tuahine Crescent beach accessway stairs which is proposed to be replaced as part of this proposal. As such, access to the beach from Tuahine Crescent will be maintained. Future Sea Level Rise (SLR) and ongoing erosion may cause the beach to retreat inland and expose the wall more frequently resulting in a narrower beach and limiting public access. However, due to the cliffed shoreline behind the revetment being in very close proximity to the replacement structure, if the shoreline retreats due to SLR, public access along the beach would be restricted by the cliff, irrespective of whether the rail iron log and rock wall was replaced with the rock revetment or not. Given the above, and as public access along the small section of beach is already restricted in some circumstances (particularly during spring high tides and periods of erosion), and will continue to be tidally restricted following the replacement of the rail iron log and rock wall with the rock revetment, the proposal will not materially change access along the beach Construction works During the construction works for the rock revetment and removal of rock above the gabion basket, and/or sand push ups, appropriate health and safety measures will be in place. The beach area

39 33 where works are being carried out will be closed off to the public during the work activity so the contractor can carry out the work safely. During the works most areas of the beach will remain accessible and appropriate pedestrian routes identified where necessary. The works will be of limited duration and as suggested will only occur Monday to Saturday to reduce disturbance to beach users. As such the works will only have temporary adverse effects on public access. 5.8 Water quality effects Construction/ removal of erosion protection structures During the construction works there is a potential for sediment to discharge into the CMA. During a high tide and/or storm surge, sediments disturbed on the foreshore, due to excavation and machinery movements, are likely to become suspended in the coastal water column, thereby resulting in a minor and temporary discolouration of sea water, but otherwise are unlikely to adversely affect marine organisms. To mitigate potential adverse effects on water quality the following measures are proposed: Excavation for the foundation of the rock revetment structure and placement of fill, and the removal of the rock above the gabion basket will take place when the intertidal area is not inundated by seawater; No segment of imported backfill for the rock revetment structure will be left unprotected at the end of each working day or when tidal water prevents further work occurring. The fill is to be protected by either rock or geotextile fabric; No refuelling of machinery will occur within the CMA; A hydrocarbon spill kit will be kept on site at all times; and The specification for imported rock and fill materials used in construction for the rock revetment will ensure these materials are free of organic material or contaminants. Overall any adverse effects of the construction works on coastal water quality are expected to be less than minor Sand push ups The water quality at Wainui Beach may be temporarily affected by turbidity caused by the release of fine materials when tidal water comes into contact with disturbed areas during sediment transfer and deposition, resulting in a minor and temporary discolouration of sea water, but otherwise is unlikely to adversely affect marine organisms. To mitigate potential adverse effects on water quality the works will take place when the intertidal area is not inundated by seawater. The potential for discharges associated with construction activities (such as fuel leaks) will be managed through appropriate construction management practices. 5.9 Cultural and archaeological effects Rock revetment Earthworks have previously been undertaken on the site (existing rail iron log and rock wall) and a search of Archsite has confirmed that there are no registered archaeological sites at the site. It is also noted that the area is dynamic and actively eroding. Therefore the proposed works are unlikely to affect an archaeological site and the accidental discovery protocol will be adhered to and Archaeological Authority applied for if any archaeological material is uncovered.

40 Sand push ups A search of Archsite has confirmed that there is a Registered Archaeological Site Y18/66 (midden) which is located on W.D Lynsar Reserve/the beach access adjacent to 33 Wairere Road. A number of middens are exposed on the beach front area of the sand dunes and bank but have been disturbed by the formation of the track to the beach. As the sand push ups involves the deposition of sand on the upper beach to restore the dunes following erosive events, an Archaeological Authority may be required for sand push up works which occur near the beach access adjacent to 33 Wairere Road. This will be obtained prior to any works in the vicinity if deemed required following advice from Heritage New Zealand Gabion basket New Zealand Archaeological Association s Archsite shows that Registered Archaeological Site Y18/10 (burial site) is located at 17A Wairere Road, and as abovementioned Archaeological Site Y18/66 (midden) is located on W.D. Lynsar Reserve/the beach access adjacent to 33 Wairere Road. These archaeological sites are located approximately 80 m and 70 m away from the gabion basket site respectively. Due to the location of the proposed rock removal at the esplanade reserve in front of 21 Wairere Road which is located a reasonable distance away from these registered sites, and given that earthworks has previously occurred on site during the emergency works in which no archaeological material was found, and the rock was placed over an erosion scarp, it is highly unlikely the proposed rock removal will affect these registered archaeological sites. As such, the accidental discovery protocol will be adhered to and Archaeological Authority applied for if any archaeological material is uncovered Summary of cultural and archaeological effects The site where it is proposed to construct the revetment and gabion basket, and/or undertake the sand push ups is not identified as a waahi tapu site in the Gisborne District Plan. The WBEMS had Tangata Whenua involvement (member of the Working Group which integrated the perspectives of multiple stakeholders in the development of the strategy) and engagement, with feedback sought from kaumatua on the values and issues relevant to the development of the strategy. In addition, GDC have engaged with Ngati Porou and Ngati Oneone in relation to the proposal. No concerns were raised with the works proceeding. As such, any adverse cultural effects of the replacement of the rail iron log and rock wall with rock revetment, and sand push ups along Wainui Beach are considered to be acceptable to Tangata Whenua.

41 35 6 Statutory assessment 6.1 RMA assessment Section 104 of the RMA sets out the matters to which a consent authority must have regard to, subject to Part 2 of the RMA, when considering an application for resource consent. These are: Any actual and potential effects on the environment of allowing the activity (refer Section 5 above); Any relevant provisions of: - a national environmental standard; - other regulations; - a national policy statement; - a New Zealand coastal policy statement; - a regional policy statement or proposed regional policy statement; - a plan or proposed plan; and Any other matter the consent authority considers relevant and reasonably necessary to determine the application. 6.2 Section 104D RMA Section 104D of the RMA is relevant to GDC s determination of the application in terms of the noncomplying component under the Combined Regional Land and District Plan. In order for GDC to consider the application under s 104, it must first be satisfied that the application can pass through one of the following two limbs of the gateway test : The adverse effects of the activity on the environment will be minor; or The application is for an activity that will not be contrary to the objectives and policies of the Plan. Only one of the two limbs must be met in order for GDC to proceed to consider the application under s 104. As set out in Section 5 above, any adverse effects of the proposal are likely to be minor. In terms of the second limb of the gateway test, the Courts have found that the term contrary to, should be treated as meaning repugnant to or opposed to in nature. Further, the Courts have found that when undertaking an assessment of an application to determine whether it is or is not repugnant to the objectives and policies of the Plan, that the objectives and policies should be considered as a whole. The activity is assessed against the objectives and policies framework of the Combined Regional Land and District Plan within Section of this report Part 2 of the RMA Part 2 of the RMA sets out the purpose and principles of the Act. The purpose of the RMA is to promote the sustainable management of natural and physical resources Section 5 Rock revetment Replacing the rail iron log and rock wall with a rock revetment will help to mitigate the effects of coastal erosion, and protect the properties and dwellings along the cliff line. The proposal represents a sustainable management approach to coastal erosion, because it will sustain the potential of

42 36 physical assets (e.g. dwellings) to meet the reasonably foreseeable needs of future generations while also maintaining the character of the coastal environment as far as possible, as the rock revetment will replace an existing structure, and will be in keeping with the highly modified existing environment Based on the extreme risk erosion zone that is or is likely to be subject to adverse effects from short- term duneline fluctuations and storm cuts, the dwelling at 6 Tuahine Crescent has a high probability of being adversely affected at any point in time. The dwelling at 4 Tuahine Crescent which is located within the high risk erosion zone also has a high probability of being adversely affected at any time from the present to The replacement rock revetment is only proposed for 25 years, at which stage consideration of the most appropriate coastal management option will be re-evaluated based on the nature, scale, and understanding of the coastal hazards at that time. At this point in time, without adequate protection, the dwellings may be adversely affected by shoreline retreat, short-term duneline fluctuations and storm cuts and/or by slope failure which has been evident along the Tuahine Crescent cliffline. Sand push ups The proposed sand scraping activities are considered consistent with the purpose of the RMA. These activities form a soft engineering approach, which enhances amenity values and widening of the upper beach following erosive episodes while mitigating the effects of short term erosion on adjacent properties. Gabion basket The gabion basket on the esplanade reserve in front of 21 Wairere Road will provide short-term protection to the adjacent property which is with the high risk erosion zone and dwelling which is within the moderate risk erosion zone. The character of the coastal environment will be maintained as far as possible, as the gabion basket will be in keeping with the gabion basket structure to the north and further south, and the rock above the gabion will be removed Section 6 Regard has been given to: The preservation of the natural character of the coastal environment (including the CMA), wetlands, lakes and rivers and their margins, and the protection of them from inappropriate subdivision, use and development; The protection of outstanding natural features from inappropriate subdivision, use and development; The maintenance and enhancement of public access to and along the CMA, lakes, and rivers; and The relationship of Maori and their culture and traditions with ancestral lands, water, sites, waahi tapu, and other taonga. Rock revetment The replacement of the rail iron log and rock wall with rock revetment is in accordance with the matters of national importance set out within the RMA. The rock revetment will replace an existing rail iron log and rock wall and although will extend slightly further seaward, will not materially change the visual impression of the shoreline at the site nor the coastline as a whole. The natural character of the coastline has already been significantly modified through the urban development of

43 37 the backshore area and the construction of erosion protection structures along the coastline. Therefore the rock revetment is considered in keeping with its environs. During spring tides large waves are likely to reach the base of the existing rail iron log and rock wall, particularly during periods of erosion, restricting access in some circumstances. Following the replacement of the with the rock revetment tidally restricted access will continue to be available along the beach. In addition, the beach to the south of the existing rail iron log and rock wall is also tidally restricted due to the existing southern groyne. The replacement rock revetment will mirror the general alignment of the existing rock revetment to the south, albeit with a slightly smaller footprint and seaward extent due to its steeper slope. Consequently, as there is already tidally restricted access due to either the existing rail iron log and rock wall, or the rock revetment further south, the rock revetment is unlikely to materially affect the provision of current tidally restricted access along the foreshore. In addition the Tuahine Crescent beach stair access will be removed and reinstated as a result of the works, and thus access from Tuahine Crescent will be maintained. Given the location of the rock revetment within a highly modified environment (at the base of the cliff in front of residential properties and adjacent to existing erosion protection structures), and the location of the Tuahine Point Outstanding Natural Feature (ONF) approximately 80 m to the south of the site, the rock revetment will not adversely affect the ONF. The rock revetment will help to protect at risk dwellings and properties which are likely to be subject to on-going erosion, and has been recommended in the WBEMS. The WBEMS takes into consideration the wider, economic, environmental, social, recreational and cultural context of the beach system as a whole. The WBEMS recommends different actions for various parts of the beach based on what is best for the associated land uses, and what has been discussed and agreed by stakeholders, working groups and the community as being the best option. Overall, the WBEMS and its recommended actions represents a sustainable management approach to coastal hazards, and takes a medium to long term view of management options and response. Therefore, the replacement of the rail iron log and rock wall with rock revetment is considered to be a sustainable approach to managing coastal hazards in the area, and constitutes a necessary and an appropriate use of the CMA. Sand push ups Sand push ups mimics the natural beach recovery processes, but increases the recovery rate. This speeds up sand redistribution onto the upper beach profile thereby assisting with providing a buffer against storm erosion while maintaining the overall sediment budget of the beach system and the overall character of the coastal environment. As discussed above, the WBEMS and its recommended actions constitutes a sustainable management approach to managing coastal hazards, and takes a medium to long term view of the management options and response. It is therefore considered that undertaking sand push ups along the beach is an appropriate and sustainable management approach to mitigating the effects of coastal erosion. Gabion Basket The gabion basket is in accordance with the matters of national importance set out within the RMA. The gabion basket only occupies a small area of the shoreline (approximately 15 m long and has a relatively low crest elevation and width), and will tie into the gabion baskets to the north. As such the structure will be in keeping with adjacent protection structures and does not extend any further seaward than existing structures. Therefore public access opportunities along the foreshore will not be affected Section 7 Regard has been given to: Kaitiakitanga;

44 38 The maintenance and enhancement of amenity values; Intrinsic values of ecosystems; and Maintenance and enhancement of the quality of the environment. Amenity values and the quality of the environment in the locale will overall be maintained as a result of the works, and any adverse effects on aquatic ecosystems are likely to be minor. As discussed above, Wainui Beach has already been highly modified by erosion protection structures and urban development of the backshore area. Rock revetment structures, gabion baskets and seawalls have been constructed along the coastline. The rock revetment will extend further seaward and have a larger footprint than the existing rail iron log and rock wall, however, overall, it will not result in the introduction of a new an erosion protection structure to an unmodified section of shoreline, and is not considered to be significantly different than the existing structure. Therefore, the quality of the coastal environment is expected to be maintained. The erosion protection structures, and beach push ups will help to protect the adjacent private properties, which have and/or are likely to be subject to erosion, and therefore is considered necessary to protect valuable assets. Although the rock revetment will occupy an area within the intertidal zone of the beach, the general environmental conditions on Wainui Beach south of the Hamanatua Stream are such that the natural pattern is for there to be macroinfauna of low species diversity and relatively low abundance. In addition, the rock revetment will be located as far landward as possible, at the base of the cliff and in the upper area of the beach where species assemblages of benthic fauna have a lower diversity and abundance. Given the abovementioned, and as the rock revetment will replace an existing rail iron log and rock wall any ecological effects of the proposal are considered to be minor. Although the sand push up works may affect benthic fauna, it has been found that benthic fauna will recover (expected to re-establish/ re-cover over 1 3 years). As such, any ecology effects from sand push ups are considered to be minor. Overall, regard has been given to the intrinsic values of ecosystems Section 8 There is nothing encompassed within the proposal which is contrary to the principles of Te Tiriti o Waitangi. 6.3 National Environmental Standards The only potentially relevant NES is the NES for Assessing and Managing Contaminants in Soil to Protect Human Health (2011) (NES Soil). As the site is not considered a piece of land the NES does not apply. 6.4 Policy framework analysis New Zealand Coastal Policy Statement The New Zealand Coastal Policy Statement (NZCPS) is a strategic document which outlines policies and objectives to achieve the purpose of the RMA in relation to the coastal environment of New Zealand. Key themes identified in the NZCPS and relating to the proposal are: Safeguarding the form and function of the coastal environment; Preservation of the natural character of the coastal environment; Preservation and enhancement of open space and recreational opportunities of the coastal environment; and Management of coastal hazards.

45 39 The King Salmon decision and subsequent Davidson decision and their implications to RMA law and practice has been considered in the assessment of the objectives and policies below. The King Salmon decision directs that the policies within the NZCPS are intended to, and do have binding effect, and these policies need to be achieved, rather than referring back to an overall broad judgement under s104 and Part 2 of the RMA. The Davidson decision extends this approach to the assessment of applications for Resource Consent. A detailed assessment of the proposal against the relevant objectives and policies contained within the NZCPS is provided in Table 6.1. Table 6-1: NZCPS objective and policy assessment Objective/policy Objective 1 To safeguard the integrity, form, functioning and resilience of the coastal environment and sustain its ecosystems, including marine and intertidal areas, estuaries, dunes and land, by: maintaining or enhancing natural biological and physical processes in the coastal environment and recognising their dynamic, complex and interdependent nature; Policy 11 To protect indigenous biological diversity in the coastal environment: (b) avoid significant adverse effects and avoid, remedy or mitigate other adverse effects of activities on: (i) areas of predominantly indigenous vegetation in the coastal environment; (ii) habitats in the coastal environment that are important during the vulnerable life stages of indigenous species; (iii) indigenous ecosystems and habitats that are only found in the coastal environment and are particularly vulnerable to modification, including estuaries, lagoons, coastal wetlands, dunelands, intertidal zones, rocky reef systems, eelgrass and saltmarsh; (iv) habitats of indigenous species in the coastal environment that are important for recreational, commercial, traditional or cultural purposes; (v) habitats, including areas and routes, important to migratory species; and (vi) ecological corridors, and areas important for linking or maintaining biological values identified under this policy. Response Rock revetment As discussed in the design report attached at Appendix D, prior to erosion protection works, the cliff toe/face was subject to erosion with finer material being moved offshore and coarser material remaining on the beach. The rock revetment is expected to mitigate future erosion of the cliff face and therefore prevent a potential source of sediment entering the beach system. However the existing rail iron log and rock wall currently reduces erosion and is therefore similarly expected to retain a potential source of sediment. Therefore, the replacement of the existing rail iron log and rock wall with rock revetment is unlikely to result in any reduction in the sand volumes in front of the cliff/revetment. The rock revetment is also expected to slightly reduce wave reflection compared to the existing rock and rail wall and so beach lowering effects are likely to be similar or slightly reduced. The general environmental conditions on Wainui Beach south of the Hamanatua Stream are such that the natural pattern is for there to be macroinfauna of low species diversity and relatively low abundance. The upper beach face where the rock revetment is to be located is also typically sparse in terms of benthic density, and there is an existing rail iron log and rock wall structure on the upper foreshore. These factors mean that the proposed site is likely to have low habitat and ecological value. Foreshore disturbance will be minimised as far as practicable during the construction of the rock revetment by vehicles transiting the foreshore along dedicated haul routes along the along the upper beach from Pare Street. On the basis of the above, the revetment works will not detrimentally affect the form and function of the coastal environment because biological and physical processes will be maintained. Consequently, it is considered the replacement of the rail iron log and rock wall with rock revetment is consistent with the objective and policy.

46 40 Objective 2 To preserve the natural character of the coastal environment and protect natural features and landscape values through: recognising the characteristics and qualities that contribute to natural character, natural features and landscape values and their location and distribution; identifying those areas where various forms of subdivision, use, and development would be inappropriate and protecting them from such activities; and encouraging restoration of the coastal environment. Policy 13 (1) To preserve the natural character of the coastal environment and to protect it from inappropriate subdivision, use, and development: (a) avoid adverse effects of activities on natural character in areas of the coastal environment with outstanding natural character; and (b) avoid significant adverse effects and avoid, remedy or mitigate other adverse effects of activities Sand push ups The proposed sand push ups will safeguard the integrity, form, functioning and resilience of the coastal environment and sustain the upper beach face and dunes as a natural defence against erosion by speeding up and mimicking the natural beach recovery processes. Although benthic organisms may be temporarily affected by the sand push up works, they have been shown to re-establish/ recover. Consequently, it is considered the sand push ups will maintain the form and function of the coastal environment, and the proposal is consistent with the objective and policy. Gabion basket It is likely that some scouring may occur in front of the wall during erosive periods. However, there is also likely to be periods when sand accretes in front of the structure. Given the beach is already highly modified with many erosion protection structures located along Wainui Beach (to the north and south of the gabion basket), the small scale of the structure (only approximately 15 m long), and that the gabion basket will tie into the adjacent erosion protection structures, any effects on coastal processes are likely to be minor. On the basis of the above, the gabion basket will not detrimentally affect the form and function of the coastal environment. Consequently, it is considered the proposal is consistent with the objective and policy. Objective 2 seeks to protect natural character values at the site and outstanding natural features (ONF). As discussed above, the intent of the Boffa Miskell landscape assessment appears to be to terminate the Tuaheni Point outstanding natural landscape/ feature at the edge of the built development. Therefore it is considered that the rock revetment site should not be within the outstanding natural landscape/feature overlay. From a practical perspective the site has also been highly modified by erosion protection structures (existing rail iron log and rock wall, concrete groyne adjacent to the southern end of the rail iron log and rock wall, and rock revetment south of the groyne). Therefore the rock revetment will not affect the ONF. Policies 13 and 15 provide more helpful qualification around the circumstances when protection is required and what the values should be protected from. It is clear that the policies seek to protect natural character values and protect natural features from inappropriate use. Rock revetment It is considered that the replacement of the rail iron log and rock wall with rock revetment constitutes an

47 41 on natural character in all other areas of the coastal environment; including by: (c) assessing the natural character of the coastal environment of the region or district, by mapping or otherwise identifying at least areas of high natural character; and (d) ensuring that regional policy statements, and plans, identify areas where preserving natural character requires objectives, policies and rules, and include those provisions. (2) Recognise that natural character is not the same as natural features and landscapes or amenity values and may include matters such as: (a) natural elements, processes and patterns; (b) biophysical, ecological, geological and geomorphological aspects; (c) natural landforms such as headlands, peninsulas, cliffs, dunes, wetlands, reefs, freshwater springs and surf breaks; (d) the natural movement of water and sediment; (e) the natural darkness of the night sky; (f ) places or areas that are wild or scenic; (g) a range of natural character from pristine to modified; and (h) experiential attributes, including the sounds and smell of the sea; and their context or setting. Policy 15 To protect the natural features and natural landscapes (including seascapes) of the coastal environment from inappropriate subdivision, use, and development: (a) avoid adverse effects of activities on outstanding natural features and outstanding natural landscapes in the coastal environment; and (b) avoid significant adverse effects and avoid, remedy, or mitigate other adverse effects of activities on other natural features and natural landscapes in the coastal environment; including by: (c) identifying and assessing the natural features and natural landscapes of the coastal environment of the region or district, at minimum by land typing, soil characterisation and landscape characterisation and having regard to: (i) natural science factors, including geological, topographical, ecological and dynamic components; (ii) the presence of water including in seas, lakes, rivers and streams; (iii) legibility or expressiveness how obviously the feature or landscape demonstrates its formative processes; appropriate use for the area in which it is proposed; primarily due to how it will mitigate adverse effects of coastal erosion on properties/dwellings that are within the extreme risk erosion zone and high risk erosion zone, and also it being a recommended action within the WBEMS. With respect to natural character, the rock revetment will replace the existing erosion protection structure (rail iron log and rock wall) and is located within a highly modified environment, with the areas to the north and south modified by erosion protection structures (groyne, rock revetments and existing rail iron log and rock wall), structures such as timber stairs located along the coastline, and intensive residential development within the backshore area along the cliffline. On this basis, the rock revetment will be in keeping with the highly modified existing environment including its character values, and adverse effects on natural character will be avoided. As set out above, T+T consider the proposed revetment constitutes an appropriate use and as it will replace an existing structure and is located within a highly modified environment will not materially change the overall impression of the coastline. On the basis of the above, is considered that the proposal is consistent with the objectives and policies because their directives around protecting natural character values are qualified to be in relation to inappropriate uses and adverse effects will be avoided. Policies 18 (c), 18(d), 18(e), 19(1) and 19(2)(c) and 27(c) of the NZCPS, discussed below, provide assistance to decision makers with deciding when a use may be deemed appropriate. The policies listed lend support to the replacement of the rail iron log and rock wall with rock revetment and why it can be considered an appropriate use. Sand push ups The sand push up works represent a soft engineering approach compared to the use of a hard engineered structure, and will improve the visual and recreational amenity of the area following erosion events. Sand push ups speed up and mimic the natural beach recovery processes, and allow increased upper beach face and dune toe protection against storm erosion, while maintaining the overall sediment budget of the beach system and preserving the overall character of the coastal environment. As such, sand push ups are considered an appropriate and favourable use for Wainui Beach,

48 42 (iv) aesthetic values including memorability and naturalness; (v) vegetation (native and exotic); which will maintain and preserve the natural character of the coastal environment. Gabion basket The gabion basket will continue to provide short term erosion protection of the adjoining property which is located within a high risk erosion zone. The structure is located within a highly modified environment with the areas to the north and south modified by erosion protection structures (gabion basket to the north, seawall to the south, and gabion basket structure further south), and intensive residential development within the backshore area. It is noted that provided the rock is removed from above the structure, then the proposed structure will have a similar footprint to the gabion basket structures to the north and further to the south. Therefore the gabion basket will be in keeping with the highly modified existing environment including its character values. Objective 4 To maintain and enhance the public open space qualities and recreation opportunities of the coastal environment by: recognising that the coastal marine area is an extensive area of public space for the public to use and enjoy; maintaining and enhancing public walking access to and along the coastal marine area without charge, and where there are exceptional reasons that mean this is not practicable providing alternative linking access close to the coastal marine area; and recognising the potential for coastal processes, including those likely to be affected by climate change, to restrict access to the coastal environment and the need to ensure that public access is maintained even when the coastal marine area advances inland. Policy 18 Recognise the need for public open space within and adjacent to the coastal marine area, for public use and appreciation including active and passive recreation, and provide for such public open space, including by: (a) ensuring that the location and treatment of public open space is compatible with the natural character, natural features and landscapes, and amenity values of the coastal environment; (b) taking account of future need for public open space within and adjacent to the coastal marine area, including in and close to cities, towns and other settlements; Rock revetment The principal driver of the proposal is to protect the private properties on the backshore area of the cliffline. Tidally restricted access along the foreshore is currently available at the site and this will still be the case following the replacement of the rail iron log and rock wall with the revetment. In addition, there is currently a concrete groyne to the south of the rail iron log and rock wall which is also likely to restrict public access at the southern end of the beach during high tides. Therefore, the approximately 40 m section of beach where the rail iron log and rock wall will be replaced with the rock revetment, will continue to have tidally restricted pedestrian access along it, and people are likely to use the Tuahine Crescent beach access steps during high tides where access is unavailable further south due to the southern groyne. The Tuahine Crescent beach access steps will be removed and reinstated as a part of the replacement works. Therefore access from Tuahine Crescent will be maintained. Overall the recreational opportunities and open space qualities of the coastal environment are expected to be maintained. Sand push ups Sand push ups will widen the upper beach following erosive periods, improving public access along the CMA. This will provide short-term protection against erosion, and enhance public open space and access following erosion events.

49 43 (c) maintaining and enhancing walking access linkages between public open space areas in the coastal environment; (d) considering the likely impact of coastal processes and climate change so as not to compromise the ability of future generations to have access to public open space; and (e) recognising the important role that esplanade reserves and strips can have in contributing to meeting public open space needs. Gabion basket Given the location of the gabion basket at the base of the dune, access along the beach will not be affected. As such, public access along the CMA will be maintained. Policy 19 (1) Recognise the public expectation of and need for walking access to and along the coast that is practical, free of charge and safe for pedestrian use. (2) Maintain and enhance public walking access to, along and adjacent to the coastal marine area, including by: (a) identifying how information on where the public have walking access will be made publicly available; (b) avoiding, remedying or mitigating any loss of public walking access resulting from subdivision, use, or development; and (c) identifying opportunities to enhance or restore public walking access, for example where: (i) connections between existing public areas can be provided; or (ii) improving access would promote outdoor recreation; or (iii) physical access for people with disabilities is desirable; or (iv) the long-term availability of public access is threatened by erosion or sea level rise; or (v) access to areas or sites of historic or cultural significance is important; or (vi) subdivision, use, or development of land adjacent to the coastal marine area has reduced public access, or has the potential to do so. Policy 16 (a) ensuring that activities in the coastal environment do not adversely affect the surf breaks; and (b) avoiding adverse effects of other activities on access to, and use and enjoyment of the surf breaks. Wainui Beach is listed as a surf break of national significance in the New Zealand Coastal Policy Statement (NZCPS), however the surf break is unlikely to be adversely affected by the proposal as; - any effects on coastal processes of the rock revetment are likely to be similar to those of the existing rail iron log and rock wall. - The sand push ups proposed involves moving relatively small (by comparison to the overall system) volumes of sand from between MLWS and MHWS. This is unlikely to affect incoming wave processes or surf zone circulation. As abovementioned, tidally restricted access to the beach will continue to be available at the rock

50 44 Objective 5 To ensure that coastal hazard risks taking account of climate change, are managed by: locating new development away from areas prone to such risks; considering responses, including managed retreat, for existing development in this situation; and protecting or restoring natural defences to coastal hazards. Policy 25 In areas potentially affected by coastal hazards over at least the next 100 years: (a) avoid increasing the risk of social, environmental and economic harm from coastal hazards; (b) avoid redevelopment, or change in land use, that would increase the risk of adverse effects from coastal hazards; (c) encourage redevelopment, or change in land use, where that would reduce the risk of adverse effects from coastal hazards, including managed retreat by relocation or removal of existing structures or their abandonment in extreme circumstances, and designing for relocatability or recoverability from hazard events; (d) encourage the location of infrastructure away from areas of hazard risk where practicable; (e) discourage hard protection structures and promote the use of alternatives to them, including natural defences; and Policy 27 (1) In areas of significant existing development likely to be affected by coastal hazards, the range of options for reducing coastal hazard risk that should be assessed includes: (a) promoting and identifying long-term sustainable risk reduction approaches including the relocation or removal of existing development or structures at risk; revetment site following the replacement of the existing rail iron log and rock wall with the rock revetment along the approximately 40 m section of beach. Therefore, access to, and use and enjoyment of the beach and surf break will be maintained. In addition, the proposed sand push ups will widen the upper beach following the sand push ups. As such, public access along the beach and enjoyment of the surf break will be maintained as a result of the proposed sand push ups. On the basis of the above the proposal is considered to be consistent with the policy. Rock revetment GDC has considered the potential coastal management options in the WBEMS for different segments of the shoreline that could be used to reduce erosion and reduce the risk to properties. The WBEMS sets out recommended actions for each area. The replacement of the existing rail and rock wall with a more robust structure is the preferred option within the strategy for the site. It is considered that the rock revetment, as a hard protection structure, is the only practical means to protect the private properties and dwellings to the west of the cliffline which are at extreme or high risk from coastal erosion. This is necessary to sustain the potential of the built physical resources (e.g. dwellings along the backshore of Tuahine Crescent) to meet the reasonably foreseeable needs of future generations, and protect private assets. The dwellings landward of the rock revetment are already in existence and the revetment will not itself facilitate more intense development. Areas within the extreme risk erosion zone are or are likely to be subject to adverse effects from short- term duneline fluctuations and storm cuts. Areas within the high risk erosion zone have a high probability of being adversely affected from the present to The proposed consent duration is only 25 years (expires at the same time as the existing southern rock revetment), at which stage consideration will be given for future coastal management options. The rock revetment will be constructed at the base of the cliff as far landward as practicable, and with a maximum practicable slope to minimise the occupation area. Further, the structure will follow the alignment of the shoreline morphology. Consequently, the form and location of the proposed revetment has been designed to minimise adverse effects on the coastal environment. In accordance with Policy 27(1)(a) the WBEMS provides for ongoing use of the existing beach and the existing beachfront properties over at least the

51 45 (b) identifying the consequences of potential strategic options relative to the option of donothing ; (c) recognising that hard protection structures may be the only practical means to protect existing infrastructure of national or regional importance, to sustain the potential of built physical resources to meet the reasonably foreseeable needs of future generations; (d) recognising and considering the environmental and social costs of permitting hard protection structures to protect private property; and (e) identifying and planning for transition mechanisms and timeframes for moving to more sustainable approaches. (2) In evaluating options under (1): (a) focus on approaches to risk management that reduce the need for hard protection structures and similar engineering interventions; (b) take into account the nature of the coastal hazard risk and how it might change over at least a 100-year timeframe, including the expected effects of climate change; and (c) evaluate the likely costs and benefits of any proposed coastal hazard risk reduction options. (3) Where hard protection structures are considered to be necessary, ensure that the form and location of any structures are designed to minimise adverse effects on the coastal environment. (4) Hard protection structures, where considered necessary to protect private assets, should not be located on public land if there is no significant public or environmental benefit in doing so. Objective 6 To enable people and communities to provide for their social, economic, and cultural wellbeing and next years (GDC is seeking consent for the rock revetment for only 25 years). However in the longer term ( years), the potential use of the beach and properties will be determined by the rate of future sea level rise. As discussed under the WBEMS, if the beach undergoes significant permanent retreat and increased inundation risk, it is possible that hard protection structures may be required to move landward to avoid serious adverse effects, and dwellings and assets may need to be relocated landward to a safer location. On the basis of the above, it is considered that the replacement of the rail iron log and rock wall with the rock revetment is consistent with the objective and policies. Sand push ups GDC promoted the use of sand push ups along Wainui Beach in the WBEMS so that council can respond quickly to severe erosion events that threaten dwellings. Sand push ups increase the volume of sand on the upper beach to buffer against erosion events and are therefore a practical means in assisting in protecting properties/dwellings from coastal erosion which are relatively close to the shoreline, while mimicking a natural repair process by transferring sand from the lower beach to the upper beach profile. As such, sand push ups aids in the protection/restoration of natural defences to coastal hazards and represents a soft option in accordance with Objective 5, and policies 25 and 27. Gabion basket The gabion basket wall, was considered a practical means to protect the adjacent property following a storm event which resulted in damage to part of 21 Wairere Road. This provides short term protection against erosion to protect the private property, and sustain the potential of built physical resources to meet the reasonably foreseeable needs of future generations. The gabion basket has been constructed at the base of the dune, as far landward as practicable, and it is proposed that the rock behind the gabion basket is removed. Consequently, the form and location of the gabion basket minimises adverse effects on the coastal environment. Further, the structure follows the alignment of the shoreline morphology. On the basis of the above, it is considered that the gabion basket is not contrary to the objective and policies. The proposal will enable people and communities to provide for their social, and economic wellbeing and their health and safety, as it will mitigate the effects of coastal erosion on the adjacent properties.

52 46 their health and safety, through subdivision, use, and development, recognising that: the protection of the values of the coastal environment does not preclude use and development in appropriate places and forms, and within appropriate limits. functionally some uses and developments can only be located on the coast or in the coastal marine area; the protection of habitats of living marine resources contributes to the social, economic and cultural wellbeing of people and communities; Policy 6 (1) In relation to the coastal environment: (a) recognise that the provision of infrastructure, the supply and transport of energy including the generation and transmission of electricity, and the extraction of minerals are activities important to the social, economic and cultural well-being of people and communities; (b) consider the rate at which built development and the associated public infrastructure should be enabled to provide for the reasonably foreseeable needs of population growth without compromising the other values of the coastal environment; (2) Additionally, in relation to the coastal marine area: (a) recognise potential contributions to the social, economic and cultural wellbeing of people and communities from use and development of the coastal marine area, including the potential for renewable marine energy to contribute to meeting the energy needs of future generations: (b) recognise the need to maintain and enhance the public open space and recreation qualities and values of the coastal marine area; (c) recognise that there are activities that have a functional need to be located in the coastal marine area, and provide for those activities in appropriate places; (d) recognise that activities that do not have a functional need for location in the coastal marine area generally should not be located there; and Policy 1 2) Recognise that the coastal environment includes: (a) the coastal marine area; The proposed revetment and gabion basket have to be sited within the coastal environment if they are to serve their intended purpose. As discussed above it is not considered that the area of the rock revetment is intended to be within the ONF, and the northern boundary of the ONF appears to be intended to be located approximately 80 m to the south of the replacement rock revetment. Therefore the replacement of the rail iron log and rock wall with the rock revetment will not affect the ONF. On the basis of the above, it is considered that the proposal is consistent with the objective and policies. The policy is clear that the coastal environment is a dynamic and complex zone where coastal processes, areas at risk from coastal erosion, and physical resources (such as the residential development along the coastline), are interacting with one

53 47 (c) areas where coastal processes, influences or qualities are significant, including coastal lakes, lagoons, tidal estuaries, saltmarshes, coastal wetlands, and the margins of these; (d) areas at risk from coastal hazards; (f ) elements and features that contribute to the natural character, landscape, visual qualities or amenity values; (h) inter-related coastal marine and terrestrial systems, including the intertidal zone; and (i) physical resources and built facilities, including infrastructure, that have modified the coastal environment. Policy 20 (1) Control use of vehicles, apart from emergency vehicles, on beaches, foreshore, seabed and adjacent public land where: (a) damage to dune or other geological systems and processes; or (b) harm to ecological systems or to indigenous flora and fauna, for example marine mammal and bird habitats or breeding areas and shellfish beds; or (c) danger to other beach users; or (d) disturbance of the peaceful enjoyment of the beach environment; or (e) damage to historic heritage; or (f ) damage to the habitats of fisheries resources of significance to customary, commercial or recreational users; or (g) damage to sites of significance to Tangata Whenua; might result. another. The development of the WBEMS and recommendations in the WBEMS to manage coastal erosion at the site has recognised and considered the listed values, resources and features, in terms of their contribution to the composition of the coastal environment. It is therefore considered that the proposal is consistent with the policy. It will be necessary for machinery to work within the CMA to supply materials and excavate the foreshore. The area where machinery movements will take place (at the top of the foreshore profile) is characterised by low ecological and habitat values, and the works will not take place when the area of affected foreshore is inundated by water Further, the area of disturbance will be the minimum necessary to undertake the work. For these reasons, vehicle use of the foreshore will be controlled and the proposal is consistent with the policy Gisborne Regional Policy Statement The Gisborne Regional Policy Statement is a strategic document which provides an overview of the major resource management issues and sets out the direction for managing the use, development and protection of the natural and physical resources of the region. Table 6-2 below assesses the applicable objectives and policies of the Gisborne Regional Policy Statement. The application is consistent with the objectives and policies. Table 6-2: Gisborne Regional Policy Statement objectives and policies assessment Objective/Policy Objective (1) Maintenance or enhancement of public access to and along rivers, lakes, and the coastal marine area. Comment The existing rail iron log and rock wall restricts pedestrian access along the foreshore at times and following replacement of the rail iron log and rock

54 48 Policy In order to recognise the importance of maintaining and enhancing public access to and along the coastal marine area, lakes and rivers, management restricting access should only be imposed where such management is necessary: d) to protect public health and safety; such as diversion away from areas of danger like land subsidence, river control construction sites, port operational areas or areas used for defence purposes; or f) in other exceptional circumstances sufficient to justify the restriction notwithstanding the national importance of maintaining the access. wall with the rock revetment tidally restricted access along the foreshore will continue to be available, In addition the Tuahine Crescent beach stair access will be reinstated following the replacement of the structure. As such, access from Tuahine Crescent to the beach will be maintained and enhanced. The rock revetment will provide protection to the adjacent properties and dwellings and will not materially change public access from the existing situation as tidally restricted access along the foreshore will continue to be available. As such the replacement rock revetment is considered to be consistent with the objective and policy. 2. To ensure when planning for and making decisions on new subdivision, use and development that: a) there is no reduction in the quality of existing legal access to and along waterbodies, unless that restriction is consistent with 2.7.2(1) above and b) opportunities for access to and along water bodies, or parts of waterbodies, not restricted by policy 2.7.1(1) above, which are considered by council to be of benefit to the local community for their conservation, recreational, cultural, scenic, spiritual or other amenity values are recognised and provided for. Objective (1) A pattern of human settlement that: - Provides a high level of personal safety from natural hazards for its inhabitants; - Avoids or mitigates the risk to property and infrastructure from natural hazards; - Does not accelerate or worsen the effects of natural hazards upon the natural and physical environment. Policy (2) To recognise the limitations of attempts to control natural processes by physical work and limit such attempts to appropriate situations where they are: a) needed to protect existing development and; b) have a favourable benefit to cost ratio; and; c) will not have significant adverse effects on the natural character of the coastal environment, or other adverse environmental effects; and d) will not cause or worsen hazards to other lands/waters; and e) can be designed with confidence of longterm effective performance; and f) are the only practical alternative. Rock revetment and sand push ups As discussed the replacement of the rail iron log and rock wall with a more robust structure and sand push ups along Wainui Beach were recommended actions in the WBEMS. The replacement of the rail iron log and rock wall is necessary to protect existing development which is located in the extreme risk erosion zone, and high risk erosion zones. Many options were considered under the WBEMS, however the replacement of the rail iron log and rock wall with a more robust structure has been identified as the most practical alternative. The rock revetment will replace an existing erosion protection structure (rail iron log and rock wall) and is within a highly modified environment, as such it is considered that it will be in keeping with the existing character values of the coastal environment at the site, and will not change the overall impression of the coastline. Sand push ups are considered to have positive amenity effects, and will increase the volume of sand on the upper beach to buffer against erosion events and assist in protecting dwellings. Sand push ups speed up and mimic a natural repair process by transferring sand from the lower beach to the upper beach profile.

55 49 As discussed above, development of the backshore area is existing and as such the proposed erosion protection measures, as recommended in the WBEMS, will not facilitate any additional or intensified residential development. The WBEMS considers the issues with hard protection structures, and limits the extent of future hard protection structures along Wainui Beach as far as possible. Under the WBEMS, hard structures are recommended to be replaced/upgraded only where necessary. The replacement of the existing rail iron log and rock wall with rock revetment from the southern groyne to the northern extent of the Tuahine Crescent beach access is considered necessary due to the extreme erosion risk and high erosion risk to the adjacent dwellings. Gabion basket The gabion basket will help to provide short term erosion protection to the adjacent property and dwelling, and is in keeping with the character values of the surrounding environment. It is considered that the gabion wall will continue to help to provide short term erosion protection to the adjacent property, and as such is not considered to be contrary to the objective and policy Proposed Regional Coastal Environment Plan Table 6-3 below assesses the applicable objectives and policies of the Proposed Regional Coastal Environmental Plan. The application is consistent with the objectives and policies. Table 6-3: Proposed Regional Coastal Environment Plan objectives and policies assessment Objective/Policy Objective 2.2.3B Outstanding natural features and landscapes/seascapes are protected from the adverse effects of inappropriate activities. Policy 2.2.4D Planning and consent authorities shall have regard to the following when preparing plans or considering any proposal which might affect the appearance of any outstanding natural features and landscapes. 1. Use and development shall respect the natural landform characteristics. Subdivision, use and development that cause strong visual contrasts with, or modification of natural landforms are visually incongruous and shall be avoided. 3. The visual continuity across the edge of land and sea is a sensitive impact of all landscape features. Developments that disrupt the visual continuity shall be avoided. Response Rock revetment As discussed above, the Tuaheni Point outstanding natural landscape/feature identified by Boffa Miskell was delineated by the edge of the built development, therefore the intent of the landscape assessment undertaken by Boffa Miskell appeared to be to exclude the area subject to this application. Therefore the replacement of the rail iron log and rock wall with the rock revetment will not affect the ONF, and the proposal is consistent with the objective and policy.

56 50 5. The characteristic components of headland landforms (I.e. cliff, escarpment, rocks and remnant vegetation) shall be protected. Objective 3.1.3A Provision is made for appropriate structures in the CMA provided that any adverse effects on the environment arising from the erection, reconstruction, placement, alteration, extension, removal or demolition of a structure are avoided as far as practicable. Where complete avoidance is not practicable, the adverse effects are mitigated and provision made for remedying those effects, to the extent practicable. Policy 3.1.4B To provide for the maintenance and upkeep of structures located in the Coastal Environment. To avoid, remedy or mitigate the effects of maintenance and upkeep. Policy 3.1.4E Council and Consent Authorities should make provision for new structures in the CMA where it can reasonably be demonstrated that such structures are: a) Reasonably necessary to provide for the lawful exercise of any activity and no reasonably practicable alternative to the new structure in the CMA exists; and b) Any new structure is consistent with the Objectives and Policies of this Plan. Provided that adverse effects on the environment arising from the new structure are, as far as practicable, avoided. Where complete avoidance is not practicable, the adverse effects should be mitigated and provision made for remedying those effects to the extent practicable. When considering what is reasonably necessary to provide for the lawful exercise of any activity Council and Consent Authorities shall consider: 1. The extent to which the structure restricts the exercise of other lawful activities or public access into or through the area in which the structure is to be located. 2. The level of security required to ensure the safe and efficient exercise of the activity for which the structure is required. Policy 3.1.4Q To recognise the potential impacts that natural hazards have on the existing subdivision, use or development in the Coastal Environment and to provide for the mitigation of these adverse effects by providing for coastal protection works only where Rock revetment As discussed in numerous places in this report, the proposed revetment is considered to be an appropriate structure at the site. Policy 3.1.4E provides some guidance on when decision makers should make provision for new structures in the CMA. It is considered that the proposed revetment is necessary and the most practicable option to provide for erosion protection to the adjacent private properties/dwellings, and adverse effects on the environment will as far as practicable, be avoided. It also states that the Council should consider the extent to which the structure restricts the exercise of public access into or through the area in which the structure is to be located. Following the replacement of the rail iron log and rock wall with the rock revetment tidally restricted pedestrian access will continue to be available along the foreshore. As such, the replacement of the existing rail iron log and rock wall with rock revetment will not materially affect public access when compared to the existing situation. One of the reasons for selecting a rock revetment over other materials typically used to construct seawalls is that rock generally requires less maintenance and lasts longer. Therefore the proposed structure has been designed to ensure minimal maintenance is required, maintenance is uncomplicated and the materials are appropriate to the dynamic coastal environment. Therefore, consistency with Policy 3.1.4B is achieved. In accordance with policy 3.1.4Q the coastal protection works are considered the best method for preventing or minimising adverse effects on the environment, having regard to the sensitivity of the properties and dwellings along the coastal frontage, and the likelihood that the option can be successfully applied. It is therefore considered that the replacement of the rail iron log and rock wall with rock revetment is consistent with the objective and policies. Gabion basket As discussed above, the gabion basket will continue to provide short term protection to the property which is located in a high risk erosion zone and dwelling which is located within a moderate risk erosion zone, and adverse effects on the environment will as far as practicable, be avoided.

57 51 coastal protection works can be shown to be the best method for preventing or minimising adverse effects on the environment having regard, among other things, to the sensitivity of the surrounding environment, the effects of the protection work when combined with other options, and the current state of technical knowledge and the likelihood that the option can be successfully applied. Objective 3.1.3B Appropriate structures are located and built in such a way so as to provide for the preservation and where appropriate, enhancement of the natural character of the Gisborne Coastal Environment. Policy 3.1.4A To recognise that within the Coastal Environment different areas have distinct natural character and amenity value and to ensure that applications for consents for structures within the Coastal Environment include adequate measures to avoid, remedy or mitigate any adverse effects on natural character and amenity values. Policy 3.1.4G To achieve efficiencies in the utilisation of existing structures within the Coastal Marine Area by ensuring that no new structures are allowed in the CMA while modification or addition to an existing structure or structures can be made and will achieve the purpose of the required new structure with the same or less adverse effect. Policy 3.1.4H To ensure that, where a structure locates in the CMA and results in adverse effects on the environment that are not able to be avoided, remedied or mitigated, the structure remains within the CMA only so long as is necessary to achieve the purpose for which it was established. This policy will be implemented in part by monitoring the exercise of resource consents and cancelling those that are not exercised for a continuous period of at least two years. To encourage the removal of structures which are obsolete, illegal or unused. As discussed above, the gabion basket will not affect public access due to the location of the gabion basket at the base of the dune. It is therefore considered that the gabion basket is not contrary to the objective and policies. Rock revetment As discussed in numerous places in this report, the proposed revetment is considered to be an appropriate structure at the site, and is located within a highly modified environment. The revetment will be built as far landward as practicable with a maximum practicable slope to minimise its occupation area. Consequently, the form and location of the proposed revetment has been designed to provide for the preservation of the natural character of the coastal environment as far as possible. Modification to the existing rail iron log and rock wall is not considered to be a practicable option, as the existing rail iron is deteriorating and unlikely to last for the intended consent term. Further, the structure holds greater uncertainty when compared to the replacement revetment in its ability to mitigate the effects of coastal erosion on the adjacent dwellings which are identified as being at extreme or high risk of coastal erosion. As discussed above the consent term will be 25 years, after which time removal of the rock revetments will be considered (both proposed replacement structure and recently constructed revetment to the south of the groyne), with the future action undertaken dependent on the understanding of the hazard at that time and landowner and community preference. As such, the replacement rock revetment is considered to be consistent with the objective and policies. Gabion basket The gabion basket is similarly considered to be an appropriate structure at the site, and is located within a highly modified environment. The gabion basket has been built on the upper foreshore and as far landward as practicable, and it is proposed to remove the rock behind the gabion basket. Consequently, the gabion basket will be in keeping with the highly modified existing environment including its character values. As such the gabion basket is considered to be consistent with the objective and policies. Objective 3.1.3D Rock revetment

58 52 No reduction in the level and quality of access the public have to and along the Coastal Marine Area as a consequence of structures located in the Coastal Environment and, where appropriate, enhanced levels of access. Policy 3.1.4K To maintain or enhance existing levels of public access to and along the coast or, where a specific reduction in public access is unavoidable, to avoid, remedy or mitigate the adverse effects of that reduction. To require all new structures, or consents for existing structures, in the CMA to provide for public access across them unless restriction is necessary: To protect public health or safety; or To protect Maori cultural values; or There is a specific operational requirement to exclude the public. Objective 3.3.3A To provide for activities that alter the foreshore or bed of the Coastal Marine Area while avoiding, remedying or mitigating any adverse effects they have on ecosystems and habitat. Policy 3.3.4J Council and Consent Authorities should adopt a precautionary approach in assessing the effects on the environment arising from the alteration or disturbance of the foreshore or seabed of the CMA where the effects are: i unknown; or ii little understood. Tidally restricted pedestrian access along the foreshore is currently available at the site and this will still be the case following the replacement of the rail iron log and rock wall with the revetment. In addition, there is currently a concrete groyne to the south of the rail iron log and rock wall which restricts public access at the southern end of the beach during high tides. Therefore, pedestrian access along the small section of beach where the replacement rock revetment is proposed will continue to be tidally restricted as a result of the proposal. The public are likely to use the Tuahine Crescent beach access steps during high tides where access is unavailable further south due to the southern groyne south of the site. The Tuahine Crescent beach access steps will be replaced as a result of the proposed works. The rock revetment has been designed with a slope and crest height so as to provide adequate protection to the adjacent dwellings and properties. As such, the seaward extent of the structure is as far landward as possible, while achieving the necessary protection desired. As discussed in response to Objective 6 of the NZCPS, the proposed revetment has to be sited within the coastal environment if it is to serve its intended purpose of protecting those dwellings on the cliff line which are at extreme or high risk of erosion. As such, the replacement rock revetment is considered to be consistent with the objective and policy. Gabion basket Given the location of the gabion basket at the base of the dune, public access will not be affected. As such the gabion basket is considered to be consistent with the objective and policy. Sand push ups As discussed above, any adverse effects of the sand push ups on benthic ecosystems are likely to be minor as communities are expected to recover subsequent to beach push up operation, only a proportion of the beach would be affected by the sand transfer at one time, and sand will not be removed from the toe of the beach profile where benthic species are most abundant. Any effects on foraging habitat for coastal birds is likely to be temporary, and localised to the area of the beach push up, and birds can use adjacent foraging areas along Wainui Beach and nearby beaches. As such, the proposed sand push ups is considered to be consistent with the objective and policy.

59 53 Objective 3.3.3C Maintenance or enhancement of natural character and amenity values of the Coastal Environment. Policy 3.3.4C To ensure that activities that alter or disturb the foreshore or bed of the CMA do not adversely affect the natural character of the Coastal Environment by: Protecting the integrity and functioning of sediment transport processes; and Ensuring that measures are taken to mitigate any adverse effects an activity may have on the biodiversity of an area; and Ensuring beach replenishment activities use sand or other natural materials that is compatible with the natural character and geophysical processes of the area. Sand push ups As discussed in numerous places in this report, sand push ups speed up and mimic the natural beach recovery processes, and provides increased upper beach face and dune toe protection against storm erosion. Push ups maintain and preserve the overall character of the coastal environment. As such, the proposed sand push ups is considered to be consistent with the objective and policy District Plan assessment It has been established that non-complying land use consent is required under the Plan. With a view to satisfying the Gateway Test set down within s 104D of the RMA, we now turn to assessing this application against the relevant objectives and policies contained in the Plan. Table 6-4 below assesses the applicable objectives and policies of the Combined Regional Land Plan. The application is consistent with the objectives and policies. Table 6-4: Combined Regional and Land Plan objectives and policies assessment Objective/Policy Objective 5.3 (3) The protection of natural features that could lessen the impact of natural hazards Policy 5.15 (22) Where subdivision use and development are proposed in an area identified as an Area Sensitive to Coastal Hazard (ASCH), the Council shall take into account the nature of the coastal hazards identified and the interaction with the type of use or development; including any subsequent use or development permitted as a result of the resource consent application or designation requirement. In exercising its powers on any subdivision consent, resource consent or building consent the Council shall take into account the information contained in the ASCH database. It may require further more detailed information, including the preparation of full Coastal Hazard Assessments as described in the Regional Coastal Environment Plan. It may require the effects of the hazard to be avoided, remedied or mitigated or decline the application. Comment The replacement rock revetment, the sand push ups, and the gabion basket are proposed to mitigate the effects of coastal erosion on the adjacent properties. As discussed above, the WBEMS was developed to provide for sustainable management of the entire beach system, and recommended different actions based on land use activities and levels of risk at various areas of the beach. Due to the extreme coastal erosion risk posed to the dwelling at 6 Tuahine Crescent, and high coastal erosion risk posed to the dwelling at 4 Tuahine Crescent, the replacement of the rail iron log and rock wall with a more robust structure was identified as the recommended action along the 40 m section of beach subject to this application (proper length of rock revetment is 40 m, it is noted that there is an additional return length of approximately 7 m to transition into existing bank and tie into existing rail iron structure at the northern terminus of the structure). Beach push ups were recommended along the entire length of Wainui Beach which provides increased upper beach

60 54 face and dune toe protection against storm erosion, and enhances public access and amenity. There is already development adjacent to the shoreline along Wainui Beach. The erosion protection works will not result in additional subdivision or development. On the basis of the above it is considered that the proposal is consistent with the objective and policy. Objective 4.3 (2) Protection of areas of significant indigenous vegetation, significant habitats and outstanding natural features and landscapes. Rock revetment As discussed in numerous areas of the report the Tuaheni Point outstanding natural landscape/feature identified by Boffa Miskell was delineated by the edge of the built development, therefore the intent of the landscape assessment undertaken by Boffa Miskell was to exclude the area subject to this application. Therefore the replacement of the rail iron log and rock wall with rock revetment will not affect the ONF. On the basis of the above it is considered that the proposal is consistent with the objective and policy. Sand push ups Areas of significant indigenous vegetation will not be affected by the works. On the basis of the above it is considered that the proposal is consistent with the objective and policy. Gabion basket Areas of significant indigenous vegetation will not be affected by the works. On the basis of the above it is considered that the proposal is consistent with the objective and policy. Objective 22.3 (2) Development and use of reserve land that does not create adverse effects on the reserve or surrounding environment. Policy 22.4 (1) To enable community wellbeing by making reserve land available in order to maintain and enhance: residential and district amenity; present and future recreation opportunity; public access; conservation and landscape values; and to maintain and protect the environmental, cultural, visual and/or historical significance of reserves. Policy 22.4 (2) Rock revetment The rock revetment will be partially located within reserve land (as shown on plan attached at Appendix C). Therefore a very small section of the reserve will be occupied by the replacement revetment, however tidally restricted pedestrian access along the beach will continue to be available, and the Tuahine Crescent beach access will be replaced as part of the works. The rock revetment has been designed with the steepest slope practicable to minimise the occupation area of the structure, and as abovementioned the Tuahine Crescent beach stair access will be replaced as a result of the works. In addition, the replacement of the existing rail iron log and rock wall with the rock revetment is likely to provide health and safety benefits as the exposed and rusting rail irons could cause health and safety issues to members of the public.

61 55 To ensure that the visual impact of reserve land and facilities maintains and enhances residential amenity and the natural value of the surrounding environment. Policy 22.4 (7) Particular attention should be given to the following matters when assessing applications for consents to conduct activities on reserves: the existing character and amenity of the reserve and the locality in which the site is set; the location and design (including colour) of any proposed structure on the reserve itself; access points onto the reserve; any historical, conservation, ecological, archaeological or waahi tapu values associated with the reserve; design and location in terms of enabling people to provide for their safety either at the reserve or on adjoining properties. The rock revetment will replace an existing rail iron log and rock wall, and, given its location at the base of the cliff, and the location of the residential environment within the backshore area, it is considered that the rock revetment will not adversely affect residential amenity. Overall, the rock revetment will be in keeping with the highly modified surrounding environment, and the existing character values and amenity of the reserve. As such, it is considered that the proposal is consistent with the objective and policies. Sand push ups The sand push up works represent a soft engineering approach compared to the use of a hard engineered structure, and will widen the upper beach following erosive periods, improving public access and amenity along the CMA. This will provide short-term protection against erosion, and enhance public open space and access following erosion events. As such, the reserve land along the upper beach will continue to be available following the sand push up works, with the resulting beach profile likely to generally mimic a beach profile which would result following accretion periods. The sand push ups will have positive amenity effects on the reserve land and the surrounding environment, as such, the proposal is considered to be consistent with the objective and policies. Gabion basket The reserve land adjacent to 21 Wairere Road comprises steep dune, and therefore is not currently used for recreational purposes or access. The reserve land is characterised by steep dune, where erosion protection structures have been constructed to the north and south of the gabion basket, and vegetation planted to help to stabilise the bank. The gabion basket structure visually changes the appearance of the reserve land, however is in keeping with the surrounding environment and the existing character and amenity of the reserve. As such, the gabion basket is considered to be consistent with the objective and policies Policy framework analysis conclusion The sand push ups and replacement of rail iron log and rock wall with rock revetment as recommended in the WBEMS are consistent with the objectives and policies in the NZCPS, Regional Policy Statement, Proposed Regional Coastal Environment Plan, and Combined Regional Land and District Plan. Further, when considered as a whole, the sand push ups and replacement of rail iron log and rock wall with rock revetment are supported by the objective and policy framework of the relevant planning documents.

62 56 The gabion basket structure is not contrary to the objectives and policies within the NZCPS, Regional Policy Statement, Proposed Regional Coastal Environment Plan, and Combined Regional Land Plan. It is therefore concluded that the application can satisfy the second limb of the Gateway Test. 6.5 Notification The applicant requests that the application is publicly notified.

63 57 7 Consultation The applicant has sent a copy of the application to Ngati Porou and Ngati Oneone, and requested that they provide any comments on the proposal that they consider necessary. The applicant received feedback from Ngati Oneone and no concerns were raised with the works proceeding. This correspondence has been attached at Appendix E. It is also noted that the WBEMS, which recommends sand push ups along Wainui Beach and replacement of the rail iron log and rock wall with a more robust structure was developed through a comprehensive stakeholder engagement process. Engagement was initiated through a stakeholder survey and a meeting to introduce the project, project scope and agree on the engagement and communication process. The meeting was open to the public and advertised widely. Stakeholders were also sent personal invites to promote their attendance. This public meeting resulted in the formation of a Key Stakeholder Forum (KSF) to bring together multiple stakeholder perspectives and work through issues. The KSF ultimately provided recommendations to Council on the content of this strategy. Working groups were also established to support the KSF and work through issues to provide recommendations to this forum. In summary, the WBEMS involved a comprehensive engagement process and the KSF incorporated the views of stakeholders and the community to develop and agree on recommended actions within the WBEMS. As such, significant consultation has already occurred, and helped to develop and agree the proposal encompassed by this application for resource consents.

64 58 8 Conclusion This AEE Report has been prepared on behalf of GDC to accompany a resource consent application to construct a rock revetment structure near the southern end of Wainui Beach and undertake sand push ups along the entire Wainui Beach. These were identified as key actions for GDC to implement in the WBEMS for managing coastal erosion, and in particular, to mitigate the effects of coastal erosion on the properties and dwellings along the coastal frontage. The dwelling at 6 Tuahine Crescent is located within the extreme risk erosion zone indicating that it is, or is likely to be subject to adverse effects from short-term duneline fluctuations and storm cuts. The dwelling at 4 Tuahine Crescent is located within the high risk erosion zone indicating that they have a high probability of being adversely affected at any time from the present to Consent is also sought to retrospectively approve the construction and use of a gabion basket which was constructed in front of 21 Wairere Road as emergency works. It is considered that any adverse effects of the replacement rock revetment and sand push ups are likely to be minor and/or similar to existing effects associated with the log wall. Following the replacement of the rail iron log and rock wall with rock revetment tidally restricted pedestrian access along the foreshore will continue to be available and the beach access steps from Tuahine Crescent will be reinstated. It is also noted that pedestrian access past the concrete groyne is also tidally restricted. The replacement rock revetment will be within a highly modified environment, and as discussed, will replace an existing structure. As such, the replacement revetment is not considered to materially change the overall impression of the site or wider coastline as it is in keeping with the existing coastal environment s character values. The application carries a non-complying status under the Combined Regional Land and District Plan and therefore is subject to the gateway test of s104d of the RMA. Overall it is considered that the proposal is consistent with the relevant objectives and policies in the Combined Regional Land and District Plan. Consequently, it is considered that the application can satisfy the second limb of the Gateway Test. Section 6 provides a detailed analysis of the proposal against the Combined Regional Land and District Plan, Proposed Regional Coastal Environment Plan, Regional Policy Statement, and higher order NZCPS. Ultimately, it is concluded the rock revetment and sand push ups is supported by the objectives and policies of these planning documents because: The principal driver of the proposal is to implement key actions recommended in the WBEMS and protect at risk properties from coastal erosion. The WBEMS has been developed and recommended actions agreed on in collaboration with stakeholders. As such the strategy represents a joint management approach and takes into consideration the different viewpoints within the community. The various plans directives around protecting natural character values are qualified to be in relation to inappropriate uses. The replacement of the rail iron log and rock wall with a more robust structure, as recommended in the WBEMS, constitutes an appropriate use. Specific policies within the NZCPS also lend support to the proposed erosion protection structure being considered appropriate because they are necessary to protect private assets and seek to sustain the potential of built physical resources to meet the reasonably foreseeable needs of future generations. The District Plan makes it clear that recreation and amenity values attached to the esplanade reserve should be maintained. The location of the replacement rock revetment is such that only a very small portion of the structure is within the reserve.

65 59 We note the following in terms of an overall comment around the context and timing of the proposed coastal erosion management solutions contained within this report. At present, tidal water comes into contact with the existing rail iron log and rock wall near the top of the tidal cycle when the beach profile is low and during storm events. As sea level rises, the frequency and duration of tidal water and wave energy acting on the toe of the existing structure will increase. Therefore, if the coastline is not adequately protected along Tuahine Crescent (existing rail iron log and rock wall structure is left as is, which is unlikely to last the lifetime of the consent, or is removed), and the shoreline, which is made up of soft sedimentary rock is left to erode, the dwellings located along the backshore may be undermined by coastal erosion. The property at 21 Wairere Road may also be subject to short term storm cuts, with the dwelling located within the moderate risk erosion zone. During major storms or erosion events the erosion scarp which fronts the property can be periodically reactivated which can cause a near vertical and very high erosion scarp to form, this can cause potential slips and damage to the property. It is considered that the sand push ups and rock revetment is consistent with the policy framework of all statutory planning documents, as well as all relevant matters contained within Part 2 of the RMA. Overall, the proposal is considered to achieve the sustainable management of natural and physical resources, which is the keystone of the RMA, and can therefore be granted consent.

66 60 9 Applicability This report has been prepared for the exclusive use of our client, with respect to the particular brief given to us and it may not be relied upon in other contexts or for any other purpose, or by any person other than our client, without our prior written agreement. Environmental and Engineering Consultants Report prepared by: Authorised for by: Tom Shand Senior Coastal Engineer Hayley Jones Richard Reinen-Hamill Resource Management Planner Project Director Report reviewed by:... Reuben Hansen Principal Environmental Planner 7-Jul-17 t:\auckland\projects\ \issueddocuments\ hmj.final.aee.docx

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